The city’s decision to do a full State Environmental Policy Act analysis of a proposed expansion of its bikesharing pilot program, which I reported earlier this week, was spurred in part by a request for a SEPA analysis by Elizabeth Campbell, a Magnolia activist with a long history of filing legal complaints against the city. Campbell sent a letter demanding a full SEPA review on August 6. Sometime that same month, SDOT decided to do the review—a process that likely added at least couple of months to the timeline for expanding bikeshare. SEPA reviews are typically performed for projects that exceed a certain threshold, in terms of their potential environmental impacts. Projects that are generally subject to SEPA review include things like new apartment buildings and projects that involve significant impacts on city rights-of-way. (To give just one point of comparison, new parking lots for fewer than 40 vehicles are categorically exempt from environmental review under SEPA. The bikeshare program does not include any new permanent structures in city right-of-way.)

The city’s experiment with free-floating bikesharing began in 2017, with a pilot program that allowed companies like Lime, Spin, and Ofo to disperse thousands of rental bikes around the city. The city approved new permanent rules for bike share companies in June, and three companies applied for permits—Uber, Lyft, and Lime. Both Uber and Lyft told me that they had expected to launch their bike share programs in September. However, the city still has not announced a date for the official expansion or granted permanent permits.

In her letter to the city, which was addressed to then-SDOT director Goran Sparrman and bikeshare program director Joel Miller and cc’d to Mayor Jenny Durkan, council member Mike O’Brien, and the heads of the city’s parks and neighborhoods departments, Campbell enumerates what she sees as the likely public costs associated with the program. Then she requests a SEPA analysis.

“The sheer number of pieces of business equipment that are to be unleashed upon Seattle’s streets, up to 24,000 bicycles and cycles, coupled with the fact that the majority of the bike-share business operators’ business equipment is to be placed, stored, and located by a number of means, including by mischief or abandonment, at any one time on the City of Seattle’s right-of-ways, parks, lands, public commons, and/or upon private property has immense environmental implications,” Campbell wrote. “At a minimum a SEPA checklist must be prepared and a threshold determination made before the Free-Floating Bike Share Program proceeds.”

The SEPA review wrapped up earlier this month.

Campbell says she asked for the review because she considers the bikes “litter” and believes they’re cluttering sidewalks like so much “trash on the streets.” SEPA seemed like an appropriate avenue, she says, because it pertains to business equipment. “I used to run a bakery,” she says. “What if I took all my bakery carts and set them out on the sidewalks [all over the city]? Realistically, it is that kind of a practice. It’s not the same as, say, a taxi business, where you’re going to take your taxis back to your garage” when they aren’t in use, she says.

I asked SDOT and the mayor’s office several times if a citizen complaint had influenced SDOT’s decision to delay the bikeshare program and go forward with a full environmental review. SDOT repeatedly denied there was any such complaint, saying that the city undertook the analysis in response to the results of two surveys (one by EMC Research conducted back in February, the other an unscientific online poll) and the gist of negative feedback from the public. “After continued conversations and community engagement around these concerns, the Department [moved] forward with SEPA in an effort to launch a formal program that not only enhances mobility, but also considers environmental impacts,” Hobson wrote. “I don’t know of any formal complaints.” Later, Hobson added that “the impetus for the SEPA review” was “the final evaluation that included the comments and concerns of community groups about safety.”

That final evaluation, which came out in August, is here. The complaints listed in the evaluation are mostly about bikes being left in places where they don’t belong, as well as the fact that many riders don’t wear helmets—not exactly the type of environmental impacts that the State Environmental Policy Act checklist is intended to address. The checklist, which is standard for all projects, includes questions about the impact a proposed project or development might have on erosion, air and water quality, native plants and animals, shorelines, and environmental health.

On Tuesday, I asked SDOT representatives again whether Campbell’s request was the reason, or a reason, for their decision to do a SEPA analysis. Initially, Hobson responded that this was “the first [she had] heard of” Campbell’s letter and request for SEPA analysis. Later, I heard back from another SDOT spokeswoman, Dawn Schellenberg, who said in an email, “After hearing some concerns, including written correspondence from Elizabeth Campbell … and wanting to do our due diligence, the department decided to complete a SEPA analysis and confirm there were no items of significance we needed to address.”

Conceivably, the city could have decided to do a full SEPA review back in August based solely on survey results and subsequent “concerns” expressed by many citizens, incidentally including Campbell. It’s also possible that there were other specific requests for a SEPA analysis. (I have a records request in to the mayor’s office and SDOT for all communications from the public that contain negative feedback on the program).

But it’s worth noting that Campbell isn’t just any random citizen: She’s a perennial thorn in the city’s side. Over the years, Campbell has filed many complaints against the city, including several that are still working their way through the legal process. For example, the city hearing examiner is currently considering complaints filed by Campbell about a tiny house village on Port of Seattle-owned property in Interbay and a proposal to build affordable housing at the Fort Lawton site near Discovery Park in Magnolia. Campbell, in other words, has been very effective in the past at delaying and deterring projects. This fact alone could give her complaints more weight at the city, which does not typically do full environmental reviews for projects with minimal impact on the natural or built environment, like the addition of a few thousand bikes throughout the city.

The SEPA review concluded with a determination of nonsignificance (DNS), meaning that expanding bikeshare has no significant negative environmental impact. Campbell, who says she was not aware that the city had decided to do a SEPA analysis, says she was disappointed to learn that the window for appealing the DNS closed on October 18; had she known, she says, she might have appealed. “They did a quick and dirty and they didn’t really address the things that I was talking about, which is that [the bikes] are disruptive,” Campbell says.

She says she’s still deciding whether to find another avenue to appeal the bikesharing program. “I’m kind of not known for letting things go,” she says.

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