1 2 3 4 5 6 IN THE SUPERIOR COURT OF WASHINGTON FOR KING COUNTY
7 8 9
ADAM JOHNSON, CARRIE REES JOHNSON, AND EMMETT JOHNSON, a minor child, (the family of Mattheis Johnson, deceased),
10 11 12
NO.
25-2-32127-4 SEA
AMENDED COMPLAINT FOR DECLARATION OF NUISANCE AND FOR ABATEMENT
Plaintiffs, v. CITY OF SEATTLE,
13
Defendant.
14 I.
15 16 17 18 19 20 21 22 23 24 25
INTRODUCTION
In the 1970s, the City transformed a toxic waste site into Gas Works Park. Today, the crackling towers represent a nuisance to our children, youth, and young adults. The edifice has claimed three lives in the past thirteen years and severely injured at least a dozen more. Two different departments within the City are currently warring with one another over whether the towers should be fixed for public safety reasons. The parks department says the work must be done to preserve public safety. The neighborhoods department says preserving history should trump all. This lawsuit is brought because the City created a nuisance that is unlike any other. There is no other City owned structure that has resulted in as many unintentional falls, injuries and deaths as the towers. And now, faced with the latest in a long line of tragedies, the City cannot put aside AMENDED COMPLAINT FOR DECLARATION OF NUISANCE AND FOR ABATEMENT - 1
STRITMATTER LAW 3600 15th Ave W, Ste. 300 Seattle, WA 98119 Tel: 206.448.1777
1 2 3 4
petty internal squabbling in order to abate the nuisance which it created. And which poses a continuing danger to our community.
5 6 7 8
II. 2.1
PARTIES
The Plaintiffs are Adam Johnson, Carrie Rees Johnson, and Emmett Johnson (a
minor child), the parents and younger brother of Mattheis Johnson who fell to his death at Gas Works Park.
9 10 11 12 13 14 15 16 17 18 Aug. 13, 2009 – July 10, 2025
19 20 21
2.2
under the laws of the State of Washington. III.
22 23 24 25
The Defendant City of Seattle is a municipal corporation incorporated as a city
3.1
JURISDICTION AND VENUE
Jurisdiction and venue are appropriate in this Court since the Plaintiffs are citizens
of Seattle residing in King County and Defendant owns and manages the nuisance property known as Gas Works Park situated within King County.
AMENDED COMPLAINT FOR DECLARATION OF NUISANCE AND FOR ABATEMENT - 2
STRITMATTER LAW 3600 15th Ave W, Ste. 300 Seattle, WA 98119 Tel: 206.448.1777
1 2 3 4 5
IV. 4.1
HISTORY OF GAS WORKS PARK
The site where Gas Works Park (GWP) rests, was constructed in 1907 and operated
until 1956.
6 7 8 9 10 11 12 13 14 15 16
4.2
The coal-based operation provided fuel for the City and heavily polluted the
17
environment. “It had char bubbling up; it had oil spills all over it.”1 Carcinogenic byproducts
18
from coal gasification leaked into the soil.2
19 20 21 22 23 24 25
1 See quotes from Thaisa Way, U of W Professor Emerita. Gas Works Park is a beautiful way to remember a toxic
past - Curbed Seattle 2See Amanda Wong, former federal manager in charge of proposing sites to the Superfund National Priorities list: A Toxic Mess: Seattle's Gas Works Park and the Politics of Environmental Cleanup - Terrain.org. AMENDED COMPLAINT FOR DECLARATION OF NUISANCE AND FOR ABATEMENT - 3 STRITMATTER LAW 3600 15th Ave W, Ste. 300 Seattle, WA 98119 Tel: 206.448.1777
1 2 3 4 5 6 7 8 9 10 11 12 13
4.3
In the 1970s, the City decided to make a park out of the abandoned plant.
4.4
Rich Haag was the architect of the park. In the Master Plan documents, he stated
14 15 16 17 18 19 20 21 22 23 24
that “[a]ll structures will be modified, etc. to meet applicable safety codes.”3
25 3 Exhibit 1: LPB101525GasWorksParkPPrev, infra.
AMENDED COMPLAINT FOR DECLARATION OF NUISANCE AND FOR ABATEMENT - 4
STRITMATTER LAW 3600 15th Ave W, Ste. 300 Seattle, WA 98119 Tel: 206.448.1777
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18
4.5
The most toxic materials were moved into a pile and capped with 18 inches of clay.
Today that spot is known as Kite Hill.4 4.5
The site was originally to be named Myrtle Edwards Park, but her family objected
to the preservation of the old coal gas refinery.5 4.6
GWP was fully opened to the public in 1976. That same year a child fell off one
of the towers. He suffered a fractured arm.6 4.7
The centerpiece of the park – are its “five-story high cracking towers and other
structures from the smoke-belching days of industrial use.” 7 4.8
Cracking is a method where heat, pressure and catalysts “crack” heavy molecules
into lighter ones.8 4.9
After purchasing the property from Washington Natural Gas in the 1960s, the area
was “discovered to be an ecological disaster. The soil was inorganic, extremely compacted, and severely chemically polluted. It could not support life.9 4.10
The contamination at GWP has since been the subject of 50 more years and
hundreds of millions of dollars in cleanup with much left to be done.10 Longstanding work which is to begin in 2027 is budgeted at $80 million.
19 20 21 22 23 24 25
4 Gas Works Park is a beautiful way to remember a toxic past - Curbed Seattle 5 Edwards, Myrtle (1894-1969) - HistoryLink.org 6 Gas Works Park is a beautiful way to remember a toxic past - Curbed Seattle 7 Gas Works Park opens in Seattle's Wallingford neighborhood in 1974. - HistoryLink.org 8 Refining crude oil - the refining process - U.S. Energy Information Administration (EIA) 9 Gas Works Park opens in Seattle's Wallingford neighborhood in 1974. - HistoryLink.org 10 https://ecology.wa.gov/blog/june-2023/cleaning-up-cleanup-of-shoreline-and-sediment-moving-forward-for-
seattle-s-gas-works-park AMENDED COMPLAINT FOR DECLARATION OF NUISANCE AND FOR ABATEMENT - 5
STRITMATTER LAW 3600 15th Ave W, Ste. 300 Seattle, WA 98119 Tel: 206.448.1777
1 2 3 4 5 6 7 8 9 10 11 12 13
4.11
Access to adjacent Lake Union is restricted as the sediment contains hazardous
substances. No boating, wading, or swimming is allowed.11
14 15 16 17 18 19 20 21 22
4.12
The City has known since the first year that GWP opened, that the ladders, catwalks
23
and platforms on the cracking towers structure (towers) are climbed by children, teens, and young
24
adults, many of whom have fallen.
25 11 Gas Works Park - Parks | seattle.gov
AMENDED COMPLAINT FOR DECLARATION OF NUISANCE AND FOR ABATEMENT - 6
STRITMATTER LAW 3600 15th Ave W, Ste. 300 Seattle, WA 98119 Tel: 206.448.1777
1 2 3 4
4.13
The City is aware that the prospect of climbing the towers is attractive to young
children, teens and young adults. This photo was taken July 2025.
5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25
V. 5.1
THE CITY’S NOTICE AND FAILURE TO CURE
Since 2008, fifteen (15) reported fall incidents have occurred – 14 of which were
responded to by the Seattle Fire Department per their records as follows: 2008
Injuries
2009
Life threatening injuries
2012
Dead
2012
Multiple fractures
2013
Head and liver life threatening injuries
2014
Multiple fractures
2015
Head and internal life-threatening injuries
2016
Multiple fractures
2019
Significant injuries
2022
Dead
2023
Brain injured
2024
Significant injuries
2025
Dead
AMENDED COMPLAINT FOR DECLARATION OF NUISANCE AND FOR ABATEMENT - 7
STRITMATTER LAW 3600 15th Ave W, Ste. 300 Seattle, WA 98119 Tel: 206.448.1777
1 2 3 4 5
5.2
In 2012 Luke Voss had just graduated high school and was on a visit to Seattle with
friends before heading off to college.
6 7 8 9 10 11 12 13
5.3
Luke had spent considerable time in other countries including Haiti and Kenya.
5.4
Following his death, his parents established a non-profit to give back to children
14 15 16 17 18 19 20 21 22 23 24
living in poverty. www.lukeslights.org.
25 AMENDED COMPLAINT FOR DECLARATION OF NUISANCE AND FOR ABATEMENT - 8
STRITMATTER LAW 3600 15th Ave W, Ste. 300 Seattle, WA 98119 Tel: 206.448.1777
1 2 3 4 5 6 7 8 9 10 11 5.15
In 2015, the City determined that some of the stairs and landings at GWP should
12 be removed to deter climbing of the south towers. The City back tracked on this plan, limiting the 13
scope of the fix to “focused removals of obvious access points.”12
14 5.16 15
Between 2019 – 2023, the City performed “selective removal of climbable
features” and undertook “limited alterations to Towers 1&2 to deter climbing.13
16 5.17
In 2022, Zoe Jelnik had graduated with honors from Bishop Blanchet High School.
17 18 19 20 21 22 23 24 25 12 Exhibit 2:
LPB091725GasWorksParkBPrev – prepared in 2025 by the City of Seattle Parks Department.
13 Id.
AMENDED COMPLAINT FOR DECLARATION OF NUISANCE AND FOR ABATEMENT - 9
STRITMATTER LAW 3600 15th Ave W, Ste. 300 Seattle, WA 98119 Tel: 206.448.1777
1 2 3 4
5.18
Zoe was born and raised in Seattle. She and her brother were avid lacrosse players.
5.19
During covid, she took a gap year to teach children in Zambia. Zoe’s dream was
5 6 7 8 9 10 11 12 13 14 15
to one day open an educational resource center in Africa.
16 17 18 19 20 21 22 23 24 25 AMENDED COMPLAINT FOR DECLARATION OF NUISANCE AND FOR ABATEMENT - 10
STRITMATTER LAW 3600 15th Ave W, Ste. 300 Seattle, WA 98119 Tel: 206.448.1777
1 2 3 4 5 6 7 8 9 10 11 12 13 14 5.20
15
Zoe had just returned and was preparing to head off to UW Bothell. Instead she
16
fell off the towers and was killed. “Following her death, her family established a nonprofit to
17
support schools and students in southern Africa. www.zoejmf.org 5.21
18
In 2023, the City hired All City Fence to restore the chain-link fence surrounding
19
the towers. The City also hired a contractor to remove vegetation and trees growing around and
20
amongst the towers.14
21
5.22
The fence does not enclose the entirety of the towers structure.15
22 23 24 25 14 Id. 15 Id.
AMENDED COMPLAINT FOR DECLARATION OF NUISANCE AND FOR ABATEMENT - 11
STRITMATTER LAW 3600 15th Ave W, Ste. 300 Seattle, WA 98119 Tel: 206.448.1777
1 2 3 4 5 6 7 8 9 10 11 12 5.23
13 14
Part of the structure goes over the top of the fence.16 and “continues to present a
potential safety hazard.”17
15 16 17 18 19 20 21 22 23 24 25 16 Id. 17 Exhibit 1: LPB101525GasWorksParkPPrev at p. 9
AMENDED COMPLAINT FOR DECLARATION OF NUISANCE AND FOR ABATEMENT - 12
STRITMATTER LAW 3600 15th Ave W, Ste. 300 Seattle, WA 98119 Tel: 206.448.1777
1 2 3 4
5.24
The structure is usually adorned with graffiti – providing further notice to the City
that the structure is accessible.18
5 6 7 8 9 10 11 12 13 14 15 16
5.25
In 2025, Mattheis Johnson was a student at Ballard High School
17 18 19 20 21 22 23 24 25 18 Exhibit 2.
AMENDED COMPLAINT FOR DECLARATION OF NUISANCE AND FOR ABATEMENT - 13
STRITMATTER LAW 3600 15th Ave W, Ste. 300 Seattle, WA 98119 Tel: 206.448.1777
1 2 3 4 5
5.26
He sang, produced his own music on Spotify, loved deep conversations, fashion,
ran track, and played ultimate frisbee for his school.
6 7 8 9 10 11 12 13 14 15 16
5.27
Mattheis had many friends and was never afraid to show a sweet, open-hearted love
for his mom—even in public.
17 18 19 20 21 22 23 24 25 AMENDED COMPLAINT FOR DECLARATION OF NUISANCE AND FOR ABATEMENT - 14
STRITMATTER LAW 3600 15th Ave W, Ste. 300 Seattle, WA 98119 Tel: 206.448.1777
1 2 3
5.28
He was often seen walking his dog with his dad and younger brother.
5.29
Mattheis was enjoying summer with his friends before returning for his junior year.
4 5 6 7 8 9 10 11 12 13 14 15
Instead, he fell off the towers and was killed.
16
VI.
CITY HALTS ITS EMERGENCY SELECTIVE DECONSTRUCTION
17
6.1
Following Mattheis’ death, the Department of City Parks & Recreation determined
18
that the towers should undergo emergency selective deconstruction.19 6.2
19 20
It noted: “Public safety is paramount, and we will not save anything that could
compromise public safety.”20 6.3
21
The City’s intent was to: “Specifically remove “Pedestrian Appurtenances” that are designed to convey human beings vertically and horizontally along the towers, designed for the purposes of maintaining, servicing and operating the former gas works facility. The working assumption is that these appurtenances provide platforms and access for graffiti and have been accessed by trespassers to climb the towers, notwithstanding fencing and signage. Falls have occurred resulting in serious injury and death.
22 23 24 25 19 Id.
20 Exhibit 1: LPB100125GasWorksParkPPrev.
From David Graves, AICP Strategic Advisor, at p. 9. AMENDED COMPLAINT FOR DECLARATION OF NUISANCE AND FOR ABATEMENT - 15
STRITMATTER LAW 3600 15th Ave W, Ste. 300 Seattle, WA 98119 Tel: 206.448.1777
1 2 3
Removing the appurtenances will eliminate them as a means of access, promoting public health and safety.”21
4 6.4
5
The City worked with Osborn Architects, Inc. and Ryan Hunter, a hazmat
6
consultant, to create this plan, due to lead paint, contaminated soils, and remnants of hydrocarbons
7
in the tanks and piping.22
8
6.5
The scope of work involved selective removal of piping, catwalks, ladders and
9
support systems.23
10 11 12 13 14 15 16 17 18 19 20 21 6.6
22 23
In its emergency plan, the City provided detailed renderings of which climbing
related appurtenances were to be removed.
24 25
21 Exhibit 1 at p. 1. 22 Exhibit 2. 23 Id.
AMENDED COMPLAINT FOR DECLARATION OF NUISANCE AND FOR ABATEMENT - 16
STRITMATTER LAW 3600 15th Ave W, Ste. 300 Seattle, WA 98119 Tel: 206.448.1777
1 2 3 4 5 6 7 8 9 10 11
6.7
The City’s renderings illustrated that despite removal of the appurtenances, GWP
would still be preserved as an iconic landmark.
12 13 14 15 16 17 18 19 20
6.8
The City notes: “The Towers are of a scale and form easily perceived from any
21
location around Lake Union and the contrast of these monolithic forms superimposed on the city
22
skyline is unique and visually exciting. These tank/tower silhouettes will be simplified by the
23
select removal of built elements, but the overall monolithic forms and grand scale identified in the
24
Report on Designation will remain intact.”24
25 24 Exhibit 3:
LPB100125GasWorksParkSRev. C of A staff report. AMENDED COMPLAINT FOR DECLARATION OF NUISANCE AND FOR ABATEMENT - 17
STRITMATTER LAW 3600 15th Ave W, Ste. 300 Seattle, WA 98119 Tel: 206.448.1777
1 2 3 4 5
6.9
towers were always the distinguishing feature – there was no reference to the appurtenances which were not shown on the plans.25
6 7
The City maintains that the National register nomination notes the gas processing
6.10
Richard Haag’s drawings provided to the National Register only show the large
structures.26
8 9 10 11 12 13 14 15 16 17 18 19 20
6.11
protect the ongoing risk to public safety posed by GWP.
21 22
The City has determined that emergency selection for deconstruction must occur to
6.12
The City has not commenced emergency selection for deconstruction to protect the
ongoing risk to public safety posed by GWP.
23 24 25 25 Exhibit 1.
Parks & Recreation memo to Landmarks Preservation October 9, 2025.
26 Id.
AMENDED COMPLAINT FOR DECLARATION OF NUISANCE AND FOR ABATEMENT - 18
STRITMATTER LAW 3600 15th Ave W, Ste. 300 Seattle, WA 98119 Tel: 206.448.1777
1 2 3 4 5 6 7 8 9 10 11 12 13
VII. 7.1
CAUSES OF ACTION
The factual allegations of paragraphs 1 through 6 are realleged and incorporated by
reference. 7.2.
The City has had knowledge of the nuisance at GWP and the dangers it poses to the
public since the inception of fully opening the park to the public in 1976. 7.3
The City has had notice of the nuisance at GWP and the dangers it poses to the
public since the inception of fully opening the park to the public in 1976. 7.4
The City has had recent notice of the nuisance at GWP and the dangers it poses to
the public, each time it has responded to accidental falls by children, youth and young adults from 2008 to the present time including but not limited to:
14
2008
Injuries
15
2009
Life threatening injuries
16
2012
Dead
2012
Multiple fractures
2013
Head and liver life threatening injuries
18
2014
Multiple fractures
19
2015
Head and internal life-threatening injuries
2016
Multiple fractures
2019
Significant injuries
21
2022
Dead
22
2023
Brain injured
2024
Significant injuries
2025
Dead
17
20
23 24 25
7.5
The City has determined that it can eliminate the risk to the public posed by the
nuisance towers at GWP without compromising the historic properties of the towers. AMENDED COMPLAINT FOR DECLARATION OF NUISANCE AND FOR ABATEMENT - 19
STRITMATTER LAW 3600 15th Ave W, Ste. 300 Seattle, WA 98119 Tel: 206.448.1777
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19
7.6
The City has, on an emergency basis, designated but has failed to use the funds
needed to eliminate the risk to the public posed by the nuisance towers at GWP. 7.7
The City has determined that the nuisance towers at GWP present a risk of danger
to the public but has failed to take available action to eliminate the risk. 7.8
The City has failed to make reasonable efforts to abate the nuisance.
7.9
A lawsuit can be brought to abate the nuisance of GWP which provides that if the
existence of a nuisance is established in an action, an order of abatement shall be entered. VIII. PRAYER FOR RELIEF Because the City refuses to move forward with its own already funded emergency plan to protect public safety by removing pedestrian appurtenances from the nuisance towers at GWP, the Plaintiffs mother, father and younger brother of Mattheis Johnson, pray for the following: 1. Declaratory Judgment that the crackling towers and their pedestrian appurtenances at GWP are a nuisance. 2. Entry of an order of abatement. 3. For a public apology from the City to Plaintiffs. 4. For such other and further relief as the Court deems just and appropriate. DATED THIS 30th day of October, 2025.
20
STRITMATTER LAW
21
/s/ Karen Koehler Karen Koehler, WSBA#15325 Mo Hamoudi, WSBA#48512 Pro Bono Counsel for Plaintiffs
22 23 24 25 AMENDED COMPLAINT FOR DECLARATION OF NUISANCE AND FOR ABATEMENT - 20
STRITMATTER LAW 3600 15th Ave W, Ste. 300 Seattle, WA 98119 Tel: 206.448.1777
1 2 3 4
CERTIFICATE OF SERVICE
5 6
I hereby certify that on October 30, 2025, I delivered a copy of the document to which this certification is attached for delivery to all counsel of record as follows:
7 8 9
Defendant City of Seattle CityClerkFiling@seattle.gov
10 11
U.S. Mail Fax Legal messenger Electronic Delivery (via King Co/ECF Efiling/email delivery)
12 13 _________________________________
14
Kristin Michaud, Paralegal
15 16 17 18 19 20 21 22 23 24 25 AMENDED COMPLAINT FOR DECLARATION OF NUISANCE AND FOR ABATEMENT - 21
STRITMATTER LAW 3600 15th Ave W, Ste. 300 Seattle, WA 98119 Tel: 206.448.1777
Exhibit 1
~1~ Seattle
\ii ~ Parks & Recreation
Date:
October 9, 2025
To:
City of Seattle Landmarks Preservation Board
CC:
From: Subject:
Gas Works Park Cracking Towers - Pedestrian Appurtenance Removal Certificate of Approval Application
As follow-up to the Landmarks Preservation Board discussion on October 1"', Seattle Parks and Recreation (SPR) is providing the following. SPR's intention is to: •
Specifically remove "Pedestrian Appurtenances"that are designed to convey human beings vertically and horizontally along the towers, designed for the purposes of maintaining/servicing and operating the former gas works facility. The working assumption is that these appurtenances provide platforms and access for graffiti and have been accessed by trespassers to climb the towers, notwithstanding fencing and sign age. Falls have occurred resulting in serious injury and death. Removing the appurtenances will eliminate them as a means of access, promoting public health and safety.
Included below are excerpts from the Landmarks and National Register nominations, the original Myrtle Edwards, now Gas Works Park Master Plan documents and Rich Haag's original design drawings for the park. Taken together all of the references and plans show Rich Haag's intention to retain the towers, given their visibility and monolithic nature. The National Register nomination notes that the " [g]as processing towers were always the distinguishing features of the gas works ...." There is no reference to the pedestrian appurtenances, and they are not shown on the plans. Note also Rich Haag's statement in the Master Plan that "[a]ll structures will be modified, etc. to meet applicable safety codes." SPR specifically points out that: •
The design intent, as conveyed in the following drawing excerpts and document citations, was to allow the volumes of the towers/tanks to remain . This did not necessarily include all the attachments/ pedestrian appurtenances. The Master Plan specifically references the monolithic nature of the towers which is what SPR is trying to maintain by preserving the towers and proposing to remove only the pedestrian related appurtenances .
•
This facility is not structurally sound which is why public access is precluded and the area fenced . The design intent was to allow the structures to deteriorate into the environment. There is no long-term management/conservation plan for the towers and no identified budget to maintain the structural integrity of the structures.
•
While in 2002, the Friends of Gas Works Park funded an analysis of the south towers which found that the Towers themselves were sound, the information noted issues and potential safety hazards associated with the ladders, catwalks and piping. That analysis is now almost twenty-five years old. The structures and particularly their appurtenances are likely beyond repair. A structural analysis would require a visual inspection/site verification of each element, assessment of any associated footings and there is no reliable information on any of the appurtenances. This analysis would be extremely expensive and cost prohibitive.
From the Landmarks nomination (p.6): (2) . Identifiable Visual Feature Gas Works Park and its Towers are ofa scale and form easily perceived from any location around Lake Union. The park is a tangible, highly visible piece of Seattle' s early history and of industrial revolution era technology. The Towers are a gothic sculptural presence and the contrast of these monolithic forms superimposed on the city skyli ne is unique and visually exciting. The experience is further enhanced by changes in perspective gained by moving around and through these forms of another era. " The black shapes of the towers on their grassy point leap out with startling clarity against the bright collage of the shoreline, silhouettes that might be the pictogram for the works of industrial man." (Landscape Australia, February 1980) Gas Works Park Landmarks Nomination
Page 7
From the National Register Nomination: The groups of gas processing towers were always the distinguishing feature of the gas works; through their retention the present Gas Works Park retains the feeling of an industrial complex. The major structures removed in the design of the Park include the large oil tanks and city gas holders, all located to the west and north of the Towers. From Rich Haag's Myrtle Edwards (now Gas Works) Park Master Plan :
Of the 5% of s ite stru ctu r es to be r etained, (see D-5) about one-half will be r econditioned In initial park deve lopment . The re maining
I
half, mainly the gene rator towe rs , will be
preserved and restricted from publi c co ntact by a s hallow wa te r moat until spe cific programs
are designated.
New structures will be pro-
vided Ln t·esponsc to comm unity prio rities and budget considerations . New structures to be
Included in lnitial deve lo pme nt will be wooden sta lls in an open air market/ concess ion area. All s tructures w ill be modifi ed , etc. to meet applicable safety codes .
2( Page
Portion of Rich Haag's 1975 Site Plan showing the Towers and surrounding area :
Landmarks Nomination package; Rich Haag's drawing showing structures to be preserved:
~ ~ Fig,.n5:
31 Page
Pllinshowingprcsel\ledttrue1urw1thadedinbiackandnamesofpafk•~H.
Landmarks Nomination package; Rich Haag's drawing showing preserved structures :
Figure 6:
Plan showing topography of the pa111. site and preserved structures.
Conclusion SPR's plan to remove only the pedestrian appurtenances, and the one pipe that extends beyond the fence, is in keeping with Rich Haag's vision to preserve the towers as the monolithic representation of the historic gas works. SPR is proposing to remove elements from the towers consistent with Rich's acknowledgement that structures would be modified for public safety. In summary, SPR is proposing to: 1) Remove all pedestrian appurtenances and one pipe that extends beyond the fence; SPR will attempt to save appurtenances on the uppermost level of the towers and portion(s) of the pipe, if possible. A final determination will be made in the field based on the actual condition and stability of the appurtenances and pipe segment(s). 2) Compile photo-document the towers with the pedestrian appurtenances in place. 3) Once the appurtenances have been removed, repaint the towers and paint the shadow lines of the catwalks and ladders as a reference to the elements that have been removed. 4) Continue to monitor the site for evidence of access and graffiti.
41 Page
5) Lighting to highlight the towers and further discourage access and security camera(s) to monitor the site and track access attempt(s) will be installed once the appurtenances have been removed under a separate Certificate of Approval request.
51 Page
Gas Works Park - Cracking Towers Landmarks Preservation Board David Graves, Strategic Advisor I October 15, 2025
~1~ Seattle
'di ~ Parks & Recreation Healthy People, Thriving Environment, Vibrant Community
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Introduction 1) Vision is to further public safety by removing the pedestrian appurtenances which have been accessed by trespassers, unlawfully climbing the structures. The unlawful climbing of the towers has caused and enabled significant ongoing graffiti on those structures and has resulted in three fatalities and multiple injuries. 2) Original intent of design documentation was/is to preserve the monolithic nature and silhouettes of the towers. Pedestrian appurtenances blur the silhouettes of the towers and go beyond preservation of the towers. 3) Management plan - inherent in the design intent. These are outdoor steel elements that are corroding and degrading over time. There is no management/maintenance plan beyond preservation of the actual towers. 3
#SeattleSh ines
Historical References From the Landmarks nomination (p.6):
(2). Identifiable Visual Feature Gas Works Park and its Towers arc ofa scale and fonn easily perceived from any location
around Lake Union. The park is a tangible, highly visible piece ofSeaule's early history and of industrial revolution era technology. The Towers are a gothic sculptural presence
and the contrast of these monolithic fonns superimposed on the city sl-ylinc is unique and visually exciting. The e.,pericnce is further enhanced by changes in perspective gained by moving around and through these forms of another era. "The black shapes of the towers on their grassy point leap out with startling clarity against the bright collage of the shoreline, silhouettes that might be the pictogram for the works ofindus1rial man " (Landscape Australia, February I 980) Gas Works Park Landm3rks Nomination
Page 7
From the National Register Nomi nation: The groups of gas process!ng towers were always the distingufshlng feature of the gas "WOrks; through their relenlion the present Gas Wotks Pant retains the feeling of an Industrial complex. The major structures removed In the design of the Pari< Include tho large oil tanks and city gas holders, all located to the west and north of tho TO'Ners.
From Rich Haag's Myrtle Edwards (now Gas Works) Park Master Plan:
~~~_ct_ures:
or the 5% of site structures to be retained, (sec D-5) about ono-baH will be reconditioned lo initial park devel opment. The remaining half, mainly the generator I.Owers, will be preserved and restricted Crom public contact by a shallow water moat unti l speclrlc programs a.re designated. New tstructures will be provided lo response to community priorities nnd budget considerations. New structures to be Included In lnillal development will be wooden sta l ls lo an open alt' market/ concessio n area. All .-structures wlll be modified , etc. to meet
I
applicable sa fely codes.
4
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SPR Proposed Removals oa.JECTSDIPI..AYED .. OMAHQECOULD
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REFERENCE ONLY. SCOPE OF WORK HAS CHANGED AND IS REFLECTED BELOW IN DRAWING SET.
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Summary Proposal 1) Remove all pedestrian appurtenances and one pipe that extends beyond the fence; SPR will attempt to save appurtenances on the uppermost level of the towers and portion(s) of the pipe, if possible. A final determination will be made in the field based on the actual condition and stability of the appurtenances and pipe segment(s). 2) Compile photo-document the towers with the pedestrian appurtenances in place. 3) Once the appurtenances have been removed, repaint the towers and paint the shadow lines of the catwalks and ladders as a reference to the elements that have been removed . 4) Continue to monitor the site for evidence of access and graffiti. 5)
Lighting to highlight the towers and further discourage access and security camera(s) to monitor the site and track access attempt(s) will be installed once the appurtenances have been removed under a separate Certificate of Approval request.
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Seattle Parks & Recreation Data:
September24,2025
To:
City of Seattle Landmarks Preservation Board
rl ogram Staff
CC:
Erin Doherty, Landmarks Preservation
From:
David Graves, AICP, Strategic Adv_!.!!!
Subject:
Gas Works Park Cracking Towers-Ped Certificate of Approval AppUcation
In response to questions from the Landmarks Preservation Board at a briefing on September 17'", Seattle Parks and Recreation (SPR) is providing the following information. I've included Board questions, as I heard them and after consulting with Erin Doherty, and SPR's response. •
Hos a condition survey been conducted of the steel elements that ore proposed for removal? No
formal survey has been done but we have done visual assessments. The steel elements are difficult to assess for a number of reasons; the steel is painted so it is difficult to undertake a complete assessment; the consultants we are working with feel that it is too risky to get on the towers to undertake any assessment; there is significant evidence of deterioration including oxidation on steel elements, pieces of the pedestrian access elements on the ground that have fallen off the towers is evidence offailure; the gas plant ceased operations in the mid-1950s which make the towers at least 70+ years old towers, lack of use, limited ongoing maintenance and continued exposure to the elements for seventy plus years has likely left the exposed pedestrian elements in varying states of stability. •
Would it be possible to leave more of the built features near the top of the tonks?Yes; additional
response is provided below •
Could the work crew start selective removal from the bottom ond make o determination to leave certain elements intact as they worked their way up? Work will likely start from the top because
the upper features are supported by lower elements which extend down to the ground. It may be possible to retain upper appurtenances that don't provide access to the towers. As an example, the upper segments of ladder cage(s) could be retained so long as the actual ladders are removed. SPR would commit to consider saving elements; actual elements saved would have to be field verified during the demolition based on the condition of element(s) to be retained and is ability to remain self-supporting without becoming a safety hazard to SPR staff as they continue to maintain the grounds around the towers. Public safety is paramount, and we will not save anything that could compromise public safety. •
Is it possible to reconfigure the perimeter fence to enclose the elevated pipe on the west side, rather than remove it? We could expand the fence to include the pipe, but that removes open
space and adds more fencing around the towers which would end up blocking views of that pipe. Due to the similarity of heights, that pipe would not be visible if the fence is extended around it and the pipe remains a potential safety hazard to SPR crews doing maintenance inside the fence. If left in place, the pipe continues to present a potential safety hazard. It could be extremely
compromised from the inside with no visible evidence on the exterior. Another option would be to remove the middle section of the pipe between the yellow bars on the following graphic. SPR could commit to saving portions of the pipe that are within the Cracking Tower fence, pending field verification by SPR's Consultant, staff and selected contractor that the remnants and supports are safe and structurally sound and don't contain any hazardous materials.
REFERENCE ONLY. SCOPE OF WORK HAS CHANGED AND IS REFLECTED BELOW IN DRAWING SET.
•
Hos SPR spoken with SPD about ways to address the issues? SPR has had discussions with SPD
about the cracking towers. Those discussions are part of the rationale for the ongoing vegetation management inside the fence. SPR staff keeps the grass mowed and invasive species under control to keep sight lines open to the towers. SPR hires contractor(s) to remove vegetation and trees that grow up under and through the towers; SPR staff won't work under the towers due to safety concerns. SPD does drive through the park on occasion and keeping the vegetation down enables better visual access. •
Con SPR clarify a potential timeline for implementing Richard Haag's vision to hove no fence around the crocking towers? SPR does not have a timeline for removal of the fence and allowing
public access to the area around the towers; SPR currently has no budget identified to do any work associated with the towers beyond the proposed removal and subsequent lighting. The broader City focus is finalizing the design of the sediment remedy and implementing the remediation project in partnership with Puget Sound Energy (PSE). PSE owns the majority share of the liability, but the City's share is not insignificant; total project costs are currently estimated to be $60-S0M.
GWP Cracking Towers- SPR Response September 24, 2025
Page 2
•
The following graphic provides details on the ages of the Cracking Towers.
GWP Cracking Towers- SPR Response September 24, 2025
Page3
Gas Works Park- Cracking Tower Work/Repairs September 9, 2025
Introduction As requested by Landmarks Board staff, below is a brief overview describing work by SPR on the fence surrounding the Cracking Towers at Gas Works Park and other actions to deter climbing of the towers. This is cursory and not intended to be a thorough history of the site. The timelines are approximate and based off memory. Background The fence around the Cracking Towers is considered an Institutional Control as part of the Consent Decree for the upland cleanup work and maintenance and improvement, if necessary, of the fence is required. Pursuant to the Consent Decree, Seattle Parks & Recreation (SPR) Staff inspect the soil cover and fence on a regular (approximately weekly) basis, needed repairs are typically handled through SPR's work order system, minor work that can be done by the grounds crew in the regular course of their activities at the park may not generate a work order. In addition, the Northeast District maintenance staff are at the park on a daily basis and also call-in work orders if they see issues with the fence or gates. Timeline (approximate) June 26, 2015- Landmarks Preservation Board (LPBJ-Architectural Review Committee (ARC) briefing to discuss removing some or all of the stairs and landings to deter climbing of the south towers. ARC suggested starting with more focused removals of obvious access points. 2016 - SPR hires PSM Consulting Engineers to undertake a Climbing and Safety Evaluation of Towers 1 & 2 (southerly large towers). August 7, 2019- LPB issues Certificate of Approval (CoA) to allow SPR to perform selective removal of climbable features and undertake limited alterations to Towers 1 & 2 to deter climbing. 2019-2023- SPR Metal Shop Crew undertakes approved work on Towers 1 & 2. Ongoing repairs were also being made to the fence and gates intermittently, as it was cut or otherwise manipulated/vandalized, ostensibly to gain access into the restricted area.
2023-SPR hired All City Fence to do a complete restoration of the chain-link fence, restore the barbed wire on top of the fence, add steel mesh panels over the chain-link and reconstruct the gates with the steel mesh to resist cutting and strengthen the gates. 2023-SPR hired a landscape contractor to remove all vegetation and trees that were growing around and amongst the towers to make the area more open and remove potential access point(s) to the towers. Note that SPR crews have been and continue to remove blackberries and mow the lawn areas around the towers within the Cracking Tower fenced area. They generally avoid working directly under the towers due to safety concerns/potential falling metal.
2024-A leaning support element within the Cracking Tower area, between the North and South Towers, was removed with a CoA from LPB issued on June 26, 2024 2023-2025- SPR facilities continues to address access points; 3 of the 4 gates have been welded shut; area(s) under the gates have been paved to strengthen the gates and limit the possibility of digging under a gate.
Incidents The following is a list of incidents at the Cracking Towers since 2008. This list is based on aid calls that Seattle Fire Department (SFD) responded to and has been provided by SFD:
Date and Time
Victim Details
Description
Outcome
10/11/2008
Male, age22
Climbed fenced-off structure; catwalk gave way, fell onto another catwalk.
Non-life-threatening {possible dislocated shoulder)
Female (age25)
Fell off structure.
Life-threatening injuries; survived
Male, age 19
Fell off towers. Was visiting Seattle from Massachusetts.
Death
Male
Fell off structure; unconscious with liver and head injuries.
Life-threatening injuries; survived
Fell 35 feet while writing graffiti.
Multiple broken bones; survived
0400 hours 12/13/2009 0023 hours 5/25/2012
0010 hours 3/29/2013
0517 hours
(age 19)
7/19/2014
Female, 19
0322 hours
Date and Time
Victim Details
Description
Outcome
1/25/2015
Male
Fell off structure.
0033 hours 2/1/2015 2210 hours 12/11/2016
Life-threatening head and internal injuries; survived
Male (age 19) Male
Fell off structure but remained conscious.
Injuries; transported to HMC
Fell off structure while intoxicated after he missed a hole in catwalk; rescued by SFD. Climbed while intoxicated; fell.
Open femur fracture, possible pelvic fracture, etc.; survived
Fell off structure; rescued by SFD.
Broken leg, head laceration; survived
Fell through an opening in the walkway while climbing with friends on the south towers. They had all been drinking.
Death
(age 21)
2213 hours
(age23J
1/1/2019 2213 hours 2/21/2022 0117 hours 9/17/2022
Male (age40J Male (age26) Female
0242 hours
(age20) Only known female victim.
11/23/2023 0030 hours
Male (age 16)
Fell off refinery; unconscious, no pulse.
Survived with brain damage.
3/29/2024 2318 hours 7/10/2025
Male (age 19) Male
Fell 60 feet; walking and talking.
Injuries; treated at HMC
Fell off towers after a classical music concert in the park.
Death
2230 hours
(age 15)
Significant injuries; survived
Gas Works Park Cracking Towers Tower Photographs David Graves, Strategic Advisor
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OWNER SEATTLE PARKS AND RECREATIONS 100 DEXTER AVE N, SEATTLE, WA, 98109 CONTACT: MIKE SCHWINDELLER PHONE: 206.615.1165 EMAIL: MI KE.SCHWI NDELLER@SEATTLE.GOV
ARCHITECT OSBORN ARCHITECTS INC., PS (OAI) 1001 SW KLICKITAT WAY, STE 204 SEATTLE, WA 98134 CONTACT: JERRY OSBORN PHONE: 206.920.6348 EMAIL: JOSBORN@OAIPS.COM HAZMAT CONSULTANT CONTACT: RYAN HUNTER PHONE: 484.269.2138 EMAIL: RYAN.HUNTER@PBSUSA.COM SITE INFORMATION
SELECTIVE REMOVAL OF PIPI~ LADDERS AND SUPPORT SYSl STRUCTURES LOCATED WITHI EMERGENCY SECURITY LIGHT
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COVER SHEET DECONSTRUCTION Pl SELECTIVE DECONST WEST DECONSTRUCl NORTH DECONSTRUC SOUTH DECONSTRUC EAST DECONSTRUCT POST DECONSTRUCT POST DECONSTRUCT POST DECONSTRUCT POST DECONSTRUCT POST DECONSTRUCT
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LPB 298/25 STAFF REPORT ON CERTIFICATE OF APPROVAL Gas Works Park 1901-2101 N Northlake Way Features and Characteristics for which a Certificate of Approval is required: The entire site, including the exteriors of all buildings and structures. Designated under Standard: C, E, and F Summary of proposed changes: Selective removal of former maintenance platforms, stairs, ladders and supporting structure, including the length of pipe and supports on the west side that extend over the boundary fence. Suggested Language for Approval: I move that the Seattle Landmarks Preservation Board approve the application and issue a Certificate of Approval for the proposed selective removal of maintenance access equipment, appurtenances, and associated supports at the former gas generating equipment in Gas Works Park, 31901-2101 N Northlake Way, as per the attached submittal. This action is based on the following: 1. With regard to SMC 25.12.750 A, the extent to which the proposed alteration or significant change would adversely affect the features or characteristics described in Ordinances 121043. a. Selective removal of built elements in the vicinity of and attached to the tanks/towers will change the overall ‘texture’ of the former gas generating equipment, but the applicant has demonstrated the reasonableness of the proposal to further deter access to and potential climbing of the structures. b. The Gas Works Park Report on Designation (LPB 148/99) notes that the “Towers are of a scale and form easily perceived from any location around Lake Union” and “the contrast of these monolithic forms superimposed on the city skyline is unique and visually exciting.” These tank/tower silhouettes will be simplified by the select Administered by The Historic Preservation Program The Seattle Department of Neighborhoods
removal of built elements, but the overall monolithic forms and grand scale identified in the Report on Designation will remain intact. c. The proposed select removal of elements is consistent with the existing condition of other tanks/towers that are sited outside the fenced area. 2. With regard to SMC 25.12.750 B, the reasonableness or lack thereof of the proposed alterations or significant change in light of other alternatives available to achieve the objectives of the owner and the applicant. a. In response to Board feedback, the applicant re-evaluated the proposed scope of work for the elevated pipeline on the west side. The applicant determined that expanding the fenced area will have a number of challenges. Alternatively, they will endeavor to retain more of that structure inside the fence line, while removing the lengths of pipe that extend over the fence. They will assess if the remaining horizontal pipe and supports are sound, and if there are hazardous material concerns. This decision will be made in the field, and the outcome will be communicated to the Landmarks Board coordinator before removal occurs. b. In response to Board feedback, the applicant re-evaluated the proposed scope of work for selective removal of elements attached to the tanks/towers. The applicant’s contractor will endeavor to keep some elements at higher elevations if they determine them to have sound supports and remain consistent with the goal to deter access and climbing. These decisions will be made in the field, and the outcome will be communicated to the Landmarks Board coordinator before removal occurs. 3. The factors of SMC 25.12.750 C, D and E are not applicable.