Article 6KAAG The Comprehensive Plan Must Do More

The Comprehensive Plan Must Do More

by
Nathan Dickey
from Seattle Transit Blog on (#6KAAG)

Seattle's much-delayed Comprehensive Plan update was released last week by the Office of Planning & Community Development (OPCD). Coverage of the broad points of the plan was quickly provided by The Seattle Times ($), The Urbanist, The Stranger, and Crosscut. The primary takeaway image is the Future Land Use Map" (FLUM), here:

image-6.png?resize=525%2C700&ssl=1

Coverage of subsequent disappointment from housing density advocates was then provided by The Urbanist and The Seattle Times ($).

The plan itself is full of florid prose describing how it supposedly expands housing opportunities across the city, meets equity goals, invests in walkable communities, and meets the challenges of climate change. It establishes Key Moves" and proposes policy changes that sound good on the surface, but the proof will be in how these policies are implemented.

The plan as currently drafted assumes the majority of new housing would primarily be built in existing Urban Villages, but also establishes new neighborhood cores and proposes to expand housing options across the (formerly) single-family zones that currently dominate the city. As apparent on the FLUM, the Plan proposes some name inflation across the city, changing current Urban Centers" into Regional Centers", Urban Villages" into Urban Centers", and Neighborhood Residential" into Urban Neighborhood" zones. The plan includes some modest expansions of some existing villages, upgrade of Ballard to Regional Center, and creation of a new Urban Center around the 130th street Link station. The plan also calls for the creation of 24 new Neighborhood Centers", which is reduced from the 40 proposed in the 2022 Draft Environmental Impact Statement (DEIS) scoping report.

The text of the plan is not specific about how it would increase housing capacity in the various Centers it proposes (beyond allowing slightly taller structures), but it doesn't preclude the concept of raising height limits or increasing floor-area-ratio (FAR) maximums in these areas.

image-11.png?resize=525%2C191&ssl=1

What is concerning, though, is how OPCD plans to meet the requirements of new state laws requiring increased density in our most exclusive zones. These single-family housing zones, renamed Neighborhood Residential" in 2021, will be again be rebranded under the One Seattle Plan as Urban Neighborhood" zones.

Warning: it's going to get wonky.

Technically Foul

OPCD has provided a summary of the proposed updates to the Neighborhood Residential development standards to turn them into Urban Residential zones.

Let's compare the current development standards...

image-10.png?resize=525%2C349&ssl=1

... to the proposed rules:

image-12.png?resize=525%2C327&ssl=1

The key points here are FAR and height limits. Let's see what the OPCD thinks would be technically feasible to build on a typical 5,000-square-foot lot in Seattle:

image-16.png?resize=525%2C177&ssl=1

Due to the maximum FAR of 0.9, only 4,500 square feet of floor area could be built, resulting four units averaging a maximum of 1,125 square feet each, including the area occupied by walls. In areas of high displacement risk" (which doesn't include the already-upzoned formerly-redlined neighborhoods of the city), OPCD is also considering limiting some Urban Residential zones to only three units, which would look like this:

image-17.png?resize=525%2C163&ssl=1

Two of these designs are not practically any different than what's already possible under Seattle's allowances for attached accessory dwelling units (ADUs) and detached accessory dwelling units (DADUs). ADUs and DADUs are already legal across all existing neighborhood residential zones, and displacement is already occurring, so it is unclear how continuing to restrict development in these areas will prevent continued displacement.

The reality is that even if these rules represented a tiny loosening of housing restrictions, any new homes built in these zones would still be unaffordable to any households making less than 1.5 times Seattle's median income.

If the average single family house sells for about $800,000, and the average cost of new construction is about $350 per square foot, then it would cost nearly $600,000 per unit to develop a property to the maximum allowed density under the 4-unit maximum. Add a 15% profit margin, and that's a minimum of sale price of nearly $700,000 for a 1,125-square-foot, three-story townhome.

That kind of minimum housing cost is what we're already seeing today. The median household income in Seattle is $105,000, which might be able to afford a mortgage somewhere around $350,000, depending on several factors. If this plan wants to make any sort of real impact on the housing affordability crisis, we need to legalize higher densities to spread the cost of land value among more units. This would slow and potentially reverse the rampant inflation of housing prices we've seen in Seattle over the past decade, relieving the housing affordability crisis without mandatory affordability requirements or onerous fees.

Achieving the Bare Minimum

E2SHB 1110, passed by the Washington State Legislature in 2023, amended the Growth Management Act to require the following:

For cities with a population of at least 75,000 based on office of financial management population estimates:
(i) The development of at least four units per lot on all lots zoned predominantly for residential use, unless zoning permitting higher densities or intensities applies;
(ii) The development of at least six units per lot on all lots zoned predominantly for residential use, unless zoning permitting higher densities or intensities applies, within one-quarter mile walking distance of a major transit stop; and
(iii) The development of at least six units per lot on all lots zoned predominantly for residential use, unless zoning permitting higher densities or intensities applies, if at least two units are affordable housing.
[...]
Any city subject to the requirements of this section [...] shall not require through development regulations any standards for middle housing that are more restrictive than those required for detached single-family residences...

https://app.leg.wa.gov/RCW/default.aspx?cite=36.70A.635

I am not a lawyer, but while Seattle's proposed Urban Neighborhood zoning appears to meet the letter of the law, it seems to take some careful steps to do no more than the bare minimum to engender new housing outside of urban villages. In fact, Seattle's response to this law is far less permissive than the Washington State Department of Commerce's Model Ordinance for cities larger than 75,000 people, which calls for a scaling FAR based on how many units are being built on the lot:

image-19.png?resize=525%2C365&ssl=1

For example, a FAR of 1.2 would allow four 1,500-square-foot units on a 5,000-square-foot property; recall that Seattle's proposed FAR of 0.9 would limit these units to 1,125 square feet. The State's model ordinance allows for 375 additional square feet, or two 180-square-foot bedrooms. A FAR of 1.6 would allow for six 1,333-square-foot units on the same property; compare this to... actually, OPCD didn't even bother to show how 6 units could be accommodated on a typical Seattle property. Each of these options are far more economically viable for builders than Seattle's proposed FAR limit of 0.9 for Urban Neighborhoods.

Instead, Seattle is proposing to achieve a vision for the future... to make Seattle more equitable, livable, sustainable, and resilient" by doing nothing more than the bare minimum.

Frankly, Seattle's proposed updates to our Neighborhood Residential zones is nothing more than an abdication of leadership. Whatever Seattle does, other cities who may be eyeing minimal compliance are guaranteed to try to do less. If Seattle is allowed to implement this highly restrictive low-density zoning under HB 1110, not only will we be perpetuating the systems that engendered the current housing crisis, but we will embolden our neighbors to do the same, or worse.

How To Do Better

Most of our beloved neighborhoods were built before zoning limited new dense construction to a mere fraction of the city's residential area. If we want to build our way out of the current housing crisis, Seattle must be ambitious about legalizing moderate-density to fill the missing middle across the entire city.

We could be ambitious like Spokane, which permanently legalized middle housing last year. With no statutory limits on unit density on lots less than 2 acres, no applicable FAR limits, and general lot coverage limits, Spokane may officially be the most housing-permissive in Washington. Sure, they still have height limits and setbacks, but Spokane is certainly blazing the trail on allowing middle housing.

If Seattle wants to retake the lead on providing sustainable, affordable housing, we need to upgrade our Urban Neighborhood zoning standards into something akin to our Low-Rise Multifamily zones. These zones allow for shared-wall rowhomes, apartments, and cottage housing. This means we need OPCD to not only raise the statutory limit on number units per lot, but we also need to raise the maximum FAR. We can keep the setbacks and the lot coverage maximums, but if we want to build our way out the housing crisis, we need to allow for 6- to 8-unit rowhomes and condos across the city with a FAR of at least 1.6, if not more (or consider eliminating FAR limits entirely, like Spokane). Even with height limits of 3-4 stories, new construction that can spread the cost of the property across several units is much more affordable to many more households.

What About Parking?

I can already hear the Concerned Citizen crying out, but what about their cars!?" The Puget Sound Regional Council identifies local densities exceeding 15-20 homes per acre (or about one home per 2,200-2,900 square feet) as preferred targets for high-frequency transit. Assuming the average urban acre is ~50% residential (the rest as roads, parks, and other uses), a neighborhood of homes with an average of two units per 2,500 square feet, or four units per 5,000 square feet, are neighborhoods that would be well served by transit service every 15 minutes or more. There is little limiting the maximum number of parking spaces a developer can include for a residence, but it contributes to the difference between an affordable home and a luxurious one.

Not-so-coincidentally, these neighborhood densities also provide a strong customer base for small local businesses, which improves walkability and reduces reliance on vehicles for everyday errands. Increasing low-to-mid-rise density kicks off a positive feedback loop of reduced car dependence and increased walkability, which supports more small businesses and unlocks viability of more developments with no space for cars, which allows for more housing and supports more small businesses. This allows us to give street space back to the people, and allows more space for more street trees, which would reduce stormwater impacts, clean our air, and shade our homes from the increasingly hot summers.

With moderate density and good transit, not every house or shop requires a parking lot. But we knew that 100 years ago.

A Call to Action

If we want an equitable future, Seattle cannot plan to do the bare minimum for the next 20 years. To do so would be an abdication of leadership, would perpetuate the housing affordability crisis, and would directly result in Seattle failing to meet its long-stated goals for equity, livability, sustainability, and resiliency. If we continue to only allow high-cost new construction that's only affordable to the highest income-earning households, then Seattle will perpetuate a cycle of displacement and gentrification that drives away creativity, excludes diversity, and increases sprawl.

OPCD is hosting a series of open houses to discuss the plan, and anyone who wants to make sure they or their neighbors can afford to continue living in Seattle can and should show up to tell OPCD they need to do better. However, apparently the vocal advocacy that pushed for Alternative 5" (and for a more-ambitious Alternative 6") during 2022's DEIS scoping meetings did not get through to OPCD leadership or Seattle's City Council.

Seattle is not alone in the housing crisis, but Seattle should lead the region, if not the state, in responding to it. We cannot allow the city to set the standard of minimal compliance with state law.

The first public feedback meeting is tomorrow in Loyal Heights.

We must tell the City: Set the bar, and raise the FAR.

External Content
Source RSS or Atom Feed
Feed Location https://feeds.feedburner.com/seattletransitblog/rss
Feed Title Seattle Transit Blog
Feed Link https://seattletransitblog.com/
Reply 0 comments