Draft EIS study finds that the proposed code changes will reduce the number of DADUs built
The EIS provides a useful tool
for community members and the city to evaluate the impacts of growth in
residential neighborhoods. The information gathered can and should be used
shape policy in our changing city. Given the information presented, we support Alternative 3 with
its emphasis
on maintaining the scale of existing development in single family residential
zones. Most importantly the EIS finds that Alternate 3 will reduce the amount
of natural occurring affordable housing lost to redevelopment. We feel that a
moderate pace of scaled growth will lead to more equitable and environmentally
sustainable Seattle that maintains a
strong sense of place.
Backyard
cottages are a great addition to our city providing the low hanging fruit for
increasing urban density while providing housing opportunities for
families. The EIS study finds that
backyard cottages increase housing options in areas that are deemed to have the
highest access to opportunity. In fact we see this trend on an ongoing
basis. A majority of the cottages we design are being built as
rentals. And while the cost of construction is relatively uniform across
the city, rental rates vary greatly. As a result, the return on
investment is higher for a cottage built in a more desirable neighborhood with
higher rental rates.
As
rental rates have increased so to have the number of backyard cottages built.
Current rates of production are close to 150 new DADUs per year. The EIS analysis finds
that Alternate 1 (no action) would result in the production of 1,890 new DADUs, Alternate 2 (representing
the broadest range of changes) would result in 1,820 new DADUs and Alternative 3 would
result in 1,705 new DADUs being built in the next
ten years. It is interesting to note, that of the alternates,
the highest number of DADUs would
be produced under Alternate 1 which represents no change to the current land
use code. Given those results, it would be hard to argue that the
proposed changes are necessary to encourage DADUs. However, the EIS does provide the opportunity
to suggest improvements through the comment process which runs through June
25th. All comments will be included in the final EIS report. To review
the EIS document and to comment
visit. DRAFT EIS.
BCBEB (back
yard cottage blog editorial board) ADU EIS guide to the EIS comparison of
alternatives.
1. Number of ADU's on a lot: Alternative 1
no action or Alternative 3 Allow an ADU and DADU on lot while maintaining the owner
occupancy covenant.
DADUs built under current land-use have an impact to the built
environment but one generally in keeping with current development patterns
in SFR zones. Allowing
three units especially in combination with the removal of the owner occupancy
requirement will lead to SFRs designed
and built to be rentals with a much higher combined value. Because the combined
rentals will have a higher value than one smaller SFR there will be financial
incentive to increase the demolition of naturally occurring affordable SFR housing. In addition,
the higher combined value of three units will make their purchase that much
less obtainable for a family and more appealing for an out of area investor. It
has been well documented in the HALA literature that opportunity gaps exist
based on proximity and home ownership. Ownership is one of the primary
means of accumulating and maintaining household wealth. This is true for
marginalized communities but also for middle class families. Allowing more than
one ADU per lot, and
eliminating the owner occupancy requirement, will reduce the amount of
affordable housing available to families to own.
2. Parking: Remove parking requirement for ADUs. Alternative 1: no action.
There is already a parking waiver system which
allows for conditions where the cost to add parking is expensive or otherwise
infeasible. If we are serious about building equitable
communities we shouldn’t be caviler about parking. Those who depend
most on cars are the working poor and families with children. More than others,
the working poor don’t have the luxury of having just one job in an urban
center served by transit. They need a car to get to multiple jobs in dispersed
locations, often in off hours. Similarly, it is virtually impossible for
families with young children to function in Seattle without a car.
3.
Owner Occupancy: Alternative 1 or Alternative 3
The EIS looks at the effects of
removing the requirement all together for the sake of studying the
impacts. The original proposal to sunset owner occupancy after a period
of time is good and should minimize the destruction of naturally occurring
affordable housing by speculative developers. The period of time should
be 3 years. However, owner occupancy should be required for all DADUs used
short term rentals.
4. Reduce
minimum lot size: Alternative 3
We
already design many cottages on lots less than 4,000 sq. ft in size and the
size of the cottage on smaller lots is driven by lot coverage as it should
be.
Additional
alternatives: Portland and Vancouver give special consideration to alley lots
and corner lots. These lots can more readily handle increased development
without disrupting the neighborhood fabric.
5.
Increasing the allowable cottage size from 800 to 1,000 sq ft.: Alternative 3
increasing
the allowable size 200 sq. ft. is a great idea and makes it easier to fit in
two bedrooms. However, Alternative 2 excludes the garage and other
storage from this calculation potentially allowing 2,000 sq. ft. ADUs. We frequently design
cottages where the garage space is not intended for parking but as part of the
cottage. The city can't and shouldn't mandate that garages are used for
parking but not including this space in the allowable square footage will
unnecessarily increase the allowable size and bulk of DADUs. And will have a negative
impact on the character of neighborhoods, the amount of natural light and
vegetation available.
6.
Additional Height: Alternative 1 (no action)
While
almost all of the cottages we design are built to the allowable height limit
the current height limit is adequate for a two story structure.
Additional height can reduce the amount of sunlight reaching neighboring
yards. The multi-family code has provisions that allow additional height
with a consideration for the impact of shading on neighboring properties.
Something similar can and should be adopted for DADUs wanting higher height
limits.
7.
Lot coverage Limit: Maintain.
Recognizing that yards
do have a value both for families raising children and as green spaces and as a
way to reduce stormwater runoff.
8. Rear
yard coverage alternate: Increase to 60% (Support):
The
proposed changes don't actually increase the total amount of lot coverage
allowed.
9.
Rooftop features alternate (Support):
Allowing
rooftop features, namely shed dormers to extend above the base ("eave
height") will not increase the bulk of DADUs allowed under the current land use code
and therefor have no environmental impact but will facilitate good design.
10.
Location of entry alternate (Support): the alternative to allow entries located facing the nearest lot line as long as the entrance is located 10
ft or more away.
11:
Maximum Household Size: No change, Alternate 1 or 3
Alternative:
increase the household size along with maintaining owner occupancy
requirements.
12: MHA fees would apply when
an owner applies for a second ADU.
MHA fees will discourage
the creation of additional units. It would seem better to require that
additional units, if allowed, meet affordable housing guidelines.
13: Reduce pre-development costs by
10%.
SDCI can start by assigning
a designated reviewer for DADUs wich will eliminate
inconsistencies and streamline the review process saving both time and money.
Additional
alternative: SDCI can waive fees
for DADUs with affordable housing
criteria.
14.
Introduce a maximum FAR ratio: Alternate 3
This
is a big introduction into the EIS study. Floor area ratio is the
ratio of the gross area of a structure to the total lot area. Currently,
the FAR is not restricted in single family zones and size is restricted by
setbacks and lot coverage. As shown in the EIS introducing an FAR limit will increase
the number of smaller more affordable houses being built and reduce the
destruction of naturally occurring affordable housing.
