It’s been a task that I have been wanting to undertake for some time: putting all the snags and costs and incremental regulatory hang ups that, together, are making increasingly difficult to deliver housing to the market. I’m still working on the costs figures for each of these. It’s not easy always to estimate or account for these because they vary. Some, like the increases to Street Improvement Permits (SIP) — they’ve gone up as much as 3,200 percent, in one case from $146 to $4700 — are easy to see. Others, like requiring an extension of a water main can vary depending on the length of the extension. The part that is really difficult is figuring out how do these all add up across the housing economy? How much do these things, cumulatively, add to the price tag of a house or to monthly rent? And how do they shape decisions to fund and build in the first place? How often do these things kill a new housing project.

Of course any rule, regulation, fee or tax adds to the cost of producing anything, even a hot dog. The issue, however, is how much do we regulate and fee and why? State and local government control price to a significant degree. When they dial up the rules and they dial up the price. If the rules are about fire safety most would agree that that’s worth paying for; but the color of the paneling on a new apartment building, not so much. Policy makers need to be held accountable for needlessly adding to to this list; if it can’t be justified with a straight face then don’t do it, period. But in today’s environment it’s easy to say, “Oh they’ll just make a little less profit!” We’re going to change that.

And a final point: non-profit housing projects pay for and deal with all of these too in addition to legal and transaction costs and requirements from funders. It’s not because there is a community room with a nurse in it that non-profit housing is so expensive, it is because costs are being needlessly and thoughtlessly added to all housing. It’s got to stop.

	Department	Department	Delay or Cost Description
1	SDOT		Threatening to end its current practice of allowing streets to be temporarily re-opened in order to reset the meter on street use fees.  Currently the per diem escalates the longer you have the street closed, but if you re-open for 5 days and then close down again you go back to the starting point again.
2	SPU	SDOT	When we do Unit Lot subdivisions or short plots, we are not allowed to submit our applications for water or power until the city has granted the ULS and provided the correct addressing!  There have been many times that we have a completed project and are ready to put it on the market, but do not have power because we have not received the official addressing.
3	SDOT		New ROWIM requirements.  Last year SDOT rolled out a new Right of Way Improvement Manual which generally increased the amount of street restoration required for project.  In some cases this has increased our requirements up to the total repaving of an entire street block for a single project!
4	SDOT		·SDOT permit fee increases.  For SIP/Utility Major permits which experienced the highest increase,
5	SPU		Multiple tap requirements.  Instead of allowing a single tap location as previously required, many projects with multiple units on a street face are now being required to provide multiple taps to the main.
6	SPU		Casing requirement.  Although it’s been ensconced in CS101 for years, SPU is now enforcing the requirement to place on-site water lines in casing pipe when multiple lines pass through a 5’ setback.
7	SDCI		Car parking requirements
8	SPU		Lack of inter-dept communication.
9	SDCI		Not issuing sewer permits because of private easements.
10	SCL		Sizing of vaults required by SCL – they are HUGE and therefore Expensive!  Someone told me they just checked and AMZNs new vault is running at 30% of capacity at an AMZN density.  Waste of space and money.
11	SDCI		Green Building Standard linked into HALA adds costs
12	SDCI		+15% better than energy code tucked into MHA/HALA.  This is really tough and expensive.  Our code is already impressive from an energy standpoint.  Makes final product more expensive, less natural light etc.
13	SDCI		POTECH Review. Did we need a full dedicated department for this now?  Don’t think so.
14	SPU		Water Main Extension requirements. Seattle Public Utilities is already requiring new and costly water main extensions for new housing based on sub divided lots rather than parent lots. This means that although water service is feasible from existing mains, new mains are being required. The effect is either fewer more expensive units to avoid the additional costs or increasing the price of existing units to absorb the costs of the new water main.  We understand that SPU may be in the process of increasing the circumstances where water main extensions will be required.
15	SPU		New drainage requirements. Seattle Public Utilities is in the process of reviewing drainage requirements as well, and we’re concerned that new housing projects that can already handle drainage without new and expensive infrastructure are going to be now required to build storm water main extensions, another significant and we believe unnecessary added cost to housing production.
16	SPU		System capacity (or similar) charges. It is our understanding that Seattle Public Utilities, or perhaps other instrumentalities of the City, are exploring implementing this type of charge to help build out the water/sewer infrastructure of the City
17	SCC	SDCI	Impact fees – The Council is moving ahead with considering impact fees. We’re highly skeptical of this. While potentially legal if done properly, it’s hard to see how this would be implemented in Seattle. Again, this is yet another additional and still unknown cost to housing production.
18	SCL		Separation from Electrical Wires – Recently Seattle City Light implemented a new policy that requires a 14’ separation between new construction and the SCL service lines.  This has made some projects financially infeasible, has requires significant redesign to others and has necessitated costly and time-consuming relocation other SCL facilities, at the property owner’s expense
19	SCL		SCL has increased power line setbacks to 14’, but is no longer willing to wing-arm right of way power lines to reduce the encroachment of this setback onto private property.
20	SDCI	SCC	Definition of Frequent Transit Service – Currently there are dozens of projects currently in permitting with as many as 100 units or more at risk because the City has not enacted legislation to clarify the definition of frequent transit service. Projects will be stopped or forced to add parking that will reduce supply and boost the price.
21	SDCI		Full Design review – Full design review continues to be a serious expense, especially in those cases where boards draw out the process into multiple meetings.
22	MAYOR	SCC	Mandatory Inclusionary Zoning/Mandatory Housing Affordability – W We know this program makes many projects infeasible because the cost of fees, inclusion, and additional construction to realize the benefits of additional floor area out weigh the value of that square footage. Again, this is an as yet unknown but significant cost and slowing of production, not to mention that many sellers of land in areas potentially impacted by upzones are beginning to demand more money for their property.
23	SDCI		New registry for vacant buildings — If a proposal goes forward to create an inspection and registration regime more complications will be added to many projects in low-rise zones.
24	SPU	SDCI	Increases in size of garbage facilities – Because of a change of staff, previous allowances for multiple weekly pick ups of recycling and garbage, garbage rooms are getting bigger based on the assumption of once a week pick up.
25	KING	SDCI	King County has introduced a new requirement for plan review for plumbing and gas piping for all projects 3 stories or greater
26	SDCI	SCC	Easement required for cars on lots with no parking requirement; removed from omnibus legisation
27	SCL		Seattle City Light is taking over a year from project application to service letter. We literally have to start our service applications at the outset of project design to have a hope of getting power to our projects before they are complete.
28	KING	SPU	Sewer capacity charges are higher for multifamily than single-family; this adds big costs to multifamily buildings
29	SDCI		Historic review for all structures over 50 years old. ($5K per project to prove that a piece of junk is a piece of junk).
30	SDI		Traffic studies required for all projects with no parking, despite code that prohibits SDCI from acting on the information. ($5-$7k per project for a study that is simultaneously mandatory and meaningless).
31	SDCI	SEPA	View corridor studies needed to verify that views from adjacent residences are not being blocked by the addition 4’ of height granted to buildings to allow 13’ tall commercial use. This has been in SEPA regs forever, not ever enforced until recently. The commercial use in most cases is mandatory, but we still have to study the impacts of the height increase associate with it. ($5K per project in drawings and diagrams).
32	SDCI		Additional phase of design review for public outreach (unknown. likely $10-30k per project, weeks to months of timeline depending on how administered)
33	SDCI		Design review requirements for dozens of pages of bespoke context analysis which could be provided a better format with 4-5 links to google maps, walk score, zoning maps, etc. ($25K per project, several weeks of work)
34	SPU		SPU memorandum of drainage control process. Dozens of pages of gobbledygook that must be reviewed and recorded for each project. Drainage reviewers are choking on the workload, delaying projects by weeks and months. The recording process adds an extra correction cycle with the review staff that is slowest to turn things around as it is.($5-10K per project to prepare and correct. Associated reviews and corrections are taking up months of review time)
35	SDCI		Administrative design review has gone a little bit off the rails. While some of our projects have gone smoothly, the general consensus among my peers is that ADR is now considered riskier than full DR. This is to say, architects feel they have a better chance of being treated fairly and predictably by the citizen boards in full DR than by the professional planning staff in ADR. This is a tremendous inversion from what we’ve experienced in the past & raises concerns for a future in which more project go through ADR than full DR.
36	SDOT	SDCI	New pedestrian zone requirements for large canopies over the sidewalk ($50K per project min.)
37	SDOT	SDCI	New pedestrian zone requirements for wider sidewalks, more improvements along public ways ($25k per project)
38	SDOT	SDCI	New requirements for curb ramps at corners ($25k per project)
39	SDCI		Increasing conservatism from reviewers on details of how fire rated assemblies should be constructed.
40	SPU		Requirements for civil engineers to design OSSM measures that are essentially prescriptive. No flexibility provided to allow OSSM measures to mitigate need for costly main extensions.
41	SDOT		New requirements for pavement restoration in recent Pavement Opening and Restoration Requirements (PORR)
42	CCAB	SDCI	CCAB ruling make it impossible for SEDUs to be the size intended by council (220sf)
43	SCC	SDCI	New bike parking regulations requiring 1.2 bike parking spots per unit
44	WA	SCC	Real Estate Excise Tax charged on every sale of real estate
45	WA	KING	Document Recording Fee charged on every substantive change to boundaries, lot size etc
46	WA	LOCAL	Property taxes
47	WA	LOCAL	Sales taxes