July 22, 2014

Dear Councilmember O’Brien,

Thank you very much for patiently engaging all sides on the microhousing issue. We understand that it is difficult to navigate to compromise or consensus on this challenging issue. However, as a city poised over the next 20 years to welcome 120,000 new people, we must find solutions to provide a variety of housing choices for all of our new citizens. Microhousing must continue to be part of that solution.

First, the current proposal is better than the proposed Department of Planning and Development proposal but not by much. Some neighbors want less density and that’s why they are pushing for bigger units and more rules. As a matter or principle, we think it is bad policy to bargain away units to make people living here today happy at the expense of new people residing here in the future.

Second, we are willing to have larger projects go through full design review and smaller ones through streamlined design review. It’s the size of the project—it’s volume and massing—that arguably has an impact on the neighborhood. We object to efforts to micromanage the lives, lifestyles, and choices of residents of the projects by mandating room sizes and sinks, for example. And we don’t support the idea of having a few neighbors dictate the decisions of builders about how to meet housing demand anymore than we’d support them making demands about what’s on the menu at a new restaurant.

That also means we don’t agree with the idea of “small efficiency apartments.” We appreciate the efforts to stretch this term as a way to both codify microhousing and to create flexibility. But it takes us backwards by subjecting projects to SEPA review based on units and needless standards that exceed International Building Code requirements.

We don’t object to SEPA process when it is appropriate, but the City has deliberately moved away from subjecting multifamily projects to SEPA review in areas rich in transit. As a matter of policy, we are, as a city, moving toward a review of projects based not on units but on overall size.

Subjecting microhousing to design review would result in unintended consequences. For example, a 4800 SF lot in the MR zone in an urban village could be developed with as many as 20 “conventional” apartments and not undergo design review.  But a microhousing project of the same exact size (floor area, height, volume) would have to go through design review simply because the units are microhousing.

Why would we single out this product for more arduous and costly process?

What we propose is the following:

• Continue to allow both microhousing and congregate housing in all commercial and multifamily residential zones such as MR, HR, SM, C, NC, L, LR, etc.;
• Not allow microhousing or congregate housing in single family zones
• For projects that are 40,000 square feet or more, full design review; and
• For smaller projects of 15,000 sf and above, a streamlined design review process.

This allows for notice to neighbors for most projects and for participation in the design process through design review. When looking at the six projects submitted in the first half of 2014 (3 congregate and 3 micro), 2 congregates with 70% of the total rooms would go through full design review and 1 congregate with 12.4% of the rooms would go through streamlined design review.  That is over 82% of the rooms and covers the larger projects that are of most concern with the neighborhoods.

The design review process, while broken, at least offers a process to achieve resolution of issues for neighbors and flexibility from design standards for developers. It also avoids the micromanagement of the inside of the buildings, which we oppose both in principle and because such interference can make projects infeasible, incentivizing larger apartments. Larger apartments will be more expensive and defeat the purpose of both density and affordability.

We would like to discuss this with you in more detail.  Thank you for your consideration.