Look out! The Washington State's Department of Commerce just selected a private engineering and planning firm, LDC Consultants, to set new formulas that counties and cities must use to calculate how much capacity for new residential development they have under their existing zoning code. If the new formula shows that more capacity is needed to reach their “2035 residential growth target” under the State’s Growth Management Act (GMA), that city or county is required to upzone for still more development.
What’s especially troubling about this, a key member LDC consulting also is tied to the Master Builders Association (MBA), well known for its interest in promoting as much density and development in communities as is humanly possible. In fact, the MBA credited this individual for doing a lot of their legwork in the recent session of the Legislature that ensured passage of the bill requiring recalculation of the formula.
The bill — ESSSB 5254 — heavily lobbied by the MBA for years, also gives cities and counties discretion to waive certain environmental requirements for dense residential developments around rail or major bus stops. In past sessions, the bill never got traction among enough Democrats, but provisions were tacked on providing funding for homeless housing ensuring easy passage this year.
So exactly how would a recalculation of the formula work to compel cities to upzone their communities and how might this affect Seattle?
The State's Growth Management Act (GMA) requires the State’s Office of Financial Management, every five years, to update its projections for the amount of growth that is likely to occur within the Puget Sound basin. Then each county is assigned an adjusted 20-year “target” and portion of that projected growth. The counties, working with the cities in that county, then apportion to each city a share of that county’s target. Then, it’s up to each city to make sure they have enough zoned capacity to meet their target.
To ensure enough zoned capacity, cities must regularly recalculate (every five years) how much room they have to add new units. Using long-established formulas, this first involves adding up the amount of vacant land considered available for development, then calculating how much new housing theoretically could be built there under current zoning. Lots deemed unbuildable or not likely to be redeveloped are excluded.
Then “developed” lots are factored in. Some of those lots are zoned to allow development at much higher density than their current use. The formula assumes a certain portion of these “underdeveloped” sites will be redeveloped over time and reach maximum allowed density. Then a count is taken of the number of units that could be added when those sites are redeveloped.
If the resulting data show there isn't enough capacity under current zoning to meet a city or county’s assigned residential target over the 20 year period, the GMA requires a city or county to upzone to address the capacity shortfall.
Theoretically, it also calls on these locales to adjust zoning downward if they’re overzoned. Also theoretically, if infrastructure lags behind the growth, the GMA requires slowing down that growth until the necessary new infrastructure can be added. Lagging infrastructure is in fact what we’re seeing here in Seattle but fat chance our elected leaders would ever downzone or slow growth until our infrastructure catches up.
In Seattle, as anyone can see, we’re drowning in record growth. Seattle has a GMA growth target of 70,000 housing units that we must reach by 2035. At our current rate, our city will reach half that target in 2018 and could exceed it in five years.
Even with such rapid growth, city planners calculate that our current zoning still has capacity for another 205,000 units, nearly three times what we need to meet our assigned targets. Unbelievably, the “HALA” upzone plan would add another 80,000 units to our zoned capacity.
To any rational observer, this becomes difficult justify. One simple way for developers and their pro-density surrogates to accomplish that is effectively "moving the goal posts"; creating a new formula that could bring down Seattle’s estimate of zoned capacity.
While it's hard to imagine a new formula that would cut Seattle's zoned capacity by 70 percent, enough to lower it from 205,000 to 70,000 unit GMA 2035 target, you never know when a planning firm linked so closely to development interests is put in charge of doing the calculating.
The bill that passed does require the consultant to set up a process for taking comment from all stakeholders before finalizing the proposed new formula. And ultimately it appears the final formula will be determined by the State Department of Commerce. Citizens groups may want to have some input into this process.
To find out how to get involved, we recommend calling the Department of Commerce Buildable Lands Section. More info can be found here on their website: http://search.commerce.wa.gov/Pages/results.aspx?k=Buildable%20Lands%20Program
JOHN V. FOX and CAROLEE COLTER are coordinators for the Seattle Displacement Coalition, a low-income housing organization. More information can be found at www.zipcon.net/~jvf4119/.