An updated draft proposal and supporting documentation has been released and is now available for the proposal to implement Mandatory Housing Affordability (MHA) Requirements in Downtown and South Lake Union under HALA.  These materials include a summary of the proposal, draft ordinance, State Environmental Policy Act (SEPA) analysis, Urban Design Study, and Transportation Study.  All documents are posted at www.seattle.gov/hala/policies.
 
The deadline for comments on the draft proposal is June 16. The deadline for an appeal of the SEPA Determination is June 23. OPCD will finalize the draft materials after the comment period such that legislation could be submitted to City Council in July.

Please send you comment letters to brennon.staley@seattle.gov. What follows is our position on this critically important plan for the future of downtown:

First of all, we want to clearly reaffirm our support for more affordable housing. Many of us individually have and do serve and contribute regularly to local affordable housing organizations, like Compass Housing Alliance, Plymouth Housing, etc.

Second, we want to make it clear that we support the “funding mechanism“ of the HALA proposal, but have strong issues with how the land use and development proposal will likely have serious negative consequences on the environment and livability of downtown (where is the “L” in HALA?), and exacerbate a “growing problem” of tower overcrowding in downtown.

We also want to thank the HALA team, for supporting Option 2 on adding equivalent development capacity through additional height rather than the additional 1000 sq. ft. per floor through additional girth in new residential development downtown. However, this alone is not enough to ensure future livability for downtown residents.

Regarding the SEPA Determination of DNS, we strongly disagree with the Director’s decision. The Director’s SEPA analysis of land use and development impacts lacks serious rigor, misapplies city policy, market influences, and ignores the plain fact that residential development is already greatly incentivized over commercial uses in DOC1 and DOC2 because there are no density limits (FAR restrictions) for residential development as there is for commercial uses.

We want to reiterate our request to include new residential development standards to provide adequate light, air, and privacy in all future projects in the “unprotected” zones of downtown. If you can change the height limits for HALA, which you can, why not also include allowances for equivalent square footage in additional height in certain zones to solve alley congestion issues and tower separation issues affecting light, air, and privacy at the same time [with tower spacing, alley setback, minimum lot size, max lot coverage, etc.].

We strongly disagree with the claim that there are not enough potentially affected parcels (parking lots/obvious teardowns, etc.)  to warrant including these provisions. For example, even if we were to accept (and we don’t) that there are only nine re-developable parcels in the affected zones, this would still potentially produce 5.5 million square feet of new mixed use/residential development, or the equivalent of as many as 3,600 new residential units, thus affecting at least 10,000 persons in total. Is this not enough to be “concerned" about the growing problem created by the city’s flawed land use code and review process?

Often, the city passes code amendments to satisfy just one or two developers’ speculative goals. If nine parcels are not enough for the city to take the downtown residents issue more seriously, then what is enough? Quite frankly, one parcel is too many when the physical and emotional health of individuals is affected by the lack of air, light and privacy. Who knows if something that is not considered a teardown today might be in a few years? Look at Escala and the properties right across its alley in the early 2000s, when the City failed to take action there because “nothing was likely to happen residentially” …and now look at it.

You’ve done part of the job. Now finish it with legislation that will do it all...protect downtown livability without reducing development capacity, and provide the funding for HALA.