The Laurelhurst Community Club (LCC) encourages the community to submit comments by Monday 5pm on the proposed changes and amendments to Seattle's Municipal Code on Accessory Dwelling Units (ADU)s.
The City Council's public hearing on the proposed regulations is Monday at 2 p.m. The public is invited to sign up to speak at the hearing in City Council Chambers on the 2nd floor of City Hall (600 Fourth Avenue).
Written comments must be submitted by noon on Monday to:
Councilmember Mike O'Brien
600 Fourth Avenue, Floor 2
PO Box 34025
Seattle, WA 98124-4025
or by email to Mike.OBrien@seattle.gov and aly.pennucci@seattle.gov
Abel Pacheco, District 4 Northeast Seattle
Chair: Planning, Land Use & Zoning
Vice-Chair: Sustainability & Transportation
206-684-8808
The proposed legislation is here.
LCC has commented seven
times on accessory dwelling unit development since their inception. Most
recently gave input on the proposed changes to de-regulation. Their recommendations for
the City Council current amendments on CB 119544 can be found here.
LCC said:
LCC endorses retaining current regulations and supports the amendments proposed by Councilmember Herbold on changes proposed by Council Bill #119544 for building and operating accessory dwelling units.
New land use code changes should balance the livability and character of all residential neighborhoods. The proposed changes do not achieve that goal, unless CM Herbold's amendments are included.
The City proposes to make changes to the current ADU/DADU Municipal Code "to remove barriers to the creation of attached and detached accessory dwelling units."
LCC's key objections are:
- No requirement for owner occupation
- Too many dwelling units on one lot
- Lack of dedicated parking
- Legalizing up to 12 unrelated people on one lot
Removing the owner occupancy requirement will make single-family lots prime real estate for condo triplexes worth over $2.5 million in sales. Current City Council members scheduled to vote will no longer be in office when new regulations go into effect. There is no rush to implement these changes, which would do very little to ease any real or perceived housing shortage.
LCC recommendations include:
- Prohibit short-term rental use to better ensure that housing for Seattle residents is increased and not used for speculative profits.
- Require owner occupancy.
- Require ownership of property for one year before permitting a second ADU.
LCC suggests neighbors communicate their support for Councilmember Herbold's amendments in regulation changes proposed by outgoing Council member O'Brien regarding the building and operating accessory dwelling units in the City's single family neighborhoods. LCC added that everyone should make an effort to be heard, and opinions matter, so engagement in this important land use issue is important.
LCC recently sent this letter to several City officials:
Dear Mayor Durkan, Seattle Council Councilmembers, Seattle's esteemed Directors,
LCC is in support of City Councilmember, Lisa Herbold's amendments to CB # 119544, regarding the deregulation of the building and operating of accessory dwelling units in single family residential zones in Seattle.
The Laurelhurst Community Club supports accessory dwelling units located in this zoning, but requests that key components that make it work well, be retained, such as: on-site owner occupied, 40% maximum rear lot coverage, not more than 8 unrelated people on a lot, prohibition of short tern rentals, and leave out any FAR zoning changes since it is not relevant to this issue.
Thank you for your attention to this significant council bill, and we ask that as stakeholders, our views are integrated into its amendments.
Here is a letter LCC sent to Council member Mike O'Brien:
The Laurelhurst Community Club (LCC) represents over 2200 households endorses retaining current regulations on permitting attached accessory dwelling and detached accessory dwelling units (ADUs and DADUs). The new set of proposed changes to existing code regulations will result in immitigable impacts, including the further loss of Seattle's tree canopy, of which 50% is contained in single family zones. The doubling the number of residents by adding one or two extra dwelling units, and allowing 12 unrelated people per lot, plus the "related" people, in areas without the infrastructure to support environmental impacts will adversely affect the quality of life and health where all people live.
Seattle has built out, and absorbed much more of its planned growth targets from the Growth Management Act, while neighboring communities have actually passed housing regulations that are more restrictive on adding density and affordable housing units (Mercer and Bainbridge Islands).
Our city has worked diligently and extensively to build more density around frequent transit access, and clustering around specific urban villages to meet and exceed its predicted growth targets . For example, at the corners next to the Laurelhurst neighborhood, this year, there are building permits under way for 1,037 residential units, or, to house approximately 1970 new residents. This is a 50% increase in the existing neighborhood population, and these units are located closer to more frequent transit. The new ADU and DADU regulations, however, would attempt to double again the number of housing units, but within the single family neighborhood which are not zoned for doubling its population because they are not served well by frequent transit. Further its topography has extreme hills which are a barrier to biking, or even to pedestrians, in addition to the limitations of the sewer and electrical grid capacity.
Thus, increased density in urban centers and villages work effectively because the infrastructure can better accommodate it, while building two more accessory dwelling units, and adding 8 more unrelated people does not.
Seattle's existing housing stock is the most affordable option for most of its residents, but allowing the single family zoned lots to be subdivided into multiple owners will cause a run-up in valuations. Note that about 20% of Seattle sf homes are rented, providing a more affordable option for large families, and a disproportionate percent of lower income folks. If non-owner occupancy is allowed for ADU and DADUs, developers will then pick off existing home owners, for example, with an offer of $1.0 million for their small home, say on a 4,000 square foot lot. Then, the affordable residence will be torn down, and three new units, averaging $750,000 could be built, and sold to 3 different owners. Developers would pocket at least $500K per lot flipping. Meanwhile, the existing renters will be displaced, and then trying to find another house to rent will have to pay more as supply and demand raises prices due to fewer sf homes left, and they cannot fit into, nor afford the smaller ADU or DADU dwellings.
Thus, the regulations on single-family zoning should not be allowed to have both an ADU and a DADU built on one lot. Seattle's existing and planned density in other multi-family zones will already meet and exceed the housing units needed in the GMA predictions.
Secondly, there needs to be an owner living on the lot that contains an ADU or DADU.
Lot sizes are not that expansive, and allow a single lot to have both an ADU and a DADU, fundamentally changes the character of single family zoning. This change creates unmitagable impacts including loss of the urban tree canopy, privacy to adjacent property owners, parking issues, shading caused by the DADU on neighboring vegetation and the ability of neighbors to garden on their own property. Impacts on school enrollment were glossed over in these "land FAR analysis. In Seattle there are too many schools already housing their students in "portables", a detached classroom plopped on playgrounds. These students must leave these units for bathroom access and other school connections.
More bizarrely, there are more impacts on infrastructure and utilities that must be explored further before allowing up to 12 unrelated people to live in a small lot designed for a different use. In March 2019, King County utilities had a blockage and spill into nearby residential properties and Union Bay because pipes were clogged beyond capacity. Unrelated, non-owner occupied can also create "free for all" attitude with so many residents coming/ going at any hours, sharing their music with adjacent homeowners and strewing the vehicles where they can. Student unsupervised housing will be a prime use for this type of accessory dwelling unit.
Most City of Seattle neighborhoods were developed decades ago with less than standard size lots, and before car ownership and garages became the norm. Thus, residential streets are narrow.
A report by Gene Balk in the Seattle Times of August 10, 2017, states that between 2010 and 2015, Seattle's population grew by 12 percent, but the number of personal vehicles also grew by 12 percent to a ratio of 637 cars per 1,000 residents. He states, " that it is a higher per capita rate than Los Angeles", and that is "5,000 cars per square mile".
Does the proposed regulation change assume that cars can be parked on both sides of every street, making them impassable? It fails to comprehensively and accurately review allowing up to 12 unrelated people to live on the lot. If ONLY 1 in 3 of them owns a car, that is 4 more cars on a lot with no off-street available, onto existing residential streets.
Often, the lack of parking burden shifts to low income, wage earners who need their cars to drop off kids at school and daycare, run to various job sites, and stop at the grocery store on the way. With nowhere to park their vehicles without a required off-street parking spot, Seattle's single-family neighborhood streets will be reduced to one lane for through-passage or residents.
Parents and senior may have to park blocks away while hauling in groceries or assisting a disabled family member into the home. In Laurelhurst, for example, 42nd Avenue NE (which is the bus route for half of it) is impossible to drive through, except in one direction because of vehicles lining each side. Wallingford, Capitol Hill, Fremont and Queen Anne are also experiencing the same overflow of cars due to lacking driveway and garage spaces.
Adding more dwelling units without off street parking requirement will make this worse for existing homeowners, and impossible for small businesses to attract customers. No parking means no customers stopping to shop, or visit a restaurant, since transit ceases at nights after 6:30pm and there is no service on weekends.
Require owner occupancy. There are many issues raised by eliminating this requirement. The home with an ADU and a DADU, plus the principal home would essentially be a commercial venture, rather than single-family zoned.
Should the zoning then be changed to neighborhood commercial? Or, should the city consider upzoning certain areas? LCC does not support these uses. Transient, short term occupants for VBRO-style quick daily rental cash income defeats the premise of increasing affordable, permanent residences—another related issue not addressed in the regulation changes proposed.
With owners on the premises, there is "skin in the game" for having some good neighbor relationships with tidier maintenance, reasonable noise generation, garbage cans handled, etc. In contrast with absentee landlords, the homeowners in-residence can be expected to have an immediate, active interest in the extra unit. And it is more likely the owner will work to ensure that the impacts which result from this increase in the density of development will be manageable. We need that assurance of owner commitment firmly in the Code.
Minimum lot size should not be decreased, for DADUs. The existing code allows for a lot as small as 4000 square feet to build a "cottage". Reducing the lot size to 3,200 would ultimately increase lot coverage, thus resulting in impacts of a severe loss of privacy to adjacent properties. Mature trees would be have to be cut down, and structure would block light for neighbors, not acceptable as it is a real impact from ADU and DADU construction in both side and back yards.
Other cities such as Santa Cruz and Boulder require 6,000 square feet for backyard cottages, 6000-8500 in Denver and 10,000 in Lexington, MA, and Mukilteo. These areas are also rapidly adding population growth but are using a reasonable formula in adding more to the built environment.
Open back yards provide extra breathing room for those residents with kitchen gardens, and a place for their children to exercise and explore nature in their yard. Allowing too much built structure in the single-family lot zones just creates a “back door" opportunity for developers who have no stake in its outcome, except profitability, and these added accessory units cannot be reversed, once built.
The 1,000-maximum square footage should include garages and storage area and square footage for DADUs should not be increased . The final study for City Council should include how many garages and storage areas could or already have been converted to accessory units. Would exclusion of these areas allow creation of an additional accessory unit?
The maximum height of DADUs should not be increased by one to three feet. Currently heights range from 15 to 23 feet depending on lot width. It’s possible that an extra three feet could mean a second story on a DADU. The study for changed regulation should explore this issue and include the height resulting from pitched rooflines and appropriate mitigation. Particular attention should be paid to the privacy of adjacent neighbors, not just in the lot occupied home, for view lines, and light for gardens, trees and plans which are vital to a healthy urban environment. Changes to height limits and minimum lot size increases also have real impacts to character of the sf neighborhoods, sliding high FAR box homes to historic craftsman ones is often incompatible.
The regulations should further study the privacy impact of allowing DADU entrances on any façade. Currently, entrances cannot face the nearest side or rear lot line unless the lot line abuts and alley or other public right-of-way. This approach provides some protection to adjacent neighbors.
Allowing 12 unrelated people living in a DADU or ADU on a single-family lot creates transient, rooming house model, not neighborhoods. This number proposed is much more dense than existing codes. This density in these types of zoning can create City maintenance and utility issues. Twelve unrelated people will be a source of excess noise in a sf neighborhood, create parking clashes, stress overcrowded transit and roads, and can irregularly impact school enrollment. The DEIS should have instead included alternatives limiting the number to 5 or 6 unrelated people, instead of 12 people in an ADU or DADU.
The affordability issue for lower and middle-income families would remain unsolved in proliferation of less regulated ADUs and DADUs. These accessory units require financing and bank loans, just like any new house, and few lower income families qualify for a mortgage. It is a false assumption that adding more structures on single family lots does anything for housing the working class, but rather just gives homeowners a way to "flip" their back yards into another profit center for renters or student housing. Even if these units are rented, they are expensive to build, and rents would be high, so they do not add to the affordable housing stock. (The City’s own experts have concluded that these units would not be affordable, and that there would be significant potential displacement of existing homes which operate at lower cost.)
In addition , the regulations should study the impacts of the 50% of ADUs and DADUs are occupied by short term nightly tourist and visitor stays, as portfolio investments. This does nothing to increase housing choices and rental housing stock. This change of use to commercial will ultimately cause be the flight back to the suburbs for residents wanting a single family home lifestyle choice, increasing the commute, and adding to Seattle's carbon footprint. The character of Seattle's residential neighborhoods will be forever lost with such a change in use.
Conclusion: LCC requests that there be no changes in the City code in the regulations of accessory dwelling units. Both ADU and DADU units are being retrofitted into existing single family zoning, with generous allowances in the existing codes . There will be greater adverse impacts by eliminating owner occupancy, no parking space requirements, larger footprints and 12 unrelated inhabitants that can never be mitigated. New land use code changes should balance on the livability and character of all residential neighborhoods, and these proposed changes do not achieve that goal.
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