Another Template Letter

City Council Members council@bellevuewa.gov
Planning Commissioners PlanningCommission@bellevuewa.gov

Subj: Request for Middle Housing Implementation

Dear City Council Members and Planning Commissioners,

I am writing to ask that you put a temporary policy in place and then add more density and/or housing incentives after a transparent public process. 

Bellevue’s version of Middle Housing density represents much more growth than the residents here were expecting from the public discussion around HB 1110 and 1337. Even if the greater amount of density is the right choice for us, there is a right way to communicate about it that won’t be possible now in the limited time before the deadline. We need to make people aware of what the changes will look like and give them a chance to weigh in on the potential effects. For instance, Tim shared his concerns about conflicts between parking and trash cans. We should listen to more residents to avoid getting tripped up by nuts-and-bolts issues and use their insights for good growth. 

The original laws were thoughtfully crafted, after a lengthy and very public democratic process, and a certain level of increased density was agreed upon for cities of different sizes, with mitigations for safety issues. Legislators had an ambitious but probably workable vision for how to add density. It encouraged sixplexes to be put where transit is very accessible, and allows four units elsewhere, creating a variety of options for Bellevue residents. Bellevue’s alternative proposal will put additional density in larger swaths of the city that do not have good transit access, guaranteeing that many more people will end up with a car-dependent lifestyle whether they want that or not. 

No mailers were sent to Bellevue households, and no notice about the survey was put on Engaging Bellevue. The outreach that’s been done could have been appropriate in a scenario where the density proposal was substantially similar to the original legislation. The state’s threshold for substantially similar was that it be within 25% of the target the state mandated for us. Instead, it appears we are more than doubling the impact of HB 1110 (see reasoning below).

Our public process should give everyone confidence that we can reasonably expect to handle the new growth with grace. We are proposing to add significant potential housing capacity before the 2034 Capital Facilities Plan update, and it will take additional years for our infrastructure to be expanded once that process is in motion. We also need expansion of community resources like schools, medical facilities, and parks.

There is a King County process for school siting under PF-22 that Bellevue has not participated in for the years 2023 or 2024. Is this being handled behind the scenes? After the housing capacity plans increased under the Comp Plan, it would have been good to see a public letter from the City of Bellevue to BSD that gives the school board some guidance for how to prepare – and then we could update it if massive new potential capacity is added by this Middle Housing policy in 2025. Otherwise, it would be reasonable for the school district to base anticipated growth on the Comp Plan projections (see below), which fall far short of what seems likely.

Tree canopy impacts are expected, but trees also grow very fast in Bellevue. We should have a full-court press to plant more trees each year, and to identify candidate locations while encouraging grass-roots participation in outreach and tree selection. Please do allow the tree credit fee system to be loosened, as the planners stated is their intention. Developers who create housing with a low tree canopy percentage should provide funding for tree planting elsewhere in Bellevue. 

With more time, we might be able to discuss adjustable housing incentives. There is uncertainty about interest rates, so we need a straightforward set of levers that we can use to ensure housing capacity in the future. 

1) We should monitor housing production and offer fee-in-lieu bonus units specifically for the housing types we feel are being under-produced. The number of fee-in-lieu units available to developers each year should vary depending on community needs. 

2) We should identify locations with both access to transit and proximity to neighborhood/growth centers that would be good places for us to extend sixplex and co-housing zoning in the event housing production falls below targets/expectations.

Having senior housing in neighborhoods is an important key to unlocking access to single family homes for young families without displacing people who want to stay as part of the community. Incentives for dedicated senior housing should be added. 

The cottage housing rules are vague and it would be best to defer implementation of this type of middle housing until we have some visuals representing the variety of potential outcomes. It would be easy to say that cottage housing is subject to the same FAR as single family homes until we’ve finished working out the details. 

Sincerely, 

(Your Name)

Doubling the impact of HB 1110

HB 1110 adds the potential for roughly 100,000 housing units because there are more than 30,000 SFH, and putting 3 additional units on each of these is 90,000. Some parcels would be allowed another two units because of proximity to major transit. 

The extra 100,000 is mainly from the addition of two ADUs per lot  = 60,000 potential units, but there are also a large number of lots, between 10-15k, that would get an extra two units based on proximity to frequent transit, neighborhood centers, the larger radius around major transit, etc. This adds 25,000+ potential units. On top of that is the expansion of the area where co-housing will be allowed. If we assume the co-housing density is functionally similar to a ten unit development (we’re allowed to count 4 co-housing residences as one middle housing residence, and it seems likely that you could realistically get 40 units on a typical 10-13ksf lot with a FAR of 0.9 and 250 sqft per unit), that adds another 25,000 potential units. 

Of course, this is only “potential housing units” or “capacity for” and this doesn’t take into account the CC&Rs and areas without sewer service, which could reduce that number. There is lot-splitting legislation up for consideration again in Olympia which could double that number. I do think it’s worth it for the city to identify these areas that may have limitations, so that we have some sense of what we’re agreeing to with any proposal. We should also include language similar to the model ordinance that states that these housing numbers don’t apply to lots that have been split. Either way, the Bellevue bonus density appears to be slightly greater than the initial middle housing potential created under HB 1110. 

Comprehensive Plan Growth Target 

The Figure LU-2 from the Comprehensive Plan does not match the current forecasts for growth potential; the Wilburton TOD alone has a theoretical capacity of 14,800, with more potential for growth in the rest of the Wilburton neighborhood. Still, it’s important to note that 200,000 >> 2,400. 

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