Dear Councilmembers,

Seattle Residents for Thoughtful Growth, representing residents from 22 neighborhoods, is deeply concerned about the direction and cumulative impact of several proposed amendments to the Comprehensive Plan and CB120985/CB120993. We support increased density focused on affordable middle housing. While some amendments are beneficial (like 110 for notice), others, as shown below, risk accelerating the loss of naturally affordable housing. In its place will come high-priced development that displaces renters and pushes out homeowners through rising property taxes and decreased livability.

CB 120993, intended to advance middle housing affordability, has instead been drafted in such a way that makes tall, detached, single-family homes the “highest and best use” of land[1]. Instead of removing this outcome from the playbook, many current amendments attempt to patch the problem with incentives—an effort that fails to address the underlying issue. The resulting outcomes will be even more damaging to Seattle’s current and future residents.

These changes will not produce the housing Seattle needs. They will fuel maximum buildout of market-rate units, often targeting the very places where lower-cost homes, more affordable rental units, and sensitive environmental areas exist. The likely outcome: displacement, tree canopy loss, and commercial shifts that erode both diversity and livability. Don’t let this be your legacy. We can fix this and meet Seattle’s needs with affordable middle housing and developer opportunities in the upzoned areas. You can always upzone more – but pavement is forever.

The most damaging amendments include:

• Middle-housing “bonuses” that overbuild (various amendments): FAR, setbacks, height, and lot coverage bonuses for middle housing are unnecessary in a bill already designed to enable it. Without limits—such as prohibiting lot subdivision below 2,500 sq ft while still allowing fee-simple ownership—these incentives simply encourage maximum lot coverage at the expense of tree canopy, green space, privacy and sunlight; and will result in buildings out of scale with existing homes. Let’s keep the tall, cubed-out buildings where they belong: in the LR+ zones, and reserve NR for affordable middle housing.

• Inflated height limits (Amendments 74, 78, 91, 93): Allows 40–47 feet (incl. roof) in Neighborhood Residential zones and pushes lowrise zones higher still, inviting bulkier, more expensive construction that displaces smaller, more affordable homes and existing middle housing, often for no increase in density.

• Removal of parking requirements (Amendments 7, 84, 85, 86): Eliminates parking citywide, even for institutions and businesses, pushing parking burdens into surrounding neighborhoods and reducing the viability of family-sized housing in a city with limited public transit.

• Environmentally Critical Area buildout (Amendment 72): Counts designated non-disturbance areas in steep slopes, wetlands and riparian zones toward density calculations, incentivizing development in hazardous and environmentally sensitive areas.

• ADU deregulation (Amendments 54, 55, 56, 57, 58, 59): Turns ADUs into effectively free additional primary units—making them larger, subdividable, and exempt from FAR, density calculations, and Mandatory Housing Affordability (MHA) requirements. This fuels lot-buildout without delivering affordability.

• Conflating Transit Routes (Amendments 60, 61, 76): Extending development entitlements intended for BRT and Light Rail facilities or frequent transit undermines the land-use goal of creating localized zones of density near appropriate transit.

We urge you to consider these amendments as a whole, not in isolation. Their combined effects could permanently negatively alter housing affordability and the livability of Seattle’s neighborhoods. We encourage you to pause on adopting CB120993 unit we can work together to turn it into an effective middle housing bill. We would like the opportunity to present our analysis and case studies to Council to ensure you are receiving a full picture of the likely outcomes. Let’s make sure CB120993 enables and encourages the housing we actually need while preserving what residents cherish about our city. Since we have interim legislation complying with state law, and CB120993 has dramatic impacts to every residential parcel in Seattle, let’s collaborate to make it work for Seattle’s current and future residents - not just serve developers.

Sincerely,

Seattle Residents for Thoughtful Growth

SRTG is  a coalition of residents of 22 neighborhoods advocating for equitable and compatible housing growth in Seattle. Neighborhoods represented include: Capitol Hill | Central District | Columbia City | Green Lake | Greenwood | Haller Lake | Madison Park | Madrona | Magnolia | Maple Leaf | Montlake | Mt Baker | Phinney Ridge | Queen Anne | Tangletown | Wallingford | Washington Park | Wedgwood |West Seattle – Fauntleroy | West Seattle - Seaview/Fairmount | Whittier Heights