2021-04-07 Planning Commission MinutesPlanning Commission Minutes Page 1 April 7, 2021
CITY OF FEDERAL WAY
PLANNING COMMISSION
April 7, 2021 City Hall
6:30 p.m. Zoom
MEETING MINUTES
Commissioners present: Lawson Bronson, Tim O’Neil, Wayne Carlson, Diana Noble-Gulliford, Dale
Couture, Hope Elder, Jae So, and Anna Patrick. Commissioners absent: Tom Medhurst and Eric Olsen
(both excused). City Staff present: CD Director Brian Davis, Planning Manager Keith Niven, Associate
Planner Chaney Skadsen, Senior Planner James Rogers, City Attorney Eric Rhoades, and Administrative
Assistant II Tina Piety.
CALL TO ORDER
Chair Bronson called the meeting to order at 6:30 P.M.
MINUTES
The March 17, 2021, minutes were approved as presented.
PUBLIC COMMENT
None
COMMISSION BUSINESS
Discussion, Housing Action Plan (HAP) Strategies Briefing – Senior Planner Skadsen delivered the staff
presentation. This is for information only. The goal of the city’s HAP document is to layout a
comprehensive housing policy direction from which regulatory changes can be implemented. Federal
Way’s HAP includes:
• Housing Needs Assessment
• Stakeholder Engagement & Public Participation
• Housing Policy, Code, and Permitting Review
• Housing Objectives and Strategies
• Implementation Schedule
The HAP objectives are to:
1. Promote new housing that expands housing choices and is inclusive to community needs.
2. Encourage homeownership opportunities and support equitable housing outcomes.
3. Plan for continued growth and ensure that the built environment promotes community
development and increases the quality of life for Federal Way’s existing and future residents.
4. Preserve existing affordable housing stock to prevent displacement pressure.
Planning Commission Minutes Page 2 April 7, 2021
The Housing Needs Assessment determined that new housing production is not keeping pace with
demand, which increases competition and drives up housing prices. The city needs to add 6,800 new units
before 2040. The assessment also determined that 40 percent of all households are cost-burdened (over
13,000) with the greatest needs are households with an income below 50 percent of the Area Median
Income (AMI). In addition, it was determined that there are disproportionate impacts in the black,
indigenous, and people of color (BIPOC) communities.
Staff developed nine strategies with implementing actions that realize the identified objectives.
1) Promote a dense, walkable, mixed-use City Center.
2) Update development regulations and design standards to be responsive to changing conditions in
mixed-use and multifamily zones.
3) Increase diversity in housing choice through expanding missing middle development opportunities.
4) Encourage Accessory Dwelling Unit production.
5) Evaluate and consider revisions to the Federal Way Multifamily Dwelling Unit Limited Property Tax
Exemption (MFTE) program.
6) Review school impact fees on multifamily housing.
7) Coordinate affordable housing development and preservation with nonprofit developers, community
groups and the South King Housing and Homelessness Partnership (SKHHP).
8) Establish a Manufactured Home Park closure chapter in the zoning code.
9) Protect tenants through the development of a rental housing inspection program.
Chair Bronson opened the meeting to public comment.
Sam Pace, Housing Specialist with the Seattle King County REALTORS®. In summary, he is
supportive of the city’s HAP specifically, the goal of increasing residential building capacity in
the city and emphasizing Missing Middle Housing and ADUs. However, he is concerned the
HAP may not go nearly far enough with regard to capacity. He believes the city’s comprehensive
plan designations and accompanying zoning and development regulations place a cap on the
amount of new housing that can be built in the city. They provide an upper limit on how much
housing will be available in Federal Way. He encourages the city to “right-size” future downtown
and TOD housing capacity based on 50-year needs, rather than the 20-year framework that he
believes has proven to be a systemic failure for the last 30 years. One item that would help to
attract homebuilders would be “additional predictability” by “grandfathering” existing uses in
downtown and TOD areas, and then provide additional “overlay zoning” that allows development
to meet 50-year market demand as an “outright permitted use.” The city has non-financial tools
that hold enormous promise if used effectively. Those tools involve the regulatory authority and
power to authorize, and to provide, legal capacity for enough housing in the city to ensure that
everyone who needs a place to live will have access to housing they can afford. [His written
comments are attached.]
The Commission received two additional public comments by email that Assistant Piety forwarded to the
Commissioners. They are attached.
Commissioner Noble-Gulliford asked Mr. Pace to provide examples of non-financial tools. Mr. Pace
responded that fully utilizing ADUs, downzoning and up-zoning as appropriate, and planning using a 50-
year horizon are examples of some non-financial tools available to the city.
Commissioner Elder suggested a change to the code so that a property owner requesting an ADU is not
required to live on the property for at least six months out of the year. This would lead to more use of ADUs.
Planning Commission Minutes Page 3 April 7, 2021
Commissioner O’Neil suggested the city allow more flexible zoning specifically to allow residential in
the City Center zone, specifically for The Commons. He also suggested eliminating single-family zoning
and exempting ADUs from impact fees. Director Davis explained that city center zoning allows
residential zoning and due to financial reasons, The Commons hasn’t included residential, but expect they
will in the future when it becomes more financially feasible.
Commissioner Carlson expressed concern about Mr. Pace’s suggestion that the city use a 50-year timeline
for planning because the PSRC doesn’t use a 50-year timeline (they use 20 years) when developing area
housing and job numbers to be used for planning. This means the city would be planning for housing and
job numbers that may be different from the official area numbers.
Commissioner Patrick expressed concern that the city should consider equity compared to the
surrounding neighborhoods/cities and King County overall. Our policies need to set the city up for
success moving forward. She expressed concern over lack of tax revenue from the newer LIHTC
apartments. The city has a number of large apartment complexes where a large number of people live, but
the city does not receive property tax from these LIHTC apartments except for the retail portion. This
leaves us with a large population but no revenue from it for the duration of the tax exemption program.
The city needs to consider alternatives to pay for our “infrastructure” (roads, schools, fire, police, etc.).
We need look beyond the designated AMI tax bracket and examine the actual tax bracket of the rentals
compared to other cities and be on the defensive. The numbers do not match up.
Commissioner Noble-Gulliford expressed concern over the financial feasibility for different housing
types (duplexes, ADUs, cottage housing, etc.) and asked if there are construction and buyer loans
available for the different types. Planner Chaney replied she will have to research this.
Commissioner Noble-Gulliford also expressed concern the city/staff is implying that BIPOC communities
will receive special services. The City should not racially discriminate against anyone and the 1968 Fair
Housing Act has been in place for decades to prevent any discrimination. Planner Chaney replied that is
not the intent, but we need to be aware of how they have been treated in the past and not repeat it.
Commissioners Noble-Gulliford and Patrick suggested the city consider offering a program that will
educate people on home-buying (similar to what the city offers to educate on recycling).
Chair Bronson expressed the need for sewers in areas of the city still using septic systems.
Commissioner Patrick expressed concern over allowing ADU’s in neighborhoods without sidewalks.
Discussion, Preliminary Growth Targets Briefing – Senior Planner Rogers delivered the staff report. This
is for information only. The Growth Management Act (GMA) provides the foundation for the
development of regional planning policies via the Puget Sound Regional Council (PSRC), and those
policies shape King County Countywide Planning Policies (CPP), which in turn provides guidance for the
development of our planning policies. The CPPs, developed by the King County Growth Management
Planning Council (GMPC), establish growth targets for each jurisdiction. The growth targets currently
being established will be used for our update to the 2024 comprehensive plan. Our comprehensive plan
will link these growth targets to land use assumptions, guiding where people will live and work within
our city. This process happens every six to eight years, and coincides with the comprehensive plan update
schedule. The methodology to develop the targets is a five-step process:
Planning Commission Minutes Page 4 April 7, 2021
• Step 1 – Create Countywide Regional Allocations
• Step 2 – Select Data Factors
• Step 3 – Collect Data
• Step 4 – Convert Data into Percentage Shares
• Step 5 – Create Preliminary Targets
After two rounds of negotiations between local jurisdictions and the state, Federal Way’s current targets
are: housing at 11,260 and jobs at 20,460. At this point, the anticipated housing units have all been
allocated, but there are still 27,899 anticipated jobs yet to be allocated. The public comment period will
run through early May. This will be the city’s opportunity to adjust if needed. Amendments to the CPPs
targets, based on public comments, will be presented to GMPC for approval by June 24. The GMPC is
scheduled to adopt the CPPs and targets during the third quarter of the year. In the fourth quarter, the
adopted CPPs and targets will go to the cities for ratification.
Commissioner Carlson asked if there had been any direction from the City Council. He noted that
Issaquah took virtually no population and other communities varied considerably based on local growth
desires. Director Davis responded that staff had not formally presented the draft allocation to the Council.
Commissioner Carlson expressed surprise that the Council had not yet been advised about the discretion it
has with its population allocation within the Core Cities regional geography. Director Davis responded
staff has not yet formally presented these findings to the Council. Commissioner Noble-Gulliford asked if
these targets are in addition to our current targets? Planner Rogers replied that they are in addition.
STAFF BUSINESS
Director’s Report – Director Davis introduced our new Planning Manager, Keith Niven.
NEXT MEETING
April 21, 2021, 6:30 p.m., Zoom Meeting
ADJOURN
The meeting adjourned at 8:11 P.M.
K:\Planning Commission\2016\Meeting Summary 04-07-21.doc
TO: Planning@CityOfFederalway.com
Testimony of Sam Pace
City of Federal Way Planning Commission
April 7, 2021
Good evening,
My name is Sam Pace.
I’m a Housing Specialist with the Seattle King County REALTORS®.
I’m here this evening representing the 7,000+ members of our Association.
We would begin by noting that the focus of GMA Goal #4 in RCW 36.70A.020 (4) is focused on a
variety of housing options affordable to all economic segments of the population.
Because housing is a necessity of life, the very real need for housing doesn’t disappear, or decline,
just because rents and prices increase, which is what happens when there is not enough housing
for everyone who needs a place to live…and that has been the situation in Federal Way - and
throughout King County - since at least 2011 when the recovery began.
We believe the Council, the Commission, and City Residents join us in wanting Federal Way to
offer a great Quality of Life.
Quality of Life begins with a good job in a company that has a great future, and a home is where
that job goes at night. But we don’t have enough housing for everyone who needs a place to live.
In fact, even before the Legislature approved incentives for cities to adopt Housing Action Plans
in 2019, our research indicated an existing shortage of 240,000 housing units in King County
alone.
So, we are supportive of:
The goal of increasing residential building capacity in the city, and emphasizing Missing Middle
Housing and ADUs, but we are concerned the Housing Action Plan may not go nearly far enough
with regard to capacity.
It’s critically important that the Planning Commission, City Council, and the Housing Action Plan
expressly recognize that the City’s Comprehensive Plan designations, and accompanying zoning
and development regulations, place a cap on the amount of new housing that can be built in the
city. They provide an upper limit on how much housing will be available in Federal Way.
Here’s one bit of context to illustrate why we think it’s important to keep that “limiting function”
front and center. The Federal Way School District has more than 23,000 students. If just 15% of
those graduate every year, that’s 3,450 graduates, annually, but this Housing Action Plan seeks
to achieve 339 additional housing units each year.
The housing targets you have seen referenced in connection with the Needs Assessment and HAP
are minimums, not maximums, under state law…and they are only based on 20-year projections.
But housing units that get built under this HAP will remain in place for more than 50-years (which
is the functional and economic life of most residential construction).
For this reason, the City’s Housing Action Plan should avoid under-utilizing opportunities to
provide capacity that is responsive to actual demand, especially in areas where Transit-Oriented
Development is anticipated.
The place to begin to address this enormous disconnect between prior planning and actual
housing demand is to “right-size” future Downtown and TOD housing capacity based on 50-year
needs, rather than the 20-year framework that has proven to be a systemic failure for the last 30
years.
A continuation of that three-decades of failure throughout King County (this is not a challenge in
just Federal Way) will fall hardest on the most economically vulnerable members of the
community.
Federal Way has failed to keep pace with its housing targets.
One item that would help to attract homebuilders would be “additional predictability.”
The Housing Action Plan could help with predictability for both builders and current residents
(and minimize NIMBY concerns) by “grandfathering” existing uses in Downtown and TOD areas,
and then provide additional “overlay zoning” that allows development to meet 50-year market
demand as an “outright permitted use” - rather than a “conditionally permitted use.” As projects
start to pencil for builders (based on costs, regulatory exactions and market conditions), existing
property owners will gravitate towards voluntary sales, and the construction of new housing at
50-year densities will begin to occur.
Housing Policy and code review changes - including “Form-based Code” approaches – in the HAP
are encouraging, and appear well intended. Nevertheless, it’s important to remember that the
impact will be marginalized without both enormous increases in capacity, and predictability
about what can be built.
Finally, being intentional about additional “Missing Middle Ownership Housing Opportunities” is
critically important for “taking would-be buyers out of the rental market” so that less affluent
households (often very diverse households) are not forced to compete with more affluent would-
be buyers for the limited supply of rental housing.
Historically, government has only been able to provide about 5% of the housing supply. So, it’s
extremely unlikely the City will ever have enough money to buy housing for everyone who needs
it.
But the City does have non-financial tools that hold enormous promise if you have the courage
and foresight to use them effectively. Those tools involve the regulatory authority and power to
authorize, and to provide, legal capacity for enough housing in the City to ensure that everyone
who needs a place to live will have access to housing they can afford.
Thank you for the opportunity to offer these comments.
Sincerely,
SEATTLE KING COUNTY REALTORS®
Sam Pace
Sam Pace
sam@sampace.com (253) 569-2663
From:Gina Clark
To:Stacey Welsh; Tina Piety; Brian Davis; Keith Niven; Chaney Skadsen
Cc:Jim Ferrell; Jeri-Lynn Clark; Susan Honda; Marco Lowe
Subject:Draft Housing Action Plan
Date:Wednesday, April 7, 2021 2:24:48 AM
Attachments:image001.png
image002.png
image003.png
image004.png
image005.png
Federal Way Draft HAP Planning Commission April 7 2021.pdf
[EXTERNAL EMAIL WARNING] This email originated from outside of the City of Federal Way and may not be trustworthy.Please use caution when clicking links, opening attachments, or replying to requests forinformation. If you have any doubts about the validity of this email please contact IT Help Deskat x2555.
Good morning, Chair Bronson and Federal Way Planning Commissioners.
Attached, please find a letter of support for staff’s initial draft of the HAP, including additional comments
from MBAKS for Planning Commission’s consideration.
I’m officially on vacation after hitting send on this email, but will be returning next Monday. I will be happy
to answer any questions at that time.
Take care, and be well.
Gina
Gina Clark | Government Affairs Manager, King County p 425.460.8224 c 425.268.1156
335 116th Ave. SE, Bellevue, WA 98004
mbaks.com
We aspire to be the most trusted and respected housing experts in the Puget Sound region.
April 7, 2021
Honorable Lawson Bronson Chair
City of Federal Way
33325 8th Ave. S.
Federal Way, WA 98003
RE: Draft Housing Action Strategies
Dear Chair Bronson and Federal Way Planning Commissioners:
With nearly 2,700 members, the Master Builders Association of King and Snohomish
Counties (MBAKS) is the largest local homebuilders’ association in the United States,
helping members provide communities a range of housing choice and affordability.
MBAKS thanks the City for the opportunity to submit comments on the draft of the
Housing Action Plan (HAP).
MBAKS applauds planning staff’s efforts in the draft HAP and supports, in full, the
recommendations and priorities staff has proposed.
Federal Way needs more housing choice along a spectrum of affordability. With the
Puget Sound Regional Council (PSRC) still estimating 1.8 million more people and 1.3
million more jobs in our region by 2050, maximizing space matters to create homes
for people today and tomorrow matters. And it especially matters when the supply of
housing continues to be at record lows.
According to Up for Growth, our state underproduced housing by 225,000 units
between 2000-2015. If we continue with our historic building patterns, 67% of
housing will be single-family residential, 29% will be some form of missing middle
(duplex, triplex, ADU) and medium density (podium apartments), and 4% high density
(apartment towers).
According to the Northwest Multiple Listing Service, King County only had 0.85 month
of housing inventory available in February. An indicator for a healthy housing market
is six-month’s supply. MBAKS Monthly Builders Bulletin
Low supply helps inflate housing price. In February 2021, the median price of single-
family homes and condos was $679,075 in King County. For single-family homes only,
the median price in King County rose 11.11%, from $675,000 a year ago to $750,000.
In Seattle, the median single-family home price for February was $798,000, a 9.24%
increase from February 2020.
As families, first-time homebuyers, seniors, single-parents, teachers, police, fire,
nurses, and grocery clerks search for housing, they are increasingly looking for more
housing choice and affordability, as more are priced out of single-family home
ownership. And as seen in the past, as home rental and mortgage prices continue to
rise in Seattle and on the Eastside, those seeking more affordable living tend to move
further north, deeper into Snohomish County, or south, deeper into King County,
where prices remain slightly more attainable.
According to the National Association of Homebuilders annual report, Priced Out, the
median single-family home price for the combined Seattle-Tacoma-Bellevue area in
2020 was $542,762, requiring a minimum income of $116,574 to qualify for a
standard loan.
In 2020 there was a population of 1,571,761 in the Seattle-Tacoma-Bellevue region, of
which 639,320 people could qualify to buy a single-family home. But 932,441 people
could not qualify for homeownership at these rates.
Furthermore, for every $1,000 increase in the price of a home, another 1,557 people
are priced out of the market. However, this number does not consider many factors
we should, including an equity lens that considers long-standing exclusionary zoning
practices, redlining, preferential lending, and other significant challenges faced by
BIPOC communities as they compete for homeownership, search for affordable rents,
and struggle to narrow economic and opportunity gaps.
Federal Way’s Housing Needs Assessment, completed by the South King County
Coalition on Homelessness Partnership (SKCCHP), and the draft HAP, is an incredible
step in the right direction to identify the full range of need and provide the planning,
concrete steps, and implementation tools to fill that need.
MBAKS understands the difficult balance cities face balancing housing, infrastructure,
economic development, and the environment, among others. But given the ongoing
housing crisis that impacts every community now and for the foreseeable future,
including Federal Way, MBAKS urges the Planning Commission to support staff’s
initial recommendations and to go bold in vision, goals, and implementation.
In addition to staff’s recommendations and strategies, MBAKS would respectfully
add the following for consideration as the City seeks to add a range of housing types
along a spectrum of affordability:
• Remove Single Family Zoning: As staff’s initial draft moves forward, consider
bolder steps, and allow more housing choice everywhere in Federal Way
including in single-family zones. Housing choice, medium density units,
missing middle are not new concepts but were co-opted in the early 1900’s by
exclusionary zoning policies, redlining, and preferential lending practices.
Today, most area within cities are still zoned single-family residential and do
not allow housing choice within those zones, for rental or ownership. This
means most of our cities are locked to additional housing opportunities such
as ADU/DADU or cottage, carriage, duplex, triplex. As Federal Way continues
to grow and finds more pressure on available land and housing costs, consider
removing single-family zoning. Kirkland took these steps last March. Many
cities have or are also considering it.
Minneapolis: https://www.brookings.edu/blog/the-
avenue/2018/12/12/minneapolis-2040-the-most-wonderful-plan-of-the-year/
Berkley: https://www.mercurynews.com/2021/02/24/berkeley-to-end-single-
family-residential-zoning-citing-racist-ties/
Sacramento: https://sacramentocityexpress.com/2021/01/25/city-council-
shows-strong-support-for-allowing-more-housing-types-in-single-family-
neighborhoods/
Portland: https://www.strongtowns.org/journal/2020/8/13/5-things-you-
should-know-about-portlands-new-housing-reform
• Maximize Efficiencies: Missing middle housing is missing because it is difficult
to build. Land in our region is expensive, as is labor, supplies, regulations, and
fees (think Federal Way’s $16,000 per unit school impact fee as an example).
Availability of land is also shrinking and vacant and available lots often present
development challenges. Think critical areas, for example. Maximizing uses on
existing land within existing urban growth areas is vital to prevent sprawl,
utilize existing infrastructure, create jobs-housing and jobs-education balance,
and benefit from transit.
To help produce more affordable housing on expensive and valuable land,
cities and applicants need to maximize efficiencies. Jurisdictions and
homebuilders (market rate or affordable) need to collaborate to get the best
use of the land to help house the most people by offering as much choice and
affordability as possible at price points home builders can afford to build. A
couple of visuals recently published in The Urbanist illustrate the points.
Please keep in mind these are simply examples, with rough numbers and
square footages to provide illustration:
People-Housing Efficiencies: The first is an example of ways to maximize land
to provide housing choice to house more people.
Cost-Affordability Efficiencies: The second picture from The Urbanist
illustrates how to maximize costs of land and construction with that of home
ownership per unit.
In either scenario, and for any type of housing product, it is vital that
communities and homebuilders work closely and openly to maximize
efficiencies to meet needs.
Scrub Your Entire Code: Ensure the rest of your zoning, land use, building, and
development codes accommodates housing choice and affordability within
each planning area. Staff has indicated this is a priority, and MBAKS supports.
https://www.strongtowns.org/journal/2018/3/21/kick-the-tires-on-your-
local-zoning-code
In addition, when updating codes, consider amendments to simplify,
incentivize, and streamline process for short plats, fee simple townhomes,
duplex/triplex, ADUs/DADUs, transit-oriented development, and other
upzone, rezone, and infill opportunities.
https://www.psrc.org/sites/default/files/hip-townhomes.pdf
https://www.psrc.org/sites/default/files/hip-upzone.pdf
https://www.psrc.org/sites/default/files/hip-infill.pdf
• Form Based Code: Staff mentioned form-based code and Federal Way may
want to consider it depending on housing goals. As seen in Shoreline, form-
based code can help a jurisdiction provide housing for more diverse
households while providing a broader range of affordability. It can produce
more urban densities that support walkable communities, boost local retail
and commercial services, and build for existing or future transit needs.
Form-based code also gives a level of predictability. It allows jurisdictions and
applicants to work within known design, form, scale, bulk, placement, and
relationship of one building to another and of building to street. It focuses on
people, not uses, and allows for maximizing of space.
• End Parking Minimums: Parking is expensive to construct. It is not
environmentally friendly, is often underutilized, and takes up valuable land
where housing could be. When working with limited land area, smaller bulk,
form, design, space should be maximized for people and environment, not
cars, especially near transit. We should work together to more carefully study,
analyze, and consider alternatives before making room for more parking.
https://www.psrc.org/sites/default/files/hip-parking.pdf
https://www.strongtowns.org/journal/more-evidence-that-we-have-too-
much-parking
• Streamline Regulation: Consider streamlining the regulatory process for
medium density, missing middle, and affordable housing projects.
Homebuilding is expensive and takes a long time. Land costs,
permit/building/inspection fees, impact and mitigation fees, environmental
review, design and engineering, utilities, labor, supplies, to name a few. The
cost of lumber, for example, has risen 110% since last April, adding
approximately $16,000-$20,000 to the cost of a 2200 square foot single-family
home. Work with builders and developers, architects, engineers, and
affordable housing advocates to provide ways to reduce regulations and
streamline process to keep costs down, ultimately for the end renter or buyer.
As mentioned by staff, Federal Way’s impact fees on multifamily are cost
prohibitive to most builders and will absolutely prevent the City from reaching
its housing needs goals.
Bonding requirements in Federal Way are costly and prohibitive to many
homebuilders and should be amended sooner rather than later.
There are other streamlining and permitting amendments that can make a
significant difference in timing and cost to housing production. Federal
Planning staff has indicated their interest in working together to help move
these issues forward, and MBAKS looks forward to the opportunity.
https://www.psrc.org/sites/default/files/hip-reg-streamlining.pdf
• Incentivize Housing: Cities can help incentive the construction of more
affordable housing by offering incentives. If Federal Way has not considered
adding more robust incentives for housing choice, MBAKS would encourage it.
Washington state law (RCW 36.70A.540) gives cities and counties authority to
enact incentive zoning programs to encourage affordable housing. Incentive
zoning provides a menu of incentives and public benefits, which local code
must provide. These may include:
Density bonuses
Parking requirement reductions
Multi-family Tax Exemption
Planned Action EIS
Incentive Zoning
Public Land for Affordable Housing
Permitting Authority
Additional FAR
Additional height bonuses
Additional setback and lot adjustments
Property tax exemptions
Affordability incentives
• Value Small Parcels Too: Consider value and use in your small or irregularly
shaped parcels. Sites where builders and cities do not have to assemble land
for larger projects. Make room for smaller builders to build, and for
production of duplex, triplex, quad, townhomes.
https://www.strongtowns.org/journal/2019/2/14/savor-your-small-parcels-
and-create-more-of-them
• Value Smaller Units Too: Zone for and incentivize smaller residences
(generally 600 to 1,500 square feet) too, and at higher densities. These enable
homeownership and equity opportunities, including for BIPOC communities,
seniors to downsize and age in place, and provide housing for college
students, smaller families, and single parents. A system based on allowed
density either dwelling units per acre, or square footage per unit often
encourages developers to build units as large and as expensive as the market
will accept.
• Build Support: Continue to build community support for a range of housing
types, affordability, and diverse neighbors. The community survey staff
conducted was successful, easy to take, relatable, and produced some great
insight. SeaTac is also doing some great community engagement as part of
their HAP work and would be happy to discuss strategies, resources, tools.
Visit their website to learn more.
https://www.psrc.org/sites/default/files/hip-community-support.pdf
• Prepare for Displacement: Displacement can be physical or economic. And
displacement can be particularly real around areas of planned transit or in
more established, older areas of the community. There are tools to help
preserve existing affordable housing and to help prevent or curb
displacement. Communities around our region are addressing both in a
variety way with several tools to help. This newly released report on anti-
displacement strategies is particularly useful.
https://www.psrc.org/sites/default/files/hip-displacement.pdf
Finally, do not forget about our partners in the world of subsidized affordable housing
at or below 50% AMI. They have been valuable partners in our work to help produce
housing choice and affordability. Federal Way already works closely with SKCCHP, but
the Housing Development Consortium (HDC) is another great resource. Patience
Malaba is the government affairs director and Mallory VanAbbema is the policy and
advocacy manager.
patience@housingconsortium.org mvanabbema@housingconsortium.org
Thank you for your consideration and opportunity to share information. MBAKS truly
appreciates the opportunity. If you have any questions or comments, please feel free
to contact me at gclark@mbaks.com or (425) 268-1156.
Sincerely,
Gina Clark
Government Affairs Manager, King County
cc: Mayor Jim Ferrell
City Council
Brian Davis, Community Development Director
Keith Niven, Planning Manager
Chaney Skadsen, Associate Planner
Stacey Welsh, Principal Planner
Tina Piety, Administrative Assistant II
1
Chaney Skadsen
From:Brian Davis
Sent:Tuesday, March 30, 2021 12:28 PM
To:Chaney Skadsen
Subject:Fwd: Housing Action Plan Strategies - Draft
Attachments:Draft Housing Strategy for Internal Review FWPS comments.docx
Brian Davis
Community Development Director
City of Federal Way
Begin forwarded message:
From: Sally McLean <smclean@fwps.org>
Date: March 30, 2021 at 10:42:02 AM PDT
To: Brian Davis <Brian.Davis@cityoffederalway.com>
Cc: Danielle Pfeiffer <dpfeiffe@fwps.org>, Tammy Campbell <tcampbell@fwps.org>
Subject: Housing Action Plan Strategies - Draft
[EXTERNAL EMAIL WARNING]
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Hello Brian,
Thank you for the opportunity to review and comment on the draft Housing Action Plan Strategies. I
focused my attention and comments on the section related to multifamily impact fees. I also made
edits and added comments to the document itself if that is more efficient.
Here is a summary of comments and suggested edits:
1. Change the title from “impact fees” to “school impact fees”
2. Consistency with neighboring jurisdictions is NOT part of the jointly created (Master Builders and
School Districts) formula calculations. Indeed the formula recognizes that there are different costs and
impacts in different communities. I would prefer this be struck from the notes.
3. We are supportive of clarifying the designation (single-family or multi-family) of town homes,
duplexes and accessory dwelling units. Please note there are times that the single-family fee is higher
than the multi-family fee.
4. Can you provide information about the single family “deferred payment”? I wasn’t aware there
were any deferred payment option. In general, the District objects to this as an option, as the cost of
providing capacity occurs prior to occupancy in order to permit and install portables (6-8 months).
Thank you again for the opportunity to be part of this committee. I appreciate learning more about
housing needs within the City of Federal Way.
Sally D. McLean
Chief Finance & Operations Officer
2
Federal Way Public Schools
(253) 945-2042
(253) 391-6989 (cell)
From: Brian Davis <Brian.Davis@cityoffederalway.com<mailto:Brian.Davis@cityoffederalway.com>>
Sent: Tuesday, March 23, 2021 8:12 AM
To: Sally McLean <smclean@fwps.org<mailto:smclean@fwps.org>>
Subject: Housing Action Plan Strategies - Draft
STOP. THINK. VERIFY.
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Sally,
Our Housing Action Plan consultant has gathered feedback from the advisory committee, Planning
Commission, City Council, and regional data. They have come up with the attached list of strategies and I
wanted you to have a chance to review it with your team since one of the strategies is “Analyze Impact
Fees on Multi-family Housing.”
Please let me know your thoughts. The next step is to present this to the Planning Commission in
preparation for the full plan (which we have not received yet) to be adopted. If possible, please send me
your feedback by next Tuesday.
I appreciate your assistance and perspective on this.
Brian Davis
Community Development Director, City of Federal Way
33325 8th Ave So., Federal Way, WA 98003
253-835-2612 | Brian.Davis@cityoffederalway.com<mailto:Brian.Davis@cityoffederalway.com>
April 22, 2021
1
Federal Way Housing Action Plan
Proposed Housing Strategies for Planning Commission Consideration
This document presents a set of proposed objectives for addressing housing needs in Federal Way to increase
residential building capacity and promote the development of market rate housing with provisions for income
restricted affordable housing and preservation of naturally occurring affordable housing. These objectives and
strategies were informed by the Housing Needs Assessment, Housing Policy, Code, and Permitting Review, the
Visual Preference Survey, and additional engagement with the Advisory Committee, City Council, Planning
Commission, stakeholders. The five proposed objectives for the Housing Action Plan are shown in Exhibit 1.
Exhibit 1. Proposed Objectives for the Housing Action Plan
Objective Description Needs Addressed
Increase
Production/Diversity
Encourage new housing
development in a variety of
formats to expand housing
choices for a diversity of
household types and income
levels.
Historic underproduction of housing has contributed to rising
housing costs.
Federal Way needs to increase annual housing production to meet
forecasted demand.
Increasing housing diversity is needed to expand housing choices
(renter and ownership) for all income levels
Homeownership
Opportunity
Support greater equity in
homeownership opportunity.
Shortage of lower-cost homeownership opportunities
Lack of pathways to attainable homeownership
Disparities in homeownership due in part to barriers experienced
by BIPOC households
Enhance Character Enhance the character and
livability of existing
neighborhoods.
Ensuring new housing is woven into the existing fabric of Federal
Way to promote community cohesion, integration, and vitality.
Complete Communities Promote complete
communities by tying
housing production to
improved infrastructure,
resources, and amenities.
Both new and existing residents need access to infrastructure,
services, and amenities that enable them to thrive.
These may include frequent transit, parks and open space,
neighborhood-serving businesses, schools, social services, etc.
Prevent Displacement Help residents to stay in
their homes through the
preservation of existing
affordable housing and
actions to reduce
displacement pressure.
Many lower-income residents face eviction and displacement
pressures as housing costs escalate rapidly.
There are significant racial disparities in displacement pressure.
About 4% of Black households see an eviction filing each year,
compared to only 1.5% of White households.
Exhibit 2 lists a set of preliminary draft housing strategies for achieving the five objectives. The table notes the
objective(s) to which each strategy is most closely related. Then the following pages provide detailed
descriptions of each strategy
Internal Draft April 22, 2021 Federal Way | Housing Action Plan 2
Exhibit 2 Proposed Housing Strategies for Consideration and Related Housing Objectives
Visualize which category of housing development the strategy is designed to directly support. The categories are
market rate, income restricted affordable housing, and those that apply to both.
Strategy Increase
Production/
Diversity
Homeownership
Opportunity
Enhance
Character
Complete
Communities
Prevent
Displacement
Encourage Transit-oriented Development
Revise Parking Minimums
Add Flexibility to Ground Floor
Requirements
Allow “Missing Middle” Housing Types
Increase Ownership Opportunities
Encourage Accessory Dwelling Units
Incentivize Inclusive and Accessible Housing
Options
Update Design Standards
Encourage Affordable Housing Development
Plan For, and Invest in, Complete
Communities
Analyze Impact Fees on Multifamily Housing
Establish a Manufactured Home Park Zone
Support Affordable Housing Preservation
Strengthen Tenant Protections
Internal Draft April 22, 2021 Federal Way | Housing Action Plan 3
Encourage Transit-oriented Development
What?
Encourage higher density
development and safe and pleasant
connections to high capacity transit. In
general, transit-oriented development
(TOD) areas are ¼ to ½ mile around
frequent, high capacity transit.
The greatest opportunity lies in
Federal Way’s City Center (future)
light rail station area, the southern
green circle in Exhibit 3. Secondary
opportunities exist for the area
around the future South 272nd St
Station and along the existing
RapidRide A Line.
Though Figure 1 focuses on the
northern part of the city, additional
routes to address in long-range
planning include:
• Planned RapidRide along S
320th St connecting to Auburn
(Metro Connects 2025 Plan)
• Pierce County Transit routes, including Route 500 and 501 to Tacoma and 402 to Puyallup. Two routes
run along Pacific Highway south of the transit center and then split ways, and one runs along 20th Ave S.
Why?
Lower car ownership rates, increasing transit ridership (outside of the COVID-19 pandemic), concerns about
greenhouse gas emissions from driving alone, growing interest in mixed-use neighborhoods, and desire for
active, healthy ways of getting around are trends in the Puget Sound region pointing to community support for
transit-oriented development. Currently adopted plans and development regulations for the City Center zones
also point to a less auto-focused downtown. People are generally willing to walk up to 10 minutes (1/2 mile) for
frequent, high capacity transit, and bike from up to 3 miles away. For local, frequent bus routes, people are
willing to walk up to 5 minutes (1/4 mile). However, if low density development is built within station areas, that
removes the opportunity for more people to live or work near transit for the foreseeable future.
Higher levels of activity—i.e., increased number of homes and businesses/organizations/institutions—combined
with safe and pleasant connections and gathering spaces near transit achieves the following:
Livable, vibrant, people-friendly places that serve the full spectrum of Federal Way’s residents and
businesses.
Increased access to opportunity—the ability to easily reach jobs, education, healthcare, and services—
through improved transit access.
A critical mass of transit riders to support the transit investment. PSRC calls for high capacity transit-served
Exhibit 3 High capacity transit walksheds
Internal Draft April 22, 2021 Federal Way | Housing Action Plan 4
areas to have densities exceeding 15 to 20 homes per acre and/or 50 jobs per acre, and if designated a
Regional Growth Center, densities of at least 45 people (resident/employee) per acre (VISION 2040,
pg 81).
If done right, transit-oriented development leverages existing assets like local businesses, cultural anchors, and
parks and adds to their vibrancy (and doesn’t displace them). Complementary development supports existing
businesses and enlivens public spaces.
How?
Encourage transit-oriented development for market rate development and affordable options through a
combination of complementary actions, including:
Plan for, and invest in, complete communities, with an emphasis on the following:
In the City Center Subarea Planning effort, explore specific opportunities, challenges, and strategies to
support transit-oriented development. Revisit the City Center-Core (CC-C) and City Center-Frame (CC-
F) zone building heights, streetscape, usable open space, and parking standards to ensure higher
design quality for this important TOD area.
Support additional long-range planning around transit, including the planned S 272nd St Station existing
and planned bus rapid transit.
In station area planning efforts, identify physical barriers, solutions, and funding mechanisms for
ensuring safe and pleasant paths for people walking, biking, and rolling to transit.
Change Comprehensive Plan classifications within a ½ mile and ¼ mile of transit to allow higher density
zoning.
Related strategies include:
Relax Parking Minimums
Add Flexibility to Ground Floor Requirements
Update Design Standards
Analyze Impact Fees on Multifamily and Attached Housing
Encourage Affordable Housing Development
Case Studies
Lynnwood planned for coming light rail, developing the City Center Subarea Plan (2005), Streetscape Plan
(2014), Lynnwood Transit Center Multimodal Accessibility Plan (2016), City Center Subarea Implementation
Strategies Report (2017), City Center Parks Master Plan (2018), City Center Design Guidelines (2019), and
others. These planning efforts set the vision for the area and development and design standards, and has
attracted hundreds of new units just prior to light rail arrival in 2024.
Many Puget Sound cities require minimum densities around transit, including Mountlake Terrace, Bothell,
Bellevue, and Redmond. Mountlake Terrace Town Center uses a minimum height – four stories – rather than
a minimum density, paired with a prohibition on surface parking near the future light rail station.
Minneapolis requires minimum densities around rail transit stations, ranging from 50 dwelling units per acre
in the Urban Center to 15 dwelling units per acre in the outer suburbs.
Internal Draft April 22, 2021 Federal Way | Housing Action Plan 5
Revise Parking Minimums
What?
Revise the parking requirements for off-street parking for Multifamily and Mixed-Use developments particularly
for developments in close proximity to high-capacity transit.
Why?
Parking is an expensive component of real estate development. Excavation for below-ground parking is
expensive, and above-ground structured parking occupies valuable building space. Both typically need to be
built with costly concrete construction. Even less expensive surface parking requires large areas that could be
used for open space or leasable building space.
Renters in most cities, including Federal Way, typically have fewer cars per household than homeowners,1 and
the availability of free parking encourages people to acquire more cars and drive more than they would
otherwise.2 Allowing developers and the City to continue reduced parking requirements where appropriate can
reduce housing costs and traffic impacts of new development.
How and Where?
The following adjustments would bring Federal Way’s parking standards closer to trends in comparable cities:
Apply new Washington state parking minimum limits within ¼ mile of frequent transit, which include light rail
and Rapid Ride for market rate and affordable developments (law takes effect July 2021).3
Implementation method: code amendment
Revise and simplify dwelling unit definitions and types outlined in FWRC 19.05.040.
Revise parking standards to encourage reductions for studios and one bedrooms and flexible
adjustments for 2+ bedrooms
Continue support of Transportation Demand Management plans to allow reduced parking
requirements where appropriate.
Case Studies
Parking minimums vary widely from city to city. Many jurisdictions have worked towards reducing or eliminating
parking minimums in recent years.
In 2019, Anacortes reduced parking minimums to 1 space per studios or 1-bedroom unit, 1.4 spaces per 2-
bedroom unit, and 1.6 spaces per 3-bedroom unit.
An Oregon law passed in 2019 reduced parking minimums for missing middle housing for most cities in the
state to one per unit.
In 2021 the cities of South Bend, Indiana, and Berkley, California eliminated parking minimums city-wide.
1 US Census, ACS 2019 5-Year Estimates, Table B25044
2 Adam Millard-Ball, J. W. (2020). What Do Residential Lotteries Show Us About Transportation Choices?
https://doi.org/10.7922/G2319T55
3 http://lawfilesext.leg.wa.gov/biennium/2019-20/Pdf/Bill%20Reports/House/2343-
S%20HBR%20FBR%2020.pdf?q=20210308171353
Internal Draft April 22, 2021 Federal Way | Housing Action Plan 6
Add Flexibility to Ground Floor Requirements
What?
Relax strict ground floor commercial requirements in most commercial zones to allow greater flexibility for
residential uses.
Why?
While a mix of uses can help improve walkability and vibrancy, requirements for ground-floor retail in new
multifamily projects can prevent development by reducing the financial feasibility of projects with space that is
less profitable to developers. Ongoing transformation in the retail sector
triggered by the rise of online shopping and big-box stores make street level
retail a risky real estate asset. Newly constructed ground floor retail spaces in
mixed-use buildings sometimes sit vacant, degrading the pedestrian environment
that ground-floor retail requirements were intended to improve. Flexible or
highly targeted requirements can concentrate retail space on the most viable
corridors and reduce costly mandates in other areas.
In Federal Way the City Center-Core (CC), City Center-Frame (CC-F), and
Community Business (BC) zones currently require at least 60% commercial
frontage on ground floor of all streets.
How?
Consider applying a ground floor commercial requirement along only those
street frontages that are most critical and allowing flexibility on secondary
streets where street level retail may be less viable.
Implementation method: overlay district map
Couple these flexible provisions with design standards to emphasize stoops
and other similar active/pedestrian-friendly ground level frontages for
residential uses.
See “Update Design Standards”
Case Studies
Wenatchee’s 2019 housing code update includes design guidelines to
ensure pedestrian-friendly design in higher density and mixed use zones.
Specific pedestrian-oriented streets in the historic downtown require non-
residential use and have more stringent design guidance.
Anacortes’ code includes standards for live-work units, which accommodate
ground-floor residential use with the flexibility to convert to commercial use when market conditions permit.
Wenatchee Block-Frontage
Standards Map
Internal Draft April 22, 2021 Federal Way | Housing Action Plan 7
Allow “Missing Middle” Housing Types in Single Family Zones
What?
Expand opportunities for market rate development of Missing Middle housing types such as duplexes, triplexes,
and/or other small home-types in the Residential Single Family (RS) zones where appropriate.
Duplexes and townhouses are examples of “missing middle” housing, connected homes that are not allowed in the
vast majority of Federal Way’s RS zones (shown in yellow in the map on the right).
Why?
In Federal Way and many communities, the only housing choices are single-family homes on large lots or medium
to large multifamily buildings. Such limited options do not reflect the wide range of needs of differing family
sizes, household incomes, and cultural groups. One solution is encouraging a larger variety of housing types,
often referred to as the “missing middle” as they are middle-sized housing, aimed at people with middle-
incomes. They are also some of the most affordable forms of housing in terms of construction-cost-per-square-
foot. In general, these types are more affordable than detached single-family homes and offer a greater range
of design and locational choices than apartment buildings can offer. They also offer more flexible ways for
communities to add compatible density into established neighborhoods and provide more opportunities for
residents to have stability and build wealth through homeownership.
This action, if adopted before April 1, 2023, is exempt from SEPA appeal.
How?
Remove barriers for missing middle housing types in single-family zones.
Implementation method: code amendments and review process
Allow attached dwelling units like Missing Middle in single-family zones
Encourage Missing Middle typology of 4 units and more on lots in close proximity to schools, parks,
transit stops, or commercial uses.
Allow development of duplexes and triplexes under the same process as single-family homes,
rather than requiring director approval, which adds time and cost to development.
Consider applying single-family impact fees to all Missing Middle housing typology.
Revise minimum lot size for townhouse developments from the current standard of 5,000 sf per unit
to improve the financial feasibility of this type of development and opportunity for infill
Ensure compatibility with existing neighborhoods
Implementation method: code amendments
Internal Draft April 22, 2021 Federal Way | Housing Action Plan 8
See “Update Design Standards”
Add design standards for façade modulation, covered entries, pitched roofs, and integration of
design details. These should also include strict standards on garage/driveway width and design
were a top priority among survey respondents.
Revise front and side yard setbacks for duplexes, triplexes, and townhouses
Case Studies
In 2019 Wenatchee revised its zoning code to allow duplexes, triplexes, cottage housing, and townhouses in
almost all low-density residential zones.
An Oregon law passed in 2019 requires all cities above 25,000 to allow duplexes, triplexes, fourplexes,
and cottage clusters to be built on all land that allows detached houses.
In 2018 Minneapolis amended its comprehensive plan to allow duplexes and triplexes in formerly single-
family zones.
Internal Draft April 22, 2021 Federal Way | Housing Action Plan 9
Increase Ownership Opportunities in Multifamily Zones
What?
Encourage development of market rate townhome and condominium development to increase entry level
homeownership opportunities at a lower-cost.
Why?
Homeownership is highly desirable for many Federal Way households. It can provide greater economic security,
residential stability, and an important financial asset to the homeowner. However, rising demand for homes has
pushed home prices out of reach for low- and middle-income families. With a rising population and a fixed
supply of land, new homeownership opportunities can best be pursued by increasing the number of shared-wall
ownership options like townhouses and condominiums.
Shared wall homes are also more energy efficient that free-standing houses and are cheaper to build. Federal
Way’s rules for townhouses and condominiums are complex and restrictive, which makes new construction slower
and more expensive than in other cities.
How?
Consider form-based code provisions in which density is governed by height limits, parking and conformance
with stronger site and building design standards.
Implementation method: code amendment
Particularly, implement in downtown, high density, multifamily and TOD areas.
Case Studies
Condominium development has slowed significantly in the past decade due to litigation-related costs for
developers. Senate Bill 5334, passed in 2020, attempted to address flaw’s in Washington’s legal
framework for condominiums and may lead to increased production in coming years.
Townhouses have been widely built in the Puget Sound region over the past several decades. Issaquah,
Redmond, and Seattle have high-quality examples of townhouses that provide ownership opportunities, high
population densities, direct street-level access, and attractive visual character.
Internal Draft April 22, 2021 Federal Way | Housing Action Plan 10
Encourage Accessory Dwelling Units
What?
Encourage the construction of market rate and accessible housing options by removing code barriers for
accessory dwelling unit (ADU)
ADUs are small dwelling units such as a basement apartment, garage apartment, or backyard cottage that
share a parcel with a house (the primary dwelling unit). Detached ADUs, like a backyard cottage or garage
apartment, aren’t connected to a house. Attached ADUs are contained within the house structure but have
separate living facilities, like a basement apartment.
Why?
All cities in Washington above 20,000 population are required to allow ADU construction, but in most cities few
ADUS have been built because restrictions like owner-occupancy and parking requirements can make adding an
ADU difficult to finance or accommodate on a site. For ADUs to play a role in reducing housing scarcity,
restrictions that severely limit ADU construction should be reconsidered.
Owner-occupancy provisions require that the homeowner lives on-site if an ADU is to be rented to the tenant.
Federal Way requires owner-occupancy, however, these provisions make it more difficult to finance construction
of an ADU, add to the permitting process, and are generally considered to be unenforceable. Owner-occupancy
requirements applied to ADUs are also an unusual housing provision because homeowners are rarely prevented
from renting out detached houses or condominiums.
This action, if adopted before April 1, 2023, is exempt from SEPA appeal.
How?
Remove barriers
Implementation method: code amendments
Eliminate owner-occupancy requirement for ADUs.
Consider reducing school impact fees on ADUs.
Allow on-street parking in front of the house, if available, to count toward the parking requirement.
Increase maximum allowed ADU size possibly from 800sf to 1,200sf remove minimum size
Revise accessory use code to more easily permit ADU’s over garages.
Promote ADU development
Implementation method: permitting and promotional activities
Simplify ADU permitting through providing community preapproved ADU plans at low cost
Include plans that are designed accessibly for those living with a disability and mobility needs
and that serve populations aging in place
Coordinate with ADU developers in the region for community preferences.
Establish ADU program to advertise to the community
Internal Draft April 22, 2021 Federal Way | Housing Action Plan 11
Case Studies
In 2017 Vancouver, WA removed ADU owner-occupancy and parking requirements and allowed larger
ADUs to be up to 50% of the size of the primary house.
In 2018 Olympia removed owner-occupancy requirements, eliminated parking requirements, and increased
allowed heights for ADUs to 24 feet.
In 2019 Burien removed its owner-occupancy requirement, parking requirements (near transit stops), and
allowed two ADUs on a lot if one is a detached ADU and the other is attached.
In 2020 Kenmore modified its owner occupancy provision so that it only applies in the first six-months after
construction and removed minimum lot sizes.
Internal Draft April 22, 2021 Federal Way | Housing Action Plan 12
Incentivize Inclusive and Accessible Housing Options
What?
Incentivize diversity of market rate and income restricted affordable housing options and sizes that align with
community profile and housing need.
Why?
Federal Way has a diverse community profile from single individuals to multigenerational families with varying
housing needs. It is important the housing supply include a variety of housing sizes, designs, and typology for
both renters and owners. The housing stock lacks small units like studios and unit sizes suitable for larger families.
How?
Remove barriers for development of smaller entry level housing options and incentivize income restricted units
include a variety of sizes.
• Remove barriers for ADU development to support intergenerational households and populations desiring
to age in place.
o Implementation method: code amendment
See “Encourage Accessory Dwelling Units” for removing barriers promoting ADU’s
including accessibility needs
• Encourage a balance of unit size options in such as, multifamily developments, townhouses, duplexes,
triplexes.
o Implementation method: code amendments and programmatic
Consider providing standards for unit size variety in developments over a certain size for
owners and renters.
See “Revise Parking Minimums”
See “Encourage Affordable Housing Development”
Internal Draft April 22, 2021 Federal Way | Housing Action Plan 13
Update Design Standards
What?
Pair all regulatory strategies to encourage new types of housing development with updated design standards to
ensure compatibility and livability.
Why?
Design standards help ensure that new housing contributes to a community’s vision for desirable, healthy, and
safe neighborhoods. While they do not create additional housing, design standards can help to mitigate impacts
of density, building massing/scale, parking and vehicle access areas, and service elements. Balanced design
standards should promote good design without imposing prohibitively costly standards on new developments.
Federal Way’s existing design guidelines (Federal Way Municipal Code Chapter 19.115) focus on safety and
orderly development. As zoning codes are adapted to encourage housing production, design guidelines should
be updated for clarity, easy implementation, and accordance with best practices for livable and transit-oriented
neighborhoods.
How?
Develop design standards in conjunction with any Housing
Action Plan-related code revisions to ensure accordance
with plan goals.
Open space standards are an important consideration for
design standards. These should be scaled based on the size
of the development and should provide clear expectations
for the types of space required. Private open space (such
as balconies or yards), common indoor amenities (like
weight rooms), and landscaped shared open space (like
rooftop decks), serve different purposes and are
appropriate for different kinds of development. Different
housing types also offer advantages and constraints for
providing open space.
The best design standards offer a strategic mix of predictability and flexibility. This includes integrating
clear minimum standards for site and building design so that the community knows what to expect as
development occurs. Options for flexibility provide the applicant ways to have some adjustment while still
meeting the intent of the standards. Such provisions are often called “departures,” “alternative designs” or
“administrative adjustments.”
Example open space standard for duplexes
showing minimum width and depth
Internal Draft April 22, 2021 Federal Way | Housing Action Plan 14
Encourage Affordable Housing Development
While increased production of market-rate housing is an essential part of this Housing Action Plan, the housing
market in Federal Way provides very few options that are income restricted affordable to very low-income
individuals and families. There are a variety of options that the city can pursue, and it is likely that a combination
of actions will be most effective. These actions could include alternative development standards or incentives for
new affordable housing, such as:
What?
The City has a variety of policy and code requirements to ensure affordable housing development such as:
• Inclusionary zoning requirements per FWRC 19.110.010(2) from 2 unit or 5% of total (whichever is
greater) of rental units affordable at 50% AMI for developments 25 units or more for developments.
• Density bonus per 19.110.010 (3)(a) One bonus market rate unit for each affordable unit included in the
project; up to 10 percent above the maximum number of dwelling units allowed in the underlying zoning
district.
Why?
Make it easier and less costly for nonprofits or other developers to construct new housing that includes units with
rents that are regulated to stay affordable for lower-income residents.
How?
Revise the multifamily tax exemption (MFTE) program to incentivize projects affordable to 0-50% AMI level
rather than only to 50% AMI and higher as has been built recently.
Provide front of the line treatment permitting for developments exceeding minimum affordability
requirements.
Identify suitable public or nonprofit land that could be donated or leased for affordable housing
development
Plan For, and Invest In, Complete Communities
This strategy would dedicate additional resources for Long Range Planning staff to work with residents to
develop community-backed visions and plans for station areas, neighborhoods, and city as a whole. The goal of
this work would be to chart a path for development and city investment which aligns areas expected to see new
housing production with improvements to infrastructure, resources, and amenities. These improvements could
include:
Investments in infrastructure such as lighting, roadways, transit, sidewalks, or parks.
Neighborhood-serving commercial areas with appropriate services and amenities catering to residents’
needs.
Internal Draft April 22, 2021 Federal Way | Housing Action Plan 15
Analyze School Impact Fees on Multifamily Housing
New population growth in a community increases demand for public infrastructure and services. Charging impact
fees on new residential development can be an important tool for partially funding these growth-related needs.
However, impact fees also increase the cost of providing new housing. And when the rates are set significantly
higher than neighboring jurisdictions, they can discourage developers from building any new housing.
Federal Way has seen no new multifamily housing development (such as apartments, condominiums, or
townhomes) other than senior housing projects following the adoption of school impact fees in 2017. Stakeholder
input indicates that local developers do not consider Federal Way to be a viable location for multifamily
development due in part to the significantly higher school impact fees compared to other jurisdictions in the
region. The primary factor for these higher rates is the number of new students generated by the new housing,
which is almost six times the King County average. In December 2020 the Federal Way City Council adjusted its
school impact fee rate schedule for multifamily housing, creating tiers based on bedrooms. However, the rates
remain significantly higher than those imposed in neighboring jurisdictions.
Implementing this strategy would include a review and adjustment of the school impact fee rate schedule for
multifamily housing with consideration for consistency with neighboring jurisdictions, and the city’s policy goals of
encouraging housing production and diversity. The City should also clarify whether multifamily impact fee rates
apply to housing formats such as townhomes and duplexes.
Additionally, deferred payment of school impact fees option should be allowed for multifamily developments
opposed to only single family per (FWRC 19.95.055).
Support Affordable Housing Preservation
Federal Way provides housing that is relatively naturally occurring affordable compared to many other
communities in the region. Much of this housing is at risk of becoming less affordable due to rapidly rising housing
costs, affordability requirements that are due to expire in coming years, or redevelopment pressures in light rail
station areas. Maintaining existing unregulated (or “naturally occurring”) and regulated affordable housing units
can often be cheaper than constructing new units (although both are needed).
This strategy prevents the potential displacement of Federal Way residents by identifying opportunities to
support the purchase of existing housing and ensuring it remains affordable in years to come. It builds on
strategies featured in the South King County Subregional Housing Strategies Framework.4 Success will require a
combination of actions, such as:
Work with South King Housing and Homeless Partner (SKHHP) network to develop a revolving loan fund for
preservation opportunities
Monitor expiring regulated affordable housing properties
Monitor expiring unregulated “naturally occurring” affordable housing properties
Require notice of intent to sell for properties with rents under certain amounts.
-4 ECONorthwest, 2020. South King County Housing Action Plan – Task 3.2 Housing Strategies Framework.
Commented [SM1]: Consistency with neighboring
jurisdictions is NOT part of the formula calculations. I would
prefer this be struck from the notes.
Commented [SM2]: Supportive of this clarification
(although at times the single family fee can be higher than
the multi-family fee)
Commented [SM3]: Can you provide information about
the single family “deferred payment”? I wasn’t aware there
were any deferred payment option. In general, the District
objects to this as an option, as the cost of providing capacity
occurs prior to occupancy in order to permit and install
portables (6-8 months).
Internal Draft April 22, 2021 Federal Way | Housing Action Plan 16
Establish a Manufactured Home Park Zone
What?
Establish a new zone and apply it to all or some of the mobile and manufactured parks in Federal Way to
support displacement prevention and/or mitigation.
Why?
Manufactured Home Parks (MHPs) provide natural affordable housing in Federal Way including a form of
affordable homeownership. The availability of mobile and manufactured housing has been decreasing across
King County as park land is redeveloped into less affordable housing or other uses. Redevelopment of Federal
Way’s manufactured home parks would cause displacement and significant hardship of low- income households
including many senior households.
How and Where?
Currently, Manufactured Home Parks are an allowed use in Federal Way’s multifamily residential (RM) and
single-family residential (RS 5.0) zones. Federal Way has 7 manufactured home parks with approximately
1,018 homes.
Establishing a Manufactured/Mobile Home Park Zoning Designation can prevent park closures and displacement
of park residents by limiting the ability of the land to be converted into another use. A manufactured home park
zoning designation would require the landowner to have the property rezoned before attempting to develop it.
This creates an opportunity for the City to preserve affordable housing in the community by preventing the
conversation of manufactured home parks to other uses.
A new Manufactured Home Park zoning district can be established for all or some of the City’s existing
Manufactured Home Communities to ensure that goals for the preservation of affordable housing are balanced
with other policy objectives such as transit-oriented development.
Case Studies
City of Kent. Kent established a Manufactured Home Park Zone that provides clarity on rules, regulations,
requirements, and standards for the development, closure, and change in use of MHPs in the city.
City of Kenmore. Kenmore created a Manufactured Housing Community (HMC) Zoning District to preserve
MHCs and mitigate park closures. The enacting ordinance provides a mechanism to mitigate park closures,
address the impacts of closure of MHPs, and offer landowners the ability to transfer their development
rights.
City of Tumwater. Tumwater created a Manufactured Home Park land use designation and zoning district.
Internal Draft April 22, 2021 Federal Way | Housing Action Plan 17
Strengthen Tenant Protections
The Housing Needs Assessment found that, on average, over 2% of renter households in Federal Way
experienced an eviction filing each year between 2004 and 2017. This rate is nearly double for Black
households, echoing similar patterns in other South King County communities. Eviction is an extremely traumatic
and disruptive event that can often result in homelessness and/or prolonged housing insecurity. Evictions also
disrupt the social fabric in neighborhoods where households are forced to leave their homes.
In 2019 Federal Way residents passed the “Stable Homes Initiative” which created new protections for renters.
Specifically, it limits the reasons for which a landlord can evict a tenant, requires a 120-day notice period when
the landlord is removing the property from market, and requiring landlords to give tenants the option to renew a
lease with at least 60 days’ notice prior to lease expiration. The city also provides limited financial support for
legal assistance and credit counseling for preventing evictions.
This strategy calls for the city to review and evaluate these new tenant protections and determine if additional
actions are needed to improve their effectiveness at preventing evictions and providing housing stability. This
evaluation should include engagement with affected community members. Additional actions could include
supporting expanded access to tenant education and legal assistance or developing a relocation assistance
program to mitigate impacts when displacement cannot be prevented. These kinds of actions could be
implemented through partnerships with nonprofit providers or neighboring jurisdictions through SKHHP.