2021-09-01 Planning Commission PacketCommissioners City Staff
Lawson Bronson, Chair Tim O’Neil, Vice-Chair Keith Niven, Planning Manager
Wayne Carlson Hope Elder E. Tina Piety, Administrative Assistant
Diana Noble-Gulliford Tom Medhurst 253-835-2601
Dale Couture Eric Olsen, Alternate www.cityoffederalway.com
Jae So, Alternate Anna Patrick, Alternate
K:\PLN Long Range Planning\Planning Commission\Agendas, Packets, Minutes, and Misc Documents\2021\Agenda\Agenda 09-01-21.docx
City of Federal Way
PLANNING COMMISSION
September 1, 2021, 6:30 p.m. City Hall Council Chambers & Zoom Meeting
AGENDA
1. CALL TO ORDER
2. ROLL CALL
3. APPROVAL OF MINUTES
a. Planning Commission Meeting of August 18, 2021
4. PUBLIC COMMENT
5. COMMISSION BUSINESS
a. Public Hearing Continued – Permanent Supportive Housing & Emergency
Shelter Code Revisions
6. STAFF BUSINESS
a. Manager’s Report
7. NEXT MEETING
a. September 15, 2021, 6:30 p.m.
8. ADJOURNMENT
Notice: This meeting will be held in-person and via Zoom (AUDIO ONLY).
• Call in and listen to the live meeting (888) 788-0099 or 253-215-8782
• Zoom meeting code 920 3994 8345 and passcode 431768
• Public Comment may be submitted via email here, or sign up to provide live comments here
Planning Commission Minutes Page 1 August 18, 2021
CITY OF FEDERAL WAY
PLANNING COMMISSION
August 18, 2021 City Hall
6:30 p.m. Council Chambers & Zoom
MEETING MINUTES
Commissioners present: Tim O’Neil, Wayne Carlson, Diana Noble-Gulliford, Tom Medhurst, Hope
Elder, Dale Couture, Anna Patrick, Jae So, and Eric Olsen. Commissioners absent: Lawson Bronson
(excused). City Staff present: Planning Manager Keith Niven, Assistant City Attorney Kent van
Alstyne, and Administrative Assistant II Tina Piety.
CALL TO ORDER
Vice-Chair O’Neil called the meeting to order at 6:30 P.M.
MINUTES
The July 21, 2021, minutes were approved as presented.
PUBLIC COMMENT
None
COMMISSION BUSINESS
Public Hearing, Permanent Supportive Housing & Emergency Shelter Code Revisions – Manager Niven
delivered the staff report. The proposed amendments are in response to house bill, ESHB 1220. Why do
we need to do anything with the code? Because of newly-adopted state legislation that has a deadline of
July and September to become effective. The city is better served by having standards in place than being
out of compliance with state law. If we don’t adopt our regulations, we won’t have them in our toolbox
and will have to follow state law. ESHB 1220 has six sections (a proposed seventh was rejected by the
governor). According to the bill, cities have to accommodate housing affordable at all levels. This means
we will have to comply with this mandate when we update our housing chapter in the comprehensive plan.
Policies must be consistent between our code (FWRC) and the comprehensive plan. Section three is the
biggest concern for the city. It states “A code city shall not prohibit transitional housing or permanent
supportive housing in any zones in which residential dwelling units or hotels are allowed. And, effective
September 30, 2021, a code city shall not prohibit indoor emergency shelters and indoor emergency
housing in any zones in which hotels are allowed, except in such cities that have adopted an ordinance
authorizing indoor emergency shelters and indoor emergency housing in a majority of zones within a one-
mile proximity to transit.” Permanent supportive housing combines affordable housing assistance with
voluntary support services to address the needs of chronically homeless people. Permanent supportive
housing has helped decrease the number of chronically homeless individuals. Investments in permanent
supportive housing have helped decrease the number of chronically homeless individuals by 8% since
2007. Research has shown it can increase housing stability and improve health. Emergency housing is
often the first place people turn to during or after experiencing an economic or domestic crisis and
provides a temporary residence. Emergency housing and shelters provide support services and short-term
stabilization for individuals and families before finding appropriate long-term housing. Manager Niven
noted that while the state has banned jurisdictions from adopting a moratorium on the siting of permanent
supportive housing, the City of Puyallup has done so.
Planning Commission Minutes Page 2 August 18, 2021
Zones that currently allow hotels and motels are Community Business (BC), Commercial Enterprise
(CE), City Center Frame (CC-F), and City Center Core (CC-C). Currently, Office Park (OP) and
Professional Office (PO) zones don’t allow dwellings. Most of the city consists of single-family and
multifamily zones.
The city must use our “projected need” as a basis for any proposed code amendments. The projected need
is an “…inventory and analysis of existing and projected housing needs that identifies the number of
housing units necessary to manage projected growth, as provided by the department of commerce,
including: (i) Units for moderate, low, very low, and extremely lowincome households; and (ii)
Emergency housing, emergency shelters, and permanent supportive housing….” Our projected need
number will be developed for us by King County, using a number from the state’s Department of
Commerce (DOC). However, DOC will not have a projected need number for King County until
December 2021. King County will likely take most, if not all of 2022, to determine the projected need
number for the jurisdictions in the county. Therefore Federal Way likely will not have an “official”
projected need number until 2023. In the meantime, DOC still expects cities to determine and use their
projected need number starting this year. Manager Niven used the following methodology to determine a
tentative projected need number for Federal Way:
1. Utilize the 2020 Seattle/ King County Point In Time Count of the homeless done in January.
2. Since the count is not segregated by city, he utilized data for SW King County. (SW King County
includes Renton, Tukwila, Burien, SeaTac, Des Moines, Vashon, Federal Way, a portion of
Milton, a portion of Auburn, and Kent.)
3. He used the population of the region to determine the city’s portion (329).
4. He extended the Point In Time Count trend from the last four years out to 20 years (449) and
applied a multiplier of 2.5% to that.
Manager Niven arrived at a 20-year forecast for Federal Way’s projected need number of 1,123 dwelling
units. He noted that some people feel the Point In Time Count undercounts the actual amount of
homelessness by 2½ to 10 times fewer people. Staff suggests the city revisit the projected need number in
2023 after we receive our “official” number from King County.
Commissioner Noble-Gulliford asked if Manager Niven knows the DOCs formula for calculating the
projected need number? Manager Niven replied that he does not know and DOC may not know yet. He
noted that Federal Way and SeaTac are the most proactive cities concerning this issue. Commissioner
Noble-Gulliford asked in regards to the calculations, is there anything other than an 8% reduction rate in
homelessness due to permanent supportive housing? Isn’t there a factor to indicate some people have
been helped and are no longer in this number? Manager Niven replied he will have to look into this issue.
He doesn’t know if there is an expectation of the amount of homeless that will be helped (and can be
moved out of the facilities).
Commissioner Patrick asked regarding Puallup’s moratorium, Pierce County has a lot of foreclosure
homes; can we look at the forecast of that? Attorney van Alstyne stated that the city can’t legally adopt a
moratorium like what Puyallup did. Manager Niven commented that staff is concerned that the model of
permanent supportive housing will move away from hotels and into neighborhood homes. This is
something we can possibly address in our regulations. The proposed amendment will increase the
separation between permanent supportive housing.
Manager Niven went over a summary of the proposed amendment (attached). The summary table shows
where permanent supportive housing and emergency housing are allowed now and where they will be
allowed under new regulations. Since emergency housing is basically the same as the city’s social
services transitional housing the proposed amendment changes social services transitional housing to
emergency housing.
Planning Commission Minutes Page 3 August 18, 2021
Vice-Chair O’Neil opened the hearing to public comment.
Ken Blenens – He is frustrated with city officials. Do they even live in Federal Way? He is a 49-
year resident. You can put a moratorium on this. We only have drug addict homelessness in
Federal Way. All the numbers are wrong. Our homeless are drug addicts, not people down on
their luck. We would happily help out and agree to this amendment if our homeless were people
down on their luck, but they’re not. You don’t care for drug addicts the same way as other
homeless. They are a problem for businesses. I often go out on my sidewalk and see a person with
a needle in their arm. This amendment is going to put more drug addicts on our streets.
Jacquelyn Copley – She lives in Federal Way. Her children are growing up here and her elderly
parents live here as well. How safe would it be if the drug-addicted homeless were close to their
house? The Police are concerned; there are hot spots of dangerous areas in the city. Crime is rising.
What habit are they funding/supporting with this amendment? Who is protecting us? What you are
doing has a long-term impact. Some of the people working on this don’t live in Federal Way.
Commissioner Carlson commented that the Planning Commission is made up of residents of Federal Way.
This is coming from the state, not the city. Please don’t place bad motives on city staff. Staff is following
the lead of the city council. He is not comfortable being a trailblazer on this issue. He also disagrees with
some of the amendments and the numeric standards but doesn’t blame the staff.
Kerry Callison – This will spread the crime out to all the different homes. We pleaded with King
County not to purchase Extended Stay, but for naught. Will this get rid of the tents and remove
people from the streets? We are looking at you to do this and protect us Having services may
help. It is a crazy idea to house senior citizens with drug addicts. With this amendment, property
values will go down and people will leave Federal Way.
Jack Walsh – He feels sorry for the position staff is in. The state legislature put us here. We
should delay this amendment because there will be a different legislature in a few years and some
of these laws may be undone. There is a need for emergency shelter and most of that part of the
amendment is fine. He has been a volunteer for the Point In Time Count and the homeless
numbers from before 2021 were very accurate and don’t need to be inflated. Isn’t this supposed to
reduce the need number by 8%, so increasing the projected need number doesn’t make sense. He
also noted the number of homeless who need a unit is lower than the count because some are
couples and can share a unit; thereby, lowering the number needed.
Jim Ross – He has lived in Federal Way for 60 years and owns a restaurant. He sees drug-addicted
homeless in his parking lot every day. If it was just homeless he would support the amendment,
but they are drug addicts who don’t want help. Such people don’t want to follow the rules (such as
no alcohol use) from supportive agencies that want to help. Please don’t put drug addicts in our
city center You can limit the size of hotels that can be used or the number of units. If only 25
rooms are available they will have to figure out something else. We need your help to solve this.
Erica Norton – She has worked in construction on a lot of the jobs for this kind of housing in
Seattle (where they belong) and has noted the developer uses sturdier components because they
know they will be destroyed. There will soon have drugs, rats, and roaches in the units. The zoning
rules should place families first. She would like drug-free zones and mandatory drug testing.
David VanVleet(?) – Staff is using only one source for information. Another study indicates
housing first is not the key to solving the homeless problem. There is a requirement they are
separated from schools, but private schools are omitted from the law. In earlier years, funding of
grants from HUD was higher for transitional (emergency) housing and now it is higher for
Planning Commission Minutes Page 4 August 18, 2021
supportive housing. He noted permanent supportive housing can go into neighborhoods but
transitional can not. The government isn’t being accountable to the citizens. There is a disconnect
between what the state wants and what citizens want.
Dara Mandeville– She is a small business owner. She is not getting patients because once they
hear she is in Federal Way they cancel. What exactly is a unit? How many people can be in a
unit? Can HOA Covenant and Restrictions forbid permanent supportive housing? Are no children
allowed in all these homes? Why don’t we centralize permanent supportive housing? To her, it
makes more logistical sense. What is the penalty of saying no?
Vice-Chair Chair O'Neil commented the Planning Commission is a voluntary citizen board and part of
our job is to take into account public comment. He thanked everyone for their comments.
Commissioner Elder asked what if we said no? What would the penalty be? Manager Niven replied if we
do nothing and someone comes in and wants 50 units of supportive housing and we don’t accept the
application, the developer is likely to sue. Attorney van Alstyne commented the developer will likely
have a valid argument. Commissioner Elder asked can we enforce a requirement that people are drug
tested? Attorney van Alstyne replied he wants to discuss the issue with our Community Services Manager
Sarah Bridgeford. Manager Niven commented the fair housing act says we can’t discriminate against
disabilities, and drug addiction is considered a disability by many.
Commissioner Patrick asked does 10 rooms/units mean 10 people in a house? Manager Niven replied
there could be more than one person in a room/unit, there could be 20 people in the house. Commissioner
Patrick asked how much parking would a 10 room/unit house require? Manager Niven replied it would be
10 to 20 spaces. The provider can ask to reduce the amount of parking (which will free up space).
Commissioner Patrick would like to see a map of what the spacing of permanent supportive housing will
look like. She also commented it is a concern that many of our neighborhoods don’t have sidewalks. She
wants to see what the placement of permanent supportive housing in our neighborhoods will look like.
Commissioner Patrick stated there are four in-care homes within a few blocks of where she lives and they
cause a lot of problems in the neighborhood. She also stated that if we allow 10 people in a house that is
being foreclosed, it could be turned into a cash cow; it would be less expensive than apartments. Manager
Niven commented that one of the biggest costs is the operating expenses. If the housing is more
congregated they likely will save money on the services to residents due to proximity. Commissioner
Patrick commented the bill isn’t clear on what the regulations are in regards to services; there are no
guidelines in the bill. Manager Niven commented the type of services needed will depend upon the
operator and different operators will have different needs; programs will vary. He will research this issue.
Commissioner Patrick asked if we can have regulations to deny those who are drug addicts. Attorney van
Alstyne commented he needs to research this issue further.
Commissioner Carlson has concerns related to the projected need number. He suggested the city use the
smallest most conservative number as the base. He is concerned the city is using too large a base number
He suggested the ½ mile separation apply only to units of three or greater. Manager Niven commented he
doesn’t expect many will locate into small homes because of the need for the proximity of services
(transit, doctors, etc.). He expects most will likely be in commercial zones. Commissioner Carlson
commented he is uncomfortable being on the leading edge; he wants to know what other communities
plan to do. He noted the supporting housing parking standards mirror what is in multifamily zones, but
they will have employees and will need to add parking for them. Commissioner Carlson noted the city has
several permits for behavioral health facilities; do we get credit in our projected need number for those?
Manager Niven replied he doesn’t know and will research the issue.
Commissioner Noble-Gulliford asked if current facilities (such as FUSION’s ) count as part of our
projected need? The services are similar and the city should get credit for those. She is concerned about
these uses in single-family zones and whether they fit within the Housing Action Plan.
Planning Commission Minutes Page 5 August 18, 2021
Commissioner Carlson suggested the spacing in single-family zones be closer to a mile and ½ mile in
multifamily and commercial zones. He asked if the state regulation can be preempted by covenants.
Attorney van Alstyne replied that the bill does not expressly preempt private covenants. Commissioner
Carlson asked staff to please examine a zero-tolerance policy. He also suggested the city require two
occupants per room.
Commissioner Noble-Gulliford asked what happens to the taxes from Extended Stay & Red Lion
(property & head tax). Manager Niven stated it depends on if they are purchased and operated by a public
entity or not. If privately owned and operated they will pay taxes. If it is a public entity, they will not.
Commissioner Patrick asked if the city can decide what population we will serve. Attorney van Alstyne
said he needs to research this question, especially in regards to barriers to entry.
Commissioner Olsen commented he has seen Federal Way change a lot; but how can we be sure the number
of homeless will grow as expected? Manager Niven replied the Point In Time Count has shown the city
grows by approximately 360 every four years. Commissioner Olsen asked in regards to spacing, does it take
into account other types of housing (such as adult family homes, ADUs, etc.). Manager Niven will ask the
Department of Commerce if what already exists will be taken into account or factored into the calculation.
Commissioner Patrick asked what happens if say, an in-home care is in an area reclassified for emergency
housing and no longer meets the code requirements. Manager Niven replied they become nonconforming
and will not have to change to meet the new requirements. If they want to make changes to the property
certain restrictions apply and if they don’t meet them, they will have to make changes to apply any new
code regulations. Commissioner Patrick asked if we can get how many units we already have?
Vice-Chair O’Neil asked if adult family homes fall under the category of permanent supportive housing.
How much of our housing is already permanent supportive housing and how many are already being
served? Maybe we already meet our projected need number and don’t have to change the code. Manager
Niven replied that we need to allow them in zones they are not currently allowed and that meets our
expected need. Vice-Chair O’Neil suggested the city adopt the lowest projected need number possible. He
commented that homelessness is a very squishy number and definition. We can arrive at a projected need
number that will allow for growth, but we need to know what we currently have.
Commissioner Carlson moved (and it was seconded) to continue the hearing to September 1st. The motion
passed unanimously.
STAFF BUSINESS
Manager’s Report – None
NEXT MEETING
September 1, 2021, 6:30 pm
ADJOURN
The meeting adjourned at 8:50 P.M.
K:\PLN Planning Commission\2016\Meeting Summary 08-18-21.doc
Summary of proposed
amendments
Proposed Code Amendments - 2021 Page 1 of 10
COMMUNITY DEVELOPMENT DEPARTMENT
33325 8th Avenue South
Federal Way, WA 98003-6325
253-835-7000
www.cityoffederalway.com
Jim Ferrell, Mayor
MEMORANDUM
DATE: 25 August 2021
TO: Federal Way Planning Commission
FROM: Brian Davis
Director of Community Development
Keith Niven, AICP, CEcD
Planning Manager
SUBJECT: Response Memo – Proposed Code Amendments For Permanent Supportive Housing
and Emergency Housing And Shelter (File 21-103086-00-UP)
The following issues were discussed as part of the Public Hearing on 18 August 2021 relating to the proposed code
amendments. Staff’s response follows the issue raised.
1. How will the Department of Commerce determine the Need for Federal Way and will existing units count
towards meeting the City’s need?
Under HB 1220, cities must inventory and analyze existing and projected housing needs for permanent
supportive housing and transitional housing and emergency housing and shelter. As a result, existing units
will be analyzed and incorporated into determining future need.
Staff also sent a request for additional information to the Department of Commerce on Thursday, 19 August 2021.
Staff received the following response from Commerce:
“We are engaging a consultant to provide the projections of housing for next year. We do not have a current
methodology, and will expect our consultant to work with King County and other jurisdictions to develop the
methodology to project housing need – for all income segments, and for the temporary and emergency
housing and PSH.
Were you looking at the shelters, transitional housing and PSH? We don’t have anything for that right now. I
was looking at King County’s subregional estimates for that housing need with another jurisdiction, and then
estimating portion, projecting ahead, and using that as the basis of “allowing” those types of housing. We are
recommending classic “show your work” cover for your code amendments.”
2. Relook at the methodology for determining need.
See Attachment 1
3. The presentation identifies investments in permanent supportive housing have helped decrease the number
of chronically homeless individuals by eight percent since 2007. Does King County have an expectation for
success from the Housing First approach?
Staff called King County Department of Community and Human Services on Friday, 20 August 2021. Staff
received the following information from King County:
Proposed Code Amendments - 2021 Page 2 of 10
“Our expectation for PSH are as follows:
• Permanently Housed: 90% of people referred to PSH are permanently housing
• Length of Stay: N/A, because the expectation is that people stay permanently
• Return to Homelessness: 5% (adults and families)…meaning that 95% retain their permanent
supportive housing
• Homeless Entries: 90% are literally homeless at entry to PSH
• Utilization Rate: 85% of all PSH units are leased at all times w/in a building (and across the system)”
4. Parking requirements should account for employees.
Agreed. Staff looked for similar examples of housing and employees being in the same facility in the code and
would suggest the number of spaces for employees be handled similar to the provisions for convalescent
centers. Staff would suggest the following revisions:
Zone Initial Proposal Updated Proposal
SE 1-2/units 1-2/units and 1 for every 2 employees
SF 1-2/units 1-2/units and 1 for every 2 employees
MF 1-2/units 1-2/units and 1 for every 2 employees
NB 1-2/units 1-2/units and 1 for every 2 employees
CB 1-2/units 1-2/unist and 1 for every 2 employees
CC-C 1-2/units 1-2/units and 1 for every 2 employees
CC-F 1-2/units 1-2/units and 1 for every 2 employees
CE 1-2/units 1-2/units and 1 for every 2 employees
Proposed Code Amendments - 2021 Page 3 of 10
5. Does the city know how many shelter and PSH units exist in the city currently?
The city currently does not keep a database of this information. However, Community Services staff
identified the following existing units, which represent the city’s best estimate of currently existing units:
Permanent Supportive Housing
- Multi-Service Center, William J Wood for veterans and their families: 44 units
Transitional Housing:
- FUSION, scattered site for families: 20± units
Shelter
- FUSION: family shelter, 29 rooms
- CCS, Temporary location for adults: 20± double occupancy rooms beds (Red Lion)
6. How many households in Federal Way are currently at imminent risk of becoming homeless?
From the draft Housing Action Plan:
Severely Cost Burdened (paying 50%+ of income for housing):
Ownership – 5,861
Rental – 4,093
Total – 9,954 households
The city does not have access to any other data to help inform this response.
7. Is there a way to prioritize housing for families?
Staff is unaware of a way to write code to address this desired outcome. This seems more appropriate to be
included as a new policy for the comprehensive plan when the housing element is updated.
8. Can the spacing for single-family be increased?
Potentially yes:
a. Increase the separation requirement from ½ mile to 1 mile (See Attachment 3).
9. Can the city require the operators to require background checks for residents?
See Attachment 2
10. Can the city require treatment for residents with substance addictions?
See Attachment 2
Proposed Code Amendments - 2021 Page 4 of 10
11. Delay these proposed amendments until the city can review peer cities ordinances.
It is staff’s recommendation that the Planning Commission recommend to the Council the adoption of
the proposed code amendments as revised. As was stated in the hearing on 18 August 2021, by adopting
the new code, the city will have protection measures in place that will not be part of code if these
amendments are postponed. After the statutory deadline for compliance on September 25, all cities will
be subject to state law which mandates allowance of shelter and PSH uses. This means an unlimited
number of shelter or PSH projects could be built in a city that has not adopted standards and limitations
such as those being proposed.
12. Can the city provide a map showing spacing for single-family zones?
See Attachment 3
RECOMMENDATION
a. Revise the proposed parking requirements as contained in this memorandum; and
b. Include the operational requirements (Attachment 2); and
c. Increase the separation for single-family zones to 1 mile.
Proposed Code Amendments - 2021 Page 5 of 10
ATTACHMENT 1 – Reevaluating Projected Need
1. Staff reached out to other cities to understand how they forecasted need.
2. Staff reread and re-evaluated the Point-in-Time Count
1. Outreach to other cities, their responses are provided below
Kent: “…did not include a forecast number as part of their code revision process, we are proposing to
reexamine the standards after the city receives information from Commerce”
Auburn: “The legislation specifies to be effective the implementation must funded by the legislature.
Even if this should change and the legislature provides funds, the city has been receptive to parts of
HB 1220 and did not feel that a more immediate response by the unrealistic deadline in September is
required, if we are making progress towards implementation of some of the provisions. Auburn has
recently been selected as one of the sites for King County’s Health through Housing project sites for
conversion of a hotel and with our Mayor’s support.”
Tukwila: “Tukwila is not trying to estimate what commerce may decide is our projected need. Our draft
ordinance caps the size of facilities by zone and includes spacing and location requirements. If those
constrain the number of facilities below what is later calculated as our need we will reevaluate then.”
Des Moines: “We have yet to calculate the need but our initial approach is to do the following:
- Calculate the percentage of DM population within the Point-in-Time Count extent
- Use the same percentage of DM on the total point-in-time count
- N-value provides a general estimate
- Review past time counts to determine trend (if any) and consider what the amount would
need to be in the next 5 years based on calculation”
SeaTac: “As to the Projected Need number, staff has landed on 100-150 people. How we came to this range:
We believe the intent of this portion of legislation is to provide for currently homeless,
those at imminent risk of homelessness, and those chronically homeless (for permanent
supportive housing).
Based on that we turned to the King County 2020 Point-in-Time Count: 2020 Seattle/King
County Point-in-Time Count of Individuals Experiencing Homelessness
Utilizing the Point-in-Time Count, SeaTac’s proportional share of homeless was 99. We
went up to 150 due to a statement in the county report that the numbers were found were
most likely an undercount.”
Renton: “To estimate the projected need for emergency housing and shelters, staff used data from
the 2020 Seattle/King County Point-in-Time Count of Individuals Experiencing Homelessness
(Count-Us-In-2020-Final.pdf (kcrha.org)). Because Renton accounts for approximately 17.5% of the
southwest population, staff posits that the city’s projected need for emergency housing and shelters is
approximately 329 beds (17.5% of 1,880).”
Proposed Code Amendments - 2021 Page 6 of 10
2. Point-in-Time Count – reevaluation
a. Is 17% an accurate representation of Federal Way’s share?
Staff’s extrapolation of Federal Way’s share of SW King County (17%) is consistent with the
methodology used by Renton, SeaTac, Des Moines and Covington. Staff did not receive a response
from staff’s request for more specific data for the city (email sent to Allhome on 19 August 2021).
No changes are recommended.
b. Is the Point-in-Time Count an under-representation?
The Point-in-Time Count is a statistically significant measurement of the number of homeless
individuals on one night per year in January. The Point-in-Time Count is generally considered to be
an under-representation of the total number of homeless individuals; however, the degree of
under-representation is unclear and has not been quantified. Two factors contribute to a potential
under-representation are methodology of count, as well as the use of a single count on a single
night of the year.
c. Should the city apply a multiplier to determine its Projected Need?
No.
Although the city believes the Point-in-Time Count is generally considered to be under-
representative of the total number of homeless individuals as discussed above, staff are
recommending no multiplier be applied for the following reasons:
i. The statistical accuracy claimed by the authors of the study (95%);
ii. The 2020 data included an internal “multiplier” used in previous years to account for
individuals in cars or vacant buildings that could not be physically seen and counted
by surveyors;
iii. Although staff initially suggested using a 2.5 multiplier based on a 2001 study analyzing
nationwide Point-in-Time counts, the Commission raised concerns this study was dated and
may not reflect the accuracy of the 2020 Seattle/King County Count; and
iv. The Point-in-Time Count counts individuals. However, the Projected Need for the city is
calculated on a per-unit basis, as opposed to an individual basis. Invariably, some units will
be occupied by individuals and some by households of two or more. As provided in the
report (see the table below), almost 27% of the 11,751 counted individuals were part of a
household. By basing the city’s projected unit need on our proportionate share of the 11,751
individuals – as opposed to our proportionate share of households – the city’s methodology
creates a built-in 27% buffer to account for any potential undercount resulting from the
Point-in-Time study.
Proposed Code Amendments - 2021 Page 7 of 10
3. Conclusion:
Revise the Projected Need for Federal Way from 1,123 to 450 (combined PSH and Shelter), consisting of
194 units (43%) of emergency housing and shelter; and, 256 units (57%) of permanent supportive
housing and transitional housing. These percentages are derived from the respective proportions of
transitional housing, disabled housing, and shelter housing found in the Point-in-Time Count.
Taking the existing count as well as what is in the pipeline (King County proposals):
Projected
Need
Existing Proposed Remainder to meet
Projected Need
Emergency housing and
emergency shelter
194 291 90 (Red Lion) 75
Permanent supportive housing
and transitional housing
256 64 101 (Extended Stay) 91
1There are an additional 20 units that are currently located at the Red Lion that will be part of the 90 proposed.
RATIONALE
a. Using the 2020 Seattle King County Point-in-Time Count is the best source of current data available to
base the city’s Projected Need.
b. Utilizing the best data available, taking the proportionate share of homeless from the Point-in-Time
Count for SW King County as a direct percentage of the city’s population as a percentage of those
cities and areas comprising the SW King County region (17%) represents a reasonable, non-arbitrary
decision and is consistent with other cities’ approaches.
c. There are adequate reasons (as stated above) for not applying a multiplier to the final adjusted Point-in-
Time Count, and no data or basis upon which to quantify such an additional multiplier is available to
the city at this time.
Proposed Code Amendments - 2021 Page 8 of 10
ATTACHMENT 2 – Additional Special Regulations and Notes
Following review and consideration of comments from the Planning Commission, public comments, and review
of the legality of imposing additional regulations, staff recommend including the following as Special Regulations
and Notes to each zone use chart as part of this amendment:
A. In single-family and multi-family residential zones, residents must be referred by providers of housing
and services for people experiencing homelessness. Direct intake of residents at the site is not allowed.
B. A description of transit, pedestrian, and bicycle access from the subject site to services and schools must
be provided to the residents.
C. An operations plan must be provided that addresses the following elements:
1. Roles and responsibilities of key staff;
2. Site/facility management, including a security and emergency plan;
3. Site/facility maintenance;
4. Occupancy policies, including resident responsibilities and a code of conduct that includes, at a
minimum, a prohibition on threatening and unsafe behavior, and the on-site use and sale of
illegal drugs;
5. Access to human and social services, including a staffing plan and expected outcome measures; and
6. Procedures for maintaining accurate and complete records.
D. Providers and/or managing agencies shall have either a demonstrated experience providing similar services
to people experiencing homelessness, certifications or academic credentials in an applicable human service
field, and/or applicable experience in a related program with people experiencing homelessness.
E. For health and safety reasons, the sponsor and/or managing agency shall take all reasonable and legal
steps to obtain verifiable identification information, including full name and date of birth, from current
and prospective residents, and shall keep a log containing this information.
F. People who are required to register as a sex offender are prohibited from residing in the facility.
G. Should the provider become aware of a current or prospective resident who has an active felony
warrant, it shall follow set protocol for contacting the FWPD and addressing these warrants.
Proposed Code Amendments - 2021 Page 9 of 10
Proposed Code Amendments - 2021 Page 10 of 10