“DEIS” for the “HALA” mandatory housing affordability requirement conceals impacts on low income housing”

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Seattle Displacement Coalition challenges adequacy of Draft Environmental Impact Statement (DEIS):

“The loss of existing low income units would greatly outweigh total affordable units produced under HALA plan.  The DEIS makes a mockery of responsible planning and analysis and thumbs it’s nose at the City’s statutory obligations under SEPA. And it thumbs it’s nose to the thousands of low income tenants in our city whose housing is being put on the chopping block due to this HALA-MHA plan.”

In a written statement submitted last Monday, a few hours before the deadline for acceptance of formal comments, the Seattle Displacement Coalition (SDC) said the DEIS would deny decision makers accurate information on how the HALA upzone plan would set off massive displacement, gentrification, and loss of low cost housing in our city.   These losses would greatly outweigh amounts of “affordable” units developers are required to provide under the mandatory housing requirement accompanying the upzones.

The Coalition’s 7-page letter with attachments identified numerous problems with the DEIS including: 

  • A lack of discussion/assessment/study of a true second alternative to ‘no action’.  Both alternatives studied assumed the same level of growth and added density, only moving it around slightly.  Consequently impacts are similar preventing decision-makers from viewing an alternative with fewer impacts that still could meet the proposals affordable housing objectives.  There is a need for a “managed growth” alternative that assumes less density and a higher mandatory housing requirement.  Without this, the DEIS does not fulfill the requirements of WAC 197-11-442 (2) that require a level of discussion of “alternative means of accomplishing a stated objective” and with detail “sufficient to evaluate their comparative merits”.
  • The document fails to adequately assess the significant direct, indirect and cumulative adverse impacts that the HALA Plan (the upzones and MHA) will have on this City’s existing supply of low income and very low income housing in our City.  The studies they draw upon or undertake are dated and irrelevant to an understanding of how the upzones will set in motion displacement and loss of low income housing.  Other significant factors and more current trends should have been studied that caused a change specifically in the supply of unsubsidized low income rentals in these high growth areas. What was ‘studied’ in the DEIS gives us no means for understanding what future upzoning would do to any remaining affordable stock in these areas slated for upzoning.
  • The analysis doesn’t look at increased speculative activity in high growth areas set in motion by the HALA upzones.  Such study is critical and necessary to understand “indirect and cumulative effects” required under SEPA.   This would include documenting the rapid turnover and increases sale and resale of existing older affordable apartments (the single most important reason causing excessive rent increases) and how that would accelerate due to HALA upzones.  Also, it would include examination of how upzones affect development potential on sites containing existing low cost housing.   Councilmember Herbold – a decision maker in this instance as well – had specifically asked for this kind of analysis as well as a closer look and said it was necessary to understand displacement effects and necessary for her to make an informed decision of displacement effects – yet even she was ignored.
  • The DEIS substantially purposely underestimates the direct impact and amount of low cost units that will be lost to demolitions, renovation/acquisition as a result of the HALA upzones accompanying the mandatory requirement. 
  • In all, losses due to demolition, speculative turnover, and increased rents will greatly out-number the 6200 approximate number of MHA required units serving those below 30 percent of median assumed to be created and assumed for study here in the DEIS). 
  • Note also the DEIS – because it trivializes levels of displacement and amounts of existing low cost housing at risk of being lost – it also imagines away the amount of added homelessness that will be caused by the HALA-MHA proposal and thus increase the demand for shelter and other homeless services.
  • As explicitly stated, the document also has excluded a study of cultural, historical, and social displacement. Areas of high concentrations of historic structures and communities with unique racial, religious, or cultural heritage – how the upzones will affect them – is not at all adequately addressed.
  • The mitigation strategies offered are minimal and won’t begin to offset existing housing that will be lost as a result of the upzoning.  It does not even include doable and legal tools that could be used to preserve existing unsubsidized rental units such as requirements accompany or preceding upzones ensuring developers replace 1 for 1 what they tear down and measures to address the resale and speculation of existing affordable units leading to higher rents and displacement.  

The full comment letter with attachments identifying specific tools and methodologies that should have been used for an  to draw up for an accurate and full study of displacement and impacts may be downloaded here:

SDCDEIScomments 1


About John V. Fox

Director, Seattle Displacement Coalition
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