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Home My WebLink About09-07-21 Public Comment - M. Egge - UDC Affordable Housing AssessmentFrom:Tom Rogers To:Agenda Subject:FW: Bozeman UDC Affordable Housing Assessment (Aug 2021) Comments Date:Tuesday, September 7, 2021 9:42:35 AM Attachments:Egge UDC Affordability Comments.pdf Please add this comment to the Clarion Report on Community Housing Thank you From: Mark Egge <mark@eateggs.com> Sent: Monday, August 30, 2021 11:57 PM To: Tom Rogers <TRogers@BOZEMAN.NET>; Chris Saunders <csaunders@BOZEMAN.NET> Cc: Don Elliott <delliott@clarionassociates.com>; Susan <sriggs@groundprint.com> Subject: Bozeman UDC Affordable Housing Assessment (Aug 2021) Comments CAUTION: This email originated from outside of the organization. Do not click links or open attachments unless you recognize the sender and know the content is safe. Tom, Chris— I've prepared comments, re: the newly released UDC Affordable Housing Assessment draft. These are attached. Thank you, Mark --Mark Egge(406) 548-4488he / him 1 Mark Egge 542 N Black Ave Bozeman, MT 59715 30 August 2021 Re: Unified Development Code Affordable Housing Assessment, Public Review Draft, August 2021 This is an excellent set of recommendations reflecting a careful and thoughtful review of Bozeman’s existing UDC and national best practices. If implemented, these recommendations will make a meaningful impact to reduce long-term housing prices in Bozeman. Overall Comments The stated recommendations need to be clearer. The recommendations in each section should be visually called out from the text, and in a manner that is consistent in each section. It would also be useful for the recommended changes be summarized in a single, numbered table—see the Downtown Bozeman Improvement Plan for an excellent example. The recommendations should be stated in a manner that City Commission could move to adopt. Park Area Requirements are a significant contributor to housing costs and need to be revisited. Sec. 38.420.020. A.1 requires 1300 SF of parkland dedication per dwelling. Given finished land costs of $1m / acre, this requirement adds $30k in land costs per unit. Current Parkland Dedication requirements are inequitable and regressive, to the extent that smaller dwelling units must pay a greater amount (as a share of purchase price) for parkland dedication. Instead of requiring a fixed amount of parkland dedication per dwelling the city should require a parkland dedication ratio. I suggest a ratio of 0.2 (meaning that 20% of developed land will be parks), or 100 SF of parkland per 500 SF of lot size. This results in no change in required parkland dedication for a 6500 SF lot (an average size in many newer subdivisions) and no change when calculated at the subdivision level— but results in lower parkland dedication costs for smaller (more affordable) homes. This improves equitability without reducing the overall ratio of new parks to new development. Specific Comments pp. 12 – The two line/bar charts are confusing. The vertical axis needs a label. The Residential and Residential Mixed-Use chart would be better replaced by a table or by something like the area chart above it. pp. 14 – A brief discussion of “dysfunctional density” seems warranted as the city continues to place a ring of high density around a relatively low-density core. pp. 15 – A discussion of “missing middle” housing seems warranted here. pp. 24 – “Single-household detached dwelling lots for income-restricted affordable housing can be as small as 2,700 square feet” – in theory. In reality, it simply isn’t financially feasible to develop a single-family detached dwelling at market rates that is low enough in cost to meet the city’s 2 threshold1 for “affordable”. For 99.9% of purposes, the minimum lot size for a single-family detached dwelling is 4000 SF (plus 1300 SF of required parkland dedication). pp. 25 - Recommendations to reduce lot size minimums should extend to all types of residential development, including single-family detached houses. Current recommendations (reducing minimum lot sizes for multi-family but not single-family) would fail to legalize many of the lots in the exemplary Bridger View subdivision, which includes single-family houses on lots predominantly in the 2100 – 2500 SF range (with some as small as 1800 SF). Other reference points include Houston (1400 SF minimum) and 711 E Lamme Street (1344 SF). Bozeman should eliminate lot size minimums for all housing types (recognizing that required setbacks and lot coverage maximums and other dimensional standards accomplish the same goal of ensuring daylight and air between buildings) or adopt the standards identified from Spokane, Washington: minimum lot sizes for detached houses are 1,800 square feet, attached houses are 1,450 square feet, and duplexes/multi- dwelling structures are 2,900 square feet. pp. 26 – “Neither Helena or Missoula regulate lot width and depth.” Nor should Bozeman. Keep required setbacks and ditch required lot widths. There’s no reason to have both. Again, a clear recommendation would be helpful here. pp. 27 – Floor Area Ratio Requirements can be useful. Seattle cleverly caps FAR at 0.5 per dwelling (see: https://www.sightline.org/2019/06/18/can-seattle-curtail-teardowns-and-provide-more- affordable-homes/ ). This incentivizes developers to put more units on a given lot, reduces McMansion tear-downs, and encourages ADUs and multifamily units. 1 < $280k, I believe, though the city seems to go out of its way not to publish this critical threshold number 3 pp. 28 – Lot Coverage Requirements. Bozeman should tier maximum floor area ratio based on dwelling type rather than zoning district (e.g. SFR = 0.5; duplex = 0.75; triplex = 1.0; 4-plex+: 2.0). pp. 30 – ADUs. Recommend allowing a second ADU per lot if at least one meets standards for Universal Design (see Seattle’s example). Bozeman has both a lack of affordable house and of accessible housing. Allowing a second ADU if it’s accessible makes sense. It’s not uncommon for cities to allow two per parcel, including cities like Tigard, OR (pop. 50,000) or Troutdale, OR (pop. 17,000). Also, consider eliminating owner-occupancy requirement in R-S and R-1. Per-approved plan sets or exemptions from NCOD requirements would greatly expedite the creation of ADUs. pp. 33 – Rooming and Boarding. Bozeman maintains household size caps restricting a household to no more than four “unrelated” parties (Sec. 38.700.090 Household). Bozeman’s laws have been criticized by the Montana Human Rights Bureau as discriminatory. Washington State recently struck down household size caps because, “they shut out cheaper options for those who could benefit from sharing housing costs and paying lower rents, such as retired seniors, college roommates, and low- to moderate-income workers. These rules also impose exclusionary definitions of family and discriminate against households with members who may not be related in the eyes of the law.” Fixing the definition of “household” would increase housing options for low- and middle-income residents, making Bozeman more inclusive towards all family structures and living arrangements. The code fix is simple: Maintain occupancy limits based on floor area or life & safety standards. Revise: Household (A) A person living alone, or any of the following groups living together as a single nonprofit housekeeping unit and sharing common living, sleeping, cooking and eating facilities.: 1. Any number of people related by blood, marriage, adoption, guardianship or other duly- authorized custodial relationship; 2. Not more than four unrelated people; or 3. Two unrelated people and any children related to either of them. 4. Persons or groups granted a request for a reasonable accommodation to reside as a single housekeeping unit pursuant to section 38.35.090. pp. 41 – HOAs. The city should eliminate any/all code requirements that require the creation of an HOA for HOA-provided services. It should be possible to create a new subdivision without an HOA; at present, it is not possible to do so. Examples include: landscape watering for median plants, stormwater facility maintenance, etc. A Few Final Thoughts 1. Section 38.400.050 The city should develop narrower alternative street sections. The current 60’ standard is extremely wide. 30’ and 42’ ROW sections should be developed and encouraged. 2. 38.400.090 Revisit access requirements; eliminate requirement for vehicle access. 3. 38.400.100 Revisit street-vision triangles. 4. Reduce required setbacks in the form and intensity standards (Table 38.320.030.C) to be consistent with the required setbacks in the Block Frontage Standards Table 38.510.030.C. Thank you for the excellent work on behalf of the City of Bozeman. Mark Egge