HomeMy WebLinkAbout06-24-25 Public Comment - E. Killenberg - Public comment supporting graduated square foot cap in the UDCFrom:Eva Killenberg
To:Bozeman Public Comment
Subject:[EXTERNAL]Public comment supporting graduated square foot cap in the UDC
Date:Monday, June 23, 2025 10:42:11 PM
Attachments:E_Killenberg_Grad_Sqft_Cap.pdf
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.
Please see the attached document.
Dear Bozeman City Commissioners,
My name is Eva Killenberg. On 6/17, I submitted a comment on how a graduated square foot cap
(GSFC) could incentivize the production of middle housing. It seems that there was a formatting error of
the images included in that comment. This comment includes images and further information in support
of the GSFC policy.
The proposed code includes a maximum building size in square feet in RA and RB zones. A GSFC
would set the maximum building size based on the number of units in the building. In 2021, Portland,
Oregon, implemented a comparable tool, a sliding scale floor area ratio based on the number of units,
as part of their Residential Infill Plan (RIP), which also implemented a variety of pro-middle housing
reforms. This policy applied to traditionally low-density, “single-dwelling” zones.
Portland’s RIP pro-middle housing reforms
Visual representation of Portland’s sliding-scale FAR on a 5000 square foot lot.
After 3 years, Portland reports impressive results. In low-density areas, they have seen a remarkable
increase in middle housing production. Consider the following statistics:
● Middle housing is now the most prominent housing type being built in low-density areas
● As a proportion of total citywide housing production, new units in low-density areas have risen
from a historical average of 15% to 23% in 2023 and 43% in the first half of 2024
● There has been no corresponding increase in the number of demolitions. When demolition has
occurred, the number of units built per unit demolished has more than doubled from 1.64 in
2018 to 3.88 in the first half of 2024.
The availability of middle housing has also led to impactful affordability gains.
● In 2023 and 2024, the average sales price of a new market-rate middle housing unit was
$250,000 to $300,000 less than that of a new market-rate single detached house
● The average fourplex sells at a price affordable to those making 80% of Median Family Income
(MFI), compared to the average single-family house at 170% MFI
The rise in affordable housing has bolstered Portland’s affordable homeownership program, making
homeownership accessible to those under a 120% MFI income threshold.
● Applications for the program have risen from a historical average of 50 applications per year to
200 applicants in 2023, and 100 in the first half of 2024.
● Over 90% of these applications are for middle housing.
After just 3 years, these are indicators of a wildly successful zoning intervention that significantly
impacts housing variety, affordability, and accessibility.
This outcome meets Bozeman’s need for a greater variety of new homes at affordable price points.
Mayor Cunningham presented these statistics in his mayoral address this Winter.
Data from the above table visualized in a pie chart.
Duplexes, triplexes, and fourplexes exist in many Bozeman neighborhoods and play an essential role in
our housing ecosystem. However, we see from this data that they have been underrepresented in new
construction over the past 6 years. These types of housing contribute to the incremental growth of
existing low-density neighborhoods, provide more housing options to current and future residents of
Bozeman, and can offer a more affordable price point than other low-density development.
The Portland example shows sliding scale FAR incentivizes these types of affordable middle housing
when applied to infill development in low-density zones. When considering a GSFC in Bozeman, this
tool could be piloted for infill development only in RA and RB zones to assess its impact. This limited
initial scope would also make calibration of the maximum building size per number of units more
straightforward.
Forward Montana’s GSFC proposal has additional creative ideas that I would also like the commission
to engage with.
1. A developer could have the option to bypass the GSFC and pay “cash-in-lieu” to build a larger
home than what the policy allows. This money could be redirected to the Community Housing
Fund and put towards city affordable housing initiatives.
2. Additional square footage could be granted for developments that preserve the existing
structure, reuse salvaged materials, or apply other sustainable development practices that we
would like to see more of in Bozeman.
3. The Affordable Housing Ordinance could work on top of a GSFC, offering additional units and
square footage if a percentage of the developed units are deed-restricted affordable housing.
This was done in Portland for 6- and 8-plexes.
Although GSFC is a more nuanced policy than a simple building size maximum, I believe this concept
and its proof of efficacy present a compelling opportunity to stimulate the type of housing that the
community of Bozeman needs. I hope you share my excitement for this policy and its potential to
deliver affordable and accessible housing that we all want to see in Bozeman.
Thank you for your consideration and continued efforts!
Source/Recommended further reading: Full 2025 Portland Residential Infill Plan Progress Report