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Home My WebLink About08-26-25 Public Comment - E. Killenberg - Public comment in support of a graduated square foot capFrom:Eva Killenberg To:Bozeman Public Comment Subject:[EXTERNAL]Public comment in support of a graduated square foot cap Date:Tuesday, August 26, 2025 7:00:45 AM Attachments:Grad Squarefoot Cap 8-26.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 attached - thank you! Dear commissioners, I appreciate the opportunity to continue the conversation on the graduated square foot cap proposal, and thank the staff and commission for their research and discussion. I think this type of policy is a surgical tool to create the types of homes Bozeman needs. This can be summarized by two items: 1. We should limit the size of single-family homes. In the current code and proposed draft, to my understanding, a single-family home can be built in any residential district. I am challenged to come up with a good reason for a new 5,000+ square foot home in Bozeman. We are in desperate need of housing that is attainable for our community members to own or rent, especially small, affordable, and abundant for-sale homes. On top of this, our planet is threatened by a climate crisis perpetuated by the irresponsible use of resources in the global north. Single-family homes of this size are not part of the solution to these problems; in fact, they exacerbate them. A graduated square foot cap puts a reasonable size limit on single-family homes. 2. We need to incentivize missing middle housing in order for it to be built. In contrast to a 5,000 square foot single-family home, a 5,000 square foot fourplex will be more affordable, sustainable, and valuable to the community. However, in many places (including Bozeman) where fourplexes and other missing middle housing are allowed in code, this type of development remains elusive. In order for missing middle housing to actually be built, we need to make it the most attractive option for developers. Our development and financing mechanisms make building single-family homes easier than missing middle housing. This is compounded by a market where large, luxury houses make the most profit. The graduated square foot cap works to balance the scales so that the housing market delivers what our city needs. The city pulled data on building applications for the last 5 years, and found there is a “lack of substantial size difference per dwelling.” The report concluded, “Considering the data on median home sizes for single homes, townhomes, or duplexes, the probable construction will largely remain consistent with existing patterns of development in the community as a whole [with a graduated square foot cap].” I interpret the data provided differently. The data for building size maximums show that each year, some number of 4,000+ sq ft single-family homes are constructed. If just 10% of permitted SFHs were instead built as fourplexes, we would have generated 280 attainable units for Bozeman families over 5 years. In addition, the data shows that 3,000 sq ft duplexes and 6,000 sq ft townhomes have also bee built. If 10% of duplexes and townhomes were constructed with an extra unit, we would gain 113 units of middle housing. While modest, in a market starved for attainable, for-sale housing units, these changes make a difference. I think of the 400+ applicants for the Bridger View lottery, and the impact that an increased supply of missing middle housing could have made on their lives. It is reasonable to believe that a graduate square foot cap could stimulate this type of change and beyond, especially when paired with an increase in allowed units, as was done in Portland. We are effectively doing this by combining RS, R1, and R2 into RA, which has the potential to allow more units in areas where previously only 1 or 2 were allowed. As part of the Residential Infill Plan, where the sliding scale FAR was implemented, Portland allowed up to four units to be constructed in all previously single-unit restricted zones. Three years later, middle housing is the most prominent housing type being built in low-density areas. It’s having a big impact on the city-wide housing market. As a proportion of total citywide housing production, new units in low-density areas have risen from a historical average of 15% to 43% in the first half of 2024. Implementing a graduated square foot cap that allows up to a fourplex in RA could also shift development outcomes in this way—shifting our new housing construction from predominantly single family homes and apartments, to a more balanced continuum of housing types. I also want to note that fourplexes seem to be a sweet spot for this type of policy in low-density residential neighborhoods. Of the 271 middle housing permits in Portland, 76% were fourplexes, and a fourplex unit sells at a price affordable to those making 80% of the Median Family Income. [ 1 ] Following Portland’s lead, the city of Sacramento passed a sliding-scale FAR in 2024. In their analysis of the policy, Opticos Design writes, “Feasibility testing on a typical lot showed that if a fourplex was built instead of a similarly-sized single-family home, it would provide units that are within the reach of four-person households making the 2022 Area Median Income (AMI) in Sacramento, $102,200. With each additional unit, attainability is extended to even more residents with lower household income.” [ 2 ] Indeed, the evidence suggests that housing on the larger end of the missing middle provides even greater affordability and feasibility for developers. According to a study by UC Berkeley’s Terner Center for Housing Innovation, buildings between 8 and 12 units allow developers to leverage economies of scale while using less expensive, wood-frame construction. [ 3 ] RB should be optimized for this type of development, with up to 12 units allowed and a wall plate that allows 3 full stories. The graduated square foot cap would still be impactful in RB in forcing compact development and incentivizing more units per building, which will provide another important bracket of missing middle housing. I agree with the city’s approach to encouraging internal conversions of existing structures where possible, and think that the graduated square foot policy should exempt remodels of existing structures that add units. Another aspect of the graduated square foot cap policy that excites me is its potential to be integrated into the Affordable Housing Ordinance. With less leverage over parking and height following the 2025 state legislative session, we need more tools in our toolbox to provide “capital-A” affordable housing. The graduated square foot cap gives us two natural options for an affordability incentive. First, the we can allow another unit to be built if a proportion of the total units provided are deed-restricted affordable. This affordability incentive was added to the sliding-scale FAR in both Portland and Sacramento. Portland allows up to four units per lot in all residential zone districts without income restrictions, but five- to six-unit developments are only allowed when at least 50% of the units are affordable to households earning up to 60% AMI. This reminds me of the scattered 5- and 6- plexes in the BonTon. These give the neighborhood its beautiful variety and diversity, while providing more affordable units to own and rent in one of Bozeman’s most expensive neighborhoods. Sacramento gives us a model for another option in their “Local Bonus” program. They increase the FAR allowance within their sliding scale for projects that include deed restricted affordable units. This could be easily translated into the graduated square foot cap; for example, a fourplex that would be capped at 3,500 square feet for market rate units could build to 4,000 square feet if one or two of the units were deed restricted affordable. With an immense amount of work already invested into the proposed draft and the deadline for the updated code looming, I can absolutely understand that the addition of a new and nuanced policy is daunting. However, I have also witnessed the severity of the housing crisis in Bozeman and the challenges before the city in creating affordable and sustainable housing. This is a problem that will require innovation, experimentation, and adaptation to solve. A policy like graduated square foot caps could be an opportunity to exercise those muscles in pursuit of a housing market that works for us, not against us. I ask that the city give it its full consideration. With gratitude, Eva Killenberg Sources: - Missing Middle Housing Toolkit for the Chicago Region [1] - Sacramento Adopts One of the Most Progressive Missing Middle Strategies in the U.S. - Opticos Design [2] - Terner Center - Unlocking the Potential of Missing Middle Housing [3] - MMH Study Report 4: Zoning, Design + Policy Recommendations (Sacramento) - Peer City Report | Unlocking Housing Choices (Denver) In visuals: