Olympia’s Planning and Development Department has decided that its new Housing Options Plan will have no significant impact on our environment and our neighborhoods. The plan prescribes new duplexes, triplexes, and apartments, along with larger and taller ADUs (Accessory Dwelling Units, a.k.a. “back-yard cottages”), along with relief from parking, on-site owner and other current ADU requirements.
The City’s position is that there are no immediate impacts from the plan per se, however there are cumulative impacts. It would unleash these by allowing “up to 950 additional, primarily market rate, infill development housing units in existing neighborhoods.”
The reality is that these added units would not be spread evenly across the city’s low-density housing zones. Certain neighborhoods will be unaffected or very lightly affected. Subdivisions completed over the past 20 or so years, during which time minimum lot sizes have been repeatedly reduced, leave little space for free-standing ADUs. Subdivisions consisting of Homeowner Associations typically have restrictions that limit construction to single-family detached houses — the City plan leaves these unaffected. Neighborhoods of high-property-value residences would be prohibitively expensive for conversion and replacement.
That leaves older, lower income areas as targets. Specifically, properties characterized by large lots with small, inexpensive houses that lend themselves to being torn down and replaced by the multiplex structures newly permitted under the City plan. These are primarily on the eastside, northeast, and northwest. The bottom line is that impacts will be concentrated in a limited number of neighborhoods, and will therefore be likely to have significant effects on those neighborhoods and their city services.
These effects reflect the entire range of impacts that the Environmental checklist (SEPA) claims will not occur in the category of neighborhood factors such as noise, loss of green space, loss of tree cover, and loss of solar energy capacity. The checklist also denies any impact due to environmental factors like increased impervious surface area, groundwater levels and quality, and stormwater runoff. Any impacts on public service elements like school capacity, street capacity, parking, sewer and water infrastructure, and stormwater conveyance capacity, some of which are already overburdened are also said to be nonexistent.
The City claims that structures will not be demolished and residents will not be displaced. The checklist says clearly that the intention of these policy changes is to add primarily market-rate infill housing in existing residential areas, a primary effect of which is demolition and displacement.
Another problem with the checklist responses is that they confuse likely actual impacts with allowed impacts. This is apparent in comments regarding view blockage, impacts on plants and marine life, the amount of impervious and hard surfaces, etc. A SEPA checklist is supposed to deal with impacts on the community, not impacts relative to regulatory limits, which is a very different matter.
A similar problem exists when the City states there will be no change in “available utilities”, but does not mention impacts on these utilities. The response to a question about negative impacts on transportation or public services and utilities is similarly problematic when it says that existing providers will continue to provide services, but fails to address the potential impacts on those providers.
Other responses are actually erroneous, as when the checklist states that there would be no impact in parking requirements. The proposed ADU element definitely includes such changes. The statement that there will be no increased need for public services like fire, police, transit, and schools ignores the fact that increases will be needed to serve the increased population moving into the new “housing options.”
A final concern not mentioned by the City is the fact that the “housing options” changes would, under state law, not be appealable. “Compliance with democratic norms” is not a listed criterion of course, presumably because it is generally understood that in democracies citizens are able to challenge actions by their elected officials. To state that appeals will not be allowed is to take a step away from democracy and toward authoritarianism. This is intolerable. This proposal should not be pursued unless a way can be found to allow normal appeals.
This is an edited version of official comments submitted by Bob Jacobs to the Olympia Planning Department. Bob is a long-time resident and former Mayor of Olympia.