Our council at work: reviewing the Housing Element of the Comprehensive Plan

By Stan Matthews

County Communications Program Manager

The San Juan County Council has scheduled a workshop on proposed changes to the Housing Element of the County Comprehensive Plan for 2 p.m. on Tuesday, April 7.

In preparation for that meeting, members have submitted written questions and comments to staff for review. Those comments (unedited except for some minor re-formatting) are in the attached document. The comments are also posted on the County website at: https://sanjuanco.com/docs/news/Housing_Comments_040309.pdf

The Council will re-open the public hearing on the proposed changes at 10:50 a.m. on April 14^th and is expected to take final action on the changes after that hearing.

Council Member Questions and Comments on

Proposed changes to the Housing Element of the County Comprehensive Plan

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Comments by Council Chair

Rich Peterson

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First, I would like to offer some overview comments about the structure of the draft plan.  I believe that the plan should be as simple and straightforward as possible while meeting the goals established for it.  I think that any assertions presented that fall within the realm of debatable points should be supported by evidence, that all obstacles to housing affordability be explored, and that available solutions be considered according to their merits and weaknesses.  Further, an objective reader without personal bias or prejudice should be able to conclude that the plan is, itself, objective and not agenda-driven.

Given the context above, my specific comments follow:

1.                  On several pages of both the staff report and the exhibits (pages 1, 2, and 7 – staff report and exhibit, page 7) there is mention of an inventory of “existing and projected housing needs.”  A discussion of current rental unit availability should, I believe, be included.  For the sake of accuracy, if, in fact, the available stock is the result of current economic conditions, and if that stock has a traceable wide fluctuation, then that should be stated.

2.                  In the staff report pages 2 and 3 “point form” statements, there are several assertions that don’t appear to be supported anywhere.  Possibly, I just missed the substantiation.  Also, some, if true, seem to be left hanging when additional discussion somewhere seems to be needed.  Further, the second point on page 2 (3,500 people shortage) seems to be in conflict with point number three, page 2 of exhibit 2 where it states that 3,000 workers will be needed daily even if we build the houses.

3.                  Staff report page 3, point 2, states that our multi-family stock is well below the state average, yet I can find no further discussion about trying to increase multi-family stock.  If it is a problem, shouldn’t it be addressed?

4.                  Staff report page 3, point 3:  Is there support for this statement anywhere or is it just a “known fact.”?

5.                  Staff report page 3, point 4 is supported where?  If this is true, then it seems that this is a major factor in explaining why people cannot afford homes here.  Shouldn’t there be more exploration of the need to increase wages?  Are wages predictably expected to remain comparatively low though 2025?  Won’t market factors of supply and demand of workers drive wages up if our numbers of workers diminish?  Why would 3,000+ workers be willing to bear the inconvenience and expense of a daily ferry commute to come here as described at the top of page 6, exhibit #1, if they could earn 30% more by working on the mainland where they live?

6.                  Staff report page 3, point 5 is confusing to me.  I think what it is trying to say is that the majority of the working population cannot afford the sufficient units that are already here.  All of the units here now are already owned by someone.

7.                  Ordinance page 3:  I need to understand the organization better.  It doesn’t seem to follow correctly outline sequence.

8.                  If we adopt the ordinance with sections 1, 2, and 3 on page 3 as set forth, do the referenced documents become law too?  Are they essentially a fait accompli?

9.                  Ordinance, page 4, first paragraph:  explain “rural rebound.”

10.              Ordinance, page 4, final sentence:  Where is the “table 3 above”?  It appears to be omitted.

11.              Ordinance, page 8, “District by District Forecasts”  What are these districts?

12.              Exhibit 1, page 11, 5.2.A #2 seems to describe projects like “The Oaks,” yet it is my understanding that we do restrict this kind of development.

13.              Exhibit 1, page , 5.2.A #3,  I believe, should remain and not be stricken.  Understandably a policy decision to be determined by the council.

14.              Exhibit 1, page 11, 5.2A #4, again speaks to “The Oaks” – type developments in my opinion and seems contradictory to our reality.

15.              Exhibit 1, page 12, 5.2.B #2:  Seems to me to foreclose any further deliberation about a Housing Authority and just simply makes it happen.

16.              Exhibit 1, page 13, 5.2.B #4, says we should establish what the voters turned down, in spite of that history,

17.              Exhibit 1, page 13, 5.2.B #5, seems to say that we can impose a whole lot of conditions upon the Town of Friday Harbor.  Are we serious?

18.              Exhibit 1, page 13, 5.2.B #15:  Where did the number 12 come from?  This seems to limit the ability to build an “Oaks”-type development when earlier this seems to be encouraged.

19.              Exhibit 2, page 2:  Something is wrong with the numbers on points 3 and/or 5.  It says to me that if we build 2,969 units we will have to import 3,000 workers daily, but if we build 2,689 (280 less), we can house them all.

20.              Exhibit 2, page 7:  I believe that at least one more premise should be added because it seems implied, i.e.

#9.  That wages will continue to be so low that wage-earning families will not be able to afford housing.  (I personally do not accept this premise).

21.              Exhibit 2, page 10, the statement  following table 5-3:  “As can be seen from the table above…and local government is the county’s largest single employer.”  This statement may be true but the referenced table certainly doesn’t show it.

Finally, I believe it is important for advocates of affordable housing (and I believe myself to be one) to not overstate the problem.  As early as 1906, the Friday Harbor Journal warned that as wealthy part-time residents and tourists continued to arrive in increasing numbers, “the man of moderate means will become dispossessed through the purchasing power of wealth.”  In the intervening 103 years we have not only survived, but thrived without major government intervention in affordable housing efforts.

I have additional typographical suggestions that can be covered during the work session, and other issues may occur to me but as of now the above points comprise my concerns.

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Comments by Council Member

Gene Knapp

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§5.2.B

1.  delete.         It is clearly aimed at Land Bank properties

and will turn the 73% of voters who voted for the Land

Bank tax (twice) into opponents of Affordable Housing

(Land Bank tax proceeds and properties can only be used

for land preservation purposes in any event).

2.  delete.         The appropriate use of Housing Authority

Assistance for San Juan County is as stated in #3.

7.  delete.         (see response to #1 above)

16.  Should read:    “Evaluate the creation of a transfer of

development rights program” (the Council has already

agreed to do the evaluation when it gets time).  The

program is controversial and needs ample discussion

before a decision should be made.

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Comments by Council Member

Howie Rosenfeld

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HOUSING NEEDS ASSESSMENT QUESTIONS/CONCERNS/SUGGESTIONS
Comments Howie Rosenfeld

Suggest adding wording regarding everyone island/countywide benefitting from urbanization of UGAs to justify some form of financial support.

1. Concern that Home Trust/other CLTs land is assessed at market rate when their value is contractually (legally?) lower, resulting in unrealistic tax rate.
2. Peg Manning claim that “GMA does not require the provision of affordable housing”, true or not? Can we just claim adequacy and get compliance?
3. Is there any current provision for “density bonuses” for affordable housing? Is this a good tool?
4. Mike Bertrand’s question: How Co. will direct growth into Town? Goal or will there be policies?
5. If Co. directs growth into the Town/UGAs, what is the Co.’s responsibilities to financially or otherwise support the costs of this growth?
6. Lisa Byer’s amendment suggestions?
7. The Islands Trust relies heavily on accessory dwelling units to supply affordable housing. Follow their lead?
8. Are we the only Co. in state without a housing authority?
9. What is it we can do that we’re not already doing? Are we limited to a Housing Authority? Other options?
10. Clarification that there is no possible residency qualification to get housing authority residence? Can the housing authority board limit the number of units to match local demand as a strategy?

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Comments by Council Member

Richard Fralick

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I have a number of document organization and factual questions that I have already given to the County Administrator via a marked up copy of both Appendix B and Section B, Element 5, Housing for consideration by staff.  I hope that he will be getting back to me with some answers prior to the workshop.

With regard to Section B, Element 5, Housing, as a bare minimum I think the document should be clearly organized to reflect the requirements of RCW 36.70A.070 with “…goals, policies, objectives and mandatory provisions for the preservation, improvement, and development of housing…” In the document as written I find goals and policies; objectives and mandatory provisions are not clearly set forth.

Philosophically I think we should provide just what we are required to provide, nothing more and nothing less, thus reserving to the County as much flexibility as possible to deal with our future housing needs as they change.  In this regard I would ask a response from the CD&P to Orcas attorney Peg Manning’s comment, in her communication to the Council,  “… the plain fact is that the County can comply with the GMA by approving a simple update that reflects the population estimates, acknowledges that there is sufficient land in the County zoned to accommodate housing for that population growth, and sets forth the incentives already in place for affordable housing.  This approach has been used successfully in other counties and has already been approved by GMHBs.”

For the purposes of the Housing Element Workshop scheduled for Monday, April 6, as a bare minimum I would like to see the following items in the Section B, Element 5, Housing discussed:

A growth rate of 2.2 %, is this straight line or compounded?

Why in table 5-B are the percentages of 2000 carried forward to 2025.  There may be good planning reasons to set different ratios in the future.  Surely year 2000 is not the ideal?

According to Table 5-B, in 2008 there were 7452 households.  At a growth rate of 2.2% (assuming straight line) this results in 164 new households/year not the 175 on page 5.  What am I missing?

Percentage of upper-income households on page 5 is stated as 29 percent.  Table 5-B says 28%.  Please make them consistent.

Page 5 the numbers in “Addressing Housing Need Resulting from Population Growth” appear to be inconsistent with number of additional housing units for very-low and low additional housing units at the bottom of the page.  Once again what am I missing or at least make them consistent.

What do you mean by “workers” and “working families”.  Please define.  Also I do not see where you include persons who work but do not get a wage per se.  It is demeaning to hard working entrepreneurs, small business owners, farmers, etc who work hard but appear not to be included in the working demographic.  It can also skew the income numbers.

One of the critical issues that I do not see discussed any where in the documents is why the median household income in San Juan County is low.  It is implied that the median income is low because people are willing to work for less to live in paradise.  Projecting this forward (in Appendix 5, Summary) it is stated that even if “2,969 housing units” are built an additional “3000+ workers will need to be brought to the islands daily”.  This statement fails to acknowledge market forces.  In such a scenario,  people will only be working in paradise not living in paradise.  This is not much (if any?) of an incentive (counter-incentive?) to work for less and wages can only rise in such a scenario.  We need to discuss how this will cause future housing needs to change.

In “Housing Policy” # 2 storm water regulations are mentioned.  This appears to be an after-thought (sentence is not even complete) and there is no discussion anywhere else that I can see.  Either discuss this more thoroughly or take it out.

In “Policies for Affordable Housing” I would like to see the following discussed:

Rental Housing:  Discuss as affordable housing in a comprehensive fashion.

# 2.  Housing Authority.   The Council needs to vigorously discuss this as an option before committing to it.  It has significant implications for the future of housing and the taxpayers in the County.  There are  few questions that have been asked but for me have yet to be answered.  What is the County’s role to be in providing affordable housing?  What specific benefits would accrue to the County by establishing a housing authority?  What would it do?  What would it cost?   John Campbell, a leading affordable housing advocate in the community, has proposed using a public corporation structure instead of a housing authority.  What are the advantages/disadvantages of  this approach? To proponents of a housing authority I would say the following.  It is neither “fear mongering” nor is it “inappropriate” to ask for this discussion.  Let’s have an open and frank conversation before a decision is made.  Everyone will be better served.

#4.  Permanent Funding Mechanism.  The voters must be involved in this decision and any policy for establishing a permanent funding source must explicitly state this.  It should be acknowledged that they have already spoken by rejecting an earlier REET.  This does not mean that a future, differently (better) formulated tax proposal would not pass.  It is my belief, that any County funded affordable housing program should only be established by a majority vote of its citizens.  Language should reflect this.

#6.  Does this mean the entire UGA or sub-districts within the UGA?

#10.  Housing Support Services.  What are these, who does it, what will it cost and is this really something the County needs or can afford to do?

#21.  Utility Limited Improvement Districts.  As we learned, the County does not have the authority to do this.  Should we get the authority, do we want to establish them?  What utilities are we talking about?  What would a ULID look like in view of the current private utility providers that exist?  Let’s discuss.

There are many more questions but if we can answer the above questions I think we will be a lot closer to making an informed decision.

Thanks for taking the time to read my perspective on this.

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Comments by Council Member

Lovel Pratt

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General comments at this time:

Given that RCW 36.70A.070 (2) (d) requires “adequate provisions for existing and projected needs of all economic segments of the community” it is not an option to pursue ‘Alternative 1. Do Nothing’, or ‘Alternative 2. Develop plans to accommodate the movement of the workforce out of the county’ (unless the RCW above can be satisfied by providing housing for some economic segments in other counties).

In selecting ‘Alternative 3. Develop an effective response to the shortage of affordable workforce housing’ I suggest that first of all we remove the word ‘workforce’.  Even though housing for seniors, for example, is not explicitly listed in the above RCW, I think that the Housing Needs Assessment should be inclusive of all housing needs.  However, I think it is important for Housing Needs Assessment and the Housing Element to clearly identify SJC’s priorities and to create a strategic approach to address SJC’s Housing Needs (and clearly workforce housing is a priority).

In 5.2 I recommend that we list the goals along with those policies that will achieve the goals.  Some goals are being addressed with existing policies/programs.  To be strategic, I recommend that those goals that are determined to be a priority that are not currently being addressed would then be a priority for SJC to address via policies/programs/funding.

Specific comments at this time:

5.2.A.6: Instead of including households with up to 150% AMI would it make more sense to include an index (assuming that the affordability index will change and likely the %AMI of those households needing access to affordable housing programs will go up)?

5.2.B.2.  I had previously requested the following regarding a workshop on a Housing Authority:

• Address the desired specific outcomes/goals of a SJC Housing Authority (i.e. access to additional section 8 vouchers, public/private development with tax credits/incentives, etc.) and look at alternative options to achieve those outcomes/goals
• Workshop attendees include representatives for all local stakeholders
• Workshop presenters can address both pros and cons of a Housing Authority

5.2.B.9. Change the first word ‘Develop’ to ‘Revise’.

5.2.B.15 Ad ‘Master Planned Resorts’ to the list of allowable land use districts (see request to come from Brent Snow):

Provide for a limited number of small-scale rural residential cluster developments of no more than twelve dwelling units each within Village, Hamlet, Residential Activity Centers, Master Planned Resort, and rural lands, excluding Resource, Natural and Conservancy designated lands.

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Comments by Council Member

Bob Myhr

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On the draft ordinance itself (031609.doc)

• Background

Section E. 6.  Change the word “will” to “may”

Section E. 7.  a. Change “is driving out” to “creates hardships for”

Section E. 7.  b.  Change “is keeping” to “makes it economic challenging for”

Section E. 7.  c.  Begin the sentence with the words “Much of [o]ur population

Section E. 7.  d.  Rewrite all of d. to read as  follows: ” The county can take steps now to encourage affordable housing for our working population to help address concerns some have expressed as potentially radical changes to the community.”

• Staff Report, March 27, 2009, for March 31, 2009, Council Meeting

Section 5.2.A, Item 13, iv.  Change spelling of ‘principle” to “principal”

Other comments:  correct safe house numbers; provide date on rental inventories on April 7

• Com Plan, Section B, Element 5, Housing, March 2009, Exhibit 1

Page 5, in general:  Housing should be tied to projected employment, not population.

Page 5: Sentence in the middle of the page should read as follows:  “Affordable housing need to be provided on each of the islands in proportion to growth in full-time population and employment.”

Page 5, bottom of page:  What happens to houses of those nearing retirement is only hearsay.

Page 6, top of page:  I do not understand the basis for the first three sentences underlined at the top of the page.  I do know that most recent hirees of the county have come at “mid-career” or early retirement or with equity from a prior location.  I have not seen good indicators that the county or other employers are not finding capable employees.  Besides first time home buyers, it seems that rental might, indeed, provide for needed housing—not just first time home buyers in the county.

Updating on 2010 Census—perhaps this element should have 2012 or 2013 “sunset” clause, or at least mandatory revision based on most recent data.

Page 7, middle of the page:  What is the real number of all parcels in the county?  How many are built on?  How many still buildable?

Page 8, what does “gentrification” mean?  Yes, anecdotal.  I think this whole paragraph should simply state that the San Juans are a desirable place to live and the market has pushed up prices—and avoid value judgments as to who the buyers are.

Page 8, middle of the page.  I take exception to rural residential clusters and request that it be taken out of the plan.  Clusters in UGAs, hamlets, villages, Lamrids are appropriate.  Rural clusters tend to create  sprawl (no matter how well designed or done),   They are inconsistent with a key priority of the county: “Protecting our natural, scenic, and open space resources.”  They add to the islands becoming “suburbia” outside of population centers.

Top of Page 9 first full sentence at the end:  Change “will drive families” to “may continue to make it economically difficult for families in the county.”

Page 10:  We still keep putting off what is meant by the term “permanently affordable”

Page 11: 5.2.A.

Put original no. 3 back in

Page 12: 5.2.B

2.-3  Change to read as follows:  Review advantages and disadvantages of a SJC Housing Authority.  Consider, instead, trying one or two projects with another adjacent Housing Authority to learn from the experience

Page 13-14, 5.2.B. 15.  Make the first sentence read as follows: ” Provide for no more than 10 small-scale residential cluster developments of no more than twelve dwelling units each within designated Village, Hamlet, and Residential Activity Centers.”   Take out the word “rural” and not allow said clusters on rural lands.

Page 14, Item 20.  Pretty much is at the state level and the county cannot affect much.