DEIS Issued for Seattle 2035 Comprehensive Plan

Alternatives 1 and 2 for growth, courtesy of DPD.
Conceptual urban village boundaries for Alternatives 1 and 2, courtesy of DPD.

Yesterday, the City of Seattle issued the Draft Environmental Impact Statement (DEIS) for the city’s comprehensive plan update, known as Seattle 2035. The comprehensive plan update will guide how Seattle grows, and covers things like housing, land use, transportation, environment, utilities, capital facilities, parks, and neighborhoods. The 394-page DEIS is the first version of the comprehensive plan update to analyze four different alternatives for growth, their anticipated impacts, and potential options to accommodate each alternative. Specifically, Seattle 2035 spans a 20-year planning horizon and plans for 120,000 new residents and 115,000 new jobs. Each alternative considers these growth targets in their analysis.

In a statement, Seattle Mayor Ed Murray said that “Seattle’s new Comprehensive Plan will be our blueprint for a more walkable, livable community. Race and social justice must be a foundational value as we update our plan. In the coming years, we need to encourage healthy growth and prosperity for all our diverse communities.” Mirroring the heart of what the Mayor said and complementary initiatives of his administration, the DEIS sets out seven core objectives for Seattle’s future Comprehensive Plan:

  1. Retaining the urban village strategy and achieving a development pattern in line with it;
  2. Leveraging growth to create housing choices and to promote healthy, complete communities;
  3. Creating jobs and economic opportunity for all Seattle residents;
  4. Building on regional transportation investments and balancing transportation investments;
  5. Supporting strategic public investment that addresses areas of need and maximizes public benefit;
  6. Becoming a more climate-friendly city; and
  7. Distributing the benefits of growth more equitably.

Alternatives Evaluated by DEIS

The DEIS is built upon four alternatives: Alternative 1 which is the Continue Current Trends (No Action) Alternative, Alternative 2 which is the Guide Growth to Urban Centers Alternative, Alternative 3 which is the Guide Growth to Urban Villages Near Light Rail Alternative, and Alternative 4 which is the Guide Growth to Urban Villages Near Transit Alternative. Each alternative is demonstratively different in their land use patterns as described below:

Distribution of households and jobs between all four alternatives, courtesy of DPD.
Distribution of households and jobs between all four alternatives, courtesy of DPD.
  • Alternative 1 is an approach to growth that targets land use development in the same patterns we’ve seen over the past 20 years. It focuses new job growth in Downtown Seattle and South Lake Union while residential growth takes place in urban centers and urban villages. It assumes that market trends remains generally the same as today.
  • Alternative 2 guides growth to the city’s established urban centers. It assumes that these centers will become even more dominant destinations for new residents and jobs than previous decades. It has the benefit of further encouraging people to walk and bike while reducing their dependence on driving.
  • Alternative 3 focuses growth in the city’s urban villages near light rail and urban centers. While growth in urban centers remains important in this alternative, special emphasis is placed on accommodating much of the growth in urban villages where they are–or will be–served by light rail transit. Boundary changes are possible within 10-minute walksheds of existing and planned light rail stations. For instance, a new urban village could be designated at I-5 and NE 130th St during the plan period while a reconfiguration of the Mount Baker and Jackson-23rd & Union urban villages could occur in conjunction with the opening of a light rail station at I-90.
  • Alternative 4 envisions growth for urban villages near frequent transit, which includes both high quality bus and rail service–not just light rail. More urban villages would be slated for increased growth capacity than conceived by Alternative 3, including expanded urban villages in Ballard, Crown Hill, Fremont, and Alaska Junction.
Conceptual urban village boundaries for Alternative 4 and Alternative 3, courtesy of DPD.
Conceptual urban village boundaries for Alternative 4 and Alternative 3, courtesy of DPD.

Chapter 2.1 of the DEIS has some really big nuggets tucked away within it. Potential changes for zoning, comprehensive planning, and housing policies are recommended:

Boundaries of Urban Centers and Villages. Consider whether to expand boundaries of certain existing urban villages and create new urban villages in order to direct growth to places that have either light rail or superior bus service. Expanded boundaries of urban villages containing high-frequency transit stations would be drawn to represent a 10-minute walking distance from the transit. A possible new urban village at 130th and I-5 would recognize a future light rail station there.

Future Land Use Map. In the urban villages, potentially replace the generalized land use designations with a single designation for each type of urban village (Residential, Hub and Urban Center). The single designation would be accompanied by policies that describe the types and intensities of uses allowed in each type of village. This change is intended to provide greater clarity about the planned future development pattern in each type of urban village and indicate limits to the most intense growth.

Rezone Criteria. Potentially eliminate land use policies that establish detailed and strict criteria about when it is appropriate to change zoning from a single-family designation. This is the only zoning category that is addressed this way in the Plan and is at a level of detail that is more appropriate for the Land Use Code.

Homeownership. Consider eliminating the goal of increasing home ownership over time as outdated and no longer applicable in Seattle.

Affordable Housing. Consider adding affordable housing as an appropriate use of City surplus land, along with some guidance for how to select among the various possible uses of surplus property. Potentially incorporate new policies that emerge from the City’s Housing Affordability and Livability Agenda.

Each of these may seem like brief and simple statements on potential changes, but they represent a huge shift. For instance, the proposal to simplify the Future Land Use Map (FLUM) designations in urban village designated areas could provide greater flexibility, certainty, and clarity. Currently, urban villages consist of designated boundaries on the FLUM, but underlying land use designations are still called out separately and generalized, which add a significant degree of ambiguity on how zoning should be implemented within the urban villages. It’s conceivable that the urban village districts can be better described at the subarea plan level or in policies as opposed to ambiguously indicated on the FLUM. Meanwhile, dropping the goal of homeownership is a strong statement that the city should be focused on all tenancy types regardless of whether a resident is a renter, social welfare or co-op tenant, or condo or fee simple property owner.

How To Get Involved

The Department of Planning and Development (DPD) is seeking public input on Seattle 2035. A 45-day public comment has been opened and will run until June 18, 2015. While all comments will be considered in Final Environmental Impact Statement, it is best to provide DPD with comprehensive comments covering issues you think are important for the Department to analyze and why one alternative–or combination of alternatives–is best. You can visit the online open house to explore the elements of the DEIS and take a quick online survey.

DPD will hold a public open house and hearing on May 27th from 6pm to 8pm at City Hall in the Bertha Knight Landes Room. Additionally, written comments can be sumbitted online, at, or mailed to DPD.

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Stephen is an urban planner with a passion for sustainable, livable, and diverse cities. He is especially interested in how policies, regulations, and programs can promote positive outcomes for communities. Stephen lives in Kenmore and primarily covers land use and transportation issues for The Urbanist.

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What’s interesting is that the maps show a Link infill station at Boeing Access Road, but not at Graham Street. I would’ve expected the latter, since Boeing Access Road would only serve as a transfer point for Sounder and an additional P&R instead of influencing development of any kind.


Boeing Access Road station was removed from the Link (and Sounder) rail plans long ago, but it still shows up on some old maps.


When discussing Seattle’s future, we all need to keep in mind that under current plans and current zoning, we have more than enough development capacity to accommodate expected growth for the next 20 years.

Last September, the City published its Development Capacity Report, and on page 2 the City says — “Based on current zoning, DPD estimates that the city has development capacity to add about 224,000 housing units and 232,000 jobs, a sufficient amount to accommodate the 70,000 households and 115,000 jobs the Countywide Planning Policies assign to Seattle for the next 20 years. About 77% of the housing capacity and 78% of the jobs capacity are within an urban center, hub urban village or residential urban village. An additional 16% of the jobs capacity is within manufacturing and industrial centers.”

Since Seattle can already accommodate more than 3 times the projected growth, why are we discussing expanding development capacity even further? The City’s own report says what we have is sufficient.


If you read the whole report, not just the summary, it isn’t as rosy.

Sure, we have room for 220k units.

As long as those 220k units are all in places like downtown, capitol hill, and SLU. And as long as most of the newcomers are happy living in one-bedroom apartments. And we’ll also need to bulldoze / rebuild the buildings in these areas that aren’t built to current zoning.

I’m not against any of that. But the areas where growth is allowed are the areas that are *already* comparitively dense. They’ve already been hit pretty hard by new construction.

The cities approach for growth thus far has been ‘Denser’ urban villages. At some point, they are going to need ‘More’ urban villages.Places like Montlake, Ravenna, Bryant, and Phinney are, at the least, going to need to allow townhomes.


The obvious answer is not to focus on the arbitrary and already expensive “urban villages”, but the vast majority of the city, which is zoned as single family. These areas need to grow, and if they do, they will provide much more affordable housing. The best solution to the housing problems that we have is to liberalize the ADU laws so they match (or even exceed) those of Vancouver BC and Portland Oregon.


You have a good point about about code changes to allow more ADUs and DADUs (what they call laneway housing in Vancouver). But that might result in a few hundred new units per year, at most, not the thousands that are needed.

And urban villages are not arbitrary, and quite a few are not expensive — see my other comment about the non-development occurring in Seattle’s South End.


My response to your other comment is the same as this one: Change the ADU laws if you want cheap housing. Just walk through what has to happen if you rezone a single family area to allow an apartment. First, someone has to buy a perfectly good house and just throw it away. Then they have to go through a review, build parking and then construct a six story building. That isn’t cheap. Unless rent is really expensive, it isn’t worth it (just keep the house). But now consider what has to happen to for an ADU. If it is attached, you just do a little work (like adding another door and maybe knock down a wall connecting to a bathroom). If it is detached, you just build a little bungalow (and those are much cheaper than they used to be). Either way, it is pretty cheap, and you retain the entire value of the existing property.

But in Seattle, you need to allow for parking. And you have big restrictions on the size and the number of units ( The toughest restriction is that someone has to own both properties. That is nuts. Very few home owners want to be a landlord. Very few landlords want to be a home owner living next to their tenant (and only be a landlord for that one property). This means that after you make this improvement — after you obviously add value to the property — you have trouble selling it. I’ve seen it in my neighborhood. Two houses going for around 500,000. If sold separately, they would get about 700,000 (400,000 for the big one, 300,000 for the small one) but again, very few people want to be a landlord. Meanwhile, if you own a property and rent it out, you can’t add an ADU. You can tear it down, put up a monster house, but you can’t add an ADU.

These aren’t small things. This is how Vancouver has grown and grown substantially ( There is basically no ADU work being done in this city despite the fact that we have really high rents and really high housing prices. In a city like this, where we have about 300,000 houses (and lots) this is huge. Much of the growth in Vancouver came before laneway houses were added (as that article points out). That explains how much of Seattle (like the Central Area) has much higher density, despite very few stand alone apartments (and very few new ones). Back when they were allowed, people lived in basement apartments or houses that were split up into apartments. They also had smaller or irregular sized lots. These are the ways that the city can grow substantially, and at very little cost.

Don’t be fooled by the cranes. Height does not necessarily equal density. We can greatly increase the number of people per acre without tearing down all the houses — just like Vancouver did.


Development capacity measures a hypothetical maximum, based on zoning. So it means that if you have a four story building, it assumes it will be torn down and replaced by a five story one. That could happen, but only if rent is really, really high.


Not exactly. The capacity report does try to model what would feasible to develop. You can read the report here:


Fair enough, I stand corrected. So the modeling basically assumes the same type of growth we have had in the past — rapidly increasing rents leading to a lot of new development, but not to the levels I suggested. It is interesting to see that the area that has the most land (Single Family) expects some of the least amount of growth. Good news for land owners and landlords. Bad news for renters.

See my other comment for the obvious solution.


The reason to pursue upzones in specific areas, even though the city has enough development capacity, is because you want growth to occur in those areas. It makes sense to create the economic incentive to align growth around areas where there is sufficient infrstracture. If you read the report you mention, they point this out:

“Why upzone when so much
development capacity exists?

While the city may have enough development capacity
overall, upzones may be proposed to encourage
growth in very strategic locations. Upzoning (changing
the zoning of a parcel from one category to another)
has occurred in urban centers and villages where the
potential for major job and housing growth increased
because of the transit investments. For example,
voters approved Sound Transit 2 in 2008, a$17.8 billion
investment to construct the LINK (light rail) system.
Zoning changes can leverage this investment for more
housing and job growth in key locations. Upzones may
help to implement policies in comprehensive plan and
neighborhood plans that encourage residential and job
growth in urban centers and villages.”


I wish up zoning was really the magic wand that could make redevelopment happen. But it isn’t. Look at all the up zoned areas around Link light rail stations in the South End, some up zoned even before light rail was in service. And redevelopment has been happening at a snail’s pace, even in this hyper-hot development market.

So it’s naive to think that sweeping rezones of SF to MF is really going to accomplish anything, other than piss off a lot of people in the neighborhoods.

Several stars must align before any redevelopment project actually gets built, and zoning is only one of those. You still need a willing property owner (seller) and a willing developer. And you need a project that can get financing (tougher to do with urbanists touting “no parking!”) And in the South End, those stars are just not aligning.


Of course, but planning departments can only control so much of this and the biggest incentive they can provide is more dense zoning.


Yes, but wouldn’t those “stars align” more often if we picked more galaxies (to torture your analogy)?

For example, let’s say I’m looking to build an apartment and I have only one block to choose from. One guy doesn’t want to sell (he lives there). The other is willing to sell, but he has a two story warehouse that is making money. Those are the only two lots on the block. lot. If rent it really high, I buy the warehouse, tear it down and build an apartment. This is what it is like in Capitol Hill and Ballard (although it is typically nice houses that are torn down — but it is not that way in the South End.

Now the city allows another block to open up. One guy has a has a parking lot and is willing to sell. I buy the lot and build (the stars have aligned, even in the cheap part of town).

Of course, that is only half the story of zoning. You are focusing only on the height limit. There are a bunch of other limits (required parking, massing, FAR, limitations on the number of units, etc.) that all, ultimately, add to the cost of building. Maybe the builder figures he can get financing with added parking, but maybe not. Maybe he can save some money (especially with low rise) but the city requires parking, so he has to build it. Same with the units (they can’t be too small). I’m surprised they don’t require a swimming pool. Anyway, with all of those added costs (beyond what is required for the health and safety of the occupants) building a new apartment only makes sense if rent is high.

The smaller the place, the more onerous the restrictions. Build a 15 story building, and you will probably add parking anyway (although maybe not as much as required). Build a townhouse or three story apartment and you might not. Meanwhile, the parking takes up a much bigger chunk of land (and your profits). Add an ADU and you really aren’t likely to add parking. The six story buildings are in between. Those restrictions are expensive enough to restrict development in some neighborhoods (where rent is not that high) but not others (where it is).

Personally, I can understand the height restrictions, but I find the restrictions based on parking and density to be unfair. Why should it be OK to tear down a nice little house and build a huge monster house, but only if one family (meaning a single guy) lives there? Why can’t you build the same house, but make it a duplex. Better yet, why can’t you convert the existing house to an apartment? If the point is preservation, then we should allow conversions.


You’re rambling too much for me to follow, so just a couple comments in response. I am not “focusing only on the height limit.” I am focusing on the reality that Seattle was developed with single-family homes covering much of its residential area, and that’s not going to change very much.

I see no evidence that there are thousands of homeowners just chomping at the bit to build ADUs and DADUs and are turned away from the permit counter for lack of parking. Yes, the code should be liberalized, but don’t expect miracles. Like I said above, hundreds of new units each year, not thousands.

And density does matter — the higher the density (measured by FAR) the more infrastructure has to be in place to support it.


OK, no rambling this time. To summarize:

1) Increasing the amount of land available under higher zoning increases the chances that land will be developed.

2) The other restrictions and requirements greatly increase the cost of development, making it unlikely in low rent areas.

3) These types or restrictions and requirements have the greatest impact on the cheapest properties (the smallest properties).

4) Home owners may not be begging to build ADUs, but landlords are prevented from building, which means that overall, it has a huge effect.

5) Vancouver dramatically grew as a result of more liberal ADU laws, and I see no reason (given our huge stock) why we wouldn’t do the same.

That is about as succinct as I can make the arguments. I expand upon them for the rest of this comment.

You said that rezoning parts of Seattle will have no effect. All the “stars have to line up”. I agree. Just because an area is zoned for six stories, doesn’t mean that you will have six story buildings. But if you double the amount of land that allows six story buildings, you double your chances, plain and simple. The south end is still growing, by the way, just not as much. This is because the line before it makes sense is much lower. Buy a parking lot and it makes sense to develop anywhere in the city. Buy a house and it only makes sense in the high rent districts.

The second point is that height restrictions are only one part of zoning. If they allow six story buildings, but require hot tubs in every unit, then you will only get six story buildings where rent is really high. Think of all the restrictions — FAR, unit size (no apodments), parking, reviews, massing, etc. All of these add substantially to the cost and are similar to the hot tub requirement. This is why you only see the cranes where the rent it high (and you see fewer in the South End).

The third point is that these types of restrictions effect smaller units more than they do bigger ones. It is simply an economy of scale. This is one reason why Portland and Vancouver build so many more ADUs (they don’t have the parking requirement).

Meanwhile, I think you missed the key point of why we see so few ADUs in Seattle. The ownership requirement. In Vancouver or Portland, a landlord can own a dozen houses. In Seattle a landlord can own a dozen houses. In Vancouver or Portland, a landlord can own a dozen houses with ADU (detached or not). In Seattle a landlord can’t. So, basically, even if people don’t want to develop the land themselves, the next buyer will, because the next buyer will be a landlord.

Not that I accept your argument (just because you don’t know anybody that doesn’t want to add an apartment, doesn’t mean they aren’t out there). But you don’t have to take my word for it, just look at Vancouver. It went through the same sort of growth pressure we did, but because the laws were more liberal, they responded with tons of infill. Some neighborhoods essentially doubled their density without the big cranes (see previous reference). Not that this stuff happens overnight — but no growth does. All these big cranes in Seattle and the city is still growing about 2 or 3 percent. That is because the huge growth is only happening on tiny parts of the city. Most of the land is seeing very little growth, because most of the land is zoned single family. It wouldn’t take much (much less than Vancouver experienced) to make a huge difference in overall growth (at way more affordable prices) if we liberalized our ADU rules. There are around 300,000 houses in Seattle. If we had only one out of a hundred new units a year, we would get about 3,000 new units a year, or close to double the amount that this report suggests we would get in twenty years (from 70,000 to 130,000).

Capacity strawman

The light rail station areas were barely upzoned and some of it was done in the middle of the recovery from a recession. Even Beacon Hill and Columbia City are getting too expensive for the middle class, nevermind longtime residents, because the upzones were so limited, and most of our city is still single family and competition for access to light rail brings people with the money to spend in these locations.

Capacity strawman

Yes, there is plenty of capacity in Ballard for people who can afford $700,000 homes.