Herbold: Mandatory Housing Affordability DEIS Has Room For Improvement

by Kamna Shastri

On July 31, Seattle Councilmembers passed legislation approving a zoning change in Seattle's Chinatown International District. The modification in the zoning code is the first step in kick-starting the city's Mandatory Housing Affordability program in the neighborhood, a program that has been highly contested in the CID community.

Just two weeks ago, on July 18, over two hundred and fifty community members — spanning multiple generations— gathered for a Town Hall meeting organized by InterIm CDA at the Nisei Veterans Committee Memorial Hall. The sweeping sense of anxiety over displacement due to development hung in crowded space's air.

Now that zoning changes have been approved, developers can build up to 170 feet in designated areas of the CID and up to 270 feet in others. The historic core of the neighborhood West of I-5 will not undergo any changes.

But questions remain: how will development transform the neighborhood? And how will the Mandatory Housing Affordability program, meant to combat our city's housing crises, impact neighborhoods like the CID that are home to many low-income residents and communities of diverse racial and ethnic backgrounds?

The MHA would require developers — who could build taller buildings due to zoning changes — to include a certain number of affordable, rent-controlled units in their buildings, or pay into a fund that would finance affordable housing projects around the city.

The goal of the MHA program is to increase the number of affordable housing units as the city grows to accommodate long time Seattleites and the influx of new residents. According to the program summary, the MHA program would provide an estimated 6,300 affordable units by the year 2025.

The Draft Environmental Impact Statement for the MHA was released on June 8. Initially set for June 28, the public comment period for the document was extended until August 7. The document is more than 400 pages and details the environmental and community impacts of implementing the MHA program in three alternative ways. Their breakdown is as follows:

Alternative 1: MHA would not be implemented, and development would occur as it is occurring now.

Alternative 2: MHA would be implemented, but would not account for displacement risk and access to economic opportunity when deciding on development capacity in what the study defines as "urban villages".

Alternative 3: MHA would be implemented, and development capacity would be based on each urban village/ neighborhood's risk of displacement and access to economic opportunity.

The DEIS details how each of these scenarios would affect housing and socioeconomics, land use, aesthetics, transportation, historic and biological resources, open spaces and recreation, utilities, air quality and greenhouse gas emissions.

But there are some crucial points the DEIS doesn't fully consider, says Councilmember Lisa Herbold. She specifically takes issue with the Housing and Socioeconomics chapter, which studies how MHA would affect both those dynamics across the Seattle region.

She points out that the study uses low income households as a stand-in for race, failing to clearly trace how racial demographics will affect how different communities are impacted by MHA.

"As it relates to the three different alternatives, they haven't looked to see whether different races may be impacted differently by the different alternatives," said Herbold.

She also says the study doesn't examine smaller geographical regions focusing instead on an analysis of a wider area range. That's a problem because there could be specific effects on certain populations who would be glossed over when grouped into a larger pool.

Herbold also points out that a section in the chapter studying current and historic displacement doesn't have a true sense of displaced households, based on the metrics used to measure them.

"The thing that is so alarming to me is that during the study period they did a look back on the displacement that occurred in the city…they used the people who qualify for the tenant relocation assistance ordinance as their proxy for low-income displaced people," Herbold said.

The Tenant Relocation Assistance program cited in the DEIS is limited in how it informs understanding the number of people facing displacement. Herbold has worked with the program in previous experiences and says the program doesn't deal with people who are displaced economically, or because of rent increases. It also only assists those people who earn 50 percent of the $89,500 area median income (AMI), when in fact anyone earning 80 percent AMI or less is considered low income and might also be vulnerable to displacement.

According to Herbold, these specific critiques aren't fully addressed by the DEIS, though they hold weight for communities that are dealing with the nuanced effects of development — which causes not only economic and physical displacement, but cultural displacement as well.

Section 3.29 of the Housing and Socioeconomics chapter studies displacement reads "no formal data currently exists to measure cultural displacement, despite signs that it is occurring in some neighborhoods," suggesting a gap in understanding the full extent of displacement on vulnerable populations. Because the DEIS will inform how the MHA program will play out in the future, the content of the study will influence upcoming legislation and finally how it will change the city.

Herbold has asked for a more thorough review of the combined role of race and lower incomes in contributing to high displacement risk in areas undergoing rapid development.

Finally, Herbold stated that the MHA is not a panacea to Seattle's affordable housing crisis, though the DEIS says "increasing development capacity and encouraging market rate development in high displacement risk areas is an anti-displacement strategy."

Responding to the phrasing, Herbold says "I don't want to pretend that adding a certain number of additional housing is not helpful in driving down rents, but it has never in any housing market in the history of time been sufficient to counter increasing rents in a high development [areas].. so adding more units might slow the pace of rent increases, but it's not at a sufficient enough rate to actually be a complete anti-displacement strategy."

Enforcing a commitment to mitigate displacement

In 2016, the City passed a displacement analysis resolution stating that "the Council reaffirms its commitment to manage future growth of the City in a manner that continues to encourage racial and social equity and minimized any potential disproportionate impacts on future development on marginalized populations, especially people of color and low-income populations."

Herbold says the resolution was significant because the council came together and unanimously committed themselves to find ways to mitigate displacement impacts that would come with the MHA program.

The council called on the Office of Planning and Community Development to help identify those exact impacts and mitigation strategies. Herbold says those analyses were not done, and has sent a letter to Director Sam Assefa with comments on the DEIS and a request to look deeper into how MHA will affect disadvantaged populations.

Seattle's commitment to equity and justice isn't just abstract and ideological, however— it's a promise codified in the City's race and social justice initiative. That's a point many speakers at InterIm's Town Hall Meeting emphasized on July 18. The initiative reads that by 2017, the City of Seattle will "ensure racial equity in City programs and services to make tangible differences in people's lives", among other goals.

With nearly a three-quarters of 2017 complete, Herbold's observations about the MHA DEIS raise important questions about how racial equity, and equity more broadly, will play out as Seattle works to remedy its affordability crises, while development continues during an economic boom.

The DEIS comment period has been extended until August 7^th. More information on the MHA program and the Environmental Impact Statement can be found here: https://www.seattle.gov/hala/about/mandatory-housing-affordability-(mha)/mha-citywide-eis

Featured image is a cc licensed photo attributed to Curtis Cronn