Next Monday, when the North Delridge Neighborhood Council meets (agenda/time/location here), the Downtown Emergency Service Center‘s proposed “supportive housing” project will be on the agenda again, as it’s been for most meetings since news of the plan broke at NDNC’s meeting last June. The group also is helping recruit members for the community advisory group about the project, the Delridge Alliance (here’s how to apply). And tonight, we have more information about the major development we first reported two days ago – the city’s decision to cut the number of units allowed in the project, from 75 to 66. We finally heard from DESC, which had no comment aside from confirming the new unit count that we found in documents filed with the Washington State Housing Finance Commission, which will review the agency’s application for key Low-Income Housing Tax Credits financing. DESC executive director Bill Hobson referred us to the city Office of Housing for the explanation. WSHFC provided us with a copy of the internal city memo that spells it out.

We don’t have a scanner handy, so we’re transcribing it. It’s dated December 12, to Office of Housing director Rick Hooper from staffer Maureen Kostyack, who attended the second of two private-home meetings where neighborhood concerns about the project were discussed. The subject is “Siting Policy Waiver for DESC Delridge Supportive Housing” and it’s on OH letterhead. (It also reveals that the roots of this project go back as early as 2010.):

This memo reviews the waiver granted for the DESC Delridge supportive housing project in light of updated information about housing counts in the Census block group.

Initial Application of Consolidated Plan Siting Policy

In 201 and again in early 2011, DESC and its consultant Common Ground requested that OH staff calculate the allowable extremely low-income housing in Census block group 10700.1, where they were considering purchasing a development site. Based on data in effect at that time, we determined that the block group contained 877 total units, of which 99 were extremely low-income units. Per the Consolidated Plan siting policy, we determined that 76 additional extremely low-income units would be allowed.

DESC proceeded with project planning, land purchase negotiation, and community outreach based on a proposed 75-unit supportive housing project. The proposed development has fewer units than permitted by zoning, and would be permitted under the City’s siting policy without a waiver.

In July 2011, Common Ground requested a consistency letter as required for DESC’s application for City funding. As part of the required checklist, we calculated the allowable number of extremely low-income units permitted under the siting policy. This calculation used the latest housing data provided by DPD. DPD uses Census data as a baseline, then updates the total housing counts quarterly, adjusting for new construction and any demolitions. For the last 10 years, DPD’s housing count used 2000 Census data as the baseline, with new construction units added and demolished units deducted over time. On April 1, 2011, with the release of 2010 Census data, DPD’s housing count began using the 2010 Census data as the new baseline. Unexpectedly, the 2010 Census reported fewer units in the block group than what was in DPD’s database prior to April 1, 2011. Therefore the number of additional extremely low-income units in the block group allowed without a waiver dropped to 63 units. OH has no established protocol for dealing with a change in data from the Census. For DESC to proceed with the proposed 75-unit project, a waiver would be required for the additional 12 units.

In response to this unexpected change, we reviewed the housing policy to determine whether the project met one or more of the waiver criteria specified in policy. We consulted with SHA regarding planned market-rate housing in the High Point development. SHA informed us of 80 market-rate homes planned for the western edge of the block group containing DESC’s project. These planned units increased the permitted extremely low-income housing to 78 new units, which would have allowed for DESC’s 75-unit project. Based on this planned growh, and consistent with the siting policy, OH approved a waiver and issued a consistency letter for the project.

Review of Siting Policy Waiver.

In recent weeks we have reviewed the housing counts in the Census block group. We discovered that the 2010 Census divided several Census tracts in two around the city, including the Census tract where the DESC project will be located. Previously identified as block group 10700.1, the block group is now identified as 10701.1. As such, the Census block group boundaries changed slightly as well. We also received more information on SHA’s planned units at High Point, including addresses that were not established at the time of the waiver. With this information, we reanalyzed our data to confirm total existing housing units and extremely low-income units in the new block group. This detailed review revealed that most of the market-rate units planned for High Point would in fact be located outside the block group containing the DESC project. In addition, three extremely low-income housing units are no longer located within the block group. Using this revised data, only 66 additional extremely low-income units would be permitted at the DESC site under the siting policy.

In light of this reduced number, we once again reviewed waiver criteria in the siting policy to determine if a waiver is still justified. Two options were considered:

*Natural Barrier. The policy permits a waiver if natural or man-made barriers (e.g. bluff, waterway, or freeway) physically separates the proposed project from existing concentrations of subsidized rental housing for extremely low-income households. 1) The bluff to the west of the DESC site fits this description of a natural barrier, and separates the site from 15 units of extremely low-income housing at High Point. However, a proportional amount of market-rate housing is located in HIgh Point. As a result, the concentration of extremely low-income housing in the eastern portion of the block group remains unchanged. 2) The greatest concentration of extremely low-income housing in the block group is contained in an SHA building over 1 mile south of the DESC site on Delridge Way SW. This site, although physically removed, does not meet the definition of natural or man-made barrier.
*Reasonable accommodation. The policy permits the OH Director to make reasonable accommodations “when such accommodations may be necessary to afford handicapped persons equal opportunity to use and enjoy a dwelling.” In this instance, the Director determined that the policy does not apply.

Revised Consistency Letter

The criteria used to justify the waiver approved by the OH Director was based on data which was thought to be correct when the waiver was approved, but now is understood to be incorrect. It appears there is no longer a basis for a waiver and the maximum number of extremely low-income units is 66. The consistency letter needs to be revised and reissued.

That was followed by a December 15th letter from OH director Hooper to Steve Walker, director of multifamily housing and community facilities at WSHFC, explaining this turn of events and asking WSHFC to let DESC “submit an application for tax credits using budgets based on a 75-unit project with the understanding that the City of Seattle is now asking DESC to reduce the size of the project to 66 units to fully comply with our Siting Policy. … Through no fault of its own, DESC did not have time to prepare revised tax credit program application materials for a slightly reduced project size to meet the Finance Commission’s deadline.” This letter is the document in which OH says that DESC is “actively working to adjust their proposal to this change” by January 31st. Meantime, the project has to go through Design Review at least one more time; the date for the second meeting is not yet set.