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HomeMy WebLinkAboutPCD 2026-04-13 Item 1B - Action - 2026 Comprehensive Plan Amendment DocketCity of Tukwila Thomas McLeod, Mayor Marty Wine, City Administrator AGENDA BILL ITEM NO. 1.B. Agenda Item Sponsor Legislative History Recommended Motion 2026 Comprehensive Plan Docket Items Nora Gierloff, DCD Director April 14, 2025 Planning & Community Development Committee April 27, 2026 Committee of the Whole ❑ Discussion Only ❑x Action Requested CONSENSUS TO forward proposed Comprehensive Plan amendments to the Committee of the Whole for finalizing the 2026 docket. EXECUTIVE SUMMARY Amendments to the comprehensive plan and map are only permitted once per year, except under specific limited circumstances. Due to this, proposed amendments are grouped together for action at the same City Council meeting. The comprehensive plan docket process is an iterative process which includes reviewing a proposed list of possible staff and privately initiated amendments to the comprehensive plan to identify which, if any, should be reviewed this year. Items included in the docket by Committee of the Whole will be forwarded to the Planning Commission for their review and recommendation and return to City Council for final decision or deferral in a fall meeting. DISCUSSION Staff did not receive any private applications for comprehensive plan amendments for the 2026 docket. City staff identified four items to include for consideration as further detailed below. If included in the docket, staff will provide a full analysis of the amendments to the Planning Commission and hold a public hearing. The Planning Commission will provide their recommendations before the items return to City Council for their consideration. Zone Consolidation The City has undertaken several significant rezones and zoning code amendments since 2023 which have modified allowed uses and development standards, while reducing the differentiation between several zoning districts. In part due to changes in state law, as well as elective decisions to create more usable development regulations, these changes have highlighted the opportunity for consolidation of zoning districts which are especially similar to other zoning districts, exist in only very small quantities of land or are not aligned with market and development realities. Staff would like to reevaluate the Office (0), Regional Commercial Mixed Use (RCM), Mixed Use Office (MUO) and Residential Commercial Center (RCC) zoning districts for consideration in consolidation of these zoning districts into existing or new zoning districts. If included in the docket a full proposal, including staff report, would be presented at a Planning Commission public hearing and receive their recommendation before the item returns to City Council. Tree Canopy Targets During the 2024 periodic update of the comprehensive plan numerical values associated with tree canopy coverage goals were inadvertently removed. While general goal language around tree canopy 11 coverage remains in the comprehensive plan, staff believes there is value in reinserting numerical values, updated by generalized use or zoning district, within the plan. Tree Canopy Goals (Goal 4.13) are proposed to be carried forward unchanged from the previous Comprehensive Plan. These goals were established after a robust public involvement process, including the convening of a Tree Committee comprised of a diverse group of stakeholders. Approximately 50% of Tukwila is impervious surface; tree canopy acts as crucial natural infrastructure, providing valuable citywide benefits such as reducing storm water loads on city infrastructure and improving water quality, fighting inequitable urban heating and air pollution, increasing aesthetics and wellness, habitat benefits and enhancing recreation. In summer 2026, staff will receive an updated tree canopy assessment, after which progress will be analyzed and next -steps identified; in coordination with Public Works, this process will also inform potential pathways for developing a ROW canopy goal. GOAL 4.13 Overall City-wide tree canopy increased to a total of 29% by 2034. Canopy cover in individual zoning categories increased by 2034 as listed below:* • Light Industrial zones: 3% increase from 20%, to achieve 23% cover • Heavy Industrial zones: 1 % increase from 9%, to achieve 10% cover • Tukwila Urban Center and Tukwila South: 5% increase from 13%, to achieve 18% cover • Office and Commercial: 3% increase from 29%, to achieve 32% cover • Parks: 5% increase from 38%, to achieve 43% cover • Public Rights -of -Way: Increase canopy coverage through street tree planting. • Specific canopy goal to be established based on future assessment. No net loss of canopy cover in individual zoning categories, as listed below: • Low -Density Residential: Maintain current City-wide canopy coverage of 47% • Medium- and High -Density Residential: Maintain current City-wide coverage of 40%* *Zoning districts will be updated to reflect recent zoning changes. If included as part of the docket staff will work to reintegrate tree canopy goal values into the comprehensive plan and return the item to the City Council with a Planning Commission recommendation. Housing policy alignment with King County Countywide Planning Policies The 2024 periodic update was the first to include review of city comprehensive plans by King County staff. This review focused primarily on meeting required housing policies in the King County Countywide Planning Policies. The County will also be conducting annual and five-year reviews to measure housing growth progress and ensure consistency with housing policy language. During the review process staff addressed many of the County concerns about inconsistent policy language and the plan was approved by King County. However, staff was not able to address all inconsistencies with countywide policies and proposes to revisit housing policy language in this year's update. A copy of the final review from the King County Affordable Housing Committee is included as an attachment. If included as part of the docket staff will work to rectify items identified in the County's review and create new policy language to fill deficiencies, to be reviewed by the Planning Commission and https://tukwilawa.sharepoint.com/sites/clerksintranet/Council Agenda Items/04-13 PCD Committee/Comp Plan Docket/4-13-26_PCD_DocketMemo (1).docx 12 subsequently returned to City Council. Please note, some items identified in the review have been subsequently rectified by separate code amendments. Parks, Recreation and Open Space Plan Coordination The Parks and Recreation Department is currently updating their Parks, Recreation and Open Space (PROS) plan with anticipation of adoption later in 2026. In the 2024 periodic update of the comprehensive plan the Parks, Recreation and Open Space (PROS) Element was largely guided by the current PROS plan. In order ensure alignment with any changes to the PROS plan, staff proposes incorporating any major changes from the update to the PROS plan into the associated element. ATTACHMENTS • Presentation • AHC Review Letter https://tukwilawa.sharepoint.com/sites/clerksintranet/Council Agenda Items/04-13 PCD Committee/Comp Plan Docket/4-13-26_PCD_DocketMemo (1).docx 13 Comprehensive Plan Amendment Docket Planning & Community Development Committee April 13, 2026 Comprehensive Plan Amendment Process • The Comprehensive Plan can only be updated once per year, except for specific limited circumstances (RCW 36.70A.130(2)) • These amendments require significant staff analysis, noticing and Planning Commission time before being considered by City Council Comprehensive Plan Amendment Docket Planning Et Community Development Committee April 13, 2026 Docketing Process • The docketing process allows the City Council an opportunity to provide a preliminary decision on whether to advance potential comprehensive plan amendment topics • This "yea" or "nay" vote on a topic sets the final docket of amendments for consideration and gives staff direction on how to proceed Comprehensive Plan Amendment Docket Planning Et Community Development Committee Apri. 13, 2026 2026 Docket • No private applications for comprehensive plan amendments were received • Staff identified four proposed amendments for the docket Comprehensive Plan Amendment Docket Planning Et Community Development Committee April 13, 2026 Item 1: Zone Consolidation • Recent updates to zone standards have narrowed the difference in both allowed uses and development standards of several zoning districts within Tukwila • Staff proposes exploring consolidation of several zoning districts which are currently very similar in allowances to other zoning districts, limited in overall acreage or otherwise compelling for consolidation Comprehensive Plan Amendment Docket Planning Et Community Development Committee ApriL 13, 2026 Item 1: Zone Consolidation • The following zones are under consideration for consolidation into existing zoning districts • Office (0) • Regional Commercial Mixed Use(RCM) • Residential Commercial Center (RCC) • Mixed Use Office (MUO) Unincerperau King County Burin City of Tukwila Zoning Map Figure 18-10 d e1 ,41 ;111‘1111;rilliliiifte >Erfl !OM kil4V % SaaTat Zoning Districts and Overlays C R - Community Residential H DR - High Density Residential MUO - Mired Use Office P • Office ItCC • Residential Commercial Center NCC • Neighborhood Commercial Canter RC - Regional Commercial !District RCM - Regional Commercial Mi, ed•Uee GLI - CommarciaVltlght Industrial LI - Light Industrial HI - Heavy Industrial MICR - Manufacturing Industrial Cener (tight) MICIH - Manufacturing Industrial Center (Heavy In 1VS-Tukwila Valley South TUC-P - Pond -UGRC - Regional Center -UC-CC - Commercial Corridor TUC-WP - Workplace TUGTOD • TsansitOriented Development ® Tukteila South Overlay Urban Renewal Overlay ® Manufacturing Ind. Center O nrlay E Public Recreedon Overlay CI] Potential Annexation Area fl�Nila Pk j�� 0 0.5 I i 1 Mi Comprehensive Plan Amendment Docket Planning Et Community Development Committee April 13, 2026 Item 2: Tree Canopy Goals • During the 2024 periodic update of the comprehensive plan numerical tree canopy targets previously adopted were inadvertently removed • While general language still exists in the current plan, staff suggests reintegrating numerical values developed by the Tree Committee stakeholder group Comprehensive Plan Amendment Docket Planning Et Community Development Committee April, 13, 2026 Item 2: Tree Canopy Goals • 2015 comprehensive plan language GOAL 4.13 Overall City-wide tree canopy increased to a total of2996 by 2034. Canopy cover in individual zoning categories increased by 2034 as listed below:* Light industrial zones: 3% increase from 2096, to achieve 23% cover Heavy Industrial zones: 196 increase from 996, to achieve 1096 cover Tukwila Urban Center and Tukwila South: 5%increase from 1396, to achieve 18% cover Office and Commercial: 396 increase from 29 96, to achieve 3296 cover Parks: 596 increase from 3896, to achieve 43% cover Public Rights -of -way: increase canopy coverage through street tree planting. Specific canopy goal to be established based on future assessment. No net loss of canopy cover in individual zoning categories, as listed below: Low -Density Residential: Maintain current City-wide canopy coverage of 47% Medium- and High -Density Residential: Maintain current City-wide coverage of 4096 • Current comprehensive plan language GOAL EN-11 Overall City tree canopy increased in diversity and total cover, with an increase in the use of native species, by2034, and No Net Loss of canopy cover in individual zoning categories, or environmentally critical areas and open spaces. Comprehensive Plan Amendment Docket Planning Et Community Development Committee April 13, 2026 Item 3: Housing Policy Alignment • King County review of the comprehensive plan identified certain policies that do not comply with certain housing policies within the Countywide Planning Policies • Staff proposes exploring additional policy language or modifications to existing language to comply with Countywide Planning Policies Comprehensive Plan Amendment Docket Planning Et Community Development Committee AprAprt 13, 2026 Item 4: PROS Element Update • The Parks and Recreation Department is currently updating the Parks, Recreation and Open Space plan, with the intention to complete the update later in 2026 • Staff proposes to align significant changes in the PROS plan with the PROS element of the comprehensive plan Comprehensive Plan Amendment Docket Planning Et Community Development Committee April 13, 2026 Request • The Planning and Community Development is requested to forward the item to the April 27, 2026 Committee of the Whole • City Council is requested to approve the docket of items for comprehensive plan amendment consideration with any removal of any items they see fit Comprehensive Plan Amendment Docket Planning Et Community Development Committee April 13, 2026 Affordable Housing Committee KING COUNTY GROWTH MANAGEMENT PLANNING COUNCIL CHAIR Claudia Balducci King County Councilmember VICE CHAIR Alex Brennan Futurewise MEMBERS Susan Boyd Bellwether Housing Jane Broom Microsoft Philanthropies Kelly Coughlin SnoValley Chamber of Commerce Amy Falcone Kirkland Councilmember, Sound Cities Association Nigel Herbig Kenmore Mayor, Sound Cities Association Thatcher Imboden Sound Transit Ryan Makinster Washington Multi -Family Housing Association Sunaree Marshall On behalf of King County Executive Dow Constantine Ryan Mclrvin Renton Councilmember, Sound Cities Association Cathy Moore City of Seattle Councilmember Teresa Mosqueda King County Councilmember Lynne Robinson Bellevue Mayor, Sound Cities Association Veronica Shakotko Master Builders Association of King and Snohomish Counties Robin Walls King County Housing Authority October 3, 2024 Neil Tabor, AICP Senior Planner City of Tukwila 6200 Southcenter Boulevard Tukwila, WA 98188 Dear Mr. Tabor, Thank you for submitting the City of Tukwila's draft Comprehensive Plan to the Affordable Housing Committee's (AHC) Housing -focused Draft Comprehensive Plan Review Program for review on August 8, 2024. On behalf of the AHC, I am sending you this summary of our review and recommendations. Background The AHC is a subcommittee of the Growth Management Planning Council (GMPC), consisting of representatives of King County and its cities, housing providers, area employers, and others. By direction of the GMPC, the AHC now conducts a housing - focused review of all King County jurisdictions' draft periodic comprehensive plan updates, assessing the draft plans for alignment with the King County Countywide Planning Policies (CPP) Housing Chapter goals and policies prior to plan adoption. As you know, our county is experiencing a deep and persistent housing shortage. In 2021, the State of Washington adopted House Bill 1220, which amended the Growth Management Act, requiring local governments to plan for and accommodate housing that is affordable to all income levels, including emergency housing. In response to this state mandate and local interest in improving the effectiveness of local housing plans and policies, the AHC led a two-year process to amend the King County CPPs. The result was a significant update to the CPP Housing Chapter, which was recommended by the GMPC, adopted by the King County Council, and ratified by the cities in 2023. The goals of both the statute and this implementation work are to encourage cities and King County to work together to provide a full range of affordable, accessible, healthy, and safe housing choices to every resident in King County. This review is guided by Housing -focused Comprehensive Plan Review Standards, as adopted by GMPC Motion 23-2. In summary, the AHC review seeks to determine whether each jurisdiction's draft plan and submission materials: 1. address all CPP Housing Chapter policies; 2. articulate implementation strategies for relevant CPP Housing Chapter Policies; and 3. lay out meaningful policies that, taken together, support the jurisdiction's ability to equitably meet housing needs. This program is still relatively new and evolving, and your engagement helps the AHC understand how jurisdictions are seeking to address their housing needs while aligning with the recent changes at the state, regional, and county levels. Maiko Winkler -Chin On behalf of Seattle Mayor Bruce Harrell 25 The AHC acknowledges the substantial amount of time and effort that went into Tukwila's draft comprehensive plan. During review, the AHC noted that many of Tukwila's plans, policies, analyses, and implementation strategies align well with CPP Housing Chapter policies. In particular: 1. Tukwila's housing inventory and land capacity analysis provide a solid foundation for the draft plan. The detailed review of existing housing stock, land availability, and potential for future development demonstrates a clear commitment to planning for and accommodating the city's current and future needs, as required by CPPs H-1 and H-11. 2. Tukwila's draft plan prioritizes economic development and job creation, particularly in areas designated for mixed -use and industrial development. The focus on integrating high-tech, office, retail, and residential uses within the Tukwila South Overlay area is a strategic approach to creating a multi -use employment center that can drive economic growth and provide opportunities for residents. This strategy aligns with CPP H-15, which emphasizes the importance of increasing housing choices near major employment centers to improve the jobs -housing balance. Below, the AHC includes recommendations necessary for Tukwila to align with the CPP Housing Chapter policies. Recommendations to Align with the CPP Housing Chapter The AHC recommends Tukwila take the following actions to align its draft comprehensive plan with CPP Housing Chapter goals and policies. 1. Plan for and accommodate housing needs (CPP H-1) Relevant Countywide Planning Policies CPP H-1 requires Tukwila plan for and accommodate its allocated share of countywide future housing needs for moderate-, low-, very low-, and extremely low-income households as well as emergency housing, emergency shelters, and permanent supportive housing. Tukwila's Proposal and AHC Findings Policy H2.2 states that Tukwila will "encourage housing development to all income segments sufficient to meet needs consistent with adopted targets." However, CPP H-1 requires that jurisdictions plan for and accommodate allocated housing needs for moderate-, low-, very low-, and extremely low-income households, as well as emergency housing, emergency shelters, and permanent supportive housing needs. Recommendation 1: To align with CPP H-1, Tukwila should also commit to planning for and accommodating moderate-, low-, very low-, and extremely low-income housing needs, not just growth targets, as well as emergency housing, emergency shelters, and permanent supportive housing needs in Policy H2.2. 26 2. Identify sufficient capacity of land for emergency housing needs (CPPs H-1 and H-11) Relevant Countywide Planning Policies CPP H-1 requires Tukwila plan for and accommodate 1,748 net new housing units, including 1,242 emergency housing beds. CPP H-11 requires jurisdictions identify sufficient capacity of land for emergency housing. Tukwila's Proposal and AHC Findings The draft plan's Housing Background Report identifies that Tukwila lacks adequate capacity to accommodate its target of emergency shelter and emergency housing. It also identifies intensity of use and spacing requirements that serve as barriers to the development of emergency housing facilities (page 39). Policies and associated implementation strategies in the draft plan address this gap, including a commitment in implementation strategy H2.(4.5).1 to "review and amend regulations and fees for emergency shelters, transitional housing, emergency housing, and permanent supportive housing (STEP Housing) through code amendments and to ensure capacity and feasibility of STEP Housing development." However, Tukwila did not include an emergency housing capacity analysis. Without this analysis, the AHC cannot determine if Tukwila is planning for and accommodating its emergency housing need and has sufficient land capacity to accommodate its emergency housing need allocation, as required by CPP H-11. Recommendation 2: To align with CPPs H-1 and H-11, Tukwila should show sufficient land capacity for its allocated emergency housing needs. Tukwila should follow Washington State Department of Commerce's guidance for completing an emergency housing land capacity analysis. 3. Prioritize extremely low-income households (CPP H-2) Relevant Countywide Planning Policies CPP H-1 requires that Tukwila plan for and accommodate 1,367 units affordable to households below 30 percent of area median income (AMI). CPP H-2 requires Tukwila to prioritize the need for housing affordable to households less than or equal to 30 percent AMI (extremely low-income). Tukwila's Proposal and AHC Findings The draft plan demonstrates sufficient capacity for 0 to 30 percent of AMI housing needs. However, the AHC is concerned that policies and implementation strategies in the draft plan do not prioritize 0 to 30 percent of AMI housing needs. Specifically, Tukwila indicates that Housing Element policy H2.1 and H2.2 and implementation strategy H2.(1-3).1 address CPP H-2. Policy H2.1 states that Tukwila will encourage production in all neighborhoods of diverse housing types that are appropriate for residents in all stages of life and all household sizes. H2.1. states that Tukwila will encourage development affordable to all income segments sufficient to meet needs consistent with adopted targets. Neither of these policies names housing affordable to 0 to 30 percent of AMI households or demonstrates a clear prioritization of extremely low-income households. Implementation strategy H2.(1-3).1, which commits Tukwila to amend its residential development standards to incentivize broader diversity of housing types, increase incentives for affordable housing, and reduce 3 27 regulations that increase housing development cost, also does not mention extremely low-income households. Recommendation 3: To align with CPP H-2, Tukwila should explicitly prioritize the housing needs of extremely low-income households in plan policies and implementation strategies. For examples of strategies Tukwila could use to align with CPP H-2, see the CPP Housing Chapter Technical Appendix.' 4. Complete the housing inventory and analysis (CPP H-3) Relevant Countywide Planning Policies CPP H-3 directs jurisdictions to conduct a housing inventory and analysis to help identify and address the greatest needs as well as summarize the findings in the Housing Element. Tukwila's Proposal and AHC Findings While Tukwila's submission includes many data points and substantive analysis, the AHC could not find specific information required by CPPs H-3(b), (g), (m). This includes: b. the number of existing housing units by condition; g. population age by race/ethnicity; and m. the housing needs of communities experiencing disproportionate harm of housing inequities including Black, Indigenous, and People of Color. This analysis should inform additional comprehensive plan policy responses and strategies. For example, analysis responsive to CPP H-3(m) could help Tukwila further identify and address gaps in existing partnerships, policies, and dedicated resources for eliminating racial and other disparities in access to housing and neighborhoods of choice, as required by CPP H-4 and H-20. Recommendation 4: Tukwila should include all inventory and analysis components as required by CPP H-3 and summarize the findings in the Housing Element. This additional analysis should inform additional comprehensive plan policy responses and strategies. 5. Identify and address gaps in policies to meet the jurisdiction's housing needs (CPPs H-4, H-12, and H-13) Relevant Countywide Planning Policies CPP H-4 requires jurisdictions to evaluate the effectiveness of existing housing policies and strategies to meet the jurisdiction's housing needs and identify gaps in existing partnerships, policies, and dedicated resources for meeting housing needs. CPP H-12 requires jurisdictions to adopt and implement policies that improve the effectiveness of existing housing policies and strategies and address gaps in partnerships, policies, and dedicated resources to meet the jurisdiction's housing needs. CPP H-13 requires jurisdictions to implement strategies to overcome cost barriers to housing affordability. 1 Washington State Department of Commerce (2023 August). Guidance for Updating Your Housing Element. Page 33. [link] 28 Tukwila's Proposal and AHC Findings Tukwila's draft Housing Background Report discusses barriers to housing development, specifically housing affordable to incomes below 80 percent of AMI (pp. 36-37). The report also proposes strategies to enable greater affordable housing production, including reducing restrictive development requirements, streamlining development and design review processes, and providing incentives for affordable housing development (pp.37-38). However, this discussion does not outline specific gaps in policy effectiveness, existing partnerships, and dedicated resources, nor specific cost barriers to housing affordability to which outlined strategies are meant to respond. The draft plan also does not commit the City to implementing any strategies identified in the Housing Background Report. Instead, the draft plan generally proposes to "identify and remove excessive regulatory barriers to housing production" (Policy H1.2), "modify residential zoning designations and development standard to align with city goals" (Policy H1.3) and "pursue establishing, or expanding, programs to provide tax incentives for increased housing development" (Policy H3.2). Therefore, the AHC finds that the draft plan does not meaningfully: • evaluate the effectiveness of existing housing policies and strategies to meet the jurisdiction's housing needs and identify gaps in existing partnerships, policies, and dedicated resources to meet housing needs, as required by CPP H-4; • adopt and implement policies that improve the effectiveness of existing housing policies and strategies and address gaps in existing partnerships, policies, and dedicated resources for meeting the jurisdiction's housing needs, as required by CPP H-12; and • implement strategies to overcome cost barriers to housing affordability, as required by CPP H-13. Recommendation 5: To align with CPP H-4, Tukwila should include an analysis that identifies specific gaps in the effectiveness of existing housing policies and strategies to meet the jurisdiction's housing needs and identify gaps in existing partnerships, policies, and dedicated resources for meeting housing needs. This analysis should inform draft policies and implementation strategies that address CPPs H-12 and H-13. Tukwila should commit to addressing specific gaps in adopted policies and implementation strategies. Tukwila may provide updated implementation strategies to the AHC in 2025. Please see the Washington State Department of Commerce's "Adequate Provisions Checklists" as a guide for how Tukwila could conduct a gap analysis and address gaps in policies and strategies. 6. Prioritize the use of local and regional resources for income -restricted housing (CPP H-14) Relevant Countywide Planning Policies CPP H-14 requires jurisdictions prioritize the use of local and regional resources (e.g. funding, surplus property) for income -restricted housing, particularly extremely low-income households, populations with special needs, and others with disproportionately greater housing needs. 5 29 Tukwila's Proposal and AHC Findings Tukwila indicated in their submitted completeness checklist and implementation strategies that draft policy H2.2 and implementation strategy H2.(1-3).1 address the requirements of CPP H-14. Draft policy H2.2. states that the City will "encourage housing development affordable to all income segments sufficient to meet needs consistent with adopted targets." Implementation strategy H2.(1- 3).1 commits Tukwila to amend its residential development standards to incentivize broader diversity of housing types, increase incentives for affordable housing, and reduce regulations that increase housing development cost. Neither the policy nor implementation strategy demonstrates an intention to prioritize local or regional resources, such as funding or surplus public land, for income -restricted housing. Policy H2.2 and implementation strategy H2.(1-3).1 also do not mention regional or local resources or refer to extremely low-income households, populations with special needs, or other groups with disproportionately greater housing needs. Recommendation 6: To align with CPP H-14, Tukwila should include a policy and implementation strategy that commits Tukwila to prioritizing available resources for income -restricted housing (e.g. funding, surplus property), particularly extremely low- income households, populations with special needs, and others with disproportionately greater housing needs. For strategies to align with CPP H-14, see the CPP Housing Chapter Technical Appendix.2 7. Expand and support the supply of income -restricted housing near high -capacity and frequent transit while mitigating displacement (CPPs H-16, H-17, H-21, and H-23) Relevant Countywide Planning Policies CPP H-16 requires jurisdictions to expand the supply and range of housing types, including affordable units, at densities sufficient to maximize the benefits of transit investments throughout the county. CPP H-17 requires jurisdictions to support development and preservation of income - restricted affordable housing near high -capacity transit. CPP H-21 requires that jurisdictions adopt policies and strategies that promote equitable development and mitigate displacement risk; mitigate displacement that may result from planning efforts, large-scale private investment, and market pressure; and implement anti -displacement policies prior to or concurrent with development capacity increases and public capital investments. CPP H-23 requires that jurisdictions adopt and implement policies that protect housing stability for renter households and expand protections and supports for moderate-, low-, very low-, and extremely low-income renters and renters with disabilities. Tukwila's Proposal and AHC Findings Tukwila's draft plan's future land use map (FLUM) proposes both "High Density Residential" and "Regional Commercial Center" zones —both of which allow for housing types typically affordable to households below 80 percent of AMI—in close proximity to the Tukwila International Boulevard Link light rail station. The FLUM also proposes maintaining high -density residential districts along frequent and high -capacity transit routes, include Metro's RapidRide. The draft plan designates the zone in immediate proximity to the city's Sounder station as a "Tukwila Urban Center - Transit 2 King County Countywide Planning Policies Appendix 4: Housing Technical Appendix, page 92. [link] 6 30 Oriented Development" zone which contains a substantial portion of the city's total capacity for housing types typically affordable to households earning less than or equal to 80 percent of AMI. The AHC commends these efforts to orient future housing development around frequent and high - capacity transit; however, the AHC finds that proposed plan does not meaningfully expand the supply and range of housing types, including affordable units, at densities sufficient to maximize the benefits of these transit investments, particularly light rail and RapidRide, as required by CPP H-16. The plan also does not meaningfully support the development and preservation of income -restricted affordable housing that is within walking distance of these existing high -capacity and frequent transit investments, as required by CPP H-17. Specifically, the draft plan maintains low -density zones within one -quarter and one -half -mile buffers of its existing light rail station, RapidRide stops, and frequent transit stops, particularly along International Boulevard directly south of State Route 518 and west of State Route 599 (Housing Background Report, page 36). Many of these areas are also designated as "qualified census tracts" by the Department of Housing and Urban Development, which are more likely to see federal low- income housing tax credit investment than others (Housing Background Report, page 6). The draft plan also does not commit to adopting any specific incentives for affordable development within zones near transit, despite discussing such incentives in the Housing Background Report (page 37). The AHC recognizes that Tukwila has identified areas nearby International Boulevard as at high risk of potential displacement and that increased development capacity sufficient to maximize nearby transit investments could result in unintended displacement of low-income renters, immigrant households, and communities of color from homes and businesses (Housing Background Report, pp.32-34). However, the AHC considers low-income housing development to be a key anti - displacement strategy. There is also potential for Tukwila to implement new tenant protections and other displacement mitigation and equitable development measures to support potentially impacted communities, in alignment with CPPs H-21 and H-23. Recommendation 7: To align with CPPs H-16 and H-17, Tukwila should amend, edit, or propose new land use and housing element policies and implementation strategies to support the development and preservation of affordable housing near its existing light rail and RapidRide stations. The City should also implement new, higher density zones or overlays and affordable housing incentives that would support the development and preservation of affordable housing near transit. Concurrent with development capacity increases, Tukwila should implement measures that mitigate the involuntary relocation of residents, cultural assets, and businesses from their current locations and promote equitable development in areas at high -risk of displacement, particularly nearby to International Boulevard, in alignment with CPP H-21. Tukwila should also expand renter protections, in alignment with CPP H-23. For strategies to align with CPPs H-21 and H-23, see the CPP Housing Chapter Technical Appendix.3 Conclusion and AHC Resources Thank you again for your submission to the Committee's Housing -focused Draft Comprehensive Plan Review Program. AHC members valued the opportunity to review Tukwila's draft Comprehensive Plan 3 King County Countywide Planning Policies Appendix 4: Housing Technical Appendix, pp. 99-101. [link] 7 31 and related submission materials. Tukwila's participation in the plan review program is instrumental in the broader work of the Committee to empower local jurisdictions to address the affordable housing crisis in King County. AHC staff are happy to assist Tukwila in addressing these recommendations. For immediate resources and guidance on aligning with the CPP Housing Chapter, refer to the: • Engrossed 2021 King County CPPs; • AHC Housing -focused Draft Comprehensive Plan Review Program Guide; and • King County Resources for Documenting the Local History of Racially Exclusive and Discriminatory Land Use and Housing Practices. The AHC would also like to acknowledge that Tukwila may be challenged to address recommendations in this letter before the state -mandated deadline for comprehensive plan adoption of December 31, 2024, and may potentially adopt a comprehensive plan in 2024 that is not in alignment with the CPP Housing Chapter. In that case, the City is encouraged to amend its plan in 2025 to incorporate AHC feedback and bring its plan into alignment with the CPP Housing Chapter policies. If you have questions or need additional information regarding aligning with the CPP Housing Chapter, please contact lead staff for the AHC plan review program, Carson Hartmann, at AHCplanreview@kingcounty.gov or 206-848-0681. Sincerely, Claudia Balducci Affordable Housing Committee Chair King County Councilmember, District 6 CC Dow Constantine Growth Management Planning Council Chair King County Executive Laura Hodgson Senior Planner Washington State Department of Commerce Plan Review Team Puget Sound Regional Council Plan Review Team King County Affordable Housing Committee 32