HomeMy WebLinkAboutPlanning 2026-07-23 Item 7.2 - Housing Policies Alignment
City of Tukwila
Thomas McLeod, Mayor
INFORMATIONAL MEMORANDUM
TO: Tukwila Planning Commission
FROM: Nora Gierloff, Community Development Director
BY: Neil Tabor, Senior Planner, DCD
DATE: July 23, 2026
SUBJECT: Comprehensive Plan Amendments to Align Housing Policies
ISSUE
Four items were included on the City’s 2026 Docket of proposed Amendments to the
Comprehensive Plan. In this process the Planning Commission assists in the development of
amendments and provides a recommendation to the City Council on how to proceed with each
proposed amendment. This topic is a proposed amendment to the Housing Element to align
policies with the King County Countywide Planning Policies (KCCHP).
DISCUSSION
King County Housing Policy Alignment
As part of the 2024 periodic update to the City's Comprehensive Plan, the plan underwent a
certification review to confirm its consistency with adopted policies at the statewide, regional,
and countywide levels. The county-level review was focused on Housing Policies within the
document, as reviewed under the King County Affordable Housing Committee, guided by King
County Staff, with the final decision made by the Committee. This was the first comprehensive
plan periodic update cycle in which King County conducted a review of jurisdictional plans.
Tukwila’s plan was reviewed for compliance with Housing Policies within the King County
Countywide Planning Policies and was granted approval during the periodic update, with further
recommendations for alignment. Recommendations by topic are listed in summary below with
staff recommendations for amendments. Full comments from the King County Affordable
Housing Committee are available in full in the attached letter.
1. Phrasing of housing by income level and STEP Housing.
County Recommendation: Update STEP Housing Capacity and phrasing of housing targets.
Staff Suggestion: The Housing Element already specifies housing capacity and commitment
to housing targets by income level. Staff does not support notion that the existing policy
language does not meet the requirements of CPP H-1 to plan for and accommodate housing
needs across income levels. Staff does not propose a change to this item.
STEP Housing, or emergency shelters, transitional housing, emergency housing and
permanent supportive housing, capacity was updated in Ordinance 2756 and is fully
compliant with capacity requirements. Although a future STEP housing related update will
be forthcoming based on HB 2266, no further action is required for the purposes of
complying with KCCHPs.
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INFORMATIONAL MEMO
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2. Demonstrate capacity for STEP Housing
County Recommendation: Update regulations to supply a sufficient capacity for emergency
housing.
Staff Suggestion: STEP Housing capacity was updated in Ordinance 2756 and is fully
compliant with capacity requirements. No further action is required.
3. Prioritizing housing affordable to the lowest income level
County Recommendation: Amend policy language to explicitly prioritize housing affordable
to extremely low-income households.
Staff Suggestion: Extremely low-income housing, or housing affordable to households
making 0-30% AMI, is exclusively produced as income restricted housing outside of
traditional housing market dynamics. As the most difficult income level of housing to create
or replace staff agrees placing special emphasis on through modification of an existing
policy or creation of a new policy is appropriate. Staff will propose a new or modified policy
to accomplish this.
4. Demographic information for housing inventory and analysis
County Recommendation: Complete the housing inventory and analysis.
Staff Suggestion: Although substantial data is available in the Housing Background Report
and much consideration was incorporated into housing policies from a racially disparate
impact (RDI) analysis, it is recognized that the three data points requested are not present.
Staff proposes updating demographic information in the Housing Background Report to fully
capture deficient data points.
5. Adequate provisions
County Recommendation: Identify and address gaps in policies to meeting housing needs
through completion of the adequate provision checklist.
Staff Suggestion: Staff completed the adequate provisions checklist after King County
review of the comprehensive plan, but before final adoption. No further action is required.
6. Prioritization of local and regional resources for income-restricted housing
County Recommendation: Commit policy language and associated implementation
strategies to use of regional resources toward income-restricted housing.
Staff Suggestion: Use of local resources, such as surplus property, is decided by the City
Council and balanced with other competing priorities such as balancing the budget through
sale of property, instead of gifting the property to a third party with a condition of using it to
develop affordable units. Staff is willing to explore language to address these
circumstances, but does not feel political direction is present to adopt a policy mandate for
this use of surplus properties or other resources.
7. Supporting income-restricted housing near transit
County Recommendation: Specifically address preservation and creation of income
restricted housing near transit. 26
INFORMATIONAL MEMO
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Staff Suggestion: While policies regarding housing affordability and policies regarding
encouraging housing near transit exist, staff concurs that there is not specific policy
language regarding preservation and creation of income restricted housing near transit. Staff
proposes to update policy language to incorporate these requirements and explore if
language can be paired with forthcoming HB 1491 (TOD) requirements.
RECOMMENDATION
Staff requests the Planning Commission to provide feedback on the proposed direction for
amending housing policies. Proposed amendment language will be presented to the Planning
Commission at a later meeting date to as a basis the Commission’s recommendation to the City
Council.
RELATED LINKS
1. Housing Element
2. Housing Background Report
ATTACHMENTS
1. King County Affordable Housing Committee Review Letter
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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.
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 McIrvin
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
Maiko Winkler-Chin
On behalf of Seattle
Mayor Bruce Harrell
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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.
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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.
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
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.
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regulations that increase housing development cost, also does not mention extremely low-income
households.
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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.
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]
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.1
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.
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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.
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.
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.
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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. 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]
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
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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.
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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]
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
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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
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