HomeMy WebLinkAboutJ_JustificationModification_HabSpaceReqts_CamelliaCourt_231004_v2Practical Difficulties Related to Habitable Space Definition
A modification is requested under RMC 4-9-250 D2 due to the practical difficulties meeting the
Habitable Space minimum standards.
The practical difficulties that are created by strict interpretation of the habitable space requirements
under RMC 4-4-155 can be categorized into the following:
Financial Implications
Livability Issues
Density Issues
Marketability
Accessibility
Financial issues come into play at all phases of a project including: Land value at purchase of the
property, construction costs, financing issues and affordability for the end user(s). It can be shown that
to meet the definition of habitable space in a dwelling unit, an increase in the size of the unit is
necessary thus reducing the quantity of dwelling units on a given site. This results in a higher cost per
unit for land adding to the overall project cost. The increased building area needed to meet the
habitable space definition obviously adds to the construction cost, again increasing the overall project
budget. Because the land and construction costs are higher the resulting bank financing costs are
increased further increasing the overall project budget. These all relate to the viability of the overall
project as the cost of housing is increased to cover the larger project cost. The increase in cost is passed
onto the end user, the tenant, whom is asked to pay more rent for a more costly building making
occupancy more impracticable. Thus the strict definition of habitable space has a direct and negative
effect on affordable housing.
Livability issues include the overall desirability of the individual dwelling unit and how it meets the needs
of the end user. While the code definition is set to provide minimal living areas as defined habitable, it
also encourages minimizing non-habitable spaces such as closets, halls, entry ways, bathrooms, pantries
and laundry rooms, all considered as non-habitable. These non-habitable spaces in contrast are what
makes dwelling units more desirable to the end user. To meet the strict definition of habitable space,
these amenities must be minimized to meet the code while attempting to maintain affordability for the
project. According to the previous two bedroom floor plan study (attached), the habitable space
conforming dwelling unit would need to be extended by 161 square feet in order to provide the same
amenities as the smaller two bedroom plan. This amounts to an extension of approximately 7 feet to
the footprint of the dwelling unit which in turn impacts the density of the project. So the designer is left
with two options, build the larger units with increased area reducing the overall density or
removing/reducing amenities to meet the strict interpretation of the code. Reducing amenities will
have a direct and negative impact on desirability resulting in having units that are harder to rent or be
rented at a lesser rate, both being impractical.
Density projections will be impacted as, in the past when property density was once determined by the
number of parking stalls able to fit on a site now becomes based on the quantity of oversized habitable
units one can fit into the zoning boundaries. Density becomes less predictable and is reduced by
approximately 14%-20%. This raises the land cost per unit which in turn reduces density goals under the
Growth Management Act skewing city density predictions and goals. Multiple occupancy of the dwelling
unit would be less likely as the strict definition of habitable space penalizes additional bathrooms and
larger closets which in turn make the units less desirable for cohabitation for those on the financial edge
October 04, 2023 Response to Staff Comments from 09-27-2023
of affording current rental rates. Roommates are less likely to rent a two bedroom unit if there is only
one bathroom that must be shared.
Marketability becomes an issue for a project with increased unit per land costs, higher construction
costs, lower rental income numbers and less practical and functional floor plans. Oversized bedrooms
with minimal closets are not in high demand for today’s renter.
Lastly, the adoption of accessibility requirements in the national, state and local building codes has had
an impact on the area of each dwelling unit. Accessibility codes now provide for larger entries, larger
bathrooms and maneuvering spaces all of which are not included in the habitable space definition. The
accessibility requirements have increased the area of all dwelling units which adds to the practical
difficulties of meeting RMC 4-4-155.
The requested modification meets the comprehensive plan land use designation in policy L-17
Commercial Mixed-Use Designation, Center Downtown (CD) zone cites as being “appropriate for the
widest mix of uses, is served by transit and is suitable for intensive urban use within a pedestrian
environment. The CD zone is intended to revitalize the area by creating a vibrant urban center in
Renton’s historic downtown core”.
The requested modification is in conformity with the intent and purpose of the Renton Municipal Code.
Minimum standards per RMC 4-4-155 identifies the intent to ensure attached dwelling units are
designed to meet minimum standards to protect the public health, safety and welfare of the residents of
the City of Renton. The modified units by conforming to the IBC, WSEC, IMC and IPC protect the health,
safety and welfare of its residents.
The proposed modification implements the following Comprehensive Plan land use policies:
Policy L-2 supports compact urban development to improve health outcomes, support transit, maximize
land use efficiency and maximize public investment in infrastructure and services.
Policy L-17 Commercial Mixed Use-Designation Center Downtown (CD) zone is “appropriate for the
widest mix of uses, is served by transit and is suitable for intensive urban use within a pedestrian
environment. The CD zone is intended to revitalize the area by creating a vibrant, urban center in
Renton’s historic downtown core”.
The proposed modification implements the following Comprehensive Plan community design element:
Policy CP-4 Develop plans that supplement and define the goals, objectives and policies of the
Comprehensive Plan within the community planning areas and make recommendations on land use
designations, design standards and capital improvements within the community planning areas.
The proposed modification is the minimum adjustment necessary to implement the Comprehensive
Plan’s policies and objectives of: L-2, (compact urban development, support of transit use and maximum
land use efficiency), L-17, the CD zone is served by transit and an intensive urban pedestrian
environment and CP-4 which defines the goals, objectives and policies of the Comprehensive Plan.
This proposed modification will meet the objectives, safety, function, appearance, environmental
protection and maintainability by conforming to the RMC, IBC, WSEC, IMC and IPC.
It should also be noted that approval of the requested modification will have no impact on the bulk
zoning requirements for this project. The issue is about relocating interior walls within the confines of
the exterior walls of the structure. There will be no adverse impacts to other property or to other
property in the vicinity as there will be no change to the overall structure, apparent bulk and setbacks.
The only adverse impact will be that the current zoned property will not be achieving the maximum
density goals set by city planners.
The proposed modification conforms to the intent and purpose of the code by meeting the minimum
standards to protect the health , safety and welfare of the residents of the City of Renton by meeting
the Renton Land Use, Building, Energy, Mechanical and Plumbing codes adopted by the City.
The proposed modification is justified and required to meet the use and situation intended by the
criteria in RMC 4-9-250 D2.
SUPPORT FOR MODIFICATION TO RMC=4-4-155C HABITABLE SPACE REQUIREMENTS
False Premise: The code definition assumes the more square feet in a dwelling the more the habitability
for occupant(s). The reality is that the code section requires larger rooms, smaller closets, less number
of bathrooms and minimal storage, all spaces necessary for livability aka habitability.
Not only does the habitable space requirement necessitate larger dwelling units, to meet the code but
requires a unit with the same amenities to be increased by 25% thereby adding to cost of the
development while reducing density. This added cost directly affects the individual rent needed to
offset a higher mortgage from a lender. Unfortunately an average tenant will be reluctant to rent a
larger unit, with less baths and smaller storage/closets at a higher rate than a more efficient floor plan.
Another issue with the habitable space definition is the inability to offer amenities for those that desire
to share housing. A single bath in a two bedroom unit will be less likely to meet their shared housing
needs.
The current demand for more housing will likely be affected as larger units will result in a reduction in
the number of units on a specific site. Based on the additional 25% increase in unit size to meet the
habitable space requirement, a development could experience a similar loss in density
In terms of the Renton Comprehensive Plan, the following policies and goals of the Land Use and
Planning Elements may be impacted.
Policy L-1: The growth goals for the 2035 targets within the growth centers may not be met due to the
impact on predicted density. The city will either need to lower their density goals or pass legislation to
abandon the habitable space requirement.
Policy L-2: Maximizing land use efficiency in compact urban developments may not occur due to less
efficient unit plans. Efficiency in dwelling unit planning cannot be passed on to the end user.
Policy L-3: Infill development as a means of meeting growth targets to provide new housing will
diminish due to larger dwellings that will not generate the amount of rents needed to afford the larger,
more expensive project and may result in the developer abandoning the project due to infeasibility.
Policy CP-B: Larger bedrooms, kitchens and living rooms do not improve livability/habitability when
bathrooms and closets are minimized as a means of meeting the habitable space definition.
Policy CP-C: Adherence to the definition of livable space will have an effect on the city growth
management act by skewing projected densities of multi-family properties.
Policy CP-3: Community plans, on a small scale may be altered in terms of features and characteristics
as structures conforming to the habitable space requirements most likely will either not meet the needs
of the end user nor provide the anticipated density of the zone in which the project is located.
In summary, designing and building dwellings to meet the habitable space definition will result in the
following:
Placing a financial burden on the cost of housing resulting in higher construction costs, higher cost per
dwelling unit for land, higher mortgages and higher rent to the end user.
Encourage the design of dwelling units with minimal amenities such as extra bathrooms, powder rooms,
extra closets, dressing rooms and kitchen pantries, features desired in today’s housing market.
Necessitates larger dwelling unit area (25% minimum) where added space does not meet the end user’s
needs.
Reduces density, both projected and actual which will distort stated goals of the city.
Limit the design flexibility for maximizing the unit mix more specific for certain high density zones.
September 19, 2023 Response to Staff Comments from 08-23-2023