An update on Missing Middle Housing
Bad news — the city seems to be proposing scaling back the ordinance, potentially quite dramatically
A quick update on my post from two weeks ago on the Missing Middle Housing zoning update.
Turns out I — and it seems, most people — misunderstood staff’s extremely complex recommendation in a pretty important way. One key piece of information switches this from “eh, this maybe isn’t great” to “oh man, this could be bad.”
The proposal for new percentile width and depth lot requirements is not intended as a substitution for existing form standards (setbacks, open space requirements, etc.). These are being proposed as additional limitations relative to current law.
On top of, not instead of the status quo.
Staff has not specified the scale of the new limitations they’re planning; they don’t yet know the actual percent of width and depth that will be allowed. But just in principle this is very worrying. It’s a limitation that — if it’s anything less than, say, 80-90 percent — could dramatically restrict what kind of housing you’d be allowed to build in Sacramento, especially on small lots.
It’s kind of hard to explain why, but it all comes down to math and geometry. Because width and depth restrictions would compound each other, the resulting restriction is exponential.
For instance, consider how this would impact a 50ft by 120ft lot in Midtown.
If the proposal is to limit MMH to 80 percent of width and depth, then 80 percent of 80 percent means 64 percent lot coverage overall. That’s a significant restriction, one that would probably make townhomes impossible. But you could still easily build a triplex or fourplex.
But if staff proposes something more on the lines of their illustration graphic, like a 40 percent width/depth standard? Well, 40 percent of 40 percent is just 16 percent. See what I mean about exponential? Things start to look very, very constraining very, very quickly.
Illustration below.
All of a sudden Missing Middle Housing is a fun planning exercise for housing nerds but nothing more. Beyond 50 percent or so width/depth ratio, all you can build on a small lot is not much larger than a tiny home. Real MMH becomes only feasible on very large lots.
What makes this proposal so potentially harmful is that, regardless of what the final percent is, it significantly punishes small lots — the opposite of the city’s stated goals to allow more flexibility and small-lot development. Width/depth doesn’t just regulate buildable area, it regulates buildable area in proportion to lot dimensions; the smaller the lot, the smaller the allowable area. So while you could realistically still build an eightplex on a very large lot in North Sac or South Sac, most lots in the inner ring suburbs and the grid could be functionally off-limits to MMH.
I am, frankly, baffled that staff is proposing this.1
My best guess is that they are doing this in response to some angry neighbors of this project up in Robla. That’s the only MMH proposal I’ve seen with any neighborhood pushback (if there are others that anyone’s seen, please let me know in the comments).
But the supreme irony there is — that Robla project? It’s on a half-acre lot! If the city went with something like 80 percent width/depth standards, that’s still almost 14,000 square feet of buildable area on a half acre.
You can fit way more than 14 units on 14,000 sq ft.
The city would have to put in extremely draconian width/depth requirements before they could prevent a large MMH project from getting built on a half acre. Standards restrictive enough to impact this lot in particular would surely be severe enough that they’d choke out Missing Middle Housing everywhere else. Suddenly we’ve just wasted years of effort only to functionally protect the status quo.
Width/depth standards are a bad idea. Sacramento must remove them from this proposal.
Four-story and five-story allowances are much less useful than they seem
A second note:
The city’s proposal tries to counterbalance the new width/depth restrictions (along with the also-not-great “attic story” Bulk Control 2.0) with the creation of a new “block scale” development standard that would increase height limits to 45 or 55 ft (four or five stories) in some areas.
Before the NIMBYs lose their minds and start throwing tomatoes over five-story apartment buildings in Elmhurst, here’s the uncomfortable truth: In reality, this likely means very, very little.
While I personally would love to see Parisian-style housing density around transit in Sacramento (and said so in my last piece), there’s a problem. In California it’s functionally impossible to build Missing Middle Housing above three stories.
The reason is simple: Single stair.
Under California’s building code, if you go above three stories, you need two staircases. But having just one stairway — or “single stair” — is functionally a requirement for Missing Middle Housing just because the lots aren’t usually big enough for two. Ergo, you can’t really build Missing Middle above three stories in California per building code, regardless of what the zoning code says.
California (and much of the U.S.) is a global outlier on this. If you’ve ever been to NYC or Paris or Rome you’ve seen how single-stair buildings are everywhere (and how their floorplans are so much nicer than our apartments).
(Pew has an excellent report explaining why the two-staircases thing adds so much cost, why it doesn’t actually add fire safety, and how it forces apartments to orient around those shitty, hotel-style corridors that everyone hates.)
There’s a budding effort to change this in California, but it’s not going anywhere fast. Until then, four and five-story MMH buildings are a pipe-dream. It doesn’t really matter if Sacramento legalizes four and five stories on paper.
They won’t get built because the building code says they’re illegal.
Why width/depth standards + higher heights could seriously backfire
The height thing matters not just because single-stair makes it illusory. It’s also important because, when combined with restrictive width and depth standards, adding four- and five-story height limits could net out as a significant de facto downzoning that would be invisible to most Sacramentans.
Huh? Raising heights could be part of a downzoning? How?
What worries me is that the city could be assuming that the higher heights are enough to counteract a significant restriction in buildable area from new width/depth limits. That more height can compensate for less width/depth.
Think of it this way. (The math is about to get complicated, but I promise this is really important.)
Height and buildable area (as governed by width/depth) multiply off each other, with the total zoned housing allowed the product of the two. In our General Plan, housing is governed by the ratio known as Floor Area Ratio or FAR. It’s the ratio of allowable building to lot size.
Any limitation more stringent than 66 percent of lot coverage (81 percent width/depth) would make it mathematically impossible to build the General Plan-mandated FAR 2.0 around transit with just a three story building. (Because… math, trust me.)2
Say the height limit remains 35 ft / three stories, but the city introduces new width/depth requirements that you can only build on 50 percent of the lot (about 70 percent width/depth). That means actual allowable FAR is now just 1.5 (50 percent x 3 stories = 1.5) even if the zoning code says you can build up to 2.0.
“Not a problem,” this proposal seems to say. “Here, you can have a fourth or fifth story to make up for that loss of buildable area.”
But if using those four or five stories requires a second stair, that means FAR 2.0 is legal only on paper and not in practice. Even if you could manage to squeeze a second staircase onto your lot (probably not possible in most MMH contexts), it adds a ton of cost and chews up a huge amount of space that could be housing.
In almost all cases it wouldn’t be financially feasible. De jure legal but de facto prohibited.
And so, for all intents and purposes, FAR 2.0 in the General Plan is suddenly more like 1.0 or 1.5 in reality. And, without meaning to do so, City council has voted to scale back their own housing plan by a quarter or even half.
Whoops.
45 ft heights are much less of a boon to housing than new width/depth restrictions would be a hindrance.
Plus, let’s be real…
…aren’t people going to be way more freaked out about the idea of four- or five-story buildings in Elmhurst than they are about two-story apartments in Robla?
City Council should pretty much send this whole thing back to the drawing board. My recommendation would be to simply keep the existing ordinance minus bulk control. It’s not hard. A two-sentence fix and then we could be done with this forever.
(As a reminder: The current ordinance only permitted ~60 units in a year and a half! This law isn’t exactly going to cause a stampede of new housing…)
Council will have an introductory workshop on this proposal at their meeting next Tuesday, April 14th. We’d love you to come out and tell them to say no to de facto downzoning in any form.
We’ll send details on timing etc. as soon as the agenda is out later this week. But for now: Put Tuesday’s council meeting on your calendar.
No downzoning in a housing crisis!
Obviously grain of salt: If the final proposal ends up being a minor restriction (say, >80 percent width and depth) then it’s not that big a deal. But then — if it’s not significantly restrictive — why propose adding a new set of standards at all? Why create a new restriction if the goal isn’t to restrict? Like I said, baffling.
Again, FAR is the ratio of building square ft to lot square ft. So to get to FAR 2.0 with three stories you need to be able to build on at least two-thirds of the lot. That means width/depth requirements can’t be more than, on average, 81.64 percent (.8164 x .8164 = .6666)