On May 27, 2025, Seattle City Council passed Council Bill 120969 (CB 120969).  The ordinance, colloquially referred to as Seattle’s Interim Middle Housing Ordinance, ensures Seattle’s compliance under Washington State’s Middle Housing Bill HB 1110.  Particularly, Seattle’s interim ordinance address HB 1110’s June 30, 2025 deadline forcing municipalities to adopt Washington State’s middle housing requirements into their municipal codes, the most notable of which effectively prohibits single-family zoning in most cities across the state.  As an architecture firm with extensive experience designing multi-family residential housing across the Pacific Northwest, AXIS Architecture + Design’s read of Seattle’s interim response to HB 1110 is straightforward: the interim ordinance meets the bare minimum of the letter of state law and its deadlines, but it sidesteps many of the tools needed to deliver abundant family-sized housing in Seattle, and lacks the bold leadership and ambitious vision required to solve Seattle’s housing challenges. 

This past September, Seattle City Council released an updated draft of its Permanent State Zoning Compliance Legislation; that legislation is intended to replace interim ordinance CB 120969, and is ultimately proposed to become Seattle’s permanent response to HB 1110.  The final vote on that permanent ordinance is scheduled to take place this December; if approved, the intention is to bring the Permanent State Zoning Compliance Legislation into effect in early 2026.  Looking ahead to Seattle City Council’s opportunity to formally and permanently comply with HB 1110 this fall, the team of multi-family residential architects at AXIS Architecture + Design offers this analysis of what opportunities were missed in the interim ordinance, where the gaps remain, and what the final Permanent State Zoning Compliance Legislation should aim to correct.

How we got here: the end of single-family zoning in Washington State

Recognizing the criticality of the housing crisis in the state, and particularly the role single-family zoning played in limiting the stock of middle housing, in 2023 Washington State adopted House Bill 1110 (HB 1110).  Known commonly as The Middle Housing Bill, the bill compelled all municipalities and counties in Washington State, regardless of size, to allow at least duplexes on residential lots, and forced cities to permit middle housing in areas previously restricted to single-family homes.  As part of HB 1110’s mandate, affected Washington State municipalities were compelled to adopt the bill’s directives by June 30, 2025 – in effect, ending single-family zoning in most municipal areas in Washington State as of that date.  For cities that would miss the June 30, 2025 deadline by failing to update their comprehensive plans in time, state statutes would supersede any conflicting local development regulations.

Intending to comply with HB 1110’s mandates and the June 30, 2025 deadline, Seattle updated its “One Seattle Plan” comprehensive plan to include significant provisions to facilitate the development of middle housing. Unfortunately, Seattle’s comprehensive plan update encountered six environmental appeals in early 2025; those challenges were ultimately dismissed, but they compressed the legislative schedule and pushed Council to advance an interim set of less-fulsome ordinances to meet the June deadline while deferring the adoption of a permanent set of codes to the fall of 2025.  On May 27, 2025, Seattle City Council adopted interim ordinance Council Bill 120969, and updated its land-use code to permit fourplexes citywide, as well as sixplexes near light-rail and RapidRide stations.  Seattle also temporarily suspended mandatory design review while the permanent set of ordinances is drafted.

The intent of these interim efforts was explicitly narrow: gain compliance of HB 1110 before the June 30 deadline, then take up the broader zoning package within the comprehensive plan by enacting additional more fulsome ordinances in late 2025.  Unfortunately, the consequence of that approach was a year of lost productivity and stalled building as developers and investors waited for clarity on what would be permitted nearly a year into the future.

The missed opportunity: interim ordinance vs. what was originally on the table

Seattle’s interim ordinance legalized additional units – it did not, however, deliver the capacity and predictability that yield family-appropriate homes at scale and at price points the market can produce reliably.  Unfortunately, a number of opportunities were missed.

Neighborhood Centers
Neighborhood Centers, the proposed boundaries of the areas which are the primary targets for adding density in the city on account of their organically developing communities and small-scale commercial centers, were reduced in size in the interim ordinance.  Beyond shrinking their size, Neighborhood Centers including Alki, Roanoke, Gas Works, South Wedgwood, Broadview, Loyal Heights, Dawson/Seward Park, and Nickerson–South Canal, were also limited in their ability to approve mid-rise and mixed-use developments.  Reducing the originally proposed and ambitious size of those Neighborhood Centers effectively suspended the much needed would-be-proposed housing development in the areas that were cut.  Mixed-use projects which would have been proposed in 2026 and beyond were forced to defer until certainty was reestablished, effectively delaying the delivery of that housing stock for one-to-two years.

Development standards
The interim ordinance updated unit counts closer to HB 1110’s guidelines, but largely preserved form-giving standards pending the final terms of the permanent legislation.  In a region where Shoreline, Bellevue, Spokane, and other nearby cities moved crisply – and in some respects beyond minimums – Seattle’s incrementalism signaled caution rather than certainty to developers and lenders.

Parking
Seattle’s interim ordinance also does not fully align with Washington State’s new parking requirements.  In parallel to Seattle’s interim ordinance, state parking law changed; SB 5184, which became effective in July 2025 and with an implementation window that runs into 2027 for larger cities, caps local minimums and provides categorical exemptions depending on the development.  Seattle’s interim ordinance compels a different set of requirements.  The discontinuity between state guidelines and Seattle’s interim ordinance introduced unnecessary uncertainty for developers and architects site planning housing projects throughout much of 2025.  Earlier alignment would have immediately lowered carrying costs and de-risked stacked-flat and smaller-unit projects by removing unneeded stalls that consume excavation, structure, and schedule.

Corner stores and daily-needs retail
Small-format retail concepts remain narrow under Seattle’s interim ordinance.  As it stands, the interim legislation largely prohibits retail beyond street corners, and limits mixed-use development to prescriptive situations in Neighborhood Centers.  The effect is a continued restriction of the small-scale retail that is essential to achieving thriving local communities that incorporate the commercial services needed to support themselves.

Design review and objective standards
With respect to design review, Seattle’s pause has created a temporary gray zone where neither discretionary review nor calibrated objective rules meaningfully shape proposed developments. Until new predictable standards arrive, projects will continue to navigate ambiguity.

What we can do better: AXIS’ recommendations for practical and buildable Permanent State Zoning Compliance Legislation

In advance of Seattle City Council’s final proceedings to adopt its Permanent State Zoning Compliance Legislation this fall, AXIS Architecture + Design encourages the City of Seattle to consider the following recommendations.

Pair unit legalization with capacity that makes sense
Seattle’s permanent ordinance should pair permitted unit counts with capacity in a way that makes sense for developers.  Aligning capacity along a unit-scaled floor area ratio (FAR) ladder (roughly 1.2 FAR for fourplexes and 1.6 FAR for sixplexes) would allow three-bedroom flats and Type A accessible units to more naturally and efficiently fit typical residential lots.  Height and lot-coverage envelopes should be calibrated to support stacked flats and compact walk-ups.  If middle housing is indeed intending to service Seattle’s young families and middle-income workforce, three stories with adequate FAR is more functional than four stories with highly restricted FAR.

Restore and ambitiously size Neighborhood Centers
Neighborhood Centers’ proposed boundaries should be restored to their originally proposed sizes.  For Neighborhood Centers where mixed-use development has already been exhaustively studied, restoring those centers’ ability to approve mixed-use projects will encourage developers to reactivate projects that have already been vetted, invested in, and are ready to build.

Align with SB 5184 parking caps
Parking policy should align with SB 5184. Codifying the 0.5 stalls-per-unit cap as early as possible, carrying through the exemptions for smaller homes and specific uses, and letting the market determine where structured parking is warranted will reduce hard costs and schedule risk.

Legalize mixed-use small-format retail beyond corners
Allowing “every-block” neighborhood retail beyond street corners, with sensible performance standards on size, hours, and loading in existing community centers and along transit streets, will support a mode shift that reduces vehicle miles traveled, and more rapidly creates the self-sustaining neighborhoods the city needs.

Follow the proven examples set by nearby regional peers
Seattle can benefit from peer examples. Shoreline and Bellevue show that timely and near-wholesale adoption of HB 1110 considerations paired with form-based updates can avoid the unnecessary delay and uncertainty being experienced by developers and builders in Seattle.

Make building affordable housing, easier

Finally, adjust the definition of “affordable housing” by simply assessing the percentage of affordable housing units in a development based on their affordability, and remove the requirement for public funding.  Alternatively, revise zoning codes to allow a higher percentage of Multi-Family Tax Exempt (MFTE) units in a project to obtain the same code advantages as publicly funded projects do.