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The Comp Plan contains no definition of affordability, despite its claim to comply with HB 1110 which unambiguously defines affordable housing as costing less than 60% of Area Median Income for renters and less than 80% of AMI for owner-occupied households. We need this definition! Instead, OPCD is defining affordable as being less than market rate. This slipperiness results in no measure of progress against needs.

The Governor said half of the needed 112,000 housing units need to be low-income, meaning subsidized, mostly rentals. There's no indication that any of the smaller homes in the new Urban Neighborhood zones would be rentals. Even the sixflats are referred to as condos, therefore unaffordable. I had hoped to see zoning that would result in homeowner-owned duplexes and Community Land Trust sponsored sixplexes.

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