The letter
Subject: Duvall's housing capacity, the rent ceiling in draft chapter 14.47, the city's lot on Big Rock Road, and five things that would make the program produce homes
We are asking for five things:
- Publish the capacity by income level
- Set the rental affordability level at 50% of median income, not 80%
- Adopt the fee-waiver framework, and aim it where it buys the most
- Weigh the city's own land before committing it, and a proposed amendment
- Do not spend the housing money on administration before the program produces anything
Duvall is rewriting its zoning code, and has to finish by December [1]. The changes decide how tall buildings can be, how many homes fit on a lot, and what the city means by "affordable."
The meetings are long and full of jargon. This lays out the numbers so anyone can check them, and says plainly what a resident can do about it.
Every figure here comes from a public record: the state's housing counts, the city's own slides and recordings, federal income tables, and rent listings. Where a number is our estimate, we say so and show the method.
The short version
- Duvall has added 514 homes since 2019 [2]. The 25-year target is 890 [3]. The town is building at about twice the pace the target asks for.
- The fight is not about the total. It is about homes for people with lower incomes: 675 of them, including 409 for households earning under about $44,400 a year [4][5].
- Zoning cannot produce those homes, because the rent that covers the cost of building an apartment here is roughly $2,300 a month, and a household at 30% of median income can afford about $1,109 [6][7]. The gap is filled with public money, public land, or not at all.
- The city's draft affordable-housing chapter (Title 14, chapter 14.47) calls a home "affordable" if it rents for what a household earning $105,000 a year can pay [5][8]. In this valley that is above what a new apartment already rents for [9].
- The city owns a vacant two-acre lot on Big Rock Road, in the proposed new densest zone, given to it by a developer under a 2008 agreement "to establish a city facility," and appraised at about $3 million [41][42][43]. The city's consultants have proposed a new police station, or a combined city hall and police campus, on what they call "the Big Rock two-acre parcel"; this is the only city lot that fits the description. No decision has been made [45]. The city's own draft code says anything built there must include homes [44].
- Residents have stronger tools than the microphone: a public records request, a letter in the official record, and an appeal to a state board that a city one bridge away just went through [10].
- The same move turns up three times: homes that fit on paper and are never funded, an "affordable" rent set above the market, and a promise to use public land for housing made three times and never kept.
How we got here
Duvall adopted a 20-year plan in 2024. In 2025 the state Department of Commerce appealed it, saying the city had not shown room for enough housing, especially for people with lower incomes [11]. The city chose to negotiate rather than litigate, and agreed to a work plan with the state and King County, due at the end of 2026 [1]. That deadline is why everything is moving fast.
The number everyone argues about: 890
King County assigned Duvall a target of 890 more homes [3].
The city's September 15 workshop slides, posted on its website, compare that target to the room the zoning leaves [12]:
| December 2025 | August 2026 | |
|---|---|---|
| Accessory dwelling units | 63 | 63 |
| R4 to R12 (neighborhoods) | 149 | 82 |
| R20, R30 | 193 | 129 |
| MU20, MU30 (mixed use) | 479 | 424 |
| Commercial, Old Town, Uptown, Midtown | 137 | 144 |
| Projects submitted since 2024 | 90 | |
| Total room | 1,021 | 932 |
| Margin over the target | +131 | +42 |
At the meeting staff said these aloud as 939 and 49 [13]; the posted slides say 932 and 42 [12]. The margin shrank because projects approved since 2024 used up land.
Two things here are worth asking about.
First, what the target is being measured against. The slides label the 890 a "2024-2044 target" [12]. The city's own plan appendix puts the need for 2024 to 2044 at 716, after subtracting the homes built since 2019 [14]. Those are different numbers doing the same job, and one sentence from the council would settle which is right.
Second, how much is already built. The state's official count has Duvall at 2,684 homes in 2019 and 3,198 in April 2026: 514 homes in seven years [2]. That is about 73 a year, against the 36 a year the target implies.
The city's own documents disagree about this. One consultant counted 433 homes built through April 2024, which matches the state exactly [14]. The consultant who ran the rezoning analysis used 780 [15]. The state shows 380 completed in those years [2]. We have asked where 780 came from, and it matters: that number decided which income levels still need room.
What the state actually wants
The appeal is about who the homes are for. The state splits the target by income. On the city's own analysis, Duvall still has to show room for 675 homes for households under 80% of the county median, including 409 under 30% [4][15].
In dollars, for a household of three, using the federal 2026 tables for King County [5]:
| Income level | Yearly income | Monthly income | Rent that counts as affordable (30% of income, utilities included) |
|---|---|---|---|
| 80% of median | $105,000 | about $8,750 | about $2,625 |
| 60% | $88,800 | about $7,400 | about $2,219 |
| 30% | $44,400 | about $3,700 | about $1,109 |
Zoning can make room for apartments. It cannot make one rent for $1,109 a month. Our own cost workup, priced up from national construction cost components and Duvall's fee schedule, says a new two-bedroom apartment here needs about $2,300 a month to be worth building [6][16]. Nothing closes a gap that size except public money: tax credits, housing levies, or county and state funds.
Duvall does not have that money. Its entire general fund for the next two years is about $16 million, which pays for police, parks, streets and staff [17]. The difference has to come from the county, the state, or nowhere. So far it has come from nowhere.
A city one bridge away reached the same conclusion officially. Mercer Island's compliance analysis identifies a gap of 510 homes for households under 30% of median that "must be addressed through other City actions in addition to the proposed zoning changes" [18].
Is any of this actually required?
The state does not require Duvall to adopt a mandatory affordable-housing rule, and it does not require the voluntary bonus program either. The city administrator said as much on September 1: the state asks the city to have an incentive program, and the city chooses the ingredients [19].
What the state does require is narrower: show room by income level; make "adequate provisions" for all income groups; remove barriers in the city's own code; and address displacement, meaning who gets priced out [20].
So the question is not "mandatory or voluntary." It is which tools deliver, and what each costs. More exist than have been discussed:
| Tool | Who pays for it | Where it stands in Duvall |
|---|---|---|
| Density and height bonuses (draft 14.47) | the neighborhood, in building size | drafted [8] |
| Mandatory set-aside | the land price, or the project that is never built | under discussion [13] |
| Property tax exemption (draft 3.12) | other property taxpayers, by a small shift | drafted [21][22] |
| Waiving city fees on affordable homes | the city's own funds | now on the council's desk: a September 8 memo from the city administrator sets out how the council could waive up to 80% of park and transportation impact fees with no backfill, and utility connection fees for affordable housing under a 2023 state law [49]; state law allows it [23], and city fees run about $33,000 per apartment and $59,000 per townhome [16] |
| Leasing surplus public land for housing | nobody, up front | not discussed in this rezoning; promised three times, never done; state law allows it [24], the city's 2023 plan made the inventory a short-term action [25], and the 2026 draft still says "analyze" and "explore" [14] |
| Joining ARCH to administer affordable homes | about $36,000 a year | raised September 15 [13] |
| A county sales tax for housing | county taxpayers | a county decision [26] |
The two in bold are the cheapest ways a small town can make an affordable home possible, and neither requires upzoning anything. The first has just reached the council. The second has not.
The question nobody answered
Before a city upzones private neighborhoods, the obvious first question is what the public already owns. Duvall has promised to ask it three times.
- Its comprehensive plan has carried policy H-4.10 for years: "Identify and promote the use of surplus public-owned land for housing affordable to low- and moderate-income households" [25].
- The 2023 Housing Action Plan reviewed that policy and recorded the result in its own words: "A few years back, the city rezoned surplus land from R4 to Public due to outcry from adjacent neighbors. Community discussion will be needed before something like this can be implemented" [25]. The one action taken under the policy moved public land away from housing.
- That same plan then proposed the program again, as Action I.1: a ground-lease program for surplus or underused city land, with an inventory of buildable public land marked short term [25].
- The September 2026 draft plan carries the policy forward, still unexecuted, now worded as "analyze the use of a ground-lease program for underutilized public-owned land, and explore partnership opportunities" [14].
County records show there is something to inventory. Inside the city limits there are 144 publicly owned parcels, about 402 acres; the city itself owns about 271 acres across 126 parcels [40]. Most of it is parks, stormwater ponds, greenbelt and road slivers, and county records alone cannot say which of the rest could carry homes: we checked, and a subdivision's drainage tract and a buildable lot carry the same "vacant" code [43]. Only the city can answer the question properly, and its own plan says it already keeps a City Facility Assessment that lists "potential surplus facilities and properties" [46]. That list has never been published.
The south end: one lot, and the land the town needs
The rezoning puts its densest new zone, MU30, at the south end of town along Big Rock Road [12][44]. The same stretch of road is where almost every other decision about Duvall's land is now being made.
The lot. In 2008, when the Walden neighborhood (now The Ridge at Big Rock) was planned, the city's development agreement with the developer required it to hand over "two acres of property ... to establish a city facility, unless otherwise agreed by the City": "two unencumbered buildable acres," delivered as "a finished grade pad ... including installed utilities and improved street frontage" [41]. The agreement's traffic study was to assume a 35,000 square foot municipal services building there [41]. The land arrived in December 2022: Lot 409, 2.09 acres at the corner of Big Rock Road and the Walden entrance, deeded to the city at no cost "as required for the approval of the plat" [42]. Nothing has been built on it. The county appraises it at about $3 million [43]. It has road on two sides and the neighborhood park beside it.
Sewer is not the constraint. The town's treatment plant, expanded to a fourth treatment train after the 2021 moratorium on new connections, now runs well under its capacity [47].
What the city has in mind. On August 19, 2025 the city's facilities consultants told the council that the police station, city hall and maintenance yard "are at the end of life" and "way too small" [45]. Of the police station, a city building at Depot Park [46], they said it has "one point of egress that could easily be blocked," exposed computer equipment, and evidence and locker rooms "too cramped to function into the future," and they recommended a new, purpose-built station "on a site outside the downtown core" [45]. The consultants then gave two options: a police station on "the Big Rock two-acre parcel," which they described as city-owned, vacant and at the south end of town, with city hall on the public works yard downtown; or city hall and police together on that parcel. They also listed it among city properties the city "could divest from to finance construction." No decision has been made; a community survey and a final report were to follow [45].
Is a new station really needed? We think the case is weaker than it sounds. The city renovated the station in 2023 and 2024 with federal recovery money: a new women's locker room, flooring, windows and paint, a project of $100,000 to $200,000 [50]. A year later its consultants called the locker rooms too cramped [45]. The other problems they named, one way in and out, exposed computer equipment and tight evidence storage, sound like work for a remodel, not reasons for a new building. The department has 13 commissioned officers [46]. And the consultants themselves warned that the cost of a new police station and city hall runs past what the council can borrow without asking the voters [45]. Before the city commits to a new station anywhere, it should publish the police facility needs assessment, the cost of fixing the station it has against the cost of building one, and its plan for the Depot Park building if the police leave it. Until then, the town can make do with the building it just renovated.
Could the station grow where it is? We asked the county's records. The police station sits on a city-owned parcel at Depot Park of 6.68 acres, zoned for public facilities, with public water, sewer and road access; it shares the parcel with the historic train depot [54]. That is more than three times the size of the 2.09-acre Big Rock lot. The upper lot behind the station, on the Main Street side, is outside the flood zone on the federal flood map; the low side toward the river is in the 100-year floodplain [55]. The station parcel runs behind the Main Street businesses, and the city owns the land between it and Main Street farther south: a 3.68-acre parcel next to the station and a 0.88-acre lot beside that one, which reaches Main Street [54]. On paper, then, a second way out could run over city land alone, with no one else's permission. Parts of both parcels are in the floodplain, and whether a drive fits is an engineering question; the business lots next to the station, including the church, have their own easements and a protected wetland behind the church [56].
So we ask: was fixing the station where it stands ever studied? On the record, the problems are one way out, exposed computer equipment, and cramped evidence and locker rooms [45]. One connection to Main Street, over the city's own land or by easement from a neighbour, gives a second way out. One modest auxiliary building, a modular or container-type building on an enlarged upper lot, gives secure room for computers, evidence and lockers. That is the most anyone could reasonably ask of this site, and it can be done cheaply and with little impact on the depot, the trail or the river. No cost for a new station has been published [45][50]; for scale, the city's new maintenance center alone is estimated at $21.9 million [50]. We also ask that the department's space needs be checked by an independent third party, not only by the consultants proposing the new building.
In fairness: the consultants said the department would prefer a site "outside the downtown core" [45], and this answers the building's problems, not that preference. The river side of the parcel likely falls under shoreline rules, the depot is historic, and a station beside a public trail needs careful security design. None of that makes a remodel harder than a new building on new land. The town should see both costs side by side before it chooses.
What the city's own draft code says. The draft MU30 zone reads: "Residential density is a requirement for any new development," at least 30 homes an acre [44]. Its use table allows a "police facility" there only "as part of a mixed-use development that conforms to minimum residential density requirements" [44]. Under the draft as written, then, a police station on Lot 409 is permitted only as part of a mixed-use development meeting that minimum: about 60 homes on 2.09 acres. The final code, an exemption for city buildings, or a rezone could change that. Whether the city counts this lot as housing room toward the state's appeal is not published. If it does, a stand-alone station would spend room the city is counting on, in a test our estimate puts between 10 homes short and 44 over.
What the 2008 agreement says about selling it. If the city sells the lot, the agreement gives the developer (now Toll Brothers) "a right of first refusal to re-acquire" it [41]. If the city builds on it for its own use, the developer reviews and comments on the plans, and the city keeps the final say [41]. A ground lease is neither: the city keeps the land and the public keeps its value.
Follow the money. The city is planning real buildings. Its new maintenance and operations center, on a Big Rock parcel, is estimated at $21.9 million, and the city says it can already cover the full design and a significant part of construction [50]. Staff make a strong case for it: the public works crew shares a 1,200 square foot shed [50]. A city hall and police station are next on the list, with no cost yet published [45][50]. The council will discuss how to use its strategic fund on October 6; the preliminary budget leaves that fund untouched [50].
The best use of the lot. Ask what the ground and the town need. The lot is high, open to the sun, on the road out of town, and was meant to be delivered with utilities. The town's worries, as residents stated them at the September meetings, are homes people can afford, work close to home, roads and pipes before density, and being cut off when the river rises [13]. The town's stronger needs are economic and housing, and a police station answers none of them. Lot 409 is the only vacant, buildable city lot in the proposed MU30 zone, where the draft code already requires homes, and at its appraisal the land is worth enough to make those homes deeply affordable (below). A station there would have to come with about 60 homes stacked over or beside it, and we doubt many families would choose to live above a police station. In our view Lot 409 should not become a police station.
The city's own plan already describes something that answers most of them. Policy LU 7.1: "Encourage commercial, small-scale manufacturing, makers' space, flexible spaces, and institutional uses to support family-wage jobs ... foster entrepreneurship and new business development, and create opportunities for workforce training." Policy LU 7.5: affordable live and work studios, with nonprofit partners [46]. Put those together with H-4.10 and the MU30 rule, and the building nearly draws itself:
- a ground floor of shared workshops, a commercial kitchen and teaching space, run cooperatively so residents can start and grow their own businesses;
- permanently affordable homes above, on a city ground lease, so the public land does what only public land can do;
- a solar roof and backup power, so the south end has a place to gather, cook and charge when the roads close.
That is a sketch, not a design, and it would need a nonprofit and a cooperative to carry it. Programs exist for each of these pieces, though none has yet been asked about this building: federal community-facility loans and grants for towns under 20,000 people, the state's Building Communities Fund, the state's clean-energy grants for backup power at community buildings, state food-system infrastructure grants, and the state and county housing funds [48]. The draft code's MU30 use table would need one change to fit it: it allows flex and tech space, cooking and vocational schools, but not light manufacturing, which the draft allows only in MU20 and Old Town [44]. And public land is the piece that makes the homes above truly affordable. At Lot 409's own appraisal, the land is worth about $48,700 for each apartment; waived fees and the tax exemption add about $97,000; together that covers what it costs to hold a rent at 30% of median for twelve years [16][43]. Nothing else on the city's list can do that.
What "affordable" means here, and why it may mean nothing
The draft chapter defines an affordable home as one priced for a household at 80% of median income [8]. For a two-bedroom that is a rent of about $2,625 including utilities, or about $2,425 without [5].
What apartments actually rent for nearby [9][27]:
| Two-bedroom rent | |
|---|---|
| Tolt 24, Carnation, built 2021, the valley's newest apartments | from $2,196 |
| Typical starting rent across 39 buildings in Bothell, Kirkland, Redmond, Woodinville, Everett | about $2,300 |
| Older Duvall two-bedrooms | $2,149 to $2,199 |
| New Duvall townhomes (Duvall Village) | $3,499 |
An apartment "restricted" to 80% of median would be allowed to charge more than the newest apartments in the valley already charge. The restriction would bind on nothing. The state's own auditors found the same pattern statewide in 2019: the legal "low-income" rent ceiling was above the typical market rent in at least 498 zip codes [28].
State law anticipated this. For programs like the city's, the default ceiling for rentals is 50% of median, not 80%. A city may raise it to 80% only after a public hearing and a written finding that the higher level is needed because of local market conditions [20]. Neither has happened.
So simulate it: what if the city holds the hearing?
Suppose the council holds the hearing and adopts a finding. What actually follows depends on the number it picks. Using the valley's newest apartments as the market anchor, a 30-home building with 6 homes restricted and a 12-year tax exemption [16]:
| Ceiling set at | Restricted rent (net of utilities) | Compared with market | Does it bind? | Rent cut per home | Rent cut bought per public dollar |
|---|---|---|---|---|---|
| 80% of median | $2,425 | $229 above market | No | none | none |
| 60% | $2,019 | $177 below | Yes | $177 a month | $0.26 (tax exemption), $0.51 (fee waiver) |
| 50% | $1,650 | $546 below | Yes | $546 a month | $0.81 (tax exemption), $1.57 (fee waiver) |
Three things follow.
At 80%, the city would be adopting a finding that it needs a rent ceiling above market rent. The program would produce no cheaper homes; the tax exemption would become a construction subsidy wearing an affordability label.
At 50% or 60%, the restriction is real, and the building still works financially, because the exemption is worth more to the owner than the rent given up [16].
Waiving city fees buys more than the tax exemption does. At 50% it returns about $1.57 of rent reduction for every public dollar, against $0.81 for the exemption, and it is a one-time cost the council can price to the dollar [16][23].
That is what the rent ceiling decides. Set it at 80% and the program restricts nothing. Set it at 50% and it cuts $546 a month from the rent of six homes in every qualifying building.
Our estimate of the number the city has not published
The city publishes capacity by zone, not by income level, and the income split is what the appeal turns on. Rather than wait, we estimated it using the same method the city's consultant used: only zones allowing 20 or more homes an acre count toward the under-80% need [15].
| Income level | Room, our estimate | Required | Margin |
|---|---|---|---|
| Under 80% of median | 665 to 719 | 675 | between 10 short and 44 over |
| 80 to 120% | 177 | 10 | 167 over |
| Over 120% | 36 | 0 | 36 over |
Two unknowns set the range: how much of the commercial row counts, and whether projects already in the pipeline count as room.
What it shows: the income level that decides the appeal is within about 40 homes of its requirement either way, so "we need what is left" is a fair answer about the dense zones. It is not an answer about the neighborhoods, where the city is adding 177 homes of room to an income level that needs 10. If the city's own numbers differ, publishing them settles it in an afternoon.
The neighborhood upzones: needed or not?
The changes also raise heights in the residential zones, from 35 feet to 40 feet in R12, 45 in R20 and 50 in R30 [12].
On January 6, a council member asked whether the neighborhood upzones were needed. On the city's recording, at 3 hours 50 minutes, staff answered that apart from how zoning blends between areas, the city does not need to change anything below R20 [29].
Later the same night, at 4 hours 1 minute, staff said it more plainly. The lower-density upzones were not expected "to yield an affordable unit, but they would satisfy a niche, which is another box that we can check with Commerce. That is the missing middle" [29].
On September 1, the same council member asked whether any room was still optional and could be removed. On the city's recording, at 20 minutes, staff answered that "right now ... we are at that minimum threshold ... we don't have any fat to trim," and, at 23 minutes, "there ain't no fat left in the map" [19]. On September 15 the council voted to add the question and answer to the September 1 minutes; the amended minutes are not yet posted [13][30].
Both can be true of different things. The dense zones have tightened since December. The neighborhoods have not, and by the city's own figures they serve an income level already met.
The precedent, one bridge away
In February 2025 the nonprofit Futurewise and two Mercer Island residents appealed that city's plan to the state Growth Management Hearings Board [10]. On August 1, 2025 the Board agreed with them: the housing element did not comply. It ordered the city to redo its capacity analysis to show how many homes would actually be produced at each income level, to adopt the required provisions immediately rather than promising them later, and to adopt anti-displacement measures [10].
Mercer Island complied rather than fight. On July 21, 2026 its council adopted the package [18]:
- inclusionary zoning in its town center: at least 10% of new homes affordable, at 50% of median for rentals and 80% for ownership;
- a fee in lieu that funds homes below 50% of median;
- public "opportunity sites" identified for housing;
- an anti-displacement ordinance: 120 days' notice before a rent increase over 3%, and $2,000 of relocation assistance for low-income tenants before an apartment building is redeveloped.
The appellants agreed the city had complied; the Board waived the September 15 compliance hearing and its final order is pending [18].
Two lessons for Duvall. The Board will look past paper capacity and ask what gets produced. And the package a city ends up adopting looks a lot like the one we are describing: a real rent ceiling, money attached, public land, and protection for the people already here.
What about our utility bills?
The homes that are actually affordable in Duvall today are the older ones: two-bedrooms at $2,149 to $2,199, and two small one-bedrooms listed this month at $1,500 and $1,695 [9][27]. No subsidy made them cheap; age did.
They are also the homes most exposed to what happens next on energy. On September 17, 2026 the Washington Supreme Court struck down Initiative 2066 by 6 to 3 [31]. Voters had passed it in 2024 to protect access to natural gas. The court did not rule on whether that is good policy; it held the initiative covered too many subjects at once, which the state constitution forbids [31].
What that means for an older Duvall home is still being worked out, and anyone who tells you otherwise is guessing. What is clear is who carries the cost when rules push older homes to convert: the people living in them. The state's housing law has a name for that risk, displacement, and it requires cities to plan for it [20]. Duvall's displacement analysis is a fair thing to ask for alongside the capacity table, and Mercer Island's ordinance shows what one looks like [18].
The county's part
King County is not a bystander. It assigned the target [3], and it is a party to the work plan. On the January 6 recording, at 3 hours 34 minutes, the city administrator explains that Commerce required King County's sign-off on the city's new capacity analysis before it would accept the work plan, and that the county gave it that December [29].
The county shaped where the homes go. Later on the same recording, at 3 hours 39 minutes, staff reported that "King County identified" that the new analysis "doesn't require us to annex any land ... We can do it within the city limits" [29]. So the answer to the state's appeal became rezoning inside the existing town, including the change to MU30 along Big Rock Road. The plan the city adopted in June 2025 pointed somewhere else as well. Its policy LU 9.2 was to work with the county to move growth-boundary land into a new "South UGA," south of Big Rock Road, "to meet growth targets and accommodate deeply affordable housing," and the plan said that land "will be needed" and that the city would apply "when the County is ready to process requests" [46]. The draft amendments of September 2026 strike those words. In the draft, LU 9.2 reads in full: "Work with King County to revise urban growth boundaries" [46]. The drafts have not been adopted; until they are, the 2025 wording stands.
Correction, October 8, 2026. Before this correction, this paragraph gave the South UGA wording as the city's current plan and ended "That door is the county's to open." The wording is in the plan adopted in 2025; the September 2026 drafts delete it, along with the passage saying the land "will be needed." We read the drafts as plain text, where struck-through words look like the rest, and missed it. The drafts are linked in sources 46 and 57.
The county's money shapes it too. The same season, county Conservation Futures money is helping the city assemble about 40 acres around the Big Rock ball fields. In September the city was awarded $2.6 million for three acres that "will remain undeveloped" [13]. The plan adopted in 2025 gave the growth area beside the ball fields a parks and open space designation [46] (the September 2026 drafts strike that designation; corrected October 8, 2026), and it will be a good park. The point is which doors the county's money opens.
Each of these is lawful and defensible on its own. Together they decide where Duvall's affordable homes can go. County money moves readily for parks and conservation at the town's edge. The county's targets push density into the existing town. And the growth-boundary change the adopted plan names for deeply affordable housing waited on the county; the September 2026 drafts would strike it (corrected October 8, 2026). Nobody has put them on one page. We have tried to.
The county also has a process for changing a city's target, called reconciliation. On the same January recording, at 3 hours 44 minutes, the administrator explains it is now a letter to the County Executive setting out the change sought and the reasons [29]. The council discussed it in January and never settled it. The county uses that flexibility for its own ground: in November 2025 its growth planning council moved 128 homes of target out of an area near Black Diamond that lacked the room [32]. Duvall's mayor sits on that body [33].
And the county owns 75 acres of farmland on Duvall-Monroe Road, bought with public money, including Conservation Futures, and idle since 2020 [34]. It sits outside the city limits, so it adds nothing to Duvall's housing numbers, and we say that plainly. But a county that asks a small town to make room for homes it cannot fund can be asked to bring something to the table.
What a resident can actually do
First, what does not work. In Washington you cannot put a zoning ordinance to a local vote. The courts hold the zoning power was given to the city council, not to the city as a corporate body, so zoning is not subject to local initiative or referendum [35]. Petitions persuade; they do not decide.
What works, with the dates attached.
- Ask for the data as a legal demand. Send a public records request to the city clerk for the workbook behind the August 2026 capacity slides, broken out by income level; the city's displacement analysis; the City Facility Assessment and its list of potential surplus properties; and the consultants' site selection study for city hall and the police station, with its survey and final report. State law starts a five-business-day response clock [36]. Any time. Do it first, because everything else gets stronger with the numbers in hand.
- Put a specific comment in the record. Email the clerk at cityclerk@duvallwa.gov, addressed to the Council and the Planning Commission, and ask that it be entered into the record of the Title 14 amendments. Comment for a meeting is due by noon on the meeting day. Every council and Planning Commission meeting until adoption is a chance; the dates are on the record page.
- Comment on the environmental review. On September 18 the city opened a consultation under the State Environmental Policy Act on the plan and code amendments, before it decides their environmental threshold. Written comments go to planning@duvallwa.gov [57]. Due October 15. (The city reissued the notice on October 1 with the later date; it first said October 2. Updated October 8, 2026.)
- Propose an amendment, not only an objection. Any resident may propose changes to the plan and the code [51]. There are three doors, each with its own date:
- Now, in the plan and code under review. A comment can carry proposed text: for example, a housing policy that city-owned land in mixed-use zones be weighed first for mixed-use civic buildings with permanently affordable homes, under a ground lease, before single-purpose city buildings are sited there; and a line in the MU30 use table allowing a shared workshop as part of a mixed-use building [24][44]. Until adoption, due by December.
- With the budget. State law lets the city amend the capital facilities part of its plan at the same time as its budget, outside the once-a-year limit [52]. That is where the city's buildings and building pads are listed [46]. Department budgets October 6 and 20; final hearing November 3.
- The annual docket. Each year the city collects proposed plan amendments for the Planning Commission; in 2019 the council was told the deadline would be July 15 every year from 2020 [53]. Next: July 15, 2027. Confirm the date with the clerk.
- Speak to the money, on the record, in October and November. The council discusses its discretionary fund on October 6 and holds the final budget hearing on November 3. This is where the city decides whether to spend about $36,000 a year on an agency to administer affordable homes, or roughly half a staff position [13]; whether to fund a fee waiver or the study its own 2023 housing plan called for [25]; and what it plans for its buildings and its land. Ask for the money to buy homes, not paperwork, and ask that Lot 409 be weighed for its best use before it is committed.
- Write to the state reviewer. Commerce reviews the city's drafts for 60 days before adoption [37]. A letter there lands where compliance is actually judged.
- Speak at the public hearing on the zoning changes when it is noticed. Spoken comment is taken only in person.
- Preserve the right to appeal. Only someone who took part, in writing or in person, can petition the Growth Management Hearings Board, and only on an issue related to what they raised [38]. The petition is due within 60 days of the city publishing the ordinance [39]. Mercer Island is the working example.
- Use the county doors. Ask the council to send the reconciliation letter to the County Executive, and ask the county when it will process the South UGA change the adopted plan named (the September 2026 drafts would strike it from the land use policies; corrected October 8, 2026). Comment at the county's growth planning council, which meets November 18 [33], and at the county council when it ratifies target changes.
Check our math
Every number here comes from a public source, and every calculation comes from one model. The model is published as a spreadsheet at dontbothellduvall.com/model/, so anyone can change the inputs and see what happens. If a number here is wrong, tell us and we will correct it in public.
- 1. City of Duvall council meeting, January 6, 2026, work plan update (city recording). youtube.com
- 2. Washington Office of Financial Management, April 1 postcensal housing estimates and permit series, Duvall. ofm.wa.gov
- 3. King County Countywide Planning Policies growth targets (Ordinance 19660), as cited in the city's capacity analysis. kingcounty.gov
- 4. BERK Consulting, Land Capacity Analysis for City of Duvall Proposed Rezones, December 3, 2025, Exhibit 6. duvallwa.gov
- 5. HUD FY2026 income limits, King County (Seattle-Bellevue HUD Metro FMR Area). huduser.gov
- 6. Our cost and feasibility model, run September 21, 2026, published as a spreadsheet with its inputs and assumptions at dontbothellduvall.com/model/. dontbothellduvall.com
- 7. Rent ceiling computed as 30% of the income limit, utilities included, HUD household-size method. huduser.gov
- 8. City of Duvall, draft DMC chapter 14.47 Affordable Housing, September 1, 2026. duvallwa.gov
- 9. Rent listings captured September 19, 2026 (Zillow and property websites), with year built from King County Assessor records. zillow.com
- 10. Growth Management Hearings Board, case 25-3-0003 (Futurewise and residents v. Mercer Island), Final Decision and Order, August 1, 2025. letstalk.mercergov.org
- 11. Washington Department of Commerce, Petition for Review, September 3, 2025. eluho.wa.gov
- 12. City of Duvall, "Workshop on Duvall Municipal Code Title 14," slides posted to the city Document Center, September 15, 2026. duvallwa.gov
- 13. City of Duvall council meeting, September 15, 2026 (city recording). youtube.com
- 14. City of Duvall draft comprehensive plan, September 2026, Appendix A, Tables A-2 and A-4. duvallwa.gov
- 15. BERK Consulting memo, December 3, 2025, Exhibits 4, 5 and 6. duvallwa.gov
- 16. Our cost and feasibility model, sections on cost stack, feasibility and the value of each tool; published at dontbothellduvall.com/model/. dontbothellduvall.com
- 17. City of Duvall, 2027-2028 preliminary biennial budget presentation, September 15, 2026. youtube.com
- 18. City of Mercer Island, Comprehensive Plan GMA compliance page and July 21, 2026 ordinances (26-09, 26C-10, 26C-11) and June 2026 ordinance 26C-07. letstalk.mercergov.org
- 19. City of Duvall council meeting, September 1, 2026 (city recording; staff's answer on capacity at 0:20 and 0:23). youtube.com
- 20. RCW 36.70A.540 and the housing element requirements of RCW 36.70A.070(2). app.leg.wa.gov
- 21. City of Duvall, draft DMC chapter 3.12 Multifamily Tax Exemption, September 1, 2026. duvallwa.gov
- 22. Chapter 84.14 RCW, including RCW 84.14.020, .090 and .110. app.leg.wa.gov
- 23. RCW 82.02.060(2). app.leg.wa.gov
- 24. RCW 39.33.015. app.leg.wa.gov
- 25. City of Duvall Housing Action Plan, adopted September 19, 2023, Actions I.1 and I.8. duvallwa.gov
- 26. RCW 82.14.530. app.leg.wa.gov
- 27. Our rent survey, September 19, 2026.
- 28. Washington Joint Legislative Audit and Review Committee, Multifamily Tax Exemption review, 2019. leg.wa.gov
- 29. City of Duvall council meeting, January 6, 2026 (city recording; timestamps 3:34, 3:39, 3:44, 3:50, 4:01). youtube.com
- 30. City of Duvall council minutes, September 1, 2026. duvallwa.gov
- 31. Washington Supreme Court, Climate Solutions v. State of Washington, September 17, 2026 (Initiative 2066). courts.wa.gov
- 32. King County Growth Management Planning Council, Motion 25-3 and staff report, November 19, 2025. cdn.kingcounty.gov
- 33. King County Growth Management Planning Council membership and meeting schedule. kingcounty.gov
- 34. King County records for parcel 0626079039, including warranty deed 20201223002074. blue.kingcounty.com
- 35. Leonard v. Bothell, 87 Wn.2d 847 (1976); Lince v. Bremerton, 25 Wn. App. 309 (1980); Save Our State Park v. Board of County Commissioners, 74 Wn. App. 637 (1994).
- 36. Chapter 42.56 RCW (Public Records Act). app.leg.wa.gov
- 37. RCW 36.70A.106. app.leg.wa.gov
- 38. RCW 36.70A.280(2)(b) and (4). app.leg.wa.gov
- 39. RCW 36.70A.290(2). app.leg.wa.gov
- 40. King County GIS, Property/KingCo_PropertyInfo, "Publicly owned lands" and parcel layers, queried September 19, 2026 (our extract, published with the model). gismaps.kingcounty.gov dontbothellduvall.com
- 41. Development Agreement, City of Duvall and CamWest Development, Inc. and CamWest Duvall LLC, executed December 2007 and January 2008 (sections 15, 16(c) and 22 to 26; conceptual site plan, November 8, 2007), city Document Center; City of Duvall, Staff Report and Recommendation to the Hearing Examiner, Walden at Big Rock Preliminary Plat (SU17-001), hearing April 17, 2019, describing the Pre-Annexation Agreement (2007) and the Development Agreement (January 8, 2008; First Amendment June 6, 2017); and City Council minutes, March 15, 2022 (final plat, Resolution 22-10). duvallwa.gov
- 42. Statutory warranty deed, Toll Bros., Inc. to the City of Duvall, dated December 9, 2022, King County recording 20230111000142 (Lot 409 and Tracts 973, 977 and 996, The Ridge at Big Rock Phase III, plat Vol. 298, pp. 004-015). recordsearch.kingcounty.gov
- 43. King County Assessor, parcel 7299021190 and neighbouring parcels (legal descriptions, tax roll valued 2025 and 2026); King County aerial imagery, 2019 and 2025; King County parcel layer, queried September 21, 2026. blue.kingcounty.com
- 44. City of Duvall, draft DMC chapter 14.20 Mixed Use and Commercial Zoning Districts, September 1, 2026: 14.20.020.B, Table 14.20.040.B and its footnotes, Table 14.20.050.A; and the draft proposed zoning map shown at the September 15, 2026 workshop. duvallwa.gov
- 45. City of Duvall City Council, August 19, 2025, item M.1, "Municipal Civic Campus Site Selection" (Makers Architecture and Urban Design): city recording, about 2 hours 33 minutes to 2 hours 49 minutes, and minutes; City of Duvall, Citywide Site Selection Services, Request for Qualifications, October 2024. youtube.com
- 46. City of Duvall draft comprehensive plan, September 2026 (drafts of September 4 and September 18, which show the adopted 2025 text with deletions struck through): policies H 4.10, LU 7.1 and LU 7.5, unchanged; LU 9.2 and ED 3.8 and the "Proposed South Urban Growth Area" passage, whose South UGA wording is struck; the Southeast UGA near Big Rock Ball Fields, whose parks and open space designation is struck; the Capital Facilities element (general government facilities; City Facility Assessment); Police Protection. duvallwa.gov
- 47. City of Duvall, sewer system information (read September 21, 2026) and Sewer Moratorium FAQ (September 22, 2021). duvallwa.gov
- 48. USDA Rural Development Community Facilities Direct Loan and Grant; Washington State Department of Commerce Building Communities Fund and Clean Energy Grants; Washington State Department of Agriculture food-system infrastructure grants; Washington Housing Trust Fund; King County Housing Finance Program. rd.usda.gov commerce.wa.gov commerce.wa.gov agr.wa.gov commerce.wa.gov kingcounty.gov
- 49. City of Duvall, City Administrator's memo to Council, "Fee Waiver Requests," September 8, 2026 (Sept 15 packet), citing DMC 14.58.030 and RCW 35.92.385. duvallwa.gov
- 50. City of Duvall, Public Works memo "2026 PW Maintenance and Operations Center Project Update," September 9, 2026, and presentation, September 15, 2026; 2027-2028 preliminary biennial budget presentation, September 15, 2026 (city recording); City of Duvall Facilities Capital Improvement Fund (2023-2024). duvallwa.gov
- 51. RCW 36.70A.470(2). app.leg.wa.gov
- 52. RCW 36.70A.130(2)(a)(iv). app.leg.wa.gov
- 53. City of Duvall council minutes, July 2, 2019, AB19-48 (comprehensive plan amendment docket timeline). duvallwa.gov
- 54. King County Assessor, eRealProperty, and King County GIS parcel records, read September 21, 2026: parcel 1326069118 (City of Duvall, "Police Station & Historic Duvall Train Station," 26225 NE Burhen Way, 6.68 acres, zoned PF); parcel 1326069119 (City of Duvall, 0.88 acres, vacant, public road access); parcel 1326069211 (City of Duvall, 3.68 acres); Duvall Business Tracts, Tract A (212990TR-A), and the plat of Duvall Business Tracts, Vol. 79 of Plats, p. 69 (1966); shared boundaries measured from the county parcel layer. blue.kingcounty.com
- 55. FEMA National Flood Hazard Layer, read September 21, 2026: parcel 1326069118 lies partly in Zone AE (1% annual chance), partly in Zone X (0.2% annual chance), and partly in Zone X (minimal flood hazard) on its Main Street side; parcels 1326069211 and 1326069119 are each split the same way. msc.fema.gov
- 56. City of Duvall Boundary Line Adjustment BLA20-001 (Redemption Church), King County recording 20220322900024, with its title exceptions (sensitive area protection easement 20210913001863; the Duvall Business Tracts easement 8911020236); Boundary Line Adjustment 01-002 (River View Plaza), recording 20010802900008. recordsearch.kingcounty.gov
- 57. City of Duvall, SEPA Pre-Threshold Consultation, CPU24-01 (2024 Comprehensive Plan Update Amendments) and CA26-005 (Title 14 amendments), issued September 18, 2026, comments due October 2, 2026; reissued as revised October 1, 2026, comments due October 15, 2026; Draft Amendments to the 2024 Comprehensive Plan, September 18, 2026. duvallwa.gov duvallwa.gov duvallwa.gov
Working analysis by one valley household and its collaborators. Not legal, planning or financial advice, and not the position of the City of Duvall, King County, or any agency.