Duvall: Grow, or Hold? · Cascadian Trading Guild

What this page is

A citizen briefing built from the public record: King County's growth targets, the AHBL, ECOnorthwest and BERK capacity analyses, the state's petition, the city's draft plan and 2023 Housing Needs Assessment, the December 2025 flood record, and the Valley Record's explainer of September 11, 2026. Every number carries its source at the bottom. Where the record was not found, the claim is marked unverified. It is not legal advice and it is not the city's position. It is one valley household's reading, offered for the public comment period, alongside a proposal for the county's idle farmland that is already on the record.

The numbers the plan is built on

2044 housing target

890 units

King County Ord. 19660 · 2019 baseline 2,778

Zoned capacity already found

1,343 units

A surplus of 453 over the target (2021 county report)

The actual deficit

675 units

All of it under 80% AMI · 409 under 30% AMI

2044 jobs target

990 jobs

Deficit 202 jobs · 13 to 17 acres of employment land

Residents who commute out

92%

Jobs-to-housing ratio 0.498 · county 1.38

Median household income

$162,622

ACS 2016-2020 · county $99,158 · median rent $2,388 vs $1,695

December 2025

Island

Flood Phase 4 · SR 203 and Woodinville-Duvall Rd closed · Dec 11 isolated

Built 2020 to 2024

433 units

Nearly all market rate · zero toward the under-80% need

Where the deficit actually sits (HB 1220 bands, net need 2024 to 2044)

Income band (share of area median income)	Four-person household earns up to	Can pay per month (30%)	Net units Duvall must show	What builds it
0 to 30% AMI, ordinary housing	$49,300	about $1,230	268	Public subsidy only (tax credits, Housing Trust Fund, county levy)
0 to 30% AMI, permanent supportive housing	$49,300	about $1,230	141	Subsidy plus a supportive-housing operator
30 to 50% AMI	about $72,900 (computed)	about $1,820	0	Already met on paper
50 to 80% AMI	$116,650	$2,916	266	Partly reachable by inclusionary set-asides
80 to 120% AMI	about $175,000 (computed)	$4,370	41	Market
Above 120% AMI			0	Market, and the market already delivered it
Emergency housing			170	Subsidy and an operator

Bands and net units: AHBL memo to the City of Duvall, Aug 28 2024, Table 1A, citing King County Ord. 19660. Dollar limits: the King County Housing Authority's published HUD income-limit table (kcha.org/housing/subsidized/eligibility, the table the Valley Record cited for 2026): 30% AMI $49,300 and 80% AMI $116,650 for a four-person household. The 50% and 80 to 120% figures are computed from those and marked so. Ninety-four percent of the remaining need is under 80% AMI.

Two frames for one town

Growth: the certifiers' frame

Show land capacity for 890 units and 990 jobs by 2044, banded by income. Find it inside city limits, since the county's plan has spoken for the ring. Prove the seats exist; whether anyone sits in them is not the city's concern. Rebuild the transportation model afterward so it matches the housing number. Three agencies certify, each checking its own ledger: Commerce checks acres and bands, King County checks the Housing Element against the 2023 Action Plan, PSRC checks the model.

Resilience: the valley's frame

Count what the valley can produce, carry, and recover. House the people who already work here, at the wages they earn here. Make work here for the people who live here, so fewer of the 92% have to drive out. Model the roads and the river first and size the town to them. Put the floor to work growing food, which is what the county designated it for in 1985 and paid for in 1986 and 2020. Economics means activity, and the activity this valley is built for is agriculture.

The state's frame is not wrong about the need. It is wrong about the unit. The need is concentrated among the households that growth-as-stock does not serve.

Three findings

Finding 1 · the instrument

The vans are for passengers who cannot buy a ticket

The city's staff describe capacity as passenger vans: show the seats, whether or not anyone fills them. Fair. But 409 of the 675 seats the state wants shown are for households under 30% AMI, and upzoning and inclusionary zoning cannot, on their own, build those. Inclusionary set-asides typically land at 60 to 80% AMI. Zero-to-thirty needs tax credits, trust-fund dollars, and an operator willing to run supportive housing in a town with no transit and two flood-prone roads. The seats that will actually get built are the market-rate ones that ride along with the upzoning. The city said this itself, to the state, before the appeal: "it would not be genuine to equate high-density housing with affordable housing" (Duvall's senior planner, quoted by The Urbanist, Oct 2025). The December 2025 BERK memo then does exactly that: every zone at 20 units per acre or more is booked as housing for 0 to 80% AMI, and the surplus is 104 units on a "medium" market factor where the county's guidance says "high."

Show the funder, or stop counting the seats.

Finding 2 · the people

The jobs target and the housing bands describe the same households

Who lives in a unit priced for 30 to 80% AMI in Duvall? The school paraprofessional, the Safeway clerk, the farmworker, the care aide, the line cook. They already work here; most commute in, because the town's own 1,500 jobs are more than half services and education while 92% of residents drive out to information, health-care and professional jobs. The state's 990 jobs and its 675 affordable units are one population seen from two sides. A plan that treats them as separate line items builds neither.

House the people who work here; make work here for the people who live here. One plan, not two.

Finding 3 · the ground

The binding constraint is physical, and no certifier measures it

In December 2025 the Snoqualmie hit Flood Phase 4, SR 203 closed north of town, Woodinville-Duvall Road closed, and on December 11 Duvall and Carnation were islands. Those are the only two arteries. Capacity under the Growth Management Act is a zoning quantity. Capacity on this ground is a road, a bridge, a floodplain, a drainfield, a parking space. PSRC's request is to redo the transportation model to fit the higher housing number: the order reversed. The December 2025 capacity memo has been read: it carries no road or flood assumption at all. The draft plan sets LOS D for SR 203, admits the city cannot apply intersection concurrency to a state highway, and says in its own reassessment strategy that where road improvements cannot be funded "the City may adjust land use assumptions." Ask the council whether it will.

Ask for the assumptions. If they are not there, that is the finding.

What the record says about the ground

1985 · the fence

King County draws the Snoqualmie Valley Agricultural Production District

One of five districts, 41,000 acres of the county's best soil combined, agriculture the protected use. This designation is the reason Commerce rejected annexation as a capacity strategy: the ring around Duvall is "already spoken for" in the county's plan. Spoken for as food.

1986 and 2020 · the farm bought twice

The public buys the farming rights, then the farm itself

Parcel 0626079039, 75.8 acres on Duvall-Monroe Road: development rights sold to the county's Farmland Preservation Program in 1986; the fee bought in 2020 for $1,058,600 with Conservation Futures and Parks Levy money, for a trail extension ranked #31 and unfunded at $17 to $35 million. Farmed until the sale. Grass since.

2016 and 2023 · the county's own words

"Maintain farmland potential on lands acquired for other purposes"

The 2016 Agriculture Commission review said it. The 2023 Conservation Futures round named food sovereignty and farmland access as the direction. The Farmland Lease Program that would carry it runs on 1.2 staff and $50,000 a year, with 26 farmable acres idle on the parcel it already manages next door.

2025 · the appeal and the flood

The state appeals the town's plan; the river closes the roads

September: Commerce appeals Duvall's plan, the first time the state itself has challenged a city plan under HB 1220. December: Flood Phase 4, both roads closed, the town an island for a day. The two events are three months apart and appear in none of the same documents.

The county's leverage runs both ways

It is the county, through its 2044 plan, that made annexation unavailable to Duvall. It is the county that asks Duvall to rebuild its Housing Element. It is the county whose Farmland Lease Program cannot lease the farmland it holds. The county fenced the valley for food, bought the farming rights, bought the farm, then left it in grass while telling the town beside it to densify. The posture this page takes toward the county is not opposition. It is: we will deliver your designations; match your fiscal priorities to them.

An honest caveat, said first. Parcel 9039 sits outside Duvall's city limits. A farm cooperative and food hub there adds not one unit and not one job to Duvall's capacity showing under the Growth Management Act. It addresses the real problem, not the paper one. That is the point, and it should be said in those words at the microphone before anyone else says it.

The proposal on the record: a community-farming cooperative as master lessee, a bounded food hub (farm market and value-added kitchen) in the standing barn, and the trailhead the county itself designated, all under a compatible-use lease (King County Code 26.12.010.K), no purchase, no conversion, no county capital. The full case, the deeds, the easement, and the permits are at the parcel proposal.

Where the fiscal priorities can shift

King County

Staff the lease program. One position and a compatible-use lease template could activate 9039 and the idle 26 acres at 9005. Under $200,000 a year from the general fund or a levy. Conservation Futures money buys land and cannot pay staff, so this is a budget choice, not a land purchase.
Let a partner build the trailhead. SNO-1 is #31 and unfunded. A joint-use agreement delivers the trailhead and on-parcel segment at partner cost and puts the interim use in farming, as the 2016 review directs.
Fund the backbone the county said it lacks. "No truck, no trailer, no tractor." Parks Levy partnership grants and the Local Food Initiative can fund wash-pack and aggregation on the valley floor.
Pair the Housing Element ask with housing capital. If the county wants 409 units under 30% AMI shown, bring levy dollars to build them, or stop counting the seats.

City of Duvall

Publish the assumptions. The BERK memo's cost, its capacity under the county's "high" market factor, and the PSRC model inputs. If flood closure and SR 203 level of service are not in them, say so in the Housing Element.
Zone the jobs deficit for food. The 13 to 17 employment acres the analysis calls for can be food processing and farm support at the south end, next to the valley floor, with a cooperative food hub as anchor tenant. That is the one way the farmland proposal can enter the city's own capacity showing.
Aim inclusionary zoning at the band it can reach. Require the set-aside at 50 to 80% AMI, the 266-unit band, and stop implying the ordinance touches 0 to 30%. Then ask the county for the money.
Keep the middle-housing strip, and say why. Smaller, cheaper homes are what the surveys asked for. It is the response to residents, not to Commerce.

The ask: Duvall as the first public stakeholder

The farm on Duvall-Monroe Road cannot count toward the city's capacity showing; it is outside city limits. It can do something more useful. Most of the public money built for a project like this (USDA Community Facilities, the state's Community Economic Revitalization Board, trail grants, county levy partnerships) wants a local government at the front. The city is being asked for standing, not cash: a resolution of support and a stakeholder seat; food-system employment named in the Economic Development element; the 13 to 17 employment acres the jobs analysis calls for zoned at the south end for food processing, so the hub's jobs land inside the city; an interlocal agreement with the county; and, at most, the $50,000 match that turns the project's feasibility study from a proposal into a funded one. What that buys, on our estimates from same-county analogues: 25 to 50 direct jobs at $40,000 to $85,000, 10 to 25 incubated food businesses, $1 million to $3 million a year of direct output, a working farm on the valley floor, and the trailhead the county designated, at no county capital. No housing on site; the deed and the easement forbid it. The project is demand for the middle-housing strip, not supply.

Run the model: what the plan itself says to do

The city's capacity showing counts zoned acres times allowed density. It does not count roads, parking, the river, or where the new households will work. The draft plan's own transportation element says what to do when those do not add up. Verbatim:

"The City shall maintain a reassessment strategy to address changes in funding availability, system performance, or adopted growth assumptions. Where transportation improvements necessary to maintain concurrency cannot be funded or implemented within required timeframes, the City may adjust land use assumptions, modify capital improvement priorities, or phase development consistent with adopted policies and the Growth Management Act."
City of Duvall Draft Comprehensive Plan, September 2026, Transportation element, concurrency and reassessment strategy.

We built a small, open model of the town's carrying capacity and ran it with public inputs: the rezone showing from the BERK memo, WSDOT's 2025 traffic counts on SR 203, standard trip and parking rates, and the December 2025 closure record. It is honest about what it finds. On an ordinary morning the three entries have room: the showing would use about a quarter of the remaining peak-hour headroom on each. The constraints are elsewhere. The showing demands about 1,500 parking spaces the plan does not price, in a town with no garage and about 230 public on-street spaces, most of them on Main Street. Thirty homes per acre with a conventional 1.5 spaces each is a third of the acre in surface lot before any building stands, so it only fits as structured parking, which costs $30,000 to $60,000 a space and lands in the rent; build to the state's 0.5-per-unit cap instead and about 600 cars go to the curb in front of the R6 and R8 houses. The consultant's memo says it in its own way: it recommends the city review "parking requirements" as a barrier to the density it assumes. SR 203 carries 12,000 to 14,000 vehicles a day on the approach into town from NE 124th, the highway the plan holds to LOS D, and on that busiest approach the headroom is tighter than the average above. The new households bring about 1,500 workers to a town with about 1,000 jobs now held by in-commuters, so out-commuting grows even in the best case. And in December the roads were closed for about three days, with the whole town cut off on December 11.

Input	Value	Source
Units in the rezone showing	1,021 (779 in zones at 20+ per acre)	BERK memo, Dec 3 2025, Exhibit 5
SR 203 daily traffic: south of NE 124th / north at Cherry Valley Rd / NE 124th to Woodinville-Duvall Rd	9,100 / 9,200 / 12,000 to 14,000	WSDOT Traffic Counts (AADT), 2025
Added morning peak trips, share leaving town	about 490, about 85%	standard trip rates; 92% commute out (Housing Needs Assessment)
Parking demand from the showing / public on-street supply	about 1,500 spaces / about 230	standard rates; supply estimated from 2.5 curb strips, replace with the city inventory
Where the densest zone sits	MU30, the south end fronting SR 203 (396 of the 779 units)	City's proposed zoning map, Valley Record Sept 11 2026; BERK Exhibit 5
Road closures, Dec 2025	about 3 days (town fully cut off Dec 11)	Valley Record closure record

The measured ask. Not "stop." Four things the council can do inside its own plan before it adopts the rezones: publish the intersection level-of-service analysis for Main Street under the new densities, since that is where LOS D bites, not at the town line; publish the parking standard the rezones assume and the on-street inventory against the 1,500 spaces the showing implies, and say whether the answer is structured parking (show the rent) or the state cap (show where the cars go); state the flood egress plan for households without a second car; and use the reassessment clause the plan already contains, phasing the rezones to the road and parking improvements that are actually funded. The model is a single readable file; ask for it through the form below, and correct any input.

What the city's own September drafts say

The city published its draft zoning chapters on September 1, 2026. Read them before the meeting, because they answer some of this and complicate the rest.

Draft chapter	What it does	What it means here
14.47 Affordable Housing	Applies to developments of 10 or more units. Offers density bonuses of 1.25, 1.5 and 1.75 times the allowed maximum for 10%, 20% or 30% of units affordable, extra height for bonus floor area that is half or wholly affordable, and tree-credit reductions. Affordable means 80% of area median income or less, held at least 50 years. A unit at 30% AMI or less counts as two.	As published it is an incentive program, not a mandate. On September 1 the council asked staff to make it mandatory instead. The draft text on the city's site is still the voluntary version, so ask which one is going to the Planning Commission.
3.12 Multifamily Tax Exemption	A new chapter creating a tax exemption for multifamily housing, tied to the affordable-housing chapter.	The 2023 Housing Action Plan asked for this and the city had none. It is the tool that actually moves the rent on set-aside units. Credit where it is due.
14.49 STEP Housing	Shelter, transitional, emergency and permanent supportive housing, implementing the state statutes behind HB 1220.	This is the zoning half of the 141 supportive units and 170 emergency units. Zoning them is necessary and is not the same as funding them.

The counting rule in 14.47 is worth one sentence at the microphone. A unit at 30% of area median income counts as two, which is a sensible incentive; it also means the paper deficit can close faster than the real one.

At the microphone: five points in the plan's own numbers

The state's appeal is not about growth. Duvall already shows 453 more units of capacity than the target. The deficit is 675 units under 80% AMI, and 409 of those are under 30% AMI.
Upzoning and inclusionary zoning cannot build housing for households under 30% AMI. Only subsidy can. Show the funder, or stop counting the seats.
Ninety-two percent of Duvall's working residents commute out. Most of the jobs in town are in services and education. The people the state's housing bands describe already work here. House them and employ them with one plan, not two.
In December both roads closed and this town was an island. Show us the flood and traffic assumptions in the capacity memo and the transportation model. If they are not there, the plan is not about this ground.
The county fenced the valley for food and left 75 acres of it in grass at the edge of town. Farmed until the sale, grass since. There is a records-backed proposal to put that land to work at no county capital cost, with an estimated 25 to 50 jobs in the wage band the state is talking about. Pass a resolution of support, name food-system jobs in the plan, zone the employment acres for food, and be the public applicant. Before the county tells Duvall to grow, let Duvall ask the county to farm what it already owns.

Five records to ask for (one page each)

Record	Why it matters
BERK Consulting's contract, task order and invoices for its Dec 3, 2025 capacity memo	The memo is on the city site and has been read: six pages, no road or flood content, and it counts any zone at 20 units per acre or more as housing for 0 to 80% AMI. Its price is unverified.
The Hearings Board case number and any settlement terms with Commerce	The petition (Sept 3, 2025) has been read: issues under RCW 36.70A.070(2)(c) and (d), .020(4), .115 and WAC 365-196-410; relief sought includes a declaration of invalidity under RCW 36.70A.302. Sanctions under RCW 36.70A.340: withheld fuel tax, sales tax, liquor revenue, and suspended real estate excise tax authority. Case number and settlement terms unverified.
The nexus study the 2023 Housing Action Plan called for	The Action Plan (adopted Sept 19, 2023) has been read: it asked the city to study inclusionary zoning with a medium-term nexus study before requiring units (Action I.8). On Sept 1, 2026 the council directed staff to draft a mandatory program instead. The draft chapter published that same day is still the voluntary, incentive-based version. Where is the study?
PSRC transportation model inputs; any level-of-service analysis for SR 203 and Woodinville-Duvall Road; flood-closure assumptions	Finding 3 stands or falls here.
The Planning Commission hearing date for the zoning amendments	The schedule is now partly public: council discussed the drafts on Jan 6, Jun 2, Jun 16, Jul 7, Jul 21 and Sept 1, 2026; the Planning Commission meets the second and fourth Wednesday at 6 pm; and the work plan Commerce required has Phase 2 adopted by December 2026. The hearing date itself is not posted yet. Written comment goes to the city clerk, cityclerk@duvallwa.gov, 15535 Main St NE; ask that it be entered into the record.

Public comment

September 15, workshop, Duvall Visitor Center, 5:30 p.m. September 17, open house, 6 p.m.

After certification the tools are the annual docket and the Growth Management Hearings Board. Before it, the tools are the microphone and the written record. This page is the written record of one reading. The farm proposal and a way to write to us are linked below.

Write to us The farm proposal Sources

Write to us Sources

Valley Record, "Duvall's controversy over potential upzoning | For the Record," Sept 11 2026. valleyrecord.com/2026/09/11/duvalls-controversy-over-potential-upzoning-for-the-record/
AHBL, "Land Capacity Analysis | Housing by Income Level," memo to the City of Duvall, Aug 28 2024, project 2230425.30 (employment section by ECOnorthwest). Tables 1, 1A, 3, 6; pp. 3 to 13. Cites King County Ord. 19660 (2023) and the 2021 King County Urban Growth Capacity Report (Ord. 19369).
City of Duvall Housing Needs Assessment, Blueline, April/May 2023 (Commerce HB 1923 grant). Exhibits 1, 4, 5, 7, 17, 18, 19, 24, 27, 29, 32; "Key Takeaways," p. 22.
The Urbanist, "Duvall Growth Plan Faces Challenge After Disregarding New Housing Law," Oct 17 2025.
BERK Consulting, "Land Capacity Analysis for City of Duvall Proposed Rezones," letter to the City Administrator, Dec 3 2025 (duvallwa.gov DocumentCenter 15116). Exhibits 1 to 6.
Washington Department of Commerce v. City of Duvall, Petition for Review, Growth Management Hearings Board, Western Washington Region, Sept 3 2025 (duvallwa.gov DocumentCenter 15114); Resolution 25-06 attached.
City of Duvall Housing Action Plan, adopted Sept 19 2023 (duvallwa.gov DocumentCenter 10360): policy H-4 text and Action I.8.
City of Duvall Draft Comprehensive Plan, Sept 2026 (duvallwa.gov DocumentCenter 15674): Transportation element, policies T 6.2 and T 6.5, concurrency and reassessment strategy; Economic Development element, commuting.
RCW 36.70A.340 (sanctions), app.leg.wa.gov.
King County Housing Authority eligibility page (80% AMI, four-person household, 2026: $116,650); HUD FY2026 King County income limits via secondary aggregators (1-person $81,700; 2-person $93,350).
Valley Record flood coverage, Dec 2025: road-closures tracker; "Carnation, Duvall isolated due to flood waters." MyNorthwest, "13 western WA rivers at dangerous Flood Phase 3, 4," Dec 2025.
HistoryLink.org, "King County Agricultural Production Districts" (File 20688) and "King County Farmland Preservation Program" (File 7691); King County Farmland Preservation Program page.
Parcel 9039 record: Warranty Deed rec. 20201223002074; King County LCI Parcel Acquisitions; 2024 Regional Trail Needs Report (SNO-1); Farmland Lease Program briefing to the Agriculture Commission, Feb 10 2022; 2016 Agriculture Commission Program Review. Full citations at the parcel proposal's record page.

Prepared Sept 15, 2026 from public records and published reporting. Working analysis by one valley household and its collaborators; not legal, planning or financial advice; not the position of the City of Duvall, King County, or any agency. Figures marked unverified were not confirmed to a primary source this week and are named so the reader can check them.