HomeMy WebLinkAbout3.1 Housing Element
STUDY STUDY SESSION MEMORANDUM 3.1
TO: Town Council March 9, 2021
SUBJECT: Housing Element Community Outreach Program
BACKGROUND
At the Annual Planning and Goal Setting Workshop (“Annual Workshop”) in February
2021, the Town Council discussed the upcoming 2022-2030 Housing Element update
which is anticipated to present significant land use policy challenges for Danville
(Attachment A). This is due to: (1) an assigned housing target of 2,241 units, a 4-fold
increase from the prior housing element cycle; and (2) new state laws that allow financial
penalties to be imposed on communities which fail to meet their assigned targets within
the 8-year Housing Element cycle.
DISCUSSION
The Town Council discussed the challenges at the Annual Workshop, evaluated possible
strategies, and directed Town staff to embark upon a community outreach plan to inform
and engage the community on this mandated effort as soon as practicable. Based on a
schedule dictated primarily by a state-prescribed timeline and recommended by the
Town’s Housing Element consultant, staff anticipates that the community outreach effort
would occur in three phases:
Household Income
Category
2015-2022
Housing Assignment
2022-2030
Housing Assignment
Difference
Very Low 196 652 +456
Low 111 376 +265
Moderate 124 338 +214
Above Moderate 126 875 +749
Total: 557 2,241 +1,684
Housing Element Public
Outreach Program 2 March 9, 2021
Phase 1 - Upfront Community Education & Engagement (Spring 2021). This effort lays
the factual groundwork for future discussions on housing:
• Town Website: Updated to provide information pertaining to Housing Element
update requirements, outline of the process, related housing legislation, frequently
asked questions (FAQs), email subscription option to stay informed.
• Initial Survey: Intended to gather information regarding the housing related
perspectives and concerns of interested participants and informs how the Town
would proceed with future education efforts.
• Town Talks (April 2): Introduces the topic of housing legislation and housing
element update in an interview-style format.
• Public Information Platforms including quarterly newsletter, social media, mailers
and short educational videos on the “what and how” of housing element
requirements.
• Stakeholders and Commissions: Informational updates to Town Commissioners and
identified community stakeholders.
Phase 2 - Community Engagement on Housing Opportunity Sites (Summer/Fall 2021).
This builds upon the groundwork of Phase 1 and envisions an effort that invites the
community to review, comment and provide input on all potential housing opportunity
sites based on the state-established parameters. This effort will involve the use of online
interactive web tools, similar to ones utilized for the Townwide Bicycle Master Plan.
Phase 3 - Community Input during Public Hearing Process (Fall 2022/Winter 2023). The
information and engagement in the first two phases would serve to – as much as
practicable – inform the community on the challenging land use decisions that would
arrive before the Planning Commission and Town Council in late 2022 and early 2023.
RECOMMENDATION
Consider the community outreach strategy presented and provide feedback, particularly
with regard to Phase 2.
Housing Element Public
Outreach Program 3 March 9, 2021
Prepared by:
Diane Friedmann
Assistant to the Town Manager
Reviewed by:
Tai Williams
Assistant Town Manager
Attachments: A – Town Council Annual Town Planning and Goal Setting
Workshop, Agenda Item 4.1
HOUSING ELEMENT UPDATE:
CHALLENGES & STRATEGIES
SUMMARY
The upcoming 2022-2030 Housing Element update will present significant policy
challenges for Danville. This is due to: (1) an assigned housing target of 2,241 units;
and (2) new state laws that allow financial penalties to be imposed on communities
which fail to meet their assigned targets within the 8-year Housing Element cycle.
These challenges occur within the political backdrop of a governor that aspires to
aggressively build 3.5 million new units by 2025, a state legislature that seeks to
wrestle regulatory control of housing approvals from local governments, and
intensifying pressure from pro-housing groups that view having a large housing
supply as the main solution to the state’s affordable housing and homeless crises. This
paper provides:
• Background for this complex multi-faceted challenge;
• Update of the Housing Element process; and
• Strategies at the state, regional and community levels
BACKGROUND
California Housing Challenge
Historically, California is viewed as having a housing shortage – defined as producing
fewer housing units than are deemed necessary to accommodate its population and
job growth. Since 2005, California has added just 308 units for every 1,000 new
inhabitants (source: 2016 McKinsey Global Institute report). Comparatively, the
states of Texas, Washington, Oregon, Arizona, Nevada and New York have added
333, 386, 397, 409, 442 and 549 units for every 1,000 new residents, respectively.
A report by the California Department of Housing and Community Development
substantiates this decline by illustrating that the number of annual housing permits
issued – a leading indicator of housing construction – has declined since the housing
boom of the 1980s (Figure A).
2
Figure A. Annual permitting of housing units 1954-2016. Source: California Department of Housing
and Community Development.
Critics have long argued that community resistance and local government controls
are the main culprits of California’s chronic housing underproduction.
RHNA: Purpose and Process
In 1969, the state enacted the Housing Element Law (Government Code Section 65583)
which requires all cities and counties to ‘plan for’ their fair share of the statewide
housing need. This is implemented through the adoption of a Housing Element by
every California city and county with a required update every eight years (referred to
as ‘cycles’). The broad concept is to spread the responsibility of accommodating new
housing units equitably among all communities.
The most controversial aspect of each Housing Element update is the requirement for
cities and counties to identify specific viable land parcels within their communities to
accommodate the new housing target, including units that are affordable for
persons/households of very low, low, moderate, and above moderate income levels).
For built-out communities, this means that lands must be repurposed – usually
through a General Plan Amendment and Rezoning – to accommodate higher density
housing.
Each community receives its assigned housing target through a process called the
Regional Housing Needs Allocation(RHNA) which involves three levels of
government, each with its prescribed role:
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1. State level, State Department of Housing and Community Development (State
HCD) and Department of Finance (DOF) collaborates to determine the
number of housing units each region in California needs to plan for. Each
region receives its number through State HCD.
2. Regional level, the Council of Governments (COGs) is responsible for
developing a method to distribute these units to its cities and counties. The
Association of Bay Area Governments (ABAG) functions as the COG for the
nine-county Bay Area region.
3. Local level, cities and counties must update their Housing Element to
accommodate the housing target assigned to them by their COG.
As noted previously, the most prominent aspect of a Housing Element involves
identifying land parcels that can be repurposed and rezoned for higher density
housing development.
Within this simplified framework, the Bay Area is currently in the final stages of Step
2 (Exhibit A).
DISCUSSION
In June 2020, ABAG was assigned a housing target of 441,176 units from State HCD,
representing a 135% increase from the previous cycle. During the latter half of 2020,
the Town led a Contra Costa coalition to provide input into ABAG’s process of
developing a methodology to distribute these units among the 101 cities and 9
counties of the Bay Area. Danville participated in a similar effort as a member of the
Tri-Valley Cities (Exhibit B).
As a county whose
residents endure some of
the longest commutes in
the Bay Area, the
coalition advocated for a
method that achieves a
greater jobs/housing
balance by placing
housing units closer to
high-wage job centers in
the south and west bay
where job growth has far
outpaced housing
growth.
4
ABAG ultimately chose a methodology, which has been submitted for HCD approval,
that prioritizes ‘social equity’ at the expense of a jobs/housing balance. The draft
methodology allocates large housing targets to rural and suburban communities,
regardless of their limited land capacity or lack of transportation services, while
simultaneously shifting housing growth away from regional job centers (Exhibit C).
Based on ABAG’s adopted methodology, Danville’s assigned housing target is now
2,241 units, representing a startling 4-fold increase from the prior cycle. This
assignment is equivalent to 14% of the existing housing stock in Danville. At a more
granular level, the housing target is divided among five household income
affordability levels:
Household Income 2015-2022 2022-2030 Difference
Very Low 196 652 +456
Low 111 376 +265
Moderate 124 338 +214
Above Moderate 126 875 +749
Total: 557 2,241 +1,684
The most affordable units, which cater to the lowest income category, require the
highest density zoning. The concept is that smaller units tend to be more affordable.
Typically, ‘very low’ income units take the form of apartments or condominiums,
‘moderate’ units might take the form of townhomes, and ‘above moderate’ units are
market rate homes.
In practice, this translates to a need to find 70-90 acres of land as designated housing
sites that could accommodate the new housing target in the 2022-2030 Housing
Element.
Why This Matters
Since incorporation in 1982, Danville has been a carefully planned community,
balancing the need for growth and expansion with the desire to preserve the history
and setting that make the community unique. This reflects the concept of local control
which was the driving force behind voter’s decision to incorporate. Growth has been
linked to the need to preserve open space, provide facilities and infrastructure, while
retaining the capacity to serve and maintain the community based upon established
service level standards. The current population places the Town at about 95% of the
buildout capacity that was envisioned by the current general plan.
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As a community reaching build-out, it will be a significant challenge to find 70-90
acres of land for higher density housing. Amplifying this challenge are new (more
restrictive) definitions on what qualifies as ‘viable’ housing sites. The inability to
achieve this objective would render the Town’s housing element to be non-compliant
with the State Housing Element Law. Repercussions include:
• Limited access to state funding, including transportation funding for local
roadway maintenance and capital improvement projects;
• Lawsuits: When community’s housing element is found to be out of
compliance, its General Plan is at risk of being deemed inadequate and
therefore invalid, opening the possibility for lawsuits. Consequences of
lawsuits include:
• Court mandated compliance
• Court suspension of local control on building matters, freezing the
community’s ability to issue building permits, zoning changes, etc.
• Court approval of housing developments on behalf of the community
• Attorney fees associated with the lawsuit
Over the past 20 years, a number of cities and counties throughout the Bay Area
(including Corte Madera, Pittsburg, Pleasanton, Alameda, Benicia, Fremont,
Rohnert Park, , Menlo Park Napa County, and Santa Rosa) have faced legal
challenges to the adequacy of their housing elements. In virtually every case,
the city settled by amending their housing element and/or zoning ordinance
to accommodate more housing and paid the plaintiffs’ attorneys fees. Each of
these cases were filed prior to the most recent amendments to the state housing
law which make it exceedingly more difficult for cities to win such cases.
• Court imposed fines of $10,000 to $100,000 per month until the violation is
cured. The court may triple the amount if non-compliance remains after 3
months; and multiply by a factor of 6 if non-compliance remains after 6 months.
The statute also allows the state to collect these fines by withholding state
funding due to the city.
The crux of the issue is the misconception that local governments control the housing
market and should therefore be held accountable for housing production.
Consequently, the trend in legislation indicates that municipalities can expect to face
increasingly punitive sanctions for failing to accommodate housing targets or
‘produce’ these units.
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Next Steps: Actions and Possible Strategies
Housing Element Update
As creatures of the State, cities and counties are bound by Housing Element Law. At
present, the next technical step in the RHNA process is to begin updating the Danville
Housing Element, which must be adopted and submitted to State HCD for review by
January 2023.
It is recommended that the Housing Element along with the accompanying General
Plan land use amendments and Environment Impact Report (EIR), be considered as
one action. This would be a departure from past practice where the Housing Element,
General Plan Amendment, and accompanying EIR were considered as separate
publicly notified actions. We believe this would minimize public confusion and
streamline the process.
Procedural and Legal Options
Many have observed that the housing targets – compounded by the “No Net Loss
Law” requirement - are so substantially out-of-reach as to be infeasible. And even if
the Town can find adequate housing sites, the ability to ensure that 2,241 units are
built within the 8-year cycle is not only improbable but also out of the Danville’s
control.
Recommendation: Explore all procedural options and legal remedies, including an
appeal of Danville’s RHNA allocation from ABAG and State HCD’s allocation
methodology.
Building (Broader) Coalitions
The Contra Costa and Tri-Valley coalitions were unsuccessful in influencing ABAG’s
housing methodology selection. However, the effort illustrated that alliances of cities
did catch the attention of ABAG and compel a more thoughtful (if immovable)
response to Contra Costa and Tri-Valley concerns. The take-away is that earlier
engagement and a broader network is necessary to achieve a higher level of success.
Recommendation: Monitor actions other agencies statewide and collaborate with
those who are seeking achieve similar or compatible objectives.
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Community Education and Outreach
In prior cycles, our community became actively engaged only when notified of
potential rezoning of lands near them. By that point, it was a challenge to provide
objective information as community members were already alarmed about changes
to their neighborhood.
Recommendation: Retain a consultant to assist the Town with developing:
• Outreach approach (framework, timeline, channels)
• Strategic messaging (tone, delivery, audience)
• Public engagement methods (online tools)
It is recommended that the community outreach effort begin as early as practicable.
8
RECOMMENDATION
Consider the information outlined and provide feedback to staff regarding the
recommended actions:
1. Explore all procedural options and legal remedies, including an appeal of
Danville’s RHNA allocation from ABAG and State HCD’s allocation
methodology;
2. Monitor actions of other agencies statewide and collaborate with those who are
seeking achieve similar or compatible objectives;
3. Retain a public relations firm to assist the Town with developing a community
outreach approach, strategic messaging, and public engagement methods.
Exhibit A: RHNA Process and Timeline
Exhibit B: Letters to ABAG: Contra Costa Mayors Conference to ABAG Methodology
Committee (August 7, 2020); Contra Costa Mayors Conference to ABAG
Executive Board (October 2, 2020)
Exhibit C: Town of Danville letter to ABAG Executive Board (November 27, 2020)
Exhibit D: News Articles of Interest
EXHIBIT A
Contra Costa Mayors Conference 1 Letter to ABAG HMC
C O U N T Y M A Y O R S C O N F E R E N C E
2221 Spyglass Lane, El Cerrito, CA 94530
August 7, 2020
Mayor Jesse Arreguin, Chair
Association of Bay Area Governments
Housing Methodology Committee
375 Beale Street, Suite 700
San Francisco, CA 94105
RE: Support for the Plan Bay Area 2050 Baseline Data Methodology
Chair Arreguin,
The Contra Costa Mayors Conference, representing all 19 cities in Contra Costa county,
wishes to convey our appreciation for the Housing Methodology Committee’s work on
evaluating housing allocation methodologies for the next RHNA cycle (2023-2031).
We recognize that it is a daunting task, not only because of the collective recognition to
provide more housing that is affordable to a wide range of income levels but also because
we can’t forget that where we distribute the 441,176 housing unit assignment by
California Department of Housing and Community Development (HCD) to the Bay Area
is just as important to the overall quality of life for all residents in the Bay Area.
In light of these considerations, the Contra Costa Mayors Conference supports and
endorses the use of Plan Bay Area 2050 as the baseline data methodology because it is
consistent with the decades-long region-wide effort to:
1. Encourage housing development in proximity to jobs, which would in turn;
2. Reduce transit and transportation congestion, helping to alleviate long region
wide commutes; and
3. Reduce greenhouse gas emissions, consistent with both AB 32 and SB 375.
EXHIBIT B
Contra Costa Mayors Conference 2 Letter to ABAG HMC
It is of great concern to Contra Costa communities that the alternative “2019 Baseline
Household” method would reverse the decades-long region-wide effort to reduce traffic
congestion and GHG emissions through a greater jobs-housing balance. We appreciate
your consideration of our perspective and recommendation.
Sincerely,
/Signed hard copy to follow via U. S. mail. /
Gabriel Quinto, Conference Chair
Contra Costa Mayors Conference
Contra Costa Mayors Conference Membership
City of Antioch City of Oakley
City of Brentwood City of Orinda
City of Clayton City of Pinole
City of Concord City of Pittsburg
Town of Danville City of Pleasant Hill
City of El Cerrito City of Richmond
City of Hercules City of San Pablo
City of Lafayette City of San Ramon
City of Martinez City of Walnut Creek
Town of Moraga
1
C O U N T Y M A Y O R S C O N F E R E N C E
2221 Spyglass Lane, El Cerrito, CA 94530
October 2, 2020
Mayor Jesse Arreguin, President
Executive Board, Association of Bay Area Governments
375 Beale Street, Suite 700
San Francisco, CA 94105
RE: Consideration of a Modified Option 8A using the Plan Bay Area 2050 Growth
Baseline Methodology
Chair Arreguin,
Once again, the Contra Costa Mayors Conference (CCMC), representing all 19 cities and
nearly one million citizens in Contra Costa county, wishes to convey our sincere
appreciation for your efforts to facilitate an equitable distribution of the 441,176
housing units assigned to the Bay Area by the California Department of Housing and
Community Development (HCD) for the next RHNA cycle (2023-2031).
Since our last communication on August 7, 2020, the ABAG Housing Methodology
Committee (HMC) has chosen to utilize “Plan Bay Area 2050 Future Households”
methodology (a ‘middle road’) and a weighting of factors that prioritize ‘access to high
resource areas’ over the region-wide efforts to reach a jobs/housing balance.
IMPACT OF BASELINE METHODOLOGY CHANGE
At a county-by-county level, our analysis indicates that using a new “Plan Bay Area 2050
Future Households” baseline results in extraordinarily inequitable – and hopefully
unintended – benefits to primarily one county (Santa Clara) at the expenses of nearly all
others (Figure A):
2
Figure A. Impact of switching to the Plan Bay Area 2050 Future Households Baseline
Coincidentally, Santa Clara county is the home to all ten of the San Francisco Bay Area’s
largest technology companies including: Apple (188,000 employees), Hewlett Packard
(186,000 employees), Google (184,000 employees), Oracle (169,000 employees), Intel
(128,000 employees), Cisco (91,000 employees, and Facebook (60,000 employees).
Consequently, it seems counter-intuitive to utilize a baseline that reduces the housing
assignment to the sub region that is in greatest need of affordable housing and has the
largest existing housing deficit illustrated by ABAG’s CASA Compact presentation:
3
4
On a jurisdiction-by-jurisdiction level, our analysis reveals an even more alarming
pattern that the PBA 2050 Future Households baseline appears to allocate
disproportionately large assignments to small and rural communities while alleviating
the responsibility of communities with large job centers (Attachment B). This disparity
occurs within the county level, as illustrated in Santa Clara county’s numbers.
Sampling of
Impacted
Jurisdictions
Plan Bay Area 2050
Growth
(advocated by CCMC)
Plan Bay Area 2050
Future Households
(advanced by HMC)
Difference % Change
Santa Clara County
Los Gatos 142 1,430 +1,288 +907%
Monte Sereno 3 140 +137 +4,567%
Mountain View 12,377 7,810 -4,567 -37%
Palo Alto 11,127 6,810 -4,317 -39%
San Jose 100,155 67,240 -32,915 -33%
Santa Clara 14,285 9,630 -4,655 -33%
Sunnyvale 12,025 9,980 -2,045 -17%
Alameda County
Albany 355 930 +575 +162%
Piedmont 60 430 +370 +617%
Unincorporated 1,638 5,950 +4,312 +263%
Contra Costa County
Danville 223 1,820 +1,597 +716%
Hercules 411 1,060 +649 +158%
Martinez 311 1,670 +1,359 +437%
Unincorporated 2,588 7,310 +4,722 +182%
Marin County
Fairfax 215 460 +245 +114%
Mill Valley 27 710 +683 +2530%
San Anselmo 202 670 +468 +232%
San Mateo County
Atherton 30 280 +250 +833%
Hillsborough 116 470 +354 +305%
Pacifica 199 1,580 +1,381 +694%
Portola Valley 3 200 +197 +6,567%
Solano County
Benicia 258 1,270 +1,012 +392%
Dixon 209 690 +481 +230%
Rio Vista 84 420 +336 +400%
Suisun City 298 1,070 +772 +259%
Vacaville 1,056 3,650 +2,594 +246%
Vallejo 2,117 5,250 +3,133 +148%
Sonoma County
Sonoma 184 620 +436 +237%
Unincorporated 6,893 9,080 +2,187 +32%
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RECOMMENDED BASELINE
We understand that the Housing Methodology Committee (HMC) has chosen to present
“Option 8A” to the ABAG Executive Board as the only option for consideration at your
October 15, 2020 meeting. It appears that other compelling options – even as a valid
minority report - did not have a chance to advance.
Consequently, we are appreciative of the opportunity to present an alternative -
Modified Option 8A – to the ABAG Executive Board at its October 15, 2020 meeting.
Contra Costa’s alternative (highlighted in green) uses the Plan Bay Area 2050 Growth
baseline and leaves the HMC-recommended factors in place. A summary of the results
for each county is shown below and the effects for all cities are included in Attachment
B.
County Option 8A
(2050 Future HH)
Modified 8A
(PBA 2050 Growth) Change %
Alameda 85,690
79,412
(6,278) -7%
Contra
Costa
43,960
27,890
(16,070) -
37%
Marin 14,210
8,803
(5,407) -
38%
Napa 3,820
1,655
(2,165) -
57%
San
Francisco
72,080
57,792
(14,288) -
20%
San Mateo 48,440
45,804
(2,636) -5%
Santa
Clara
143,550
196,746
53,196 37%
Solano 11,920
8,075
(3,845) -
32%
Sonoma 17,520
15,000
(2,520) -
14%
6
The recommended use of the Plan Bay Area 2050 Growth baseline appears to make
significantly more intuitive sense for the entirety of the San Francisco Bay Area as it:
•Encourages housing development in proximity to job centers, which would
•Reduce transit and transportation congestion, helping to alleviate long region wide
commutes; and
•Reduce greenhouse gas emissions, consistent with both AB 32 and SB 375.
Furthermore, alternative Modified Option 8A is consistent with both the RHNA statutory
objectives as it would:
1.Increase housing supply, but in a manner that adds much needed housing near
the job centers;
2.Promotes infill development and reinvestment in urban centers that wish to
redevelop, thereby promoting socioeconomic equity;
3.Protects the environment, agricultural resources, and wild land hazards by
moving development pressure away from the urban edges;
4.Helps the San Francisco Bay Area achieve mandated GHG reduction targets
through an improved jobs/housing balance; and lastly
5.Ensures policy consistency with Plan Bay Area 2050 Blueprint by more closely
aligning the housing assignment at the major centers.
We appreciate your consideration of our recommendation and perspectives.
Sincerely,
/Signed hard copy to follow via U. S. mail. /
Gabriel Quinto, Conference Chair
Contra Costa Mayors Conference
Attachment A: Comparison of Baseline Methodologies and Housing Allocation
Alternatives – Option 8A (recommended by ABAG HMC) and
Modified Option 8A (recommended by CCMC)
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Contra Costa Mayors Conference Membership
City of Antioch City of Oakley
City of
Brentwood
City of Orinda
City of Clayton City of Pinole
City of Concord City of Pittsburg
Town of Danville City of Pleasant
Hill
City of El Cerrito City of Richmond
City of Hercules City of San Pablo
City of Lafayette City of San
Ramon
City of Martinez City of Walnut
Creek
Town of Moraga
+
“Small Town Atmosphere, Outstanding Quality of Life”
November 27, 2020
Public Information Office
ASSOCIATION OF BAY AREA GOVERNMENTS
METROPOLITAN TRANSPORTATION COMMISSION
375 Beale Street Suite 800
San Francisco, CA 94105
Subject: Methodology for Distribution of RHNA
Dear ABAG & MTC colleagues:
Once again, the Town of Danville wishes to express our appreciation for ABAG’s work
on the 6th Cycle RHNA process. The Town recognizes that it is not an easy task to develop
a methodology that appropriately and fairly distributes the 441,176-unit RHND to the
101 cities and nine Bay Area counties.
On October 15, 2020, the ABAG Executive Board voted to support the Housing
Methodology Committee’s recommended methodology “Option 8A” and to forward it
for public review in advance of submittal to the State Department of Housing and
Community Development. The methodology utilizes the “Plan Bay Area 2050 Future
Households” Baseline and applies a series of Factors that adjust the Baseline allocation, in
a manner which prioritizes a social equity focus (“Access to High Opportunity Areas”)
at the expense of region efforts to reach a jobs/housing balance and a greenhouse gas
emissions (GHG) reduction targets.
Prior to the October public hearing, the Contra Costa Mayors Conference, Alameda
County Mayors Conference and cities in the Bay Area submitted letters expressing
significant concerns with the proposed methodology. This letter highlights five concerns
that have been identified, which is that the proposed methodology is:
1. Inconsistent with Plan Bay Area 2050 Draft Blueprint.
2. Promotes suburban sprawl and furthers a pattern of jobs-housing imbalance.
3. Inconsistent with other State mandates including the requirement to reduce
Vehicle Miles Traveled (VMT) and greenhouse gas (GHG) emissions.
4. Directs growth to areas with limited land capacity, restricted open space and
natural hazards.
5. Works against equity and fair housing goals.
EXHIBIT C
Page 2
This letter also suggests an alternate methodology which would more equitably
distribute RHNA and in a manner that is more consistent other State mandates.
1. Insufficient evidence to demonstrate consistency with Plan Bay Area 2050 Draft
Blueprint, the Bay Area’s long-range transportation, housing, economic and
environmental plan.
SB 375 requires that the RHNA is consistent with the Sustainable Communities
Strategy. In other words, consistency between the 2023-2031 RHNA and the Plan
Bay Area 2050 Draft Blueprint (PBA 2050) is statutorily required. Page 13 of
ABAG’s RHNA methodology report concludes that the two documents are
consistent since the 8-year RHNAs do not exceed the 35-year (2015-2050) growth
forecasts for sub-regions in the Bay Area.
This conclusion is flawed on several levels. First, the 35-year forecast period is
more than four times the length of the 8-year RHNA time horizon. It is
unreasonable to conclude that a RHNA can be deemed consistent with the SCS if
it presumes a sub-regional growth rate that is four times higher than the forecast
for that area. It is also unreasonable to presume that a community can condense
and assimilate housing growth that is projected over a 35-year period into a much
shorter period of time.
Second, and more importantly, there is no way to evaluate consistency without
jurisdiction-level forecasts. Consistency at a sub-regional level is meaningless, as
sub-regions do not have the authority to write, adopt, or implement Housing
Elements. This responsibility rests with cities and counties alone. Sub-regions
contain jurisdictions with vastly different populations, employment bases,
geographies, hazard levels, and physical constraints. Lumping dissimilar cities
together as sub-regions in PBA 2050, and then assigning growth at the city-level
through the RHNA process, makes it impossible to determine consistency between
the two processes.
We urge ABAG to publish jurisdiction-level forecasts for PBA 2050 so that
consistency can be accurately and transparently determined. If the 2040 forecasts
are used as a proxy, the RHNA appears grossly inconsistent with the forecasts for
many jurisdictions, including our own.
Page 3
2. The Plan Bay Area 2050 Future Households Baseline promotes suburban sprawl
by allocating a disproportionate number of housing units to the region’s urban
fringes away from the major job centers, furthering the historic pattern of jobs-
housing imbalance.
Figure A. Impact of switching to the 2050 Future Households Baseline from the 2050 Growth Baseline.
Furthermore, this baseline reduces housing assignment in the western and
southern subregions of the Bay Area that has historically under-produced
housing, at the expense of subregions that have historically been the region’s
housing supplier. Under the Draft RHNA, the housing allocation to Santa Clara
County fails to match the explosive jobs growth in that County over the past
decade. This under allocation of new housing to Santa Clara County results in
significantly higher allocations to other counties and fails to adequately address
the significant jobs-housing imbalance in Santa Clara County.
Page 4
Figure B. Job Growth in the Bay Area between 2010 to 2016, as documented by ABAG.
This conflicts with Plan Bay Area 2050 (PBA 2050), which anticipates a 42%
increase in housing growth in Santa Clara while the methodology assigns only
32% of the RHND there. This amounts to over 40,000 units allocated elsewhere in
the region – most problematically, to outer suburbs, small cities, and rural and
unincorporated county areas.
Figure C. Job Growth in the Bay Area between 2010 to 2016, as documented by ABAG
Page 5
3. The proposed RHNA methodology is inconsistent with State mandates to
reduce Vehicle Miles Traveled (VMT) and greenhouse gas (GHG) emissions,
improve air and water quality, preserve agricultural land, and focus
development away from areas with high wildfire risks.
As result of the lack of jobs-housing balance, the Draft RHNA will work against
key regional planning goals and State mandates including those to address VMT
and GHG emissions by perpetuating sprawl and inefficient growth patterns.
The housing distribution under the Draft RHNA conflicts with the requirements
of SB 743, which requires use of the VMT standard when evaluating potential
environmental impacts of a proposed development under CEQA. The Legislative
Intent of SB 743 is to: encourage infill development; improve public health through
active transportation; and reduce GHG emissions. Placing the housing in the
urban fringes of the Bay Area, away from job centers and transportation hubs, will
increase, not reduce, VMT. As a result, review of proposed housing developments
under CEQA will not meet established VMT Thresholds of Significance and will
result in potentially significant environmental impacts that cannot be easily
mitigated.
The Draft RHNA also conflicts with the GHG reduction requirements under AB
32, SB 32, and AB 197. These laws require that the State limit GHG emissions so
that emission levels in 2030 do not exceed 1990 levels. Based on Plan Bay Area’s
housing and job projections, and emphasis on housing-jobs balance and transit-
oriented housing, the plan would still fall short of GHG emission reduction goals.
The Draft RHNA’s departure from prioritizing housing-jobs balance and transit-
oriented housing will lead the region and the State further from achieving these
GHG emission requirements.
This impact is amplified for the Town of Danville as the community is not
projected to add a significant number of new jobs over the next 35 years and
Danville has limited bus service and limited access to mass transit options.
4. The proposed RHNA methodology directs growth to cities and unincorporated
county areas with limited to no develop-able land, restricted open space areas,
land outside of voter-approved urban growth boundaries, areas that lack mass
transit, and natural hazard constraints.
Sampling of
Impacted
Jurisdictions
PBA 2050 Growth
Methodology
(Proposed Altern)
PBA 2050 Future
Households
(HMC Option 8A)
Difference % Change
Santa Clara County
Los Gatos 142 1,430 +1,288 +907%
Page 6
Monte Sereno 3 140 +137 +4,567%
Mountain View 12,377 7,810 -4,567 -37%
Palo Alto 11,127 6,810 -4,317 -39%
San Jose 100,155 67,240 -32,915 -33%
Santa Clara 14,285 9,630 -4,655 -33%
Sunnyvale 12,025 9,980 -2,045 -17%
Alameda County
Albany 355 930 +575 +162%
Piedmont 60 430 +370 +617%
Unincorporated 1,638 5,950 +4,312 +263%
Contra Costa County
Danville 223 1,820 +1,597 +716%
Hercules 411 1,060 +649 +158%
Martinez 311 1,670 +1,359 +437%
Unincorporated 2,588 7,310 +4,722 +182%
Marin County
Fairfax 215 460 +245 +114%
Mill Valley 27 710 +683 +2530%
San Anselmo 202 670 +468 +232%
San Mateo County
Atherton 30 280 +250 +833%
Hillsborough 116 470 +354 +305%
Pacifica 199 1,580 +1,381 +694%
Portola Valley 3 200 +197 +6,567%
Solano County
Benicia 258 1,270 +1,012 +392%
Dixon 209 690 +481 +230%
Rio Vista 84 420 +336 +400%
Suisun City 298 1,070 +772 +259%
Vacaville 1,056 3,650 +2,594 +246%
Vallejo 2,117 5,250 +3,133 +148%
Sonoma County
Sonoma 184 620 +436 +237%
Unincorporated 6,893 9,080 +2,187 +32%
Page 7
5. While the Draft RHNA provides an emphasis on equity and fair housing which
is vitally important, we believe the unintended consequences of the growth
patterns dictated by Option 8A may actually work against equity goals by:
o Requiring people who are unable to work from home to travel long distances
from where they live to where they work.
o Increasing auto reliance those residents who are unable to work from home for
daily commutes by underemphasizing transit access – at a significant
economic, social and environmental cost to those residents.
o Disincentivizing urban re-investment on in-fill lots and brownfields by
prioritizing housing growth away from cities that want and need new housing
to serve their communities and support their local economies.
o Allocating a disproportionate number of housing units to communities that are
largely built out, with little undeveloped or under-developed lands, would
result in the need to re-designate lands for housing which already contain
either viable housing and/or high assessed-value developments.
Page 8
In terms of economics, this makes these lands un-likely to redevelop regardless
of the change in land use designation, especially when multiple properties
would need to be aggregated to create a viable site. Furthermore, assigning
units to physically constrained communities in some instances would require
the removal of existing affordable units (due to their age and/or other
characteristics) in order to accommodate a high housing assignment. In either
scenario, these lands would carry a high land cost and any resulting re-
development would result in housing units that would be far from affordable
without significant subsidies.
Adopting a RHNA that more equitably assigns units to under-developed
urban areas would result in timely re-development addressing the States
critical housing shortage.
Recommended Alternative Baseline and Factors
As previously requested, and similar to the approach advocated by Contra Costa Mayors
Conference and others at the Executive Board’s October public hearing, we would urge
the Executive Board to consider an Alternative to Option 8A, that uses the “Plan Bay Area
2050 Growth” Baseline. We would also seek further refinements to the Factors as follows:
HMC Option 8A Proposed Alternative Methodology
Baseline Plan Bay Area 2050 Households Plan Bay Area 2050 Growth
Factors and Weighting
Very-Low and Low
Income Units
• 60 % Access to High
Opportunity Areas
• 20 % Jobs Proximity – Auto
• 20 % Jobs Proximity - Transit
Moderate and Above
Moderate Income
Units
• 40 % Access to High
Opportunity Areas
• 60 % Jobs Proximity Auto
• 20 % Access to High
Opportunity Areas
• 40 % Jobs Proximity - Auto
• 40 % Jobs Proximity - Transit
Together, these changes would have the following beneficial outcomes for the region,
each of which would improve its consistency with Plan Bay Area:
• Increased share of RHNA to the “Big Three” cities and inner Bay Area, and a
corresponding decrease in that assigned to the outer Bay Area, unincorporated,
and small and rural communities by approximately 30,000 units. This will ensure
Page 9
that that the largest share of housing growth is allocated to the region’s biggest
job centers, in areas well-served by transit and infrastructure.
• Reduced allocation to unincorporated county areas by over 10,500 units –
avoiding further residential growth pressures in areas most subject to natural
hazards, lack of infrastructure capacity, and threatened loss of agricultural and
open space land.
• Alignment of the share of housing growth in Santa Clara County to match
Plan Bay Area 2050 and the County’s significant jobs growth of the past
decade. Santa Clara, home of some of the region’s largest tech firms, has the
largest numeric deficit in housing production to jobs production over the past
decade, which could be corrected in part by this adjustment.
Please do not hesitate to contact me if you have questions or would like to discuss this
letter further.
Sincerely,
TOWN OF DANVILLE
Karen G. Stepper, Mayor
C: Danville Town Council
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______
Construction workers unload roofing tiles at the future Santa Ana Veterans Village,Construction workers unload roofing tiles at the future Santa Ana Veterans Village,
which will provide permanent supportive housing to ex-service members. The citywhich will provide permanent supportive housing to ex-service members. The city
helped developers get financing by committing a stream of revenue from futurehelped developers get financing by committing a stream of revenue from future
“project-based” rent vouchers to the project. Santa Ana is one of just 15 California“project-based” rent vouchers to the project. Santa Ana is one of just 15 California
jurisdictions on track to meet state-mandated housing goals. (Photo by Mindyjurisdictions on track to meet state-mandated housing goals. (Photo by Mindy
Schauer, Orange County Register/SCNG)Schauer, Orange County Register/SCNG)
NEWSNEWSHOUSINGHOUSING
California needs more housing,California needs more housing,
but 97% of cities and countiesbut 97% of cities and counties
are failing to issue enoughare failing to issue enough
RHNA permitsRHNA permits
2018 data shows most California cities got a failing2018 data shows most California cities got a failing
grade in permitting new homes.grade in permitting new homes.
EXHIBIT D
1/25/2021 California needs more housing, but 97% of cities and counties are failing to issue enough RHNA permits – Orange County Reg…
https://www.ocregister.com/2019/12/09/losing-the-rhna-battle-97-of-cities-counties-fail-to-meet-state-housing-goals/2/13
By By JEFF COLLINSJEFF COLLINS | | JeffCollins@scng.comJeffCollins@scng.com and and NIKIE JOHNSONNIKIE JOHNSON | |
nijohnson@scng.comnijohnson@scng.com | Orange County Register | Orange County Register
PUBLISHED: PUBLISHED: December 9, 2019 at 7:40 a.m.December 9, 2019 at 7:40 a.m. | UPDATED: | UPDATED: December 10, 2019 atDecember 10, 2019 at
6:37 p.m.6:37 p.m.
Neighborhood leaders gathered in Long Beach in the spring of 2017 to discussNeighborhood leaders gathered in Long Beach in the spring of 2017 to discuss
a City Hall plan to address the city’s housing shortage. What they learneda City Hall plan to address the city’s housing shortage. What they learned
sparked a revolt.sparked a revolt.
To increase the housing supply and stem skyrocketing residential costs,To increase the housing supply and stem skyrocketing residential costs,
planners proposed multi-story apartment buildings line major streets andplanners proposed multi-story apartment buildings line major streets and
boulevards throughout the city, including its affluent, mainly suburban eastboulevards throughout the city, including its affluent, mainly suburban east
side.side.
To the planners, it was an equitable solution to the housing crisis. ToTo the planners, it was an equitable solution to the housing crisis. To
neighborhood associations, it was armageddon.neighborhood associations, it was armageddon.
“There was a passionate, angry plea … demanding the city halt the plans for“There was a passionate, angry plea … demanding the city halt the plans for
ruining neighborhoods,” said activist Corliss Lee. “With increased buildingruining neighborhoods,” said activist Corliss Lee. “With increased building
heights comes lots of people and cars.”heights comes lots of people and cars.”
In the ensuing outcry, residents mobbed town hall meetings and ultimatelyIn the ensuing outcry, residents mobbed town hall meetings and ultimately
forced the city to compromise, concentrating new housing mostly inforced the city to compromise, concentrating new housing mostly in
downtown Long Beach.downtown Long Beach.
The Long Beach revolt may be symptomatic of California’s losing battle withThe Long Beach revolt may be symptomatic of California’s losing battle with
an ever-worsening housing crisis, some housing officials say.an ever-worsening housing crisis, some housing officials say.
California needs between 1.8 million and 3.5 million new homes by 2025,California needs between 1.8 million and 3.5 million new homes by 2025,
state and private reports say. To get there, cities and counties would havestate and private reports say. To get there, cities and counties would have
to approve two to four times the number of homes they’ve been permitting into approve two to four times the number of homes they’ve been permitting in
the past few years.the past few years.
But instead of approving more homes, almost every California city and countyBut instead of approving more homes, almost every California city and county
is falling behind its state-mandated housing goals, a is falling behind its state-mandated housing goals, a Southern California NewsSouthern California News
Group analysis of state dataGroup analysis of state data shows. shows.
Most cities and counties comply with a state law requiring them to plan andMost cities and counties comply with a state law requiring them to plan and
zone for housing at all income levels. But fewer than 3% — just 15zone for housing at all income levels. But fewer than 3% — just 15
jurisdictions — were on track to actually build those homes by the end ofjurisdictions — were on track to actually build those homes by the end of
2018.2018.
1/25/2021 California needs more housing, but 97% of cities and counties are failing to issue enough RHNA permits – Orange County Reg…
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Among SCNG’s findings:Among SCNG’s findings:
97% of all cities and counties were behind in permitting new housing97% of all cities and counties were behind in permitting new housing
sought under the sought under the Regional Housing Needs AssessmentRegional Housing Needs Assessment process, or RHNA process, or RHNA
(pronounced “reena”).(pronounced “reena”).
Almost two-thirds of local governments are less than 50% on track.Almost two-thirds of local governments are less than 50% on track.
Almost half are behind in all four homebuilding categories: very-low-Almost half are behind in all four homebuilding categories: very-low-
income, low-income, moderate-income and above-moderate-income.income, low-income, moderate-income and above-moderate-income.
The problem is worse for low-income housing: Just 22% of the state’sThe problem is worse for low-income housing: Just 22% of the state’s
jurisdictions are on track for permitting low-income housing, while 45% are onjurisdictions are on track for permitting low-income housing, while 45% are on
track for upper-income housing.track for upper-income housing.
And the inability to stay on track will be even more acute for SouthernAnd the inability to stay on track will be even more acute for Southern
California in the decade ahead California in the decade ahead when the region’s target is expected to triplewhen the region’s target is expected to triple..
A scorecard created by SCNG showed that just one-sixth of California citiesA scorecard created by SCNG showed that just one-sixth of California cities
and counties earned an A or a B based on building permit numbers. Moreand counties earned an A or a B based on building permit numbers. More
than half earned a D or an F.than half earned a D or an F.
“The numbers accentuate why California is in our worst housing crisis in state“The numbers accentuate why California is in our worst housing crisis in state
history,” said David Chiu, chair of the state Assembly Housing and Communityhistory,” said David Chiu, chair of the state Assembly Housing and Community
Development Committee. “We’re not building enough homes, pure andDevelopment Committee. “We’re not building enough homes, pure and
simple.”simple.”
California “is all talk and virtually no action,” added John Burns, an Irvine-California “is all talk and virtually no action,” added John Burns, an Irvine-
based homebuilding consultant.based homebuilding consultant.
“Most cities and counties celebrate economic growth, yet don’t permit enough“Most cities and counties celebrate economic growth, yet don’t permit enough
housing to accommodate the additional workforce, resulting in high homehousing to accommodate the additional workforce, resulting in high home
prices, high rents and worsening traffic,” Burns said. “Anti-growth stancesprices, high rents and worsening traffic,” Burns said. “Anti-growth stances
seem to be the key to getting reelected in many cities.”seem to be the key to getting reelected in many cities.”
City and county officials around the state lamented that while they see theCity and county officials around the state lamented that while they see the
need for more housing, their RHNA targets are unrealistic given the risingneed for more housing, their RHNA targets are unrealistic given the rising
costs of construction, a labor shortage, aging infrastructure and neighborhoodcosts of construction, a labor shortage, aging infrastructure and neighborhood
resistance to change.resistance to change.
RHNA is “the worst four-letter word you’ve never heard of,” said aRHNA is “the worst four-letter word you’ve never heard of,” said a
commentary by Laguna Niguel Mayor John Mark Jennings, who dislikes thecommentary by Laguna Niguel Mayor John Mark Jennings, who dislikes the
process even though his city got an A- in the SCNG scorecard after permittingprocess even though his city got an A- in the SCNG scorecard after permitting
eight times its RHNA target.eight times its RHNA target.
The need for more housing “is not in question,” Jennings wrote.The need for more housing “is not in question,” Jennings wrote.
1/25/2021 California needs more housing, but 97% of cities and counties are failing to issue enough RHNA permits – Orange County Reg…
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But “this one-size-fits-all, oversimplified, top-down approach creates a host ofBut “this one-size-fits-all, oversimplified, top-down approach creates a host of
problems that cities are left to address,” he wrote. “Never mind allowing localproblems that cities are left to address,” he wrote. “Never mind allowing local
residents and business owners to decide what is right for their communities.residents and business owners to decide what is right for their communities.
And never mind that a city is built out leaving no space for the mandatedAnd never mind that a city is built out leaving no space for the mandated
units.”units.”
The consequences of not meeting state housing goals, however, “are dire,”The consequences of not meeting state housing goals, however, “are dire,”
Chiu warned.Chiu warned.
“We will lose our workforce and our competitiveness. Hundreds of thousands“We will lose our workforce and our competitiveness. Hundreds of thousands
of families will be pushed out on the streets and into homelessness,” Chiuof families will be pushed out on the streets and into homelessness,” Chiu
said. “… When you have a huge percentage of our state paying an enormoussaid. “… When you have a huge percentage of our state paying an enormous
portion of their monthly income on housing, it makes it harder for everydayportion of their monthly income on housing, it makes it harder for everyday
Californians to put food on the table, afford health care (or) pay forCalifornians to put food on the table, afford health care (or) pay for
educational expenses.”educational expenses.”
1/25/2021 California needs more housing, but 97% of cities and counties are failing to issue enough RHNA permits – Orange County Reg…
https://www.ocregister.com/2019/12/09/losing-the-rhna-battle-97-of-cities-counties-fail-to-meet-state-housing-goals/5/13
1/25/2021 California needs more housing, but 97% of cities and counties are failing to issue enough RHNA permits – Orange County Reg…
https://www.ocregister.com/2019/12/09/losing-the-rhna-battle-97-of-cities-counties-fail-to-meet-state-housing-goals/6/13
1/25/2021 California needs more housing, but 97% of cities and counties are failing to issue enough RHNA permits – Orange County Reg…
https://www.ocregister.com/2019/12/09/losing-the-rhna-battle-97-of-cities-counties-fail-to-meet-state-housing-goals/7/13
Mostly voluntaryMostly voluntary
Until recently, RHNA goals have been mostly voluntary, and few municipalitiesUntil recently, RHNA goals have been mostly voluntary, and few municipalities
met their targets to actually build housing.met their targets to actually build housing.
Although state leaders have enacted several measures designed to “put teeth”Although state leaders have enacted several measures designed to “put teeth”
in RHNA, few sanctions exist for cities and counties failing to meet actualin RHNA, few sanctions exist for cities and counties failing to meet actual
construction goals.construction goals.
Senate Bill 35Senate Bill 35 forces communities failing to meet RHNA construction goals to forces communities failing to meet RHNA construction goals to
automatically green-light residential projects meeting zoning and planningautomatically green-light residential projects meeting zoning and planning
rules and other standards. But so far, rules and other standards. But so far, just 44 projects around the state havejust 44 projects around the state have
sought approval under SB 35sought approval under SB 35, mainly for affordable housing, according to data, mainly for affordable housing, according to data
compiled by the Bay Area News Group.compiled by the Bay Area News Group.
Other laws opened cities up to lawsuits if their plans fail to include enoughOther laws opened cities up to lawsuits if their plans fail to include enough
housing or if they fail to approve developments that comply with their land-housing or if they fail to approve developments that comply with their land-
use policies. So far, use policies. So far, Huntington Beach remains the only city sued by the stateHuntington Beach remains the only city sued by the state
under those laws.under those laws.
In January, Gov. Gavin Newsom threatened to withhold transportation fundingIn January, Gov. Gavin Newsom threatened to withhold transportation funding
from local governments that failed “to make progress toward requiredfrom local governments that failed “to make progress toward required
production goals.” But in June, Newsom production goals.” But in June, Newsom backed down during budgetbacked down during budget
negotiationsnegotiations from imposing financial consequences on localities that fail to from imposing financial consequences on localities that fail to
build enough housing.build enough housing.
Under the RHNA process, the state housing department determines howUnder the RHNA process, the state housing department determines how
many homes each region must plan for over a five- to eight-year period. Thenmany homes each region must plan for over a five- to eight-year period. Then
regional planning agencies like the regional planning agencies like the Southern California Association ofSouthern California Association of
GovernmentsGovernments or the or the Association of Bay Area GovernmentsAssociation of Bay Area Governments divvy up the divvy up the
numbers among local cities and counties.numbers among local cities and counties.
For the scorecard, SCNG looked at how far each jurisdiction is into its RHNAFor the scorecard, SCNG looked at how far each jurisdiction is into its RHNA
cycle and compared how many building permits it has issued with the numbercycle and compared how many building permits it has issued with the number
it should have issued by now to be on track.it should have issued by now to be on track.
Asked to explain their housing performance, all 25 of the jurisdictions reachedAsked to explain their housing performance, all 25 of the jurisdictions reached
by SCNG — even those that had earned a D or an F — said they’re pro-by SCNG — even those that had earned a D or an F — said they’re pro-
housing and understand the need for stepped-up homebuilding.housing and understand the need for stepped-up homebuilding.
But many argued they’re only responsible for “setting the table” forBut many argued they’re only responsible for “setting the table” for
development under RHNA. They must adopt land-use plans and ensuredevelopment under RHNA. They must adopt land-use plans and ensure
there’s sufficient zoning for new housing, but aren’t responsible if the homesthere’s sufficient zoning for new housing, but aren’t responsible if the homes
don’t get built.don’t get built.
1/25/2021 California needs more housing, but 97% of cities and counties are failing to issue enough RHNA permits – Orange County Reg…
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Finding solutionsFinding solutions
“State law does not require cities to achieve their RHNA goals because cities“State law does not require cities to achieve their RHNA goals because cities
only control one aspect of the development process — plans andonly control one aspect of the development process — plans and
development regulations,” said Brian Saeki, city manager for the San Gabrieldevelopment regulations,” said Brian Saeki, city manager for the San Gabriel
Valley town of Covina, which received an F in the SCNG scorecard for failing toValley town of Covina, which received an F in the SCNG scorecard for failing to
report the 80 building permits it issued since 2014.report the 80 building permits it issued since 2014.
“We’re at the mercy of the market,” added Albert Lopez, planning director of“We’re at the mercy of the market,” added Albert Lopez, planning director of
the Bay Area’s Alameda County, which received a C- after permitting aboutthe Bay Area’s Alameda County, which received a C- after permitting about
half of the homes needed to be on track. “If the builders want to come in, wehalf of the homes needed to be on track. “If the builders want to come in, we
will accommodate them.”will accommodate them.”
Scott Wiener, chairman of the state Senate Housing Committee, called thoseScott Wiener, chairman of the state Senate Housing Committee, called those
answers “an excuse.”answers “an excuse.”
“We hear this all the time,” Wiener said. “Cities don’t build housing. It’s all the“We hear this all the time,” Wiener said. “Cities don’t build housing. It’s all the
developers’ fault.”developers’ fault.”
While most cities do “set the table” by adopting land-use plans, they alsoWhile most cities do “set the table” by adopting land-use plans, they also
adopt restrictive regulations and high “impact” fees that keep housing out,adopt restrictive regulations and high “impact” fees that keep housing out,
Wiener said.Wiener said.
“There are far too many cities in California that make it extremely difficult or“There are far too many cities in California that make it extremely difficult or
even impossible to build new housing,” he said. “Cities that have veryeven impossible to build new housing,” he said. “Cities that have very
restrictive zoning. Cities that put you through a multi-year approval process,restrictive zoning. Cities that put you through a multi-year approval process,
even for a small project. Cities that will zone for, say, 20 units, but then forceeven for a small project. Cities that will zone for, say, 20 units, but then force
you down to five units. … The list goes on.”you down to five units. … The list goes on.”
Communities that are on track don’t agree cities should merely “set the table.”Communities that are on track don’t agree cities should merely “set the table.”
“Cities can modify how the table is set,” said Peter Noonan, rent stabilization“Cities can modify how the table is set,” said Peter Noonan, rent stabilization
and housing manager for West Hollywood, which got an A after issuing 20and housing manager for West Hollywood, which got an A after issuing 20
times the 77 building permits it’s required to provide. “RHNA is the minimum,times the 77 building permits it’s required to provide. “RHNA is the minimum,
not the maximum.”not the maximum.”
Cities can change standards such as parking requirements and height limits,Cities can change standards such as parking requirements and height limits,
and they can set density minimums to spur development, Noonan said.and they can set density minimums to spur development, Noonan said.
Successful cities and counties have “inclusionary zoning” laws, create housingSuccessful cities and counties have “inclusionary zoning” laws, create housing
trust funds, lower development fees and, in some cases, buy the land or buildtrust funds, lower development fees and, in some cases, buy the land or build
infrastructure to spur affordable homebuilding.infrastructure to spur affordable homebuilding.
1/25/2021 California needs more housing, but 97% of cities and counties are failing to issue enough RHNA permits – Orange County Reg…
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ObstaclesObstacles
West Hollywood passed an “inclusionary zoning” ordinance in 1986 —West Hollywood passed an “inclusionary zoning” ordinance in 1986 —
requiring developers to either include affordable units in their projects or payrequiring developers to either include affordable units in their projects or pay
a fee into an affordable housing fund. It also created a nonprofit housinga fee into an affordable housing fund. It also created a nonprofit housing
provider, the West Hollywood Community Housing Corp., which partners withprovider, the West Hollywood Community Housing Corp., which partners with
the city in low-income housing development.the city in low-income housing development.
San Bernardino County, which permitted 45 times its RHNA target, bought aSan Bernardino County, which permitted 45 times its RHNA target, bought a
15-acre tract in the unincorporated community of Bloomington to build 15-acre tract in the unincorporated community of Bloomington to build anan
almost 300-unit affordable housing developmentalmost 300-unit affordable housing development..
The county then found funding to replace the area’s septic systems withThe county then found funding to replace the area’s septic systems with
sewers and storm drains. The development, which has been opening insewers and storm drains. The development, which has been opening in
phases since 2016, included a new library and a pool.phases since 2016, included a new library and a pool.
“Communities can be less than enthusiastic about a new affordable housing“Communities can be less than enthusiastic about a new affordable housing
project in their neighborhood,” said David Wert, San Bernardino Countyproject in their neighborhood,” said David Wert, San Bernardino County
spokesman. But when projects look high-end, include a new library and bringspokesman. But when projects look high-end, include a new library and bring
needed infrastructure to an area, “it becomes an asset.”needed infrastructure to an area, “it becomes an asset.”
The development’s existence “meant a world of difference” to Jennifer Gibson,The development’s existence “meant a world of difference” to Jennifer Gibson,
43, who moved to Bloomington Grove about two years ago after becoming43, who moved to Bloomington Grove about two years ago after becoming
disabled. “We have higher rent in California than a lot of other states have, sodisabled. “We have higher rent in California than a lot of other states have, so
it’s extremely important for there to be some type of affordable housing. It’sit’s extremely important for there to be some type of affordable housing. It’s
families that are working hard — just a normal, average family trying to makefamilies that are working hard — just a normal, average family trying to make
a living and survive.”a living and survive.”
If she and her children, now 18 and 22, hadn’t been able to move intoIf she and her children, now 18 and 22, hadn’t been able to move into
Bloomington Grove, Gibson said, they would probably have to live withBloomington Grove, Gibson said, they would probably have to live with
relatives. Without sufficient affordable housing options, “there would be a lotrelatives. Without sufficient affordable housing options, “there would be a lot
more homeless people, a lot more people in shelters, a lot more people notmore homeless people, a lot more people in shelters, a lot more people not
able to be independent,” she said.able to be independent,” she said.
But cities and counties say they face a host of obstacles to getting homes built.But cities and counties say they face a host of obstacles to getting homes built.
Chief among them is steady push-back from so-called “NIMBYs,” or localChief among them is steady push-back from so-called “NIMBYs,” or local
residents resistant to change.residents resistant to change.
Cities and counties also cite the high cost of land, construction and financing.Cities and counties also cite the high cost of land, construction and financing.
1/25/2021 California needs more housing, but 97% of cities and counties are failing to issue enough RHNA permits – Orange County Reg…
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“There’s a labor shortage that brings the price up. The cost of materials …“There’s a labor shortage that brings the price up. The cost of materials …
(also) is very high,” said Matt Hertel, senior planner for the city of Sacramento,(also) is very high,” said Matt Hertel, senior planner for the city of Sacramento,
which got a C in the SCNG scorecard after issuing just over half the 15,000which got a C in the SCNG scorecard after issuing just over half the 15,000
permits it needed to be on track. “The infrastructure is aging and doesn’t havepermits it needed to be on track. “The infrastructure is aging and doesn’t have
the capacity for added development.”the capacity for added development.”
Even though California allocated billions of dollars for affordable housing inEven though California allocated billions of dollars for affordable housing in
the past year, local officials say they’ve been stymied by the 2011 decision tothe past year, local officials say they’ve been stymied by the 2011 decision to
shut down redevelopment agencies, wiping out about $1 billion a year in low-shut down redevelopment agencies, wiping out about $1 billion a year in low-
income housing funding.income housing funding.
Outdated planning documents, environmental concerns and a lack of land forOutdated planning documents, environmental concerns and a lack of land for
new housing likewise complicate development.new housing likewise complicate development.
“Torrance is a largely built-out city,” said long-range planning manager Gregg“Torrance is a largely built-out city,” said long-range planning manager Gregg
Lodan, whose city got an F in the RHNA scorecard after falling behind in allLodan, whose city got an F in the RHNA scorecard after falling behind in all
four housing categories.four housing categories.
Some cities also disputed whether the RHNA numbers were allocated fairly.Some cities also disputed whether the RHNA numbers were allocated fairly.
UCLA urban planning Professor Paavo Monkkonen agreed, arguing in a recentUCLA urban planning Professor Paavo Monkkonen agreed, arguing in a recent
“issue brief” on RHNA the process bases numbers more on politics than need.“issue brief” on RHNA the process bases numbers more on politics than need.
“That’s why Beverly Hills … was famously determined to ‘need’ only three new“That’s why Beverly Hills … was famously determined to ‘need’ only three new
units of income-restricted housing between 2013 and 2021, while otherunits of income-restricted housing between 2013 and 2021, while other
similarly sized cities and much more affordable cities were determined tosimilarly sized cities and much more affordable cities were determined to
‘need’ hundreds of units,” Monkkonen’s brief says.‘need’ hundreds of units,” Monkkonen’s brief says.
RHNA, Monkkonen said, “creates unrealistic production goals.”RHNA, Monkkonen said, “creates unrealistic production goals.”
In Long Beach, residents who helped stop the spread of high-densityIn Long Beach, residents who helped stop the spread of high-density
development last year say they’re feeling the pressure from Sacramento, anddevelopment last year say they’re feeling the pressure from Sacramento, and
worry about its impact on their neighborhoods.worry about its impact on their neighborhoods.
“Not all cities are the same,” said Joan Greenwood, president of Long Beach’s“Not all cities are the same,” said Joan Greenwood, president of Long Beach’s
Wrigley Neighborhood Alliance. “I don’t think it makes sense to put all thisWrigley Neighborhood Alliance. “I don’t think it makes sense to put all this
density in an area where they can’t accommodate it with schools and parks.”density in an area where they can’t accommodate it with schools and parks.”
“Local control of zoning is one of the most important issues of freedom there“Local control of zoning is one of the most important issues of freedom there
is,” added Robert Fox, executive director of Long Beach’s Council ofis,” added Robert Fox, executive director of Long Beach’s Council of
Neighborhood Organizations and a candidate for the City Council’s 2ndNeighborhood Organizations and a candidate for the City Council’s 2nd
District seat. “American democracy is local control.”District seat. “American democracy is local control.”