HomeMy WebLinkAboutStaff Report 389-07TO:
City of Palo Alto
City Manager’s Report
1
HONOIL~BLE CITY COUNCIL
FROM:CITY M~AGER DEPA~RTMENT: PLANNING ~D
COMMUNITY ENVIRONMENT
DATE:OCTOBER 15, 2007 CMR: 389:07
SUBJECT:STUDY SESSION REGARDING ABAG REGIONAL HOUSING NEEDS
ALLOCATION FOR PALO .A~LTO AND HOUSING ELEMENT
REQUIREMENT.
This is an informational report and no Council action is required.
BACKGROUND
Periodically (usually every seven years), the state requires all jurisdictions in the state to update
their General Plan (Comprehensive Plan) Housing Elements. Within its Housing Element, each
jurisdiction must plan for its share of the region’s housing need for residents of all income
categories. The amomat of housing cities and counties must plan for is determined by state
housing policy. The ReNonal Housing Needs Allocation (RHNA) is each j urisdiction’s assi~ed
share of the region’s total housing need based on a methodo!ogy developed by individual
Councils of Govermnent.
The State Department of Housing and Community Development (HCD) determined that the Bay
Area needs to plan for 214,500 housing units during the 2007 - 2014 planning period. HCD also
determined how many of these units are needed across four income categories: very tow, low,
moderate, and above moderate. With this assigmnent of the overall re~onal need by the state, the
Association of Bay Area Governments (ABAG) was responsible for allocating the total regional
need to all jurisdictions in the Bay Area as mandated by state law. The RHNA methodology
developed by ABAG, working with a Housing Methodology Committee (comprised of members
representing the entire ABAG re,on) was approved by the ABAG Board in January, 2007. It
used the following factors and weights to develop the allocation:
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Household gowth (45%)
Existing employment (22.5%)
Employment gowth (22.5%)
Household ~owth near existing transit (5%)
Employment gowth near existing transit (5%)
Household ~owth, existing employment and employment gowth assumptions were derived
from ABAG’s regional household and employment forecasts, _Projections 2007.
CMR:389:07 Page 1 of 3
On September 26, 2007, City staff met with the Plalming Commission to discuss the ABAG
numbers, allocation methodology and Housing Element process.
DISCUSSION
On July 19, 2007, ABAG’s Executive Board adopted the draft RHNA allocations for
jurisdictions in the San Francisco Bay Aa’ea by income category for the 2007 - 2014 RHNA
cycle. Palo Alto’s currem total draft allocation is 3,505 units, including 846 very low, 666 low,
786 moderate, and 1,207 above moderate income units. Jurisdictions had until September 18,
2007, to request revisions to their allocations.
Palo Alto sent the attached letter (Attactmaent A) to ABAG on September 13, 2007, requesting
adjustments to the City’s assigned allocation based on several factors. The City requested that
the allocation should be based on projected gowth within Palo Alto’s jurisdictional boundary
not its sphere of influence, since the City does not have land use control over unincorporated
properties within Santa Clara County. Staff has met with ABAG, County and HCD staff to
discuss this possible adjustment. ABAG staff has indicated wi!lin~aess to support a reduction of
645 units to Pato Alto’s allocation and reassign those units to the County based on projected
~’owth on the Stanford campus.
The City also contested the population forecasts for Palo Alto in Projections 2007. Given Palo
Alto’s limited remaining vacant land and the City’s historic growth rates, the Projections 2007
~oxvth rate of 26.6% by 2035 is unrealistic. The City also objected to the allocation
methodology that penalizes jurisdictions that have implemented smart ~’owth policies by
assigNng additional ~owth to transit-oriented areas where increased ~owth has already been
factored in long range plans.
A_BAG staff has 60 days to respond to the City’s requests for revisions. After receiving ABAG’s
response, the City will have an additional 60 days to further appeal the RHNA numbers. In early
2008, ABAG will hold a public hearing on any appeals regarding the assigned allocations.
Based on state requirements, the final RHNA will need to be adopted by ABAG’s Executive
Board prior to June 2008
Also attached is the publication A Place to Call Home (Attactmaent B), prepared by ABAG, that
provides an overview of the Bay Area housing situation and on pages 8-t2 summarizes the
RHNA process and methodology for the 2007-2014 RHNA cycle. This publication also
provides on pages 35 - 39 an overview of the performance of each city in the Bay Area in
meeting its allocation for the 1999 - 2006 RHNA cycle. This should provide the Council with
back~ound information that should be helpful in th dy on discussion.
PREPARED BY:~ ~p
Chief Plam~in~ an~ortation Official
CMR:389:07 Page 2 of 3
DEP:~RTMENT HEAD:
CITY Mz~NAGER APPROVAL:
ATTACHMENTS
Director and Community Enviromnent
A i 1~C~’1--ss-~a" ’ "ty Manager -
Attachment A
Attachment B
Letter to ABAG dated September 13, 2007
A Place to Call I-Iome, ABAG, 2007 (for Council members only)
CIvIR:389:07 Page 3 of 3
ATTACHMENT A
Department of Planning and
Community Environment
September 13, 2007
ABAG Executive Board
c/o Henry Gardner, Secretary - Treasurer
Association of Bay Area Governments
P.O. Box 2050
Oakland, CA 94604-2050
Dear Mr. Gardner:
Thank you for providing us with the opportunity to review and comment on the Draft Regignal
Housing Needs Allocation (RHNA), which was adopted by the ABAG Executive Board on July
19, 2007. The City of Palo Alto (City) supports the main concepts behind the draft allocation
method such as smart gowth, infill development, protection of open space and rural areas,
restricting urban sprawl, and transit oriented development. The City also appreciates ABAG
staff’s recent recommendation to modify Palo Alto’s RHNA to address the City’s unique Sphere
of Influence circumstance with the County of Santa Clara and Stanford University which is
outside the City boundaries but within its Sphere of Influence. ABAG staff’s recognition that the
City of Palo Alto does not have "land- use permitting" authority outside its boundaries and the
resultant determination that 645 dwelling units are outside the City’s boundaries and should be
assigned to the County is very much appreciated. The City, therefore, request that ABAG adjust
the City of Palo Alto’s Regional Housing Needs Allocation to 2,860 units and transfer the
remaining 645 units to the County of Santa Clara.
The City would also like to comment on circumstances specific to Palo Alto we believe should
be taken into consideration both in the Projections 2007 figures and in the allocation
methodology.
Comments on Projections 2007
As you know, the Projections 2007 forecast was critical in determining the RHNA for individual
jurisdictions. City staff has discussed with your staff on several occasions constraints on future
housing production within Palo Alto. As we have stated in various email correspondence and on
response to ABAG’s Survey of RHNA Data, we believe that the population and household
projections for the City of Palo Alto are not achievable. Projections 2007 assumes a growth rate
of 26.6 % by 2035 in our sphere of influence while historical Census data shows the City of Palo
Alto’s population has only grown by approximately 4.7% over the last 30 years. Although in the
last 7 years, Palo Alto has experienced significant new housing development resulting in
approximately an 8% increase in population, this is still far below ABAG’s projections and this
growth cannot be sustained given Palo Alto’s limited land availability and redevelopment
potential.
Printed with soy-based inks on 100% rec~-cled paper processed without chlorine
250 Hamilton Avenue
P.O. Box 10250
Palo Alto, CA 94303
650.329.2441
650.329.2154
Mr. Henry Gardner
Association of Bay Area Government
Page 2 of 3
During the last RI-LNA period, the City made significant efforts to identify lands that could
convert to housing and to encourage that conversion, Palo Alto approved approximately 2,550
units including a single project that added about 1,000 units on one of the City’s last
undeveloped lands. In a memo to the A_BAG Executive Board from Paul Fassinger dated last
November, Mr. Fassinger explained the household, population, and employment revisions to the
Projections 2007 and why ABAG chose to revise the projections for several jurisdictions.
ABAG staff revised and lowered ABAG Projections 2007 household and population projection
for the City of San Leandro because they "pointed to the fact that its recent success in developing
housing could not be sustained..." Similar to the City of San Leandro, it would also be very
difficult for Palo Alto to continue the housing development Palo Alto has experienced in the last
7 years given Palo Alto’s very limited land available for new development.
ABAG’s revised technical document states that;
"Household growth in ABAG’s Projections is most influenced by local land use plans and
policies, including planned and protected agricultural lands, open space and parks, city centered
growth policies, urban growth boundaries, and any physical or geological constraints."
Yet Projections 2007 does not reflect the City’s Comprehensive Plan anticipated population
growth or recognize that Palo Alto has approximately 65 percent of its 26 square mile land area
dedicated to protected open space, parks and preserves and the City’s boundaries are fixed on all
sides by neighboring cities, hence, no "new" lands are available. Atherton’s household and
population projection were also revised and lowered in Projections 2007 because ABAG staff
agreed that "Atherton has no capacity to expand beyond it’s existing town limits. The town has
almost no vacant lots." Palo Alto also does not have any capacity to expand beyond its existing
jurisdictional boundary and has less than 0.5 percent vacant land, yet the City’s population and
household projections in Projections 2007 remain unrevised.
Comments on Allocation Methodology
The City opposes the inclusion of an additional Transit Oriented Development (TOD) factor in
the allocation methodology to the extent that it would disproportionately assign housing to cities
like Palo Alto that have shown a commitment to TOD. Palo Alto recently adopted the California
Avenue Pedestrian and Transit Oriented Development Combining District, which is intended to
allow higher density residential dwellings within a walkable distance of the California Avenue
Caltrain Station. ABAG staff revised and lowered the City of Larkspur’s population and
household projections for Projections 2007 because "The city implemented smart growth
concepts when the ferry terminal was developed and the density in that area is much higher than
the remainder of the city." Palo Alto’s circumstances are very similar. Over half of all
residential approvals and construction in the City of Palo Alto (approximately 1400 dwelling
units) within the last 5 years are within a mile of either the University Avenue or California
Mr. Henry Gardner
Association of Bay Area Governments
Page 3 of 3
Avenue train station. A majority of the remaining residential entitlements or construction is
along E1 Camino Real, which is served by major bus routes. The remainder of the City, which
consist mainly of developed and established single-family neighborhoods or approximately
16,000 detached single-family homes, cannot support the higher densities. Nonetheless, the City
of Palo Alto’s population and household projections were not revised for Projections 2007.
Furthermore, we understand that the draft Projections 2007 already takes into account likely
development along transit lines through its underlying assumptions and imposing an additional
TOD factor penalizes cities that have developed smart growth policies.
The City would also appreci.ate a detailed explanation on how the methodology addresses
household and employment growth near transit if the fixed transit station is at or very near its
jurisdictional boundary. In the case of Palo Alto, a Caltrain station is located at the Mountain
ViewiPalo Alto jurisdictional boundary. The revised .technical document does not clearly
explain how the methodology reapportions the 5% household and employment growth within a
half mile radius of the transit station if the half mile radius crosses jurisdictional boundaries.
In conclusion, the City urges ABAG to consider factors such as adequate open space provision,
lack of land availability and suitable sites, and sufficient service provision and availability in
developing a realistic RHNA. If ABAG adopts more achievable goals, this will enable all cities,
including Palo Alto, to focus on the provision of adequate housing for a diverse population.
The City of Palo Alto appreciates your consideration of our requests.
Sincerely,
Director of Planning and Community Development
cc: Paul Fassinger, ABAG Research Director
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