HomeMy WebLinkAboutAttachment-A_RHNA-Allocation-Response-Letter-SEPT-10-REDLINEPage 1 of 3
September 511, 2012
Mr. Mark Luce, President
Association of Bay Area Government
Joseph P. Bort Metro Center
P.O. Box 2050
Oakland, CA 94607-4756
Re: City of Palo Alto Response Request for Revision to Adopted RHNA Methodology for the
2014-2022 Housing Cycle
Dear Mr. Luce:
Thank you for ABAG’s July 25, 2012 memo to Bay area cities and counties, which provided an
overview of the adopted Regional Housing Needs Assessment (RHNA) methodology and
jurisdictional allocations for the 2014-2022 housing cycle. The While the adopted allocations
appear to have taken into consideration many some of the concerns and comments expressed
by member jurisdictions. , the target projections are still unrealistic. The target projections will
be difficult to attain in In Palo Alto, however, given the built-out nature of the city and multiple
school, service and infrastructure constraints and impacts make these projections unattainable.
Therefore, the purpose of this letter is to request a revision to the draft allocation, to reduce
the total number of units assigned to the City of Palo Alto. In support of this request, the
following reiterates the City of Palo Alto’s ongoing concerns regarding the long-term
Sustainable Communities Strategy (SCS) projections and the potential impact on future RHNA
cycles. Furthermore, this letter provides information about our ongoing effort to facilitate a
joint agreement for transfer of units to the County of Santa Clara for housing on Stanford lands.
In summary, the City of Palo Alto’s comments are as follows:
1. Although adjustments were made for this housing cycle, the The regional forecast of
jobs and housing for the region continues to substantially overstate growth for the
overall SCS period (through 2040) and continues to ignore the updated demographic
forecasts of the State’s Department of Finance (DOF). This not only creates an
unrealistic scenario for the upcoming cycle, but also creates the effect of “back-loading”
the housing numbers and potentially creating unreasonable and unachievable housing
mandates in the current and future housing cycles. Although the SCS process does allow
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for adjustment of long-term growth projections on a periodic basis, the City encourages
ABAG to regain public confidence of its numbers by working with HCD to reduce the
2010-2040 projections by 41% to reflect the adaptations already made by the
Department of Finance to the changing State of California demographics. Furthermore,
current and future projections should be adjusted so they are more consistent with
historical growth patterns and/or a range of projections should be adopted that reflect
meaningful planning scenarios in response to market changes over time. An analysis of
the inadequacy of the current long-range projections, authored by Palo Alto
Councilmember Greg Schmid, was submitted to ABAG during the Alternative Scenario
selection process and is attached to this letter. Tables outlining the discrepancies
between the most recent DOF projections and those prepared by ABAG for the SCS are
also attached.
2. The proposed RHNA allocation assigns 77 housing units to the County of Santa Clara
(unincorporated), although Stanford University’s General Use Permit with the County of
Santa Clara County allows and plans for up to 1,500 residential units to be built on
Stanford lands within the SCS timeframe. The City acknowledges that these units have
not been otherwise assigned to the City of Palo Alto, but at least some of them are
proximate to El Camino Real and the University Avenue Caltrain station, and would be
consistent with the objectives of the SCS and SB375. Specifically, approximately 350
planned units on two sites on Quarry Road just west of El Camino Real appear
appropriate to include somewhere in the housing analysis. City staff has met with staff
from the County and Stanford to discuss the possibility of a joint agreement to a
“transfer” of a similar allocation of units from the City of Palo Alto to the County of
Santa Clara. This is an ongoing effort, and we will keep ABAG apprised of our progress.
The City requests that ABAG remain open to such a transfer if an agreement between
the City, the County and Stanford is reached.
3. As stated in previous letters, the City of Palo Alto is a national leader in policies and
programs that reduce GHG emissions. Examples of key City sustainability programs
include an aggressive Climate Action Plan, the provision of clean energy to Palo Alto
customers via the City owned and operated electric utility, various utility programs to
reduce emissions, leadership in Green Building and sustainable design, affordable
housing programs, higher density land uses near transit, and numerous “complete
streets” oriented policies and projects. An attached letter, sent to ABAG on March 5,
2012, provides additional detail on these programs. The City encourages ABAG to allow
flexibility within the SCS for local jurisdictions to provide further means, such as those
outlined in the letter, of reducing land use/transportation related emissions.
4. The City of Palo Alto continues to have concerns regarding the potential negative
environmental, school capacity and infrastructure capacity (recreational, utilities,
transit, etc.) impacts the overstated housing mandates may create. The City will, of
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course, be conducting an environmental review to fully assess the impacts of these
mandates during the preparation of our Housing Element for this planning period.
Thank you once Once again, thank you for the opportunity to comment on the adopted RHNA
methodology for the 2014-2022 Housing Cycle. As stated earlier, the City is officially requesting
a reduction in the proposed allocation for the reasons stated above. If you have questions or
need additional information, please contact Curtis Williams, the City’s Director or Planning and
Community Environment, at (650) 329-2321 or curtis.williams@cityofpaloalto.org.
Sincerely,
Yiaway Yeh
Mayor
Attachments:
1. March 5, 2012 Letter from Mayor Yeh to Mark Luce (ABAG), including two attachments:
a) November 15, 2011 Memorandum: “California Demographic Forecasts: Why Are the
Numbers Overestimated,” prepared by Palo Alto Councilmember Greg Schmid
b) “Regional Land Use and Transportation SCS: Achieving Statewide GHG Reduction
Rates,” prepared by Contra Costa Transportation Authority.
2. Tables Detailing Discrepancies Between Department of Finance (DOF) and SCS Projections
cc: City Council
Planning and Transportation Commission
James Keene, City Manager
Curtis Williams, Director of Planning and Community Environment
Ezra Rapport, Executive Director, ABAG
Miriam Chong, Interim Planning Director, ABAG