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City of Palo Alto (ID # 3369)
Regional Housing Mandate Committee Staff Report
Report Type: Meeting Date: 12/13/2012
City of Palo Alto Page 1
Summary Title: Appeal of Adopted RHNA 2014-2022 Housing Cycle
Title: City of Palo Alto Appeal of the Adopted Regional Housing Needs
Allocation (RHNA) for the 2014-2022 Housing Element Cycle
From: City Manager
Lead Department: Planning and Community Environment
Recommendation
Staff recommends that the Committee recommend that City Council officially appeal the City’s
Adopted Regional Housing Needs Allocation (RHNA) for the 2014-2022 Cycle and provide input
on the proposed appeal arguments (Attachment A).
Background
On July 19, 2012 the Association of Bay Area Governments (ABAG) Executive Board adopted the
Regional Housing Needs Allocation (RHNA) methodology for the 2014-2022 housing cycle. For
the City of Palo Alto, ABAG projects a need for 2,179 new housing units at various income levels
during this time period. This allocation represents the City of Palo Alto’s share of the 187,990
units the California Department of Housing and Community Development (HCD) projects will be
needed within the Bay Area over that same time period.
State Law prescribes the required appeal process a jurisdiction must follow when the
jurisdiction believes that the allocation is overstated or otherwise incorrect. The first step in
the appeal process requires a jurisdiction to submit a “Request for Revision” letter to ABAG.
The City Council directed that this first step be taken in September and a letter, which was
reviewed by the Council and signed by the Mayor, was submitted to ABAG on September 11,
2012. The letter detailed the reasons why a significant reduction in the total number of
housing units allocated to the City of Palo Alto was appropriate (Attachment C). On November
15, 2012, however, the City received a letter (Attachment B) from ABAG denying the request
for revision for various reasons.
City of Palo Alto Page 2
The next step in the prescribed appeal process is the formal appeal of the allocation. In the
denial letter, ABAG outlined the findings that must be made in order for an appeal to be
granted. Staff has prepared a Summary of Arguments based on prior Council input (Attachment
A) and once the arguments are approved by Council, staff will incorporate them into a formal
appeal for the Mayor to sign. If Council chooses to move forward with this appeal, it must be
submitted by February 18, 2012.
Discussion
State Government Code §65584.05 provides the following grounds for appeal of the Regional
Housing Needs Allocation (RHNA) methodology and jurisdictional allocation:
1. ABAG failed to adequately consider the information submitted by the City of Palo Alto in
the survey ABAG administrated in January 2012 , or a significant and unforeseen change
in circumstances has occurred in the City of Palo Alto that merits a revision of the
information; or
2. ABAG failed to determine its share of the regional housing need in accordance with the
information described in, and the methodology established pursuant to Section
65584.04.
Section 65584.04 requires ABAG to consider multiple factors when determining the
methodology for allocation of housing units: (A) lack of available sewer and water service due
to State or Federal laws, regulations or regulatory actions, (B) the availability of suitable land for
urban development and increased residential densities, (C) land that is protected under Federal
or State Programs, and for unincorporated, County land (D) preservation of agricultural land.
Furthermore, the law states that ABAG shall allocate housing within the region consistent with
the Sustainable Communities Strategy.
In the initial “Request for Revision” letter, the City outlined several reasons why the housing
allocation was overstated. Staff recommends that these arguments also be asserted in the
formal appeal process as follows:
1. State Law requires that the allocation be consistent with the Sustainable Communities
Strategy (SCS). A key aspect of the Sustainable Communities Strategy (SCS) is projecting
growth within the region. In fact, projected growth and its related impacts are the
primary drivers for all other SCS policies and goals. The regional forecast of jobs and
housing for the region, however, substantially overstate growth for the overall SCS
period (through 2040) and continues to ignore the updated demographic forecasts of
City of Palo Alto Page 3
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
future housing cycles. Although the SCS process does allow 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
approximately 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. 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 in this timeframe. Indeed, there were active
discussions with the property owner (Stanford University) in the recent past about
housing development on those sites in connection with its current Medical Center
expansion that was recently approved by the City. While the City acknowledges that
these units have not been otherwise assigned to the City of Palo Alto, these two sites
are proximate to El Camino Real and the University Avenue Caltrain station, and would
be consistent with the objectives of the SCS and SB375. The sites are located very close
to developed land located within the City’s boundaries.Furthermore, this land is not
protected agricultural land, and therefore should not be discounted as a suitable area
for growth. It appears to be an oversight in the designation of priority development
areas (PDAs) that these sites were not included in the Valley Transportation Authority’s
(VTA’s) “cores and corridor” designation and thereby treated as a PDA under the RHNA
methodology. The City notes that significant areas of Palo Alto, designated by VTA in
“cores and corridors,” have been treated as PDAs for the purpose of distributing housing
units, even though the City did not agree to their designation as PDAs. For these
reasons, the City believes allocations should be adjusted accordingly.
3. The City of Palo Alto continues to have concerns regarding the limited availability of land
for the proposed types and density of housing required to provide for the specified
RHNA units. Palo Alto is a substantially built out city, yet nothing in the methodology
has taken that factor into account, as required by Section 65584.04(b). The built extent
City of Palo Alto Page 4
of Palo Alto and the relatively high quality of existing buildings limits potential
redevelopment and entails impacts (traffic, public services, neighborhood compatibility,
etc.) that are heightened by the limitations of land availability.
In addition to the points above, staff recommends clarifying that the City of Palo Alto shares the
SCS’s vision to reduce Green House Gas emissions, but notes that the City of Palo Alto is a
national leader in policies and programs that reduce GHG emissions. Examples of key City
sustainability programs will be enumerated.
Next Step
If the Committee recommends approval, staff will incorporate the arguments into a formal
appeal which will be forwarded to the Council for approval on a January 2013 agenda.
Resource Impact
No further resources are required beyond staff’s time to prepare the Council staff report and to
finalize the appeal to ABAG.
Policy Implications
The Regional Housing Needs Assessment relates directly to the City’s Comprehensive Plan and
Housing Element, The appeal to ABAG reinforces the City’s Comprehensive Plan policies and
priorities.
Environmental Review (If Applicable)
No environmental review is necessary by the City to comment on the proposed allocation.
Attachments:
Attachment A: Summary of Appeal Arguments (DOCX)
Attachment B: ABAG Response Letter to City, November 15, 2012 (PDF)
Attachment C: City Request for Revision Letter, September 11, 2012 (PDF)
Attachment A
City of Palo Alto Appeal of Adopted RHNA Methodology for the 2014-2022 Housing Cycle
Summary of Appeal Arguments
Note: Government Code §65584.05 provides the following grounds for appeal:
1. ABAG failed to adequately consider the information submitted by the City of Palo Alto in the
survey ABAG administrated in January 2012 , or a significant and unforeseen change in
circumstances has occurred in the City of Palo Alto that merits a revision of the information; or
2. ABAG failed to determine its share of the regional housing need in accordance with the
information described in, and the methodology established pursuant to Section 65584.04.
Palo Alto Arguments:
1. As noted above, State Law requires that the allocation be consistent with the Sustainable
Communities Strategy (SCS). A key aspect of the Sustainable Communities Strategy (SCS) is
projecting growth within the region. In fact, projected growth and its related impacts are the
primary drivers for all other SCS policies and goals. The regional forecast of jobs and housing for
the region, however, 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 future housing cycles. Although the SCS process does
allow 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 approximately 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. 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 in this timeframe. While the City acknowledges that these units have not been
otherwise assigned to the City of Palo Alto, these two sites are proximate to El Camino Real and
the University Avenue Caltrain station, and would be consistent with the objectives of the SCS
and SB375. Furthermore, this land is not protected agricultural land, and therefore should not
be discounted as a suitable area for growth. It appears to be an oversight in the designation of
priority development areas (PDAs) that these sites were not included in the Valley
Transportation Authority’s (VTA’s) “cores and corridor” designation and thereby treated as a
PDA under the RHNA methodology. The City notes that significant areas of Palo Alto, designated
by VTA in “cores and corridors,” have been treated as PDAs for the purpose of distributing
housing units, even though the City did not agree to their designation as PDAs. For these
reasons, the City believes allocations should be adjusted accordingly.
3. The City of Palo Alto continues to have concerns regarding the limited availability of land for the
proposed types and density of housing required to provide for the specified RHNA units. Palo
Alto is a substantially built out city, yet nothing in the methodology has taken that factor into
account, as required by Section 65584.04(b). The built extent of Palo Alto and the relatively high
quality of existing buildings limits potential redevelopment and entails impacts (traffic, public
services, neighborhood compatibility, etc.) that are heightened by the limitations of land
availability.
4. In addition to the points above, it is important to reiterate that the City of Palo Alto shares the
SCS’s vision to reduce Green House Gas emissions. 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. 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.
/' ,
Representing City and County Governments of the San Francisco Bay 1m2 NOV " 9 AMI I : 2 7 ABAG
November 15,2012 HECEIVED
CITY MANAGER'S OFFICE
Mayor Yiaway Yeh
City of Palo Alto
P.O. Box 10250
~:":';:-i [--
Palo Alto, CA 94303 !
Subject: ABAG Response to RHNA Revision Request
Dear Mayor Yeh, .
I am writing in response to the City of Palo Alto's (City) request for a revision of your
jurisdiction's draft Regional Housing Need Allocation (RHNA) for the years 2014-2022.
ABAG's Executive Board adopted the final RHNA methodology for this cycle at the July 2012
meeting. The final methodology was developed with a substantial amount of comments,
discussion and advice from a Housing Methodology Committee made up of elected officials,
senior staff and interested parties from around the region. In making its decision, the Executive
Board tried to balance SB 375's emphasis on greenhouse gas reduction with the need for all
jurisdictions in the region to provide housing choices for people at all income levels.
(t"':-'::
" .,~ '.~ .
........ ·.,;.1
As you are aware, SB 375 requires that the RHNA be consistent with the development pattern
included in the Sustainable Communities Strategy (SCS)l. To help ensure this outcome, the
adopted RHNA methodology initially allocates the pre-determined regional housing need from
the California Department of Housing and Community Development (HCD) to local jurisdictions,
consistent with the land use criteria specified in the draft SCS2 for the RHNA period, 2014-2022.
Through this process, the region's housing, transportation, and land use planning are aligned.
Adoption of the final RHNA methodology was accompanied by release of draft RHNA numbers
for each jurisdiction. This initiated a 60-day period in which local jurisdictions could request a
revision to its RHNA. By law, revisions to these allocations must be: 1) in accordance with the
factors outlined in statute that are the basis for the methodology, 2) based on comparable data
available for all affected jurisdictions and accepted planning methodology, and 3) supported by
adequate documentation. 3
1 California Government Code Section 65584.04(i)(1)
2 ABAG used the draft SCS adopted in July 2012, commonly known as the Jobs-Housing Connection Strategy
(JHCS), because of the timing differences between the SCS and RHNA processes. 'ro ensure consistency, ABAG
will make no changes to the land use criteria of the SCS for the period from 2014-2022.
3 California Government Code Section 65584.05(b)
Mailing Address: P,O. Box 2050 Oakland, California 94604-2050 (510) 464-7900 Fax: (510) 464-7985 info@abag.ca.gov
Location: Joseph p, Bort MetroCenter 101 Eighth Street Oakland, California 94607-4756
Page 2 of3
Response to City of Palo Alto RHNA Revision Request
November 15,2012
Your letter indicates the City of Palo Alto's concerns that the SCS overstates growth, the
County's allocation is too low, credits should be allowed for other GHG reduction efforts, and the
housing mandate will have negative effects to the environment, school capacity, and
infrastructure.
Per the RHNA statutes, the factors mentioned by the City cannot be used to lower a jurisdiction'S
allocation. The region must allocate 187,990 units to all jurisdictions as directed by HCD. Even
if ABAG were to lower the SCS forecast, the RHNA would still have to distribute the 187,990 to
all jurisdiction.
The County's allocation is based on the growth potential and factors derived through the SCS and
RHNA methodologies. However, ABAG is open to transfers between jurisdictions that meet the
limitations outlined in the RHNA statute.
The GHG reductions encompassed in the SCS under SB 375 are specific to land use changes.
Other ef~orts by local governments to reduce GHG need to be addressed under AB 32.
The regional housing need goal is to promote the following objectives: increase the housing
supply and the mix of housing types, tenure,and affordability in all cities and counties within the
region in an equitable manner; and facilitate infill development and socioeconomic equity, the
protection of environmental and agricultural resources, and the encouragement of efficient
development patterns.
Per Government Code §65584.05, a jurisdiction has an opportunity to appeal ABAG's denial of
its revision request. The deadline for local jurisdictions to submit a request for an appeal is
February 18,2013. If you decide to pursue an appeal, please contact ABAG staff to obtain a
template to use when submitting your request.
As background, Government Code §65584.05 provides details about the specific criteria on
which an appeal must be based. The two grounds for requesting an appeal are:
• ABAG failed to adequately consider the information submitted by your jurisdiction as part
of the survey we administered in January 2012 or a significant and unforeseen change in
circumstances has occurred in the local jurisdiction that merits a revision of the
information submitted in the survey; or
• ABAG failed to determine the jurisdiction's share of the regional housing need in
accordance with the information described in, and the methodology established pursuant
to Government Code §65584.04.
\
Page 3 of3
Response to City of Palo Alto RHNA Revision Request
November 15,2012
Appeals will be heard by an ad hoc committee of ABAG' s Executive Board at a public hearing
between March 30 and April 4 (date to be determined).
Thank you for your continued involvement in developing the SCS and RHNA. I look forward to
continuing to work with you on developing policies and programs to address the region's housing
challenges. If you have questions about RHNA or the appeals process, please contact Gillian
Adams, Regional Planner, at 510-464-7911 or GillianA@abag.ca.gov.
Regards,
Miriam Chion
Interim Planning Director
CC: Mark Luce, President, ABAG
Ezra Rapport, Executive Director, ABAG
September 11, 2012
Mr. Mark Luce, President
Association of Bay Area Government
Joseph P. Bort Metro Center
P.O. Box 2050
Oakland, CA 94607-4756
City9fPalo Alto
Office of the Mayar and City Council
Re: City of Palo Alto 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 ofthe adopted Regional Housing Needs Assessment (RHNA) methodology and
jurisdictional allocations for the 2014-2022 housing cycle. While the adopted allocations
appear to have taken into consideration some ofthe concerns and comments expressed by
member jurisdictions, the target projections are still unrealistic. In Palo Alto, the built-out
nature ofthe 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. 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 (DO F). 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 future housing cycles. Although the SCS process does
allow 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
Prlllted with '''jI-based il\ks 01\ 100% recyded pa~f Pt(l~$5ed without chlorlru\
P.O. Box 10250
Palo Alto, CA 94303
650.329.2477
650.3283631 fax 1
M r. Mark Luce, Presi dent
Association of Bay Area Government
September 11, 2012
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 ofthe 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 EI Camino Real and the University Avenue Caltrain station, and would be
consistent with the objectives ofthe SCS and SB375. Specifically, approximately 350
planned units on two sites on Quarry Road just west of EI 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 ajoint 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 tity 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 polides 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 emis.sions.
2
Mr. Mark Luce, President
Association of Bay Area Government
September 11, 2012
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
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,
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@cityofpaloaito.org.
Sincerely,
~' ,1//" /~
Yi yJ I ---
Mayor
Attachments:
1. March 5,2012 Letter from MayorYeh 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 (OaF) 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
3
MUI'Ch 5,2012
Mr. Mllrk Luee, Pll!.~ident
Association or Boy Area Governments
Jos~ph P. Bort Metro Center
P.O. Box 2050
Oakland, CA 94607-4756
IAttachment 11
~i!yof Palo Alto
Officr of thr Mayor alld City Council
Re: City ofPlllo Alto Comments on Sustainable Communities Strategy (SCS) Alternative
Scenarios
Dcar Mr. Luce:.
AssoCiation of Bay Mila Governments (ABAG) staff has requested local agency comments on
its propo3ed land use Altcmalivc Scenarios developed B-1 [l part oftfJe One Bay Area Sustainable
Community Strategy (SCS). We look forward to the further discussion and refinement of the
Preferred Scenario before the final Regional SCS is completed early in 2013. However, at this
juncture we belitwe it is necessary for the City to express its concerns regarding the SCS
A/lemative Scenarios and the related regional jobs and housing forecasts, and to suggest
altemalive approaches 10 the Pre[ell'Cd Scenario.
This relle!' pll)vidas the City of Polo Alto's (City) comments, which have been fonnulated
following till: City's considentble review and analysis of the Alternative Scenarios and Ielated
regional job and housing forecasts. The Cily acknowledges llIId h[lpreciates the facl lhal the SCS
process wiU continue following release of ABAG's Preferred Scenario, scheduled for Morch B,
2012. In summary, the City's concerns are as follows:
• The City of Palo Alto has been a national leader in implementing policiCB and programs that
l'educe greenhouse gas (OHO) emissions and the effectiveness of these efforts should be
eonsidered os a pMt of the SCS and achieving regional GHO emission reduction targets.
• The regional foreca.~t of jobs and housing being considered as part of the SCS likely
overstates future growth in the Bay Area and at a minimum is highly uncertain; ABAG
should recognize the dislinct possibility that actual growth rates in the Bay Area over the
nexl30 years may be lower and should pha.~e job and housing allocations HOd
implementation accordingly.
• Palo Alto's allocation of jobs Rnd housing units under all of the Altemalive Scenarios is
excessive by reference 10 lis historical growth trends and development capacity; these
aUocatiom should more accurately consIder policy constraints, mlll'ket feasibility, and the
high infrastlUcture costs and local fiscal impacts of stICh intensive redevelopmenl
P.O. B .. l~250
P.lo AlIo, CA 94303
6.5IJ.3292f17
1 650.3283631 fox
ABAG: SCS AltemaUve Scenarios
March 5, :lOU
• The land use changes contemplated in the SCS Alternative Scenarios have a propOltionately
smull contribution to achieving AB321SB375 aHG reduction targets and there are very
limited differences shown between the Alternative Scenarios; the considerable effort and
investment needed to affcct these hmd use changes should be rc-directed to more cost
effective regional and local GHa reduction measures.
While the City retains serious concerns regarding the Regional Forecast of jobs and housing and
also the allocation of fuhIre development under the Alternative Scenarios, Palo Alto is firmly
committed to doing its share to achieve the State-mandated (AB32JSB375) OHG reduction
targets. The measures already adopted by the City provide ample evidence of this commitment.
Going fOlward, thc City expects to cooperate with ABAG and our other regional pOl1ners in the
future effort.~ needed to achieve substantial reductions in aHG emissions through realistie and
achievable regional and locol policies, programs, and investments.
The following items elabol1ltc on the summary points listed above.
1. 11U1 City of Polo AiJo lIas been a nalionolleader ill implemfilltillg policies and programs
t1laJ nlduce GHG en/isaio",. •.. .
Over the past decade, the City of Palo Alto has adopted a range of policies, programs and
projects to reduce OHG emissions, focused upon improving energy efficiency, enhancing multi
modal trausporMion alternatives tD the single-occupant vehicle, and creating walkable, mixed
use districts. Implementing these policies, programs, and invesl;ments the City has become a
national leader in redueing GHG emissions. Some of the key programs include: .
a. City of Palo Alto Climate Protection Plan (CPP): The CPP, adopted by the City Councilin
December 2007, includes goals for the reduction of CO2 from n 2005 baseline level as a result of
changes in City operutions and from CO~ reduction efforts within the community.
• The City has surpassed its short term goal of H 5% reduction in emissions by 2009 for a
total reduction of 3,266 metric tons of CO2•
• By 2020, the City and community will reducc emissions by 15% from 2005 levels, equal
to 119,140 metric tons of CO" oonsistent with State emission reduction goals.
b. Availability of Clean Energy: The City of Palo Alto is in a unique position as owner and
operator of its electric utility to make available and provide clean energy to City customers. In
this regard, the City Council adopted a goal to have 33% of the electricity supply to be provided
by renewable electricity suppliers by 2015, five ~BfS in advance of the State requirement.
• For FY20n, renewable electricity supplies account for 20% of the City's needs.
• Contracts are in place with suppliers to provide 26% of the City's eJectrical needs as
renewable by FY2014 with the potential to reach 30% from contracts that are still under
negotiations.
• Currently, 24% of the City's customers participate in the Palo Alto Green program,
paying a surcharge on electric serviee to support tenewable electricity supplies.
• The City's Utilities Department is preparing a. plan to be released later this ~a .. for the
electric portfolio to be carbon neutral.
!l8AG: SCS lI/1:ernalMl SCefiarlO1i
Mardi 5, }(lt~
C. UJi\ityPrograms to Reduce Bmission8: In addition 10 providing clean energy options for ilS
clllItomel1l. the Utilities Department offers programs such 6li rebate.,. assistance. Information, and
workshops 10 halp customclll inCn;aSI; electricity efficiency and c[)St &8vings that reduce
emissiollS. These succelises of these programs are mea.~tlrable: Tn FY2011, Palo Altooustomers
n::allced c.:'Ch emissions by 12,557 tons through the use of electdc and n!l1l1nli gas efficiency
programs. Incentives for solar photovoltaic (PV) and solar hot water systems, and other program
efficlellcleli.
d. Leadcr$hip in Green Building and Sllstainable Deliign: In FY 2009, the City Council adopted
the City's Green Building Ordinance to bulld a new generation of efficlelll buildings in Palo Alto
that are environmentally responsible and healthy places in whic~ to live and work, This program
Wall one of the first in the nation to mandale green building requirements and certifications for
virtually all public lind private buildings.
• In FY 2011, the Cily initialed tne fillit LEED-ND pilot program (LEED for
Neighborhood Development) in the United SllItes for llfi'i'CllSing a development site's
ability to qualify 115 a 5ustllinablc neigllbornood project, including featUI'es Ihal reduce
dependence on aulomobile lISe, increase walkability, and encourage healthy Jiving.
• The City also rolled out energy use disclosure requirements for eJlisting buildings
undergoing smalll'enov!ltlon work to better understand the existing buildings' current
performance and areas where education, policy, and prograJns can be innuentlal in
reducing energy mage.
• The amount of ro~ diverted from the environment has increased since the adoption of
the 2009 ordinance and programs. In 2010, the first full year of the ordinance, c.:'Ch was
reduced by approximately 1,013 tOllll. In 2011, (X)2 was reduced by a jJprcllimlltcly 2,818
Ions, II 178% increlille over the previous year.
• Prior ll) the Cily's ordilll!llctl, !Ill few lIS six geen building projccls existed IhruughoUllhe
City. By the end ofF! 2011, more than 240 green buildillgJ! have been compleled or arc
under construction,
'e, AffoIJlable Housing; The City of Palo Alto has been a Il'8der in providing for affordable
housing in one of the most expemlive housing markets in the nation.
• In 1974, l'lllo Alto became Olle of the firsl citillll in the United States 10lldoptlln
inclusionaty hou&ing program thllt required the provisioo of below markel rate (BMR)
residential units io new multiple-family dwelling projects,
• Today, the City oversees 239 ownership units III1d 198 rentlll BMR units that ate
IIvailable fo qualified applicant!!. As the cosl for h!lWllngill Palo Alto comlnucs to
inen:ase, the value of these affordable units to provide housing withln Ihl:'. wblmized Bay
Area hIlS Illso increalled. BMR 1100000ing provides gn:lII:er opportunily far lower i lICome
families 10 Jive closer to their jobo and utilize public IrIlnsil.
• Recently, Palo Alto welcomed two new BMR housing projects, including the Tree House
Apartments, 0 35·unlt comple/( with a Green Point R!I1II1f!, of 193 (the highest score in
Polo Allo for multiple family housing) lind AJta Torre, II 56""oil compleJl for very low
income seniol1!.
• Construction is underway at 801 Alma Streel, II So..unit family affordable project
immediately adjacent to CalTrain III1d within walking distance 10 shops and services on
Univllf'Sity AVl!IIUl! in downltlwn,
MAG: SCS AirornaUv8 scenarios
March 5, 2D12
f. Highe! Density Land USe.!! Near Tmnsit: The City's Comprehensive Plan designates two
Bre85 of the City (downtown lind CalifomiaAvenuej as appropriate for "Transit Oriented
RJ:sldential," in a 2,ooD-fool radius of the City's two Caltrain stations. These arcus are identified
for higher intensity residenlial and milted-use development focused around a W81kable, bicyele
friendly environment.
• In 2006, two years before the adoption of SB375, the City Council adopted the Pedestrian
and Trunait Oriented Development combining district (PTOD) for the ares around Ihe
California Avenlle CalTruin station. This disllici allows for residential densities 11140
units per acre, increased floor areA utios, increased building heights, reduced parking
requiremems. and density bonuses for the provision of BMR housing in milled-use and
multiple family projects.
• In 2007, Council ~upported the designation of this area iIIl a Priority Development Aren
(PDA) as part of ABAG's FOCUS program Ihat would eventually evolve into Plan Bay
Area. This land USe planning effort is one example of u pattern of early-adoption
decisions nlode by the City Council to address growth, tmnsit and greenhouse ga.~
emissions within ourconununity.
• The Council hIlS directed that housing sites proposed in Ihe City'S Housing Element
should be focused in trnnsit-prOldmate llI'Cas, and that increased height and intensity may
be considered in those loentions.
g. Transportation Policies and Projects: The City of Palo Alto has developed transportation
policies, programs and projects to implement a trans ii-oriented, walk8ble and bieycle-friendly
vision that demonstrate leadership of Ihe "Complete Streets" concept promoted by the
Metropolitan Transportation Commission, Somc of these key r=l1t measures include:
• Bicycle and Pedestrian Transportation Plan: The City is completing its updatw plan to
accommodate enhanced bicycle and pedestrian facilities and PnJgrams, and to elevate the
City'sBicycle-FriCndly Community slatus from Gold to Platinum level.
• Stanford AvcnuefBl Camino Real Intersection Improvements; The City has recently
completed improvements at this intersection to enhance safety for pedeslrians ond
. cyclists, including children who use the intersection as a route to school, and to upgrade
the aesthetic qualities of the intersection and of EI Camino Real. We e)(pect the project
will serve as a template for improving intersections throughout Ihe Grand Boulevard
corridor.
• Safe Routes to School: The City'S Safe Routes 10 School program bas resulted in II
phenomenal increase in school children bicycling and walking to school over the post
decade. In the 2011 fiscal year, Cily staff coordinated 140 in-class bike and pedestrian
safety education progrllllU in l2 elementary schools, reaching 4,250 student,. Recent
surveys of how children lISually get to elemenlary school showed an average of 42%
choosing to walk, bike or slalte to SChool, compored to a nalional aVerage of only 13%
(figureR for middle schools and high schools are even greater). A recent grant will ullow
the City to prepare Safe Route., maps for every elememary school in the city as well as 10
apand OUI education cuniculom into middle schools Md to adults.
• Traffic Calmipg pn Residenlial Arteriam: 'The City has an ambitious !raffie calming
program along "residential mneriaill" in efforts [0 support our Safe Rouecs to School
program and 10 enhance hicyde Hnd pedesloan safety. In particular. the ongoing
4
ABAG: SCS Alternative Scenarios
March 5, 2012
Charleston Road-Arastradero Road Corridor project has provided substantial safety
improvements and selective lane reductions to enhance bicycling and walking while
maintaining efficient levels of vehicle throughput simillll' to those prior to the traffic
calming improvements.
• Bicycle Parking COll'llls: The City has recently installed six green "bicycle parking
coll'llls" in the Bay Area. with each corrlll providing for up to 10 bicycle parking spaces
in highly visible, signed on-street areas in downtown. Up to a dozen more such
installations are planned in the downtown and California Avenue areas.
• California Avenue Streetscape Improvements: A pending grant would support the
substantial upgrade of California Avenue to a more pedestrian and bicycle-friendly
roadway, incorporating "complete street" principles, and also enhancing access to the
California Avenue Caltrain station.
• Local Shuttles: The City, with support from the Coltrain JPB, offers local shuttle services
for commuters, school children, seniors and others between points of interest within the
city. These shuttles fUl1her reduce the need for single-occupant vehicle trips and reduce
traffic congestion and parking needs.
Acconlingly,.the City of Palo Alto requests that ADAG consider the effectiveness of these local
GHG emission reduction efforts, incorporate them as a part of the SCS and related regional GHG
reduction targets. and provide "credits" to those jurisdictions that have demonstrated
implementation of meaningful GHG reduction measures.
2. Tile Regional Foreca.vt of job. v alld houslllg beillg conddered as part of the SCS appears to
oyerstate future growth ill file Bay Area.
The regional jobs and housing forecast used for the Alternative Scenarios is lower than the
foreeast for the Initial Vision Scenruio and the Core Concentratio[l Unconstrained Scenario,
reflecting conunents received from the local agencies following review of the Initial Vision
Scenario. However, in the City of Palo Alto's view, the mostrccentjobs and housing forec[l.~ts
for the three "constrained" Alternative Scenarios remain at the high end of plausible Day Area
jobs and housing growth over the next 30 years. The City is disappointed and dismayed at the
minimal public discourse around the development of these projections, though we do appreciate
Dr. StevenLevy's recent presentation of the analysis behind the projections. At this point,
however, ABAG has provided insufficient justification for the methods and results of the
regional job and housing forecasts used in the Alternative Sceml1ios. An evaluation of the
Regionnl Forecast prepared late last year by Councilmember Greg Schmid provides an
assessment of ('..alifornin growth forecasts (see Attachment A), indicating the tendency for
foree asts to overstate growth as compared to actual figun::s from the Census. and discussing
some of the key factors that will influence California's future growlh.
a. Jobs. Regarding thc ABAG jobs foreeast, a comparison with the last 20 years is noteworthy.
Average job increases between 1990 and 2010 approximated 10,000 net new jobs annually.
Excluding the three years that included the Great Recession where substantial jobs losses
occurred (i.e. 2008-2010), the Bay Region added jobs at an average annual mte of 25,200
between 1990 and 2007. The ABAG jobs forecast used for the Alternative Scenarios
assumes that the Region will add an average of over 33,000 jobs annually from 2010 to 2040.
5
AIlAG: SCS Alternative Samarlos
March 5, 2D12
a 32% increase over the pre-recession trend line. The method used to arrive at the jobs
forecast assumes a "shift-share" of a national jobs growth forecast that itself is subject to
question. As a pan of revisions to the regional jobs forecast, ABAG should consider a more
fundamental economic assessment that identifies the key industries in the Bay Area that will
drive job growth and also the distinct possibility that future jobs and housing may be closer
to recent historical growth trends.
b. Housing. Regarding the ABAG housing forecast used for the Alternative Scenarios, an
additional 770,BOO households are shown added to the Bny Area between 201 0 and 2040 -an
annual average growth of 25,700 households. The average annual housing growth rate
between 1990 and 2010 was 21,000. At the present time, two years into ABAG's forecast
period. the Bay Area, like.much of the United States. remains in a weak housing Qlnrket
characterized by very limited new development, low pricing, slow sales of existing homes,
tight eredit, and an oversupply of homes resulting from a historically high number of
foreclosed and distressed properties. These conditions are expected to continue for several
more years until the existing inventory is reduced and substantial improvement in the job
market and related increases in household income occurs. In any event. the Bay Area will
need to be in "catch-up" mode, meaning even higher additional households per year must be
realized to meet the SCS forecast growth rates, once more norma] housing market conditions
emerge. Moreover. ABAG's regional housing forecast is based on a filled share of a national
popUlation forecast prepared by the U.S. Census Bureau that presumed international in
migration (primarily of Asian and Hispanic peoples) would continue and comprise
approximately 80 percent of all population growth nationwide.
c. Housing Affordability. In addition to questions regarding job growth (the ultillUlte calise of
housing demand) there are a number of other questions regarding ABAG's housing forecast
including those relnted to affordabiJity. A presentation made by Karen Chapple of UC
Berkeley at the ABAG's January Regional Advisory Working Group (RA WG) suggested
that given likely wages paid by the new jobs expected, over70 percent of all new households
formed in the 2010 to 2040 period will be "moderate" income or below. In many Bay Area
locations, especially the inner Bay Area urbanized areas that are the focus of growth under
the SCS Alternative Scenarios, such "affordable" housing units must be subsidized in one
fashion or another, either as "inclusionary" units burdened upon the market rate units
constructed 0]' by public sl.Ibsidies such as (now eliminated) redevelopment agency funding
and federal tax credits. Given the loss of redevelopment powers and funding and Iccent court
cases affecting inclusionary programs (palmer, Patterson) there is no assurance that adequate
housing subsidy funding will be available. .
d. RHNA. Then there is the matter of the Regional Housing Needs Allocation (RHNA). As
presently proposed, the regional foreeast and related Preferred Scenario allocations to be
released as a draft on March g'b will apparently serve as the basis of the future RHNA for
each city and county, whieh will require a one-third of the overall Preferred Scenario housing
allocation to cities in each 8-year "planning period" regardless of any assessment of realistic
development capacity (note: recent information from ABAG indicates that less than one-third
of the 201 ()"2040 forecast IS likely for the 2015-2022 period, however, due to the economic
A8AG: SCS AlternatIVe Scenarios
March 5, 1011
housing downturn). This approach seem8 highly arbitrary, insensitive to local conditions and
constmillts, and far beyond what can realistically be expected from Qn economic perspective.
Accordingl y, given aU of these concems. the City strongly recommends that the jobs and housing
forecasts for the Preferred Scenario be reduced to reflect more aceuralely current conditions,
historical trends, and more fundanlenllli assessment of economic (job) growth potential in the
Bill' Area. Developing a more realistic jobs and housing forecast would reduce the implied need
to intensify land uscs, redu{:e projected GUG emissions by lowering energy consumption,
congestion and single occupancy vehicle trips, and require less costly transit and highway
infrastructure investments. The SCS effort i. 10 be revisited and updated every four years, so that
there would be "Cuture opportunities to re-evaluate whether a higher forecast is appropriate and
adjustments would be needed.
1. Pala Alto's allocation ofjobl tJnd IlOusing Imit, IIndeT the Alterna/ipe SU/Jiuio.r iI highly
u/lTBallaHc and ucesMil'e relative trJ Iwlomar growth tnmdr and devBwpment Mp4City.
Santa Clara County dominates all other Bay Area counties in tRe allocation of ABAG's regional
forecast of jobs ~nd housing, absorbing 30 percent oJ the regional job forecast and 26 percenl of
the regional housing forecnst. Palo Alto is allocau~d new jobs ranging from 18,040 Outward
GI'owth) to 26,070 (Focused GI'owlh). Palo Alto households allocated range from 6,107
(Outward Growth) to 12,250 (Constrained Core Concentration and Focused Growth). These
allocations have been made without rega!'d to existing developuplt capacity in Palo Alto (use of
remaining vacant land and redevelopment of existing developed areas). the likely match between
new household affordability and local housing prices, or a range o(other pOLCntiallocai costs for
achieving the required high density development < <
a. Jobs. The City presenlly contains approXimately 62,300 jobs, according to ABAO. During
the past decade (2000 to 2010). Palo AIm experienced a 14 percent decline in cmployment
reflecting the combined cHoct of the "dot-com" bust and the Great Recession. Whilo
e(:onomic conditions ore expected to improve, there have been structural changes in
teChnology industries that hove ddven growth in the Silicon Valley over the past 50 years
that portend only modest growth. The Alternative Scenarios assume that Palo Alto's job
growlh by 2040 will Increase over the 2010 e.qtimate by between 27 percent and 40 percent.
b. Housing. The hDlL'ing projections in the A1tcrnative Scenarios represent a 2.5-50 percent
increase in housing units from 2010-2040, up to approximately 400 new units per year, The
Cily has In thc past 40 years (1970-2010) produced an average of 14& units per year. Tn more
tllan double thai ootput in a relatively built-out city is again entirely unrulistic and using
such on assumption liS the basis for growth scenarios ond transportation investmenL~ will
likely result in failure of the planning effort.
c. Constraints. The City of Palo Alto is highly built out, and the existing limited number of
vacant sites and redevelopment opportunity sites severel y limit how the households and jobs
ollocated to Palo Alto in the SCS Alternative Scenarios could be accommodate{], The
"constrained" scenolios clearly do not appear to consider the many constrainl8to new
development in Palo Alto" including limited school capacity Bnd funding for infrastructure.
7
A~AGr SCS Alr.rnawe Scenaria.
Ma",h 5, 2012
Accordingly, the City requests that the allocations of jobs and housing units in Palo Alto should
be lowered substantially to more accurately consider policy constraints. market fC!llIibility. and
infrastructure and local fiscal imracts of such intensive redevelopment.
4. The 141td us/! chaRge .. clJ/ltemp/Qted in tile SCS AIterllati¥B SC6t1arias have a
praptrrtiolJately small conJributum ta aciJisvi"g AB32/SBJ7S GHG reduction targets.
The AB32/SB375 target for Califol1lia is a reduction to 85 million equivalent metric tons per
year by 2050. an 80 rcrcent reduction from current levels. To return to 1990 levels of 427
million Ions. an 80 million ton reduction of projected 2020 levels is required. Of this 80 million
ton reduction, approximately 96 percent is propoaed to be achieved from improved fuel standards.
energy efficiency, industrial measures, and other methods needed to curb emissions from the
construction, manUfacturing, and agricultural Si:ClOrll. Only four percent. however, or 3.2 million
lons, would be achieved by altering land use patterns. This is shown elfectivelyon the graph
(Allachment B) prepared by the Contru Costa Connty Transportation Authority (CCfA) in their
letler dated February 15,2012.
a Negligible Difference Between AlternatiVe!!: The potential contributions of the land use
changes contemplate.:! in the SC.s A1temativ!, Scennri03 show reductions in GHG emissions
through 2040 range from 7.9 percent (Outwurd Growth) to 9.4 percent (COnsuained Core
Concentration). Compared 10 the initial CUffent Regional Plun Scelllltio, tne Alternalive
Scenarios reduce GHa emissions by Q.9 percent to 2.4 percent of the remaining4 percent
affected by land use and transportation patterns. This is a negligible difference between the
land usc scenarios and argues for a more f1~){ible approach that combines olller GHG
emission n:duction strategies witn a more realistic land Ulic scennrio.
b. Regional Transportation Pricing and Policies: The MTC analysis of various transportation
pricing and policy changes (e.g., telecommuting. electric vehicle 8trll1egiCs, parking pricing)
may account for alleast a 6.5% fw1her reduction in aHa emissions, considerablY more
signiflcantthan the differences between the land usepatte.ns in the Alternative Scenario.~.
c, Cost Effectiveness. Given the numerous challenges associated with fundamental changes ill
the way that Bay Area land usc pallerns would otherwise evolve, including wholesale
changes to land use regulations. presuming changes in market characteristics and preferences
of homebuyers, and the need for substanlial public investments and subsidies, we question
the fCHsibllity and.cost-cffectiveness of the Alternativc Scenarios. Regarding market
feasibility, there is no .:vidence that the resulting hOUSing capacity and prototype!! would
match buye.r preferences and affordability. Regarding cost-effectiveness, the com[larahle
costs (mostly borne by local jurisdictions) of implementing the Altemative Scenarius may bc
far higher than other alternatives for achieving compllIable GHO emisfiion reductions.
Acconlingly. the City of Palo Alto recommeoos that a performB,!ce-based approach, involving
establishing GHG reduction targets for the local jurisdictions along with a menu of opllonslbr
achieving these targets (including feasible and realistic alterations in land u~e pOlicy) should
become the basis of the proposed SCS.
B
Conclusion
A8AG: SCS Altem.Uve Salnario$
March 5, 2012
In conclusion. the City of Palo Alto suggests that the Preferred Scenario for the Sustainabil!ty
Communities Strategy should include:
• A focus on GHG emission reductions, with the flexibility for each city and county to
provide for a reasonable minimum mnounl of housing pltls options for other
commitments to GHG emission reductions;
• Grant funding for transportation and planning oriented to Priority Development Areas
(PDAs);
• Realistic housing forecasts limiled to each upcoming 8-year RHNA cycle, with (eview
every four years to update projections; and
• Longer range projections thai are not allocated to cities and counties, but are used to
provide contex:t for regional transportation investments.
Thank you again for the opportunity to comment in advance of your proposal for a Draft
Preferred Scenario. If you have questions or need additional infonnalion, please contact Curtis
Williams, the City's Director of Planning and Community Environment, at (6.50) 329-2321 or
curtis. williams@cilyofpaloalto.oI,g.
Sincerely,
j), (;'-), /i...~.-,
{YiawayYeh
Mayor
City of Palo Alto
Attachments:
Attachment A: November 1.5,2011 Memorandum: "California Demographic Forecasts: Why
are the Numbers Overestimated," prepued by City of Palo Alto Councilmember
Greg Schmid
Altachment B: ''Regional Land Use and Transportation SCS: Achieving Statewide OHG
Reduction Rates," prepared for Contra Costa Transportatior! Authority
cc: Adrienne J. Tissier, Chair, Metropolitan Transportation Corrnnission
Steve Heminger, Metropolitan Transportation Commission
Ezra Rapport, Association of Bay Area Governments
John Ristow. Valley Transportalion Authority
Palo Alto City Council
9
California Demographic Forecasts: Why are the numbers over
estimated7
Prepared bv City of Palo Alto
November IS, 2D11
Actual California Popu[atiGn growth
Attachment a
1
Over the la,t decade, the state of California added 3.4 million people, 10 reach a total of 37.3 million.
This WaS an Increase of 10% oller the decade. Thi, growth rate follow~ t~e gradual slowing that,tarted
after·1990, down dramaticallytrom thellery high rate, of the post-World War II era. NOIe thaUne
Del'artmehl ofFinanee's (DOFI2007 projections retlect a very high growth perspective. The DDF
. "umbors are tutrently used as the population forecasts tor allstate and local prolects-th"" are not
5chedul@dtobe rellised until 2013.
Table 1. California's populadon growth OVer tbe last live decades
laverage growth from census 10 census)
.!:mila DW af Finance Pra["ftions 120071
1960s 29.2
1970s 18.5
1911O.s 25.7
1990i U.8
2000$ 10.11 14.8
211111s 12.8
20Z0. 11.6
Z030i 10.2
Source: US Census BUreau actual Census nllmbers; Callfarnia Departmonl af Finance 2007 PIOjE!Clions.
Recent State forecasts have been consistently over-estimated
E~en after the sharp decline In growth during the 19905, fOlstaslers consistently tended to be overly
optimistic .bout po~ulalion growth rale.through the 2000" In 2005, the Public Polity Institute 01
California issued a report ("Callfomlo 2025: Taking on Ihe Future") that I~tluded the populadon
proJections of all the key demo!lra~hlc forecoste". The consensus f",ec .. t from Ihls group was some
4Il% higher than the Mtual oulMme for the state:
Table 2. California Population Forocasts for 2010 made before 2005
(Percentag. voWlh expect"d from 2000-2010)
Callfomla Depl of Finance 15.2
USC Pupulallon Dynamics ·11.6
UC BlII'kele¥ (Lee, Miller) 13.9'
Public Pallcy Institute at CA 15.Z·
CCSCE 17.2
UCLA Anderson Farecasting 16.6
Aurase of siX ZOOS foretosts 15.0
'=center ~olnt at band
Source: Public Policy Insdtute of California, ·Callfornla 2025: Tald~ on Ihe Future", 2005, Page 29.
2
The consel1SU' forec.st was some 50r. above the actual numbers. The only lorQCaster who produced a
number below the actualtO')6 growth waslhe UC Berkeley group who staled Ihat there wa5 a 5%
Chance that the growth rale would be lowerthan 7.1%. The 2005 PPIC Report .taled thol "Recent trend5
make population proje[lIons fot California es"..ci.l1y dlfflcull...For these reasons, plannersshould
consider alternative population scenarios ... as useful aitematllles lor planne ... • (PPIC, 2005, pages 27·
ZS)
Even as late as Ihe end of 2009, on the ~e ofthe detenni.I census, estimates by Ihe California Depl. 0/
FinanCe (the organization re.sponslble forthe nutnbersthat are used for all state allocation formulas)
remained strikingly high at 14.l% which was 1,5 million or 44.7% a~ the a bo~e the
contemporaneou, and more accurate Ce~5u, Bureau's Current Population Estimate •.
C,'Weal Components of Change and the Future
The Census data provide a nice detailed perspective on the ~ctlJal components of change during the
decade. W~lIe the 3.1 million people added through natural increase Ibirths minus death,) were the
large.t .ingle growth factor, the 2 million net gain from loreign immigration was important In
overcomlnl a net outflow of 1.6 million Irom native born emigration. prlmarilv to other .tales.
Tabl8 3. Components ofl'opulation Change In Cdlfornla.. ZBOo-2010
ImUlions of people'
Births
Death.
+5.45
-2.35
Net Domortlt mljration -L63
F"relEn Immigration +2,58
F"r"ie" "mlRlalion -D.59
MNluny, elt -Dm
TaTAL +3.38
Sourc,,: USc, Population Dynamlo Resear.ch Group. ''What th .. C"mllltwQuld shoW". February2DU.
3
The challenge for prolecting change In the future Is the dramatic sl1ifC' In some 01 these base categories.
With the aslng population, we know that, .~en with slight Increases In 10nBe~ltv, the aging population In
California will ratse the annual number 01 deaths In Calilornia from 271K In 2011 to 462K In 2039, while
the number of births will rise sllghtlv from S32K In 2011 to 551 in 2039. The naturaltncrease will fall
from some 250K today to 90K In 2040.
Thu •• over time any Incre .. e in Californ a's population will increasingly mly on migration. Since net
domestic migration has aVQraged a net olJlflow 01 some lOOK per vear 'inee the earlv 1990s. any growth
In popl.llation will he IncreasIngly dependent on larelgn migration. (Source: USC, Popl.llatlon !/oinamic5
GrOllfls, AprIl21J1l].
There Is lillie reason to See a major shift in domestic mlgntioRwith C8"'omla'. high cost and ~igh
unemployment rate. That 'eBVlU 10reiRn mlgratlon.s the critleal component source of long-term
population growth. The most dynamic .0Urce for calilornla's srowth has been Immigration from Me_ico.
hoth legal and illegal. All obser~.rs (The Dept 01 Homeland Security, the Pew Charitable Tnun Hispanic
Center, and the Me~lcan Migration Proja.t at Princetonl agree thaI net Imml.eratlon from Me1<ico hu
been down dramaticallv In retent years with the strltter enforcement elborder orossing and the
p rOlanged rece.slon In the us. Pew estimate. that "e ill"gallmmlgrant pop~latlon In the US fell bV
some 7% between 2007 and 2010. The imponont debate about the future is whether this I •• bwiness
cvcle phenomenon or part 01 a longer term trend.
The group that has the be.tdat. source and takes the longer term look is the Mexican Migration Prolect
at Princeton. For dECades they have been tracking migration pattern' from Mexico and doing annual
survevs of thousands of families from migration centers In Mexico. They foondthat the percent 01 nrst
time Immigrants from the Mexican communities of highest immiBration fell from 1.Z'lI. of adults In 2000
to 0.6% in 2005 to lero In 2010. TheV Identify that the changes are due to Malcan demographic and
economic factor5 as much liS from U.S. conditions. Thllyldentlfied five internal factor. of change In
Mexico:
• Fertility roles are falling dtllmlltically from S.8 birth. , .. ,-women In 1S70 to 2.Blo 1995 to 21n
2010 IreJllaceme~t level).
• The number of young Plople enterins the labor market on fallen from One million a vear ill tne
IS90s to 700]( lodav and demographic factors will bring Ihil down Iv abouI3QilK In 2030, Mt
enoush to meet klca I job needs.
• The ral. 0/ college ,,\lend"nee .nd college completion has doubl.d oVer tne Jalt dec~de. raising
the Ciresr patn of an increasing share of voung w<>rkers.
• The wage disparitv betWl"en Mexico and the U.5.ls narroWing sharplv with .""rI8B wage gaps
falling from 10:1 in the 1960. 10 some 3.7:1 In the e.rlv 20005.
• The cost of migration h •• rken dramatlcallv lor Utega! entrants, further narrowing the ear~lnBS
gap.
1\11 of these factors point to the ~eed. at the least, of looking at alternative scenarios of population
growth In california that are more $en.itlve to possible underlying chanlll's In migration pattern'.
5
Sources of Demogl'aphic projections about California
US Bureau 01 the Censuslresponslble for the decennial census and does updated .stlmates each vear of
state populations-has been much cioser to actual numbers than the Cal Dept, of Finance)
California Department of Finance (responsible for state population .nimales between the Census
vealS-forecasts used as IteV source for state government planning). Statewide estimates for 2010
(made In 2009) were 41% higher than the 2010 Census numbers for the state, 83% over for the nine Bay
Area counties and 137% higher for the three West Bav counties.
Ronald Lee, UC Berkelev, Center for Economl~ and DomolP'aphip of Aling, "Special Report! The
Growth & Aging of Callfurnla's Population", 2003 (an Important repon that identified the det.ned
assumptions that went into the Department of Finance's long·term projection.).
Hans Johnson, Public PollcV Instltut.e of Callforn/a, "callfornl~ 2025: Takfng on the Future",ChaptEr 2
'californi.'s Population In 2025' (a report that gathered projections from eight academic and
government sources]. JohllSOn concluded that ·poPlJlatlon protections for cailfornlaar. especially
diffkult. . .1n addition 10 overweightins contemporary trends, foreca,ters are notoriouslv bad at
predict Ins fundamental demographic Shifts .. , for these reasons, planners should consider alternative
population scenarios: Pages17-1B.
John pltldn & Dowell Myer., USC Population Dynaml~ lIeseBrdJ Group, "The 2010 Census Benchmark
for California'. Growing and Changing Population", February J011; "Projections of the Population of
caJifornla by N.~Vltv and Voarof Entry to the U.S:, Aprfl2, 2011. ,Pltkln and Mvers had the 10 wert of
the foreca,l$ in the 200S study-though stlll overestimating growth by 16%, They .re worldng with the
California Department of Finance on components for a new lunger.term forecast; thEv ale .tm assuming
a net Imml~ratlon number of 160,000 holding steady In the futur •• ]
S"'"e LollY, Center for the Continuing Studv of the callfDrnla Economy
UClA Anderson Forecasting Project
Grell Schmid
Detotter 2011
FIGURE 3: Regional Land Use and Transportation SCS
ACHIEVING STATEWIDE GHG REDUCTION TARGETS
Tons'
Required Reductions: CD 2020 Emission, ................................. 507
Bay Area Regional Contribution
Scenarios _~"'I 0%
Year Tons·
By 2020 ........... 80
By 2050········· 715"
850
800
750
700
650
600 -550 c
C!l
C > 500
'5 450 0-427 w
'"' 400 0 U 350
'" c 300 0 l-
v 250 '£
80%
CI) 200 :E
c 150 ,Q
~ 100
50
1990 1995
o Target 2020 Emission, 11990)················427 7.0'Yp Current Regional Plans -----::Ii;;
7.'I"k Outward Growth-----1I:~
8.2'7'0 Initial Va.sion/Core ConcenfTation
@ Foreca,t 2050 Emission, ...................... 800" o Target 2050 Emissions 120"10 of 1990) ....... 85
® Target 2035 Emission, r,nterpolated) ······275 9.1% FocuseC Growth --------'
"'Million Metric Tons C02 Equivc~nt
.. Estimate based on Colifomio Council on
Science end Technology Report, 2011
2000 2005 2010 2015
9.4% Constrained Core Concentration
S07 CD
275i®
2020 2025 2030 2035 2040 2045
Projected Land Use & Transportation Emissions Reductions
REGIONAL LAND USE & TRANSPORTATION (SCS)
LOW CARBON FUEL STANDARDS
IMPROVED FUEL EFFICIENCY [PAVLEY I & II)
; NON-TRANSPORTATlON EMISSIONS REDUCTION
ACTUAL/PROJECTED EMISSIONS
15%
5 0
2050
Comparison of Department of Finance (DOF) Interim Projections released on May 2012 and the Preferred Sustainable Community Strategy (SCS) Projections released on May 2012
Department of Finance (DOF) Interim Population Projections for California and Counties: July 1, 2015 to 2050 in 5‐year Increments
DOF 'Pop. Growth
2000 2010 2015 2020 2025 2030 2035 2040 2045 2050 2010 ‐ 2040
Bay Area Region 6,805,677 7,165,778 7,365,127 7,593,463 7,805,868 8,023,484 8,240,104 8,433,609 8,585,622 8,726,594 1,267,831
Alameda County 1,448,768 1,513,251 1,547,734 1,584,797 1,619,555 1,650,596 1,678,473 1,705,642 1,722,773 1,734,695 192,391
Contra Costa County 953,675 1,052,024 1,102,534 1,161,014 1,209,433 1,263,049 1,323,005 1,381,576 1,438,880 1,496,207 329,552
Marin County 247,424 252,727 253,757 255,502 257,117 259,060 261,982 264,910 267,590 270,275 12,183
Napa County 124,601 136,659 141,951 146,582 152,439 158,538 165,088 171,625 178,478 183,352 34,966
San Francisco County 778,942 807,048 813,090 820,135 826,850 834,693 842,065 845,750 844,247 840,712 38,702
San Mateo County 708,384 719,467 735,025 751,480 765,495 776,862 786,730 791,781 793,885 794,162 72,314
Santa Clara County 1,687,415 1,787,267 1,846,126 1,917,070 1,980,661 2,048,021 2,110,906 2,164,936 2,195,432 2,220,174 377,669
Solano County 395,991 413,154 428,106 446,513 468,039 490,381 512,695 533,041 552,869 574,705 119,887
Sonoma County 460,477 484,181 496,803 510,370 526,280 542,284 559,160 574,347 591,469 612,312 90,166
Projections Prepared by Demographic Research Unit, California Department of Finance, May 2012
Draft Sustainable Community Strategy (SCS) Population Projections for Bay Area Counties: 2010 to 2040
SCS 'Pop. Growth
2000 2010* 2015 2020 2025 2030 2035 2040 2045 2050 2010 ‐ 2040
Bay Area Region 6,784,400 7,150,739 7,787,000 8,133,885 8,497,000 9,299,159 2,148,420
Alameda County 1,510,271 1,988,032 477,761
Contra Costa County 1,049,025 1,334,968 285,943
Marin County 252,409 285,317 32,908
Napa County 136,484 163,609 27,125
San Francisco County 805,235 1,085,656 280,421
San Mateo County 718,451 906,070 187,619
Santa Clara County 1,781,642 2,425,645 644,003
Solano County 413,344 511,482 98,138
Sonoma County 483,878 598,380 114,502
Projections Prepared by ABAG, May 2012
* 2010 SCS based on actual 2010 Census counts
Percentage Difference between 2010 and 2040 DOF Interim and SCS Population Projections for Bay Area, comparing SCS to DOF Interim Population Projections May 2012
2040 Pop. Difference SCS
& DOF
2000 2010 2015 2020 2025 2030 2035 2040 2045 2050 2040
Bay Area Region ‐0.3%‐0.2% 2.5% 4.2% 5.9% 10.3% 865,550
Alameda County ‐0.2%16.6% 282,390
Contra Costa County ‐0.3%‐3.4%‐46,608
Marin County ‐0.1%7.7% 20,407
Napa County ‐0.1%‐4.7%‐8,016
San Francisco County ‐0.2%28.4% 239,906
San Mateo County ‐0.1%14.4% 114,289
Santa Clara County ‐0.3%12.0% 260,709
Solano County 0.0%‐4.0%‐21,559
Sonoma County ‐0.1%4.2% 24,033
Percentage Difference 2010‐2040 Projected Population Rate of Growth, comparing SCS to DOF Interim Population Projections May 2012
2010 ‐ 2040 Net Gain
Difference SCS & DOF
2000 2010 2015 2020 2025 2030 2035 2040 2045 2050 2010 ‐ 2040
Bay Area Region 48.8% 57.0% 69.5% 880,589
Alameda County 148.3% 285,370
Contra Costa County ‐13.2%‐43,609
Marin County 170.1% 20,725
Napa County ‐22.4%‐7,841
San Francisco County 624.6% 241,719
San Mateo County 159.4% 115,305
Santa Clara County 70.5% 266,334
Solano County ‐18.1%‐21,749
Sonoma County 27.0% 24,336
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