HomeMy WebLinkAboutStaff Report 3128
City of Palo Alto (ID # 3128)
City Council Staff Report
Report Type: Consent Calendar Meeting Date: 9/10/2012
Summary Title: City Response to Adopted ABAG RHNA Allocation - contd.
Title: Approval of City Response to the Adopted Regional Housing Needs
Allocation (RHNA) for the 2014-2022 Cycle(continued from September 4,
2012 Council Meeting)
From: City Manager
Lead Department: Planning and Community Environment
Recommendation
Staff recommends that the City Council approve and direct the Mayor to execute the attached
letter (Attachment A) to the Association of Bay Area Governments (ABAG) regarding the City’s
response to the adopted Regional Housing Needs Allocation (RHNA) for the 2014-2022 Cycle.
Discussion
The Council continued this item from its September 4, 2012 agenda. This report provides
additional information in response to Council questions regarding the RHNA Allocation appeal
process. The Council particularly asked whether the draft letter is the City’s final opportunity to
“appeal” the allocations or whether there will be subsequent chances for appeal. Staff has
concluded, based on the information below and contact with ABAG, that the current response
period (through September 18) is intended to provide jurisdictions with an opportunity to
request revisions, and that appeal is not yet timely. According to State law, ABAG has 60 days
following the “revision and comment” period to respond to comments, and then will issue its
final determinations. Cities and counties will then have another 60-day period to formally
appeal the ABAG allocations. The following summarizes State law.
Appeal Process
Each regional council of governments (i.e. ABAG in Palo Alto) is free to establish its own
deadlines for assigning and appealing RHNA allocations, provided this schedule is consistent
with the overall RHNA framework established in State Housing Element Law. Government Code
Section 65584.05 establishes a two-part process for appealing the RNHA allocation. The first
step is that the City may request “a revision of its share of the regional housing need.”
Government Code Section 65584.05(b). The statute also specifies that this request “must be
based upon comparable data available for all affected jurisdictions and accepted planning
methodology, and supported by adequate documentation.” Under the statute, ABAG has 60
days after the request is submitted to either “accept the proposed revision, modify its earlier
determination, or indicate, based upon the information and methodology described in [State
law], why the proposed revision is inconsistent with the regional housing need.” Government
Code Section 65584.05(c). Second, if ABAG does not modify the proposed revision to the
satisfaction of the requesting party, the City may file a formal “appeal.” Government Code
Section 65584.05(d). The two grounds for appeal are specified in the statute as follows:
(1) ABAG failed to adequately consider the information submitted under State law, or a
significant and unforeseen change in circumstances has occurred in the local jurisdiction that
merits a revision of the information submitted pursuant to that subdivision.
(2) ABAG failed to determine its share of the regional housing need in accordance with the
information described in, and the methodology established under State law.
Timeline
The statutory scheme requires ABAG to conduct a public hearing on all appeals within “60 days
after the date [ABAG] established to file appeals.” Government Code Section 65584.05(e).
Consistent with this statute, ABAG has established a comprehensive schedule for the RHNA
allocation. In particular, ABAG has scheduled September 18, 2012 as the “Deadline for Local
Requests for Revisions to Draft Allocation” and January 11, 2013 as the “Deadline for Local
Appeals to Draft Allocation.” (Exhibit B.) This schedule is publicly posted on ABAG’s One Bay
Area website. On July 25, 2012, the City received a letter from ABAG stating: “The deadline to
submit an appeal or to request for [sic] a revision is September 18, 2012.” (Note this has created
confusion because under the statutory scheme and published schedule, September 18, 2012
was the deadline for filing a “request for revision”, not an appeal. Staff has verified with ABAG,
however, that they intend to follow the statutory two-step process nevertheless.)
A very similar process was conducted for the previous RHNA cycle where Palo Alto filed a
request to revise its RHNA share, ABAG partially granted this request by reducing the share and
Palo Alto elected to further appeal and ABAG ultimately denied the appeal.
Revised ABAG Letter
To better delineate between the “request for revision” and “appeal” City staff has updated the
ABAG letter (Attachment A), particularly the opening paragraph. Based on both the statute and
ABAG’s posted schedule, staff believes the City’s deadline for appeal of the Draft Allocation will
be January 11, 2013. Staff plans on returning to Council in November/December prior to
January 11 for further direction. Staff believes the current letter adequately preserves the
City’s formal appeal rights for the second phase of the two-step process.
Attachments:
Attachment A: Revised Draft RHNA Allocation Response Letter (DOCX)
Attachment B: RHNA Schedule 2014-2022 (PDF)
Attachment C: Staff Report and Attachments, City Council Meeting of September 4,
2012 (PDF)
Prepared By: Aaron Aknin, Assistant Director
Department Head: Curtis Williams, Director
City Manager Approval: ____________________________________
James Keene, City Manager
Page 1 of 3
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
Re: City of Palo Alto Request for Revision to Adopted Draft 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. While the adopted allocations appear
to have taken into consideration some of the concerns and comments expressed by member
jurisdictions, the target projections are still unrealistic. In Palo Alto, the built-out nature of the
city and multiple school, service and infrastructure constraints 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 (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 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
Page 2 of 3
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 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 official is 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.
Page 3 of 3
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
2014‐2022 RHNA / SCS Schedule
This schedule aligns the milestones for the RHNA with those of the SCS/RTP. The dates for each milestone take statutory
requirements for public comment, local government response, etc. into account.
ABAG RHNA
Milestones
SubRHNA
Milestones
SCS/RTP
Milestones
1 Subregions Form Mar. 2011
2 Present SCS Alternative Scenario Concepts for Initial Review June 10, 2011
3 Release Block Grant Concept July 2011
4 Review RHNA Methodology Concepts at ABAG Executive Board Sept. 2011
5 Transportation Project Assessment to MTC Planning Committee Oct./Nov.
2011
6 Release SCS Alternative Scenario Results for Public Review Dec. 2011
7 County Public Workshops Jan. 2012
8 Dept. of Housing and Community Development (HCD) Issues RHND1 Feb. 24, 2012
9 Release Draft SCS Jobs‐Housing Connection Scenario & OneBayArea
Grant Proposal
Mar. 2012
10 Release Preliminary Draft RHNA Method Mar. 2012
11 MTC and ABAG Adopt SCS Jobs‐Housing Connection Scenario &
OneBayArea Grant
May 2012
12 EIR Kick‐Off (Scoping) Public Meeting May 2012
13 ABAG Releases Draft Method and Assigns Preliminary Subregional Shares2
Action to be taken by ABAG Executive Board
May 17, 2012
14 Public hearing on Draft Method and Preliminary Subregional Shares at
ABAG Regional Planning Committee3
June 6, 2012
15 ABAG Adopts Final Method
Action to be taken by ABAG Executive Board
July 19, 2012
16 ABAG Releases Draft Allocation4
Action to be taken by ABAG Executive Board
July 20, 2012
17 Deadline for Local Requests for Revisions to Draft Allocation5 Sept. 18, 2012
18 Release Draft SCS/RTP and Draft EIR Nov. 2012
19 Release Draft Air Quality Conformity Analysis Jan. 2013
20 ABAG Responds to Requests for Revisions6 By Nov. 15, 2012
21 Deadline for Local Appeals to Draft Allocation Jan. 11, 2013
22 Respond to Comments on Draft SCS/RTP EIR and Air Quality Conformity
Analysis
Feb. 2013
23 Public Hearing on Local Appeals of ABAG Response to Revision
Requests7
Between Feb.
20 ‐25, 2013
24 Deadline for Subregions to Submit Final Allocation and Resolution of
Consistency with the SCS to ABAG for Review and Possible Consultation
Feb. 1, 2013
25 ABAG Issues Final Allocation8 April 12, 2013
26 Adopt RTP/SCS, Certify EIR, Make Conformity Determination April 2013
27 ABAG Adopts Final Allocation at Public Hearing9
Action to be taken by ABAG Executive Board
May 16, 2013
28 Local Governments Adopt Housing Element Revision Oct. 2014
1 The date for HCD to determine the RHND has been set at this date by mutual agreement between ABAG and HCD.
2 The survey of local governments regarding the statutory RHNA factors must be conducted within the 6 months prior to this date.
GC §65584.04(b)
3 GC §65584.04(h) requires a public hearing and 60‐day comment period on the draft method.
4 There is no statutory requirement that there be a gap between adoption of the final method and issuance of the draft RHNA.
5 Local jurisdictions have 60 days to review allocation and request revisions. GC §65584.05(b)
6 ABAG has up to 60 days to respond to requests for revisions, may be compressed. GC §65584.05(c)
7 A hearing must take place no earlier than 40 days and no more than 45 days after the deadline to file appeals. GC §65584.05(e)
8 Must occur within 45 days after completion of appeal process. Could be compressed to 0 days. GC §65584.05(f)
9 Must occur within 45 days of issuance of final allocation. No minimum interval required. GC §65584.05(h)
Updated May 1, 2012
City of Palo Alto (ID # 3084)
City Council Staff Report
Report Type: Consent Calendar Meeting Date: 9/4/2012
Summary Title: City Response to Adopted ABAG RHNA Allocation
Title: Approval of City Response to the Adopted Regional Housing Needs
Allocation (RHNA) for the 2014-2022 Cycle
From: City Manager
Lead Department: Planning and Community Environment
Recommendation
Staff recommends that the City Council approve and direct the Mayor to execute the attached
letter (Attachment A) to the Association of Bay Area Governments (ABAG) regarding the City’s
response to the Adopted Regional Housing Needs Allocation (RHNA) for the 2014-2022 Cycle.
Background
On July 19, 2012 the ABAG Executive Board adopted the Regional Housing Needs Allocation
(RHNA) methodology for the 2014-2022 housing cycle (Attachment B). 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 (Attachment C). The City’s number is up
slightly from the ABAG’s most recent prior projection, but is reduced substantially from earlier
iterations. The allocation is also significantly less than the 2,860 housing units assigned during
the 2007-2014 period. That said, it still represents a substantial number of units for a built-out
city.
A new and important aspect of this RHNA cycle is that the cycle does not stand alone. It is an
integral part of, and must be consistent with, the Sustainable Community Strategy (SCS) for the
region. The SCS attempts to guide Bay Area growth through the year 2040. This planning effort
is intended to implement Senate Bill 375, which expects to reduce greenhouse gas (GHG)
emissions by supporting higher intensity development near transit along with substantial
increases in transportation investments. As part of the SCS process, the Association of Bay Area
Governments (ABAG) and the Metropolitan Transportation Commission (MTC) selected the
Draft Preferred Land Use Scenario, known as the “Job-Housing Connection Strategy.” This
scenario assumes that the Bay Area will need to accommodate 1.1 million new jobs and
660,000 new housing units through the year 2040. The preferred scenario anticipates as many
as 29,650 new jobs and 7,410 new housing units in the City of Palo Alto over that time period.
The City has until September 19, 2012 to appeal the RHNA allocation determination. ABAG,
however, is requesting responses by September 11 to accommodate the ABAG Executive Board
meeting schedule. Given the reduction in overall units relative to earlier projections, staff
believes that an appeal may not be necessary for this cycle, but that the City should register
some of its continuing concerns. These concerns relate to continued objections to long-term
population and growth projections, as well as to the proposed allocations for housing on
unincorporated Stanford lands.
Discussion
A draft letter is provided as Attachment A. Based upon past input from the Regional Housing
Mandate Committee (RHMC) and the City Council, the letter focuses on four key points:
1. The regional forecast of jobs and housing for the region, including the inconsistency
with recent historical patterns, and the City’s concerns about the implications of
overstated growth. The overall projections continue to ignore the updated
demographic forecasts from the State Department of Housing (Population Projections,
May 2012). For the upcoming housing cycle, ABAG reduced the overall housing
numbers, primarily based on the depressed statewide housing market and glut of
vacant, foreclosed homes. However, long-term growth assumptions essentially
remained the same. This creates the effect of “back-loading” the housing numbers, and
creating unreasonable and unachievable housing mandates in the current and future
housing cycles. The SCS process will allow long-term growth projection adjustments on a
periodic basis, but staff believes it is appropriate to continue to register the City’s
concerns and oppositions to the projections. The letter therefore encourages ABAG to
adjust future projections so they are more consistent with historical growth patterns
and to consider a range of forecasts, as well as to recent lower forecasts by the State
Department of Finance (DOF). The City’s March 5, 2012 letter to ABAG and
Councilmember Schmid’s projections analysis have been attached to the letter, along
with a chart staff prepared comparing DOF projections to ABAG projections for the
Sustainable Communities Strategy.
2. The proposed RHNA allocation only assigns 77 housing units to the County of Santa
Clara (unincorporated area), while Stanford University’s General Use Permit (GUP) with
Santa Clara County allows for up to 1,500 more residential units to be built on Stanford
lands within the SCS timeframe. The letter acknowledges that those units have not been
allocated to Palo Alto, but that 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, the approximate 350 units on two sites on Quarry
Road just west of El Camino Real would appear appropriate to include somewhere in the
housing analysis. City staff has met with staff from the County and Stanford to evaluate
the potential for an allocation of those units or some portion thereof and County
agreement to a “transfer” of a similar number of units from the City of Palo Alto. The
letter to ABAG identifies the issue (previously noted in a June 28, 2012 letter to ABAG
included as Attachment D) and requests that ABAG remain open to such a transfer. Staff
does not believe that ABAG would alter the overall allocation in the absence of
agreement between the City, County, and Stanford. Those adjustments do not have to
meet the September 18 deadline for responses, so long as the net total number of units
between the jurisdictions does not change.
3. The letter encourages ABAG to provide flexibility within the SCS for local jurisdictions to
provide further means of reducing land use/transportation related emissions. Detailed
examples of Palo Alto GHG reduction policy initiatives were included in the March 5
correspondence to ABAG, and the conclusion provides a list of these initiatives for
future reference.
4. The City continues to have concerns regarding the potentially negative environmental,
school capacity and infrastructure impacts the overstated housing mandates may
create. Additionally, the City will be conducting an environmental review to assess the
full impacts of these mandates.
Regional Housing Mandate Committee (RHMC) Comments
The Regional Housing Mandate Committee met on August 28, 2012 and provided comments on
the draft letter to ABAG. The comments are included in the summary above, and will be
incorporated into the final, draft letter presented to the City Council for review. In summary,
the comments are as follows:
Additional wording should be added stating that the overall projections continue to
ignore the updated demographic forecasts from the State Department of Finance
(Population Projections, May 2012) and therefore overstate growth for the overall SCS
period, through 2040.
The letter should specify that the overstated growth projections create an unrealistic
and unachievable housing mandate for the current and future housing cycles.
Additional wording should be added stating that the City encourages ABAG to regain
public confidence of its numbers by acknowledging the adaptations already made the
Department of Finance to the changing State of California demographics.
Wording should be revised to clarify that City staff has met with staff from the County
and Stanford to discuss the possibility of a joint agreement to transfer a similar
allocation of units from the City of Palo Alto to the County of Santa Clara.
The concluding paragraph of the draft, which encourages ABAG to provide greater
flexibility in GHG reduction strategies and details various GHG emission reduction
strategies the City has adopted, should be made into the third bullet point to provide
greater emphasis.
A fourth bullet point should also be added stating that the City continues to have
concerns regarding the potential negative environmental, school capacity and
infrastructure capacity impacts the overstated housing mandates may create, and that
the City will be conducting an environmental review to fully assess the impacts of these
mandates.
An additional document, prepared by Planning staff and which details the discrepancies
between the Department of Finance projections and Sustainable Community Strategy
projections, should be attached to the letter.
The Committee voted 4-0 to recommend that the Council approve the letter as modified.
Next Steps
ABAG has requested responses by September 11, so they may be included for the Executive
Board’s meeting on the 18th. Staff expects to conclude discussions with the County and
Stanford in September or October, but any adjustments resulting from those discussions could
still be accommodated, so long as the net total number of units does not change. The current
draft Housing Element has been submitted to the State, and a response is expected in October.
Work on the next Housing Element should proceed quickly following the certification of the
current Element, hopefully in early 2013.
Policy Implications
The Regional Housing Needs Assessment and Sustainable Communities Strategy relate directly
to the City’s Comprehensive Plan, zoning, and transportation policies, so that a key objective of
the City is to assure that the regional plan continues to allow for implementation of those goals,
policies, and codes.
Resource Impacts
Staff had retained planning and economic consultants for an additional $25,000 for economic
consultant services to provide input to the City’s response to the Alternative Scenarios and
follow-up regarding the specific impacts and options for the City. Given the recent reduction in
overall housing units, the consultant’s services are on hold, and therefore no additional funding
is required at this time.
Environmental Review
No environmental review is necessary by the City to comment on the proposed allocation. An
Environmental Impact Report is expected to be prepared by ABAG and MTC for the Preferred
Land Use Scenario of the Sustainable Community Strategy. Environmental review will be
required for the City’s Housing Element proposed to address the allocations.
Attachments:
Attachment A: Draft RHNA Allocation Response Letter (see note) (PDF)
Attachment B: July 25, 2012 Letter from ABAG re: Final RHNA Allocations and Timeline
(PDF)
Attachment C: February 24, 2012 HCD RHND Letter to ABAG (PDF)
Attachment D: June 29, 2012 Letter to ABAG re: County RHNA Allocation (PDF)
Prepared By: Aaron Aknin, Assistant Director
Department Head: Curtis Williams, Director
City Manager Approval: ____________________________________
James Keene, City Manager
Page 1 of 3
September 5, 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 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 adopted allocations appear to
have taken into consideration many of the concerns and comments expressed by member
jurisdictions. The target projections will be difficult to attain in Palo Alto, however, given the
built‐out nature of the city and multiple school, service and infrastructure constraints and
impacts. The purpose of this letter is to reiterate 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 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 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
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
Page 2 of 3
Department of Finance to the changing State of California demographics. Furthermore,
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
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.
Page 3 of 3
Thank you once again for the opportunity to comment on the adopted RHNA methodology for
the 2014‐2022 Housing Cycle. 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
March 5, 2012
Mr. Mark Luee, President
Association of Bay Area Govemments
Joseph P. Bort Metro Center
P.O. Box 2050
Oakland, CA 94607-4756
Ci!JgfPaloNto
Office of the Mayor and City Council
Re: City of Palo Alto Comments on Sustainable Communities Strategy (SCS) Alternative
Scenarios
Dear Mr. Luce:
Association of Bay Area Govemments (ABAG) staff has requested local agency comments on
its proposed land use Altemative Scenarios developed as a part of the One Bay Area Sustainable
Community Strategy (SCS). We look forward to the fUlther discussion and refinement of the
Preferred Scenario before the final Regional SCS is completed early in 2013. However, at this
juncture we believe it is necessary for the City to express its concerns regarding the SCS
Altemati ve Scenarios and the related regional jobs and housing forecasts, and to suggest
altcl11ative approaches to the Preferred Scenario.
This letter provides the City of Palo Alto's (City) comments, which have been formulated
following the City'S considerable review and analysis of the Alternative Scenarios and related
regional job and housing forecasts. Tbe City acknowledges and appreciates the fact that the SCS
process will continue following release of ABAG's Preferred Scenario, scheduled for March 8,
2012. In summary, the City's concerns are as follows:
• The City of Palo Alto has been a national leader in implementing policies and programs that
reduce greenhouse gas (GHG) emissions and the effectiveness of these efforts should be
considered as a part of the SCS and achieving regional GHG emission reduction targets.
• The regional forecast 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 distinct possibility that actual growth rates in the Bay Area over the
next 30 years may be lower and should phase job and housing allocations and
implementation accordingly.
• Palo Alto's allocation of jobs and housing units under all of the Alternative Scenarios is
excessive by reference to its historical growth trends and development capacity; these
allocations should more accurately consider policy constraints, market feasibility, and the
high infrastructure costs and local fiscal impacts of such intensive redevelopment.
Prh~h:J wHh mY-\)lIsed inks (In 11)0';1" recycled rarer pro(e~8ed without chlorine.
P.O. Box 10250
Palo Alto, CA 94303
650.329.2477
1 650328.3631 fax
ABAG: SCS Alternative Scenarios
March 5, 2012
• The land use changes contemplated in the SCS Alternative Scenarios have a propottionately
small contribution to achieving AB32/SB375 GHG reduction targets and there are very
limited differences shown between the Alternative Scenarios; the considerable effort and
investment needed to affect these land use changes should be re-directed to more cost
effective regional and local GHG reduction measures.
While the City retains serious concerns regarding the Regional Forecast of jobs and housing and
also the allocation of future development under the Alternative Scenarios, Palo Alto is firmly
committed to doing its share to achieve the State-mandated (AB32/SB375) GHG reduction
targets. The measures already adopted by the City provide ample evidence of this commitment.
Going forward, the City expects to cooperate with ABAG and our other regional pattners in the
future efforts needed to achieve substantial reductions in GHG emissions through realistic and
achievable regional and local policies, programs, and investments.
The following items elaborate on the summary points listed above.
1. The City of Palo Alto has been a national leader ill implementillg policies and programs
that reduce GHG emissiolls. '
Over the past decade, the City of Palo Alto has adopted a range of policies, programs and
projects to reduce GHG emissions, focused upon improving energy efficiency, enhancing multi
modal transportation alternatives to the single-occupant vehicle, and creating walkable, mixed
use districts. Implementing these policies, programs, and investments the City has become a
national leader in reducing GHG emissions. Some of the key programs include:
a. City of Palo Alto Climate Protection Plan (CPP): The CPP, adopted by the City Council in
December 2007, includes goals for the reduction of CO2 from a 2005 baseline level as a result of
changes in City operations and from CO2 reduction efforts within the community.
• The City has surpassed its short term goal of a 5% reduction in emissions by 2009 for a
total reduction of 3,266 metric tons of CO2.
• By 2020, the City and community will reduce emissions by 15% from 2005 levels, equal
to 119,140 metric tons of CO2, consistent 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 years in advance of the State requirement.
• For FY2011, renewable electricity supplies account for 20% of the City's needs.
• Contracts are in place with suppliers to provide 26% of the City's electrical needs as
renewable by FY2014 with the potential to reach 30% from contracts that are still under
negotiations.
• CUiTently, 24% of the City's customers participate in the Palo Alto Green program,
paying a surcharge on electric service to support renewable electricity supplies.
• The City's Utilities Department is preparing a plan to be released later this year for the
electric portfolio to be carbon neutral.
2
ABAG: SCS Alternative Scenarios
March 5, 2012
c. Utility Programs to Reduce Emissions: In addition to providing clean energy options for its
customers, the Utilities Department offers programs such as rebates, assistance, information, and
workshops to help customers increase electricity efficiency and cost savings that reduce
emissions. These successes of these programs are measurable: In FY20 II, Palo Alto customers
reduced CO2 emissions by 12,557 tons through the use of electric and natural gas efficiency
programs, incentives for solar photovoltaic (PV) and solar hot water systems, and other program
efficiencies.
d. Leadership in Green Building and Sustainable Design: In FY 2009, the City Council adopted
the City's Green Building Ordinance to build a new generation of efficient buildings in Palo Alto
that are environmentally responsible and healthy places in which to Jive and work. This program
was one of the first in the nation to mandate green building requirements and certifications for
virtually all public and private buildings.
• In FY 20 II , the City initiated the first LEED-ND pilot program (LEED for
Neighborhood Development) in the United States for assessing a development site's
ability to qualify as a sustainable neighborhood project, including features that reduce
dependence on automobile use, increase walkability, and encourage healthy li ving.
• The City also rolled out energy use disclosure requirements for existing buildings
undergoing small renovation work to better understand the existing buildings' current
performanee and areas where education, policy, and programs can be influential in
reducing energy usage.
• The amount of CO2 diverted from the environment has increased sinee the adoption of
the 2009 ordinance and programs. In 20 I 0, the first full year of the ordinance, CO2 was
reduced by approximately 1,013 tons. In 2011, C02 was reduced by approximately 2,818
tons, a 178% increase over the previous year.
• Prior to the City's ordinance, as few as six green building projects existed throughout the
City. By the end ofFY 2011, more than 240 green buildings have been completed or are
under construction.
'e. Affordable Housing: The City of Palo Alto has been a leader in providing for affordable
housing in one of the most expensive housing markets in the nation.
• In 1974, Palo Alto became one of the first cities in the United States to adopt an
inclusionary housing program that required the provision of below market rate (BMR)
residential units in new multiple-family dwelling projects.
• Today, the City oversees 239 ownership units and 198 rental BMR units that are
available to qualified applicants. As the cost for housing in Palo Alto continues to
increase, the value of these affordable units to provide hOUSing within the urbanized Bay
Area has also increased. BMR housing provides greater opportunity for lower income
families to Jive closer to their jobs and utilize public transit.
• Recently, Palo Alto welcomed two new BMR housing projects, including the Tree House
Apartments, a 35-unit complex with a Green Point Rating of 193 (the highest score in
Palo Alto for multiple family housing) and Alta Tone, a 56-unit complex for very low
income seniors.
• Construction is underway at 801 Alma Street, a 50-unit family affordable project
immediately adjacent to CalTrain and within walking distance to shops and services on
University Avenue in downtown.
3
ABAG: SCS Alternative Scenarios
March 5, 2012
f. Higher Density Land Uses Near Transit: The City's Comprehensive Plan designates two
areas of the City (downtown and California A venue) as appropriate for 'Transit Oriented
Residential," in a 2,OOO-foot radius of the City's two Caltrain stations. These areas are identified
for higher intensity residential and mixed-use development focused around a walkable, bieyc\e
friendly environment.
• In 2006, two years before the adoption of SB375, the City Council adopted the Pedestrian
and Transit Oriented Development combining district (PTOD) for the area around the
California A venue CalTrain station. This district allows for residential densities at 40
units per acre, increased floor area ratios, increased building heights, reduced parking
requirements, and density bonuses for the provision of BMR housing in mixed-use and
multiple family projects.
• In 2007, Council supported the designation of this area as a PriOlity Development Arca
(PDA) as part of ABAG's FOCUS program that would eventually evolve into Plan Bay
Area. This land use planning effort is one example of a pattern of early-adoption
decisions made by the City Council to address growth, transit and greenhouse gas
emissions within our community.
• The Council has directed that housing sites proposed in the City's Housing Element
should be focused in transit-proximate areas, and that increased height and intensity may
be considered in those locations.
g. Transportation Policies and Projects: The City of Palo Alto has developed transpOltation
policies, programs and projects to implement a transit-oriented, walkable and bicycle-friendly
vision that demonstrate leadership of the "Complete Streets" concept promoted by the
Metropolitan Transportation Commission. Some of these key recent measures include:
• Bicycle and Pedestrian Transportation Plan: The City is completing its updatcd plan to
accommodate enhanced bicycle and pedestrian facilities and programs, and to elcvate the
City's Bicycle-Friendly Community status from Gold to Platinum Icvel.
• Stanford AvenuefEl Camino Real Intersection Improvements: The City has recently
completed improvements at this intersection to enhance safety for pedestrians and
cyclists, including children who use the intersection as a route to school, and to upgrade
the aesthetic qualities of the intersection and of El Camino Real. Wc expect thc project
will serve as a template for improving intersections throughout the Grand Boulevard
corridor.
• Safe Routes to School: The City's Safe Routes to School program has resulted in a
phenomenal increase in school children bicycling and walking to school over thc past
decade. In the 2011 fiscal year, City staff coordinated 140 in-class bike and pedestrian
safety education programs in 12 elementary schools, reaching 4,250 students. Recent
surveys of how children usually get to elementary school showed an average of 42%
choosing to walk, bike or skate to school, compared to a national average of only 13%
(figures for middle schools and high schools are even greater). A reccnt grant will allow
the City to prepare Safe Routes maps for every elemcntary school in the city as well as to
expand our education cuniculum into middle schools and to adults.
• Traffic Calming on Residential Arterials: The City has an ambitious traffic calming
program along "residential arterials" in efforts to support our Safe Routes to School
program and to enhance bicycle and pedestrian safety. In parricular, 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 similar to those prior to the traffic
calming improvements.
• Bicycle Parking Corrals: The City has recently installed six green "bicycle parking
corrals" in the Bay Area, with each corral 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 Califoll1ia Avenue areas.
• Califoll1ia A venue Streetscape Improvements: A pending grant would support the
substantial upgrade of Califoll1ia Avenue to a more pedestrian and bicycle-friendly
roadway, incorporating "complete street" principles, and also enhancing access to the
Califoll1ia Avenue Cal train station.
• Local Shuttles: The City, with support from the Caltrain JPB, offers local shuttle services
for commuters, school children, seniors and others between points of interest within the
city. These shuttles futther reduce the need for single-occupant vehicle trips and reduce
traffic congestion and parking needs.
Accordingly, the City of Palo Alto requests that ABAG consider the effectiveness of these local
GHG emission reduction effOlts, 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. The Regional Forecast of jobs alld hOl/sillg being considered as part of the SCS appears to
overstate future growth in the Bay Area.
The regional jobs and housing forecast used for the Altell1ative Scenarios is lower than the
forecast for the Initial Vision Scenario and the Core Concentration Unconstrained Scenario,
reflecting comments received from the local agencies following review of the Initial Vision
Scenario. However, in the City of Palo Alto's view, the most recent jobs and housing forecasts
for the three "constrained" Altell1ative Scenarios remain at the high end of plausible Bay 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. Steven Levy'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 Altell1ative Scenarios. An evaluation of the
Regional Forecast prepared late last year by Councilmember Greg Schmid provides an
assessment of Califoll1ia growth forecasts (see Attachment A), indicating the tendency for
forecasts to overstate growth as compared to actual figures from the Census, and discussing
some of the key factors that will influence Califoll1ia's future growth.
a. Jobs. Regarding the ABAG jobs forecast, 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 rate of 25,200
between 1990 and 2007. The ABAG jobs forecast used for the Altell1ative Scenmios
assumes that the Region will add an average of over 33,000 jobs annually from 2010 to 2040,
5
ABAG: SCS Alternative Scenarios
March S, 2012
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 palt 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 770,800 households are shown added to the Bay Area between 2010 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 market
characterized by very limited new development, low pricing, slow sales of existing homes,
tight credit, and an oversupply of homes resulting from a historically high number of
foreclosed and distressed propelties. 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 normal housing market conditions
emerge. Moreover, ABAG's regional housing forecast is based on a fixed 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 ultimate cause of
housing demand) there are a number of other questions regarding ABAG's housing forecast
including those related to affordability. 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, over 70 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 or by public subsidies such as (now eliminated) redevelopment agency funding
and federal tax credits. Given the loss of redevelopment powers and funding and recent 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 forecast and related Preferred Scenario allocations to be
released as a draft on March 8th will apparently serve as the basis of the future RHNA for
each city and county, which 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 2010-2040 forecast is likely for the 2015-2022 period, however, due to the economic
6
ABAG: SCS Alternative Scenarios
March 5, 2012
housing downturn). This approach seems highly arbitrary, insensitive to local conditions and
constraints, and far beyond what can realistically be expected from an economic perspective.
Accordingly, given all of these concerns, the City strongly recommends that the jobs and housing
forecasts for the Preferred Scenario be reduced to reflect mOrc accurately current conditions,
historical trends, and more fundamental assessment of economic (job) growth potential in the
Bay Area. Developing a more realistic jobs and housing forecast would reduce the implied need
to intensify land uses, reduce projected GHG emissions by lowering energy consumption,
congestion and single occupancy vehicle trips, and require less costly transit and highway
infrastructure investments. The SCS effort is to be revisited and updated every four years, so that
there would be future opportunities to re-evaluate whether a higher forecast is appropriate and
adjustments would be needed.
3. Palo Alto's allocation of jobs and 1I0using UlIitS rmder tile Altemative Scellarios is higilly
unrealistic and excessive relative to lIistorical growth trends and develapment capacity.
Santa Clara County dominates all other Bay Area counties in the allocation of ABAG's regional
forecast of jobs and housing, absorbing 30 percent of the regional job forecast and 26 percent of
the regional housing forecast. Palo Alto is allocated new jobs ranging from 18,040 Outward
Growth) to 26,070 (Focused Growth). 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 regard to existing development 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 of other potential local costs for
achieving the required high density development.
a. Jobs. The City presently contains approximately 62,300 jobs, according to ABAG. During
the past decade (2000 to 2010), Palo Alto experienced a 14 percent decline in employment
reflecting the combined effect of the "dot-com" bust and the Great Recession. While
economic conditions are expected to improve, there have been stluctura\ changes in
technology industries that have driven growth in the Silicon Valley over the past 50 years
that portend only modest growth. The Alternative Scenarios assume that Palo Alto's job
growth by 2040 will increase over the 20 I 0 estimate by between 27 percent and 40 percent.
b. Housing. The housing projections in the Alternative Scenarios represent a 25-50 percent
increase in housing units from 2010-2040, up to approximately 400 new units per year. The
City has in the past 40 years (1970-2010) produced an average of 148 units per year. To more
than double that output in a relatively built-out city is again entirely unrealistic and using
such an assumption as the basis for growth scenarios and transportation investments 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 severely limit how the households and jobs
allocated to Palo Alto in the SCS Alternative Scenarios could be accommodated. The
"constrained" scenarios clearly do not appear to consider the many constraints to new
development in Palo Alto, including limited school capacity and funding for infrastructure.
7
ABAG; SCS Alternative Scenarios
March 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 feasibility, and
infrastructure and local fiscal impacts of such intensive redevelopment,
4. The land use changes contemplated ill tlte SCS Altemaiive Scenarios have a
proportionaiely small contributioll to achieving AB32/SB375 GHG reduction targets.
The AB32/SB375 target for Califomia is a reduction to 85 million equivalent metric tons per
year by 2050, an 80 percent reduction from current levels, To retum to 1990 levels of 427
million tons, an 80 million ton reduction of projected 2020 levels is required, Of this 80 million
ton reduction, approximately 96 percent is proposed to be achieved from improved fuel standards,
energy efficiency, industrial measures, and other methods needed to curb emissions from the
construction, manufacturing, and agricultural sectors. Only four percent, however, or 3.2 million
tons, would be achieved by altering land use pattems, This is shown effectively on the graph
(Attachment B) prepared by the Contra Costa County Transportation Authority (CCTA) in their
letter dated February 15,2012.
a, Negligible Difference Between Alternatives: The potential contributions of the land use
changes contemplated in the SCS Alternative Scenarios show reductions in GHG emissions
through 2040 range from 7.9 percent (Outward Growth) to 9.4 percent (Constrained Core
Concentration), Compared to the initial Current Regional Plan Scenario, the Altemative
Scenarios reduce GHG emissions by 0.9 percent to 2.4 percent of the remaining 4 percent
affected by land use and transportation patterns. This is a negligible difference between the
land use scenarios and argues for a more flexible approach that combines other GHG
emission reduction strategies with a more realistic land use scenario.
b, Regional Transportation Pricing and Policies: The MTC analysis of various transportation
plicing and policy changes (e.g" telecommuting, electric vehicle strategies, parking pricing)
may account for at least a 6,5% further reduction in GlIG emissions, considerably more
significant than the differences between the land use pattems in the Alternative Scenarios.
c, Cost Effectiveness. Given the numerous challenges associated with fundamental changes in
the way that Bay Area land use patterns would otherwise evolve, including wholesale
changes to land use regulations, presuming changes in market characteristics and preferences
of homebuyers, and the need for substantial public investments and subsidies, we question
the feasibility and cost-effectiveness of the Altemative Scenarios. Regarding market
feasibility, there is no evidence that the resulting housing capacity and prototypes would
match buyer preferences and affordability, Regarding cost-effectiveness, the comparable
costs (mostly borne by local jurisdictions) of implementing the Alternative Scenarios may be
far higher than other altematives for achieving comparable GlIG emission reductions,
Accordingly, the City of Palo Alto recommends that a performance-based approach, involving
establishing GHG reduction targets for the local jurisdictions along with a menu of options for
achieving these targets (including feasible and realistic alterations inland use policy) should
become the basis of the proposed SCS,
B
Conclusion
ABAG: SCS Alternative Scenarios
March 5, 2012
In conclusion, the City of Palo Alto suggests that the Preferred Scenario for the Sustainability
Communities Strategy should include:
• A focus on GHG emission reductions, with the flexibility for each city and county to
provide for a reasonable minimum amount of housing plus options for other
commitments to GHG emission reductions;
• Grant funding for transportation and planning oriented to Priority Development Areas
(PDAs);
• Realistic housing forecasts limited to each upcoming 8-year RHNA cycle, with review
every four years to update projections; and
• Longer range projections that are not allocated to cities and counties, but are used to
provide context 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 information, please contact Curtis
Williams, the City's Director of Planning and Community Environment, at (650) 329-2321 or
curtis. williams@cityofpaloalto.org.
Sincerely,
/),0
-f Yiaway Yeh
Mayor
City of Palo Alto
Attachments:
Attachment A: November IS, 2011 Memorandum: "California Demographic Forecasts: Why
are the Numbers Overestimated," prepared by City of Palo Alto Councilmember
Greg Schmid
Attachment B: "Regional Land Use and Transportation SCS: Achieving Statewide GHG
Reduction Rates," prepared for Contra Costa Transportation Authority
cc: Adrienne J. Tissier, Chair, Metropolitan Transportation Commission
Steve Heminger, Metropolitan Transportation Commission
Ezra Rapport, Association of Bay Area Governments
John Ristow, Valley Transportation Authority
Palo Alto City Council
9
California Demographic Forecasts: Why are the numbers over
estimated?
Prepared by City of Palo Alto
November 15, 2011
Actual Califomia Population growth
IAttachment A •
1
Over the last decade, the state of California added 3.4 million people, to reach a total of 37.3 million,
This was an increase of 10% over the decade. This growth rate follows the gradual slowing that started
after 1990, down dramatically from the very high rates of the post-World War II era. Note that the
Department of Finance's (DOF) 2007 projections reflect a very high growth perspective. The DOF
numbers are currently used as the population forecasts for all state and local projects-they are not
schedu led to be revised until 2013.
Table 1, California's population growth over tbe last five decades
(average growth from census to census)
1960s
19705
19805
19905
20005
2010s
2020s
20305
~
29.2
18.5
25.7
13.8
10.0
Dept of Finance Projections (2007)
14.8
12.8
11.6
10.2
Source: US Census Bureau actual Census numbers; California Department of Finance 2007 Projections.
Recent State forecasts have been consistently over-estimated
Even after the sharp decline in growth during the 19905, forecasters consistently tended to be overly
optimistic about population growth rates through the 20005. In 2005, the Public Policy Institute of
California issued a report ("California 2025: Taking on the Future") that included the population
projections of all the key demographic forecasters. The consensus forecast from this group was some
40% higher than the actual outcome for the state:
Table 2. California Population Forecasts for 2010 made before 2005
(Percentage growth expected from 2000-2010)
California Dept of Finance 15.2
U5C Population Dynamics 11.6
UC Berkeley (Lee, Miller) 13.9'
Public Polley Institute of CA 15.2'
CCSeE 17.2
UCLA Anderson Forecasting 16.6
Average of six 2005 forecasts 15.0
'''center point of band
Source: Public Policy Institute of California, "California 2025: Taking on the Future", 2005, Page 29.
2
The consensus forecast was some 50% above the actual numbers. The only forecaster who produced a
number below the actual 10% growth was the UC Berkeley group who stated that there was a 5%
chance thatthe growth rate would be lower than 7,1%. The 2005 PPIC Report stated that "Recenttrends
make population projections for California especially difficult...For these reasons, planners should
consider alternative population scenarios ... as useful alternatives for planners." (PPIC, 2005, pages 27-
28)
Even as late as the end of 2009, on the eve of the decennial census, estimates by the California Dept. of
Finance (the organization responsible for the numbers that are used for all state allocation formulas)
remained strikingly high at 14.1% which was 1.5 million or 44.7% above the above the
contemporaneous and more accurate Census Bureau's Current Population Estimates.
Critical Components of Change and the Future
The Census data provide a nice detailed perspective on the actual components of change during the
decade. While the 3.1 million people added through natural increase (births minus deaths) were the
largest single growth factor, the 2 million net gain from foreign immigration was important In
overcoming a net outflow of 1.6 million from native born emigration, primarily to other states.
Table 3. Components of Population Change in California. 2000·2010
(millions of people)
Births
Deaths
+5.45
-2.35
Net Domestic migration -1.63
Foreign Immigration +2.58
Foreign emigration -0.59
Military, etc -0.07
TOTAL +3.38
Source: USC. Population Dynamics Research Group, "What the Census would show", February 2011.
3
The challenge for projecting change In the future is the dramatic shifts in some of these base categories.
With the aging population, we know that, even with slight increases in longevity, the aging population in
California will raise the annual number of deaths in California from 271K in 2011 to 462K in 2039, while
the number of births will rise slightly from 532K in 2011 to 5511n 2039. The natural Increase will fall
from some 260K today to 90K in 2040.
Thus, over time any increase in California's population will Increasingly rely on migration. Since net
domestic migration has averaged a net outflow of some 160K per year since the early 1990s, any growth
in population will be increasingly dependent on foreign migration, (Source: USC, Population Dynamics
Groups, April 2011).
There is little reason to see a major shift in domestic migration with California's high cost and high
unemployment rate. That leaves foreign migration as the critical component source of long-term
population growth. The most dynamic source for California's growth has been immigration from Mexico,
both legal and illegal. All observers (The Dept of Homeland Security, the Pew Charitable Trust Hispanic
Center, and the Mexican Migration Project at Princeton) agree that net immigration from Mexico has
been down dramatically in recent years with the stricter enforcement of border crossing and the
prolonged recession in the US. Pew estimates that the illegal immigrant population In the US fell by
some 7% between 2007 and 2010. The important debate about the future is whether this is a business
cycle phenomenon or part of a longer term trend.
The group that has the best data source and takes the longer term look is the Mexican Migration Project
at Princeton. For decades they have been tracking migration patterns from Mexico and doing annual
surveys of thousands of families from migration centers in Mexico. They found that the percent of first
time immigrants from the Mexican communities of highest immigration fell from 1.2% of adults in 2000
to 0.6% in 2005 to zero in 2010. They identify that the changes are due to Mexican demographic and
economic factors as much as from U.S. conditions. They identified five internal factors of change in
Mexico:
4
• Fertility rates are falling dramatically from 6.8 births per women in 1970 to 2.8 in 1995 to 2 in
2010 (replacement level).
• The number of young people entering the labor market has fallen from one million a year in the
1990s to 700K today and demographic factors will bring that down to about 300K in 2030, not
enough to meet local job needs.
• The rate of college attendance and college completion has doubled over the last decade, raising
the career path of an increasing share of young workers.
• The wage disparity between Mexico and the U.S. is narrowing sharply with average wage gaps
falling from 10:1 in the 1960s to some 3.7:1 in the early 20005.
• The cost of migration has risen dramatically for illegal entrants, further narrowing the earnings
gap.
All of these factors point to the need, at the least, of looking at alternative scenarios of population
growth in California that are more sensitive to possible underlying changes in migration patterns.
5
Sources of Demographic projections about California
US Bureau of the Census (responsible for the decennial census and does updated estimates each year of
state populations-has been much closer to actual numbers than the Cal Dept. of Finance)
California Department of Finance (responsible for state population estimates between the Census
years-forecasts used as key 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 Bay counties.
Ronald lee, UC Berkeley, Center for Economics and Demographics of Aging, "Special Report: The
Growth & Aging of California's Population", 2003 (an important repolt that identified the detailed
assumptions that went into the Department of Finance's long-term projections).
Hans Johnson, Public Policy Institute of California, "California 2025: Taking on the Future", Chapter 2
'California's Population in 2025' (a report that gathered projections from eight academic and
government sources). Johnson concluded that "population projections for California are especially
difficulL.ln addition to overweighting contemporary trends, forecasters are notoriously bad at
predicting fundamental demographic shifts ... For these reasons, planners should consider alternative
population scenarios." Pages 27-28.
John Pitkin & Dowell Myers, USC Population Dynamics Research Group, "The 2010 Census Benchmark
for California's Growing and Changing Population", February 2011; "Projections of the Population of
California by Nativity and Year of Entry to the U.S.", April 2, 2011. (Pitkin and Myers had the lowest of
the forecasts in the 2005 study-though still overestimating growth by 16%. They are working with the
California Department of Finance on components for a new longer-term forecast; they are still assuming
a net immigration number of 160,000 holding steady in the future.)
Steve Levy, Center for the Continuing Study of the California Economy
UCLA Anderson Forecasting Project
Greg Schmid
October 2011
Required Reductions:
Year Tons·
By 2020 ........... 80
By 2050 ......... 715"
850
800
750
700
650
600 -550 c
Q)
.~ 500
.H-450 427
0" 400
u 350 '" c ~ 300
.!::! 250 I 8O"k
l: ~ 200
c 150 .2
Tons'
CD 2020 Emissions ................................. 507
® Target 2020 Emissions 11990) ............ · .. ·427
@ Forecast 2050 Emissions ...................... 800" o Target 2050 Emissions (20"10 of 1990) ...... · 85
® Target 2035 Emissions fonlefpalatedJ ...... 275
'Million Metric Tons C02 Equivalent
"E>timcte based on Colifomia Council on
Science end T e<hnclcgy Report, 2011
5{)7 CD
~
; 427 : '2'
~\6J
Bay Area Regional Contribution
Scenarios
7.0'Yo CUfTent Regional Plans ------:
7.9"., Outward Growth ~
8.2'% Initial VISion/Core ConcenfTation
9.1% Focused Growth ------~
9.4% Constrained Core Concentrotion
~75i®
I .. ~ I .. , , 0%
15%
~ 100 5 . r.-. t r "\!t
50
1990 1995 2000 2005 2010 2015 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-TRANSPORTATION EMISSIONS REDUCTION
ACTUAL/PROJECTED EMISSIONS
2050 ;e
iii
C'l ::r 3 (J)
::l ~
III
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
Estimate Projections
Estimate Projections
Estimate Projections
Estimate Projections
ASSOCIATION OF BAY AREA GOVERNMENTS
Representing City and County Governments of the San Francisco Bay Area
July 25, 2012
San Francisco Bay Area
City Managers and Planning/Community Development Directors,
The Regional Housing Need Allocation (RHNA) process for the San Francisco Bay Area
reached its second milestone. On July 19, 2012, the ABAG Executive Board adopted the Draft
RHNA Methodology and Preliminary Subregional Shares for the fifth cycle: 2014 - 2022 for all
jurisdictions and subregions by income category. The adoption finalized the Draft RHNA
Methodology according to the recommendations submitted by ABAG Staff in response to the
input received during the 60-day public comment period that began on May 18, 2012 and closed
on July 16, 2012. This milestone was reached through your involvement and the diligent efforts
performed by the Housing Methodology Committee (HMC). The HMC represents a diverse set
of interests that reflect both local and regional needs. This regional committee created the
adopted Draft RHNA Methodology through an iterative process of workshops and meetings that
began in January 2011. As we have reached the half-way point in the RHNA process, this memo
provides an overview of the adopted RHNA Methodology and Subregional Shares as reflected in
Resolution(s) 12-12 and 12-13. Finally, this memo details the next RHNA steps for local
jurisdictions and subregions.
Page 2 of 6
Final Draft RHNA Methodology
1. Sustainability Component
This component advances the goals of SB 375; this factor is based on the Jobs-Housing
Connection Strategy, which allocates new housing development into Priority Development
Areas (PDAs) and non-PDAs. By concentrating new development in PDAs, the Strategy
helps protect the region’s natural resources, water supply, and open space by reducing
development pressure on rural areas. This allows the region to consume less energy,
reducing household costs and the emission of greenhouse gases. Following the land use
distribution specified in the Jobs-Housing Connection Strategy, 70% (131,593) of the
187,990 units determined by HCD will be allocated to PDAs and the remaining 30%
(56,397) will be directed to non-PDA locations.
As of July 19, 2012, the Jobs-Housing Connection Strategy has been modified to a feasible
growth concentration over the 2014-2022 RHNA cycle. This new distribution results in a
shifting of approximately 3,500 units or 1.5 percent of the total regional allocation. This
modification shifts housing units from Oakland, Newark, and San Jose primarily to medium
sized cities within the employment commute shed of these cities.
2. Fair Share Component
This component achieves the requirement that all cities and counties in California work to
provide a fair share or proportion of the region’s total and affordable housing need. In
particular, cities that had strong transit networks, high employment rates, and performed
poorly on the 1999-2006 RHNA cycle for very-low and low income units received higher
allocations. Fair Share scoring is addressed through the factors listed below.
Upper Housing Threshold: If growth projected by the Jobs-Housing Connection Strategy
in PDAs meets or exceeds 110% of the jurisdiction’s household formation growth, it is
not assigned additional growth outside the PDA, which ensures that cities with large
PDAs are not overburdened.
Page 3 of 6
Minimum Housing Floor: Jurisdictions are assigned a minimum of 40 percent of their
household formation growth but not to exceed 1.5 times its 2007–2014 RHNA. This
factor encourages all jurisdictions to produce a fair proportion of total housing need.
Past RHNA Performance: In non-PDA areas, the total low- and very-low income units
that were permitted in the 1999–2006 RHNA cycle were used as a factor for this cycle.
For example, cities that exceeded their RHNA obligation in these two income categories
received a lower score.
Employment: In non-PDA areas, the employment was factored using the 2010 job
estimates for a jurisdiction. Jurisdictions with higher employment received a higher score.
Transit: In non-PDA areas, transit was factored for each jurisdiction. Jurisdictions with
higher transit frequency and coverage received a higher score.
3. Income allocation (Amended as of July 19, 2012)
The income allocation factor ensures that jurisdictions that already supply a large amount of
affordable housing receive lower affordable housing allocations. This also promotes the state
objective for increasing the mix of housing types among cities and counties equitably. The
income allocation requirement is designed to ensure that each jurisdiction in the Bay Area
plans for housing people of every income.
The income distribution of a jurisdiction’s housing need allocation is determined by the
difference between the regional proportion of households in an income category and the
jurisdiction’s proportion for that same category. Once determined, this difference is then
multiplied by 175 percent. The result becomes that jurisdiction’s “adjustment factor.” The
jurisdiction’s adjustment factor is added to the jurisdiction’s initial proportion of households
in each income category. The result is the total share of the jurisdiction’s housing unit
allocation for each income category.
Page 4 of 6
On July 19, 2012, the calculation of current income groups by jurisdiction was modified.
This calculation was based on the regional median household income instead of the county
median household income. This adjustment provided a better regional alignment of the
income distribution formula of 175 percent. Using the median income for the region
eliminates this disparity and places all counties on equal footing.
This adjustment did not change a jurisdiction’s total allocation, but shifted the distribution
across its income categories. Counties with residents that are above the regional median
household income (Contra Costa, Marin, San Mateo, and Santa Clara) experienced a shift
towards a greater concentration of units in the very-low, low, and moderate income
categories. Counties with residents below the regional median household income (Alameda,
Napa, San Francisco, Solano, and Sonoma) experienced shifts towards a greater
concentration in the above moderate income category
4. Sphere of Influence Adjustments
Every city in the Bay Area has a Sphere of Influence (SOI) which can be either contiguous
with or go beyond the city’s boundary. The SOI is considered the probable future boundary
of a city and that city is responsible for planning within its SOI. The SOI boundary is
designated by the county’s Local Area Formation Commission (LAFCO). The LAFCO
influences how government responsibilities are divided among jurisdictions and service
districts in these areas.
The allocation of the housing need for a jurisdiction’s SOI where there is projected growth
within the spheres varies by county. In Napa, San Mateo, Santa Clara, Solano, and Sonoma
counties, the allocation of housing need generated by the unincorporated SOI is assigned to
the cities. In Alameda and Contra Costa counties, the allocation of housing need generated by
the unincorporated SOI is assigned to the county. In Marin County, 62.5 percent of the
allocation of housing need generated by the unincorporated SOI is assigned to the city and
37.5 percent is assigned to the county.
Page 5 of 6
Subregions Shares
Napa, San Mateo and Solano counties with the inclusion of all cities within each county have
formed the three subregions for this RHNA cycle. These counties are each considering an
alternative housing allocation methodology. The share of the RHND total for each of these
subregions is defined by the ratio between the subregion and the total regional housing growth
for the 2014 to 2022 period in the Jobs-Housing Connection Strategy, which is the same ratio as
in RHNA. Napa will receive 0.7883%, San Mateo will receive 8.7334%, and Solano will receive
3.7113% of the region’s total RHND.
Next Steps
The most recent adoption authorizes the beginning of the 60-day Revisions and Appeals process.
During this period, each jurisdiction and subregion are allowed to request for revisions to its
allocation or submit an appeal to the RHNA process.1 The objective of the appellate process is to
allow ABAG Staff to work directly with local jurisdictions and subregions to discuss its
proposed allocation of housing units for the 5th 2014-2022 RHNA cycle. The deadline to submit
an appeal or to request for a revision is September 18, 2012. To ensure that ABAG Staff will
have adequate time to respond to requests before or by the next Executive Board Meeting on
September 20, 2012, we are recommending that jurisdictions and subregions submit their request
by September 10, 2012. Requests or questions regarding the Revision and Appeals process
should be sent to RHNA_Feedback@abag.ca.gov.
By April 2013, ABAG will issue Final Allocations that will be subject to a final adoption by the
ABAG Executive Board. In June and July 2013, the Department of Housing and Community
Development (HCD) will review the San Francisco Bay Area RHNA Plan. Thank you for your
involvement in this process. By the end of August we will be distributing a technical report that
details the mechanics of the RHNA methodology. In this report, you will find worksheets and
explanations to each step we took to calculate the individual allocations to jurisdictions and
subregions. For a list of the upcoming phases for the RHNA process, please see the attached list
of events at the end of the enclosed packet.
1 Government Code §65584.05(b)
Page 6 of 6
Respectfully,
Miriam Chion
Acting Director of Planning and Research, ABAG
Attachment A: Draft RHNA (released on July 19, 2012)
DRAFT REGIONAL HOUSING NEED ALLOCATION (2014‐2022)
Very Low
0‐50%
Low
51‐80%
Moderate
81‐120%
Above
Moderate
120%+
Total
REGION 46,680 28,940 33,420 78,950 187,990
Alameda County
Alameda 442 247 282 745 1,716
Albany 80 53 57 144 334
Berkeley 530 440 581 1,395 2,946
Dublin 793 444 423 615 2,275
Emeryville 275 210 258 749 1,492
Fremont 1,707 922 974 1,829 5,432
Hayward 862 490 625 2,044 4,021
Livermore 835 472 494 916 2,717
Newark 328 166 157 422 1,073
Oakland 2,050 2,066 2,803 7,782 14,701
Piedmont 24 14 15 7 60
Pleasanton 713 389 405 551 2,058
San Leandro 502 269 350 1,156 2,277
Union City 316 179 191 415 1,101
Alameda County Unincorporated 428 226 294 814 1,762
9,885 6,587 7,909 19,584 43,965
Contra Costa County
Antioch 348 204 213 677 1,442
Brentwood 233 123 122 278 756
Clayton 51 25 31 34 141
Concord 794 442 556 1,670 3,462
Danville 195 111 124 125 555
El Cerrito 100 63 69 165 397
Hercules 219 117 100 243 679
Lafayette 146 83 90 107 426
Martinez 123 72 78 194 467
Moraga 75 43 50 60 228
Oakley 316 173 174 500 1,163
Orinda 84 47 53 42 226
Pinole 80 48 42 126 296
Pittsburg 390 253 315 1,058 2,016
Pleasant Hill 117 69 84 176 446
Richmond 436 304 408 1,276 2,424
San Pablo 55 53 75 264 447
San Ramon 514 278 281 338 1,411
Walnut Creek 601 353 379 892 2,225
Contra Costa County Unincorporated 372 217 242 530 1,361
5,249 3,078 3,486 8,755 20,568
RHNA Methodology adopted by ABAG Executive Board on July 19, 2012.
ABAG is scheduled to issue Final Allocation in April 2013 and to adopt in May 2013.
DRAFT REGIONAL HOUSING NEED ALLOCATION (2014‐2022)
Very Low
0‐50%
Low
51‐80%
Moderate
81‐120%
Above
Moderate
120%+
Total
Marin County
Belvedere 4 3 4 5 16
Corte Madera 22 13 13 24 72
Fairfax 16 11 11 23 61
Larkspur 40 20 21 51 132
Mill Valley 41 24 26 38 129
Novato 111 65 72 166 414
Ross 6 4 4 4 18
San Anselmo 33 17 19 37 106
San Rafael 239 147 180 437 1,003
Sausalito 26 14 16 23 79
Tiburon 24 16 19 19 78
Marin County Unincorporated 55 32 37 60 184
617 366 422 887 2,292
Napa County
American Canyon 116 54 58 164 392
Calistoga 6 2 4 15 27
Napa 185 106 141 403 835
St. Helena 8 5 5 13 31
Yountville 4 2 3 8 17
Napa County Unincorporated 51 30 32 67 180
370 199 243 670 1,482
San Francisco County
San Francisco 6,207 4,619 5,437 12,482 28,745
6,207 4,619 5,437 12,482 28,745
RHNA Methodology adopted by ABAG Executive Board on July 19, 2012.
ABAG is scheduled to issue Final Allocation in April 2013 and to adopt in May 2013.
DRAFT REGIONAL HOUSING NEED ALLOCATION (2014‐2022)
Very Low
0‐50%
Low
51‐80%
Moderate
81‐120%
Above
Moderate
120%+
Total
San Mateo County
Atherton 36 27 29 14 106
Belmont 116 63 67 121 367
Brisbane 25 13 15 30 83
Burlingame 280 149 158 388 975
Colma 20 8 9 30 67
Daly City 408 194 225 681 1,508
East Palo Alto 64 54 83 266 467
Foster City 148 87 76 119 430
Half Moon Bay 52 31 36 67 186
Hillsborough 50 29 34 16 129
Menlo Park 237 133 145 219 734
Millbrae 193 101 112 272 678
Pacifica 121 68 70 154 413
Portola Valley 21 15 15 13 64
Redwood City 706 429 502 1,147 2,784
San Bruno 365 166 208 555 1,294
San Carlos 195 107 111 183 596
San Mateo 859 469 530 1,172 3,030
South San Francisco 576 290 318 922 2,106
Woodside 23 13 15 11 62
San Mateo County Unincorporated 100 61 72 106 339
4,595 2,507 2,830 6,486 16,418
Santa Clara County
Campbell 252 137 150 390 929
Cupertino 354 206 230 269 1,059
Gilroy 235 159 216 473 1,083
Los Altos 168 99 112 96 475
Los Altos Hills 46 28 32 15 121
Los Gatos 200 112 132 173 617
Milpitas 1,000 568 563 1,145 3,276
Monte Sereno 23 13 13 12 61
Morgan Hill 272 153 184 315 924
Mountain View 810 490 525 1,088 2,913
Palo Alto 688 430 476 585 2,179
San Jose 9,193 5,405 6,161 14,170 34,929
Santa Clara 1,045 692 752 1,586 4,075
Saratoga 147 95 104 92 438
Sunnyvale 1,780 992 1,027 2,179 5,978
Santa Clara County Unincorporated 22 13 14 28 77
16,235 9,592 10,691 22,616 59,134
RHNA Methodology adopted by ABAG Executive Board on July 19, 2012.
ABAG is scheduled to issue Final Allocation in April 2013 and to adopt in May 2013.
DRAFT REGIONAL HOUSING NEED ALLOCATION (2014‐2022)
Very Low
0‐50%
Low
51‐80%
Moderate
81‐120%
Above
Moderate
120%+
Total
Solano County
Benicia 94 54 56 123 327
Dixon 50 24 30 93 197
Fairfield 861 451 514 1,664 3,490
Rio Vista 15 12 16 56 99
Suisun City 105 40 41 169 355
Vacaville 287 134 173 490 1,084
Vallejo 283 178 211 690 1,362
Solano County Unincorporated 16 9 12 26 63
1,711 902 1,053 3,311 6,977
Sonoma County
Cloverdale 39 29 31 111 210
Cotati 35 18 18 66 137
Healdsburg 31 24 26 75 156
Petaluma 198 102 120 321 741
Rohnert Park 180 107 126 482 895
Santa Rosa 943 579 756 2,364 4,642
Sebastopol 22 17 19 62 120
Sonoma 24 23 27 63 137
Windsor 120 65 67 187 439
Sonoma County Unincorporated 219 126 159 428 932
1,811 1,090 1,349 4,159 8,409
REGION 46,680 28,940 33,420 78,950 187,990
RHNA Methodology adopted by ABAG Executive Board on July 19, 2012.
ABAG is scheduled to issue Final Allocation in April 2013 and to adopt in May 2013.
June 29, 2012
Ezra Rapport, Executive Director
Association of Bay Area Governments
P.O. Box 2050
Oakland, CA 94604-2050
Re: Regional Housing Needs (RHNA) Allocations for Stanford University
Campus/Santa Clara County
Dear Mr. Rapport:
Thank you for the opportunity to provide input regarding the draft regional housing needs
allocations (RHNA) to be considered by the ABAG Board in July. The City of Palo Alto in
general concurs with the principle that housing within Santa Clara County should be allocated to
a city with jurisdiction over the sphere of influence (SOI), as the County has strong programs in
place to direct cities to annex pockets of unincorporated areas. We do have a specific and
substantial concern with allocations of housing for Santa Clara County, as it pertains to the
Stanford University campus area, however.
The Stanford University Campus lies within Palo Alto’s Sphere-of-Influence (SOI), but new
campus development generates population and housing needs that are governed by Santa Clara
County, not the City, and are not subject to potential annexation by the City of Palo Alto
(pursuant to a tri-party agreement between the City, County and Stanford). In the prior RHNA
cycle (2007-2014), the “Stanford share” of the allocation increased the City of Palo Alto’s
allocation by 645 units. It was not until the appeal period, however, that this correction was
made, and the units redistributed to the County, with the concurrence of the City, County and
Stanford.
The proposed RHNA figures allocate only 58 units to Santa Clara County (as compared to 1,090
units in the prior planning period). According to the most recent annual report (see
http://www.sccplanning.org/SCC/docs/Planning,%20Office%20of%20(DEP)/attachments/Stanfo
rd/AR10_all.pdf) regarding Stanford’s General Use Permit (GUP) with the County, however,
approximately 1,000-1,500 new housing units are planned on the campus over the next 10 years
or so. Those units do not appear to be accounted for in any way in the County’s allocation,
although they are already planned and zoned appropriately. The City understands that there is no
Priority Development Area for lands on the campus, but there are some designated housing sites
that are located immediately proximate to El Camino Real and near the University Avenue
Caltrain station. These two sites (H and I in the report) are planned to accommodate a minimum
of 350 units. These sites would be within VTA’s El Camino Corridor area if it was applied on
the west side of El Camino Real.
The City of Palo Alto requests that the RHNA numbers reflect some of this housing development
in the County’s allocation, which we believe is consistent with the County’s current housing
element. While we understand that the reallocation of units does not mean that they reduce Palo
ABAG: Draft RHNA Allocations: June 29, 2012
Page 2
Alto’s allocation accordingly, it would seem that some of them, particularly those nearest El
Camino and the train station, would have that effect.
The City of Palo Alto hopes these allocation issues may be addressed in a timely manner so there
is no need to protest the final numbers, as happened in the prior cycle, and to allow a more
thoughtful evaluation and allocation as part of the current review. The City of Palo Alto has
broached this subject with the County and Stanford, and will continue to meet with them to
assure there are not impacts or unintended consequences for them.
Thank you again for your consideration of the City’s suggestion. If you have any questions,
please feel free to contact Curtis Williams, the City’s Director of Planning and Community
Environment, at (650) 329-2321 or Curtis.williams@citofpaloalto.org.
Sincerely,
James Keene, City Manager
City of Palo Alto
cc: Palo Alto City Council
Palo Alto Planning and Transportation Commission
James Keene, Palo Alto City Manager
Bill Shoe, Santa Clara County Planning Office
Charles Carter, Stanford University
Ken Kirkey, Planning Director, ABAG
Hing Wong, ABAG
Justin Fried, ABAG