HomeMy WebLinkAboutStaff Report 3437
City of Palo Alto (ID # 3437)
Regional Housing Mandate Committee Staff Report
Report Type: Meeting Date: 1/31/2013
City of Palo Alto Page 1
Summary Title: RHNA Appeal
Title: City of Palo Alto Appeal of the Adopted Regional Housing Needs
Allocation (RHNA) for the 2014-2022 Housing Element Cycle
From: City Manager
Lead Department: Planning and Community Environment
Recommendation
Staff recommends that the Committee provide input on the proposed appeal letter and
completed appeal template and recommend that the City Council officially appeal the City’s
Adopted Regional Housing Needs allocation (RHNA) for the 2014-22 Cycle.
Background
On July 19, 2012 the Association of Bay Area Governments (ABAG) Executive Board adopted the
Regional Housing Needs Allocation (RHNA) methodology for the 2014-2022 housing cycle. For
the City of Palo Alto, ABAG projects a need for 2,179 new housing units at various income levels
during this time period. This allocation represents the City of Palo Alto’s share of the 187,990
units the California Department of Housing and Community Development (HCD) projects will be
needed within the Bay Area over that same time period.
State Law prescribes the required appeal process a jurisdiction must follow when the agency
believes that the allocation is overstated or otherwise incorrect. The first step in the appeal
process requires a jurisdiction to submit a “Request for Revision” letter to ABAG. The City
Council directed that this first step be taken in September and a letter, which was reviewed by
the Council and signed by the Mayor, was submitted to ABAG on September 11, 2012. The
letter detailed several reasons why a significant reduction in the total number of housing units
allocated to the City of Palo Alto was appropriate (Attachment D). On November 15, 2012,
however, the City received a letter (Attachment E) from ABAG denying the request for revision
for various reasons.
The next step in the prescribed appeal process is the formal appeal of the allocation. ABAG has
created a template for this appeal, which lays out the findings that must be made in order for
an appeal to be granted. These findings are taken directly from State law. Prior to receiving the
City of Palo Alto Page 2
official appeal template, staff drafted a Summary of Arguments for this appeal. The Summary
of Arguments was reviewed by the Regional Housing Mandate Committee on December 13,
2012. The Committee gave direction for the official appeal to focus on one specific reason for
appeal related to allocation of units between the County and City, while also conveying the
other points made in the request for revision letter. The appeal details are specified below, in
the attached appeal cover letter and completed appeal template.
The Committee also instructed staff to explore other avenues for contesting the Department of
Housing and Committee Development’s (HCD) overall housing projections. Finally, the
Committee requested that staff research the “Request for Revision” letters that were
submitted to ABAG. All 15 of these letters are attached to this report. If Council chooses to
move forward with this appeal, it must be submitted by February 18, 2012. Staff has scheduled
the item for the Council’s February 11, 2012 agenda.
Discussion
Appeal Process
State Government Code §65584.05 provide the following grounds for appeal of the Regional
Housing Needs Allocation (RHNA) methodology and jurisdictional allocation:
ABAG failed to adequately consider the information submitted by the City of Palo Alto in
the survey ABAG administrated in January 2012;
A significant and unforeseen change in circumstances has occurred in the City of Palo
Alto that merits a revision of the information; or ABAG failed to determine its share of
the regional housing need in accordance with the information described in, and the
methodology established pursuant to Section 65584.04.
Section 65584.04 requires ABAG to consider multiple factors when determining the
methodology for allocation of housing units: (A) lack of available sewer and water service due
to State or Federal laws, regulations or regulatory actions, (B) the availability of suitable land for
urban development and increased residential densities, (C) land that is protected under Federal
or State Programs, and for unincorporated, County land (D) preservation of agricultural land.
Furthermore, the law states that ABAG shall allocate housing within the region consistent with
the Sustainable Communities Strategy.
Request for Revision Letter
The City’s initial “Request for Revision” letter focused on reasons why a significant reduction in
the total number of housing units allocated to the City of Palo Alto was appropriate. The
following summarizes these points and the full, detailed arguments are attached: 1) that the
regional forecast provided by HCD and mandated by ABAG was inconsistent with the
Department of Finance population projections; 2) despite the fact that the Stanford General
Use Permit allows from the construction of housing of Stanford Lands within the County of
Santa Clara’s jurisdiction, the County was only allocated 77 units in the upcoming housing cycle.
Two specific parcels on near the intersection of Quarry Road and El Camino Real are near
City of Palo Alto Page 3
transit, and allow for up to 350 units per the Use Permit. Therefore, the re-assignment of 350
units from the City of Palo Alto to the County of Santa Clara is appropriate and consistent with
the intent of the Sustainable Communities Strategy; 3) ABAG’s methodology does not consider
the “built out” nature of Palo Alto; and, 4) the City of Palo Alto is a national leader in programs
that reduce Greenhouse Gas Emission, yet methodology does not allow any flexibility.
Focus of Appeal
All the points above have been incorporated into the appeal cover letter (Attachment A),
however, as directed by the RHMC, the attached appeal template (Attachment B) focuses on
the re-assignment of 350 units from the City of Palo Alto to the County of Santa Clara. The
Committee focused on this point as it is the most relevant given the required appeal findings, it
would have limited precedential impact on other cities and thus is politically more palatable
and would result in the greatest reduction of units. The text in the completed appeal template
is as follows:
“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 RHNA housing element timeframe. Specifically, approximately 350 planned units on
two sites on Quarry Road just west of El Camino Real appear appropriate to include somewhere
in the housing analysis in this timeframe. Indeed, there were active discussions with the
property owner (Stanford University) in the recent past about housing development on those
sites in connection with its current Medical Center expansion that was approved by the City in
2011. While the City acknowledges that these units have not been otherwise assigned to the
City of Palo Alto, these two sites are proximate to El Camino Real and the University Avenue
Caltrain station, and would be consistent with the objectives of the SCS and SB375. The sites
are located very close to developed land located within the City’s boundaries. Furthermore, this
land is not protected agricultural land, and therefore should not be discounted as a suitable
area for growth. It appears to be an oversight in the designation of priority development areas
(PDAs) that these sites were not included in the Valley Transportation Authority’s (VTA’s) “cores
and corridor” designation and thereby treated as a PDA under the RHNA methodology. The City
notes that significant areas of Palo Alto, designated by VTA in “cores and corridors,” have been
treated as PDAs for the purpose of distributing housing units, even though the City did not
agree to their designation as PDAs. For these reasons, the City believes allocations should be
adjusted accordingly.”
The appeal template also allows for supporting documentation to be attached. Staff is currently
compiling this documentation, including text from the Stanford University’s General Use
Permit, and will attach it to the appeal template prior to City Council review.
Remaining Issues
At the last Committee meeting it was noted that State Law requires that HCD’s housing
projections be consistent with the Department of Finance’s population projections. This is
City of Palo Alto Page 4
critical because HCD’s housing projections become the basis for which ABAG allocates housing
mandates to each City. For the upcoming housing cycle, the DOF reduced their population
projections in March 2012, shortly after HCD distributed the Bay Area’s overall allocation to
ABAG. HCD, however, never made the same downward adjustment. This results in an
approximate 15% discrepancy between the HCD and DOF population projections.
Unfortunately, while ABAG has the ability to appeal HCD’s projections (ABAG did not appeal),
there is no prescribed appeal process for cities. Staff has been in conversations with Senator
Jerry Hill’s office about this issue and expects future discussions to include other legislators. It is
expected these conversations will be ongoing, but will not impact the allocations for the
upcoming cycle. City staff will report back to the Committee at future meetings.
Staff has also attached the Request for Revision Letters as requested by the RHMC (Attachment
F). There were 15 submitted in the Bay Area. As noted by ABAG in their cover letter, most of
the requests focused on comments about the SCS housing and employment forecasts, and the
use and impacts of the factors that make up the RHNA methodology. In addition to the City of
Palo Alto, four other cities from Santa Clara County submitted Request for Revision letters: the
cities of Cupertino, Mountain View, Saratoga and Sunnyvale. The County of San Clara also
submitted a letter, which stated the County has consulted with Stanford, and will not be
requesting a voluntary increase in its RHNA allocation. Since that time, however, the County
and Stanford have continued discussions on the matter, and staff expects to receive additional
information prior to the end of the appeal period.
Next Step
If the Committee recommends approval, the attached appeal will be forwarded to the Council
for approval on February 11, 2012. The appeal must be received by ABAG by February 18, 2013.
Resource Impact
No further resources are required beyond staff’s time to prepare the Council staff report and to
finalize the appeal to ABAG.
Policy Implications
The Regional Housing Needs Assessment relates directly to the City’s Comprehensive Plan and
Housing Element, The appeal to ABAG reinforces the City’s Comprehensive Plan policies and
priorities.
Environmental Review
No environmental review is necessary by the City to comment on the proposed allocation.
Attachments:
Attachment A: RHNA Appeal Cover Letter, February 2013 (DOCX)
Attachment B: Completed COPA RHNA Appeal Template (PDF)
City of Palo Alto Page 5
Attachment C: DOF_HCD Comparison Table (PDF)
Attachment D: September 11 Letter to ABAG on Revision to Adopted RHNA
Methodology for the 2014-2022 Housing Cycle (PDF)
Attachment E: ABAG Response Letter to City, November 15, 2012 (PDF)
Attachment F: Request for Revision Letters from Other Agencies (PDF)
Attachment G: California Demographic Forecasts (Schmid) (PDF)
February 12, 2013
Ms. Gillian Adams, Regional Planner
Association of Bay Area Government
Joseph P. Bort Metro Center
P.O. Box 2050
Oakland, CA 94607-4756
Re: City of Palo Alto Appeal of Adopted RHNA Methodology for the 2014-2022 Housing Cycle
Dear Ms. Adams:
We are in receipt of ABAG’s November 15th letter, in response to the City of Palo Alto request for a
reduction to the Regional Housing Needs Assessment (RHNA) jurisdictional allocation for the 2014-2022
housing cycle. This letter denied the City of Palo Alto’s request, briefly outlined the reasons for denial,
and provided the schedule and findings necessary to appeal this determination. The required appeal
template was also emailed to the City at a later date. With that in mind, pursuant to Government Code
§65584.05, the purpose of this cover letter and attached completed appeal template is to officially
appeal the adopted RHNA Methodology determination for the City of Palo Alto. The following outlines
the criteria for which this appeal is based.
As noted in your letter, Government Code §65584.05 provides the following grounds for appeal:
1. ABAG failed to adequately consider the information submitted by the City of Palo Alto in the
survey ABAG administrated in January 2012 , or a significant and unforeseen change in
circumstances has occurred in the City of Palo Alto that merits a revision of the information; or
2. ABAG failed to determine its share of the regional housing need in accordance with the
information described in, and the methodology established pursuant to Section 65584.04.
The City of Palo Alto’s “Request for Revision” letter outlined several reasons why the City of Palo Alto’s
housing allocation was overstated. The following appeal focuses on one these items grounds for appeal.
However, the City’s other concerns remain and are stated below for the record.
The City of Palo Alto’s grounds for appeal are as follows:
1. 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 RHNA housing element timeframe. Specifically, approximately 350 planned units on
two sites on Quarry Road just west of El Camino Real appear appropriate to include somewhere
in the housing analysis in this timeframe. While the City acknowledges that these units have not
been otherwise assigned to the City of Palo Alto, these two sites are proximate to El Camino
Real and the University Avenue Caltrain station, and would be consistent with the objectives of
the SCS and SB375. Furthermore, this land is not protected agricultural land, and therefore
should not be discounted as a suitable area for growth. It appears to be an oversight in the
designation of priority development areas (PDAs) that these sites were not included in the
Valley Transportation Authority’s (VTA’s) “cores and corridor” designation and thereby treated
Attachment A
as a PDA under the RHNA methodology. The City notes that significant areas of Palo Alto,
designated by VTA in “cores and corridors,” have been treated as PDAs for the purpose of
distributing housing units, even though the City did not agree to their designation as PDAs. For
these reasons, the City believes allocations should be adjusted accordingly.
In addition to the reasoning above, The City of Palo Alto would like to reiterate several reasons why the
RHNA methodology for this cycle is flawed, and should be revisited in future cycles.
1. State Law requires that the allocation be consistent with the Sustainable Communities Strategy
(SCS). A key aspect of the Sustainable Communities Strategy (SCS) is projecting growth within
the region. In fact, projected growth and its related impacts are the primary drivers for all other
SCS policies and goals. The regional forecast of jobs and housing for the region, however,
substantially overstate growth for the overall SCS period (through 2040). More importantly for
this upcoming cycle (through 2022), the overall regional allocation continues to ignore the
updated demographic forecasts of the State’s Department of Finance (DOF). This creates an
unrealistic scenario for the upcoming cycle, while also creating 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 to reflect the adaptations
already made by the Department of Finance to the changing State of California demographics.
Furthermore, current and future projections should be adjusted so they are more consistent
with historical growth patterns and/or a range of projections should be adopted that reflect
meaningful planning scenarios in response to market changes over time. An analysis of the
inadequacy of the current long-range projections, authored by Palo Alto Councilmember Greg
Schmid, was submitted to ABAG during the Alternative Scenario selection process and is
attached to this letter. Tables outlining the discrepancies between the most recent DOF
projections and those prepared by ABAG for the SCS are also attached.
2. The City of Palo Alto continues to have concerns regarding the limited availability of land for the
proposed types and density of housing required to provide for the specified RHNA units. Palo
Alto is a substantially built out city, yet nothing in the methodology has taken that factor into
account. The built-out extent of Palo Alto and the relatively high quality of existing buildings
limits potential redevelopment and entails impacts (traffic, public services, neighborhood
compatibility, etc.) that are heightened by the limitations of land availability.
3. In addition to the points above, it is important to reiterate that the City of Palo Alto shares the
SCS’s vision to reduce Green House Gas emissions. As stated in previous letters, the City of Palo
Alto is a national leader in policies and programs that reduce GHG emissions. Examples of key
City sustainability programs include an aggressive Climate Action Plan, the provision of clean
energy to Palo Alto customers via the City owned and operated electric utility, various utility
programs to reduce emissions, leadership in Green Building and sustainable design, affordable
housing programs, higher density land uses near transit, and numerous “complete streets”
oriented policies and projects. The City encourages ABAG to allow flexibility within the SCS for
local jurisdictions to provide further means, such as those outlined in the letter, of reducing land
use/transportation related emissions.
Once again, thank you for the opportunity to appeal the adopted RHNA Methodology for the 2014-2022
Housing Cycle and the City of Palo Alto’s allocation. The required appeal template is attached. 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
H. Gregory Scharff
Mayor
Attachments:
A. Completed Appeal Template with Attachments
B. Table Comparing DOF/HCD Projections
C. Long-range projections analysis, authored by Palo Alto Councilmember Greg Schmid
Attachment B
ASSOCIATION OF BAY AREA GOVERNMENTS o Representing City and County Governments of the San Francisco Bay Area
ABAG
2014-2022 Regional Housing Need Assessment (RHNA) Appeal Request
All appeal requests must be received by ABAG February 18, 2013, 5 p.m. Late submissions will not be accepted.
Send requests to Gillian Adams, ABAG Regional Planner:
GillianA@abaq.ca.qov or P.O. Box 2050, Oakland, CA 94604-2050
Date: February 12, 2012
Contact: Curtis Williams
Phone: 650-329-2321
APPEAL AUTHORIZED BY:
Name: H. ------~~-----------------------------Scharff
Jurisdiction: _~o_f_P_a_lo_A_lt_o _________ _
Title: Director of Planning and Community Environment
Email: curtis.williams@cityofpaloalto.org
PLEASE CHECK BELOW:
[jJ Mayor 0 Chair, County Board of Supervisors
D City Manager
D
o Chief Administrative Officer
BASES FOR APPEAL [Government Code Section 65584.05(d)]*
[!] Misapplication of RHNA Methodology
[!] Failure to Adequately Consider Information Submitted in the Survey Regarding RHNA Factors:
D Existing or projected jobs-housing relationship
D Sewer or water infrastructure constraints for additional development
D Availability of land suitable for urban development or for conversion to residential use
D Lands protected from urban development under existing federal or state programs
D County policies to preserve prime agricultural land
D Distribution of household growth assumed for purposes of comparable Regional Transportation Plan
D Market demand for housing
D County-city agreements to direct growth toward incorporated areas of county
D Loss of units contained in assisted housing developments
D High housing cost burdens
D Housing needs of farmworkers
[jJ Housing needs generated by the presence of a university campus within a jurisdiction
[!] Significant and Unforeseen Change in Circumstances
Brief Description of Basis for Appeal Request and Desired Outcome:
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 RHNA Housing Element timeframe. SpeCifically, approximately 350
planned units on two sites on Quarry Road just west of EI Camino Real appear appropriate to include somewhere in the housing analysis in this timeframe. These two sites are
proximate to EI Camino Real and the University Avenue Caltrain station, and would be consistent with the objectives of the SCS and SB375. Furthermore, this land is not
protected agricultural land, and therefore should not be discounted as a suitable area for growth. It appears to be an oversight in the designation of priority development areas
(PDAs) that these sites were not included in the Valley Transportation Authority's (VTA's) "cores and corridor" designation and thereby treated as a PDA under the RHNA
methodology. The City notes that significant areas of Palo Alto, designated by VTA in "cores and corridors," have been treated as PDAs for the purpose of distributing housing
units, even though the City did not agree to their designation as PDAs. For these reasons, the City believes allocations should be adjusted accordingly. Historically, the
allocation of housing attributable to Stanford University between the City of Palo Alto, on the one hand, and the County of Santa Clara has been a complicated process. There
are several existing agreements between the City, County and Stanford that regulate Stanford's academic and non-academic build out. The 350 units planned for Quarry/EI
Camino, while contiguous with Palo Alto, are physically located in the County and are long ranged planned for Stanford housing. Therefore these units should be included in the
County's allocation and a commensurate number should be reduced from Palo Alto's allocation.
List of Supporting Documentation Included in Submittal:
1. ______________________________________________________________________________ __
2. ____________________________________________________________________________ __
3. __________________________________________________________________________________ _
*Per Government Code Section 65584.05(d), appeals to the draft RHNA can only be made by jurisdictions that have previously filed a
revision request and do not accept the revision request findings made by ABAG.
Department of Finance (DOF) Interim Projections released on May 2012 and the Regional Housing Needs Determination
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
2020 Projected Pop 2021 Interpolated Pop 2022 Interpolated Pop 2023 Interpolated Pop 2024 Interpolated Pop 2025 Projected Pop
7,593,463 7,635,944 7,678,425 7,720,906 7,763,387 7,805,868
Projected Monthly Pop Gain 3,540
Approx Pop on Oct 2022 7,692,585
HCD Regional Housing Needs Determination: ABAG with ADJUSTED DOF POPULATION PROJECTIONS
1 7,692,585 Approximate Pop Oct 2022
2 158,797 2.065% of Total Pop
3 7,533,788 Projecected HH Pop
Age Groups (ACS) Adj Projected HH Pop Headship Formation Adj HH
<15 1,361,769
15‐24 923,345 9.34%86,240
25‐34 1,003,990 40.41%405,712
35‐44 935,160 51.08%477,680
45‐54 1,053,815 53.84%567,374
55‐64 1,002,135 55.30%554,181
65‐74 754,681 56.81%428,734
75‐84 352,442 60.56%213,439
85+146,376 60.76%88,938
4 2,822,299 2,822,299
5 ‐2,665,507
6 156,792 8.8 Yr Proj HH Growth
7 Owner Renter Total
56.19%43.81%
88,101 68,691 156,792
1.50%5%
4,991 1,322 3,435 4,756 4991
8 808 0.50%161,548 808
9 ‐2,790 Effective Vacant Units Healthy Market Units
94,900 83,000 ‐11,900
1.55%1.48%
43,280 41,210 ‐2,070
‐13,970 ‐2790
159,801 Regional Housing Need Determination (RHND) with Adjusted DOF Population Projections
HCD RHND 187,990 Adjusted RHND 159,801 28,189 Diff in RHND
15%% DIFF IN RHND Adjusted Pop results in approximately 15% LESS HH Need
Estimate Projections
20%
September 11, 2012
Mr. Mark Luce, President
Association of Bay Area Government
Joseph P. Bort Metro Center
P.O. Box 2050
Oakland, CA 94607-4756
City9fPalo Alto
Office of the Mayar and City Council
Re: City of Palo Alto Request for Revision to Adopted RHNA Methodology for the 2014-2022
Housing Cycle
Dear Mr. Luce:
Thank you for ABAG's July 25, 2012 memo to Bay area cities and counties, which provided an
overview ofthe adopted Regional Housing Needs Assessment (RHNA) methodology and
jurisdictional allocations for the 2014-2022 housing cycle. While the adopted allocations
appear to have taken into consideration some ofthe concerns and comments expressed by
member jurisdictions, the target projections are still unrealistic. In Palo Alto, the built-out
nature ofthe city and multiple school, service and infrastructure constraints and impacts make
these projections unattainable. Therefore, the purpose of this letter is to request a revision to
the draft allocation, to reduce the total number of units assigned to the City of Palo Alto. In
support of this request, the following reiterates the City of Palo Alto's ongoing concerns
regarding the long-term Sustainable Communities Strategy (SCS) projections and the potential
impact on future RHNA cycles. Furthermore,this letter provides information about our ongoing
effort to facilitate a joint agreement for transfer of units to the County of Santa Clara for
housing on Stanford lands.
In summary, the City of Palo Alto's comments are as follows:
1. The regional forecast of jobs and housing for the region continues to substantially
overstate growth for the overall SCS period (through 2040) and continues to ignore the
updated demographic forecasts of the State's Department of Finance (DO F). This not
only creates an unrealistic scenario for the upcoming cycle, but also creates the effect of
"back-loading" the housing numbers and potentially creating unreasonable and
unachievable housing mandates in future housing cycles. Although the SCS process does
allow for adjustment of long-term growth projections on a periodic basis, the City
encourages ABAG to regain public confidence of its numbers by working with HCD to
reduce the 2010-2040 projections by 41% to reflect the adaptations already made by
Prlllted with '''jI-based il\ks 01\ 100% recyded pa~f Pt(l~$5ed without chlorlru\
P.O. Box 10250
Palo Alto, CA 94303
650.329.2477
650.3283631 fax 1
M r. Mark Luce, Presi dent
Association of Bay Area Government
September 11, 2012
the Department of Finance to the changing State of.California demographics.
Furthermore, current and future projections should be adjusted so they are more
consistent with historical growth patterns and/or a range of projections should be
adopted that reflect meaningful planning scenarios in response to market changes over
time. An analysis of the inadequacy ofthe current long-range projections, authored by
Palo Alto Councilmember Greg Schmid, was submitted to ABAG during the Alternative
Scenario selection process and is attached to this letter. Tables outlining the
discrepancies between the most recent DOF projections and those prepared by ABAG
for the SCS are also attached.
2. The proposed RHNA allocation assigns 77 housing units to the County of Santa Clara
(unincorporated), although Stanford University's General Use Permit with the County of
Santa Clara County allows and plans for up to 1,500 residential units to be built on
Stanford lands within the SCS timeframe. The City acknowledges that these units have
not been otherwise assigned to the City of Palo Alto, but at least some of them are
proximate to EI Camino Real and the University Avenue Caltrain station, and would be
consistent with the objectives ofthe SCS and SB375. Specifically, approximately 350
planned units on two sites on Quarry Road just west of EI Camino Real appear
appropriate to include somewhere in the housing analysis. City staff has met with staff
from the County and Stanford to discuss the possibility of ajoint agreement to a
"transfer" of a similar allocation of units from the City of Palo Alto to the County of
Santa Clara. This is an ongoing effort, and we will keep ABAG apprised of our progress.
The tity requests that ABAG remain open to such a transfer if an agreement between
the City, the County and Stanford is reached.
3. As stated in previous letters, the City of Palo Alto is a national leader in polides and
programs that reduce GHG emissions. Examples of key City sustainability programs
include an aggressive Climate Action Plan, the provision of clean energy to Palo Alto
customers via the City owned and operated electric utility, various utility programs to
reduce emissions, leadership in Green Building and sustainable design, affordable
housing programs, higher density land uses near transit, and numerous "complete
streets" oriented policies and projects. An attached letter, sent to ABAG on March 5,
2012, provides additional detail on these programs. The City encourages ABAG to allow
flexibility within the SCS for local jurisdictions to provide further means, such as those
outlined in the letter, of redUCing land use/transportation related emis.sions.
2
Mr. Mark Luce, President
Association of Bay Area Government
September 11, 2012
4. The City of Palo Alto continues to have concerns regarding the potential negative
environmental, school capacity and infrastructure capacity (recreational, utilities,
transit, etc.) impacts the overstated housing mandates may create. The City will, of
course, be conducting an environmental review to fully assess the impacts of these
mandates during the preparation of our Housing Element for this planning period,
Once again, thank you for the opportunity to comment on the adopted RHNA methodology for
the 2014-2022 Housing Cycle, As stated earlier, the City is officially requesting a reduction in
the proposed allocation for the reasons stated above. If you have questions or need additional
information, please contact Curtis Williams, the City's Director or Planning and Community
Environment, at (650) 329-2321 or curtis.williams@cityofpaloaito.org.
Sincerely,
~' ,1//" /~
Yi yJ I ---
Mayor
Attachments:
1. March 5,2012 Letter from MayorYeh to Mark Luce (ABAG), including two attachments:
a) November 15, 2011 Memorandum: "California Demographic Forecasts: Why Are the
Numbers Overestimated," prepared by Palo Alto Councilmember Greg Schmid
b) "Regional Land Use and Transportation SCS: Achieving Statewide GHG Reduction
Rates," prepared by Contra Costa Transportation Authority.
2. Tables Detailing Discrepancies Between Department of Finance (OaF) and SCS Projections
cc: City Council
Planning and Transportation Commission
James Keene, City Manager
Curtis Williams, Director of Planning and Community Environment
Ezra Rapport, Executive Director, ABAG
Miriam Chong, Interim Planning Director, ABAG
3
MUI'Ch 5,2012
Mr. Mllrk Luee, Pll!.~ident
Association or Boy Area Governments
Jos~ph P. Bort Metro Center
P.O. Box 2050
Oakland, CA 94607-4756
IAttachment 11
~i!yof Palo Alto
Officr of thr Mayor alld City Council
Re: City ofPlllo Alto Comments on Sustainable Communities Strategy (SCS) Alternative
Scenarios
Dcar Mr. Luce:.
AssoCiation of Bay Mila Governments (ABAG) staff has requested local agency comments on
its propo3ed land use Altcmalivc Scenarios developed B-1 [l part oftfJe One Bay Area Sustainable
Community Strategy (SCS). We look forward to the further discussion and refinement of the
Preferred Scenario before the final Regional SCS is completed early in 2013. However, at this
juncture we belitwe it is necessary for the City to express its concerns regarding the SCS
A/lemative Scenarios and the related regional jobs and housing forecasts, and to suggest
altemalive approaches 10 the Pre[ell'Cd Scenario.
This relle!' pll)vidas the City of Polo Alto's (City) comments, which have been fonnulated
following till: City's considentble review and analysis of the Alternative Scenarios and Ielated
regional job and housing forecasts. The Cily acknowledges llIId h[lpreciates the facl lhal the SCS
process wiU continue following release of ABAG's Preferred Scenario, scheduled for Morch B,
2012. In summary, the City's concerns are as follows:
• The City of Palo Alto has been a national leader in implementing policiCB and programs that
l'educe greenhouse gas (OHO) emissions and the effectiveness of these efforts should be
eonsidered os a pMt of the SCS and achieving regional GHO emission reduction targets.
• The regional foreca.~t of jobs and housing being considered as part of the SCS likely
overstates future growth in the Bay Area and at a minimum is highly uncertain; ABAG
should recognize the dislinct possibility that actual growth rates in the Bay Area over the
nexl30 years may be lower and should pha.~e job and housing allocations HOd
implementation accordingly.
• Palo Alto's allocation of jobs Rnd housing units under all of the Altemalive Scenarios is
excessive by reference 10 lis historical growth trends and development capacity; these
aUocatiom should more accurately consIder policy constraints, mlll'ket feasibility, and the
high infrastlUcture costs and local fiscal impacts of stICh intensive redevelopmenl
P.O. B .. l~250
P.lo AlIo, CA 94303
6.5IJ.3292f17
1 650.3283631 fox
ABAG: SCS AltemaUve Scenarios
March 5, :lOU
• The land use changes contemplated in the SCS Alternative Scenarios have a propOltionately
smull contribution to achieving AB321SB375 aHG reduction targets and there are very
limited differences shown between the Alternative Scenarios; the considerable effort and
investment needed to affcct these hmd use changes should be rc-directed to more cost
effective regional and local GHa reduction measures.
While the City retains serious concerns regarding the Regional Forecast of jobs and housing and
also the allocation of fuhIre development under the Alternative Scenarios, Palo Alto is firmly
committed to doing its share to achieve the State-mandated (AB32JSB375) OHG reduction
targets. The measures already adopted by the City provide ample evidence of this commitment.
Going fOlward, thc City expects to cooperate with ABAG and our other regional pOl1ners in the
future effort.~ needed to achieve substantial reductions in aHG emissions through realistie and
achievable regional and locol policies, programs, and investments.
The following items elabol1ltc on the summary points listed above.
1. 11U1 City of Polo AiJo lIas been a nalionolleader ill implemfilltillg policies and programs
t1laJ nlduce GHG en/isaio",. •.. .
Over the past decade, the City of Palo Alto has adopted a range of policies, programs and
projects to reduce OHG emissions, focused upon improving energy efficiency, enhancing multi
modal trausporMion alternatives tD the single-occupant vehicle, and creating walkable, mixed
use districts. Implementing these policies, programs, and invesl;ments the City has become a
national leader in redueing GHG emissions. Some of the key programs include: .
a. City of Palo Alto Climate Protection Plan (CPP): The CPP, adopted by the City Councilin
December 2007, includes goals for the reduction of CO2 from n 2005 baseline level as a result of
changes in City operutions and from CO~ reduction efforts within the community.
• The City has surpassed its short term goal of H 5% reduction in emissions by 2009 for a
total reduction of 3,266 metric tons of CO2•
• By 2020, the City and community will reducc emissions by 15% from 2005 levels, equal
to 119,140 metric tons of CO" oonsistent with State emission reduction goals.
b. Availability of Clean Energy: The City of Palo Alto is in a unique position as owner and
operator of its electric utility to make available and provide clean energy to City customers. In
this regard, the City Council adopted a goal to have 33% of the electricity supply to be provided
by renewable electricity suppliers by 2015, five ~BfS in advance of the State requirement.
• For FY20n, renewable electricity supplies account for 20% of the City's needs.
• Contracts are in place with suppliers to provide 26% of the City's eJectrical needs as
renewable by FY2014 with the potential to reach 30% from contracts that are still under
negotiations.
• Currently, 24% of the City's customers participate in the Palo Alto Green program,
paying a surcharge on electric serviee to support tenewable electricity supplies.
• The City's Utilities Department is preparing a. plan to be released later this ~a .. for the
electric portfolio to be carbon neutral.
!l8AG: SCS lI/1:ernalMl SCefiarlO1i
Mardi 5, }(lt~
C. UJi\ityPrograms to Reduce Bmission8: In addition 10 providing clean energy options for ilS
clllItomel1l. the Utilities Department offers programs such 6li rebate.,. assistance. Information, and
workshops 10 halp customclll inCn;aSI; electricity efficiency and c[)St &8vings that reduce
emissiollS. These succelises of these programs are mea.~tlrable: Tn FY2011, Palo Altooustomers
n::allced c.:'Ch emissions by 12,557 tons through the use of electdc and n!l1l1nli gas efficiency
programs. Incentives for solar photovoltaic (PV) and solar hot water systems, and other program
efficlellcleli.
d. Leadcr$hip in Green Building and Sllstainable Deliign: In FY 2009, the City Council adopted
the City's Green Building Ordinance to bulld a new generation of efficlelll buildings in Palo Alto
that are environmentally responsible and healthy places in whic~ to live and work, This program
Wall one of the first in the nation to mandale green building requirements and certifications for
virtually all public lind private buildings.
• In FY 2011, the Cily initialed tne fillit LEED-ND pilot program (LEED for
Neighborhood Development) in the United SllItes for llfi'i'CllSing a development site's
ability to qualify 115 a 5ustllinablc neigllbornood project, including featUI'es Ihal reduce
dependence on aulomobile lISe, increase walkability, and encourage healthy Jiving.
• The City also rolled out energy use disclosure requirements for eJlisting buildings
undergoing smalll'enov!ltlon work to better understand the existing buildings' current
performance and areas where education, policy, and prograJns can be innuentlal in
reducing energy mage.
• The amount of ro~ diverted from the environment has increased since the adoption of
the 2009 ordinance and programs. In 2010, the first full year of the ordinance, c.:'Ch was
reduced by approximately 1,013 tOllll. In 2011, (X)2 was reduced by a jJprcllimlltcly 2,818
Ions, II 178% increlille over the previous year.
• Prior ll) the Cily's ordilll!llctl, !Ill few lIS six geen building projccls existed IhruughoUllhe
City. By the end ofF! 2011, more than 240 green buildillgJ! have been compleled or arc
under construction,
'e, AffoIJlable Housing; The City of Palo Alto has been a Il'8der in providing for affordable
housing in one of the most expemlive housing markets in the nation.
• In 1974, l'lllo Alto became Olle of the firsl citillll in the United States 10lldoptlln
inclusionaty hou&ing program thllt required the provisioo of below markel rate (BMR)
residential units io new multiple-family dwelling projects,
• Today, the City oversees 239 ownership units III1d 198 rentlll BMR units that ate
IIvailable fo qualified applicant!!. As the cosl for h!lWllngill Palo Alto comlnucs to
inen:ase, the value of these affordable units to provide housing withln Ihl:'. wblmized Bay
Area hIlS Illso increalled. BMR 1100000ing provides gn:lII:er opportunily far lower i lICome
families 10 Jive closer to their jobo and utilize public IrIlnsil.
• Recently, Palo Alto welcomed two new BMR housing projects, including the Tree House
Apartments, 0 35·unlt comple/( with a Green Point R!I1II1f!, of 193 (the highest score in
Polo Allo for multiple family housing) lind AJta Torre, II 56""oil compleJl for very low
income seniol1!.
• Construction is underway at 801 Alma Streel, II So..unit family affordable project
immediately adjacent to CalTrain III1d within walking distance 10 shops and services on
Univllf'Sity AVl!IIUl! in downltlwn,
MAG: SCS AirornaUv8 scenarios
March 5, 2D12
f. Highe! Density Land USe.!! Near Tmnsit: The City's Comprehensive Plan designates two
Bre85 of the City (downtown lind CalifomiaAvenuej as appropriate for "Transit Oriented
RJ:sldential," in a 2,ooD-fool radius of the City's two Caltrain stations. These arcus are identified
for higher intensity residenlial and milted-use development focused around a W81kable, bicyele
friendly environment.
• In 2006, two years before the adoption of SB375, the City Council adopted the Pedestrian
and Trunait Oriented Development combining district (PTOD) for the ares around Ihe
California Avenlle CalTruin station. This disllici allows for residential densities 11140
units per acre, increased floor areA utios, increased building heights, reduced parking
requiremems. and density bonuses for the provision of BMR housing in milled-use and
multiple family projects.
• In 2007, Council ~upported the designation of this area iIIl a Priority Development Aren
(PDA) as part of ABAG's FOCUS program Ihat would eventually evolve into Plan Bay
Area. This land USe planning effort is one example of u pattern of early-adoption
decisions nlode by the City Council to address growth, tmnsit and greenhouse ga.~
emissions within ourconununity.
• The Council hIlS directed that housing sites proposed in Ihe City'S Housing Element
should be focused in trnnsit-prOldmate llI'Cas, and that increased height and intensity may
be considered in those loentions.
g. Transportation Policies and Projects: The City of Palo Alto has developed transportation
policies, programs and projects to implement a trans ii-oriented, walk8ble and bieycle-friendly
vision that demonstrate leadership of Ihe "Complete Streets" concept promoted by the
Metropolitan Transportation Commission, Somc of these key r=l1t measures include:
• Bicycle and Pedestrian Transportation Plan: The City is completing its updatw plan to
accommodate enhanced bicycle and pedestrian facilities and PnJgrams, and to elevate the
City'sBicycle-FriCndly Community slatus from Gold to Platinum level.
• Stanford AvcnuefBl Camino Real Intersection Improvements; The City has recently
completed improvements at this intersection to enhance safety for pedeslrians ond
. cyclists, including children who use the intersection as a route to school, and to upgrade
the aesthetic qualities of the intersection and of EI Camino Real. We e)(pect the project
will serve as a template for improving intersections throughout Ihe Grand Boulevard
corridor.
• Safe Routes to School: The City'S Safe Routes 10 School program bas resulted in II
phenomenal increase in school children bicycling and walking to school over the post
decade. In the 2011 fiscal year, Cily staff coordinated 140 in-class bike and pedestrian
safety education progrllllU in l2 elementary schools, reaching 4,250 student,. Recent
surveys of how children lISually get to elemenlary school showed an average of 42%
choosing to walk, bike or slalte to SChool, compored to a nalional aVerage of only 13%
(figureR for middle schools and high schools are even greater). A recent grant will ullow
the City to prepare Safe Route., maps for every elememary school in the city as well as 10
apand OUI education cuniculom into middle schools Md to adults.
• Traffic Calmipg pn Residenlial Arteriam: 'The City has an ambitious !raffie calming
program along "residential mneriaill" in efforts [0 support our Safe Rouecs to School
program and 10 enhance hicyde Hnd pedesloan safety. In particular. the ongoing
4
ABAG: SCS Alternative Scenarios
March 5, 2012
Charleston Road-Arastradero Road Corridor project has provided substantial safety
improvements and selective lane reductions to enhance bicycling and walking while
maintaining efficient levels of vehicle throughput simillll' to those prior to the traffic
calming improvements.
• Bicycle Parking COll'llls: The City has recently installed six green "bicycle parking
coll'llls" in the Bay Area. with each corrlll providing for up to 10 bicycle parking spaces
in highly visible, signed on-street areas in downtown. Up to a dozen more such
installations are planned in the downtown and California Avenue areas.
• California Avenue Streetscape Improvements: A pending grant would support the
substantial upgrade of California Avenue to a more pedestrian and bicycle-friendly
roadway, incorporating "complete street" principles, and also enhancing access to the
California Avenue Caltrain station.
• Local Shuttles: The City, with support from the Coltrain JPB, offers local shuttle services
for commuters, school children, seniors and others between points of interest within the
city. These shuttles fUl1her reduce the need for single-occupant vehicle trips and reduce
traffic congestion and parking needs.
Acconlingly,.the City of Palo Alto requests that ADAG consider the effectiveness of these local
GHG emission reduction efforts, incorporate them as a part of the SCS and related regional GHG
reduction targets. and provide "credits" to those jurisdictions that have demonstrated
implementation of meaningful GHG reduction measures.
2. Tile Regional Foreca.vt of job. v alld houslllg beillg conddered as part of the SCS appears to
oyerstate future growth ill file Bay Area.
The regional jobs and housing forecast used for the Alternative Scenarios is lower than the
foreeast for the Initial Vision Scenruio and the Core Concentratio[l Unconstrained Scenario,
reflecting conunents received from the local agencies following review of the Initial Vision
Scenario. However, in the City of Palo Alto's view, the mostrccentjobs and housing forec[l.~ts
for the three "constrained" Alternative Scenarios remain at the high end of plausible Day Area
jobs and housing growth over the next 30 years. The City is disappointed and dismayed at the
minimal public discourse around the development of these projections, though we do appreciate
Dr. StevenLevy's recent presentation of the analysis behind the projections. At this point,
however, ABAG has provided insufficient justification for the methods and results of the
regional job and housing forecasts used in the Alternative Sceml1ios. An evaluation of the
Regionnl Forecast prepared late last year by Councilmember Greg Schmid provides an
assessment of ('..alifornin growth forecasts (see Attachment A), indicating the tendency for
foree asts to overstate growth as compared to actual figun::s from the Census. and discussing
some of the key factors that will influence California's future growlh.
a. Jobs. Regarding thc ABAG jobs foreeast, a comparison with the last 20 years is noteworthy.
Average job increases between 1990 and 2010 approximated 10,000 net new jobs annually.
Excluding the three years that included the Great Recession where substantial jobs losses
occurred (i.e. 2008-2010), the Bay Region added jobs at an average annual mte of 25,200
between 1990 and 2007. The ABAG jobs forecast used for the Alternative Scenarios
assumes that the Region will add an average of over 33,000 jobs annually from 2010 to 2040.
5
AIlAG: SCS Alternative Samarlos
March 5, 2D12
a 32% increase over the pre-recession trend line. The method used to arrive at the jobs
forecast assumes a "shift-share" of a national jobs growth forecast that itself is subject to
question. As a pan of revisions to the regional jobs forecast, ABAG should consider a more
fundamental economic assessment that identifies the key industries in the Bay Area that will
drive job growth and also the distinct possibility that future jobs and housing may be closer
to recent historical growth trends.
b. Housing. Regarding the ABAG housing forecast used for the Alternative Scenarios, an
additional 770,BOO households are shown added to the Bny Area between 201 0 and 2040 -an
annual average growth of 25,700 households. The average annual housing growth rate
between 1990 and 2010 was 21,000. At the present time, two years into ABAG's forecast
period. the Bay Area, like.much of the United States. remains in a weak housing Qlnrket
characterized by very limited new development, low pricing, slow sales of existing homes,
tight eredit, and an oversupply of homes resulting from a historically high number of
foreclosed and distressed properties. These conditions are expected to continue for several
more years until the existing inventory is reduced and substantial improvement in the job
market and related increases in household income occurs. In any event. the Bay Area will
need to be in "catch-up" mode, meaning even higher additional households per year must be
realized to meet the SCS forecast growth rates, once more norma] housing market conditions
emerge. Moreover. ABAG's regional housing forecast is based on a filled share of a national
popUlation forecast prepared by the U.S. Census Bureau that presumed international in
migration (primarily of Asian and Hispanic peoples) would continue and comprise
approximately 80 percent of all population growth nationwide.
c. Housing Affordability. In addition to questions regarding job growth (the ultillUlte calise of
housing demand) there are a number of other questions regarding ABAG's housing forecast
including those relnted to affordabiJity. A presentation made by Karen Chapple of UC
Berkeley at the ABAG's January Regional Advisory Working Group (RA WG) suggested
that given likely wages paid by the new jobs expected, over70 percent of all new households
formed in the 2010 to 2040 period will be "moderate" income or below. In many Bay Area
locations, especially the inner Bay Area urbanized areas that are the focus of growth under
the SCS Alternative Scenarios, such "affordable" housing units must be subsidized in one
fashion or another, either as "inclusionary" units burdened upon the market rate units
constructed 0]' by public sl.Ibsidies such as (now eliminated) redevelopment agency funding
and federal tax credits. Given the loss of redevelopment powers and funding and Iccent court
cases affecting inclusionary programs (palmer, Patterson) there is no assurance that adequate
housing subsidy funding will be available. .
d. RHNA. Then there is the matter of the Regional Housing Needs Allocation (RHNA). As
presently proposed, the regional foreeast and related Preferred Scenario allocations to be
released as a draft on March g'b will apparently serve as the basis of the future RHNA for
each city and county, whieh will require a one-third of the overall Preferred Scenario housing
allocation to cities in each 8-year "planning period" regardless of any assessment of realistic
development capacity (note: recent information from ABAG indicates that less than one-third
of the 201 ()"2040 forecast IS likely for the 2015-2022 period, however, due to the economic
A8AG: SCS AlternatIVe Scenarios
March 5, 1011
housing downturn). This approach seem8 highly arbitrary, insensitive to local conditions and
constmillts, and far beyond what can realistically be expected from Qn economic perspective.
Accordingl y, given aU of these concems. the City strongly recommends that the jobs and housing
forecasts for the Preferred Scenario be reduced to reflect more aceuralely current conditions,
historical trends, and more fundanlenllli assessment of economic (job) growth potential in the
Bill' Area. Developing a more realistic jobs and housing forecast would reduce the implied need
to intensify land uscs, redu{:e projected GUG emissions by lowering energy consumption,
congestion and single occupancy vehicle trips, and require less costly transit and highway
infrastructure investments. The SCS effort i. 10 be revisited and updated every four years, so that
there would be "Cuture opportunities to re-evaluate whether a higher forecast is appropriate and
adjustments would be needed.
1. Pala Alto's allocation ofjobl tJnd IlOusing Imit, IIndeT the Alterna/ipe SU/Jiuio.r iI highly
u/lTBallaHc and ucesMil'e relative trJ Iwlomar growth tnmdr and devBwpment Mp4City.
Santa Clara County dominates all other Bay Area counties in tRe allocation of ABAG's regional
forecast of jobs ~nd housing, absorbing 30 percent oJ the regional job forecast and 26 percenl of
the regional housing forecnst. Palo Alto is allocau~d new jobs ranging from 18,040 Outward
GI'owth) to 26,070 (Focused GI'owlh). Palo Alto households allocated range from 6,107
(Outward Growth) to 12,250 (Constrained Core Concentration and Focused Growth). These
allocations have been made without rega!'d to existing developuplt capacity in Palo Alto (use of
remaining vacant land and redevelopment of existing developed areas). the likely match between
new household affordability and local housing prices, or a range o(other pOLCntiallocai costs for
achieving the required high density development < <
a. Jobs. The City presenlly contains approXimately 62,300 jobs, according to ABAO. During
the past decade (2000 to 2010). Palo AIm experienced a 14 percent decline in cmployment
reflecting the combined cHoct of the "dot-com" bust and the Great Recession. Whilo
e(:onomic conditions ore expected to improve, there have been structural changes in
teChnology industries that hove ddven growth in the Silicon Valley over the past 50 years
that portend only modest growth. The Alternative Scenarios assume that Palo Alto's job
growlh by 2040 will Increase over the 2010 e.qtimate by between 27 percent and 40 percent.
b. Housing. The hDlL'ing projections in the A1tcrnative Scenarios represent a 2.5-50 percent
increase in housing units from 2010-2040, up to approximately 400 new units per year, The
Cily has In thc past 40 years (1970-2010) produced an average of 14& units per year. Tn more
tllan double thai ootput in a relatively built-out city is again entirely unrulistic and using
such on assumption liS the basis for growth scenarios ond transportation investmenL~ will
likely result in failure of the planning effort.
c. Constraints. The City of Palo Alto is highly built out, and the existing limited number of
vacant sites and redevelopment opportunity sites severel y limit how the households and jobs
ollocated to Palo Alto in the SCS Alternative Scenarios could be accommodate{], The
"constrained" scenolios clearly do not appear to consider the many constrainl8to new
development in Palo Alto" including limited school capacity Bnd funding for infrastructure.
7
A~AGr SCS Alr.rnawe Scenaria.
Ma",h 5, 2012
Accordingly, the City requests that the allocations of jobs and housing units in Palo Alto should
be lowered substantially to more accurately consider policy constraints. market fC!llIibility. and
infrastructure and local fiscal imracts of such intensive redevelopment.
4. The 141td us/! chaRge .. clJ/ltemp/Qted in tile SCS AIterllati¥B SC6t1arias have a
praptrrtiolJately small conJributum ta aciJisvi"g AB32/SBJ7S GHG reduction targets.
The AB32/SB375 target for Califol1lia is a reduction to 85 million equivalent metric tons per
year by 2050. an 80 rcrcent reduction from current levels. To return to 1990 levels of 427
million Ions. an 80 million ton reduction of projected 2020 levels is required. Of this 80 million
ton reduction, approximately 96 percent is propoaed to be achieved from improved fuel standards.
energy efficiency, industrial measures, and other methods needed to curb emissions from the
construction, manUfacturing, and agricultural Si:ClOrll. Only four percent. however, or 3.2 million
lons, would be achieved by altering land use patterns. This is shown elfectivelyon the graph
(Allachment B) prepared by the Contru Costa Connty Transportation Authority (CCfA) in their
letler dated February 15,2012.
a Negligible Difference Between AlternatiVe!!: The potential contributions of the land use
changes contemplate.:! in the SC.s A1temativ!, Scennri03 show reductions in GHG emissions
through 2040 range from 7.9 percent (Outwurd Growth) to 9.4 percent (COnsuained Core
Concentration). Compared 10 the initial CUffent Regional Plun Scelllltio, tne Alternalive
Scenarios reduce GHa emissions by Q.9 percent to 2.4 percent of the remaining4 percent
affected by land use and transportation patterns. This is a negligible difference between the
land usc scenarios and argues for a more f1~){ible approach that combines olller GHG
emission n:duction strategies witn a more realistic land Ulic scennrio.
b. Regional Transportation Pricing and Policies: The MTC analysis of various transportation
pricing and policy changes (e.g., telecommuting. electric vehicle 8trll1egiCs, parking pricing)
may account for alleast a 6.5% fw1her reduction in aHa emissions, considerablY more
signiflcantthan the differences between the land usepatte.ns in the Alternative Scenario.~.
c, Cost Effectiveness. Given the numerous challenges associated with fundamental changes ill
the way that Bay Area land usc pallerns would otherwise evolve, including wholesale
changes to land use regulations. presuming changes in market characteristics and preferences
of homebuyers, and the need for substanlial public investments and subsidies, we question
the fCHsibllity and.cost-cffectiveness of the Alternativc Scenarios. Regarding market
feasibility, there is no .:vidence that the resulting hOUSing capacity and prototype!! would
match buye.r preferences and affordability. Regarding cost-effectiveness, the com[larahle
costs (mostly borne by local jurisdictions) of implementing the Altemative Scenarius may bc
far higher than other alternatives for achieving compllIable GHO emisfiion reductions.
Acconlingly. the City of Palo Alto recommeoos that a performB,!ce-based approach, involving
establishing GHG reduction targets for the local jurisdictions along with a menu of opllonslbr
achieving these targets (including feasible and realistic alterations in land u~e pOlicy) should
become the basis of the proposed SCS.
B
Conclusion
A8AG: SCS Altem.Uve Salnario$
March 5, 2012
In conclusion. the City of Palo Alto suggests that the Preferred Scenario for the Sustainabil!ty
Communities Strategy should include:
• A focus on GHG emission reductions, with the flexibility for each city and county to
provide for a reasonable minimum mnounl of housing pltls options for other
commitments to GHG emission reductions;
• Grant funding for transportation and planning oriented to Priority Development Areas
(PDAs);
• Realistic housing forecasts limiled to each upcoming 8-year RHNA cycle, with (eview
every four years to update projections; and
• Longer range projections thai are not allocated to cities and counties, but are used to
provide contex:t for regional transportation investments.
Thank you again for the opportunity to comment in advance of your proposal for a Draft
Preferred Scenario. If you have questions or need additional infonnalion, please contact Curtis
Williams, the City's Director of Planning and Community Environment, at (6.50) 329-2321 or
curtis. williams@cilyofpaloalto.oI,g.
Sincerely,
j), (;'-), /i...~.-,
{YiawayYeh
Mayor
City of Palo Alto
Attachments:
Attachment A: November 1.5,2011 Memorandum: "California Demographic Forecasts: Why
are the Numbers Overestimated," prepued by City of Palo Alto Councilmember
Greg Schmid
Altachment B: ''Regional Land Use and Transportation SCS: Achieving Statewide OHG
Reduction Rates," prepared for Contra Costa Transportatior! Authority
cc: Adrienne J. Tissier, Chair, Metropolitan Transportation Corrnnission
Steve Heminger, Metropolitan Transportation Commission
Ezra Rapport, Association of Bay Area Governments
John Ristow. Valley Transportalion Authority
Palo Alto City Council
9
California Demographic Forecasts: Why are the numbers over
estimated7
Prepared bv City of Palo Alto
November IS, 2D11
Actual California Popu[atiGn growth
Attachment a
1
Over the la,t decade, the state of California added 3.4 million people, 10 reach a total of 37.3 million.
This WaS an Increase of 10% oller the decade. Thi, growth rate follow~ t~e gradual slowing that,tarted
after·1990, down dramaticallytrom thellery high rate, of the post-World War II era. NOIe thaUne
Del'artmehl ofFinanee's (DOFI2007 projections retlect a very high growth perspective. The DDF
. "umbors are tutrently used as the population forecasts tor allstate and local prolects-th"" are not
5chedul@dtobe rellised until 2013.
Table 1. California's populadon growth OVer tbe last live decades
laverage growth from census 10 census)
.!:mila DW af Finance Pra["ftions 120071
1960s 29.2
1970s 18.5
1911O.s 25.7
1990i U.8
2000$ 10.11 14.8
211111s 12.8
20Z0. 11.6
Z030i 10.2
Source: US Census BUreau actual Census nllmbers; Callfarnia Departmonl af Finance 2007 PIOjE!Clions.
Recent State forecasts have been consistently over-estimated
E~en after the sharp decline In growth during the 19905, fOlstaslers consistently tended to be overly
optimistic .bout po~ulalion growth rale.through the 2000" In 2005, the Public Polity Institute 01
California issued a report ("Callfomlo 2025: Taking on Ihe Future") that I~tluded the populadon
proJections of all the key demo!lra~hlc forecoste". The consensus f",ec .. t from Ihls group was some
4Il% higher than the Mtual oulMme for the state:
Table 2. California Population Forocasts for 2010 made before 2005
(Percentag. voWlh expect"d from 2000-2010)
Callfomla Depl of Finance 15.2
USC Pupulallon Dynamics ·11.6
UC BlII'kele¥ (Lee, Miller) 13.9'
Public Pallcy Institute at CA 15.Z·
CCSCE 17.2
UCLA Anderson Farecasting 16.6
Aurase of siX ZOOS foretosts 15.0
'=center ~olnt at band
Source: Public Policy Insdtute of California, ·Callfornla 2025: Tald~ on Ihe Future", 2005, Page 29.
2
The consel1SU' forec.st was some 50r. above the actual numbers. The only lorQCaster who produced a
number below the actualtO')6 growth waslhe UC Berkeley group who staled Ihat there wa5 a 5%
Chance that the growth rale would be lowerthan 7.1%. The 2005 PPIC Report .taled thol "Recent trend5
make population proje[lIons fot California es"..ci.l1y dlfflcull...For these reasons, plannersshould
consider alternative population scenarios ... as useful aitematllles lor planne ... • (PPIC, 2005, pages 27·
ZS)
Even as late as Ihe end of 2009, on the ~e ofthe detenni.I census, estimates by Ihe California Depl. 0/
FinanCe (the organization re.sponslble forthe nutnbersthat are used for all state allocation formulas)
remained strikingly high at 14.l% which was 1,5 million or 44.7% a~ the a bo~e the
contemporaneou, and more accurate Ce~5u, Bureau's Current Population Estimate •.
C,'Weal Components of Change and the Future
The Census data provide a nice detailed perspective on the ~ctlJal components of change during the
decade. W~lIe the 3.1 million people added through natural increase Ibirths minus death,) were the
large.t .ingle growth factor, the 2 million net gain from loreign immigration was important In
overcomlnl a net outflow of 1.6 million Irom native born emigration. prlmarilv to other .tales.
Tabl8 3. Components ofl'opulation Change In Cdlfornla.. ZBOo-2010
ImUlions of people'
Births
Death.
+5.45
-2.35
Net Domortlt mljration -L63
F"relEn Immigration +2,58
F"r"ie" "mlRlalion -D.59
MNluny, elt -Dm
TaTAL +3.38
Sourc,,: USc, Population Dynamlo Resear.ch Group. ''What th .. C"mllltwQuld shoW". February2DU.
3
The challenge for prolecting change In the future Is the dramatic sl1ifC' In some 01 these base categories.
With the aslng population, we know that, .~en with slight Increases In 10nBe~ltv, the aging population In
California will ratse the annual number 01 deaths In Calilornia from 271K In 2011 to 462K In 2039, while
the number of births will rise sllghtlv from S32K In 2011 to 551 in 2039. The naturaltncrease will fall
from some 250K today to 90K In 2040.
Thu •• over time any Incre .. e in Californ a's population will increasingly mly on migration. Since net
domestic migration has aVQraged a net olJlflow 01 some lOOK per vear 'inee the earlv 1990s. any growth
In popl.llation will he IncreasIngly dependent on larelgn migration. (Source: USC, Popl.llatlon !/oinamic5
GrOllfls, AprIl21J1l].
There Is lillie reason to See a major shift in domestic mlgntioRwith C8"'omla'. high cost and ~igh
unemployment rate. That 'eBVlU 10reiRn mlgratlon.s the critleal component source of long-term
population growth. The most dynamic .0Urce for calilornla's srowth has been Immigration from Me_ico.
hoth legal and illegal. All obser~.rs (The Dept 01 Homeland Security, the Pew Charitable Tnun Hispanic
Center, and the Me~lcan Migration Proja.t at Princetonl agree thaI net Imml.eratlon from Me1<ico hu
been down dramaticallv In retent years with the strltter enforcement elborder orossing and the
p rOlanged rece.slon In the us. Pew estimate. that "e ill"gallmmlgrant pop~latlon In the US fell bV
some 7% between 2007 and 2010. The imponont debate about the future is whether this I •• bwiness
cvcle phenomenon or part 01 a longer term trend.
The group that has the be.tdat. source and takes the longer term look is the Mexican Migration Prolect
at Princeton. For dECades they have been tracking migration pattern' from Mexico and doing annual
survevs of thousands of families from migration centers In Mexico. They foondthat the percent 01 nrst
time Immigrants from the Mexican communities of highest immiBration fell from 1.Z'lI. of adults In 2000
to 0.6% in 2005 to lero In 2010. TheV Identify that the changes are due to Malcan demographic and
economic factor5 as much liS from U.S. conditions. Thllyldentlfied five internal factor. of change In
Mexico:
• Fertility roles are falling dtllmlltically from S.8 birth. , .. ,-women In 1S70 to 2.Blo 1995 to 21n
2010 IreJllaceme~t level).
• The number of young Plople enterins the labor market on fallen from One million a vear ill tne
IS90s to 700]( lodav and demographic factors will bring Ihil down Iv abouI3QilK In 2030, Mt
enoush to meet klca I job needs.
• The ral. 0/ college ,,\lend"nee .nd college completion has doubl.d oVer tne Jalt dec~de. raising
the Ciresr patn of an increasing share of voung w<>rkers.
• The wage disparitv betWl"en Mexico and the U.5.ls narroWing sharplv with .""rI8B wage gaps
falling from 10:1 in the 1960. 10 some 3.7:1 In the e.rlv 20005.
• The cost of migration h •• rken dramatlcallv lor Utega! entrants, further narrowing the ear~lnBS
gap.
1\11 of these factors point to the ~eed. at the least, of looking at alternative scenarios of population
growth In california that are more $en.itlve to possible underlying chanlll's In migration pattern'.
5
Sources of Demogl'aphic projections about California
US Bureau 01 the Censuslresponslble for the decennial census and does updated .stlmates each vear of
state populations-has been much cioser to actual numbers than the Cal Dept, of Finance)
California Department of Finance (responsible for state population .nimales between the Census
vealS-forecasts used as IteV source for state government planning). Statewide estimates for 2010
(made In 2009) were 41% higher than the 2010 Census numbers for the state, 83% over for the nine Bay
Area counties and 137% higher for the three West Bav counties.
Ronald Lee, UC Berkelev, Center for Economl~ and DomolP'aphip of Aling, "Special Report! The
Growth & Aging of Callfurnla's Population", 2003 (an Important repon that identified the det.ned
assumptions that went into the Department of Finance's long·term projection.).
Hans Johnson, Public PollcV Instltut.e of Callforn/a, "callfornl~ 2025: Takfng on the Future",ChaptEr 2
'californi.'s Population In 2025' (a report that gathered projections from eight academic and
government sources]. JohllSOn concluded that ·poPlJlatlon protections for cailfornlaar. especially
diffkult. . .1n addition 10 overweightins contemporary trends, foreca,ters are notoriouslv bad at
predict Ins fundamental demographic Shifts .. , for these reasons, planners should consider alternative
population scenarios: Pages17-1B.
John pltldn & Dowell Myer., USC Population Dynaml~ lIeseBrdJ Group, "The 2010 Census Benchmark
for California'. Growing and Changing Population", February J011; "Projections of the Population of
caJifornla by N.~Vltv and Voarof Entry to the U.S:, Aprfl2, 2011. ,Pltkln and Mvers had the 10 wert of
the foreca,l$ in the 200S study-though stlll overestimating growth by 16%, They .re worldng with the
California Department of Finance on components for a new lunger.term forecast; thEv ale .tm assuming
a net Imml~ratlon number of 160,000 holding steady In the futur •• ]
S"'"e LollY, Center for the Continuing Studv of the callfDrnla Economy
UClA Anderson Forecasting Project
Grell Schmid
Detotter 2011
FIGURE 3: Regional Land Use and Transportation SCS
ACHIEVING STATEWIDE GHG REDUCTION TARGETS
Tons'
Required Reductions: CD 2020 Emission, ................................. 507
Bay Area Regional Contribution
Scenarios _~"'I 0%
Year Tons·
By 2020 ........... 80
By 2050········· 715"
850
800
750
700
650
600 -550 c
C!l
C > 500
'5 450 0-427 w
'"' 400 0 U 350
'" c 300 0 l-
v 250 '£
80%
CI) 200 :E
c 150 ,Q
~ 100
50
1990 1995
o Target 2020 Emission, 11990)················427 7.0'Yp Current Regional Plans -----::Ii;;
7.'I"k Outward Growth-----1I:~
8.2'7'0 Initial Va.sion/Core ConcenfTation
@ Foreca,t 2050 Emission, ...................... 800" o Target 2050 Emissions 120"10 of 1990) ....... 85
® Target 2035 Emission, r,nterpolated) ······275 9.1% FocuseC Growth --------'
"'Million Metric Tons C02 Equivc~nt
.. Estimate based on Colifomio Council on
Science end Technology Report, 2011
2000 2005 2010 2015
9.4% Constrained Core Concentration
S07 CD
275i®
2020 2025 2030 2035 2040 2045
Projected Land Use & Transportation Emissions Reductions
REGIONAL LAND USE & TRANSPORTATION (SCS)
LOW CARBON FUEL STANDARDS
IMPROVED FUEL EFFICIENCY [PAVLEY I & II)
; NON-TRANSPORTATlON EMISSIONS REDUCTION
ACTUAL/PROJECTED EMISSIONS
15%
5 0
2050
Comparison of Department of Finance (DOF) Interim Projections released on May 2012 and the Preferred Sustainable Community Strategy (SCS) Projections released on May 2012
Department of Finance (DOF) Interim Population Projections for California and Counties: July 1, 2015 to 2050 in 5‐year Increments
DOF 'Pop. Growth
2000 2010 2015 2020 2025 2030 2035 2040 2045 2050 2010 ‐ 2040
Bay Area Region 6,805,677 7,165,778 7,365,127 7,593,463 7,805,868 8,023,484 8,240,104 8,433,609 8,585,622 8,726,594 1,267,831
Alameda County 1,448,768 1,513,251 1,547,734 1,584,797 1,619,555 1,650,596 1,678,473 1,705,642 1,722,773 1,734,695 192,391
Contra Costa County 953,675 1,052,024 1,102,534 1,161,014 1,209,433 1,263,049 1,323,005 1,381,576 1,438,880 1,496,207 329,552
Marin County 247,424 252,727 253,757 255,502 257,117 259,060 261,982 264,910 267,590 270,275 12,183
Napa County 124,601 136,659 141,951 146,582 152,439 158,538 165,088 171,625 178,478 183,352 34,966
San Francisco County 778,942 807,048 813,090 820,135 826,850 834,693 842,065 845,750 844,247 840,712 38,702
San Mateo County 708,384 719,467 735,025 751,480 765,495 776,862 786,730 791,781 793,885 794,162 72,314
Santa Clara County 1,687,415 1,787,267 1,846,126 1,917,070 1,980,661 2,048,021 2,110,906 2,164,936 2,195,432 2,220,174 377,669
Solano County 395,991 413,154 428,106 446,513 468,039 490,381 512,695 533,041 552,869 574,705 119,887
Sonoma County 460,477 484,181 496,803 510,370 526,280 542,284 559,160 574,347 591,469 612,312 90,166
Projections Prepared by Demographic Research Unit, California Department of Finance, May 2012
Draft Sustainable Community Strategy (SCS) Population Projections for Bay Area Counties: 2010 to 2040
SCS 'Pop. Growth
2000 2010* 2015 2020 2025 2030 2035 2040 2045 2050 2010 ‐ 2040
Bay Area Region 6,784,400 7,150,739 7,787,000 8,133,885 8,497,000 9,299,159 2,148,420
Alameda County 1,510,271 1,988,032 477,761
Contra Costa County 1,049,025 1,334,968 285,943
Marin County 252,409 285,317 32,908
Napa County 136,484 163,609 27,125
San Francisco County 805,235 1,085,656 280,421
San Mateo County 718,451 906,070 187,619
Santa Clara County 1,781,642 2,425,645 644,003
Solano County 413,344 511,482 98,138
Sonoma County 483,878 598,380 114,502
Projections Prepared by ABAG, May 2012
* 2010 SCS based on actual 2010 Census counts
Percentage Difference between 2010 and 2040 DOF Interim and SCS Population Projections for Bay Area, comparing SCS to DOF Interim Population Projections May 2012
2040 Pop. Difference SCS
& DOF
2000 2010 2015 2020 2025 2030 2035 2040 2045 2050 2040
Bay Area Region ‐0.3%‐0.2%2.5% 4.2% 5.9%10.3%865,550
Alameda County ‐0.2%16.6% 282,390
Contra Costa County ‐0.3%‐3.4%‐46,608
Marin County ‐0.1%7.7%20,407
Napa County ‐0.1%‐4.7%‐8,016
San Francisco County ‐0.2%28.4%239,906
San Mateo County ‐0.1%14.4%114,289
Santa Clara County ‐0.3%12.0%260,709
Solano County 0.0%‐4.0%‐21,559
Sonoma County ‐0.1%4.2%24,033
Percentage Difference 2010‐2040 Projected Population Rate of Growth, comparing SCS to DOF Interim Population Projections May 2012
2010 ‐ 2040 Net Gain
Difference SCS & DOF
2000 2010 2015 2020 2025 2030 2035 2040 2045 2050 2010 ‐ 2040
Bay Area Region 48.8%57.0%69.5%880,589
Alameda County 148.3%285,370
Contra Costa County ‐13.2%‐43,609
Marin County 170.1%20,725
Napa County ‐22.4%‐7,841
San Francisco County 624.6%241,719
San Mateo County 159.4%115,305
Santa Clara County 70.5%266,334
Solano County ‐18.1%‐21,749
Sonoma County 27.0%24,336
Estimate Projections
Estimate Projections
Estimate Projections
Estimate Projections
/' ,
Representing City and County Governments of the San Francisco Bay 1m2 NOV " 9 AMI I : 2 7 ABAG
November 15,2012 HECEIVED
CITY MANAGER'S OFFICE
Mayor Yiaway Yeh
City of Palo Alto
P.O. Box 10250
~:":';:-i [--
Palo Alto, CA 94303 !
Subject: ABAG Response to RHNA Revision Request
Dear Mayor Yeh, .
I am writing in response to the City of Palo Alto's (City) request for a revision of your
jurisdiction's draft Regional Housing Need Allocation (RHNA) for the years 2014-2022.
ABAG's Executive Board adopted the final RHNA methodology for this cycle at the July 2012
meeting. The final methodology was developed with a substantial amount of comments,
discussion and advice from a Housing Methodology Committee made up of elected officials,
senior staff and interested parties from around the region. In making its decision, the Executive
Board tried to balance SB 375's emphasis on greenhouse gas reduction with the need for all
jurisdictions in the region to provide housing choices for people at all income levels.
(t"':-'::
" .,~ '.~ .
........ ·.,;.1
As you are aware, SB 375 requires that the RHNA be consistent with the development pattern
included in the Sustainable Communities Strategy (SCS)l. To help ensure this outcome, the
adopted RHNA methodology initially allocates the pre-determined regional housing need from
the California Department of Housing and Community Development (HCD) to local jurisdictions,
consistent with the land use criteria specified in the draft SCS2 for the RHNA period, 2014-2022.
Through this process, the region's housing, transportation, and land use planning are aligned.
Adoption of the final RHNA methodology was accompanied by release of draft RHNA numbers
for each jurisdiction. This initiated a 60-day period in which local jurisdictions could request a
revision to its RHNA. By law, revisions to these allocations must be: 1) in accordance with the
factors outlined in statute that are the basis for the methodology, 2) based on comparable data
available for all affected jurisdictions and accepted planning methodology, and 3) supported by
adequate documentation. 3
1 California Government Code Section 65584.04(i)(1)
2 ABAG used the draft SCS adopted in July 2012, commonly known as the Jobs-Housing Connection Strategy
(JHCS), because of the timing differences between the SCS and RHNA processes. 'ro ensure consistency, ABAG
will make no changes to the land use criteria of the SCS for the period from 2014-2022.
3 California Government Code Section 65584.05(b)
Mailing Address: P,O. Box 2050 Oakland, California 94604-2050 (510) 464-7900 Fax: (510) 464-7985 info@abag.ca.gov
Location: Joseph p, Bort MetroCenter 101 Eighth Street Oakland, California 94607-4756
Page 2 of3
Response to City of Palo Alto RHNA Revision Request
November 15,2012
Your letter indicates the City of Palo Alto's concerns that the SCS overstates growth, the
County's allocation is too low, credits should be allowed for other GHG reduction efforts, and the
housing mandate will have negative effects to the environment, school capacity, and
infrastructure.
Per the RHNA statutes, the factors mentioned by the City cannot be used to lower a jurisdiction'S
allocation. The region must allocate 187,990 units to all jurisdictions as directed by HCD. Even
if ABAG were to lower the SCS forecast, the RHNA would still have to distribute the 187,990 to
all jurisdiction.
The County's allocation is based on the growth potential and factors derived through the SCS and
RHNA methodologies. However, ABAG is open to transfers between jurisdictions that meet the
limitations outlined in the RHNA statute.
The GHG reductions encompassed in the SCS under SB 375 are specific to land use changes.
Other ef~orts by local governments to reduce GHG need to be addressed under AB 32.
The regional housing need goal is to promote the following objectives: increase the housing
supply and the mix of housing types, tenure,and affordability in all cities and counties within the
region in an equitable manner; and facilitate infill development and socioeconomic equity, the
protection of environmental and agricultural resources, and the encouragement of efficient
development patterns.
Per Government Code §65584.05, a jurisdiction has an opportunity to appeal ABAG's denial of
its revision request. The deadline for local jurisdictions to submit a request for an appeal is
February 18,2013. If you decide to pursue an appeal, please contact ABAG staff to obtain a
template to use when submitting your request.
As background, Government Code §65584.05 provides details about the specific criteria on
which an appeal must be based. The two grounds for requesting an appeal are:
• ABAG failed to adequately consider the information submitted by your jurisdiction as part
of the survey we administered in January 2012 or a significant and unforeseen change in
circumstances has occurred in the local jurisdiction that merits a revision of the
information submitted in the survey; or
• ABAG failed to determine the jurisdiction's share of the regional housing need in
accordance with the information described in, and the methodology established pursuant
to Government Code §65584.04.
\
Page 3 of3
Response to City of Palo Alto RHNA Revision Request
November 15,2012
Appeals will be heard by an ad hoc committee of ABAG' s Executive Board at a public hearing
between March 30 and April 4 (date to be determined).
Thank you for your continued involvement in developing the SCS and RHNA. I look forward to
continuing to work with you on developing policies and programs to address the region's housing
challenges. If you have questions about RHNA or the appeals process, please contact Gillian
Adams, Regional Planner, at 510-464-7911 or GillianA@abag.ca.gov.
Regards,
Miriam Chion
Interim Planning Director
CC: Mark Luce, President, ABAG
Ezra Rapport, Executive Director, ABAG
ASSOCIATION OF BAY AREA GOVERNMENTS
Representing City and County Governments of the San Francisco Bay Area
M E M O
To: ABAG Executive Board
From: Miriam Chion, Interim Planning Director
Date: November 7, 2012
Subject: RHNA Revision Requests and Start of Appeals Period
Summary
The ABAG Executive Board adopted the final Regional Housing Need Allocation (RHNA) methodology
and draft housing allocations to local jurisdictions on July 19, 2012. This initiated a 60-day period in
which a local jurisdiction could request a revision to its RHNA. ABAG staff has 60 days (until November
15) to respond to these requests.
By law, a local jurisdiction that has requested a revision has the opportunity to submit an appeal if ABAG
does not accept the proposed revision or modify the revised share to the satisfaction of the requesting
local jurisdiction. This memo outlines the proposed approach for conducting these appeals for
consideration and action by the Executive Board.
RHNA Revision Requests
Fifteen local governments submitted revision requests during this period (attached). The jurisdictions that
submitted revision requests are:
City of Cupertino
City of Hayward
City of Lafayette
City of Mill Valley
City of Mountain View
City of Newark
City of Novato
City of Oakley
City of Orinda
City of Palo Alto
Town of Ross
City of San Ramon
County of Santa Clara
City of Saratoga
City of Sunnyvale
Most of the requests focused on comments about the housing and employment forecasts from the SCS,
and the use and impacts of the factors that make up the RHNA methodology. ABAG Staff is in the
process of reviewing these requests, including reaching out to each jurisdiction to gather additional
information.
Proposed RHNA Appeals Process
By law, a local jurisdiction that has requested a revision has the opportunity to submit an appeal if ABAG
does not accept the proposed revision or modify the revised share to the satisfaction of the requesting
local jurisdiction.
Appeals Committee
Staff recommends that the ABAG Board form an appeals committee to hear RHNA appeals. According to
state law, a local government may appeal only if ABAG denies the revision request or does not respond to
the satisfaction of the local government. The committee will deliberate about the appeals at a public
Item 9
2014 – 2022 RHNA Revision Requests and Start of Appeals Period
Page 2
hearing at which local jurisdiction staff will be asked to present their appeal request to the committee. The
committee would then make a recommendation to the ABAG Executive Board.
Staff recommends that a five-member appeals committee be formed from self-nominated members of the
ABAG Executive Board or elected officials that were members of the Housing Methodology Committee
(HMC) that helped to develop the RHNA methodology. It is further recommended that of those selected
for the committee, at least a portion be individuals who also served on the HMC. ABAG President Mark
Luce will select the members of the committee, as well as an alternate that can participate on the
committee in the event that a member must recuse himself or herself.
The specific timeline for completing the appeals process and developing the final RHNA is outlined in the
RHNA statutes. ABAG staff is currently revising the RHNA schedule to align with the proposed changes
to the schedule for adoption of the SCS and RTP. A revised schedule will be provided to Executive Board
members by the Nov. 15 meeting.
Summary Recommendation
Staff respectfully recommends that the Executive Board:
1) Form a RHNA Appeals Committee. Committee members could be drawn from the ABAG
Executive Board or the elected officials who were members of the Housing Methodology
Committee via a self-nominated process. It is further recommended that of those selected, at least
a portion be individuals who also served on the Housing Methodology Committee.
Item 9
Item 9
CUPERTINO
September 5,2012
Ms. Miriam Chion
OFFICE OF THE CITY MANAGER
CITY HALL
10300 TORRE AVENUE· CUPERTINO, CA 95014-3255
(408) 777-3212· FAX (408) 777-3366·
Director of Planning and Research
Association of Bay Area Governments
PO Box 2050
Oakland, CA 94607-4756
RE: Adoption of Draft Regional Housing Needs Allocation (RHNA) for the Fifth Cycle:
2014-2022
Dear Ms. Chi on:
Thank you for the opportunity to comment on the draft RHNA numbers. One of the
primary components of Senate Bill 375 is to link transportation and land-use planning
through the Sustainable Communities Strategy (SCS) so as to reduce the region's carbon
dioxide emissions from cars and light duty trucks. The primary strategy of the SCS should
be to build better access to mass transit and housing proximity to jobs and services, so
people have more transportation choices and reduce vehicle miles they need to travel. The
City of Cupertino is a predominantly built-out community with less public transit access as
compared to the larger cities within Santa Clara County. There are no significant planned
bus/rail extensions within our jurisdiction. Any modest increase in household growth,
over what is already accounted for in our general plan, would increase carbon dioxide
emissions through additional vehicle miles traveled, given the lack of transportation
choices and proximity to jobs in our communities.
Also, it appears that cities determined to be more "affluent" are being targeted for more
very-low income units under the methodology. While on the surface the theory may make
sense, in actuality larger less affluent cities actually receive more federal resources based
upon their low income populations to provide housing for these populations. For example,
the largest city in Santa Clara County receives nearly $12,000,000 in federal resources to
house the homeless and the low and very low income, what ABAG has defined as the
smaller "affluent" ~ities receive only $310,000 or much less to provide housing for the
lower income populations. Whereas in the past, cities like Cupertino have been able to rely
on Redevelopment Agency housing set-aside funds and inclusionary housing programs to
provide affordable low and very-low income units, with recent court rulings (Palmer/Sixth
Item 9
Street Properties LP v. City of Los Angeles) and the dissolution of RDAs in California, these
resources have vanished.
Furthermore, the RHNA methodology proceeds to penalize smaller built out communities
for "poor performance". Until monetary resources are made available to smaller
communities to provide the affordable housing, we request that the penalty be removed or
reduced.
Sincerely,
{la(kJ
Interim City Manager
CC: Cupertino City Council
Aarti Shrivastava, Director of Community Development
Timm Borden, Director of Public Works
Vera Gil, Senior Planner
CITY OF
HAYWARD
HEART OF THE BAY
September 17,2012
Ezra Rapport
Executive Director
Association ofBay Area Governments
P.O.Box 2050
Oakland,CA 94604-2050
Re:Request for Revision for Hayward's Regional Housing Need Allocation (RHNA)
Dear Mr.Rapport:
The City ofHayward requests that its RHNA be reduced.Incorrect housing production
data was used in the formula to determine the current draft RHNA.During the years
1999 -2006,Hayward was more successful in building affordable housing than was
documented in the ABAG publication titled "A Place to Call Home".
The following table shows housing production data according to ABAG records and data
per City of Hayward records.The City data is consistent with the annual reports that
have been submitted to the California Department ofHousing and Community
Development (copy attached).
1999 -2006
RHNA According to ABAG Per City Records
Income Level Allocation by Permits Percent of Permits Percent of
Income Level Issued Allocation Issued Allocation
Permitted Permitted
Very low 625 40 6%117 18.7%
Low 344 17 5%24 7.0%
Moderate 834 818 98%833 99.9%
Above 1,032 1,727 167%1,876 181.8%Moderate
Total RHNA 2,835 2,602 92%2,850 100.5%
It is our understanding that as the higher numbers for affordable housing produced are
used in the formula,it will result in a lower RHNA for the City of Hayward.
DEVELOPMENT SERVICES DEPARTMENT._--_.._-_.-..~_-------___.
777 B STREET,HAYWARD,CA 94541-5007
TEL:5101583-4234 •FAX:510/583-3649 •TOO:510/247-3340 •WEBSITE:www.hayw;;:rd-ca.govItem 9
C I TY OF
H AYWARD
September 17,2012
Ezra Rapport
Executive Director
H E A RT O F T H E BAY
Association of Bay Area Governments
P.O. Box 2050
Oakland, CA 94604-2050
Re: Request for Revision for Hayward's Regional Housing Need Allocation (RHNA)
Dear Mr. Rapport:
The City of Hayward requests that its RHNA be reduced. Incorrect housing production
data was used in the formula to determine the current draft RHNA. During the years
1999 -2006, Hayward was more successful in building affordable housing than was
documented in the ABAG publication titled "A Place to Call Home".
The following table shows housing production data according to ABAG records and data
per City of Hayward records. The City data is consistent with the annual reports that
have been submitted to the California Department of Housing and Community
Development (copy attached).
1999 -2006
RHNA According to ABAG Per City Records
Income Level Allocation by Permits Percent of Permits Percent of
Income Level Issued Allocation Issued Allocation
Permitted Permitted
Very low 625 40 6% 117 18.7%
Low 344 17 5% 24 7.0%
Moderate 834 818 98% 833 99.9%
Above 1,032 1,727 167% 1,876 181.8% Moderate
Total RHNA 2,835 2,602 92% 2,850 100.5%
It is our understanding that as the higher numbers for affordable housing produced are
used in the formula, it will result in a lower RHNA for the City of Hayward.
DEVELOPMENT SERVICES DEPARTMENT ._--_ .. _-_.-..... , .~-------.. ~ ..... __ .
777 B STREET, HAYWARD, CA 94541-5007
TEL: 5101583-4234 • FAX: 5101583-3649 • TOO: 510/247-3340 • WEBSITE: www.haywz.rd-ca.gov
In addition to the RHNA,the City ofHayward is generally concerned about the mandates
coming from state and regional agencies along with the reduction in resources available
to local jurisdictions.As noted in Hayward's previous comment letters on the
development ofthe Sustainable Communities Strategy (SCS),the State's elimination of
redevelopment agencies will make it difficult,ifnot impossible,to accommodate growth
envisioned in the SCS and the RHNA.This fiscal constraint created by the elimination of
redevelopment agencies must be addressed in the SCS.When the Hayward City Council
members reviewed the draft RHNA on September 11,2012,they were particularly
frustrated with the fact that the State is requiring cities to accommodate affordable
housing,while at the same time taking away one of the most effective tools to build such
housing.
Regarding the proposed One Bay Area Grant (OBAG)program,future cycles of grant
funding should be less dependent on theproduction of housing,and recognize more the
importance ofjobs.Furthermore,it makes no sense to penalize a jurisdiction for not
producing enough housing by taking away the assistance needed to produce affordable
housing.Finally,in addition to resources for transportation infrastructure,programs that
support job creation are needed in order to realize the projected job growth.The SCS
must foster complete communities with a balance of new jobs and new housing.
We look forward to continuing to work with ABAG throughout the process of finalizing
the RHNA.If you have any questions,please contact me at (510)583-4004 or bye-mail
at david.rizk@havward-ca.gov.Thank you.
David Rizk,AICP
Development Services Director
Attachments
cc:Steve Heminger,Executive Director,MTC
Ken Kirkey,Planning Director,ABAG
Doug Kimsey,Planning Director,MTC
HingWong,ABAG
Beth Walukas,Deputy Director ofPlanning,Alameda Co.Transportation Commission
Fran David,City Manager
Kelly Morariu,Assistant City Manager
Morad Fakhrai,Director ofPublic Works -Engineering and Transportation
Don Frascinella,Transportation Manager
Richard Patenaude,Planning Manager
Erik Pearson,Senior Planner
Item 9
In addition to the RHNA, the City of Hayward is generally concerned about the mandates
coming from state and regional agencies along with the reduction in resources available
to local jurisdictions. As noted in Hayward's previous comment letters on the
development of the Sustainable Communities Strategy (SCS), the State's elimination of
redevelopment agencies will make it difficult, if not impossible, to accommodate growth
envisioned in the SCS and the RHNA. This fiscal constraint created by the elimination of
redevelopment agencies must be addressed in the SCS. When the Hayward City Council
members reviewed the draft RHNA on September 11, 2012, they were particularly
frustrated with the fact that the State is requiring cities to accommodate affordable
housing, while at the same time taking away one of the most effective tools to build such
housing.
Regarding the proposed One Bay Area Grant (OBAG) program, future cycles of grant
funding should be less dependent on the production of housing, and recognize more the
importance of jobs. Furthermore, it makes no sense to penalize a jurisdiction for not
producing enough housing by taking away the assistance needed to produce affordable
housing. Finally, in addition to resources for transportation infrastructure, programs that
support job creation are needed in order to realize the projected job growth. The SCS
must foster complete communities with a balance of new jobs and new housing.
We look forward to continuing to work with ABAG throughout the process of finalizing
the RHNA. If you have any questions, please contact me at (510) 583-4004 or bye-mail
at david.rizk@havward·ca.gov. Thank you.
David Rizk, AICP
Development Services Director
Attachments
cc: Steve Heminger, Executive Director, MTC
Ken Kirkey, Planning Director, ABAG
Doug Kimsey, Planning Director, MTC
HingWong, ABAG
Beth Walukas, Deputy Director of Planning, Alameda Co. Transportation Commission
Fran David, City Manager
Kelly Morariu, Assistant City Manager
Morad Fakhrai, Director of Public Works -Engineering and Transportation
Don Frascinella, Transportation Manager
Richard Patenaude, Planning Manager
Erik Pearson, Senior Planner
Item 9
LAFAYETTE
September 7, 2012
Supervisor Mark Luce, President
Association of Bay Area Governments
P.O. Box 2050
Oakland, CA 94607-4756
City Council
Carol Federighi, Mayor
Mike Anderson, Vice Mayor
Brandt Andersson, Council Member
Carl Anduri, Council Member
Don Tatzin, Council Member
Subject: Appeal of Lafayette's adjusted Regional Housing Needs Allocation (RHNA),
adopted July 19, 2012
Dear Supervisor Luce:
Thank you for the opportunity to submit the City of Lafayette's appeal of the RHNA, as adjusted by the
Growth Concentration Scenario and adopted by the ABAG Executive Board on July 19, 2012.
To be clear, we supported the RHNA methodology adopted earlier and the allocations that resulted
from the methodology, as presented in Mayas the draft allocations. Our objection is to the adjustment
of those numbers through the Growth Concentration Scenario. These adjustments were made to
compensate for some 3,000 units removed from three cities larger cities in the South and East Bay. The
3,000 units represent about 1.6% of the total regional allocation.
The reason for our objection and appeal is simple. The calculation of the adjusted numbers for Contra
Costa County is clearly wrong. We have focused on Contra Costa County; we do not know whether the
same errors affected the calculation of allocations for other counties.
A chronology of our investigation of these numbers is instructive:
1. Prior to the July 19 meeting, we discovered dramatic discrepancies in the adjustments for different
cities in Contra Costa County. Specifically the following adjustments were made to allocations for
the cities of Contra Costa:
Decrease:
0% Increase:
1-3% Increase:
8-15% Increase:
Hercules
Brentwood, Danville, Martinez, Oakley, Orinda, Pleasant Hill, San Pablo
Antioch, Clayton, Concord, EI Cerrito, Pinole, Pittsburg, Richmond, Walnut Creek
Lafayette (15%), Moraga (8%), San Ramon (10%)
3675 Mount Diablo Boulevard, Suite 210, Lafayette, CA 94549
Phone: 925.284.1968 Fax: 925.284.3169
www.ci.lafayette.ca.us
Item 9
lafayette Appeal of RHNA
September 7, 2012
Page 2 of 3
I pointed out these discrepancies to ABAG in my letter dated July 19 regarding the proposed
adjustments and lack of public review of the adjusted allocations.
2. Councilmember Brandt Andersson, an alternate ABAG Board member sitting as a voting member for
the July 19 meeting, spoke with ABAG staff member Hing Wong prior to the meeting, and was told
that there had been no change to the methodology and any significant changes were the result of
changed inputs. He was not able to explain why the input numbers should be so dramatically
different for different cities.
During the meeting, ABAG staff member Miriam Chion presented the distribution of the
adjustments as being IIproportional." When pressed on how a proportional distribution could result
in such disparate adjustments, she was unable to provide an explanation. ABAG Executive Director
Ezra Rapport also spoke with Councilmember Andersson, confirming that the methodology was
unchanged and the differences were due to changes in the input. He, too, was unable to explain
what those changes might be.
3. Lafayette requested that ABAG show the methodology applied to four similar cities, two of which
had minimal adjustments (Orinda and Danville) and two that had excessive adjustments (Lafayette
and Moraga). On July 31, ABAG staff members Hing Wong and Sailaja Kurella met in Lafayette with
Councilmember Don Tatzin, ABAG Vice-Chair Julie Pierce, and City staff members Ann Merideth and
Niroop Srivatsa. After a review of the methodology factors, City representatives agreed that the
factors were reasonable. Numerous adjustments that were made as part of the methodology were
reviewed; such adjustments were quite minor, moving one or two units, up or down, resulting in
insignificant net movement. However, there was no good explanation of why taking away the 3,000
units in combination with the vacancy calculations resulted in the discrepancies between cities.
ABAG staff responded that they would review the data for errors.
4. Still without any explanation for the discrepancies in the allocation adjustments, another meeting
was held at ABAG's offices in Oakland on August 22 so that real-time data retrieval and analysis
could be done if necessary. ABAG staff members Miriam Chion, Jason Munkres, and Sailaja Kurella
met with Councilmembers Tatzin and Andersson, Vice-Chair Pierce, and City staff members. ABAG
staff announced that a glitch had been found in the Orinda calculations that changed its allocation
from 0% to 9%. However, this just meant that four cities in Contra Costa are wildly out of synch
instead of three. It did not explain why any of the cities were allocated several times their expected
adjustment.
The discussion then focused on why the input numbers were changed so dramatically for some
cities, specifically the effect of the vacancy rate on those numbers. We pointed out that the 2014-
2022 projected vacancy rates for the three cities with inexplicable adjustments (Lafayette, Moraga,
and San Ramon) were a small fraction of their vacancy rates for 2010 or 2040, a situation that
applied to no other cities except, oddly, Danville. ABAG Staff was unable to provide any explanation
for this dramatic anomaly. Nor was ABAG staff able to explain why the vacancy rates used in the
calculations were so dramatically different from Census vacancy numbers or those of other data
sources.
5. ABAG staff agreed at the meeting to respond to several questions, one of which was to investigate
the obvious anomalies in the vacancy rates and determine what caused them and whether they
might be the cause of the excessive adjustments. On August 29, Lafayette received answers to these
questions from ABAG staff. No question regarding the issue of the validity of the vacancy rates used
Item 9
Lafayette Appeal of RHNA
September 7,2012
Page 3 of 3
or the effect of those vacancy rates on the adjustments was included in the ABAG response. The
only comment related to vacancy rate impacts was profoundly unhelpful:
It is important to note that the amount to be rebalanced for each 5-year period differs from year to
year and that the number of households to be rebalanced will not equal the number of housing units
to be rebalanced~ resulting in vacancy rates that fluctuate slightly from the hypothesized
unidirectional convergence on the target vacancy rate.
Two disturbing conclusions can be drawn from our attempt to get an explanation for what is obviously
an incorrect application of the RHNA methodology approved by the ABAG Board:
• Despite the insistence of ABAG staff that the adjustments were "proportionate/' they are extremely
disproportionate, by up to a factor of 10 or more. They are in error.
• Despite six weeks of concerted effort by both ABAG and Lafayette, there is no explanation for the
erroneous calculations. ABAG staff has repeatedly been unable to explain how they arrived at input
numbers that appear to be causing the errors.
The only reasonable conclusion at this time is that the Contra Costa County adjustments adopted by the
ABAG Board on July 19 are severely inaccurate, and ABAG staff is unable to provide any plausible
explanation for the error. The inability of ABAG staff to explain the source or development of their
clearly erroneous numbers is deeply disturbing.
Therefore, the City appeals Lafayette's adjustment adopted on July 19, 2012, and insists that ABAG
suspend implementation of those inaccurate adjustments unless and until the miscalculations or wrong
data that led to the erroneous adjustments for Lafayette are identified and corrected.
While we are only appealing Lafayette's adjustment, the underlying problem appears to affect several
other cities, and, because of the necessary "rebalancing", all other cities. Not only are these other cities
suffering the same vacancy rate disconnect, but they have increased allocations as a result. Therefore,
we further request that, when the source of the errors is identified, all other ABAG counties be reviewed
to determine whether similar errors have occurred in other counties. A cursory review shows that a few
cities in Alameda, Santa Clara, and San Mateo counties show dramatic, inexplicable fluctuations in the
projected vacancy rates similar to the affected Contra Costa cities.
We hope that ABAG is as eager as we are to correct the application of the RHNA allocation methodology
Sincerely,
Carol Federighi
Mayor
Cc: Lafayette City Council
Councilmember Julie Pierce, ABAG Vice President
Ezra Rapport, ABAG Executive Director
Miriam Chion, ABAG Assistant Planning Director
Sailaja Kurella, ABAG Regional Planner
Item 9
Garry Lion
Mtlynr
Andrew Berman
Vice M'l~or
Shawn Marshall
Coun ,hrwmlwr
Via E-Mail and U.S. Mail
October 1,2012
Executive Board
Association of Bay Area Governments
P.O. Box 2050
Oakland, CA 94604-2050
RE: Request for Revision of Regional Housing Need Allocation
Dear Board Members:
Stephanie Moulton·Peters
('OlillclhnL'nll,cr
Kenneth R. Wachtel
COltl"ldlml'111lhJr
James C. McCann
'lIy r-'.I11"~('"
It has come to staffs attention that the letter and corresponding analysis sent to the Board from
the City of Mill Valley on September 11, 2012, inadvertently contained a few typographical
errors. The errors have been corrected and highlighted in bold font in the attached revised letter
and analysis with individual footnotes explaining the corrections.
Please accept this letter and the revised attachments as a substitute for the City's original
submission dated September 11, 2012. Feel free to contact me should you have any further
questions or concerns.
Sincerely,
~~c·~c~ __ _
es C. McCann
ty Manager
enclosure
cc: City Council
Planning and Building Director Moore
ill [E rn [E 0 W [] (]J
OCT 042012
EXECUTIVE DIRECTOR'S OFFICE
City of Mill Valley, 26 Corte Madera Avenue. Mill Valley. California 94941 • 415-388-4033
Item 9
Garry lion
Mayor
Andrew Berman
Vice Mdyor
Shawn Marshall
Cotlnt:ilmemoer
Via E-Mail and U.S. Mail
Revised date: October 1, 2012
(Original letter dated September 11,2012)
Executive Board
Association of Bay Area Governments
P.O. Box 2050
Oakland, CA, 94604-2050
RE: Request for Revision of Regional Housing Need Allocation
Dear Board Members:
Stephanie Moullon-Peters
CllllllLdmelnht'r
Kenneth R. Wachtel
CUlIIlLilml!IJ11)pr
James C. McCdnn
On behalf of the City Council and citizens of Mill Valley, we wish to fonnally object to
the draft Regional Housing Needs Allocation (RHNA) assigned to the City of Mill Valley
for the period 2014 to 2022 and request that this RHNA allocation be reduced and that
the allocations by income category be modified. We base this request on the following
substantive issues:
1. Our Mill Valley-specific analysis (draft attached) of demographic and housing
trends with the assistance of Robert Eyler, CEO of the Marin Economic Forum,
demonstrates:
a. Mill Valley's population is growing at a rate exceeding ABAG's SCS and
RHNA projections, and the foundation is in place to continue that growth
for the foreseeable future, so Mill Valley will be accommodating our fair
share of the Bay Area's future growth.
b. That population growth is being caused by on-going turnover in our
existing housing from long-tenn, post-family residents to an influx of new,
growing families, so Mill Valley's growth is coming via larger
households.
c. As a result of better utilizing our existing housing stock to accommodate
growth and because of an existing large surplus of housing units, Mill
Valley does Inot need any new housing units. .
d. ABAG and the State measure population growth via household growth
(assuming constant population per household) and focus on housing unit
I "not" was inadvertently left out of the original letter.
City of Mill Valley. 26 Corte Madera Avenue, Mill Valley, California 94941 • 415-388-4033
Item 9
City of Mill Valley -
REVISED Requestfor Revision of Regional HOllsing Need Allocation
production, so Mill Valley will be unfairly judged usmg the current
measuring sticks.
2. Identified constraints due to Mill Valley's geographic location, topography and
natural environment (e.g., severe fire hazard zones, floodwaylfloodplain, sea level
rise, severe slopes with geologic instability, sensitive and protected plant and
animal areas) results in substantially limiting sites for new housing and must be
taken into account in determining a reasonable and rational RHNA for Mill
Valley.
3. While we understand the "fair share" principles inherent in state Housing Element
law and the RHNA allocation process, some of the "fair share" methodologies
unfairly penalize communities like Mill Valley where land costs, naturally
occurring and immitigable development constraints and, more recently, the
unavailability of the suitable financing for more affordable housing, has created a
combination of circumstances over which we have no control and which affect
our ability to actually produce affordable housing units. Yet, the "Past RHNA
Perfonnance" factor increases the number of units in these income categories
without addressing the realities of existing deVelopment constraints.
4. We have expressed our concern in previous correspondence to ABAG that
employment projections for Mill Valley are excessive and do not reflect historic
employment trends or the limited nature of employment opportunities in our
community. It also does not take into account home based businesses and self
employment which accounts for a larger share of Mill Valley's residents
employment than the rest of the Bay Area. As "Employment" is a scoring factor
in the adopted RHNA methodology, we believe that this factor is overstated and
results in inappropriately and unfairly increasing Mill Valley's RHNA.
5. The "Income Allocation" factor is a further attempt to engineer a more equitable
distribution of incomes across the region, but as with the "Past RHNA
Perfonnance" factor, it only exacerbates a problem created by existing naturally
occurring development constraints that make actual affordable housing production
problematic.
We request in the strongest possible tenns that the Executive Board carefully consider
our comments and apply this infonnation to reduce the overall City of Mill Valley RHNA
for the 2014-2022 Housing Element cycle, as well as modify the allocations by income
category, accordingly. We will happily meet with you or your staff in your offices or
perhaps more helpfully here in Mill Valley to discuss our concerns and to share with you
our beautiful community and identify the many constraints, which must be taken into
consideration in realistically planning for growth and change in our community over the
next several years. Thank you.
2
Item 9
City 0/ Mill Valley -
REVISED Request/or Revision of Regional Housing Need Allocation
Sincerely,
+<~{17v
Garry E. Lion
Mayor
enclosure
cc: City Council
Planning and Building Director Moore
15e:---. C.-"1<-t~~_
James C. McCann
City Manager
3
COMMUNITY DEVELOPMENT DEPARTMENT • PLANNING DIVISION
500 Castro Street • Post Office Box 7540 • Mountain View • California • 94039-7540
650-903-6306 • Fax 650-962-8501
VIA E-MAIL AND U.S. MAIL
September 18, 2012
Ezra Rappaport
Association of Bay Area Governments
P.O. Box 2050
Oakland, CA 94604-2050
Re: REQUEST FOR REGIONAL HOUSING NEEDS ALLOCATION REVISION
Dear Mr. Rappaport:
The City of Mountain View formally requests a revision to our Regional Housing Needs
Allocation (RHNA) for the 2014-2022 period.
The City of Mountain View adopted its new General Plan on July 10, 2012. The City originally
anticipated new residential uses in North Bayshore from early public input and City Council
direction. However, based on additional public hearings and community discussions, our
adopted General Plan eliminated any new residential uses in our North Bayshore area.
It is our understanding that the City’s RHNA numbers include new residential uses in North
Bayshore. Since our General Plan prohibits residential uses in North Bayshore, the City’s
RHNA numbers must be revised to be consistent with what is allowed by our General Plan.
Thank you for the opportunity to request a revision to our RHNA numbers. If you have any
questions, please do not hesitate to contact me at (650) 903-6456 or by email at
randy.tsuda@mountainview.gov.
Sincerely,
Randy Tsuda
Community Development Director
CC: File, CM, PP
Via email to: Ezra Rappaport; Hing Wong; Gillian Adams; Miriam Chion
Item 9
Item 9
~ CITY OF NEWARK, CALIFORNIA tlt1 ~-----
37101 Newark Boulevard· Newark. California 94560-3796 • (510) 578-4000 • FAX (510) 578-4306
August 20, 2012
Ms. Miriam Chion
Acting Director of Planning and Research
Association of Bay Area Governments
101 Eighth St.
Oakland CA 94607
RE: Fonnal Appeal of Regional Housing Needs Allocation for the City of Newark
Dear Ms. Chion:
I am writing to fonnally appeal the Regional Housing Needs Allocation (RHNA) for the City of
Newark. The allocation for Newark is inappropriate and out of step with State law and common
sense.
The allocation does not reflect infrastructure decisions as required by State law. Newark's
RHNA allocation in the 2014-2022 cycle was increased by 24% over the 2007-2014 cycle at the
same time that fixed transit funding serving Newark was eliminated. The removal of the
Dumbarton Rail Service from the R TP investment strategy must be reflected in the RHNA
allocation. To increase the housing allocation at the same time that transit funding is eliminated
is in violation ofSB 375. Your unadjusted reliance on the flawed SCS allocation process in your
RHNA methodology is the cause of this issue. We pointed this out in our letter of June 25,2012.
ABAG chose to ignore our suggested modification to the methodology to address this issue.
Therefore, you have perpetuated the flaws of the SCS process and have put forth an allocation
that is a clear violation ofSB 375 in that you are creating an allocation that ignores infrastructure
realities. Given the removal of the Dumbarton Rail service from the Transportation Investment
Strategy, Newark's RHNA allocation should have decreased substantially and certainly not
increased.
It also should be noted that in the time since the last RHNA allocation, scheduled bus service
levels in Newark have also been substantially reduced. To add housing to an area at the same
time as transit service is being reduced will lead to more automobile trips, more greenhouse gas
production and more air pollution. This is exactly what SB 375 was intended to prevent.
We would have preferred to see transit service improve and have been making strides to add
density around proposed transit in concert with proposed transit infrastructure. Regional
@ recycled paper web site: www.newark.org email: webmaster@newark.org
Item 9
Miriam Chin
August 20,2012
Page 2
agencies have directly undennined our efforts toward more sustainable land use with their
infrastructure decisions. Now, to add insult to injury, the RHNA allocation shows a substantial
increase in housing that must be accommodated in Newark, instead of the decreased allocation
that should correspond to the disinvestment.
To comply with state law you must assign the housing growth to the jurisdictions that are slated
for transit investment, not to areas that have experienced disinvestment. Newark's RHNA
allocation should at least be reduced to match the level of the 2007-2014 cycle: 863 units. That
would be a reduction of 210 units from your proposed allocation of 1073 units for 2014 -2022.
We would be happy to meet with you to discuss potential solutions to this problem. Thank you
for your attention to this issue. If you wish to discuss this further please contact Terrence
Grindall of my staff at terrence.grindall@newark.org or 510-578-4208.
Sincerely,
J~C~
City Manager
cc: Newark City Council
Ken Kirkey, Metropolitan Transportation Commission
Art Dau, Alameda County Transportation Commission
Item 9
~-~ (~ t:ri.-J -~ --..
THE CITY OF
NOVATO
CALIFORNIA
75 Rowland Way #200
Novato, CA 94945-3232
415/899-8900
FAX 415/899-8213
www.novato.urg
i\Iayor
Denise. \thas
~Iayor Pro Tern
Pat Eklund
Councilrnernbers
Madeline Kellner
Eric Lucan
Jeanne MacLearny
City t>.Ianager
i\[jchael s. Frank
September 7,2012
Mr. Ezra Rapport, Executive Director
Association of Bay Area Governments
P. O. Box 2050
Oakland, CA 94607-4756
Dear Mr. Rapport:
The City of Novato has reviewed the RHNA distribution for the 2014
through 2022 cycle. Unfortunately, we have not been able to verify the
detailed data that went into the fonnula, but will do so as time allows. We
want to be sure that the data that drives the RHNA distribution is accurate.
So, we are reserving our opportunity to comment on that aspect of the
fonnula until we have had the opportunity to review the detailed data.
We do, though, want to emphasize that:
1. The job growth projections for the City of Novato (which drive the
housing allocation) for the 2014 through 2022 are far too high. As we have
stated in previous letters (see attached), the recession has not rebounded and
we have very limited land available for growth. We are in the process of
updating our General Plan and several undeveloped properties are
inaccurately zoned given our hillside ordinance and other constraints which
will limit what can be built.
2. The transit portion of the RHNA methodology appears to be based
on inaccurate infonnation about the availability of public transit.
Thank you for the opportunity to comment.
Sincerely,
Denise Athas, Mayor
Attachments: Letters sent to ABAG for this cycle:
• Letter dated January 30, 2012
• Letter dated March 14, 2012
• Letter dated April 20,2012
• Letter dated June 29,2012
f11rErnCEDwce[JJ
SEP 132012
EXECUTIVE DIRECTOR'S OFF!C ~
Item 9
3231 Main Street
Oakley, CA 94561
925 625 7000 tel
925 625 9859 fax
wmv.ei.oakley.ca.us September 7, 2012
MAYOR
Kevin Romick
VICE MAYOR
Carol Rios
COUNCILMEMBERS
Pat Anderson
Randy Pope
Jim Frazier
Ezra Rapport, Executive Director
ABAG
Joseph P. Bort Metro Center
101 Eight Street
Oakland, CA 94607-4770
Steve Heminger, Executive Director
MTC
Joseph P. Bort Metro Center
101 Eighth Street
Oakland, CA 94607-4770
SUBJECT: Comments and Request for Revisions to the Adopted Regional
Housing Needs Allocation (RHNA) and Subregional Share for the City of
Oakley
Dear Mr. Heminger and Mr. Rapport:
The City of Oakley is requesting revisions to the Regional Housing Needs
Allocation (RHNA) that was recently adopted by the Association of Bay Area
Governments (ABAG) on July 19, 2012. This letter reiterates the comments
addressed to ABAG on June 27, 2012. It appears that during the adoption of
the RHNA allocation, the original comments that the City Council provided to
ABAG were not considered or addressed. Oakley is very concerned with the
high number of low-and very-low income units allocated to the City. The
methodology did not take into account several factors that included the intent
of the Oakley Priority Development Areas (PDAs), the lack of rail transit
within Oakley, the number of existing jobs within Oakley, the current RHNA
performance relating to the construction of low-and very-low income units,
and lastly, the State's recent elimination of Redevelopment Agencies.
As already stated to ABAG, Oakley has several unique conditions which
should necessitate a reduction in the overall number of low and very-low
income units that have been allocated to Oakley. As stated in previous letters,
a majority of the entitled units in Oakley are not located within PDAs. With
this said, Oakley's housing projections become misleading, specifically within
Oakley's three PDAs. In short, many of the units that have been approved
and are not located within PDAs seem to be assumed within the PDA areas.
Although Oakley still feels it is important to reduce target emissions through a
Item 9
September 7, 2012
Comments and Request for Revisions to the Adopted Regional Housing Needs Allocation (RHNA) and
Subregional Share for the City of Oakley
Page 2 of 4
comprehensive regional strategy, there are several unique conditions to
Oakley that need to be reconsidered when looking at the adopted RHNA.
The Oakley City Council has previously expressed its comments, which were
not addressed prior to the adoption of the RHNA, as follows:
• The objective of the Sustainability Component is to concentrate new
development in areas to protect the region's natural resources and
reduce development pressures on rural outlying areas. While the City
agrees with this objective, it is not applicable to Oakley because
Oakley's General Plan already accommodates areas suitable for
residential development to accommodate the total household
projections in the Jobs-Housing Connection Scenario and Sh·ategy. The
original intent of the Oakley PDAs was to designate areas in which
employment centers would be created. The need to accommodate
more residential development in PDAs undermines this goal.
• A majority of 798 acres that make up the Oakley "Employment Area"
PDA is not suitable for residential development. A large portion of the
PDA encompasses 378 acres of land owned by DuPont, in which
approximately 170 acres are occupied by wetlands. Other portions of
the DuPont property are located within a floodplain, are being
remediated and are not currently ready for any type of development,
and other portions are designated for Light Industrial land uses.
Another portion of that PDA is occupied by 78 acres of land and
governed by the River Oaks Crossing Specific Plan. A long-standing
deed restriction and the Specific Plan do not allow for residential land
uses. The remaining areas in the PDA are either designated for Light
Industrial or Business Park land uses which also do not permit
residential development. The requirement to provide 70% of the
RHNA allocation within the "Employment Area" PDA creates a
situation where the City would have to amend the Oakley 2020 General
Plan and Rezone hundreds of acres of land to allow for residential land
uses. As stated within the first bullet, the intent of the PDA was to
create jobs that have been envisioned within the General Plan since
2002 to help support the City's existing, entitled and designated
housing.
Item 9
September 7, 2012
Comments and Request for Revisions to !be Adopted Regional Housing Needs Allocation (RHNA) and
Subregional Share for the City of Oakley
Page 3 of4
• The draft RHNA allocated the maximum number of units to Oakley,
meaning we have been allocated 1.5 times the current RHNA cycle
allocation. This seems to go against the Fair Share Component's
objective. Based on the Fair Share Component's objective, several
factors should have been taken into account when determining the
allocation:
• Oakley does not have a strong transit network. While the City
does have ambitions to one day have a strong transit network,
there is currently a lack of existing infrastructure for direct rail
transit. This should have resulted in a lower Fair Share score.
• There is also a strong desire to bring jobs into the City. This is
evident by the City's desire to have three PDAs. However,
Oakley is not currently a job rich city and, therefore, we should
have received a lower Fair Share score.
• Lastly, the methodology does take into account the most recent
RHNA performance, rather the 1999-2006 RHNA cycle was used
in the Fair Share scoring. The City of Oakley incorporated in
1999, and did not adopt a General Plan until 2002. Subsequently,
a Housing Element was adopted in 2005 for the 1999-2006 cycle,
and another Housing Element in 2009 for the current 2007-2014
cycle. The City has been committed to not only making land
available to accommodate the RHNA allocation, Oakley has
already built almost all of the current cycle's allocation,
including exceeding the number of low-and very-low income
units required. This past performance should be taken into
account and should result in Oakley receiving a lower overall
score.
• Oakley is not currently served by direct rail transit. The need for an
increased job growth is a priority for Oakley. As previously stated, the
PDA areas are intended for jobs, which would ensure the residents of
Oakley would not need to commute to inner Bay Area job locations,
thereby reducing unit and GHG emissions. The RHNA allocation does
not take into account that Oakley is predominantly made up of single
family residences, and is an area where that lifestyle is preferred over
higher-density development. Almost as important is the fact that
Oakley has successfully produced low-and very-low income units to
Item 9
September 7, 2012
Comments and Request for Revisions to the Adopted Regional Housing Needs Allocation (RHNA) and
Subregional Share for the City of Oakley
Page 40f 4
satisfy the current RHNA cycle. This shows Oakley's serious
commitment to provide housing for all income levels. As stated by
other East Contra Costa County cities, job growth should be a priority
for East Contra Costa County and a means to reduce greenhouse gas
emissions as well as meeting the housing preferences for the region.
• The recent elimination of Redevelopment Agencies further financially
burdens local agencies that are already facing fiscal concerns due to the
current economy. Oakley is very apprehensive with the RHNA
allocation as it suggests multiple acres of land will need to be rezoned
to accommodate a large number of higher density units that might
never be built and would occupy land needed to create jobs.
The City of Oakley City Council hopes these comments will be considered and
that the adopted RHNA for Oakley will be reduced accordingly.
~:4g~OY\"JVI-.w
Bryan H. Montgomery
City Manager
C: Oakley City Council
Senator Mark DeSaulnier -7th District
Assembly Member Joan Buchanan -15th District
City of Clayton Councilmember Julie Peirce
City of San Ramon Councilmember Dave Hudson
Item 9
22 orinda way -orinda-california -94563
September 12,2012
-~---Mr;-Mark-I:tlce-;-President~~--~-----~~--~-~---~--~~-~-~------------
Association of Bay Area Governments
P.O. Box 2050
Oakland, CA 94607-4756
Subject: Comments on Draft Regional Housing Need Allocation
Dear Mr. Luce,
Thank you for the opportunity to review and comment on the Draft Regional
Housing Need Allocation (RHNA). Through the process of considering comments
on the alternative Sustainable Communiti~s Strategies (SCS), ABA.G and MTC
selected a preferred alternative that is consistent with the overall vision for growth
embodied in the Orinda General Plan. We thank you for your judicious application
of SB 375 and for addressing our concerns through theBeS process. It is our hope
. that ABAG will continue its practice of carefully considering local jurisdictions'
comments as it considers theRHNA and in.so doing, enable each community to
forge its own unique vision for the future, consistent with the objectives of state law.
We respectfully submit our comments and request that the ·Final RHNA reflects our
input.
While the total number of units in the Draft RHNA for Orinda is reasonable,
the proposed distribution of the level of affordability places an undue burden on the
small Orinda community by including a disproportionately high number of below
market rate units. County~wide, 57% of the Draft allocation is for below market rate
units; however, for Orinda, 81 % of the Draft allocation is for below market rate units.
This is the highest proportional allocation of any jurisdiction in Contra Costa County
and more than 42% higher than the county-wide average. Furthermore, 37% of the
Draft allocation is forvery-Iow income-households compared to the county-wide
average of 26%; State housing law [in Government Code §65584(d)(1)] requires the
allocation plan to increase the housing supply and mix of housing types in an
equitable manner. As drafted, the RHNA does not allocate the regional housing
need equitably in that it places an unrealistic and highly disproportionate burden on
the City of Orinda for the provision of below market rate units. .
The Orinda community understands and embraces the need to properly plan
for the housing needs of all segments of the community and through deliberate and
open planning processes, the Orinda community is fulfilling its housing obligations
while maintaining the qualities that make Orinda unique and desirable ..
General Information
(925) 253-4200 (ph)
(925) 254-9158 (fax)
Administration
(925) 253-4220 (ph)
(925) 254-2068 (fax)
Planning
(925) 253-4210 (ph)
(925) 253-7719 (fax)
Parks & Recreation Police
(925) 254-2445 (ph) (925) 254-6820 (ph)
(925) 253-7716 (fax)· (925) 254-9158 (fax)
Public Works
(925) 253-4231 (ph)
(925) 253-7699 (fax)
Item 9
Outcomes of our community discussions have resulted in a significant
number of housing opportunities affordable to residents of all income levels and at
various stages of life. For instance, the City of Orinda partnered with Eden Housing
in the development of 67 units on the City's former library site. These units will be
available to senior households with extremely-low, very-low, and low incomes.
in-addres~s-th-e-ne-e-ds-of-stadents-;-extended-families-and-small-hotlseholds-, ~,~-~--~~---
the second unit standards were modified to allow second units by right on hundreds
of parcels throughout the community and, to accommodate young families, second
units with multiple bedrooms and up to 1,250 square feet are permitted by right.
Pulte Homes' 73 units on an infill site in downtown Orinda is another example of the
City's efforts to provide housing options. These homes will beon small lots within
walking distance of BART and the services of downtown and the development
includes eight units deed restricted in perpetuity to below market rate levels. As a,
final example, with the encouragement of the City, owners of the 150-unit Orinda
Senior Village development renewed the affordability restrictions on the property and
thereby preserved an important housing option for 150 extremely-low, very-low and
low-income households. These projects were all included in our third cycle housing
element and are in various stages of the development process or already have
come to fruition.
Thank you again for the opportunity to provide our input on the Draft RHNA
and we look forward to reviewing the proposed HHNA before it is adopted. If you
have any questions about our comments, please feel free to contact Director of
Planning, Emmanuel Ursu at (925) 253-4240 or via email at eursu@cityoforinda.org.
12#cy-
Steven Glazer
Mayor, City of Orinda
Copy: Ezra Rapport, Executive Director, ABAG
Steve Heminger, Executive Director, MTC
2
Item 9
City of PalQ Alto C (t-~'--
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
Office of the Mayor and City COllncil
mCE(ECEDWCE[JJ
SEP.172012
EXECUTIVE DIRECTOR'S OFFICE
Re: City of Palo Alto Request for Revision to Adopted RHNA Methodology for the 2014-2022
Housing Cycle
Dear Mr. Luce:
Thank you for ABAG's July 25, 2012 memo to Bay area cities and counties, which provided an
overview ofthe adopted Regional Housing Needs Assessment (RHNA) methodology and
jurisdictional allocations for the 2014-2022 housing cycle. While the adopted allocations
appear to have taken into consideration some ofthe concerns and comments expressed by
member jurisdictions, the target projections are still unrealistic. In Palo Alto, the built-out
nature of the city and multiple school, service and infrastructure constraints and impacts make
these projections unattainable. Therefore, the purpose of this letter is to request a revision to
the draft allocation, to reduce the total number of units assigned to the City of Palo Alto. In
support of this request, the following reiterates the City of Palo Alto's ongoing concerns
regarding the long-term Sustainable Communities Strategy (SCS) projections and the potential
impact on future RHNA cycles. Furthermore, this letter provides information about our ongoing
effort to facilitate a joint agreement for transfer of units to the County of Santa Clara for
housing on Stanford lands.
In summary, the City of Palo Alto's comments are as follows:
1. 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
Printed With !olly-b.1sed inks on 100 recycled polp~r pruceued wlthuut chlonne.
P.O. Box 10250
Palo Alto, CA 94303
650.329.2477
650.328.3631 fax 1
Item 9
Mr. Mark Luce, President
Association of Bay Area Government
September 11, 2012
the Department of Finance to the changing State of California demographics.
Furthermore, current and future projections should be adjusted so they are more
consistent with historical growth patterns and/or a range of projections should be
adopted that reflect meaningful planning scenarios in response to market changes over
time. An analysis ofthe inadequacy ofthe current long-range projections, authored by
Palo Alto Councilmember Greg Schmid, was submitted to ABAG during the Alternative
Scenario selection process and is attached to this letter. Tables outlining the
discrepancies between the most recent DOF projections and those prepared by ABAG
for the SCS are also attached.
2. The proposed RHNA allocation assigns 77 housing units to the County of Santa Clara
(unincorporated), although Stanford University's General Use Permit with the County of
Santa Clara County allows and plans for up to 1,500 residential units to be built on
Stanford lands within the SCS timeframe. The City acknowledges that these units have
not been otherwise assigned to the City of Palo Alto, but at least some of them are
proximate to EI Camino Real and the University Avenue Caltrain station, and would be
consistent with the objectives of the SCS and SB375. Specifically, approximately 350
planned units on two sites on Quarry Road just west of EI Camino Real appear
appropriate to include somewhere in the housing analysis. City staff has met with staff
from the County and Stanford to discuss the possibility of 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.
2
Item 9
Mr. Mark Luce, President
Association of Bay Area Government
September 11, 2012
4. The City of Palo Alto continues to have concerns regarding the potential negative
environmental, school capacity and infrastructure capacity (recreational, utilities,
transit, etc.) impacts the overstated housing mandates may create. The City will, of
course, be conducting an environmental review to fully assess the impacts of these
mandates during the preparation of our Housing Element for this planning period.
Once again, thank you for the opportunity to comment on the adopted RHNA methodology for
the 2014-2022 Housing Cycle. As stated earlier, the City is officially requesting a reduction in
the proposed allocation for the reasons stated above. If you have questions or need additional
information, please contact Curtis Williams, the City's Director or Planning and Community
Environment, at (650) 329-2321 or curtis.williams@cityofpaloalto.org.
Sincerely,
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
3
Item 9
• TgWN
ROSS
September 20, 2012 lBrlm(laWtiill
SfP ~·4 2!J'~
Mr. Mark luce
President
EXECUTI.VE,OIAECTOR'S OFFICE
Association of Bay Area Governments
P.O. Box 2050
Oakland, CA 94604-2050
Dear Mr. luce:
RE: Town of Ross Appeal and Request For Revision on draft Regional Housing
Need Allocation (2014-2022)
This letter is an appeal and request for a revision to the draft Regional Housing Need Allocation
for the 2014-2022 housing cycle for the Town of Ross. The Town of Ross is a small, built-out,
single-family residential community. The 18-unit allocation for Ross overestimates the housing
units that the Town may realistically develop in the housing cycle, even with rezoning and
incentives for new unit development.
Fair Share Component
Employment
The Town appeals the determination regarding existing and proposed employment within the
Town, which is based on regional estimates and not actual data for the Town of Ross. The
regional forecasts overstate growth and ignore the updated demographic forecasts of the
State's Department of Finance (DOF). The Town encourages ABAG to work with the State
Department of Housing and Community Development (HCD) to reduce the 2010-2040
projections to reflect the data generated by the Department of Finance. We request ABAG to
complete peer review of the growth projections for Marin County and recalculate the RHNA in
response to that peer review.
The Town has a very small, built-out, downtown commercial area. The commercial
development is so low that the Town supports government services with an annual parcel tax
on residential sites, a tax that did not receive voter approval in 2012. The primary employers
are the Town (15 employees), public grade school (359 students in 2010-2011), private high
school (limited by code to 321 students) and a residence for the developmentally disabled.
These top four employers together employ fewer than 200 full and part time people. Staff
contacted each "major" employer and they do not anticipate any notable growth in the next 30
years.
T< )\\';-') <)F I{( )SS • 1'.< >. BOX .120 • I{< )SS, C.\ 'J.!'):;7 -0.120
(-u:;) -1-:;.1-1-1-:;.1 • F.\X (-1-1:;) -l:;J-L '):;0
Item 9
"
Past RHNA Performance
The Town requests that ABAG use the Town of Ross' actual performance for the 1999-2006
RHNA cycle (10 low to very low income units) Instead of the estimate by ABAG staff (5 low to
very low income units). ABAG should consider that the Town will not develop housing units at a
rate equal to development in the past. The Town was incorporated in 1908. The existing 840
housing units in Ross were built when land was available for development and subdivision. Only
52 new units were built in Ross over the last 30 years. Half of the new units were built on
vacant lots. Fewer than 30 vacant lots remain, and these pose significant challenges for
development due to environmental constraints such as steep topography (80% slopes), limited
water supply for firefighting, and access issues.
Thank you for your consideration.
Sincerely,
P. Rupert Russell, Mayor
Town of Ross
cc: Marin County Supervisor Susan Adams
Item 9
CITY OF SAN RAMON
September 18,2012
Ezra Rapport, Executive Director
ABAG
Joseph P. Bort Metro Center
101 Eighth Street
Oakland, CA 94607
2222 CAMINO RAMON
SAN RAMON. CALIFORNIA 94583
PHONE (925) 973-2500
WEB SITE: www.sanramon.ca.gov
SUBJECT: Comments and Requests for Revisions to the Draft 2014-2022 Regional
Housing Needs Allocation
Dear Mr. Rapport:
The City of San Ramon is requesting revisions to the Draft Regional Housing Needs Allocation
adopted by the Association of Bay Area Governments (ABAG) Executive Board on July 19,2012.
This letter is sent as a follow-up to two previous letters sent to the Executive Board on July 18, 2012
and to ABAG staff on June 26,2012 regarding the draft RHNA methodology. In both letters, San
Ramon detailed our continued concerns over the income adjustment formula and the singling out of
San Ramon for additional allocations without merit. Our requests for revisions are based on the
following comments:
• Growth Concentration Adjustment Based on Transit Access. In the July 10th Executive
Board staff report, ABAG staff recommended a Growth Concentration adjustment to
"strengthen a fair share distribution between large cities and medium cities with high
job growth and transit access." The adoption of the Growth Concentration adjustment
resulted in increased allocations to six "major recipients" including a 10% increase in San
Ramon's Draft RHNA. The adjustment was made, in part, under the premise of transit
access. As previously noted, all six major recipients of increased allocations have light
and/or heavy rail stations within their jurisdiction EXCEPT San Ramon. San Ramon simply
does not have the same level or type of transit, or access to transit as the other major ...
recipients.
• Growth Concentration Adjustment Based on High Job Growth. The six targeted
communities for increased allocations are identified as "medium cities with highjob growth"
however, no definition is provided for what constitutes a "medium city" or "high job
growth". If the point of RHNA is to allocate a FAIR SHARE of units, other jurisdictions
Cn>' COUNCIL' 973-2530
CITY MANAGER 973-2530
CITY ATTORNEY 973-2549
CITY CLERK' 973-2539
AOMINISTRATIVE SERVICES 973-2609
PLANNlNG'COMMUNI1>' DEVELOPMENT' 973-2560
ENGINEERING SERVICES 973-2670
POLICE SERVICES 973-2700
PUBLIC SERVICES 973-2800
PAR~S & COMMUNITY SERVICI.5 973-3200
ECONOMIC DEVELOPM[NT: 973-2554
Item 9
September 18,2012 Page 2
that fit the criteria of both medium city and highjob growth should also be assigned a higher
RHNA. A sample of seven other jurisdictions were identified in San Ramon's July 18th letter
to the Executive Board where City size and employment growth matches San Ramon's.
Additionally, San Ramon noted that of the cities includes in the sample, all cities have
existing, functional and funded light and/or heavy rail EXCEPT San Ramon. However, no
such jurisdictions were subject to a double-digit percent increase in RHNA except San
Ramon. Ifhigh job growth and transit access is the primary criteria for increased allocations,
San Ramon is not where increased allocations should be made.
• Jobs-Housing Balance in San Ramon. San Ramon has made significant progress in the
past two housing cycles to bring our community closer to reaching the regional goal of a
balanced jobslhousing ratio. As demonstrated by our past RHNA performance (1999-2006),
San Ramon built over 7,000 new units of which over 1,700 (24% of all units built) were
below-market rate. San Ramon is committed to reaching a 1.05 jobslhousing ratio by
General Plan buildout in 2030. We are a rare example of a community that is successfully
addressing the regional need while other cities, especially transit-rich and employment-rich
communities with ratios upward of 2.0 should be asked to do more.
• Income Allocation Adjustment Factor. San Ramon would like to reiterate our concern
with the 175 percent income adjustment as unrealistically high. The draft RHNA calls for
1,073 (76%) of our total unit allocation to be very low-to moderate-income level housing
units. This substantial percentage of affordable units is not feasible given the available tools
to incentivize the construction of affordable housing as well as the recent elimination of our
Redevelopment Agency. Artificially inflating the amount of affordable units to jurisdictions
forces cities to zone for far more units than their assigned RHNA and mounts the pressure to
build in areas contrary to the regional goals.
We ask for your consideration of San Ramon's comments and an adjustment of our allocation
accordingly. If you wish to discuss our comments further, please contact me by email at
pwong@sanramon.ca.gov or by telephone at 925-973-2565.
Sincerely,
ent:
Comment letter to Ken Kirkey, dated June 26, 2012
Comment letter to ABAG Executive Board, dated July 18,2012
Item 9
September 18, 2012
Cc: San Ramon City Council/City Manager
Miriam, Chion, ABAG Acting Director of Planning and Research
Debbie Chamberlain, Planning Manager
Cindy Yee, Associate Planner
c12.0S5 ABAG Executive Board ABAG RHNA 2014-2022 Draft Allocation Letter
Page 3
Item 9
CITY OF SAN RAMON
July 18,2012
ABAG Executive Board
10 1 Eighth Street
Oakland, CA 94607
2222 CAMINO RAMON
SAN RAMON. CALIFORNIA 94583
PHONE: (925) 973-2500
WEB SITE: www.sanramon.ca.gov
SUBJECT: July 10th ABAG Staff Memo Re: Final Regional Housing Need Allocation
Methodology, 2014-2022 Draft Regional Housing Needs Allocation (RHNA)
Dear ABAG Executive Board:
This letter is written as a follow-up to the City of San Ramon's comment letter dated June 26,2012
to ABAG staff regarding the draft RHNA methodology_ In that letter, San Ramon detailed our
concern over the income adjustment fonnula (see attached). These issues continue to be of concern
and inadequately addressed by ABAG staff. In the July 10,2012 report to the Executive Board from
ABAG's Executive Director, San Ramon is the target of another increase in allocation without a
clear explanation on why our community has been singled out for increase.
The July 10th report identifies two adjustments for the Board's consideration for adoption of the Final
RHNA Methodology. The reason provided for the Growth Concentration adjustment is to
"strengthen a fair share distribution between large cities and medium cities with high job
'growth and transit access." The major recipients of this proposed redistribution are:
Cities # of Additional Units Employment Growth %
(2010-2040)
Fremont 467 34%
Sunnrrale 392 27%
Santa Clara 279 28%
Pleasanton 158 32%
SanRamon 126 32%
San Carlos 61 23%
San Ramon is opposed to the additional assigned units to our jurisdiction. While the adjustment is
characterized as a 1.5 percent "minor adjustment" and a "shift of a small share" in the region, it
represents a 10% increase in San Ramon's draft allocation and a 50% increase since the first draft
allocation presented to the ABAG Executive Board in March 2012.
CITY COUNCIL 973-2530
CITY MANAGFR 973-2530
CITY ATTORNEY 973-2549
CITY CLERK 973-2539
ADMINISTRATIVE SERVICES 973·2609
PLANNING. COMMUNITY DEVELOPMEJolT 973 2560
ENOINErklNO SERvlcrS 973-2670
POLICE SrRVICI:S 973-2700
PUBLIC S!RVIC(S 973.2800
PARKS" COMMl NITY SrRvlcrs 973·3200
ECO~OMIC DLV(LOPMlNT. 973·2554
Item 9
July 18, 2012 Page 2
The adjustments are made, in part, under the premise of transit access. All of the six major recipients
of additional units listed above have light and/or heavy rail stations within their jurisdiction
EXCEPT San Ramon. San Ramon, like many other similarly-sized cities may provide transit access
through express bus service and bus transit stations, but in no way do we provide the same level or
type of transit, or access to transit as the other cities listed.
Additionally, the targeted communities for increased allocations are identified as ''medium cities
with high job growth." No definition is provided in the report for what is considered a "medium
city", but one can assume that if San Ramon is considered medium-sized, numerous jurisdictions in
addition to San Ramon should also be considered for adjustment:
City Housing Units Employment Employment RaiVMass PDA?
(2010) (2010) Growth f"-') Transit?
SanRamon 26,220 43,880 32% No Yes
City A 49,450 77,020 29% Yes Yes
CltyB 32,420 39,900 33% Yes Yes
CityC 48,300 69,100 30% Yes Yes
CityD 32,680 41,650 33% Yes Yes
Clty_E 29,170 58,340 32% Yes Yes
CityF 28220 89,370 33% Yes Yes
CityG 19,810 45,060 25% I Yes Yes
Source: Jobs-Housing Concentration Scenario, March 2012 and Plan Bay Area
In the two tables above, all cities listed have similar employment growth rates to San Ramon's
projected 32% increase. One glaring difference again is that all cities listed have existing, functional
and funded light and/or heavy rail EXCEPT San Ramon. We question why San Ramon is
considered for an increase when other cities in similar size, housing unit, employment growth, AND
with existing transit have not been considered for increased allocations. We also question why a city
like Newark with an expected 41% and 32% increase in housing unit and employment growth,
respectively, could merit a 7% allocation reduction while San Ramon is proposed to go up. As noted
in the July 10111 report, if high job growth and transit access is the primary criteria for increased
allocations, San Ramon is not where increased allocations should be made.
If the focus of this year's RHNA methodology is to implement the preferred JobsIHousing
Connection Scenario, other cities with significantly higher jobs/housing ratios should also be
considered for growth concentration. San Ramon has made tremendous efforts to meet the past
RHNAs assigned to our jurisdiction. During the past 10 years, San Ramon added over 8,000 housing
units to address the jobs/housing balance. In attached June 26111 letter to the Board, we identified that
San Ramon's anticipated jobslhousing ratio will be 1.05 by 2030. We are a rare example of a
community that is successfully addressing the regional need, but other cities, especially transit-rich
Aru! employment-rich communities should be asked to do more, if not the same.
Item 9
July 18, 2012 Page 3
Some make the argument that San Ramon should be content that their allocation is significantly
lower than the previous cycles. However, we find these arguments do not take the comprehensive
picture into view. The 3nl and 4th cycle RHNA assignments were made on very different
methodologies and land use goals. If a sustainability component had been included with the last two
cycles, San Ramon's allocations surely would have been much lower while cities with heavy transit
infrastructure would have been assigned far more units.
Thank. you again for the opportunity to comment on the draft RHNA Methodology. We ask that the
Executive Board take San Ramon's comments into consideration at your July 19,2012 and reject the
Alternative Proposals as drafted, or as a worse-case alternative, adopt the Income Distribution only
proposal. If you wish to discuss our comments further, please contact me by email at
pwong@sanramon.ca.gov or by telephone at 925-973-2565.
Sincerely,
Attachment:
Comment letter to Ken Kirkey, dated June 26,2012
Cc: City Council/City Manager
Debbie Chamberlain, Planning Manager
Cindy Vee, Associate Planner
Ezra Rapport, ABAG Executive Director
c12.0S8 ABAG Executive Board ABAG RHNA 2014-2022 Draft Methodology Comment Letter
Item 9
CITY OF SAN RAMON
June 26, 2012
Ken Kirkey, Director of Planning and Research
Association of Bay Area Oovernments
101 Eighth Street
Oakland, CA 94607
2222 CAMINO RAMON
SAN RAMON. CALIFORNIA 94583
PHONE (925) 973-2500
WEB Sm. www.smnrumon ell.gov
SUBJECf: Comments on the Association of Bay Area Governments (ABAG) 1014-1022
Draft Regional Housing Needs Allocation (RHNA) Methodology
Dear Ken:
Thanlc you for the opportunity to review and comment on the draft RHNA Methodology. The
following comments have been prepared for inclusion in the public record in anticipation of the
ABAG Executive Board meeting on July 19, 2012.
Overall, the City of San Ramon supports ABAO's and MTC's effort to bring a greater jobslhousing
balance to the region. As you may be aware, San Ramon has made significant progress in the last
decade to bring our community closer to reaching this regional goal. Between 2000 to 2008, the
jobslhousing ratio moved significantly lower from 1.51 to 1.24 in the City of San Ramon. With the
policies set forth in the newly adopted San Ramon General Plan 2030. including the designation of
two Priority Development Areas (PDAs), it is anticipated that San Ramon will reach its goal of a
1.05 jobslhousing ratio by Oeneral Plan buildout in 2030. Additionally, the City's Air Quality and
Greenhouse Oas Element and associated Climate Action Plan will ensure that the anticipated
balanced growth will not conflict with the implementation of AB 32-the Olobal Warming Solutions
Act of2006.
In general, San Ramon finds the main components that make up the RHNA methodology acceptable
with exception of the income allocation strategy and the transit factor used for non-PDA areas_ Our
understanding is that the income allocation strategy determines the difference between the regional
proportion of households in an income category and ajurisdiction's proportion in that category'. This
difference is then multiplied by 175 percent in an effort to be more closely aligned ajurisdiction's
income distribution with the region's distribution.
San Ramon's concern over the income allocation is the use of an overly-aggressive 175 percent
multiplier. The choice of 175 percent appears to be arbitrary and comes with little explanation as to
Cm' COUNCIL 973 2530
Cm MAN"~rR 973·2530
CIty t\TTOR""V 973.2549
C,TY CLClK 973·2539
ADMINISTRATIve SeRVICES 973-2609
PL.,'NNING CO.,,,uNm· DEVLlOPMENT 913 2560
ENGIN!tlINC SnmcES 973·267U
POlice Sel' ICLS 973·2700
PuOLlC StRI"('E$ 973.2HOO
P" ••• " CO" .. , MTV S, "VI(I , Q7J·32OU
Et o""",1C DcYI LO'Mr'T 973 2554
Item 9
June 26,2012 Page 2
why such a high value was selected. The primary justification provided in the previous housing
cycle was a 175 percent adjustment made the most meaningful adjustment for jurisdictions that
currently do not have a large supply of affordable housing. San Ramon questions why a 100 or ISO
percent adjustment was not studied as an alternative for this cycle. Has ABAO analyzed the
construction data since the factor's inclusion in 2009 to determine what impact this adjustment factor
has had on creating more affordable units in aftluent communities? Is there historical data that
supports why an adjusbnent of 175 is ideal to reaching the stated objective?
The 175 percent income adjustment is unrealistically high and ultimately defeats the region's goal of
meeting the housing needs in a sustainable and balanced approach. For example in San Ramon, our
2009 to 2014 below-market rate allocation is over 2,600 units which equals approximately 75
percent of our 3,463 total assigned units. It is impractical to expect that a community ofless than
25,000 residential units (in 2008) could add 2,600 new "atTordable" units in a 7.5 year span. By
comparison, in communities with successful inclusionary housing ordinances where 25 percent of
new development is reserved for below-market rate units, San Ramon will need to approve over
10,000 new units in 7.S years to even come close to adding the requisite 2,600 affordable units in our
community.
It appears this same flawed methodology is being repeated in the impending housing cycle. With yet
another estimated allocation of over 75 percent of our draft RHNA as below-market rate units, the
message that the regional agencies sends to our community is mixed: 1) San Ramon should plan for
a much higher production of units beyond what we are allocated in order to reach our exorbitantly
high allocation of affordable units, contrary to the region's sustainable land use goal, or 2) we will
keep assigning an unrealistic RHNA, knowing that these allocations can never be met thus resigning
the region to face an even greater shortage of housing units in 2023.
With regards to the fair-share component, San Ramon would encourage the Board to give more
weight to the transit factor in non-PDA areas. Given the intent ofSB 375 to more closely align land
use and transportation planning, not enough emphasis is being made to allocate units to jurisdictions
with no PDAs. By using a Jobs-Housing Connection Strategy and an income allocation component,
this already heavily burdens jurisdictions that have a high employment base and lower percentage of
affordable units to take a greater share of the region's allocation. If a community opted-out of
establishing a PDA and also has a strong network of transit, this factor should carry more weight
because jobs and affordability are already greatly emphasized in other components of the
methodology.
The City of San Ramon encourages the Executive Board to take into consideration the above
comments and decrease in the income adjustment percentage as well as weight the transit factor
more heavily in non-PDA areas. If you have any questions regarding the information in this letter,
please contact Cindy Vee, Associate Planner at (925) 973-2562 or via e-mail:
cyee@sanramon.ca.gov.
Item 9
Iune 26, 2012
Sincerely,
Cc: City CounciVCity Manager
Debbie Chamberlain, Planning Manager
Cindy Yee, Associate Planner
cI2.04S Ken Kirkey ABAG RHNA 2014-2022 Draft Methodology Comment Letter
Page 3
Item 9
CITY OF SARATOGA
13777 FRUITVALE AVENUE· SARATOGA, CALIFORNIA 95070 • (408) 868-1200
COUNCIL ~lE~mERS:
September 18, 2012
Ezra Rapport
ABAG Executive Director
101 Eight Street
Oakland, CA 94607
RE: Appeal of 2014-2022 Draft RHNA Allocation
Dear Mr. Rapport:
MflIlIly uppello
Jill Hlmlrr
Emilyw
Howard Miller
aU/dPage
The City of Saratoga respectfully requests a reduction to the 438 units shown in the draft
RHNA allocation for 2014-2022. The City's allocation is a direct result of the minimum
housing floor within the fair share component of the final draft methodology. As stated in
our previous comment letters, the minimum housing floor is clearly inconsistent with the
overall objective of Government Code 65584 and Senate Bill 375 which is to better
integrate land-use and transportation planning. Any significant housing growth in smaller
bedroom communities that are not supported by employment centers or public transit
would increase regional vehicle miles traveled and greenhouse gas emissions.
The past RHNA performance within the fair share component also penalizes smaller cities
that have a lower number of affordable units permitted in the 1999 -2006 cycle. Cities
should be evaluated on the number of affordable units permitted as a percentage of the
total units permitted in their jurisdiction. Affordable housing units are being built in
smaller built-out cities and those cities should be acknowledged for that effort based on the
performance of the local housing market and the total number of permits issued.
I look forward to working with your staff to discuss the reductions to Saratoga's 2014-2022
draft RHNA allocation.
Sincerely,
J mes Lindsay
ommunity Development Director
Item 9
September 18, 2012
Miriam Chion, Interim Director of Planning and Research
Association of Bay Area Governments
PO Box 2050
Oakland, CA 94604-2050
RE: Draft Regional Housing Needs Allocation (RHNA 2014-2022) Request for Adjustment
Dear Ms. Chion:
Thank you for the opportunity to comment on the draft RHNA numbers. The City of Sunnyvale
has reviewed the numbers and believes that the growth assumptions for Sunnyvale 2040 have
been overstated by ABAG and that an adjustment is required prior to adoption in order to
influence a more realistic 8-year RHNA program.
As you are aware, Sunnyvale has been consistently recognized as a leader in meeting its
housing needs for all income levels. We are confident that both our current and draft general
plans provide adequate sites to accommodate the units in Sunnyvale's RHNA totals including
focusing growth in the City's PDAs; however, market forces will playa major role in dictating
how quickly those units get built and how affordable they will be. For example, in 1993,
Sunnyvale rezoned a significant amount of land to transition from industrial to residential use;
however, it took ten years before the market caught up to that decision and homes were actually
developed on these sites.
It appears that ABAG may have utilized Sunnyvale's draft Land Use and Transportation
Element (Horizon 2035) as a starting point for its 2040 projections. First, it is important to bear in
mind that this document is a draft and is still subject to CEQA review and City Council action.
Second, even if the City Council adopts the land uses in Sunnyvale's Draft Horizon 2035 plan it
should be noted that a buildout scenario is well beyond 2035. Sunnyvale does not expect
buildout to occur by 2035 but anticipates a growth rate in line with historical patterns, which is
much less.
We also believe that Sunnyvale's affordable unit completions in the 1999-2006 Housing
Element cycle, one of the key factors in the complex formula ABAG used to develop the current
Draft RHNA, appear to have been undercounted. City staff contacted ABAG staff, Justin Fried
and Sailaja Kurella several weeks ago with the correct data for this factor. They responded that
they would investigate our concern and respond to our request for correction shortly. We would
like to reiterate our request that the necessary corrections be made, particularly as we
understand these numbers influence the RHNA numbers and will also impact our
competitiveness in future OBAG and VTA funding applications.
ADDRESS ALL MAIL TO: P.O. BOX 3707 SUNNYVALE, CALIFORNIA 94088-3707
TDD (408) 730-7501 o Printed on Recycled Paper
Item 9
Ms. Chion
RHNA Request for Adjustment
September 18, 2012
We understand that there are several sets of projections associated with Sunnyvale that may
make it unclear where to start on a realistic 2040 projection: 1) Current Sunnyvale General Plan;
2) Draft General Plan (Horizon 2035); and 3) Current General Plan with proposed PDAs at
Lawrence Station and East Sunnyvale. The following demonstrates the differences between the
projections and ABAG 2040:
BUILDOUT PROJECTIONS
Current GP +
Existing Current Horizon Proposed ABAG 2040
2010 GP 2035 PDAs Projections
PDAs 16,021 22,443 28,989 24,211 31,751
Non-PDAs 39,379 44,127 43,177 44,127 42,358
TOTAL 55,400 66,570 72,166 68,338 74,109
We understand that the allocation of housing units is driven by the Sustainable Community
Strategies process, and based on an assumption that 70% of the units region-wide would be
developed within PDAs. Again, in comparing the various projections for Sunnyvale, the split for
PDAs varies significantly and is inflated in the ABAG 2040 projection with 84% of net new
growth occurring in Sunnyvale PDAs.
SUNNYVALE NET NEW GROWTH FROM 2010
Current
GP+ ABAG
Existing Current Horizon Proposed 2040
2010 GP 2035 PDAs Projections
PDAs -7,406 12,968 8,190 15,730
61% 77% 63% 84%
Non-PDAs -4,748 3,798 4,748 2,979
39% 23% 37% 16%
TOTAL 12,154 16,766 12,938 18,709
Item 9
Ms. Chion
RHNA Request for Adjustment
September 18,2012
The ABAG 2040 projections above demonstrate that the assumed rate of development is
aggressive and has resulted in a RHNA allocation that is unrealistically high. ABAG has also
significantly overstated the projected housing numbers in two of Sunnyvale's PDAs -EI Camino
Real corridor (planned PDA) and Lawrence Station (proposed PDA). ABAG's 8-year projection
to build approximately six thousand (5,978) units at a rate of 747 annual units a years is
significantly more aggressive than historic development in Sunnyvale. Historic averages
indicate an actual 14-year average of 300 net new dwelling units built per year even considering
periods of high entitlement demand.
Sunnyvale also disputes the percent allocation between very low, low, moderate and above
moderate housing units for the RHNA, and considers the draft allocation to be significantly
skewed based on historic trends. Due to the state's decision to dissolve redevelopment
agencies, reductions in federal and state funding programs for housing, and the Palmer court
decision declaring inclusionary housing requirements for rental housing unlawful, it is
increasingly difficult for cities to assist in the development of affordable housing in order to meet
the "quantified objectives" requirement of the housing element. The vast majority of funding
sources noted in HCD's 2009 "Building Blocks for Effective Housing Elements" (e.g.
Redevelopment, housing set-aside funds, federal stimulus [ARRAJ funds, Propositions 1 C and
prior state bond funds, and various types of HUD funding) have all either been fully expended or
significantly reduced.
Our financial estimates indicate that the local funding sources we anticipate to be available
during the coming cycle amounts to just 1-2% of the total subsidy that would be required to
produce the number of very low, low and moderate income units Sunnyvale has been allocated
in the Draft RHNA, which we have estimated at nearly $700 million dollars, assuming an
average density of 40-50 units per acre. The City already has adequate sites at the "default
densities" to meet the adequate sites requirement, however we are concerned about meeting
the "quantified objectives" requirement at the end of the cycle. We understand the tremendous
strain that ABAG is under to develop the RHNA, however we are concerned that the affordability
levels are not achievable in the current and projected funding environment for housing
agencies. We recommend that at least the very low income category be significantly reduced to
realistically recognize the very high subsidy amount required for each very low income unit. We
would like to further discuss with ABAG staff a reasonable percentage split for Sunnyvale's very
low, low, moderate, and above moderate units.
Sunnyvale has been proactively involved with both the SCS and RHNA process. Although we
understand the concepts and theories behind the methodology ABAG used to allocate the units
to local jurisdictions, we do dispute that Sunnyvale should have such a high allocation of
affordable units when larger cities have had their allocations reduced (and given to only the next
five largest cities). In addition to accommodating market rate units we are concerned about the
practical difficulties and very high cost of building out the affordable units we have been
assigned for eight years especially considering the current limitations of outside funding. The
proposed eight-year RHNA rate sets Sunnyvale up to fail at providing required housing although
our adopted and proposed land use plans clearly show a commitment to meet the City's
responsibility.
Based on our own analysis as well as the City's commitment to providing its fair share of
affordable units, Sunnyvale staff recommends a reduced 8-year projection of 4,339 total net
new units that requires 542 units per year and a 75/25 percent growth split between Sunnyvale
Item 9
Ms. Chion
RHNA Request for Adjustment
September 18, 2012
PDAs and the remainder of the City as well as a mix of affordable and moderate units closer to
historic percentages.
Sunnyvale Recommended Housing Units for 2014-2022 RHNA
Recommended
8 yr increment
Type (32% of 80)
HU
EI Camino Planned Mixed Use Corridor 912
Downtown Planned Transit Town Center 480
Lawrence Station Proposed Transit Neighborhood 502
E. Sunnyvale Proposed Urban Neighborhood 810
Tasman Crossing Planned Mixed Use Corridor 448
Moffett Park Planned Employment Center -
Reamwood Proposed Employment Center 108
Peery Park Proposed Employment Center -
PDAs Total 3,260 75%
-
ITR Not in PDAs (6a and 4a) 352
ITR 5 (see Northrop Grumman tab) (288)
Village Centers (Six of Seven) 136
Total Other Citywide HU 879
Non PDAs Total 1,079 25%
-
TOTAL CITYWIDE 4,339
Due to the timeframe for adoption of the RHNA we are concerned that Sunnyvale will be
burdened with an unusually high requirement for housing. At this time we are requesting an
adjustment to Sunnyvale's RHNA allocation and respectfully petition for the ability to meet with
you as soon as possible to discuss Sunnyvale staff's recommended changes.
Han on Hom
Director of Community Development
cc: City of Sunnyvale: Honorable Mayor Spitaleri and City Councilmembers
Gary Luebbers, City Manager
, County of Santa Clara
Department of Planning and Developrnent
Plcmning Office
COUllly GO\'crllIllCIiI CClll(;r, t::asl \\lIng. 7111 Ploor
70 West Heckling Sueel
San Jose. California 95 I '0·' 705
(408) 200-5770 FAX (408) 288-9198
www.sccplannlng.org
September 19, 2012
Ezra Rapport, Executive Director
Association of Bay Area Goverrunents '
P.O. Box 2050
Oakland, CA 94604-2050
[E[ErnCE0 W(![jJ
SEP 242012
EXECUTIVE DIRECTOR'S OFFICE
RE: Santa Clara County Draft Regional Housing Need Allocation for Stanford
University Campus Lands
Dear Mr. Rapport:
This letter is inform the Association of Bay Area Governments (ABAG) that the County
of Santa Gara is not requesting any revisions to its draft Regional Housing Need
Allocation (RE-ll-JA) related to Stanford University campus lands.
County staff of the Departm.ent of Planning and Development met with and consulted
Stanford University staff in this regard, as indicated in our August 7, 2012 letter to you.
As a result of those deliberations, Stanford University representatives concurred that
the County should not request a voluntary increase in its RHNA for Stanford University
lands at this time. Please find additional explanatory information on this subject matter
in the attached transmittal to the Countys Housing, Land Use, Environment, and
Transportation Committee of the Board of Supervisors, dated August 16,2012.
If there are any further questions or need for additional information, please contact me
at (408) 299-6740, or BilI Shoe, Principal Planner, (408) 299-5749 or by email at
bill.shoe@pln.scc,~ov.org. Thank you for your time and consideration in this matter.
Sincerely,
C~~
Ignacio Gonzalez, Director, Department of Planning and Development
Attaclunents:
1. Transmittal of August 16, 2012 to Santa Clara County Housing, Land Use,
Environment, and Transportation Committee (HLUET)
2. Letter of August 7,2012 to:Mr. Ezra Rapport from Ignacio Gonzalez
3. Letter of JW1e 29, 2012 from Gty of Palo Alto to Ezra Rapport, ABAG
CC: Santa Clara County Board of Supervisors
Jeff Smith, County Executive
Sylvia Gallego, Deputy County Executive
Kirk Girard, Planning Office Manager
Goard of SupcNisors: MIke wasserman. George Shirakawil. Dave cortese. Ken Yeager. Liz Kniss
County Exccwivc: Jeffrey v. Smilh
Bill Shoe, Principal PJmu1er, Santa CI<lra County Planning Office
William T. Phillips, Stanford University
Charles Carter, Stanford University
Mr. James Keene, City Manager, City of Palo Alto
Curtis Williams, Director, Planning and Community EnviroIU11ent, City of Palo
Alto
County of Santa Clara
Department of Planning and Development
Board of Supervisors: Mike Wasserman, George Shirakawa, Dave Cortese, Ken Yeager, Liz Kniss Page 1 of 6
County Executive: Jeffrey V. Smith
63455 A
DATE: August 16, 2012
TO: Housing, Land Use, Environment, and Transportation Committee (HLUET)
FROM: Ignacio Gonzalez, Director
SUBJECT: Update on status of Region's Sustainable Communities Strategy and RHNA Methodology
RECOMMENDED ACTION
Accept report relating to the status of the Region's Sustainable Communities Strategy and Regional Housing
Needs Allocation. (Department of Planning and Development)
FISCAL IMPLICATIONS
There are no fiscal implications to the General Fund from accepting this report.
CONTRACT HISTORY
Not Applicable.
REASONS FOR RECOMMENDATION
The purpose of this transmittal is to provide HLUET with additional information on, and an opportunity to
consider and discuss, a report previously provided on June 19, 2012 to the Board of Supervisors regarding
the status of the development of the region's Sustainable Communities Strategy (SCS) and of the Regional
Housing Needs Allocation (RHNA).
On May 17, 2012, a Draft SCS was approved by the Association of Bay Area Governments (ABAG)
Executive Board and the Metropolitan Transportation Commission (MTC) to be released for public review
and comment. MTC and ABAG will now begin production of an Environmental Review for the Draft SCS.
A draft Environmental Impact Report is due to be completed and released for public comment in Fall 2012.
Also on May 17, the ABAG Executive Board approved a Draft RHNA Methodology for review and
comment. On July 19, the ABAG Executive Board adopted a Final RHNA methodology. The SCS and
RHNA provide the basis for the next cycle of Housing Element updates due in Fall of 2014 for Bay Area
jurisdictions.
Staff's analysis, comments, and assessment of the Draft SCS and the Final RHNA Methodology are
summarized as follows:
1. The Draft SCS is firmly based on sound planning principles focusing urban growth and new housing in
the urban core of the Bay Area, to achieve the maximum possible reduction in greenhouse gas
emissions, vehicle miles traveled, and limit Greenfield development, per the mandates of SB375.
2. The Final RHNA Methodology significantly incorporates the focused growth strategy embodied in the
Draft SCS, whereby Priority Development Areas (PDAs) selected by the cities and some counties have
been designated to accommodate the majority of new housing and job growth.
Board of Supervisors: Mike Wasserman, George Shirakawa, Dave Cortese, Ken Yeager, Liz Kniss Page 2 of 6
County Executive: Jeffrey V. Smith
Agenda Date: August 16, 2012
3. The SCS, which functions as the major component of the Final RHNA Methodology, results in a
methodology and allocation outcomes that are in closer alignment to and more consistent with the
County's General Plan and countywide urban growth management policies than ever before.
4. The preliminary outcomes of the Final RHNA Methodology reflect staff's input and comments provided
to ABAG and MTC during its development.
5. The County's housing unit allocation outcomes of the Final RHNA Methodology are consistent with
unincorporated area housing development capacity and permitting trends, including the portion of
County draft RHNA attributable to unincorporated areas of Stanford University lands.
6. The preliminary outcome of the Final RHNA Methodology adopted by the ABAG Executive Board on
July 19, 2012 is summarized in Table 1 below. It requires the County to demonstrate the zoning
capacity for development of 77 new housing units during the 2014-2022 time period, a slight increase
from the previous Draft RHNA numbers presented to the Board on June 19, 2012 and shown in Table 2.
The Draft RHNA numbers and their allocation between affordability categories are as follows:
Table 1: DRAFT RHNA for Santa Clara County per the Final RHNA Methodology adopted by the ABAG
Executive Board July 19, 2012
Affordability
Category
Very Low Low Moderate Above
Moderate
Total
Housing Unit
Capacity
22 13 14 28 77
For reference, Table 2 summarizes the preliminary outcome of the Draft RHNA Methodology for the
unincorporated areas of the County approved by the ABAG Executive Board on May 17, 2012 for review
and comment. These preliminary outcomes were presented to the Board of Supervisors on June 19, 2012.
They are supeceded by the preliminary outcomes of the Final RHNA Methodology, summarized in Table 1
above.
Table 2, Included for reference: DRAFT RHNA for Santa Clara County per the Draft RHNA
methodology approved for review by the ABAG Executive Board May 17, 2012 and presented to the
Board of Supervisors June 19, 2012 (superceded by Table 1, above).
Affordability Category Very Low Low Moderate Above Moderate Total
Housing Unit Capacity 15 9 11 24 58
The Adopted RHNA Methodology is similar in many respects to the RHNA methodology of previous
Housing Element cycles. However, due to its reliance on and coordination with the development of the SCS,
the RHNA allocation for the County unincorporated areas is significantly lower than in previous RHNA
cycles. To reiterate, this achievement reflects an unprecedented and highly positive degree of correlation and
consistency with the County's General Plan and countywide growth management policies, which stipulate
that urban housing and development occur within cities. This reduction is consistent with the trend over the
last two RHNA cycles of successively lower County RHNA allocations, a result of constant staff advocacy
and significantly improved understanding and cooperation at the regional planning level regarding the
relative roles of the County and the cities in implementing longstanding countywide urban growth
management policies.
Staff advocacy and involvement included for the first time representation on the region's Housing
Methodology Committee (HMC) that advised ABAG on the development of the Final RHNA Methodology.
Staff presence on the HMC was particularly instrumental in ensuring that the methodology accurately
reflected and allocated housing need associated with unincorporated area land use and development on
Stanford University campus lands. The Final RHNA Methodology for this housing element cycle relies on
household growth calculations done for the SCS at very fine levels of geographic detail, taking into account
city boundaries, Spheres of Influence, Travel Analysis Zones, and the location and types of Priority
Board of Supervisors: Mike Wasserman, George Shirakawa, Dave Cortese, Ken Yeager, Liz Kniss Page 3 of 6
County Executive: Jeffrey V. Smith
Agenda Date: August 16, 2012
Development Areas. The RHNA methodology for the previous housing element cycle, 2007-2014, is not
believed to have used such a fine level of detail for Stanford University lands.
The result of the proactive attention to the details of Stanford city/unincorporated area boundaries is that staff
has a high degree of confidence that only the housing need attributable to unincorporated Stanford University
lands has been apportioned to the County, and that the household formation and growth rates, combined with
current vacancy rate assumptions, are appropriate for the Stanford University lands and for other
unincorporated areas outside city Spheres-of-Influence (Note: Housing allocation for unincorporated areas
within a city Sphere-of-Influence is assigned to the city in Santa Clara County).
Attachment A contains a May 17, 2012 memo from ABAG Staff to the ABAG Executive Board describing
the Draft Methodology in more detail, and a July 10, 2012 memo describing the changes made to the Draft
Methodology for adoption as the Final Methodology. Draft RHNA numbers, for all ABAG jurisdictions,
produced by the Final Methodology are also included in Attachment A. The last page of Attachment A is a
flow chart that outlines the steps in the Draft RHNA Methodology for calculating the RHNA numbers.
Attachment B is the most recent schedule for the overall SCS and RHNA process provided by ABAG.
Next Steps
Response to City of Palo Alto Letter: Based on the preceding information and analysis, Planning Office
Staff does not anticipate at this time the need to comment significantly on the RHNA Methodology or
consider a protest or appeal of the preliminary RHNA numbers for the County. Both the methodology and
the preliminary numbers properly reflect the primarily rural nature of the County's unincorporated areas and
are adjusted for County-specific policy issues and other characteristics where appropriate.
However, the Department of Planning and Development (DPD) is in receipt of a June 29, 2012 letter from
the City of Palo Alto regarding the Regional Housing Needs (RHNA) Allocations for Stanford University
Campus Lands. DPD staff is in the process of discussing the City’s concerns with Stanford University.
DPD has sent an initial response to ABAG (see Attachment D). Staff anticipates the County will provide a
formal response on the current draft RHNA to address the subject by September 18, 2012, during the period
defined for requests for revisions to the draft RHNA. The next opportunity for DPD to make any
recommendations to the Board, or to have the Board review any subsequent comment letter to ABAG, would
be at the September 11, 2012 Board of Supervisors meeting.
County Staff has worked closely and proactively with ABAG Staff and the City of Palo Alto to ensure that
the portion of the County RHNA that is associated with Stanford unincorporated areas has been properly
assigned to the County, not the City of Palo Alto. In the prior RHNA cycle (2007-2014), the allocation for
Stanford University unincorporated areas was first assigned to Palo Alto, and later correctly assigned to the
County during the appeal period. In contrast, for this upcoming 2014-2022 RHNA cycle, the proper
assignment has been incorporated into the Final RHNA Methodology and County allocations adopted by
ABAG on July 19, 2012.
The concern stated in the City of Palo Alto’s letter regarding the allocation for the upcoming cycle is not
whether the aforementioned assignment was correctly made, but whether the County’s RHNA is too low in
regard to Stanford unincorporated areas. Specifically, it suggests that the Stanford General Use Permit
(GUP) plans for approximately 1,000-1,500 new housing units to be developed on the campus over the next
10 years, and requests that the County’s RHNA numbers reflect some of this development. The letter also
suggests that increasing the County’s RHNA might reduce that of Palo Alto’s.
For HLUET’s consideration, the Planning Office has the following comments on the letter of the City of
Palo Alto:
1. The comparison of the County’s current RHNA to the prior period does not account for significant
changes in the RHNA methodology for this cycle, predominantly the reliance on the Sustainable
Communities Strategy (SCS) and Priority Development Areas (PDAs) to account for over 70% of new
housing capacity.
Board of Supervisors: Mike Wasserman, George Shirakawa, Dave Cortese, Ken Yeager, Liz Kniss Page 4 of 6
County Executive: Jeffrey V. Smith
Agenda Date: August 16, 2012
2. The units of housing capacity identified in the GUP are not the equivalent of dwelling units. They
represent a number of students and faculty to be housed, categorized variously under Faculty / Staff,
Postdoctorate, Graduate, and Undergraduate housing. Only the Faculty/Staff category can be directly
equated with housing units as defined by the State Department of Housing and Community Development
(HCD). Faculty / Staff units are single-family residences.
In contrast, Undergraduate unit capacity could be developed in the form of dormitories, which HCD does
not count as housing units for purposes of housing elements. Housing for the Graduate category could be
satisfied in a number of ways, including studios or multi-bedroom apartments. Until a specific
development proposal is made by Stanford for Graduate or Postdoctorate housing, it is not possible to tell
how many HCD-defined dwelling units (“kitchens and independent access”) would be created out of the
GUP housing unit capacity (“students/faculty housed”).
3. The Stanford Community Plan and GUP reflect an allocation for development, not plans for
development. Furthermore, the allocation under the GUP has no time limit. It is not a “10 year plan” that
roughly correlates with the next 8-year housing element cycle. There is no requirement, or any
expectation, that capacity under the GUP necessarily will be utilized in the next 10 years.
4. Changes to the County’s RHNA would not result in corresponding changes in the City’s RHNA. ABAG
Staff have confirmed on a number of occasions that any changes to one jurisdiction’s RHNA would
result in that change being reapportioned throughout the region. An increase in the County’s RHNA
would result in a reduction to the overall housing need to be redistributed throughout the region.
5. Finally, the regional housing needs determination from HCD and the resultant methodology for each
jurisdiction’s RHNA are based primarily on housing need and the SCS policy framework for improving
housing and transportation integration. Each city and county then has the obligation to determine
whether it has planned for a sufficient housing capacity to meet their portion of the need in all income
categories.
If the County were to consider voluntarily increasing its RHNA for Stanford unincorporated areas to some
extent, it would only be as a result of careful evaluation and consultation with Stanford University.
Considerations include, but are not limited to an understanding that such modifications would not involve
changes to or new conditions to the General Use Permit or changes to the Stanford Community Plan, and that
possible changes would not imply any commitment to or precedent for future housing allocations to the
County. To that end, Planning Office staff are engaged in ongoing discussions with Stanford officials and
staff to determine whether any such modification is appropriate and what recommendations to make to the
County’s Board of Supervisors in this regard.
One Bay Area Grant Requirements for Complete Streets and Housing Elements: Along with the Draft
SCS and the Draft RHNA Methodology, on May 17th, 2012 the ABAG Executive Board and the MTC also
approved by resolution the One Bay Area Grant (OBAG) program. To be eligible for the transportation
funding in the current OBAG funding cycle, each jurisdiction must have an adopted and certified Housing
Element for the 2007-2014 period, and must have a circulation element within its general plan that is
compliant with the Complete Streets Act. As an alternative, cities or counties that have not recently adopted
a circulation element that complies with the Complete Streets Act may adopt a Complete Streets Policy
Resolution by January 31, 2013. A draft resolution potentially satisfying this condition is being developed
now by Roads and Airports staff, and will be further refined in consultation with MTC and the Valley
Transportation Authority before being presented to the Board of Supervisors for consideration later this year.
There will be a future report providing additional details on the adopted OBAG program, in particular the
additional requirement for the next OBAG funding cycle that each jurisdiction's General Plan Circulation
Element needs to be updated for compliance with the Complete Streets Act by October 2014. Consistent with
the current OBAG program, it is expected that each jurisdiction's Housing Element for the 2014-2022 time
period will also need to be certified by the State Department of Housing and Community Development in
order to be eligible for future transportation funding cycles of the OBAG program.
Board of Supervisors: Mike Wasserman, George Shirakawa, Dave Cortese, Ken Yeager, Liz Kniss Page 5 of 6
County Executive: Jeffrey V. Smith
Agenda Date: August 16, 2012
CHILD IMPACT
The recommended action will have no/neutral impact on children and youth.
SENIOR IMPACT
The recommended action will have no/neutral impact on seniors.
SUSTAINABILITY IMPLICATIONS
Accepting this report will not have a direct Sustainability impact. However, both the Draft SCS and the Draft
RHNA Methodology support and promote sustainable development principles. They also reflect and are
consistent with the positive role that the County's existing growth management policies play in focusing
urban growth within cities and preserving the rural nature and resources of lands outside cities' Urban
Service Areas.
BACKGROUND
On May 17, 2012, the ABAG Executive Board and the MTC approved the release of the region's Draft
Sustainable Communities Strategy for public and commencement of environmental review. The Draft
RHNA Methodology was also approved for comment. After receipt of comments, the Draft Methodology
was scheduled to be modified as appropriate then to go before the ABAG Executive Board on July 19, 2012
for adoption as the Final RHNA Methodology [the Final RHNA Methodology was adopted by ABAG
Executive Board on July 19, 2012]. Because Supervisors Cortese and Wasserman serve as members of the
ABAG Executive Board and had an opportunity to vote on the draft RHNA Methodology on July 19, 2012,
the Planning Office provided an original version of this report to the Board of Supervisors on June 19, 2012,
and thus provided an opportunity for the Board to discuss and comment on the draft RHNA methodology
before the July 19th meeting of the ABAG Executive Board had they desired to. Subsequent to the Board of
Supervisors’ meeting, the County Executive’s Office suggested submitting the report to the HLUET in
August to provide them an additional opportunity to discuss and comment on the RHNA Methodology and
the Draft RHNA results.
Also on May 17, 2012, the ABAG Executive Board and the MTC approved by Resolution the One Bay Area
Grant (OBAG) program for 2012-2016. A separate discussion of the OBAG program, including a Draft
Complete Streets Policy Resolution, is anticipated to be presented to the Board by the Roads and Airports
Department, in conjunction with the Department of Planning and Development, in Fall 2012.
The last attachments to this updated transmittal include a letter from the City of Palo Alto to ABAG
commenting on the County’s initial draft RHNA numbers (Attachment C). A response to that letter is also
attached (Attachment D). County staff are presently evaluating the issue raised by the City of Palo Alto in
consultation with Stanford University representatives to determine if modifications to Stanford’s portion of
the County’s RHNA are appropriate and what recommendations to bring to the Board of Supervisors for its
consideration.
CONSEQUENCES OF NEGATIVE ACTION
If the HLUET does not accept this report, staff will respond to comments and requests for additional
information or analysis as directed by the Committee.
STEPS FOLLOWING APPROVAL
The Clerk of the Board will provide a record of the Committee’s action to the Department of Planning and
Development for its files. Staff will also provide future reports to the Board as ABAG and the MTC reach
further milestones in the development and adoption of the SCS.
Board of Supervisors: Mike Wasserman, George Shirakawa, Dave Cortese, Ken Yeager, Liz Kniss Page 6 of 6
County Executive: Jeffrey V. Smith
Agenda Date: August 16, 2012
ATTACHMENTS:
RHNA methodology memos from ABAG as Attachment A (PDF)
RHNA Schedule as Attachment B (PDF)
Letter of City of Palo Alta RHNA Comments_06.29.12 as Attachment C (PDF)
Letter to ABAG re City of Palo Alto letter as Attachment D (PDF)
County of Santa Clald
Department of Planning and Development
Planning Office
COllnly Gov(!rnmcnl Cenler, Easl Wing, "" Floor
70 West HeclcUng Slreer
San Jose. CCllifomfa 95 I 10-1 705
(08) 299-5770 F,\X (408) 288·9198
www.sccplannlng.ors
August 7, 2012
Ezra Rapport, Executive Director
Association of Bay Area Governments
P.O. Box 2050
Oakland, CA 94604-2050
Re: County of Santa Clara Response/Comments on City of Palo Alto Letter of June
29,2012 Concerning RHNA for Stanford University Campus Lands
Dear Mr. Rapport:
The County of Santa Clara is responding to the June 29, 2012 letter from the City of Palo
Alto regarding the Regional Housing Needs (RHNA) Allocations for Stanford University
Campus Lands. The purpose of our letter is to convey that the County is in the process of
discussing the City's concerns with Stanford University. Staff anticipates the County will
provide a fonnal response on the current draft RHNA to address the subject by September
18, 2012, during the period defined for requests for revisions to the draft RHNA.
lfthe County were to consider voluntarily increasing its RHNA for Stanford unincorporated
areas to some extent, it would only be as a result of careful evaluation and consultation with
Stanford University. Considerations include, but are not limited to an understanding that
such modifications would not involve changes to or new conditions to the General Use
Pennit or changes to the Stanford Community Plan, and that possible changes would not
imply any commitment to or precedent for future housing allocations to the County. To that
end, County staff are engaged in ongoing discussions with Stanford officials and staff to
determine whether any such modification is appropriate and what recommendations to make
to the County's Board of Supervisors in this regard.
Thank you for receiving our comments on this matter. If there are any questions or further
need for infonnation, please contact me at (408) 2996740 or Bill Shoe, Principal Planner,
(408) 2995749 or by email at bill.shoe@pln.sccgov.org.
Sincerely,
Ignacio Gonzalez, Director of Planning and Development
Bo<mJ of Supervisors: ~'lIke wasserman. George Sl1irakawa. Dave correse, Ken "'·eager. Liz Kniss
COLIOly Exccullvc: Jeffrey V. Smlill
. June 29, 2012
E~a Rapport, Executive Director
Association of Bay Area Governments
P.O. Box 2050
Oakland, CA 94604-2050
G~ of Palo Alto
Office of the City Mana.ger
Re: Regfcnal Housing Needs (RHNA) Al]ocations 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 withjurisdiction over the sphere of influence (S01). as the County has strong programs in
plaCe to direct cities to annex pockets ofunincorporafud areas. We do have a specific and .
substantial co~cem with allocations of housing for Santa Clara County, as it pertains to the
Stanford U~versity campus area, however.
The Stanford University Campus lies within Palo Alto's-Sphere-of-Influence (S01), but new
campus development generates population and housing needs that are governed by Santa Clara
County, not the City, and are not subject to poteJ;l:tial 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 anocation 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 RENA 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/docsfPlanning. %200fficeOIo200flIo20 rDEP)/attachmentslStanfo
rdlARlO all.pdf) regarding Stanford's General Use Permit (OUP) with the County, however,
approximately 1,000-1,500 new housing units are planned. 00 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 CaiDino Re8I and near the University Avenue
Caltrain station. These two' sites (H and I in the report) are planned to accommodate a minimum
rdnll:rl wltl' SO)'·b.u.NI UlL:.s on ~o~ rtcydcd papt'r prott'Mod with:J\l1 chlorine
P.O. Box 10250 PaJoAlw,CA 94303
650.329.2.563
650.3i5.5025 fax
I
I
I I
.1
L .,
I
ABAG: Draft RHNA Allocations: June 29,2012
Page 2
of 350 units. These sites w.o uld be wi thin VT A' s E1 Cam ino Corridor area if it was app lied 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
Alto's allocation accordingly, it would seem that some of them, particularly th<;>se nearest El
Camino and the train station, would have that effect.'
The City of Palo Alto hopes these allocation issuc::s 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 B$ 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 tliem 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 OJ;' Curtis.williams@citofpaloalto.org,
,. Sincerely, "
, ~,,,, :11' Jt: IJ,;-~,:" .. . ;'. . ... ' 0.:' "J ":.
, am~ K~ene: 'C~~ ~ana~e;'
City of Palo Alto
cc: Palo Alto City Coun,cil ,
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
~g Wong. ABAG
'Justin Fried, ABAG:
1
California Demographic Forecasts: Why are the numbers over
estimated?
Prepared by City of Palo Alto
November 15, 2011
Actual California Population growth
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
scheduled to be revised until 2013.
Table 1. California’s population growth over the last five decades
(average growth from census to census)
Census Dept of Finance Projections (2007)
1960s 29.2
1970s 18.5
1980s 25.7
1990s 13.8
2000s 10.0 14.8
2010s 12.8
2020s 11.6
2030s 10.2
Source: US Census Bureau actual Census numbers; California Department of Finance 2007 Projections.
2
Recent State forecasts have been consistently overestimated
Even after the sharp decline in growth during the 1990s, forecasters consistently tended to be overly
optimistic about population growth rates through the 2000s. 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
USC Population Dynamics 11.6
UC Berkeley (Lee, Miller) 13.9*
Public Policy Institute of CA 15.2*
CCSCE 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.
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 that the growth rate would be lower than 7.1%. The 2005 PPIC Report stated that “Recent trends
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.
3
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, 20002010
(millions of people)
Births +5.45
Deaths ‐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.
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 551 in 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
4
economic factors as much as from U.S. conditions. They identified five internal factors of change in
Mexico:
• 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 2000s.
• 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 report 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
difficult…In 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