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Staff Report 3498
City of Palo Alto (ID # 3498) City Council Staff Report Report Type: Action Items Meeting Date: 2/11/2013 City of Palo Alto Page 1 Summary Title: Appeal to ABAG of RHNA Allocation Title: City of Palo Alto Appeal of Adopted Regional Housing Needs Allocation (RHNA) for the 2014-2022 Housing Element Cycle From: City Manager Lead Department: Planning and Community Environment Recommendation and Draft Motion: Draft Motion: I move that City Council authorize the Mayor to execute the attached appeal cover letter (Attachment A) and completed appeal template (Attachment B) to the Association of Bay Area Governments (ABAG) regarding the City’s appeal of the adopted Regional Housing Needs Allocation (RHNA) for the 2014-2022 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 C). On November 15, 2012, however, the City received a letter (Attachment D) from ABAG denying the request for revision for various reasons. City of Palo Alto Page 2 The next step in the prescribed appeal process is the formal appeal of the allocation. 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 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. As directed by the Committee in December, staff has also explored 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 (Attachment F). On January 31, 2013, the Committee reviewed the draft appeal cover letter and completed appeal form and forwarded it to the Council for final approval. The Committee eliminated from the cover letter all issues (projections, constraints, and GHG emissions reductions) other than the concern about the County allocation criteria outlined in the template. If Council chooses to move forward with this appeal, it must be submitted to ABAG by not later than February 18, 2012. Discussion Appeal Process State Government Code §65584.05 provides 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. City of Palo Alto Page 3 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 included in the request letter (Attachment C): 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 for the construction of housing on 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 near the intersection of Quarry Road and El Camino Real are near transit, and allow for up to 350 units per the General 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 the methodology does not allow any flexibility. Focus of Appeal The appeal cover letter (Attachment A) and the attached appeal template (Attachment B), as recommended by the Council’s Regional Housing Mandate Committee, focus on the re- assignment of 350 units from the City of Palo Alto to the County of Santa Clara. The Committee focused on this argument 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 for Palo Alto. 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. 1. 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 (table and map attached). 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. City of Palo Alto Page 4 2. 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 highly 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. 3. 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 corridors” designation and thereby treated as a PDA under the RHNA methodology (attached map). 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. 4. Lastly, the City of Palo Alto agrees that it is generally appropriate to focus more intense growth in cities rather than on open space or rural unincorporated county areas, and to encourage annexation of unincorporated areas proximate to transit stations and corridors. The Stanford owned lands subject of this appeal present an anomaly, however, in that a) these particular lands are located in an urban area, near transit, across from a vibrant Shopping Center and adjacent to a very extensive hospital expansion; b) Stanford’s expansion and housing to support its growth are unique among counties in the Bay Area and ABAG has previously re-adjusted the allocation between Palo Alto and the County in previous cycles to account for this anomaly, and c) a tri- party agreement between Santa Clara County, Stanford University, and the City of Palo Alto precludes the City from annexing these potential housing sites (although the sites are served by the Palo Alto Unified school district). For these reasons, the City believes allocations should be adjusted accordingly.” City staff has recently met with County and Stanford staff to discuss the potential for a “cooperative” transfer between the agencies. The meeting was generally encouraging, but there remain some issues of concern for the County and Stanford. An agreement with the County will take some time, and certainly would not be decided prior to the February 18 deadline for the appeal. If an agreement with the County is subsequently reached, the City could withdraw its appeal prior to ABAG’s determination in late March. Regional Housing Mandate Committee (RHMC) Review City of Palo Alto Page 5 The RHMC reviewed the draft cover letter and appeal on January 31, 2013, and recommended approval to Council by a 3-1 vote, with Councilmember Schmid dissenting. The majority indicated that it was important to focus the appeal on the City’s strongest argument, which is the transfer of units to the County’s allocation for the two Stanford housing sites. Those Committee members believed that other arguments, related to economic and housing projections, land constraints, and GHG emissions, detracted from the more focused argument, reduced the City’s credibility, and related more to ABAG’s previous decision not to appeal the original allocation from HCD. Councilmember Schmid disagreed and stressed that the City should include its objections to the projections in its appeal. The Committee did direct that staff set up a future meeting with Stephen Levy to continue discussion about the forecasts in prospective deliberations. The Committee’s staff report is included as Attachment G. Related Issues During the Regional Housing Mandate Committee’s review of the appeal process, it was noted that State Law requires that HCD’s housing projections be consistent with the Department of Finance’s population projections. This is significant 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 its 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, though ABAG did effectively negotiate lower housing numbers from the DOF initial projections. There remains an approximate 15% discrepancy between the HCD and DOF population projections, however (Attachment E). Unfortunately, while ABAG has the ability to appeal HCD’s projections, 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 and Council at future meetings. Next Steps If the City Council approves and directs the Mayor to execute the attached appeal cover letter and completed appeal template, they will be submitted to ABAG in advance of the February 18, 2013 appeal deadline. Staff will continue to work with the County and Stanford regarding a potential RHNA “transfer” agreement. Resource Impacts City of Palo Alto Page 6 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: Draft RHNA Appeal Cover Letter, February 2013 (DOCX) Attachment B: RHNA Appeal Template and Attachments (PDF) Attachment C: September 11, 2012 Request for Revision Letter to ABAG (PDF) Attachment D: November 15, 2012 ABAG Response Letter to City (PDF) Attachment E: DOF_HCD Projections Comparison Table (PDF) Attachment F: Request for Revision Letters from Other Agencies (PDF) Attachment G: January 31, 2013 Regional Housing Mandate Committee Staff Report (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. The City of Palo Alto’s grounds for appeal are 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. 1. 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 (table and map attached). 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. 2. 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 highly 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. 3. 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 corridors” designation and thereby treated as a PDA under the RHNA methodology (attached map). 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. 4. Lastly, the City of Palo Alto agrees that it is generally appropriate to focus more intense growth in cities rather than on open space or rural unincorporated county areas, and to encourage annexation of unincorporated areas proximate to transit stations and corridors. The Stanford owned lands subject of this appeal present an anomaly, however, in that a) these particular lands are located in an urban area, near transit, across from a vibrant Shopping Center and adjacent to a very extensive hospital expansion; b) Stanford’s expansion and housing to support its growth are unique among counties in the Bay Area and ABAG has previously re-adjusted the allocation between Palo Alto and the County in previous cycles to account for this anomaly, and c) a tri-party agreement between Santa Clara County, Stanford University, and the City of Palo Alto precludes the City from annexing these potential housing sites (although the sites are served by the Palo Alto Unified school district.). For these reasons, the City believes allocations should be adjusted accordingly. 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 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: 2/12/13 Contact: Curtis Williams Phone: 650-329-2321 APPEAL AUTHORIZED BY: Name: H. Gregory Schraff Jurisdiction: The City of Palo Alto Title: Director of Planning and Community Environment Email: curtis.williams@cityofpaloalto.org PLEASE CHECK BELOW: Ii] Mayor 0 Chair, County Board of Supervisors D City Manager 0 Chief Administrative Officer D Other:_'--____________ _ BASES FOR APPEAL [Government Code Section 65584.05(d)]* I!l Misapplication of RHNA Methodology Ii] 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 offarmworkers Ii] Housing needs generated by the presence of a university campus within a jurisdiction Ii] Significant and Unforeseen Change in Circumstances Brief Description of Basis for Appeal Request and Desired Outcome: The proposed RHNA aRocaUon assigns 77 hoosfng units to the County of Santa Clara (Wllncorporaled). allhough Slanford Unlverslly's General Use Pennlt with hi County of Santa Clllra County allows and plans for up 10 1,500 residentlal units to be built on Stanford lands within the RHNA housing element tlmaframe. 1. Specifically, approximately 350 planned unlls on two sites on Quarry Road just west of EI Camino Real appear appropriale 10 Include somewhere in the housfng analysis In IhIs tlmeframe (table and map atlached). Indeed, there were acUve discussions with the property owner (Stanford University) In the recent past about housing development on those sites In COfInedlon with lis current Medical Center expansion thet was approved by the City In 2011. 2. WhOe the City acknowledges lhallhese units have not been 01herwJse assigned 10 the City of Palo Alto, !hasetwo slles are proxinate to EI Camino Real and the University Avenue Cartrain slalion, and would be highly consistent wllh the obJecllves of the SCS and S8375. The sites are located veryclose to developed Iancllocaledwilhin theCity's boundaries. FurlM:nTIOf8, this land Is not protected agricullurellBnd, and therefore should nol be discounted as a sullable area forgrowih. 3.11 appears to be an oversight In the designation of priority development areas (PDAs) thatthase sites were not Included In the VaHey TransportaUon AUthorlly's (VTA's) ·cores and COJ'rldors" deslgnallon and thereby !realed aa a POA under the RHNA methodology (attached map~ The City noles thai significant areas of Palo Alto, designated by VT A In "cores and corrldors," have been treated as PDAs for the purpose of distribullng housing unlta, even though the City did not agree 10 their deslgnallon as PQAs, 4. Laslly. the Cllyof Palo Alto agrees that II is generaHy appropriate to focus more Intense growth In cities rather than on open space or rural unIncorporated county areas, and 10 encourage annexaUon of unlncorporaled areas proximate 10 transit stations and mrridors. The Stanford owned lands subjed of this appeaf present an anomaly, however, In thai a) Ihese particular lands are located in an urban area, near lranslt, aero .. from a vibranl Shopping Cenler and adjacent 10 a very extensive hospital expansion; b) Stanford's expansion and hOUsing to support Its growth are unique among counlles in the Bey Area and ABAG has pravlously re-adjusled the allocation between Palo Alto and tha County In previous cycles 10 account for this anomaly. and c}a lri-party agreement between Santa Clara County, Stanford University, and the Cily of Palo Alto precludes the Cily from annexing these potenlial housing sites (elthough the sites are served by the Palo Alto Unified school dlslr\cl~ For these reasons, !he City believes elioceUona should be adjusted accordingly, List of Supporting Documentation Included in Submittal: 1. Relevant Pages from Stanford University General Use Permit-(June 2011) . 2. VTA Cores, Corridors, and Station Areas Map for Palo Alto 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. GENERAL USE PERMIT 2000 ANNUAL REPORT NO. 10 STANFORD UNIVER ITY COUNTY OF SANTA CLARA PLANNING O FFIC E lUAU 2011 STANFORD UNIVERSITY I GENERAL USE PERMIT 2000 I ANNUAL REPORT No.10 I I. Develo p ment OverviewII. Development Overview Annual Report 9 June 2011 TABLE 2 ANNUAL REPORT 10 OTHER SPACE CAPS - PROJECT SUMMARY Non- Building Cap Category Maximum Allowable Square Footage ASA Approved (sq. ft.) Building Permit (sq. ft.) Cumulative Building Permits Approved (sq. ft.) in Previous ARs Cumulative Total Building Permits Approved (sq. ft.) Balance Remaining (sq. ft.) Remaining 1989 GUP Square Footage 92,229 0 0 92,229 92,229 0 Temporary Surge Space 50,000 0 0 28,085 28,085 21,915 Childcare/ Community Center 40,000 7,895 0 27,947 28,144 11,856 HousingHousing The 2000 GUP allows for the construction of 3,018 net new housing units on campus, with allocations for faculty and staff, graduate and undergraduate students, and postdoctoral and medical students as shown in Table 3. The GUP identified potential housing sites for students, staff and faculty (Map 3, Appendix A). As with academic/academic support building space, the housing units will be distributed among the 10 development districts (see Table 3). Housing may also be developed on sites other than those shown on Map 3, and the estimated distribution of the type and location of housing among development districts may deviate from the locations described in the 2000 GUP pursuant to 2000 GUP Conditions F.2, F.3, and F.4. As explained under 2000 GUP Condition A (A.1.c, A.1.d, and A.3.b), the square footage of housing units constructed is tracked but does not count toward the 2000 GUP building area cap (see Table C-2, Appendix C). During the AR 10 reporting period, two housing projects (Olmsted Terrace Faculty Homes – File Number 9923, and Olmsted Road Staff Rental Housing – File Number 9792) were approved. For purposes of the housing linkage requirement, as provided in GUP Condition F.8, the housing requirement is counted at the time of the framing inspection. The Olmsted Terrace Faculty Homes and Olmsted Road Staff Rental Housing projects were framed during this reporting period. In addition, two student housing renovation projects resulted in a slight change in housing units. A nnua l Rep ort 1 0Annual Report 10 June 2011 10 Annual Report As illustrated in Figure 4, the cumulative total of approved units under the 2000 GUP allocation is 1,358 units. The Olmsted Road Staff Rental Housing includes the construction of 25 units of staff housing – 17 single family detached homes and four duplexes. The Olmsted Terrace Faculty Homes entails the construction of 39 single-family detached houses on lots ranging in area from 3,200 to 7,500 square feet each. The three- and four-bedroom homes will range from approximately 1,930 to 2,400 gsf, and include a two-car garage and a designated guest parking space. I I. Develo p ment OverviewII. Development Overview Annual Report 11 June 2011 TABLE 3 ANNUAL REPORT 10 DISTRIBUTION OF RESIDENTIAL DEVELOPMENT Development District1 Allowable 2000 GUP Net Additional Units ASA Approved Units but Not Yet Framed Past Cumulative2 Final Framing Inspection Approved Units Cumulative West Campus Stable Site 372 Faculty/Staff 0 0 0 0 Lathrop 0 0 0 0 0 Foothills 0 0 0 0 0 Lagunita Driving Range Searsville Block Mayfield/Row 195 Faculty/Staff 367 Graduate 125 Undergrad/ Grad 0 0 0 0 Campus Center 352 Graduate 0 351 0 351 Quarry Quarry/Arboretum Quarry/El Camino 200 Postdoc 150 Postdoc 0 0 0 0 Arboretum 0 0 0 0 0 DAPER & Administrative 0 0 0 0 0 East Campus - Manzanita - Escondido Village - Crothers - Olmsted Rd Rental - Olmsted Terrace 100 Undergrad/ Graduate 1,043 Graduate 75 Faculty/Staff 2 25 39 East Campus Subtotal 0 937 66 1,003 San Juan Lower Frenchman’s Gerona Mayfield 717 Dolores 18 Faculty/Staff 12 Faculty/Staff 9 Faculty/Staff 0 0 4 4 San Juan Subtotal 0 0 4 4 Total 3,018 Allowed2 0 1,288 70 1,358 1. Housing may be developed on other sites and development may vary from the estimated distribution with regard to either the type (student, postdoctoral, or faculty/staff) or amount of housing on the site (2000 GUP Conditions F.2, F.3, and F.4). Redistribution occurred in AR 6. 2. Cumulative totals include results from previous annual reports. See Appendix C and/or previous annual reports for more detailed background on these cumulative totals. ppApp endix AAppendix A Reference Ma p sReference Maps A Manzanita B Mayfield/Row C Escondido Village D Escondido Village E Escondido Village F Driving Range G Searsville Block H Quarry/Arboretum I Quarry/El Camino K Lower Frenchman’s L Gerona N Mayfield O Stable Sites Source: Stanford University General Use Permit, December 2000 MAP A-3 POTENTIAL HOUSING SITES ppApp endix CAppendix C Cumulative Project sCumulative Projects C-5 KEY TO MAP C-2 ANNUAL REPORT 1 THROUGH ANNUAL REPORT 8 CUMULATIVE HOUSING PROJECTS Fiscal Year Map No.* Project Housing Units Square Footage Annual Units Annual Report 1 (2000-01) 1 Mirrielees – Phase I 102 0 102 2 Escondido Village Studios 5 & 6 281 139,258 3 Mirrielees – Phase II 50 0 Annual Report 2 (2001-02) Branner Student Housing Kitchen 0 1,596 331 Annual Report 3 (2002-03) N/A None N/A N/A 0 Annual Report 4 (2003-04) N/A None N/A N/A 0 Annual Report 5 (2004-05) N/A None N/A N/A 0 Drell House (conversion to academic) -1 (-906) 579 Alvarado 1 3,258 Annual Report 6 (2005-2006) 4 Casa Zapata RF Unit Replacement -8 (-691) (-8) Annual Report 7 (2006-2007) None N/A N/A 0 Annual Report 8 (2007-2008) 5 Munger Graduate Housing 349 267,6831 349 5 Munger Graduate Housing 251 192,5171 Schwab Dining Storage N/A 464 6 Blackwelder/Quillen Dorms 130 N/A Annual Report 9 (2008-2009) 7 Crothers Renovation 133 N/A 514 8 717 Dolores 4 0 9 Crothers 2 0 10 Olmsted Terrace Faculty Housing 39 103,127 11 Olmsted Staff Rental Housing 25 53,831 Annual Report 10 (2009-20010) Arrillaga Family Dining Commons N/A 28,260 70 Cumulative Net Contribution toward 2000 GUP Housing Units 1,358 788,397 1,358 *Map C-2 illustrates the locations of housing projects that add more than one unit. Individual housing projects are not shown on Map C-2. 1. Based on an average of 767 square feet per unit constructed for the Munger Graduate Student Housing project. ppApp endix CAppendix C C umulati ve Project sCumulative Projects C-6 • Menlo Park o '. I'-.~, I'" . >'1- '.000 .' • '.000 '''''" •. Wi • • "" • ,~, • l .,..-..-... "" "''''' ...... -_ ... .-." ~Vf><I .... ".."...",11.'Oll MAP C·2 CUMULATIVE HOUSING PROJECTS Palo Alto FOCUS o development and consetvoUon strategy for the Son Francisco Boy ~rea Neighborhood Feotures JIll 1'8' J' '" c;:J • Iii " -lit El'l I1J » :..'k '!l' ,. City or County ~dmlnlstrotlon College/U n Iversl ty K-12 School Child Core Facility Community Facility Cultural Center Police Station Fire Station Library Post Office Hospital Residential Heolthcore Facility Medical Clinic Grocery Store or Supermarket Specialty Food or Formers Morket Public Transportation 10 -20 M/nu!o Bus SOfY/C9 Sonto Cloro VT~ Stanford Marguerite Shuttle Dumborton Express .. Coltrain Roll Station Bicycle Network off street path on-street. striped lone on-street route Identified by sign/stencil Potential Priority Development Area Inside PDA Outside PDA Protected Open Spoce Source: AssocioHon of Boy Areo Governmenls. Sl.regl Base NOP <:> 2006 TgleAllos. Inc. AU rlgills reservQd ABAG GIS/July 2008 Scole Hiles ~ ° 0.12.5 0.2.5 0 . .5 Kilometers ~ ° 0.2.5 0 . .5 I ,_.__-: !.J '1' ,e ;-, .:~ , .' VTA Cores. Corridors. and Station Areas: Palo Alto Overview 08 II Sedimentatio nBasin Lake Lagunita Ea s t Pa l o A l t o Sta n f o r d Un i v e r s i t y Me n l o Pa r k Mountain View Jun ipero Serra B oulevardPage Mi ll Road ero Road E l C a m ino Real S an A n t o n i o A v e n u e Charleston Road O r e g o n E x p r e s s w a y Middlefield Road University Avenue r eeway 101 Alm a Str e et El Ca min o Re a l F o othill E x pressw Hillview East Bayshore West Bayshore Fabian Sand Hill Road Embarcadero Road Th i s m a p i s a p r o d u c t o f t h e Cit y o f P a l o A l t o G I S Thi s d o c u m e n t i s a g r a p h i c r e p r e s e n t a t i o n o n l y o f b e s t a v a i l a b l e s o u r c e s . Le g e n d VT A C o r e s , C o r r i d o r s & S t a t i o n s ( P a l o A l t o ) Pa l o A l t o C a l i f o r n i a A v e n u e P D A Cit y J u r i s d i c t i o n a l L i m i t s Tra n s p o r t a t i o n S t a t i o n s 0' 320 0 ' City of Palo AltoCalifornia Avenue PDAand VTA Cores, Corridors andStation Areas CITY OF PALO ALTO INCOR PO RATED CALIFORNIA P a l o A l t o T h e C i t y o f APRIL 16 1894 Th e C i t y o f P a l o A l t o a s s u m e s n o r e s p o n s i b i l i t y f o r a n y e r r o r s . © 1 9 8 9 t o 2 0 1 2 C i t y o f P a l o A l t o rriv e r a , 2 0 1 2 - 0 6 - 0 7 1 1 : 4 5 : 5 1 CP A P D A ( \ \ c c - m a p s \ g i s $ \ g i s \ a d m i n \ P e r s o n a l \ r r i v e r a . m d b ) 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 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% 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 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 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, UJa~ 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 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 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 LAFAYETTE SE1'IUl>l~-lNOORl'OKATI!J)l9118 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 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 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 Garry Lion M~l~nr Andrew Berman Vice M,,~or Shawn Marshall C{)un IlllJtlllltwr 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 COllllclhnenll1cr Kenneth R. Wachtel COlU'h.:i1ml·ml)(Jr James C. McCann 'lly "'1'"1"~(" 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.-;u 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 Garry lion Mayor Andrew Berman Vice Mdyor Shawn Marshall C(Jllm:ilmernOl!'f Via E-Mail and U.S. Mail ( MILL VALLEY) 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 ClllIIlUlml!lnh,;r Kenneth R. Wachtel CUllIlLilnWlnhpr James C. McCann 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 City of Mill Valley - REVISED Requestfor Revision of Regional HOllsing Need Allocation production, so Mill Valley will be unfairly judged using the current measuring sticks. 2. Identified constraints due to Mill Valley's geographic location, topography and natural environment (e.g., severe fire hazard zones, tloodwaylfloodplain, 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 retlect 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 Performance" 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 City 0/ Mill Valley - REVISED Request/or Revision 0/ Regional Housing Need Allocation Sincerely, +<~11JV Garry E. Lion Mayor enclosure cc: City Council Planning and Building Director Moore (5~ C.-"1t--tct:-~_ 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 ~~C_ITY __ O_F_N_E_W_A_R_K~._CA_L_IF_O_R_N_IA __________________________________________ _ 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 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 ~ THECITYOF NOVATO CALIFORNIA 75 Rowland Way #200 Novato, CA 94945-3232 415/899-8900 FAX 415/899-8213 www.novato.urg Mayor Denise . \thas ~!ayor Pro Tern Pat Eklund Councilrnernbers Madeline Kellner Eric Lucan Jeanne MacLearny City t,!anager l\!ichael 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 f11rE(ECEDWcefD 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 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. 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 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 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) 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 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#r- 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 City of Palo AJto L (~:,,-- 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 Council f11 CE (ECEDWCE[1J 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 .!illy·b.1seJ. inks on IOOlJ', recycled polp~r pruceued wlthuut .:hlorlne. 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 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 · ' 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 September 20, 2012 • ~ ROSS fBrltJ(laWfiill Sf? 2.4 .~'~ Mr. Mark luce President EXECUTIVE DIRECTOR'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 lS-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< )\\'~ OF H< )SS • P.o. BOX .120 • H< )SS, C.\ 'q\)~7 -0.120 (-ll~) ..j.~J-l..j.~.1· F.\X (..j.l~) -l~J-L')~() 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 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 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 fonnula 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 CITY COUNCIL 973·2530 CITY MANAGER 973-2530 CITY ATTORNEY 973-2549 CITY CLERK' 973-2539 AOMINISTRATIVE SERVICES 973-2609 PLANNING/COMMUNITY DEVELOPMENT 973-2560 ENGINEERING SERVICES 973-2670 POLICE SERVICES 973-2700 PUBLIC SERVICES 973-2800 rAR~S & COMMUNITY SERVICLS 973-3200 ECONOMIC DEVELOPMfNT: 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 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 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 CITY OF SAN RAMON July 18,2012 ABAG Executive Board 101 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 I 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 formula (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 lOth 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% Sunnyvale 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 Pl ANNINO.COMMUNITY DEVELOPMEI<T 973 2560 EHOINErRINO SERVICfS 973-2670 POLICE SrRVI([S 973-2700 PUBLIC S!RVIC(S 973.2800 PARKS" COMMI 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. 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 ("AI) Transit? SanRamon 26,220 43,880 32% No Yes CiJyA 49,450 77,020 29% Yes Yes CityB 32,420 39,900 33% Yes Yes CityC 48,300 69100 30% Yes Yes CityD 32,680 41,650 33% Yes Yes CityE 29170 58,340 32% Yes Yes CityF 28,220 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 10th 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 Jobs/Housing 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 26th 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 Bru! 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 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 3m 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 CITY OF SAN RAMON June 26. 2012 Ken Kirkey, Director of Planning and Research Association of Bay Area Governments 101 Eighth Street Oakland, CA 94607 2222 CAMINO RAMON SAN RAMON. CALIFORNIA 94583 PHONE (925) 973-2500 WEB SITE wwwsmnrumon ell.gov SUBJECT: Comments on the Association of Bay Area Governments (ABAG) 1014-1021 Draft Regional Housing Needs Allocation (RHNA) Methodology Dear Ken: Thank 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 ABAG'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 General Plan buildout in 2030. Additionally, the City's Air Quality and Greenhouse Gas Element and associated Climate Action Plan will ensure that the anticipated balanced growth will not conflict with the implementation of AB 32-the Global Wanning 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 CIn· COUNCIL 973 2530 Cin MANAGrR 913·2530 CIty t\TTORI'lEY 973.2549 LITY LURK 973·2539 ADMINISTRATIve Sel vlCES 973-2609 P"'NNI"G CO ..... uNm· DEYLLUPMEI<1" 97) 2560 EIIGINf[RINC SnmcES Y73·267U POLIce SC.'IC15 973·2700 PuBLIC SCR.'= 971.2HOO PA ... '" Co .... , MTV SI "VICI ' 073·3200 Ec:oMl\u(" DcVI LOi'Mr~T 973 25'" 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. 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 1 SO 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 detennine what impact this adjustment factor has had on creating more affordable units in aftluent communities? Is there historical data that supports why an adjustment 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 "affordable" 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 Iune 26,2012 Sincerely, ~ment Director Cc: City Council/City Manager Debbie Chamberlain, Planning Manager Cindy Yee, Associate Planner c12.045 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 CITY OF SARATOGA 13777 FRUITVALE AVENUE· SARATOGA, CALIFORNIA 95070 • (408) 868-1200 COUNCIL MamERS: 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: Mmllly Grppello Jill Hluller Emily UJ Howard Miller OU/ckPage 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 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 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 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 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. d d H Sunnyvale Recommen e ousmg nits or 2014-022 R U' f 2 HNA 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 PeeryPark 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 DepClrtlllcnt of PIClnning ,:lIlcl Dcvelopment Planning Office county Govcrnment Ccnler. 1::,151 Wing. 7111 floor 70 West Hecicling Sireel San Jose. Califomia 951 10-1705 (408) 299-5770 F .. \X (408) 288-9198 ww\V.sccpianning.org September 19, 2012 Ezra Rapport, Executive Director Association of Bay Area Governments P.O. Box 2050 Oakland, CA 94604-2050 m[E[JSceOWCE[]J 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 COW1ty of Santa Clara is not requesting any revisions to its draft Regional Housing Need Allocation (RHNA) related to Stanford University campus lands. COW1ty staff of the Department 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 COW1ty'S 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 Bill Shoe, Principal Planner, (408) 299-5749 or by email at bi1l.shoe@pln.scc.~ov.or~. Thank you for your time and consideration in this matter. Sincerely, C-~~ Ignacio Gonzalez, Director, Department of Planning and Development Attachments: 1. Transmittal of August 16, 2012 to Santa Gara County Housing, Land Use, Environment, and Transportation Committee (HL DET) 2. Letter of August 7,2012 to Mr. Ezra Rapport from Ignacio Gonzalez 3. Letter of June 29, 2012 from Oty of Palo Alto to Ezra Rapport, ABAG CC: Santa Clara COlUlty Board of Supervisors Jeff Smith, County Executive Sylvia Gallego, Deputy County Executive Kirk Girard, Planning Office l\IIanager Board of Supervisors: Mike Wasserman. George Silirakawa. Dave Cortese. Ken veager. Liz Kniss Count}' E.xecullve: Jeffrey V. Smith Bill Shoe, Principal PlalUler, Santa Clara 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 Environment, 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 county Government Center. East Wing. 7Ih Floor 70 West Hedcling Street San Jose. California 951 10-1705 (408) 299-5770 FAX (408) 288-9198 www.sccplanning.org August 7, 2012 Ezra RappOli, 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. RappOli: 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 formal response on the cun'ent draft RHNA to address the subject by September 18,2012, during the period defined for requests for revisions to the draft RHNA. Ifthe 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, 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 information, please contact me at (408) 2996740 or Bill Shoe, Principal Planner, (408) 299 5749 or by email at bill.shoe@pln.sccgov.org. Sincerely, Ignacio Gonzalez, Director of Plmming and Development Board of Supervisors: I\·like Wasserman. George Shirakawa. Dave Cortese. Ken Yeager. Liz Kniss County Executive: Jeffrey V. Smilll , June 29, 2012 E~a Rapport, Executive'Director Association of Bay Area Govemments P.O. Box 2050 Oakland, CA 94604-2050 Cio/ of Palo Alto Office of the Citl) Manager Re: Regional Housing Needs (RHNA) Allocations for Stanford University Campus/Santa Clara County Dear Mr. Rapport: , , Thank you for the opportunity to provide input regarding the draft regional housing needs allocations (RHNA) to be considered by the ABAG Board in July. The City of Palo Alto in general concUrs with the principle that housing within Santa Clara County should be allocated ,to a city with jurisdiction over the sphere of influence (SOl), as the County has strong programs in place to direct cities to annex pockets of unincorporated areas. We do have a specific and ' substantial cOJ;lcem with allocations of housing for Santa Clara County, as it pertains to the Stanford U~iversity campus area, however. The Stanford University Campus lies within Palo Alto's Sphere-of-Influence (SOl), 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;ltial annexation by the City of Palo Alto (pursuant to' a tri-party agreement between the City, County and Stanford). In the prior RHNA cycle (2007-2014), the "Stanford share" of the 'allocation increased'the City of Palo Alto's allocation by 645 units. It was not until the appeal period, however, that this correction was made, and the units redistributed to the County, with the concurrence of the City, County and Stanford. The proposed RHNA figures allocate only 58 units to Santa Clara County (as compared to 1,090 units in the prior, planning period). According to the most recent annual report (see http://www.sccplanning.org/SCC/docslPlanning,%200ffice%200fOIo20(DEP)/attaclunents/Stanfo rd/ARIO all.pdf) regarding Stanford's General Use Permit (GUP) with the County, however, approximately 1,000-1,500 new housing units are planned on the campus over the next 10 years or so. Those units do not appear to be accounted for in any way in the County's allocation, although they are already planned and zoned appropriately. The City understands that there is no Priority Development Area for lands on the campus, but there are some designat~d housing sites that are located immediately proximate to EI Camino Reru and near the University Avenue Cal~ain station. These two'sites (H and I in the report) are planned to ac~ommodate a minimum Printed with soy-based inks on 100% recycled pl'!per processed without chlorine P.O. Box 10250 Palo Alto, CA 94303 650,3~9.2563 650.325.5025 fax I i I I I ,I I I I' I I I I I ., I I i I I I I J I 1 ! , ; ABAG: Draft RHNA Allocations: June 29,2012 Page 2 of350 units. These sites ~ould be within VTA's EI Camino COlTidor area if it was applied on the west side of E1 Camino Real. The City of Palo Alto requests that the RHNA numbers reflect some of this housing development in the COWlty'S allocation, which we believe is consistent-with the County's CUlTent 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 EI Camino and the tra~n station, would have that effect. . The City of Palo Alto hopes these allocation iSSUIfS 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 ~ part of the CUlTent review. The City ofPaIo Alto has broached this subject with the COWlty and Stanford, and will continue to meet with them to assure there are not impacts or Wlintended 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 o~ Curtis.wiIIiams@citofualoalto.org. cc: Palo Alto City COWl.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 Hing Wong, ABAG 'Justin Fried, ABAG 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