August 12, 2014

CVP Asks Marin County to "Amend its Housing Element

and Extend the Public Review Process"

 

On Monday, August 25th, the Draft of the Marin County “Housing Element” (HE) for the 2015-2023 planning cycle will have its final review by the Planning Commission before being sent to the Department of Housing and Community Development (HCD) in Sacramento.

 

The County Housing Element plan will have significant impacts on all residents of Marin County. It is important that the public and our elected representatives on the Board of Supervisors have adequate time to review and comment on the plan prior to submission to HCD.

 

For the reasons noted below, we find that the proposed HE and its approval process schedule is unresponsive to community needs and unacceptable. We believe the submission should be HCD delayed and the review process extended to allow for greater public participation and comments by our Marin County Supervisors.

 

• Public Workshops Failed: The County workshops that were held to solicit public input were biased toward predetermined outcomes. Its participants were not provided with sufficient facts about potential housing project site conditions or impacts to make reasonable, informed decisions.

 

• Site and Density Decisions Lack Sufficient Logic: The methodologies and criteria used by the County to designate development sites and unit densities are generally inconsistent, inequitable and illogical. No reasonable feasibility analysis has been conducted to evaluate potential negative or unforeseen outcomes.

 

• Fast-Track Schedule is Unnecessary: The County is fast-tracking the review, submittal and approval of the HE unnecessarily. The County has until May 31st of 2015 to gain final certification of the HE from HCD, without risk of penalty of any kind.

 

• The Fast-Track Schedule Denies Sufficient Public Participation: The fast-track timetable for submittal of the Draft HE to the Department of Housing and Community Development (HCD) is unreasonable and fails to adequately involve the participation of the general public. The final document has not been made available to the public yet. Once the Draft HE is sent to HCD, the opportunity for public input is over, for all practical purposes. And many residents are out of town this month, so are unable to either respond to the draft HE or attend the August 25th public hearing.

 

• The Fast-Track Schedule Denies Sufficient Participation by Our Elected Officials: The fast-track timetable for submittal of the Draft HE to the Department of Housing and Community Development (HCD) fails to adequately provide for preliminary review and comment by our elected representatives on the County Board of Supervisors. Once the Draft HE is sent to HCD, the opportunity for significant input or changes by the BOS is over, for all practical purposes.

 

• Housing Density Far Exceeds Our Legal Requirements:  The HE’s site and density designations are in excess of the state mandated Regional Housing Needs Allocation (RHNA) quota requirements (the so-called “buffer”) and are unprecedented and potentially damaging to the character and economic and environmental sustainability of our County. The HE and its Alternatives propose to increase the number of mostly market rate housing units to approximately 422 percent of the RHNA requirement (781 units planned for instead of 185 required), and the number of high density affordable units to approximately 242 percent of the RHNA requirement (148 units instead of 61 required). There is no logical reason or legal requirement to do this.

 

• The State Density Bonus Adds 35 Percent More Units But Is Not Considered:  The HE fails to account for additional units that will result from the State Density Bonus law, which can automatically add up to 35 percent more units for projects providing minimal affordable housing. This could potentially increase the overall number of mostly market rate housing units approvable under this HE to approximately 470 percent (870 units planned for instead of 185 required) of the RHNA requirement.

 

• Failure to Ensure Affordable Housing:  Many of the HE policies and programs are untested and unlikely to result in the construction of any truly affordable housing for those most in need in Marin County. More than half the “affordable” units noted in the HE are for families making more than $97,100 a year.

 

• Significant Community and Environmental Impacts: The housing locations and densities proposed in the HE will overly impact our local roads, schools, water resources, infrastructure, and public services, and dramatically alter the character of our communities, and require further investigation.

 

We are strong supporters of realistic affordable housing solutions. However, based on the findings noted above, we hereby respectfully request that the County:

 

• Delay the submission of the Draft Housing Element to HCD until such time as the public has had adequate opportunity to review it and comment on it, and until such time as the Board of Supervisors can schedule a public hearing to review it and comment on it prior to submission to HCD.

 

• Reduce the number of designated building sites and units that are in excess of our legal requirements (the “buffer”) to a number which more realistically addresses our RHNA obligations under the law, and which is more reasonable and consistent with what other cities and counties have done.

 

• Refocus on how to create affordable housing in ways that protect public health and safety, are more equitably distributed throughout the County, and are more appropriate for the small-scale character of our towns and the infill development opportunities in our communities, and that do not place unsustainable burdens on the capacity of our roads, schools, water resources, utilities, infrastructure, and public services.

 

Please Support the CVP HE Request

Please put "Marin County Housing Element" in the "Purpose" Box