Saying most of their arguments are precluded by law, staff of the Southern California Association of Governments (SCAG) is recommending denial of appeals filed by South Pasadena and six other San Gabriel Valley cities for reductions in the number of affordable and market-rate housing units they must plan and zone for over the next eight years under the Regional Housing Needs Allocation (RHNA).
In its appeal, South Pasadena sought an 846-unit (41%) reduction from the 2,062-unit allocation it received last year from SCAG. The latter figure is the city’s share of the 1.34 million units allocated by the state Department of Housing and Community Development as the “regional determination” figure for Southern California. The regional determination was in turn divided up among SCAG’s 191 municipal members pursuant to a methodology that the agency spent months devising last year.
Many of it’s members want SCAG to consider challenging HCD’s regional determination.
A SCAG Subcommittee will hold a hearing Jan. 11 to consider the San Gabriel Valley cities’ appeals and its staff recommendations.
The hearing, one of many that SCAG will conduct this month to adjudicate RHNA appeals, is open to the public.
Joanna Hankhamer, South Pasadena’s Director of Planning and Community Development, and Janet Braun, a member of the city’s Planning Commission, are slated to make the case for South Pasadena at the day-long hearing. Braun served with four other citizen volunteers on an ad hoc committee appointed by the city council to help the city prepare its appeal.
Hankhamer told the South Pasadenan News that during an orientation workshop in December, SCAG staff was clear it would take a narrow approach to appeal grounds, so she was not surprised by denial recommendation. She said at the January 11 hearing, “the city will have the opportunity to revisit that interpretation with the SCAG RHNA Subcommittee.”
The other San Gabriel cities for which staff is recommending denial, along with their RNHA allocation and percentage reduction request, are: Pasadena (9,408, 22%), Alhambra (6,808, 51%), El Monte (8,481, 37%), Temple City (2,182, 55%), San Gabriel (3,107, “undefined”) and San Dimas, (1,245, 80%).
A total of 47 cities filed appeals of their RHNA allocations and to date, SCAG staff has filed reports on half, in all but one case recommending denial. The only exception is Riverside County, for which staff recommended a very small, 0.06 percent downward adjustment to that county’s 40,578-unit allocation.
South Pasadena argued it deserves a reduction because SCAG improperly applied the methodology used to determine its allocation; it has land protected from urban development under existing state and federal programs; circumstances have changed because recent reports suggest HCD vastly overestimated the “regional determination”; and because of fair housing considerations.
It also argued it has sewer and water infrastructure constraints, that schools could be negatively impacted, and that it lacks land suitable for urban development or for conversion to residential use.
As for the first four issues, SCAG staff said the city is simply proposing to revise how SCAG deals with high quality transportation areas, but that methodology revisions are “not an eligible basis for appeal.”
Regarding the infrastructure argument, it said, “costs incurred to upgrade and develop appropriate sewer and water infrastructure may not be considered by SCAG as a justification for a RHNA allocation reduction,” and that in any case, the city did not provide evidence that “decisions made by the applicable utility service providers would preclude the construction” of new housing units. It also said under the state code, “potential impact on school districts is not an eligible basis for an appeal.”
Staff also rejected the notion the city lacks suitable land for development or conversion because cities are “required to consider the possibility of alternate land use opportunities and zoning to accommodate” housing needs.