South Pasadena will file a full-throated appeal of the number of housing units it must plan for over the eight-year period starting in 2021 under the state’s Regional Housing Needs Allocation (RHNA). Local officials say the 2,064 units allocated for the city by the Southern California Association of Governments (SCAG) — 3,173 percent higher than the figure mandated under the previous eight-year cycle — is patently unrealistic.
The state Department of Housing and Community Development (HCD) tasked SCAG with allocating a total of 1.34 million units among the government agency members in its six-county jurisdiction. Alhambra is supposed to add 6,810 units, a 356 percent jump, while San Marino was told to add 398, an increase of 19,800 percent over the previous cycle.
On Wednesday, the City Council approved the appeal, which will be filed Monday. The letter is still being finalized this week, but staff offered an overview of the general basis for the appeal.
Margaret Lin, Manager of Long-Range Planning and Economic Development, said the city will argue the housing target should be modified to achieve “a more feasible and achievable goal.”
The city will also argue the data used in the methodology inaccurately assumed a majority of the city is within the so called “high quality transit area” and failed to take into consideration existing infrastructure and topography. In addition, SCAG failed to consider local input about the capacity of the city’s schools and infrastructure to absorb such a large increase in new housing units. Nor, she said, did SCAG consider that 38 percent of the properties in the city are historic resources.
While the appeal goes forward, the city will continue to work on a Housing Element Update that comports with the existing RHNA allocation.
Lin said a draft of the cover letter for the appeal was provided to Council members, but no such document was included in the public agenda package.
The appeal will go before a SCAG subcommittee in December or January with a final allocation due in February. The city’s plan to accommodate the allocation must be folded into the Housing Element Update it is currently developing in connection with the city’s General Plan revision and must be filed with the HCD by October of 2021.
The Council expressed heartfelt thanks to the members of the ad hoc committee which is finalizing the appeal. These were Planning Commissioners Janet Braun and John Lesak; and community members Mark Gallatin, Patrick Kirchen and Zhen Tao.
Gallatin, who lead the effort to articulate the historical resources argument, told the South Pasadenan News the city is not arguing that historical resources cannot be developed to increase housing units, but that the bar to do so should be raised to require analysis under the California Environmental Quality Act.
He said the appeal is designed to speak to two audiences: the SCAG’s number-crunching technical staff and the elected officials who serve on the appeal board, “who understand the importance of localism and local input” when coming up with final allocations.
Some resistance to an appeal was expressed on the City Council because under the rules, any reduction in units allocated to one city are simply allocated to neighboring towns, creating competition between cities.
Gallatin said under new rules SCAG has adopted, if the total adjustments of all the appeals is 7 percent or less, SCAG will adjust proportionally to all jurisdictions. If the total is over 7 percent, SCAG will be required to develop a method to distribute the additional housing units.
He would not estimate the number of units the appeal hopes to achieve for South Pasadena, but emphasized that HCD and SCAG “made some fundamental miscalculations” in the way they allocated the 1.34 million regional figure “to the effect that they double what we believe is the accurate” figure.
Gallatin added it is not the city’s intent to put the onus for its share of the units on other jurisdictions. South Pasadena wants to provide its share of affordable housing but does not want to be “set up to fail.” He noted the city is taking constructive action in that has seen a large increase in the approval of accessory dwelling units (ADUs) and is preparing to adopt an inclusionary zoning ordinance.
It is unclear how many other cities may appeal their allocations, though the Pasadena City Council is set to approve an appeal of its 9,409-unit allocation during its meeting on Oct. 26.