What ABAG thinks Alameda needs

Quick quiz: Will the City of Alameda need more or less housing in the next eight years than it needed in the past eight years?

If you answered, “More,” you can send in your application for membership in HOMES (or a slot on the City Planning Board).  Just don’t expect to get a job as a planner with the Association of Bay Area Governments (“ABAG”).

Under state law, cities like Alameda must prepare a “Housing Element” that shows how the city will meet its share of the “Regional Housing Needs Allocation” (“RHNA”) for its region.  ABAG is the organization that splits up the RHNA for the Bay Area:  It specifies how many new housing units each city must “accommodate” – i.e., have land available to build on — in four different income categories over an eight-year period.

For the last cycle (2007-14), ABAG decreed that Alameda needed 2,046 new housing units.  To meet this quota, the City created a new zoning category for multi-family housing and slapped that designation on 16 parcels throughout the City.  As a result, our local planners were able to come up with a Housing Element showing that Alameda had land available for building 2,525 housing units – well in excess of the ABAG diktat.

Next week, the ABAG Executive Board is expected to adopt the RHNA for the next cycle (2014-2022).  For this period, Alameda’s share of the regional housing need drops to 1,723 new housing units.  Thus, according to ABAG, the City needs fewer new housing units in the next eight years than it did in the prior period.

Here are the details:

Period Very low income Low income Moderate income Above-moderate income Total
2007-14 482 329 392 843 2,046
2014-22 444 248 283 748 1,723

It seems counter-intuitive that, at a time when the regional planners are issuing reports – e.g., the Plan Bay Area – predicated on expected growth in jobs and housing from 2010-40, Alameda’s housing needs are expected to be lower in 2014-22 than they were in 2007-14.  So what gives?

From a mathematical standpoint, part of the explanation appears to be that the state gave ABAG a lower regional housing target this cycle (187,990 units) than it did last cycle (214,500 units).  According to the state, the lower number reflected the “extraordinary uncertainty regarding national, State, local economies and housing markets.”  Presumably, ABAG took account of the region-wide reduction in determining the allocation for each city in the Bay Area.

The rest of the explanation lies in the change in methodology used by ABAG to spread the required new housing units around.  On its Website, ABAG explains that the new methodology involved a “sustainability” component and a “fair share” component.  Politicians may know exactly what these terms mean – at least they use them a lot — but the Merry-Go-Round must confess to bewilderment.  The best we can tell, the idea is to allocate the lion’s share – 70 per cent – of the regional housing need to “Priority Development Areas,” or PDAs for short, that feature multi-family housing and access to public transportation.

As we discussed in a previous post (“A ‘Plan’ for Alameda Point“), Alameda is home to two such PDAs —  the Naval Air Station “transit town center” and the northern waterfront “transit neighborhood.”  But only the ABAG planners know how this fact translates to assigning 1,723 new housing units to Alameda.  Unfortunately, none of the publicly available documents provides any further explanation.

Of more interest, perhaps, are the implications of ABAG’s decision for Alameda’s ongoing planning efforts.  As things now stand, the City’s land inventory already includes more than enough housing units to meet the new RHNA quota for 2014-22.  Last year, staff argued that state law required the City to re-zone 16 parcels to get to the number of housing units dictated by ABAG.  While this may have been an overstatement of the law, no similar argument will be made this time.  As City Planner Andrew Thomas stated in a written report to the Planning Board, “the current inventory of land that is available for approximately 2,525 units will be more than adequate to accommodate 1,716 units [1,723 in the final version].”

Which raises an intriguing question:  Is it possible, or desirable, to reverse the process that took place last year  – i.e., since Alameda now has a surplus of land available for the new housing units mandated by ABAG, should the City consider re-zoning any of it for other uses – say, open space?  The Merry-Go-Round posed this question to Mr. Thomas, who responded, in typically diplomatic fashion:

Given that our RHNA number is going down to 1725 from 2400+ [which includes the “carryover” from the 1999-2006 RHNA] and that we had sites for 2400 and are adding Alameda Point in the next round, the City will have more flexibility in the future when balancing its housing needs with other needs. However, please be aware that the city’s ability to zone land is not without its limitations.   State and federal law establish limitations on “takings” and other constraints on the city’s land use authorities.  These are legal issues and I am no lawyer, so I will stop here.

Fair enough.  So let’s turn to another issue:  how the new RHNA for 2014-22 may affect proposals for new housing development projects.  The current inventory shows that the City has land available for 1,246 very-low and low income housing units.  But the new RHNA for 2014-22 says the City needs only a total of 692 units in those two categories.  Does this mean that a developer should be able to put a project designed for the higher-income market on one of the sites currently designated for very-low and low-income housing?

This very scenario appears to be playing out on the so-called Neptune Beach property.  The Housing Element adopted last year counted on this parcel to provide 95 housing units in the very-low and low-income categories.  But the developer who bought the property, Tim Lewis Communities, is proposing to build 48 single-family homes, only 15% of which fall into the “affordable housing” category.  If its proposal goes through, maybe other upscale developers will train their sights on one of the other nine parcels currently designated for very-low or low-income housing.

Finally, as Mr. Thomas’s response suggests, the new RHNA for 2014-22 raises issues about planning for housing at Alameda Point.  The ABAG allocation for Alameda is for the City as a whole, including Alameda Point, but, as Mr. Thomas points out, the City chose not to include any housing units from that area in its land inventory for the last cycle.  It thus met its 2007-14 RHNA quota without any contribution from Alameda Point.  For purposes of satisfying the new RHNA quota for 2014-22, there is even less need to include housing units from Alameda Point, since the required number is lower and the existing inventory on the main Island already contains enough housing units to meet it.

Imagine the reaction from certain members of the Planning Board if, the next time the subject of housing at the Point comes up, someone argues there shouldn’t be any housing units built there because ABAG says we don’t need them.  It might be fun to watch, but it won’t happen.  And, of course, staff has no intention of making such an argument.  Indeed, as Mr. Thomas says, staff intends to include Alameda Point this time.  But one wonders how the new RHNA for 2014-22 will affect staff’s recommendation about the number of units from the Point to include in the land inventory:  It’s hard to justify planning for, say, 4,000 housing units at Alameda Point when ABAG says the City as a whole needs only 1,723 units and we already have land available for 2,525.

A report by Mr. Thomas about the new RHNA for 2014-22 was on the Planning Board agenda for May 13, but, given the lateness of the hour, the Board spent less than two minutes on the item.  Let’s hope that, when staff presents its revisions to the Housing Element later this year, the Board will find more time to discuss the issues that ABAG’s decision raises.


2007-14 SF Bay Area Housing Needs Plan: 2007-14 SF Bay Area Housing Needs Plan

City of Alameda 2007-14 Housing Element: 2007-14 Housing Element (as adopted)

2014-22 RHNA: Final RHNA (2014-2022)

May 13, 2013 staff report to Planning Board: 2013-05-13 staff memo to PB re Housing Element

About Robert Sullwold

Partner, Sullwold & Hughes Specializes in investment litigation
This entry was posted in Alameda Point, Development, Housing and tagged , , , , , . Bookmark the permalink.

1 Response to What ABAG thinks Alameda needs

  1. Boxscore says:

    Just because we don’t need more housing, don’t expect building to cease. Politicians remain all too eager to accept money from housing developers like Tim Lewis. And the city is addicted to one-time fees. Alameda doesn’t seem to understand (or care) that costs for city services for new residents quickly outstrip any new property taxes. And since the planning department allows developers to order their own traffic studies, that never seems to be an issue until after the building is built.

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