Op-Ed: An Open Letter the State Housing Office

Al Dugan writes that the ABAG formula does not fairly evaluate a city's past performance to meet housing needs or properly reflect actual population growth.

On Jan. 5, Novato resident Al Dugan sent the following letter to Glen Campora, assistant deputy director of the California Department of Housing and Community Development and included copies to members of the Novato City Council and Gov. Jerry Brown.

Dear Mr. Campora:

I am a resident of Novato and have lived in this city since 1983.  I got involved with the affordable housing issue in 2011 when the city was looking at zoning changes and sites for more affordable housing.  I began to research the issue and was very surprised to find out what has occurred in Novato during the 1999-2006 housing cycle.

The state of California addresses the distribution of low and very low housing in an equitable manner in Government Code Section 65584(d).  This requires “Increasing the housing supply and the mix of housing types, tenure, and affordability in all cities and counties within the region in an equitable manner, which shall result in each jurisdiction receiving an allocation of units for low- and very low income households.”  This was clearly not the case from 1999 to 2006.  Even though Novato is 20 percent of the county's population from 1999 to 2006, the city created 51.4 percent of the affordable housing in Marin County.  

The Association of Bay Area Governments (ABAG) report “A Place to Call Home: Housing in the San Francisco Bay Area 2007” provides a breakdown of affordable housing Regional Housing Needs Allocations and Permits Issued by cities in the county of Marin from 1999 to 2006. 

  • RHNA allocated 1,241 Very Low Income Housing for Marin County.  A total of 528 permits were issued and 297 were from Novato or 56 percent.  Five of the 11 cities in Marin (Belvedere, Corte Madera, Fairfax, Ross and San Anselmo) had no permits issued. Larkspur had 13 percent of its allocated goal, San Rafael had 6 percent and Tiburon had 15 percent.
  • RHNA allocated 618 Low Income Housing for Marin County.  A total of 751 permits were issued and 527 were from Novato, or 85 percent.  Six of the 11 cities in Marin (Belvedere, Corte Madera, Fairfax, Ross, San Anselmo and Sausalito) had no permits issued.  Novato was allocated 242 Low Housing units and 527 permits were issued or 218 percent more than allocated by RHNA. Larkspur had 21 percent of its allocated goal, San Rafael had 42 percent and Tiburon had 21 percent.
  • RHNA allocated 1,726 Moderate Income Housing for Marin County.  A total of 1040 permits were issued and 496 were from Novato, or 48 percent.  Six of the 11 cities in Marin (Corte Madera, Fairfax, Ross, San Anselmo, Sausalito and Tiburon) had no permits issued. Larkspur had 4 percent of its allocated goal, San Rafael had 69 percent and Mill Valley had 73 percent. 
  • RHNA allocated 2,930 Above Moderate Income Housing for Marin County.  A total of 3,453 permits were issued and 1,646 were from Novato, or 48 percent.  All 11 cities in Marin had permits issued. Novato was allocated 1,130 Above Moderate Housing units and 1,646 permits were issue or 146 percent more than allocated. 

I do not believe the ABAG formula fairly evaluates past performance or properly reflects actual growth or the needs of Novato. I will address these issues:

It does not appear the current ABAG formula evaluates past performances like Novato for very low and low affordable housing to be in compliance with Government Code Section 65584(d). 

The census data indicates Novato population from 2000-2010 grew from 47,630 to 51,904, which is an 8.97 percent growth and an increase of 4,274 residents. The average household was 2.52 persons.  The household growth was 1,755.  In the 1999-2006 housing cycle, Novato built 2,966 affordable housing units. Thus Novato built 1,211 more affordable housing units than the TOTAL household increase in this time period.

More importantly, to complete a comparison for 2000-2010 for affordable housing and households affordable housing in 1999 would have to be removed and the affordable housing built in 2007, 2008, 2009 and 2010 would have to be added, and I do not have this information.  Given one year would be removed and four years added, it is expected the 1,211 difference would be the minimum difference.

Adding the Minimum Housing Floor factor of 40 percent to Novato’s affordable housing calculation in the next cycle does not seem reasonable.  The affordable housing far exceeded the needs of Novato and was subsequently filled with residents outside of Novato.  It is not fair to the citizens for Novato to have to support tax free affordable housing for non-Novato residents that stresses the schools and public services.

Reviewing this information outlined above, it is clear that the result of this distribution in Marin County resulted in Novato serving as the prime source of very low and low affordable housing, as well as all other affordable housing, for the other cities in Marin.  This concentration of affordable housing in Novato results in not less traffic but actually more traffic in Marin.  This requires people to commute from Novato to other Marin cities due to the lack of affordable housing in those other cities and is at odds with the goal of SB 375.  This is also appears to be in violation of Government Code Section 65584(d). 

It is essential that the HCD reviews for Novato in the future cycles are reasonable and properly reflect past performance and local conditions.  It may be necessary, if there is not equality or goals that are in the Novato’s best interest, for a citizen’s group in Novato to take legal action.


Al Dugan

(Patch readers: What do you think about this stance? Add a comment below.)

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Eleanor Sluis January 28, 2013 at 07:37 PM
You can be a winner with a Novato rural, family oriented strategy especially moms and dads who understand issues as noted by bloggers. Yes, it is difficult. However, you will not faint if you are authentic. Women and men need support in asking questions and judging answers. This is necessary to being involved with the city plans.. Public responses both emotional and rational are necessary for a democratic society On page 7 new strategic plan parts A c-1. The city wants to combine all the plans for Hamilton and the City into one plan. The administration’s reasoning is my concern. Translating their wording into plain English implies that developers and staff are 2/3 more important than residents are. It shows that residents receive 1/3 of the emphasis for their needs in the city. Yet, it is residents who foot the bills. An unbalanced approach to democracy is developers, staff, and Chamber having power, prominence, and money while not listening to the public. The city council colludes with this reasoning by placing this item and others as consent items not discussed with the public in forums, commissions, or in the media. Pick three blogs about improving Novato and read them aloud or create your own. Be in the winner's circle of those who have written or spoken. http://ci.novato.ca.us/agendas/pdfstaffreports/012913_Agenda%20Planning%20Item%201-29-13.pdf Please attend the 6pm meeting at City Hall, Tuesday, to speak about your concerns. Thanks.
Al Dugan February 01, 2013 at 10:27 PM
Dave, click on your name and you will see a message from me with the link to Novato Homeowners Association that will have a full press release very soon. You can join now.
Dave Robertson February 02, 2013 at 12:25 AM
Al: Do you mean me? I didn't know all that existed here. I did as you said but there is nothing there from you. Can you try again, please? Thanks.
Al Dugan February 02, 2013 at 01:38 AM
Dave, checked and the message is pending. You should have it soon.
Roger February 02, 2013 at 03:09 AM
Buds, give Al a break. He is just trying to do what you always tell readers to do....stop complaining on the Patch and take some real action to get the change you want.


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