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City of Mill Valley
Mill Valley Talks About Their Affordable Housing Challenges
On April 11, 2015 Community Venture Partners submitted the following comment letter on the Mill Valley 2-15 - 2023 Housing Element.
Dear City Council Members:
On March 18, 2015 CVP submitted a detailed comment letter on the Draft Housing Element (the “HE”) for 2015-2023. In response to that letter and those of many other comments and letters by members of the community the City issued a series of notices and documents, including the Staff Report and its “Housing Element Facts.” This second comment letter is in response to those documents and the statements.
Executive Summary
In our first letter we asked for the consideration of four incremental changes to the Housing Element as it is presently written: changes we still urge you to enact.
- Insert language into the Housing Element and possibly the Land Use Element of the General Plan to better ensure that development proposals on Miller Avenue, particularly in the Gateway and Main Street rooms, be for mixed-use development because this regulatory deficiency has hampered the Planning Commission’s discretion in the past;
- Reduce the Housing Element Site list inventory “buffer” by adding another layer of “filters” be used to determine eligibility (similar to the ones already employed regarding age, FAR, etc.) in order to eliminate those sites that either (1) conflict with the clear goals and intentions of our General Plan (e.g., Sloats, Goodmans, Car Wash, etc.), or (2) conflict with clearly expressed and demonstrated desires of the community (e.g., Richardson property, etc.). Doing this leaves ample “buffer” to satisfy our RHNA obligation and planning “flexibility” by a wide margin.
- Remove the Mill Valley Affordable Housing Committee’s Supplemental Housing Site List because its inclusion is contrary to the overall GPAC public process rules of fairness;
- Remove the proposal to create a Housing Advisory Committee for the reasons noted in our April 18th letter.
Those requests were substantiated by well-researched arguments and citations of State Law. Since submitting that letter we have asked City Staff to provide their own researched arguments and citations of State Law to substantiate their claims, but nothing has been offered. Instead, in response Planning Staff appears to have doubled down on the immutability and absoluteness of their positions, even going so far as to take positions that have veered into being nonsensical (State Laws “don’t apply” [“HE Facts”] to Mill Valley?).
I’ll comment on those in the sections below. However, in being so intent on proving “Who is right,” they have entirely missed the whole point of my comments, which is that we all need to consider doing “What is right.”
Our fundamental position is that the GPAC process and the General Plan got it right but the Housing Element has it wrong. And the HE “tail” should not be allowed wag the General Plan “dog.” We should do what is right for our community and what is encoded in our General Plan. So I ask you to once again carefully consider our requests and the comments.
And finally, please consider this. In its response to the community and in its “Housing Element Facts,” Planning Staff makes an enormous effort to say that the HE is a meaningless, toothless, no consequence exercise that doesn't change anything. They say we retain “absolute” local control of everything that happens in our City. So then why is it that when we ask them to reduce the "buffer" to get rid of the sites that conflict with the General Plan or long held community desires, they say, "Oh, no we can't do that because HCD wouldn't like it?”
Does that sound like “absolute” local control to you?
For the full text of this letter see the document below or go to:Community Venture Partners Blog.