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Make Your RHNA comments to ABAG

It’s not news. MTC and ABAG are lumbering bureaucracies.

In case you’re new to reading The Marin Post, MTC is the Metropolitan Transportation Commission and ABAG is the Association of Bay Area Governments. These agencies maintain power by creating complexity, apparently unfamiliar with Albert Einstein’s quote, "If you can't explain it to a six-year-old, you don't understand it yourself."

MTC/ABAG are engaged in a long-term regional effort called Plan Bay Area 2050. The Plan outlines 35 strategies across four key areas—housing, the economy, transportation, and the environment. The goal is to make the Bay Area more equitable for all residents and more resilient in the face of unexpected challenges. It reads good on paper.

Opposition, that began with the introduction of the first Plan Bay Area adopted in 2013, keeps growing, slowly building to a tipping point.

Regional Housing Needs Allocations

This year, ABAG, as a tool of the state Housing and Community Development (HCD) agency, is rolling out the 8-year housing quotas. The state’s overall goal for the 9-counties and 101 Bay Area cities has more than doubled. HCD is mandating 441,000 new homes or apartments in the 2023-2031 cycle. Marin is expected to add 14,405 new units.

Across the state, city councils, boards of supervisors and the public are incredulous. It’s common to hear the quotas called “unreasonable,” “unattainable,” and “prescriptions for failure.”

The state refers to the quotas as Regional Housing Need Allocations or RHNA (prounounced ree-na) numbers. Twenty-eight Bay Area jurisdictions have submitted letters of appeal.

ABAG began hearing appeals on Friday, September 29, including appeals from Belvedere, Corte Madera, San Ramon, and Contra Costa County. The appeals, except for 35 units in Contra Costa County, were denied.

ABAG Meeting Schedule re: City Appeals to RHNA

10/8/21, 2:00-5:00PM (Fairfax, Larkspur, Mill Valley (all Marin County). UPDATE: Appeals were denied.

10/15/21 1:00-5:00PM (Ross, San Anselmo, Sausalito, Tiburon (all Marin)

10/22/21 9:00-5:00PM (Unincorporated Marin, Los Altos, Los Altos Hills, Monte Sereno, Palo Alto, Saratoga, Unincorporated Santa Clara)

10/29/21 9:00-5:00PM (Sonoma Windsor, and any carry -over hearings

11/12/21 10:30-12:00PM – final deliberations

The hearing unfolds like this. Each city or county’s case is allocated about an hour: A 5-minute appeal from a city rep, a 3-minute rebuttal from ABAG staff, unlimited time for public comment, then time for ABAG Committee Q&A, followed by a final appeal from the city, and then a motion and vote.

Common themes ran through the September 29th appeals:

The upcoming city appeals will likely be denied because the grounds for granting an appeal are very narrowly confined to errors in the methodology. Elements of common sense, critical thinking, or the welfare of residents is not grounds for supporting the appeal.

The hearings remind me of management guru Peter Drucker who said, “There is nothing quite so useless, as doing with great efficiency, something that should not be done at all.”

There is a hint of promising news. Before the 2021 legislative session ended, Senator Portantino, in association with Senator Glaser an a few others, requested the state audit committee consider an agenda item urging an audit of HCD. Without explanation, the committee meeting was cancelled, but we can advocate for its revival in 2022.

What you can do re: upcoming meetings:

On Friday, October 15h, ABAG will be hearing appeals from three Marin communities--Ross, San Anselmo, Sausalito, and Tiburon. Uninorporated Marin will be heard the following Friday.

You can find the hearing agenda here and Zoom link:

Get your thoughts about the RHNA process and methodology in the public record by taking these steps:

Let’s be clear.There’s little that will change the outcome of the ABAG appeal process. However, this is an opportunity to name the shortcomings of this process for the public record.

The denials of the RHNA appeals will be a set-back for cities. Even more alarming, it shows a dangerous trend to rigid adherence to a methodology most agreed is flawed. We could benefit from the wisdom of winemaker Robert Mondavi. He said, “In both life and work, stay flexible. Whether in a country, a company, or a family, the same holds true: Dictatorship and rigidity rarely work. Freedom and elasticity do.” The RHNA methodology aches for greater flexibility.


RHNA, ABAG, RHNA methodology, RHNA appeals