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Comments on the Sausalito Housing Element process
The following letter has been sent to the Sausalito City Council, providing additional comments regarding the city's current Housing Element process and the recently published "Sausalito Residential Development Assessment Report."
Dear Sausalito City Council,
John Flavin and I recently submitted a “Residential Development Assessment Report” prepared by Community Venture Partners ("CVP"). It was compiled in response to concerns surrounding Sausalito's recently initiated Housing Element development process and the housing quotas handed to us by ABAG. The Report was preceded and aided by CVP's research taken over the past two years during Sausalito's General Plan development.
I offer the following additional comments for your consideration.
The Report provides an overview of the many alternative ways to designate zoned, housing development capability to meet our RHNA requirements, in conjunction with the community’s objective of bringing equity, diversity, and inclusion to Sausalito's housing stock. As you will note, not all of these suggestions will be needed to satisfy this year's RHNA (the number of existing housing opportunity sites far exceed the City’s current RHNA quota) nor will all of them be acceptable to everyone.
However, since the quantity of potential housing highlighted by this analysis is far above the RHNA requirement, no rezoning or conversions of existing commercial / industrial / working waterfront properties will be required in the City’s new Housing Element cycle. Regardless of whether any particular property appears to be "underutilized," Sausalito's working waterfront, industrial, and commercial properties offer distinct and vitally important resources to our business community, residents, adjacent communities, and the City treasury, both now and into the future. Housing districts are notoriously municipal resource users, and municipalities (including Sausalito) have historically relied on business districts to support the costs of services required by residential areas.
A prominent local developer has claimed that we cannot reach our RHNA numbers through AJUs and JDU's - that high-density projects will be necessary. Although that may have once been true, it is no longer the case. As the Report shows, we now have many alternative affordable housing opportunities.
Another individual, who wrote today to Housing Element Advisory Committee, also claims that the Report is based on “unrealistic” expectations, pointing out, for example, that building on a portion of the City Hall property would be “extremely unlikely” due to setbacks, FAR, parking, and height limits. However, he fails to note that under SB 35, combined with the State Density Bonus law, a 100% affordable project is exempt from most if not all of these requirements.
He continues by saying that the Report contends that “every home owner in Sausalito would add 1-2 units.” However, the Report only assumes that 25% of the existing residential parcels would be eligible and even those would not be developed to their maximum allowable density. The Report also fully recognizes that any assumptions about what are or are not housing opportunity sites must be reasonable, and took that into account in its results.
I mention all this by way of advising the Council to look at the facts, read the Report carefully, and not to listen to hysterical fearmongering.
State-mandated ADU/JDU regulations and SB9 lot splits are by-right, afforded ministerial review, and are not subject to CEQA or other forms of environmental review. To not count qualifying parcels as legitimate housing opportunity sites would be beyond irresponsible.
Regarding affordability, ADU's and JDU's are categorically much smaller and much more affordable to rent than our typical high-end, single-family housing. At the same time many of the housing units that are developed as a result of SB 9, will also be smaller (e.g. duplexes) and more affordable. And, as the Report points out, the City owns a considerable amount of land that is yet another opportunity to develop affordable housing.
It goes without saying that with all residential development in Sausalito, the City retains the authority to enforce its local inclusionary percentages of affordable units and deed-restricted units for each development application to ensure diversity in our community. To presume that all ADU and SB 9 developments will be luxury units is simply false.
The Report reviews and analyzes City-owned property with attention to geographical detail and with some creativity. It is certainly true that the primary constraint to housing creation in this very expensive area is the cost of land; it is also true that control over development now rests almost totally in the hands of the land-owner, as the State has removed most local control over development standards. So, the only way our city will control the size, appearance, and amenities in a development will be to develop property it owns, sells with conditions, or joint ventures with a willing development partner.
As the provisions of our State ADU laws and SB 9 increase residential density in our city, we will need our industrial and businesses districts more than ever to generate taxes and services needed to support increased demands on infrastructure and municipal services. These areas should not be cannibalized for housing.
I also note that the City Staff Report for January 27th's meeting, on page 2, states: "77 Parcels are within a Very High Fire Severity Zone and are not eligible under SB 9." The suggested SB 9 Interim Guidance attachment also sites fire hazard zones as exclusionary. I am surprised at this representation, as the California State "Fire Hazard Severity Zone in SRA" map, at least as adopted on November 7, 2007, shows absolutely no fire hazard areas of any severity anywhere in Sausalito. (Complete fire hazard zone information and maps for the state of California can be found here)
Even if we did have high fire severity areas or chose to designate same, the sites could become subject to other applicable state codes specifically dictating SB 9 inclusion as "sites that have adopted fire hazard mitigation measures pursuant to existing building standards or state fire mitigation measures applicable to the development." [Section 65913.4(a)(6)(D)]
Finally, much has been discussed about "equity, diversity, and inclusion." Those objectives will be poorly served if we concentrate new units in high density, stack-and-pack developments segregated from our residential neighborhoods while hobbling the City's ability to balance its budget, serve its residents and maintain a diverse, unique business community.