October 25, 2020
Mill Valley Mayor Sashi McEntee, Vice Mayor John McCauley, and Members Urban Carmel, Trish Ossa & Jim Wickham
City Manager: Alan E. Piombo, Jr.
Director of Planning: Patrick Kelly
City Clerk: firstname.lastname@example.org
Re: Item 5: Regional Housing Needs Assessment (RHNA) Recommended Methodology Authorization for Mayor to sign the letter Re: RHNA Methodology (Attachment 1)
Dear Mill Valley Mayor, Vice Mayor, and City Councilmembers:
Summary: Reject the staff recommendation to authorize the Mayor to sign the letter re: RHNA Methodology until it strongly addresses the shortcomings of the methodology, inaccuracy of the numbers, and perilous impact on Mill Valley.
I object to the City’s submissive response to the RHNA Methodology handed down by MTC/ABAG and urge you to write a strong response on behalf of residents of Mill Valley. Your draft letter reads as if you are unaware of the facts and impacts of the proposed RHNA quota for Mill Valley. I am writing to ask you to stand up to the false narrative and flawed data and advocate for our City.
Your letter is filled with fawning phrases such as, “Please accept our comments” . . . and “The City appreciates the efforts and dedication” . . . and “We hope ABAG provides the overall policy guidance,” but fails to challenge any of the MTC/ABAG growth assumptions.
This is not just inappropriate, but perilous, considering what is at stake for Mill Valley.
Your Letter ignores findings of fact
A recent investigative report by The Embarcadero Institute, entitled “Double Counting in the Latest Housing Needs Assessment” (September 2020) states,
“Senate Bill 828, co-sponsored by the Bay Area Council and Silicon Valley Leadership Group, and authored by state Sen. Scott Wiener in 2018, has inadvertently doubled the “Regional Housing Needs Assessment” in California. [Emphasis added]
It goes on to explain,
“Use of an incorrect vacancy rate and double counting, inspired by SB-828, caused the state’s Department of Housing and Community Development (HCD) to exaggerate by more than 900,000 the units needed in SoCal, the Bay Area and the Sacramento area. [Emphasis added]
“The state’s approach to determining the housing need must be defensible and reproducible if cities are to be held accountable. Inaccuracies on this scale mark the fact that cities and counties are surpassing the state’s market-rate housing targets, but falling far short in meeting affordable housing targets. The inaccuracies obscure the real problem and the associated solution to the housing crisis—the funding of affordable housing.”
If you are not familiar with this analysis, I recommend you read the report, found by CLICKING HERE.
Your letter inexplicably accepts unrealistic assumptions about growth and housing needs, without protest
MTC/ABAG estimates Mill Valley’s housing allocation will increase from 129 units during the 2015-2023 housing cycle to 830 units in the 2023-2031 cycle: an increase of 701 new housing units! This increased need is a 543% from one eight-year cycle to the next. (See “Marin’s Estimated Housing Quotas Are off the Chart!”)
Compare these RHNA housing numbers to the actual population growth. According to U.S. Census data, the population of Mill Valley was 13,903 in 2010 and increased to 14,259 in 2019: an increase of 356 people. This increase of 356 residents represents a 2.6% increase from one ten-year cycle to the next.
MTC/ABAG’s proposed addition of 830 units in ten years (2023-2031) would add 1,951 people in less than 10 years. That represents a population increase of 650% of our population increase over the previous decade! This would be the biggest population explosion in our history, out pacing even the 1950s to the 1960s.
It is simply fanciful to believe that a small city like Mill Valley, with extremely limited public transportation, at-capacity sewage treatment capabilities, decreasing employment opportunities, and limited by wildfire risks and sea level rise could absorb the level of population MTC/ABAG is projecting in a 10-year period.
Your submissive letter fails to challenge these outlandish and erroneous growth assumptions, not to mention the damage they would inflict on infrastructure and safety.
The community depends on you to look out for our best interests. To meekly turn a blind eye to MTC/ABAG’s outrageous mandates would be negligent. Like other Mill Valley residents, I am all for promoting truly affordable housing, but the new RHNA mandates don’t make any sense.
CalMatters columnist Dan Walters, reporting about the inflated numbers and the Embarcadero Institute report writes, “resistance has developed among affected local governments and officials are mulling whether to challenge them in court.”
Instead of meekly standing on the sidelines, join leaders from other Bay Area communities who are strongly challenging RHNA methodology. I urge you to object to unrealistic allocations that would foist unsustainable, high-density development in Mill Valley and throughout Marin and the Bay Area.
I urge you to write a letter of strength!
109 Ryan Avenue