Oct 13 2021

ABAG Hears Appeals of 28 Bay Area Housing Allocations

Some of the 28 appealing jurisdictions are: the cities of Tiburon, Ross, Lafayette, Belvedere, Sausalito, Saratoga, Los Altos, Alameda, Palo Alto. and the counties of Marin, Santa Clara, Sonoma, and Contra Costa.

In addition to the 28 appeals submitted, Moraga, Mountain View, Napa County, San Bruno, San Rafael, and St. Helena sent comment letters about RHNA in lieu of submitting an appeal.   Read more about the ABAG Housing Allocation Here

The Piedmont City Council acted to not appeal the Association of Bay Area Governments (ABAG) proposed allocation of 587 new housing units in Piedmont.  The Piedmont Planning Department under the direction of the Piedmont City Council moved ahead to maximize new housing production and headed off citizen pressure to seek a reduction in Piedmont’s housing allocation requirement.

Piedmont has to date not received its official final Regional Housing Needs Allocation (RHNA) of 587 new housing units.

On March 1, 2021 the Piedmont City Council approved the issuance of a Request for Proposals for Professional Services to Update the Piedmont Housing Element to fulfill the yet to be approved ABAG housing allocation for planning period 2023-2031. Subsequently, on May 3, 2021, the City Council approved a $691,230 consulting contract to update the Housing Element and provide for the ABAG housing allocation.

Final RHNA (Housing Allocations) will be announced in December 2021, following ABAG Executive Board adoption.  A public hearing by the Executive Board will be part of ABAG deliberations.   Read more here

ABAG received 28 appeals from Bay Area jurisdictions by the July 9th deadline. In addition, a number of jurisdictions sent ABAG comment letters about RHNA, in lieu of submitting an appeal.  Housing Element Law requires ABAG to allocate all of the 441,176 units assigned to the Bay Area by HCD (California Health and Community Development Department). If the appeal of a jurisdiction’s draft RHNA allocation is successful, ABAG must redistribute the units to other local governments in the region.  < ABAG

The City Council decision not to appeal the proposed 587 housing unit allocation could result in Piedmont’s allocation being increased if even one of the 28 appeals is successful.  For some jurisdictions, appealing their allocation appears to have been a defensive measure and insurance on their part to avoid even further increases in their allocations.

The ABAG public hearings and subsequent continuations will occur remotely.  Hearing accessibility instructions (Zoom Link) will be posted to the > meetings webpage no less than 72 hours prior to the hearing and the continuations.

Appeals were heard on September 24, 29, and October 8, 2021 (recordings linked at bottom of this article).  Read the complete texts of all Appeals here.

Upcoming Hearings:

Day 4: Friday, October 15 1:00 to 5:00 (Remotely, with In-Person Option)
• Appeal #15: MRN – Ross
• Appeal #16: MRN – San Anselmo
• Appeal #17: MRN – Sausalito
• Appeal #18: MRN – Tiburon

Day 5: Friday, October 22 9:00 to 5:00 (Remotely, with InPerson Option)
Appeal #19: MRN Unincorporated Marin County
Appeal #20: SCL Los Altos
Appeal #21: SCL Los Altos Hills
Lunch Break
Appeal #22: SCL Monte Sereno
Appeal #23: SCL Palo Alto
Appeal #24: SCL Saratoga
Appeal #25: SCL Unincorporated Santa Clara County

Day 6: Friday, October 29 9:00 to 5:00 (Remotely, with InPerson Option)
Appeals #26 & #27: SON – Unincorporated Sonoma County

Appeal #28: SON – Windsor

Appeals Carried Over from Prior Hearing Days

Final Deliberations

Recordings of previous hearings are available and noted below:

RHNA Appeals Day 1 (Remotely)
Friday 9/24/2021, 9:00a to 5:00p

Meeting Recording
375 Beale Street, San Francisco, CA 94105

RHNA Appeals Day 2 (Remotely)
Wednesday 9/29/2021, 9:00a to 1:00p

Meeting Recording
375 Beale Street, San Francisco, CA 94105

RHNA Appeals Day 3
Friday 10/8/2021, 2:00p to 5:00p

Meeting Link
375 Beale Street, San Francisco, CA 94105

One Response to “ABAG Hears Appeals of 28 Bay Area Housing Allocations”

  1. While I am supportive of ABAG and HCD’s efforts to encourage infill and affordable housing, the actual RHNA housing needs assignments are questionable. The draft ABAG numbers were available in mid-2019, reflecting the job and population growth projections of recent years. However, subsequent to ABAG’s work in estimating projected need, several things happened including the pandemic. Several major tech companies decided to leave the state. California’s population growth stopped and actually declined, losing 180,000 people in 2020 according to the Department of Finance. Bureaucracies like ABAG and HCD are not likely to change course, but taking numbers like 587 units literally is arbitrary and unnecessary. The Orange County RHNA lawsuit is probably more likely to affect change than an appeal to the groups dedicated to defending the numbers.


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