OPINION: Housing Element Lacks Full Consideration of Housing Options
The final site designations for new housing in Piedmont will be set when City Council approves the 6th Cycle Housing Element Monday night, March 20, 2023 at the Council meeting. AGENDA.
Long story short, there will be three categories of housing added to Piedmont over the next 8 years – low, moderate and above moderate. It will be a mix of ADUs, single-family and multi-family units on public and private land. The numbers and locations for this housing can be viewed at >site designation.
The final site allocations and locations have been developed over the course of many meetings but have been driven largely by two actions:
– City Council’s decision to exclude civic center sites for housing and
– the unwillingness of the Planning Department to include an SB9 projection in the Housing Element (HE).
Council’s decision is loosely based on feasibility assessments that showed Veterans and City Hall did not pencil out for housing, but had 801 Magnolia Avenue and the tennis courts been considered as one site, it’s very likely 48 units of affordable housing could be built in the center of Piedmont. Without Civic Center development, housing types and allocations have changed at the other sites. For example, Ace/Sylvan are now designated for 80 affordable housing units (40 each) whereas in past HE drafts these sites had been designated for moderate housing. Likewise, Moraga Canyon, once slated for 100 affordable units and 32 moderate units, is now slated 60 affordable units and 72 moderate units.
SB 9 is more of a wild card in the Housing Element, one the City of Piedmont decided not to play. Visit Piedmont Civic Association for background on SB 9 but basically SB 9 allows parcels and houses of sufficient size to subdivide and add ADUs without the approval of the local jurisdiction.
With its large estate zone, Piedmont has significant potential to add moderate and above moderate housing through SB9. Despite HCD guidance to the contrary, LWC, Piedmont’s housing consultant, and the Planning Department contend that they were informed that Piedmont could not include SB9 projections in its HE. This in light of other communities similar to Piedmont that did include SB 9 projections in their Housing Element – Atherton (48), Woodside (18) and Los Altos Hills (18).
Visit HCD Planning Tool to see what other communities are doing with their HE. What these cities did that Piedmont did not was take a proactive role in incorporating SB 9 into their housing elements. In Atherton’s case, the City actively surveyed the community in October 2021, before SB 9 went into effect in January 2022. In Woodside, council members developed the SB 9 projections through public meetings. Given its limited development potential, Piedmont should have utilized an SB 9 projection in its own HE. As the Atherton City Manager noted:
“Atherton is a 100% built-out community with limited needs and resources. ….Unlike other communities, the Town also has extremely limited public property, all of which is either built out (civic center, police station, small corporation yard) or gifted to it and under deed restrictions for use (Holbrook-Palmer park). In other words, planning for Atherton’s RHNA is incomparable to other communities and required creative solutions. As such, the 6th Cycle Housing Element addresses the identified needs of the community using upzoning in portions of the Town where property owners have expressed interest, along with a combination of accessory dwelling units, lot splits pursuant to Senate Bill 9, vacant lot development. This solution provides a distributed approach in a way that best prevents segregation, racial or ethnic concentration of housing, or results in a disparate impact to access or opportunities for housing.”
By not including the Civic Center and SB9 in the Housing Element, the plan has forced more development on to Grand Avenue and Moraga Canyon. While this may satisfy HCD, it’s questionable whether it is good planning for Piedmont.
Garrett Keating, Former Member of the Piedmont City Council
Garrett’s analysis is excellent. I would add that revising the site list by removing 48 housing units from the civic center is a good thing in my view. These existing buildings have decades of useful life if properly upgraded and maintained. There’s no way 48 apartments could be added here and retain these historic buildings.
Regarding the SB9 units, LWC should be asked for confirmation in writing from HCD that SB9 units wouldn’t count towards Piedmont’s RHNA. Since the HCD guidelines allow such units, and other jurisdictions have done so, a question of the competence or integrity of LWC inevitably is raised.
I agree. – most of the civic center buildings should be preserved, with the possible exception of veterans. The HE shows 18 units at 801 and 30 at the tennis courts. These sites are not historic.