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League Submits Comprehensive Comments on HCD’s Draft 2025 Statewide Housing Assessment

Public Workshops Planned; Comments on Report Due by March 4

January 24, 2017
The California Department of Housing and Community Development (HCD) recently released its Draft 2025 Housing Assessment: “California’s Housing Future: Challenges and Opportunities.”
 
The agency is asking stakeholders, including cities, to provide comments on the report that outlines what HCD has identified as the challenges to addressing housing affordability as well possible options to help increase housing supply and reduce overall housing costs. The League has submitted comprehensive comments that examine the report and identify areas where HCD’s evaluation does not fully account for how market forces, other state policies and lack of affordable housing resources affect housing development. Cities should also review the report and provide feedback to HCD.

Useful Information on Size and Scope of Problem:
 
HCD’s draft report contains information that helps describe the significant housing needs of California’s diverse regions and residents, which includes:
  • The assessment of the serious need for more affordable housing;
  • The analysis of the economic impact of where housing is located;
  • The understanding of the full range of housing needs in terms of rental and homeownership supply; and
  • Using the lens of housing types, affordability and costs to project California’s housing needs through 2025. 
Disproportionate Focus on Role of Local Government and Incomplete Analysis of Market Forces and Lack of Affordable Housing Resources
 
The League’s comments highlight some areas of concern, which include the following:
  • The draft report disproportionately focuses on local government’s role in the planning, zoning, and permitting process, but fails to examine or acknowledge the fundamental private market forces that contribute greatly to housing production or lack thereof.
  • While some discussion of affordable housing resources is provided, surprisingly, the report makes no mention of how the elimination of redevelopment agencies in 2011 contributed to the loss of over $1 billion annually in affordable housing resources. Moreover, despite the scope of the described affordable housing crisis, the report conveys the Administration’s opposition to any expenditure of additional state General Fund dollars on affordable housing.
  • Concerns are also raised with several apparent conclusions presented in the report on the role of local government in the development of housing which lack sufficient supporting research and evidence.
  • Inconsistent messaging. Some areas of the report state that a one-size-fits-all approach to housing does not work in California because of the state’s diverse needs and markets. In other areas, however, the report advocates for top-down land use policies and changes that could affect all California cities. 
The League’s detailed comments are available on the League’s website for cities to review.
 
HCD Requests Public Comments by March 4
 
Cities are encouraged to carefully review the full report and provide written comments to HCD by Saturday, March 4. Comments and questions can be submitted via email to sha@hcd.ca.gov.
 
As part of the public process, HCD has scheduled several statewide housing assessment public workshops.
 
The workshops are scheduled as follows:
  • Fresno: Jan. 30 from 1-4:30 p.m.
  • Los Angeles: Feb. 3 1-4:30 p.m.
  • Sacramento: Feb. 6 1-4:30 p.m.
  • Redding: Feb. 24 1-4:30 p.m.
  • Bay Area: TBD 
Next Steps
 
All cities should review HCD’s report and consider providing written comments by March 4.
 
The League will continue to provide updates, host webinars, and solicit input throughout the year. Cities’ involvement is critical to maintaining local land use authority, public engagement, and transparency.


 
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