Op-Ed: Housing Allocations Have to be Reasonable

Al Dugan writes to ABAG and the Novato City Council to prove Novato has done more than its share with the lowest-income levels of housing.

Editor's note: On July 10, Novato resident Al Dugan sent the following letter to Mark Luce, president of the Association of Bay Area Governments, and CC'd the members of the Novato City Council.

I am a resident of Novato and have lived in this city since 1983.  I got involved with the affordable housing issue last year when the city was looking at zoning changes and sites for more affordable housing.  I began to research the issue and was very surprised to find out what has occurred in Novato during the 1999–2006 housing cycle.

The state of California addresses the distribution of low and very low housing in an equitable manner in Government Code Section 65584(d).  This requires “Increasing the housing supply and the mix of housing types, tenure, and affordability in all cities and counties within the region in an equitable manner, which shall result in each jurisdiction receiving an allocation of units for low- and very low income households.” 

This was clearly not the case from 1999 to 2006.  Even though Novato is 20 percent of the population from 1999 to 2006 the city created 51.4 percent of the affordable housing in Marin County.  

The Association of Bay Area Governments report “A Place to Call Home: Housing in the San Francisco Bay Area 2007” provides a breakdown of affordable housing Regional Housing Needs Allocations and permits issued by cities in the county of Marin from 1999 to 2006. 

  1. RHNA allocated 1,241 Very Low Housing for Marin County.  A total of 528 permits were issued and 297 were from Novato, or 56 percent.  Five of the 11 cities in Marin (Belvedere, Corte Madera, Fairfax, Ross and San Anselmo) had no permits issued. Larkspur had 13 percent of their allocated goal, San Rafael had 6 percent and Tiburon had 15 percent.
  2. RHNA allocated 618 Low Housing for Marin County.  A total of 751 permits were issued and 527 were from Novato, or 85 percent.  Six of the 11 cities in Marin (Belvedere, Corte Madera, Fairfax, Ross, San Anselmo and Sausalito) had no permits issued.  Novato was allocated 242 Low Housing units and 527 permits were issued, or 218 percent more than allocated by RHNA. Larkspur had 21 percent of their allocated goal, San Rafael had 42 percent and Tiburon had 21 percent.
  3. RHNA allocated 1,726 Moderate Housing for Marin County.  A total of 1,040 permits were issued and 496 were from Novato, or 48 percent.  Six of the 11 cities in Marin (Corte Madera, Fairfax, Ross, San Anselmo, Sausalito and Tiburon) had no permits issued. Larkspur had 4 percent of their allocated goal, San Rafael had 69 percent and Mill Valley had 73 percent. 
  4. RHNA allocated 2,930 Above Moderate Housing for Marin County.  A total of 3,453 permits were issued and 1,646 were from Novato, or 48 percent. All 11 cities in Marin had permits issued. Novato was allocated 1,130 Above Moderate Housing units and 1,646 permits were issue or 146 percent more than allocated.

I do not believe the ABAG formula fairly evaluates past performance or properly reflects actual growth. I will address both of these issues:

  1. It does not appear the current ABAG formula evaluates past performances like Novato for very low and low affordable housing to be in compliance with Government Code Section 65584(d).  Can you please send me the actual calculation for Novato for the coming housing cycle and explain how it allows compliance given the past performance for very low and low affordable housing?
  2. The census data (www.bayareacensus.ca.gov) indicates Novato population from 2000-2010 grew from 47,630 to 51,904 which is an 8.97 percent growth and an increase of 4,274. The average household was 2.52 persons. The household growth was 1,755. In the 1999-2006 housing cycle, Novato built 2,966 affordable housing units. Thus Novato built 1,211 more affordable housing units than the TOTAL household increase in this time period. More importantly, to complete a comparison for 2000–2010 for affordable housing and households affordable housing in 1999 would have to be removed and the affordable housing built in 2007, 2008, 2009 and 2010 would have to be added, and I do not have this information.  Given one year would be removed and four years added, it is expected the 1,211 difference would be the minimum difference. (See attached worksheet.)  Adding the Minimum Housing Floor factor of 40 percent to Novato’s affordable housing calculation in the next cycle does not seem reasonable.

Reviewing this information outlined above, it is clear that the result of this distribution in Marin County resulted in Novato serving as the prime source of very low and low affordable housing, as well as all other affordable housing, for the other cities in Marin.  This concentration of affordable housing in Novato results in not less traffic but actually more traffic in Marin.  This requires people to commute from Novato to other Marin cities due to the lack of affordable housing in those other cities and is at odds with the goal of SB 375. This is also appears to be in violation of Government Code Section 65584(d).

It is essential that the ABAG RHNA allocations for Novato in the future cycles are reasonable and properly reflect past performance and local conditions.


Dave Robertson July 19, 2012 at 06:20 AM
I think it is more likely that we have a case of "clueless politicians and bureaucrats."
Al Dugan August 07, 2012 at 05:57 AM
For the record, I have not received a response from Mr.Luce of ABAG. Several Role asked me to let them know.
Al Dugan August 13, 2012 at 05:20 AM
I have still not received a response from Mr. Luce or anyone from ABAG. I am following up and will post the letter following up for a response.
Mark Burnham August 13, 2012 at 05:26 PM
novato will become the 1985 version of hill valley that marty mc fly returns to after biff gets ahold of the sports almanac. someone has to steal the almanac back from our city council.
Al Dugan September 04, 2012 at 02:14 AM
I had numerous people email me and ask i provide any response received from Mr. Luce, President of ABAG, or anyone from ABAG. Even after a followup I still have not received any response from ABAG or Mr. Luce. I believe this clearly indicates ABAG does not believe they own any citizen a response or that they care about the people and jurisdictions they are trying to top down plan based on the flawed SB 375 law. They have sent a clear message without any message.


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