How housing became a numbers game
Change is coming to west county as supervisors rezone for high-density development
The Board of Supervisors approved the housing element of the county’s general plan last week. While that might sound rather boring and bureaucratic, it has the potential to bring radical changes to small, unincorporated towns throughout Sonoma County, including west county burgs like Graton and Forestville.
That’s because Sonoma County is being required by the state to facilitate the creation of 3,824 new homes in unincorporated parts of the county over the next eight years (2023 to 2031).
In comparison, during the last housing element cycle (2015-2023), the county was required to facilitate the building of only 515 homes.
“The state gave us a massive mandate, increasing our housing target sevenfold since our last Housing Element update eight years ago,” said Supervisor Chris Coursey, chair of the Sonoma County Board of Supervisors.
The county appealed this mandate to the California Department of Housing and Community Development, arguing for city-centered growth, but its appeal was denied.
Second District Supervisor David Rabbitt tried to put the task the county faces in perspective. Speaking of the target of 3,824 homes over the next eight years, he said “It's 1.3 units per day for eight years” he said. “Think about that.”
Daunting indeed, but it’s a little less so when you realize that 52% of those 3,824 homes are already in process: developers have already filed for permits or are in the construction phase.
Regardless, in the service of hitting its state-mandated housing goals, the board of supervisors rezoned dozens of properties around the county—many to high-density residential (R3 20), which will allow developers to build up to 20 units per acre.
Several such properties were rezoned in Graton, Forestville and Guerneville. (See the list at the end of this article.)
“At its core, the housing element is about how we can provide for housing,” said Bradley Dunn, a policy analyst for Sonoma County. “In Sonoma County, housing is obviously a really pressing issue. We hear about how hard it is to find affordable housing every day. The housing element rezones properties, including in West County…to meet the needs of our workforce and make sure that we’re providing the housing that is critical to making Sonoma County a great place to live.”
The reign of RHNA. Or, where do these numbers come from?
That 3,824 housing target is what’s known as a RHNA number; RHNA (rhymes with Tina) stands for Regional Housing Needs Allocation.
How does that number get determined? It starts with the state government. The California Department of Housing and Community Development determines the total number of homes that each region in California must plan for in order to meet the housing needs of people across the income spectrum. It passes that number down to a regional authority—in our case, ABAG (the Association of Bay Area Governments), which then divvies up that number among all cities, towns and counties in that region.
Jurisdictions have to show that they intend to facilitate the building of homes across the economic spectrum. Of the 3,824 homes that Sonoma County is required to see built in its unincorporated areas, 1,024 must be for very low income, 584 for low income, 627 for moderate income, and 1,589 for above-moderate income. (Cities within Sonoma County have their own RHNA targets to hit; Sebastopol is expected to facilitate the building of 213 housing units over the next eight years.)
And it gets even more complicated. In order to stop local governments from dumping all low-income housing in poor neighborhoods, the state required the county to come up with a map designating different parts of the county as high-, medium-, and low-resource areas, referring to economic, educational, and environmental indicators. The county must show the state that it is putting low-income housing in high- and moderate-resource areas. (Graton, Forestville and Guerneville are considered moderate-resource areas.)
“There are state regulations called Affirmatively Furthering Fair Housing, which is a process by which we are not able to dump all of our low- and moderate-income housing into low-income and low-resource communities and communities of color,” Dunn said. “It is incredibly important, both from a legal perspective, but also from and moral and ethical perspective that we are putting low- and moderate-income housing in higher-resource areas because that gives people access to resources.”
Rising consequences
Although the state has had housing targets for local governments for many years, those targets didn’t have teeth until recently.
“The state has really changed the way they approach housing elements,” Dunn said. “So now there are a lot more consequences…there’s more accountability built into how housing elements are being judged. So you can’t just say, ‘Oh yeah, housing can go here’ and just never build any housing.”
The state has put two big sticks in place to ensure that local governments comply with their housing targets.
The first is the so-called Builder’s Remedy, which is a provision of California's Housing Accountability Act, an old law that has recently been reinterpreted to give builders leverage over local governments that don’t have certified a housing element in place. The Builder’s Remedy effectively prevents local governments from denying housing projects, even when those projects don’t comply with local planning regulations.
Sonoma County was supposed to have submitted their housing element to the state back in January. It missed that deadline. As a result, nine Builder’s Remedy projects have been applied for throughout the county, including one in Graton, where a local developer wants to put an RV park for very-low- and low-income residents at the corner of Graton Road and 116.
The other bully club in the state’s enforcement toolkit is the ability to withhold state and federal funds from local governments that don’t get their Housing Elements in on time.
“The other thing is you also lose out on the ability to apply for or receive certain grant funding for things like affordable housing, and the county obviously relies on funding from the state for a lot of its housing programs…So basically getting a certified housing element is really important,” Dunn said.
Verbiage, hard targets, and a barrage of comments
Sonoma County’s Housing Element, which is put together by the county’s planning department and its consultants after extensive public outreach, consists of two parts: A policy section and site index.
The policy section talks about the policies the county has in place and what the county is doing to encourage more (and more affordable) housing.
The site index is where the rubber meets the road. This is a list of developable properties that could be used to meet the RHNA numbers.
And as you might expect, the site index is what had neighbors up in arms. At the supervisors meeting, dozens of commenters lined up at the microphone to express their displeasure at the inclusion of various properties around the county.
Commenters from Graton and Forestville had several complaints about the properties slated for high-density development in their communities. These ranged from serious issues like the lack of water in Graton, where most people are on wells, to a lack of egress on narrow roads in case of evacuation. There were a few NIMBY-ish complaints of the “I moved here for peace and quiet” variety as well.
Fifth District Supervisor Lynda Hopkins defended the commenters from the charge of NIMBYism, however.
“I don’t see this as a kind of NIMBYism conversation,” she said. “This is a planning conversation. Communities have been stripped of their ability to plan. They don't have the infrastructure. They do have carrying capacity concerns.”
She apologized to the people who came to give public comment.
“I'm sorry for how broken the process is...To me, this is the opposite of what government should be…I believe you when you say you want affordable housing, because that's what I hear when I go into communities, but you want to be able to have a community conversation and say, ‘Hey, here’s where affordable housing should go. And by the way, here’s where we need sidewalks and a park and improvements to our schools to actually make the support infrastructure investments that we need in order to accommodate additional housing’—because that's what I hear from West County. And I do believe you. I do not think this is just a NIMBY thing.”
Hopkins, alone among the supervisors, engaged in a little last-minute horse-trading with the planning staff, striking one of the Forestville sites as unsafe due to lack of egress and adding back half of another property near the proposed Forestville skate park. She apologized to commenters from Graton that she couldn't give them a similar remedy, but the planning staff said that rejiggering the Graton properties on the fly during the meeting was not possible.
Some speakers expressed the hope that the county could make up more of its numbers in more urbanized areas of the county. During public comment, Eric Koenigshofer, who is the Fifth District representative to the Planning Commission, suggested that the county look to areas with more robust infrastructure to fulfill its RHNA numbers.
“With regards to where the county government itself can most effectively engage in infill, the county center and the airport area are two biggest opportunities you have,” he said. “Both need to be looked at very, very hard.”
Now that the Board of Supervisors has approved the Housing Element, the document will be sent back to the Department of Housing and Community Development for certification—a process that can take up to three months.
Watch the supervisors’ discussion of the Housing Element and hear community comments here. Find the final draft version of the housing element and its many appendices here.
List of Properties from Site Index (Appendix D) of the Housing Element
GRATON
GRA-1 9001 Donald Street (Rezoned R3-20)
GRA-3 3155 Frei Road (Rezoned R3-20)
GRA-5 8525 Graton Road (Rezoned R3-20)
FORESTVILLE
FOR-1 6555 Covey Road (Rezoned R3-20)
FOR-3 6194 Forestville Street (Rezoned R3-20)
FOR-6 6250 Forestville Street (Rezoned R3-20)
GUERNEVILLE
GUE-4 16050 Laughlin Road (Rezoned R3-20)
Thanks for covering this. The big story, for Gratonites, is Two Crows Development and their Builder's Remedy Permit application to put in either 40 tiny homes or trailers in a 1.9 acre lot at the corner of Graton Rd and 116. Other than the traffic and access problems, the big one is there is no municipal water in Graton. . .the water for 80 new residents would have to come from the same shrinking water table the residents all share. You might want to contact us and do another story.
While this appears to be pretty much a copy of the article that appeared in the Press Democrat last week, thanks for giving it another airing. One way you could have embellished it for West County rteaders is to point out the specific locations for the Forestville-Guerneville proposals. While the necessity to use groundwater seems to be a negative for the Graton trailer park, I'd rather see ground water going to residents (as it already does for those of us in Sebastopol) than vineyards.