March 31, 2021
Dear Friends and Aligned Organizations of AEL:
Come out of The River canyons and your gardens ON ARIL 8 AT 10:05 to speak to our Planning Commission and Board of Supervisors about enacting policy to make housing affordable to all and to stop the economic discrimination that suburban sprawl perpetuates.
THIS ACTION ALERT CONCERNS THE APRIL 8, 2021 PUBLIC HEARING ON THE PLACER COUNTY HOUSING ELEMENT UPDATE.
The Housing Element is the way local jurisdictions cause developers to build affordable housing within their “market rate” housing developments. OUR HOUSING ELEMENT PROMISES PROVIDE SAFE, DECENT AND SANITARY HOUSING TO ALL PLACER COUNTY RESIDENTS. The proposed Housing Element Update will not achieve this promise.
Housing costs have increased an astonishing 54% since COVID.. As you probably know, even before COVID, more than 87% of Placer County’s citizens had annual incomes of $76,000 or less – qualifying them for an affordable home – one that is priced $270,000 less than a market rate unit. Developers are required to price 10% of the homes in their developments to be “affordable”.
The County’s proposed Housing Element will allow developers to pay $2.00 PSF (about $6,000 for a 3,000 sq. ft. home), rather than build their legally required affordable housing units. Given the choice of paying $6,000 or pricing a home $270,000 less than the other 90% of the homes in subdivisions, what do think the developer will do?
Additionally, if developers bring in, say, a car dealership that employs 850 low wage workers, the County’s proposed Housing Element commits public funds to build housing for these workers – and does not assign the developer any responsibility to provide housing for workers and their families.
What is the point of spending millions of dollars on Placer County’s Housing Element when it is a hollow document? Government leadership is desperately needed as income-disparity grows and grows. We must enact a major policy shift to meet the housing needs of workers who are the heart of the economic engine of our County.
In no genuine policy sense, does this Housing Element Update: 1)redress decades of economic discrimination against working families and 2)stop consciousless profiteering by developers and 3) meet the housing needs of working people and families going forward.
ON APRIL 8, 2021, PLEASE COME TO THE PUBLIC HEARING AND TELL THE BOARD OF SUPERVISORS THAT THE HOUSING ELEMENT DOES NOT MEET OUR HOUSING NEEDS. IT WILL PERPETUATE HIGH COST SPRAWL FOR THE FEW AND DENY HOUSING OWNERSHIP OPPORTUNITY FOR THE MANY.
THE MEETING ANNOUNCEMENT AND LINKS TO THE HOUSING ELEMENT ARE BELOW.
WHERE: PLANNING COMMISSION HEARING ROOM
3091 COUNTY CENTER DRIVE, AUBURN, CA 95603
WHEN: APRIL 8, 2021 – 10:05 A.M.
SUBJECT: PLACER COUNTY 2021 HOUSING ELEMENT UPDATE
WHAT TO SAY:
TELL YOUR STORY. HOW MUCH OF YOUR ANNUAL INCOME DO YOU DEVOTE TO HOUSING? AN AFFORDABLE HOUSE IN ONE IN WHICH NO MORE THAN 30% OF YOUR INCOME GOES TO HOUSING.
COMMENT ON THE HOUSING CRISIS: HOUSING PRICES SINCE THE COVID OUTBREAK HAVE INCREASED 54%. BEFORE COVID, THERE WAS A $270,000 GAP BETWEEN WHAT 86% OF OUR COMMUNITY CAN AFFORD AND THE MEDIAN COST OF A NEW HOME IN PLACER COUNTY. SINCE COVID THAT GAP HAS GROWN FROM $270,000 TO $405,000! THAT MEANS MORE PROFIT FOR DEVELOPERS AND RELATORS – LESS HOUSING SECURITY FOR THE REST OF US.
TELL THE SUPERVISORS WHY THE HOUSING ELEMENT IS A “FAIL”: THE PROPOSED PLACER COUNTY HOUSING ELEMENT UPDATE WILL NOT CAUSE THE MORE THAN 6,000 AFFORDABLE OWNERSHIP UNITS THAT THE COUNTY IS DEFICIENT IN PRODUCING OVER THE PAST DECADES TO BE BUILT. NEITHER WILL IT CAUSE NEW HOUSING TO MEET THE REQUIRED STATE AFFORDABLE HOUSING ALLOCATION.
MOST IMPORTANTLY: IT WILL NOT MEET THE NEEDS OF EXISTING RESIDENTS. IT WILL NOT CAUSE DEVELOPERS TO PRODUCE MULTIFAMILY RENTAL HOUSING.
More:
THIS HOUSING ELEMENT UPDATE EXEMPTS MOST HOUSING DEVELOPERS* FROM PRODUCING ANY AFFORDABLE HOUSING AT ALL FAILS TO INCLUDE ADEQUATE INCENTIVES TO CAUSE BUILDERS TO REDEVELOP EXISTING INFILL PROPERTIES FOR HOUSING. IT SUPPORTS CLIMATE KILLING URBAN SPRAWL.
SPRAWL IS COSTLY TO BUILD. THE HOUSING ELEMENT AS PROPOSED PERPETUATES SPRAWL AS THE “STANDARD”. FOR REASONS OF HOUSING COST, HABITAT LOSS, AIR QUALITY AND CLIMATE CHANGE, SPRAWL MUST BE REPLACED BY SMART GROWTH AND REDEVELOPMENT. ONLY IN THIS WAY WILL WORKING PEOPLE HERE FIND HOMES THAT ARE AFFORDABLE TO THEM.
*1) DEVELOPMENT PROJECTS OF 100 UNITS OR LESS ARE EXEMPT FROM AFFORDABILITY REQUIREMENTS
2) DEVELOPERS CAN BUY THEIR WAY OUT OF PROVIDING ANY AFFORDABLE UNITS BY PAYING A “FEE” OF LESS THAN $6,000 PER HOME.
3) IF THE DEVELOPMENT IS A “SPECIFIC PLAN” (AS MOST SPRAWL HOUSING IS) AFFORDABLE UNITS MAY BE THE LAST BUILT, CONCENTRATED AND LOCATED IN THE WORST SITES.
NOTE: ONLY ONE HOUSING PROJECT IN THE PAST 5 YEARS HAS BEEN OVER 100 UNITS AND NOT A SPECIFIC PLAN.
BACKGROUND:
On their way to and from work, my dental hygienist and her boyfriend, a tug-boat captain, pass by thousands and thousands of new homes being built across our County. She told me yesterday, that though they save and save, they will never be able to own one of these homes.
The price of housing rises more quickly than they can save. Since COVID, the rate of price increase has is growing exponentially. My hygienist and her boyfriend, therefore believe that they will be perpetual renters. Because of this, they will not have children when they marry. She told me her of anxiety about this, is with her all the time.
I told her to think about what it would be like if new development in Placer County was priced to meet the needs of working people, like her? What if housing was located in a way that workers and students could access jobs, school and meet their needs without getting into cars? This “what is” requires leadership from our Supervisors to set policy directives that make it a reality. It also takes our Supervisors calling out developer profit.
We believe a fair return on investment is fair and we understand that the risk of project development has costs. But when is enough enough?
The Draft of Placer County’s Housing Element that has been written by a team of consultants perpetuates high cost sprawl and is derelict in its responsibility to Placer County’s working families. The Housing Element Update is not a strategic plan and vision to bring us to where we want to be – a place where people of all income levels can find high quality, safe, secure and affordable housing. It perpetuates policies that created today’s housing affordability crisis. As an example, Placer County consultants’ response to the public’s question as to why developments under 100 units are exempt from providing affordable housing choices was – “that’s what is done elsewhere”. That is not why a bad idea should be perpetuated.
AEL asked Placer County, and now we ask you, to consider systemic change in the way we serve our community’s need for housing.
Together we can make this happen. Please compel the County to undertake a big picture analysis of the deleterious effects of low-density sprawl on overall community and environmental well-being; as reflected in the housing-affordability crisis and our dangerously poor air-quality. (And then too, sprawl housing’s contribution to climate change. It’s the elephant in the room. With sprawl we lose the calculable ecosystem services provided by our carbon sequestering grasslands and forests). As conceived, the Placer County Housing Element Update fails its citizens and will not open the door to home-ownership to all – but will persist in constraining home-ownership to the privileged few.
The Housing Element Update also neglects the needs of citizens who will never achieve home ownership. Programs to measurably expand quantity and access to affordable rental housing are absent or insufficiently incentivised – as are programs to renovate our dilapidated stock of existing rental units.
Placer County is confronting two big problems that are interrelated. These are our air quality and our dearth of affordable housing. Both promise to deny Placer County residents a safe and healthy future. You may know that western Placer County’s is the fifth worst air quality region in the nation due to our auto dependent land use patterns and among Ca counties, we rank among the worst for provision of affordable housing.
Over the past two years, Placer County invited citizens to meetings, to provide written comments and to participate in public hearings on the Update of the Housing Element. We dutifully did this, but not one significant citizen suggestion was incorporated in the Draft Housing Element update – which is now being reviewed by the CA State Office of Housing and Community Development. In good faith, we exercised our civil rights; but were denied real, meaningful participation.
Nearly nine of every 10 people you interact with each day in Placer County qualifies for affordable housing; not because they are necessarily low income, but because the housing product that is available here is unaffordable to them. As was demonstrated in our Citizen Initiated Smart Growth Plan Phase 2, the median income for for a 4 person Placer County family is $76,100 annually. An affordable home (one for which no more than 30% of income must be dedicated to housing) for this same family is priced at $282,374. The average Placer County sale price for a home in 2018 was $570,000, an affordability of gap of $287,626. COVID has had an astonishing upward price impact on housing, so these stats. do not accurately reflect the current situation which is more dire.
The Regional Housing Needs Allocation (RHNA) sets out housing price benchmarks to ensure that every jurisdiction causes developers to produce housing for all income groups. Since 2013-2020, Placer County has enabled developers to build many thousands of homes and of them, only 7.2% (Placer County data) are priced for people with very low/extremely low, low and moderate incomes ($76,100 yr.). Under the Regional Housing Needs Allocation Placer developers built 99% of its ‘obligation’ for housing above moderate income households. As written, the Placer County Housing Element Update will allow this pattern of practice to continue.
The new Housing Element will cause only 132 units affordable units to be built each year. There is no provision for “making-up” for the 3,600 affordable units for which Placer is deficient since 2013.
Our recommendations include but are not limited to:
- Eliminate the 10% rule: Why do we institutionalize a rule that 10% of total units in developments are priced for 87% of our community? We need to turn this rule on its head and make 10% of the units affordable to the 13% that exceed moderate income. For decades developers have sold policy-makers on their “truth” that profit is not achievable if new housing is priced to meet community housing needs. As a result, the price homes to induces new growth – and does not meet residents’ needs. It begs the question – how do we define profitability? Profit for some is a 7% return on investment. Profit for others is a 228% return on investment (the American Institute of Architects identifies a 228% ROI as the development industries’ standard). Developers are among the wealthiest people in the world (Eli Broad, Kauffman and Broad Developers, a major developer in Placer County, is the 64th wealthiest person on the planet).
Reasons to eliminate the 10% rule:
1) The earning power of 87% of working families (2018) in Placer County is $76,100 or less. The 10% rule allows developers to build 90% of new homes for just 13% of our community (affordable is spending no more than 30% of income on housing).
2) Developers can avoid even the 10% affordable units responsibility by paying a small fee of $2.00 per square foot in-lieu of building the affordable home – even though the actual cost to build the home is $250-400 psf. The in-lieu fee is about $5,000. per home – certainly insufficient to allow the County to collect the fee and go out and build the home that the developer is derelict in producing.
The in-lieu fee should be eliminated or the”fee” should be the equivalent of the median sales price of the development seeking the exclusion and utilized only if the County has specifically identified a substitute home.
- Eliminate the Exclusion for Development Projects of 100 Units or Less: If the development is 100 units or less, there is no affordability requirement. In the past four years, only one project in Placer County has been both over 100 units and not a Specific Plan. So the affordability components of this Housing Element Update are being written for a tiny sliver of the total units produced in Placer County each year.
- Eliminate Housing Element Exclusions for Specific Plans: The General Plan is the County’s Master Plan document. It is implemented with Specific Plans. The Housing Element update allows Specific Plans to concentrate (not distribute them within the development) the required 10% affordable units and to locate the affordable units in the least desirable locations and on the sites that will be the last to be built. This is exactly what happened with the Placer Ranch Specific Plan project which was approved by the County in 2019. When this project was proposed to be part of the City of Roseville, it included 590 units of rental housing. When the County of Placer took the project on – the 590 units of rental housing disappeared and were replaced by single-family sprawl and high-priced condominiums. Ironically, the County of Placer is the “applicant’ for the Placer Ranch project. Additionally, Placer County citizens deeply subsidize the very same low-density sprawl homes that they cannot afford. The County has committed $17.8 m to subsidize infrastructure for the Placer Ranch project.
- Eliminate the In-Lieu Fee: Developers can buy their way out of building any affordable housing for only $2.00 per square foot under the proposed Housing Element Update. The average salels price of a home in Placer County in 2018 was $570,000. So you’re a developer and if you build an affordable home, you’ll have to sell it for $287,000 less than a conventional home. Or you pay an in-lieu fee of $2.00 psf ($5,500)+/-. What would you do? Developers have exercised the in-lieu option – allowing the County to accumulate $13 m; yet the County has not utilized those in-lieu funds to produce a single unit of affordable housing.
- Institute Workforce Housing-Commercial Nexus: Community members asked the County to include a nexus program to link new commercial projects approvals and housing for workers – priced to be affordable to future workers. The County deferred responsibility for workforce housing when it should be an integral part of this Housing Element Update. The Carvana project, which the County approved this year, will bring 850 low-wage workers to the County and Carvana developers have no responsibility, under the approved project, to provide housing to accommodate them.
Placer County’s website promises that Our Housing Element will ensure that decent, safe and affordable shelter is provided for all residents. The County Housing Element will not fulfill that promise. Please compel the County to undertake a big picture analysis of the deleterious effects of low-density sprawl on overall community and environmental well-being; as reflected in the housing-affordability crisis and our dangerously poor air-quality.
We hope to be active participants in the Governor’s Housing Affordability Task Force and respectfully requests that our comments, herein, be forwarded to the Task Force staff.
Sincerely,
Leslie Warren, Chair
Alliance for Environmental Leadership
This is the Hearing Notice
WHERE: PLANNING COMMISSION HEARING ROOM
3091 COUNTY CENTER DRIVE, AUBURN, CA 95603
WHEN: APRIL 8, 2021 – 10:05 A.M.
SUBJECT: PLACER COUNTY 2021 HOUSING ELEMENT UPDATE
GENERAL PLAN AMENDMENT (PLN20-00111)
ADDENDUM TO PREVIOUSLY ADOPTED NEGATIVE DECLARATION
ALL SUPERVISORIAL DISTRICTS
Notice is hereby given that the Placer County Planning Commission will conduct a public hearing, on the date and time noted above, to consider and make recommendations to the Board of Supervisors to adopt a resolution to amend the Placer County General Plan to update the Housing Element. The Placer County 2021 Housing Element is an update of the goals, policies, and implementation programs for the planning and development of housing throughout unincorporated Placer County. The amendments include modifications to the text and implementation programs as well as goals and policies. Adoption of the Housing Element will amend Section 2, Housing, of the Placer County General Plan adopted by the Board of Supervisors on May 21, 2013. The Planning Commission will also consider a recommendation to the Board of Supervisors to adopt an Addendum to a previously adopted Negative Declaration prepared pursuant to the California Environmental Quality Act. The Administration Division contact is Anne Marie Novotny, who can be reached at (530) 745-3170 or by email at amnovotny@placer.ca.gov.
Staff reports will be posted on the Planning Services Division web site referenced below by 5:00 PM, the Thursday prior to the scheduled hearing date.
https://www.placer.ca.gov/AgendaCenter/Planning-Commission-53
Administrative remedies must be exhausted prior to an action being initiated in a court of law. If the proposed project is challenged in court, one may be limited to those issues raised at the public hearing described in this notice or in written correspondence delivered prior to the public hearing. All letters, written materials, studies or reports, in excess of one (1) page should be delivered to the Planning Services Division, 3091 County Center Drive, Auburn, CA 95603, at least 24 hours or (1) business day prior to the beginning of the meeting as noticed above.
