By Jorge Casuso

December 17, 2019 -- Unless the numbers change, there is little chance Santa Monica can lower its State-mandated target of building more than 9,000 new housing units -- more than two-thirds affordable -- over the next decade, experts say.

No longer can cities lower their targets by trading or transferring the units to other jurisdictions, accordng to the Southern California Association of Governments (SCAG), which sets the targets for the region.

And successfully appealing the draft Regional Housing Needs Assessment (RHNA) numbers SCAG will issue in April for its 197 jurisdictions has little likelihood of success.

The numbers, notes Mayor Kevin McKeown, have not been finalized.

"Any decision on appealing tentative numbers might be premature, pending final calculations and approval, but we very definitely provided feedback on the allocation strategy," McKeown said.

Santa Monica's housing target more than doubled -- from adding some 4,800 new housing units between 2021 and 2029 to adding 9,118 units -- after SCAG used an alternative methodology to determine the targets.

The new methodology shifted the buden from inland cities to those closer to the ocean and boosted the quotas for cities like Santa Monica "that have access to high quality transit, jobs, and a healthy development community," staff said.



City officials, McKeown said, have asked SCAG to give Santa Monica "credit for past housing production."

They also have asked for "more equitable consideration with respect to both existing and future transit, and more reasonable site analysis consideration as a built-out community with few remaining vacant parcels."

But there was no talk at the City Council's December 10 study session of filing an appeal ( December 13, 2019).

"If we don't do this, the State will do it for us," Councilmember Gleam Davis said. "It's coming whether we like it or not."

By the Numbers

To meet its target, Santa Monica -- which has a population of 93,556 -- must create a total of 9,118 units, of which 6,324 -- or 69 percent -- must be affordable.

Of those, 2,865 must be very low income, 1,714 must be low income and 1,745 must be moderate income. The rest -- 2,794 -- are market rate, a goal Santa Monica is expected to easily meet.

By comparison, according to an analysis of SCAG data by the Lookout:

Los Angeles, with a population of 3,933,766, has a target of 463,269 units, of which 263,721 -- or 57 percent -- must be affordable.





Culver City, with 40,108 residents, has a target of 3,395 housing units, of which 2,308 -- or 68 percent -- must be affordable.





West Hollywood, with 36,735 residents, has a target of 3,977 new housing units, of which 2,464 -- or 62 percent -- must be affordable.





Beverly Hills, with 34,662 residents, has a total target of 3,170, of which 2,338 units -- or 74 percent -- must be affordable.





Malibu, with 12,774 residents, has a total target of 78 units, of which 61 -- or 78 percent -- must be affordable.

Santa Monica's Housing Track Record

Unlike the region at large, Santa Monica has a record of meeting both its market-rate and affordable housing targets, said former Santa Monica Mayor Dennis Zane.

During SCAG's 5th planning cycle -- from 2013 to 2021 -- the region more than doubled its market rate target but only created 25 to 30 percent of its affordable housing goal.

By comparison, Santa Monica quadrupled its RHNA allocation, as well as exceeding its affordable housing target, with 38 percent of the total housing built being affordable.

"We’ve knocked it out of the park when it comes to both market-rate development and affordable housing," Zane told the Planning Report, a trade publication for regional planners.

"You won’t see any city in the state that has as effective of a housing development program," he said.

That the region exceeded its housing goals debunks the argument that slow-growth advocates are to blame for the regional housing crisis, Zane said.

"The shortage of supply because nimbies blocked development is complete bulls--t," Zane told the Lookout.

Instead California's housing crisis -- which has spurred the worst homeless crisis in the nation -- was triggered by the sudden influx of high tech jobs into the region.

Zane estimates that some "200,000 low-income households in LA County alone have been forced out as a by-product of the tech invasion."

But despite Santa Monica's track record building affordable housing, Zane believes SCAG is setting the bar too high this time.

"How do they expect anyone to meet it?" Zane told the Council.

Contesting the Numbers

A jurisdiction has un uphill battle if it chooses to contest its RHNA target, experts say.

"There isn’t an option to trade or transfer RHNA units to neighboring jurisdictions" as there was in the past, said Margaret de Larios, a spokesperson for SCAG.

"If a jurisdiction would like to reduce a draft RHNA allocation it would have to be in the context of filing an appeal."

Appeals can be filed within 45 days of SCAG's distribution of the draft RHNA allocation in April, according to SCAG's website.

"Appeals can be filed by a jurisdiction on their own RHNA number or any other jurisdiction in the SCAG region," de Larios said.

The California Department of Housing and Community Development can also file an appeal.

Appeals cannot be based on "voter-approved measures that restrict residential permits issued" or on "underproduction of units based on the prior RHNA allocation," according to SCAG's website.

They also cannot be based on "stable population numbers based on the last RHNA cycle."

Starting next summer, the RHNA Appeal Board (RHNA Subcommittee) will review all filed appeals and make determinations, de Larios said.

Units that are successfully appealed will be reallocated back to the region, she said.

"We will be developing the guidelines for appeals, which will eventually be reviewed by the Regional Council most likely in March," de Larios said.