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Home My WebLink About4425_CCv0001.pdf RESOLUTION NO. 4425 A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF REDLANDS APPEALING THE DATA PRESENTED IN THE REGIONAL HOUSING NEEDS ASSESSMENT FOR SOUTHERN CALIFORNIA, JUNE, 1988, AS PREPARED BY SOUTHERN CALIFORNIA ASSOCIATION OF GOVERNMENTS. WHEREAS, Government Code Section 65584 {c} provides that within 90 days following a determination of a council or government determination of the regional housing needs a local government may revise the regional housing needs in accordance with the considerations set forth in Section 65584; and WHEREAS, there is a 30 day review period under which a locality may request modification of its numbers with Housing and Community Development Department's approval; and WHEREAS, the City of Redlands has a growth control initiative, Measure N, approved by the voters in November , 1987 , which limits the number of dwelling units to 400 per year; and WHEREAS, the Regional Housing Needs Assessment for Southern California has not been adjusted to take into account Measure N and has identified a future need which exceeds the limits imposed by said voter initiative; and WHEREAS, State law as interpreted by the State Attorney General and legal counsel for SCAG prohibits consideration of Proposition R or Measure N, City of Redlands' voter approved initiatives, in the Regional Housing Needs Assessment; and WHEREAS, the Regional Housing Needs Assessment does not interrelate with the Regional Mobility Plan, Air Quality Management Plans, and Job/Housing Balance Plans, and this has resulted in higher housing requirements for Redlands than is equitable or desireable from a regional perspective, and WHEREAS, the City of Redlands has exceeded its housing goals for the preceeding five year period which now, instead of receiving a credit based upon formulas utilized by the Southern California Association of Governments, has resulted in a requirement for an increased share of housing units; NOW THEREFORE, BE IT RESOLVED that the City Council of the City of Redlands finds as follows: 1. That the numbers established in the Regional Housing Needs Assessment is not appropriate for the City of Redlands. 2. That the City of Redlands requests the Regional Housing Needs Assessment Future Needs category be adjusted to 2,000 over the next five year period. ADOPTED, SIGNED AND APPROVED this 20th day of September , 1988. Mayor of the City of Redlands ATTEST: Eity lerk I , Lorrie Poyzer, City Clerk , City of Redlands, hereby certify that the forgoing resolution was adopted by the City Council at a regular meeting thereof held on the 20th day of September 1988 , by the following vote: AYES: Councilmembers DeMirjyn , Johnson , Cunningham; Mayor Beswick NOES: None ABSENT: Councilmember Wormser - � R i City Jerk < bcc : Oji. 4F 1f914* C;I 1�- - r r4lrcp�- . September 27, 1988 Christine D. Reed , Director of State Department Of Housing And Community Development 921 Tenth Street Sacramento, CA 95814 Dear M, . Reed: The City of Redlands has appealed the Southern California Association of Governments ' determination of regional housing need and requested revision according to the Resolution . A copy of a attached letter to SLAG detailing the basis Of our appeal and revision request is also attached. Since State Housing Element Law is vague concerning procedure for a community to protest regional housing need determinations, please consider this letter notification of Redlands revision request in accordance with State Law Section 65584 (c) . Please also note that Redlands is protesting the lack of documentation of SCAG ' � requesting an extension of time to provide proadditi"ona! suNp()rt c ocur c!Itation for Z: re,. i on . Sincerely, Sohn Holmes �ity Manager JH/cvd Two (2) attachments 3�) C:AJON 51REE 1. P 0 BOX 2C)gr RFDLANDS. CA 9237' of I F914Ami \ Cil O LA IWKf TA .'^ f September 26, 1988 Mark. A. Pisano, Executive Director Southern California Association of Governments 600 South Commonwealth Avenue, Suite 1000 Los Angeles , CA 90005 Dear Mr . Pisano: Please consider this letter and attached resolution as notification that the City of Redlands does not agree with SCAG' s determination of regional housing need for the City of Redlands and requests ;revision . The basis of our appeal is both procedural and philosophical as outlined in the following points: 1. SCAG' s procedure for determining regional and sub- regional housing need shares has not been documented, making it impossible for local governments to ascertain correctness of calculations . As late as September 26, SCAG staff was unable to produce documentation of formulas used and calculations . For this reason alone, the review process should be extended a full 90 days from the date documentation is provided to Local Governments . 2 . SCAG 's methodology to determine regional and sub-regional projected housing need is inherently flawed because it is based on historical data biased with intra-regional transfers of demand . SCAG ' s method of determining future housing need relies on definitions which confuse housing need with housing demand . Those terms are undefined in Government Code Section 65584 (a) , which requires that, "The distribution of regional housing needs shall . . . . take into consideration market demand for housing . . . " The City of Redlands maintains that much of the Redlands housing need identified by SLAG based on historical trends is, in reality, the housing need of Orange and L.A. Counties transferred to Redlands because of the failure of those job-rich sub-regions to supply sufficient quantities of reasonable housing . Only a portion of the SCAG identified Redlands housing need will be actually generated in Redlands or its sub-region . 30 CAJON STREET. P.O. BOX 2090 6 REDLANDS, CA 92373 Mark A. Pisano Page 2 September 26 , 1588 Do L.A. and Orange Counties get credit for meeting future housing demand because they have historically transferred much of that demand to other stub-regions? By relying on historical trends to forecast future sub-regional needs , SLAG is acquiescing to the circularity that it professes to avoid . The concept of public welfare cannot be stretched to require cities to accept responsibility to meet housing demand that exists only because it has gone unmet within other sub-regions . 3 . SCAG' s future housing need projections are inconsistant with the growth management plan goal of achieving a jobs/housing balance. SLAG methodology depends on continuing existing trends modified by 20% to approach a regional jobs/housing balance over time. By encouraging cities to attain minimum housing levels based on an incremental (and arbitrary) percentage improvement towards jobs/housing balance, it is blocking more rapid improvement that may be made in communities with suffi- cient political will . The only defensible methodology to identify future regional housing needs is to identify housing levels at the jobs/housing balance point and set that level as the future housing share. To imply sanctions for communities which move more rapidly toward jobs/housing balance is counterproductive. To be rational, SCAG should be offering incentives to such communities . 4. Defining a community ' s fair share of projected housing at a level that is higher than necessary to achieve jobs/housing balance is contrary to the open- space element provisions of Government Code Section 65561 . The Legislature has found that discuraging premature and unnecessary conversion of open-space land to urban uses is a matter of public interest and general welfare. Mark A. Pisano Page 3 September 26, 1988 We recognize the difficult task SCAG has been given to pro- ject housing needs . We feel, however, that much more addi- tional analysis must be done. Please be assured that the City of Redlands is ready to identify and implement programs to provide a fair share of bona fled sub-regional housing need based on a defensible analysis of sub-regional demand . Sincerely, .. L hn Holmes ity Manager JH/cvd CC: Christine D . Reed, Director of State Department Of Housing And Community Development 921 Tenth Street Sacramento, CA 95814 Attachment: City Council Resolution