State Sends Goleta a ‘Do It Again’ Letter on Housing

City Must Revise Housing Element or Risk Losing Local Control

Goleta Planning & Environment Review Director Peter Imhof. (December 3, 2019) | Credit: Paul Wellman (file)

California is pushing hard to add housing among its cities and counties, and Goleta recently received a letter stating its draft Housing Element submitted in June needed a re-do. This holds the potential for open development within the city without the protections of city permit rules, but only if Goleta misses the deadline to resubmit the report. Planning Director Peter Imhof said his planners were on track to get the augmented information through city approvals and to the state before the due date of February 15, 2023.

Back in June, Goleta officials were feeling pleased they’d submitted their Housing Element fairly early in the process. The 11-page letter they received in September from the Department of Housing and Community Development (HCD), however, listed many additional details that the state wanted. 

In Goleta’s case, the state was wary of “nonvacant” sites — lots with obsolete uses, like a long-vacant building, blighted areas, and other underutilized land — wanting to know more about “age of structures, size of lots, existing uses, environmental constraints, and further justification regarding the residential development potential,” Imhof explained. Other comments asked for details, for instance, about areas targeted for new housing: were they buildable, which developers expressed interest, and what are estimated construction costs?

Much of what the state requested was either technical or clerical in nature, said Imhof, or a call for “more robust City administrative efforts to encourage and facilitate housing development.” Though the council speaks of affordable housing during each development discussion and set a 20 percent affordability index for new developments, the state wanted specific details regarding recent housing approvals for “special needs populations,” like the elderly, people with disabilities, large households, female-headed households, farmworkers, and homeless persons.

In essence, Goleta must identify areas that will be zoned to hold 1,837 additional housing units between 2023 and 2031: 682 for very low income households, 324 for low, 370 moderate, and 461 above moderate. In the previous go-round, 2014-2022, the city’s allocation was 979. The county as a whole must zone for 24,856 new homes in this Regional Housing Needs Allocation cycle, numbers that underlie the Housing Element document.


Dozens of California cities and counties find themselves in the same limbo, receiving letters from the state that “revisions will be necessary” while only a handful of the letters express pleasure at finding the “adopted housing element in full compliance,” according to the information at the HCD website. In Santa Barbara County, Goleta and the City of Santa Barbara’s drafts are both out of compliance and have until February to correct the document, while Buellton is under review.

This has been a rough cycle, said Lisa Plowman, head of county planning, 191 of the 197 Southern California Association of Governments members failed to meet their deadline of October 15, 2021. That group includes Los Angeles, Imperial, San Bernardino, Ventura, Orange, and Riverside counties, and their cities.

The penalty is severe if a community fails to certify its Housing Element with the state. The Los Angeles Times recounted recently how Santa Monica could face 16 “builder’s remedy” developments of 4,562 new apartments, one of them 15 stories tall. All were filed during the year-long interval the city was out of compliance with state housing rules, and those that contain the 20 percent low-income housing target could be beyond some local rules — no environmental review, no discretionary review, and only objective standards might apply, advised Allen Bell, a supervising planner with the County of Santa Barbara — though Santa Monica is expected to fight the proposals.

According to Goleta’s Peter Imhof, a detailed response from the state was common for the Housing Element, which is heading into its sixth eight-year cycle. In anticipation, Goleta received a Regional Early Action Planning grant of $195,000 to support staff’s time on the Housing Element update.

Correction: In addition to Goleta, Santa Barbara city and Buellton have also submitted their draft Housing Element to the state.


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