The Coastal Housing Coalition has been advocating for workforce housing development on the South Coast for the past 20 years. To that end, the Coalition has been intimately involved in the County’s Housing Element Update – the process by which the county plans for the development of housing to meet our community’s needs. As the next step in this process, the County Board of Supervisors is set to consider which properties it should rezone for residential development in order to meet demand. In this letter sent to the supervisors, the Coalition explains why it is imperative that the county rezone all of the sites identified in its Housing Element to address our dire housing crisis.
I submit this letter on behalf of the Coastal Housing Coalition (“CHC”), a nonprofit organization that advocates for workforce housing. My board is made up of land use and housing experts—planners, architects, developers, realtors, and other professionals that have been advocating for more housing on the Central Coast for two decades. We believe that the lack of available workforce housing at all income levels near jobs is adversely affecting our region’s economy, environment, and civic life, all of which will worsen if you do not address this crucial problem.
We have participated throughout the Housing Element process by hosting educational sessions on the Housing Element, meeting with community stakeholders, and voicing our opinion at this Board’s rezone workshop. We submit this comment letter to continue to advocate for this Board to rezone all of the sites identified in the County’s Housing Element sites inventory. We explain the reasons supporting this position below.
The County Must Permit Development of Housing at Unprecedented Rates to Address the Housing Crisis Impacting Our Community
The jurisdictions within Santa Barbara County must plan for 24,856 housing units by 2031 to address the current housing crisis. The County is responsible for planning for a total of 5,664 units, 4,142 units in the South Coast and 1,522 units in North County. Ensuring our housing supply will meet our community’s needs requires unprecedented vision and planning.
The County’s failure to permit housing is no secret. California YIMBY commissioned a report in the fall of 2023 to estimate “a ‘conversion rate’ for each city and county [in the State] that compares historical rates of housing permitting to potential market-feasible housing development opportunities, assuming no limitations due to zoning.” (Housing Underproduction in California, https://cayimby.org/reports/housing- underproduction-in-california/.) The report found that the County has the seventh “lowest conversion rate of housing development opportunities” in the State. (Ibid.)
This history of underdevelopment has led to drastic impacts to our community. Median home prices (presently more than $2 million in the City of Santa Barbara) have more than doubled in nearly all jurisdictions since 2012, while vacancy rates have decreased 40 percent to 1.1 percent. These skyrocketing prices and lack of housing supply are shocking when compared to average median income—$107,300 for a family of four. This has led to a drastic decrease in the family aged population (30-49) in the County according to a recent report by the Santa Barbara County Association of Governments (“SBCAG”). (Understanding Regional Travel Patterns Report, https://www.sbcag.org/wpcontent/uploads/2024/01/UnderstandingRegionalTravelPatterns.pdf.)
These impacts do not just tear at the threads of our community; they degrade our environment. For example, SBCAG found that 30 percent of workers commuting to Santa Barbara (and 43 percent commuting to Goleta) travel greater than 16 miles. SBCAG also found that 11,100 people commute daily to the County from Ventura. Locating homes nears jobs and reducing these long commutes is a key way we can achieve our lofty climate goals, preserve our local economy, and support families.
Rezoning All Sites Does Not Mean All Sites Will Be Developed with Housing
Rezones alone do not produce housing and you must not assume that all the housing projects presented at the workshop or otherwise will come to fruition. Project level review of the selected rezone sites will likely identify additional regulatory, environmental, and physical constraints that will likely further restrict achievable unit density and affordability levels. Housing development traditionally occurs at an extremely slow rate due to the entitlement/permitting process, environmental review, fluctuation in access to capital, cost of construction and financing difficulties as well as long construction timelines.
Accordingly, when deciding on which sites to rezone, it is important to consider the low success rate for housing projects in this community. There needs to be an ample supply of property zoned for housing because the process to develop housing itself is naturally a multi-year endeavor with low success rates, as mentioned above. Even if a site has the proper zoning for housing, the process and associated timeline at providing a unit for occupancy would realistically be 7+ years based on the following assumptions:
Any number of delays could prolong the estimated timeline above causing further delays in producing the much-needed housing for our community. Maximizing the land available for housing needs your leadership now in order to have a fighting chance of seeing housing units available to serve our community by the end of this decade.
Rezoning Is a Critical First Step but Not a Comprehensive Policy Solution to Addressing Our Housing Needs
CHC is concerned the process the County has undertaken in the implementation of Program 1 in the Housing Element could have an unintended negative impact on local housing production. Specifically, at the January 9th Board hearing, the Board identified various criteria, including the provision of additional affordable units beyond local and state minimums, the provision of deed restricted moderate-income units, the provision of public park land, the inclusion of day care centers, and other criteria by which they would evaluate the proposed rezone sites. Understanding that these criteria are unenforceable for the properties they choose to rezone, the Board further requested property representatives to submit Letters of Intent to memorialize developers’ “offers” with respect to the Board’s rezone criteria.
State Laws explicitly require that any regulatory constraints to housing development be identified in the adopted Housing Element, and that an agency cannot establish policies or regulations that have the effect of reducing the number of housing units allowable on a site without equally offsetting those constraints within the jurisdiction. During this rezone process, the Board has essentially required that developers voluntarily, and perhaps prematurely, limit the number of housing units developable as a prerequisite to being selected for rezoning despite being included in its certified Housing Element.
CHC understands and is generally in alignment with the Board’s desire for more affordable and moderate- income housing, and the provision of public open space and neighborhood amenities to be interwoven into existing communities to maintain a high-quality of life as our region continues to evolve in the future. However, CHC takes issue with the approach the Board has adopted to attempt to compel developers to provide these benefits and the implied negative connotation of multifamily housing the Board is promoting in this policy discourse. Ultimately, we believe the rezoning of sites is only a small first step and short-term solution to solving the housing crisis at hand, and we remind the Board that Program 1 is only the first of 25 total programs the County has identified in its Housing Element to better facilitate housing development and achieve our local housing needs.
The County Should Focus on Policies to Incentivize Housing and Community Benefits
It is our strong belief that we must focus our collective efforts on creating policies and regulations to incentivize housing units, not develop additional ways to restrict their development (e.g., through arbitrary rezoning criteria). Therefore, in addition to rezoning all sites considered, we strongly recommend that the Board prioritize the following Housing Element programs as part of the 2024 budget cycle and departmental work plan.
Program descriptions from the County’s Housing element are attached to this letter for reference.
- Program 5: Tools and Incentives for High-Quality Affordable Housing
- Program 6: Housing for Farmworkers and Other Employees
- Program 13: Density Bonus Provisions
- Program 16: Reduction of Governmental Constraints
- Program 21: Local Preference
- Program 22: Recreational Amenities for Housing Projects
- Program 23: Workforce Housing Study
- Program 24: Rental Housing Incentive Program
Within each program description in the Housing Element, Staff suggests the types of policies and actions that will achieve the various goals. CHC is in alignment with many of these suggestions as we strongly believe focusing on creating the below policy solutions would be far more effective in achieving the Board’s goals. In this spirit, our organization is fully committed to helping research, draft, advocate for, and facilitate adoption of such policies in partnership with the County.
- A local density bonus ordinance amendment to provide equivalent or greater incentives and density bonuses for the provision of deed restricted moderate- and middle-income housing with inclusion of a local preference policy to ensure new housing units are affordable to and available to our local workforce.
- The reduction and/or waiver of parks fees and other incentives in exchange for the provision of public parks, open space, and community benefits within private developments
- The creation of an adaptive reuse ordinance to minimize physical and regulatory constraints and incentivize the rehabilitation of existing non-vacant commercial sites as housing.
- The amendment of our local ADU ordinance to allow the sale of newly constructed ADUs as established in recently adopted State legislation.
Similarly, the County must prioritize infrastructure improvements to accommodate our future housing needs as part of the Public Works budget and allocate funding accordingly in its upcoming Capital Improvement Plans.
Conclusion
Since our organization’s creation two decades ago, CHC has educated and advocated for workforce housing policies as being the most critical ingredient in achieving an economically, socially, and environmentally sustainable future for the South Coast of Santa Barbara County. When we began describing our region’s housing needs as a “crisis,” that was a novel concept. Today, however, the term housing crisis has become a household name and ubiquitous discussion topic across our region and state. Truthfully, that change has been validating, emboldening, and welcome as more and more people from all walks of life come to understand the important role that having available housing spanning the spectrum of affordability plays in the long-term vitality of our communities.
However, we still find that the negative connotations of housing and exclusionary housing ideals pervade in veiled pro-housing rhetoric— “we don’t need more housing, we need more affordable housing,” or, “increasing supply will induce more demand, therefore don’t build anything.” These arguments ignore the fundamental facts that the housing crisis is a statewide issue, that exclusionary local land use policies have caused severe long-term regional impacts and externalities, and the intrinsic responsibility that each and every jurisdiction has in collectively addressing this issue for our region and State’s future.
In this regard, a recent Court of Appeal decision regarding an associated State Housing Law (SB 10) was published (Aids Healthcare Foundation v. Bonta), in which the Court addressed many of these underlying arguments to oppose housing development and avoid compliance with the intent of the State Legislature. An excerpt from the Court’s brief is provided below:
“[W]e independently find a sufficient factual and policy basis for our Legislature’s repeated findings over the years that the issue of assuring an adequate supply of affordable housing is one of statewide or regional concern, even though it might appear to be a local issue at first blush. To begin, there is a direct link between the affordability of housing and the supply of housing. Under basic economic principles, prices go up when demand exceeds supply. Thus, the rise in housing prices at every income level in California is logically linked to the insufficient supply of housing at all of those income levels. What is more, the task of ensuring a great supply of housing is one that is logically handled at the state level. That is because local governments are susceptible to “not in my backyard” (or NIMBY) pressure: Local residents do not want to live near high density housing, so they elect local officials hostile to such housing or lobby heavily against such housing, figuring that some other local government will approve higher-density projects; because local governments would not address the housing shortage if left to their own devices, state intervention is sensible—if not outright necessary.“
We appreciate the County’s efforts to date and understand the Board’s goals with this process, but we would urge the Board members to take accountability for our housing needs not out of obligation, but as an opportunity to plan for the future of our local, regional, and statewide needs proactively and adequately.
Again, we recommend the County to rezone all these sites as a critical first step, and subsequently prioritize our collective efforts on the creation of facilitatory policies to incentivize the types of housing and community benefits most important to our local community. We look forward to our continued partnership and collaboration with the County, and the great opportunity ahead to plan for our community’s future.
For any questions regarding the Coalition’s position, please contact Craig Minus, executive director, at craig@coastalhousing.org.