Los Gatos’ residential housing plan is still not up to snuff yet, according to State reviewers.
While Campbell got good marks from the California Department of Housing and Community Development for its Housing Element back in March, Los Gatos’s draft of its housing document was rejected last week.
Chief among the concerns? The community failed to fully account for its segregated nature, according to a letter HCD sent to Los Gatos Community Development Department Director Joel Paulson on May 30.
Bay Area municipalities were supposed to have a completed Housing Element by the end of January.
Los Gatos adopted one on Jan. 30, but received a failing grade April 14.
Meanwhile, Los Gatos submitted a revised Housing Element, March 31, which is what HCD was responding to last Tuesday.
In its latest submission, Los Gatos tried to say it doesn’t have a “Racial Concentration of Affluence,” which the HCD found at-odds with reality.
“The Town is predominantly a high resource category according to (Tax Credit Allocation Committee) / HCD Opportunity Maps and is predominantly higher income,” the letter reads. “These patterns differ from the surrounding region and the element should include specific analysis of the Town compared to the region.”
In fact, the Sacramento-based agency says it wants to see the Town “formulate policies and programs”—above and beyond what’s already in the Housing Element—in order “to promote an inclusive community.”
In the letter, HCD tells Los Gatos to develop more “housing mobility” initiatives that help low-income families move to better neighborhoods.
The government did note that the Town updated its draft Housing Element to include the distance between public schools and transit, but says Los Gatos didn’t go far enough. They want the Town to examine this in terms of how easily people in at-risk groups can access transportation.
“In addition, it must also analyze any disproportionate transportation needs for members of protected classes,” reads the appendix to the letter sent by HCD Senior Program Manager Paul McDougall, which requests additional information about how locations designated for housing will fix historic segregation problems. “While the element was revised with brief conclusions that identified sites do not exacerbate fair housing conditions, it must also quantify the number of units by income group and location then evaluate the impact on socio-economic concentrations.”
Town Manager Laurel Prevetti responded to the rejection.
“The Town expected the letter from HCD to identify items for which the State is not yet satisfied, as is typical in the Housing Element review process,” she told the Los Gatan, Tuesday. “This is consistent with HCD’s letters to other jurisdictions requiring additional information and analysis. Some of the comments from HCD are inaccurate in that the Town’s Housing Element does contain the requested information. We are continuing to work with our HCD reviewer to have a Housing Element that satisfies the State.”
According to HCD, Los Gatos didn’t fully undertake a comprehensive reckoning of its history as a place that hasn’t been very welcoming to minorities.
“The element included some information about regional history, referenced stakeholder comments and discussed the location of assisted projects and housing choice vouchers. However, the element needs to provide information and analysis that relates, supports, or supplements the existing analysis, fair housing conclusions, or contributing factors,” the letter states. “The element must consider other relevant factors that have contributed to certain fair housing conditions. This analysis must consider information that is unique to the Town or region; such as governmental and nongovernmental actions; historical land use and zoning practices (e.g., past redlining/Greenlining, restrictive covenants, planning documents, etc.); disparities in investment to specific communities including transportation investments; seeking investment or lack thereof to promote affordability and inclusion; local initiatives, or other information that may have impeded housing choices and mobility.”
The problem, according to the State, isn’t that Los Gatos is completely unaware of the problem, but rather that the solutions the community has proposed “do not appear adequate” to foster “meaningful” change.
HCD says Los Gatos should have estimated the number of housing units that need to be renovated, for one, and it noted the Town failed to fix other defective areas it pointed out in January.
The State flagged the uncertainty around Development Review Committee decisions as another place the Housing Element could be improved; HCD also pointed to where the Town could do more to help people with disabilities.
One theme the letter writer kept coming back to was how Los Gatos didn’t make the grade when it came to what’s known as Affirmatively Furthering Fair Housing—that’s the concept that municipalities need to outline the serious actions they will take to overcome patterns of segregation.
“For example, the element must add significant and meaningful housing mobility actions to overcome the existing patterns in the Town related to the broader region,” the letter states. “Given, among other things, the Town is entirely in the highest category of disparities in access to opportunity and largely does not reflect the socio-economic characteristics of the broader region (the Housing Element) must include significant actions to promote housing mobility within the Town and relate to the region to promote an overall inclusive community.”
This analysis followed a May 10 conversation between HCD and Town officials.
Saratoga is also behind the eight ball on its Housing Element. It submitted a third draft to the State on May 30.
On June 15 at 7pm, Los Gatos’ Housing Element Advisory Board is set to discuss how to respond to HCD.
