ENCINITAS — Based on initial development proposals, sites that Encinitas told the state could support affordable housing will produce many fewer affordable units than projected, despite likely yielding more units overall.
“The applications received to date do not contain as many units at the lower-income level as projected, according to revised language in the city’s 2021-2029 Housing Element update draft. Though the proposals indicate “the sites are likely to yield more [total] units than projected.”
Local jurisdictions must periodically update, and the state must approve, the Housing Element (or chapter) of their General Plans. These updates mean to ensure cities’ land-use policies would reasonably enable private sector housing production to satisfy forecasted demand, affordably, at all incomes.
Encinitas’ current update — not yet approved, but in the works ahead of next spring’s deadline — will cover the period 2021 to 2029
The updated draft identifies 15 sites the city government reckons could support 1,504 lower-income units. The city more or less recycled this inventory from its previous Housing Element, which involved “upzoning” to allow higher residential density — a process culminating only last year, following a court battle and vocal resident opposition, which continues to simmer.
Carried forward into the present update, the site inventory’s upzoned capacity far exceeded the city’s requirement to plan for 838 lower-income units — a target assigned in last year’s Regional Housing Needs Assessment.
As a result, the city would enjoy what the Housing Element draft calls an “adequate buffer.” That is, even if projects produced fewer affordable units than forecasted, the buffer could absorb the shortfalls, up to a point.
But applicants have since put forward proposals for 7 sites, including only 227 of the 847 lower-income units the city estimated might go there — a 27% yield. Yet at the same time, including density bonuses, the applicants have proposed 1,453 units overall or 172% of forecasted capacity. That works out to 5.4 market-rate units for every affordable unit.
If projects continue falling far short of projections, eventually the city would deplete its buffer and fall into the red. Under the state’s “no net loss” provision, the city would need to make up the difference, probably (though not necessarily) by upzoning additional parcels.
“At some point in the [2021-2029] planning period, it is likely that ‘no net loss’ requirements will mandate that additional sites be designated for lower-income housing,” according to the revised Housing Element. However, “even if all of the applications [for the first 7 sites] are approved as currently proposed, the city’s lower-income inventory, including ADUs [accessory dwelling units], will remain at 974 units, [still] in excess of the 838 units required.”
The revised 974-unit forecast assumes the inventory’s remaining sites will yield their entire projected capacities as affordable units, though the empirical trend so far suggests otherwise.
Under state law “the sites are considered to be available and suitable for lower-income housing at their presumed capacity until or unless they are approved with fewer affordable units than projected,” city staffer Lillian Doherty told The Coast News.
Moreover, “it is also possible … that affordable lower-income housing may be constructed that is not listed in the city’s inventory and will provide additional capacity,” she said.
Rather than a plan that predictably risks additional upzoning, Encinitas City Council candidate Susan Turney and Planning Commissioner Bruce Ehlers say they’d prefer the city bolster its inclusionary housing policy.
Encinitas currently requires developers to make 10-15% of new residential projects affordable at lower incomes. Other California cities have stiffer inclusionary requirements, such as 25-30% (under certain circumstances) in Corte Madera and 15-25% in Davis.