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Solana Beach asks state to reconsider housing distribution methodology

SOLANA BEACH — Solana Beach is imploring the state to make a change to the region’s housing distribution methodology — which will require the nearly built-out, 3.4-square-mile coastal city to find space for 875 new units in the coming decade.

The city sent a letter to the state’s Department of Housing and Community Development (HCD) in late September, calling the approximately 160% increase in its allocated housing units “impracticable,” particularly given the fact that the city only has 3.3 acres of vacant land to build on.

HCD allocated nearly 172,000 units to San Diego County for the upcoming 2021-2019 housing cycle. On Sept. 6, the San Diego Association of Governments Board approved a methodology for distributing those units to the region’s 19 jurisdictions — a methodology that has left the region’s smaller cities reeling.

For example, Del Mar and Solana Beach — the smallest cities in the county — both saw their allocations increase more than double from the last cycle, compared to the overall regional increase of 6%. The larger coastal cities of Encinitas, Carlsbad and Oceanside all saw their allocations decrease.

The methodology awaits the final approval of HCD to be put into place.

Cities will need to use the resulting allocation to develop their housing elements — planning documents that show the state where and how cities plan to accommodate those units. All cities in the county are required to have HCD-certified housing elements by April 2021, to be in compliance with state law.

Solana Beach Mayor Dave Zito said the city’s general plan can technically accommodate the allocated units, but perhaps not in terms that HCD will actually approve — a must for the city to actually move forward with implementing the units.

“It’s not a function of whether it’s possible or not, it’s a function of what is OK with the community, and what HCD will require,” he said.

According to the city’s Community Development Director Joseph Lim, HCD prefers that housing elements focus on infill development — identifying vacant properties that are one to 10 acres in size.

“Well, we don’t have any,” said Lim, adding that Solana Beach’s largest vacant lot is just under one acre, and is privately owned. The average size of the city’s vacant parcels is .43 acres.

Lim said the city is hoping HCD will accept the inclusion of lots that are already developed — essentially the city’s only viable option. Such solutions would mean tearing down existing commercial sites, for example, and replacing them with mixed-use or residential developments.

Zito and others are worried that if HCD isn’t pleased with the city’s updated housing element, and it isn’t certified in time, Solana Beach may be left in a vulnerable position.

This could mean ending up in the same spot as Encinitas — which finally has a certified housing element for the current 2013-2021 cycle, years after the deadline. But the delay came at no small price to the city, which was sued several times for its lack of housing opportunities and eventually received a court order to develop a housing element within a 120-day deadline.

Zito said the lack of a certified housing element would not only expose the city to similar lawsuits, but cause Solana Beach to lose eligibility for most regional and state grants, including, for example, a relatively recent grant it received to revitalize Lomas Santa Fe Corridor.

“We wouldn’t be able to effectively compete for any of those grant funds anymore,” Zito said.

The city is facing demands from all sides — not only from HCD, but its residents and the California Coastal Commission — which has not been known to prioritize regional housing needs.

The letter reads that the allocation is inconsistent with the state’s Coastal Act — which is administered by the Coastal Commission — and would likely impede visitor access to the city’s beaches, bluffs and lagoon areas. Because the Coastal Commission must approve development projects in the coastal zone, any development that limits things like visitor parking spaces, for example, might prove problematic.

“ … The California Coastal Commission has been opposed to allowing cities to intensify residential uses over visitor-serving development,” the letter reads, adding that the Coastal Commission has “generally not (permitted) projects” that involve reduced parking standards, increased heights, greater restrictions on hospitality units and the intensification of coastal bluff areas.

The methodology developed by SANDAG puts a 65% weight on the presence of transit, and a 35% weight on job density. For Solana Beach, that means many of its units were allocated based on the presence of its train station — which, according to the letter, serves “a much wider geographic region and a greater commuter population than Solana Beach alone.”

In a comment submitted to SANDAG, former longtime City Councilwoman Lesa Heebner pointed out that The Coaster that runs through Solana Beach does not run often enough to allow people to discard their vehicles, nor does it serve as much of a draw based on the city’s lack of large “employment centers.”

“To those with the type of jobs we have in Solana Beach, the presence of a train station would not be an impetus to move here,” read Heebner’s comment.

Solana Beach is far from the only city struggling to come to terms with the numbers, with other small cities in the region, like Del Mar, also citing concerns about the methodology. At the Sept. 6 SANDAG meeting, Zito proposed an alternative motion that would have reduced the allocation to the region’s five smallest cities by 55%, redistributing the units to regions that have seen their allocations decrease since the last cycle.

The motion failed by one vote and did not gain the support of Del Mar and Lemon Grove — which were both taken to account by the motion.

Although Solana Beach has struggled to fulfill housing mandates in the past, affordable housing has posed a particular challenge. The city was allocated 340 units in its last cycle. As of late 2018, only 62 of those units have been issued building permits, and only six of those units were “affordable,” or in the low or very-low income categories.

For its next cycle, the city was allocated 334 very-low-income units, and 167 very-low-income units, based on a new equity adjustment that attempts to bring a greater diversity of housing types to the region’s cities.

The city has a few affordable housing projects currently on its plate but has often struggled to bring them to fruition due to the exorbitantly high cost of land in the area. For example, an approved project called the Pearl is anticipated to bring 10 affordable housing units to what is currently a city parking lot. But the project required a subsidy of $200,000 per unit to the developer.

And due to Coastal Commission requirements, the city needed to find a way to replace the parking spaces onsite, requiring the developer to build a structure to replace the parking that would be lost.

Said project is currently on hold due to financing difficulties.

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