On Dec. 12, the San Diego City Council will hear the mayor’s Housing Action Package 2.0 again. While we support most of the HAP 2.0 proposals, the amendments proposed to the Complete Communities Housing Solutions program should not be approved because they further weaken already weak affordable housing requirements. Instead, the City Council needs to strengthen those requirements.
The Complete Communities program, approved three years ago, is a density bonus program, which allows generous increases in density in exchange for providing affordable homes for very low, low, or moderate income households.
The Complete Communities affordable housing requirement now in place – 40 percent – might seem incredibly high, but it is actually weaker than the city’s current inclusionary housing requirement of 8 percent. This is because the 40 percent requirement is based on the pre-bonus (existing) density of the parcel being developed. With inclusionary housing the required percentage is based on the total number of homes built. The result is fewer affordable homes are required by Complete Communities than would be required by the citywide inclusionary housing ordinance.
The reality of Complete Communities is generous increases in density and thus land value, but fewer affordable housing units. Given the boost in land value provided by Complete Communities, the affordable housing percentage required of developers should be higher — at least 15 percent of the total units.
Take for example, a new project being proposed in North University City, “4249 Nobel Drive” at the corner of Genesee Avenue and Nobel Drive. This project provides a clear and disturbing picture of the affordable housing failings of the Complete Communities program. This project would replace 108 existing apartments (29 dwelling units per acre on a 3.7-acre parcel) built in the mid-1970s with a 1,315-unit high-rise project (355 dwelling units per acre). Under the current Complete Communities regulations, the city would require the developer of the new project to provide only 45 affordable homes!
Thus, a project getting a 1,000+ percent density increase, more than 10 times the current density, and the financial windfall that comes with it, would have to provide only 3.4 percent of its units as affordable. If the current inclusionary housing requirement of 8 percent were applied, 106 affordable homes would be required.
This project exposes the huge weakness of the existing Complete Communities program, and the proposed amendments in HAP 2.0 will make things worse by further weakening the affordable housing requirements in two ways: First, by allowing affordable units to be built off-site in another community, likely in an area of lower socio-economic opportunity; and second, by allowing the developer to provide only moderate income housing (at 80 percent and 120 percent of Area Median Income (AMI) called the “100 percent moderate income option”) instead of very low, low, and moderate income housing (at 50 percent, 60 percent, and 120 percent AMI) as is now required. A family of four making $140,150 (120 percent AMI) a year would qualify for the moderate income units.
It is almost certain developers will opt for the moderate income only alternative, as they have done with the Accessory Dwelling Unit (ADU) Density Bonus program, resulting in Complete Community projects providing NO housing for lower income households making 50-60 percent AMI. Also, it is likely the affordable units will not be built as part of the project, but provided off-site in a different community with fewer amenities.
These problems with the current program and proposed amendments are important because our lower income residents are struggling with the cost of living, homelessness is growing, and naturally occurring affordable housing is being torn down and replaced by expensive new units. In fact, the apartments to be demolished by the project in North University City are some of the most affordable units in the area. Furthermore, the existing apartments are located in an area where 2/3 of the residents are people of color.
The Complete Communities changes run afoul of state housing element law, its Affirmatively Furthering Fair Housing (AFFH) requirements, the city’s statements in its housing element, the staff report for HAP 2.0, and the purpose and intent of Complete Communities.
As stated in the Municipal Code the CCHS Regulations: “…are intended to materially assist in providing adequate housing for all economic segments of the community; [and] to provide a balance of housing opportunities within the City of San Diego….”
Complete Communities can and should be used to take serious action on Affirmatively Furthering Fair Housing, to provide more affordable housing for very low and low income residents, and to help create more socio-economically balanced communities.
The city must strengthen the affordable housing requirements of Complete Communities to fulfill the program’s original intent. If we don’t, the affordable housing from this program will be minimal and concentrated in lower opportunity areas creating more socio-economic and racially imbalanced communities. Such concentration will lead to families being harmed by longer commutes, higher transportation costs, and lack of access to higher resource areas with better schools and jobs.
Complete Communities should be pulled from the HAP 2.0 package and sent back to the Planning Department to: 1) evaluate how the program is working now, and 2) create a program that results in complete, not incomplete, communities with robust, on-site affordable housing requirements.
Thanks for tackling our current fever with Housing Mania where giving away zoning increases to developers does not include sufficient truly affordable housing requirements.
Two other key things to remember: new housing is expensive housing and has nothing to do with helping the unhoused. And: Builders are not in the business of building enough to bring down housing prices.
Finally, there is no legal need to give away zoning increases for free! Yet there is always a political need in this town. And the giveaways have already been extremely generous (just one damaging note: defining down transit-proximity to 1 mile away when all studies show people walk a half-mile max – and this is the fed funding requirement for transit-oriented-development. Another: reducing public park requirements). This latest set of proposals is more evidence that planning is more politics than ever and actual urban planning is dead in the City of San Diego – sadly, when we need it most.
If the stated goal of increasing the number of units being built is indeed the goal, why not increase the allowable base density. This would result in a greater number of affordable units being required if the Complete Communities regulatory framework is utilized
45 affordable units? That’s a lot of smokers and people loitering outside all day because they don’t work or pay rent but always have money for cigarettes.
We should not be adding new barriers to constructing homes, we should be removing them. Adding new barriers to constructing homes will result in less homes being built. Less homes being built will result in higher home prices than we would otherwise see.
Typical YIMBY logic. We’ve seen no evidence that simply allowing developers to build more high-end or “market rate” housing has had any effect on housing prices. San Diego city hall politicians have been on an upzoning frenzy since 2017 and average housing prices just hit an all-time high.
If the inclusionary housing program was applied in the Nobel example, and the rule is actually 10% minimum (not 8%), you could only rebuild 108 total (at the 29 d.u./acre on a 3.7 acre site) with 10 of them being affordable units. Inclusionary does not allow any bonus units. 45 > 10.