Support evidence-based selection of sites in Berkeley's Housing Element!

Berkeley City Council

The 2023-2030 Housing Element is the next big opportunity for the City of Berkeley to allow for more housing and create a more affordable, more just city. The city is required by law to plan for 9,025 new housing units, including 1,441 low and 2,504 very-low income units, in the next eight years.

In previous Housing Element cycles, cities used various tricks to meet the letter of the law without guaranteeing that the required amount of housing would actually be built. In response, the state legislature added more stringent requirements to cut down on this abuse. As Berkeley starts preparing its 2023-2030 Housing Element, we are calling on the City Council and Planning Department to follow these new laws so that Berkeley's housing needs goals can actually be met.  

Sponsored by
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East Bay YIMBY
Oakland, CA

To: Berkeley City Council
From: [Your Name]

Dear Councilmembers:

As a resident of the Bay Area, I'm writing to you because I'm concerned about Berkeley's ability to successfully meet its share of regional housing need—9,025 units, including 1,441 low and 2,504 very-low income housing units—over the next eight years. Housing element law compels cities to make room for more housing and I ask that the City of Berkeley follow these laws rigorously and honestly. This will create a more affordable and just Berkeley in the decades to come, and set a positive example for other cities in the Bay Area to follow.

In particular, Berkeley City Council should direct planning staff to only include housing element sites that are realistic and likely to be redeveloped, or discount the capacity appropriately. The HCD manual requires "substantial evidence" that the current use on a nonvacant site will be discontinued for it to count as a low-income site. This means reaching out to the landowner and confirming that they intend to redevelop it. If it is a big-box store or successful business with no plans to redevelop, its capacity should be discounted accordingly.

The manual also recommends accounting for the likelihood that any site will be developed within the RHNA cycle based on development trends of housing element sites in the previous RHNA cycle. Los Angeles has done such a study, and San Francisco Planning plans to study this as well. The City of Sacramento also incorporated likelihoods of development in its realistic site capacities. Just as a university sends out many more acceptance letters than the number of seats they would like to fill in a freshman class, cities need to designate more sites in their site inventory than the RHNA target to account for the fact that not every site will be redeveloped in the next eight years. In the last RHNA cycle, one study found that only 9% of sites in the typical Bay Area city were actually developed; it was even lower for Berkeley, only about 2.5%. This suggests that Berkeley may need to zone for 10 times its RHNA target to actually meet its RHNA. We ask that Berkeley Planning perform a more precise study to find out exactly how much each site needs to be discounted.

For further information, please refer to these studies:
* California Department of Housing and Community Development, “Housing Element Site Inventory Guidebook”, https://www.hcd.ca.gov/community-development/housing-element/housing-element-memos/docs/sites_inventory_memo_final06102020.pdf
* Issi Romem and Samantha Wilkinson, "Creating a Stronger Housing Element: The Example of Los Angeles", https://planning.lacity.org/odocument/15117d38-35ca-416b-9980-25eb20201ba2/Appendix_4.6_-_Regression_Methodology.pdf
* City of Los Angeles, “Draft Housing Element 2021-2029: Appendix 4.6: Regression Methodology”, https://planning.lacity.org/odocument/15117d38-35ca-416b-9980-25eb20201ba2/Appendix_4.6_-_Regression_Methodology.pdf
* Sidharth Kapur, Salim Damerdji, Christopher S. Elmendorf, and Paavo Monkkonen, "What Gets Built on Sites That Cities "Make Available" for Housing?", https://escholarship.org/uc/item/6786z5j9
* City of Sacramento, “2021-2029 Housing Element: Sites Inventory Table”, https://www.cityofsacramento.org/-/media/Corporate/Files/CDD/Planning/Long-Range/Housing-Element/HCD-Table_SacHE_AdoptionDft_SitesInventory_Aug2021.xlsx?la=en
* MapCraft Inc., “LA County Housing Element Analysis”, https://drive.google.com/file/d/1jZJ-UuCpKZYnFWez5QuSsVlYmiDa-yzw/view
* MapCraft Inc., “Long Beach Housing Element Analysis”, https://drive.google.com/file/d/1zEUyyLGCLQoSgg9HpQ6Jp27I3VVKFXZ8/view

Thank you,