BILL ANALYSIS                                                                                                                                                                                                    Ó



                                                                  AB 679
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          Date of Hearing:  May 11, 2011

                       ASSEMBLY COMMITTEE ON LOCAL GOVERNMENT
                                Cameron Smyth, Chair
                      AB 679 (Allen) - As Amended:  May 2, 2011
           
          SUBJECT  :  Land use: housing element

           SUMMARY  :  Allows Napa County, until October 31, 2022, to meet up 
          to 15% of its existing share of the regional housing need for 
          lower-income households by committing funds for the construction 
          of affordable housing units, and constructing those units in one 
          or more cities within the county, if specified conditions are 
          met.

           EXISTING LAW  :
           
           1)Allows a county to transfer a portion of its share of the 
            regional housing need to a city or cities within the county 
            that agree to the transfer, but stipulates that county's share 
            of low- and very low-income housing can be reduced only in 
            proportion to the amount by which the county's share of 
            moderate- and above moderate-income housing is reduced.

          2)Until June, 2007, allowed Napa County to meet up to 15% of its 
            existing share of the regional housing need for lower-income 
            households by committing funds for the purpose of constructing 
            affordable housing units, and constructing those units in one 
            or more cities with the county, only after all of the 
            following conditions were met:

             a)   An agreement was executed between the county and the 
               receiving city or cities, following a public hearing held 
               by the county and the receiving city or cities to solicit 
               public comments on the draft agreement.  The agreement must 
               contain:

               i)     A plan and schedule for timely construction of 
                 dwelling units;

               ii)    Site identification by street address for the units 
                 to be developed; 

               iii)   A statement either that the sites upon which the 
                 units will be developed were identified in the receiving 








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                 city's housing element as potential sites for the 
                 development of housing for lower-income households, or 
                 that the units will be developed on previously 
                 unidentified sites; and,

               iv)    The number and percentage of the county's 
                 lower-income housing needs previously transferred.

             b)   The council of governments (COG) that assigned the 
               county's share receives and approves each proposed 
               agreement to meet a portion of the county's fair share 
               housing allocation within one or more of the cities within 
               the county;

             c)   The city or cities in which the units are developed 
               agreed not to count the units towards their share of the 
               region's affordable housing need.

             d)   The county and the receiving city or cities, based on 
               substantial evidence on the record, make the following 
               findings:

               i)     Adequate sites with appropriate zoning exist in the 
                 receiving city or cities to accommodate the units to be 
                 developed;

               ii)    If needed, additional subsidy or financing for the 
                 construction of the units is available;

               iii)   The receiving city or cities have housing elements 
                 that have been found by the Department of Housing and 
                 Community Development (HCD) to be in compliance.

             e)   If the sites upon which units are to be developed were 
               previously identified in the receiving city's housing 
               element as potential sites, then the receiving city must 
               amend its housing element to identify replacement sites, as 
               specified;

             f)   The county and receiving city or cities must complete 
               the annual report and provide to HCD;

             g)   For a period of five years after a transfer occurs, 
               requires the report to include information on the status of 
               transferred units, implementation of the terms and 








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               conditions of the transfer agreement, and information on 
               any dwelling units actually constructed, including the 
               number, type, location, and affordability requirements.

             h)   Provides that the receiving city must demonstrate that 
               it has met, in the current or previous housing element 
               cycle, at least 20% of its share of the regional need for 
               housing for very low-income households allocated to the 
               city.

             i)   Provides that the credit that the county receives shall 
               not exceed 40% of the number of units that are affordable 
               to lower-income households and constructed and occupied 
               during the same housing element cycle in unincorporated 
               areas of the county, as specified.

             j)   Provides that HCD, concurrent with review by the COG, 
               must evaluate the agreement to determine whether the city 
               or cities are in substantial compliance.

           FISCAL EFFECT  :  None

           COMMENTS  :   

          1)In 1996, Napa County successfully pursued legislation ƯAB 3452 
            (V. Brown), Chapter 1018, Statues of 1996] to allow the county 
            to transfer a portion of its lower-income regional housing 
            needs assessment (RHNA) without having to follow the 
            proportionality requirement if it provided funding to ensure 
            that the units got built within the city that accepted the 
            transfer.  Such transfers were limited to 15% of the county's 
            total share of the RHNA for lower-income households and 
            included a sunset date of June 30, 2004.  At the time, the 
            county argued that there were a variety of unique 
            circumstances in Napa County that made affordable housing 
            development difficult within the unincorporated area, 
            including a voter-approved measure designed to protect the 
            county's valuable agricultural land. 
          2)Napa County's special transfer authority was extended in 2000 
            by AB 2430 (Wiggins), Chapter 358, Statutes of 2000, which 
            allowed the county to pursue non-proportional transfers 
            through June of 2007.  AB 2430 also placed additional 
            conditions on the transfers, including limiting the number of 
            units transferred to not exceed 40% of the number of 
            lower-income units built in the unincorporated area during the 








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            same planning period.  In other words, for every one unit 
            transferred, the county would have to show that 2.5 units were 
            built in the unincorporated area. The extension of the 
            transfer authority expired in June 30, 2007.

          3)This bill re-enacts certain provisions of the Napa-specific 
            transfer statute that would allow the county to transfer 15% 
            of its lower-income RHNA to cities within the county without 
            having to transfer at the higher income levels if it provides 
            funds to build the units. The provisions of re-enactment 
            language will sunset on October 31, 2022.  As well, this bill 
            deletes the requirement that the receiving city demonstrates 
            that it has met, in the current or previous housing element 
            cycle, at least 20% of its share of the regional need for 
            housing for very low-income households allocated to the city, 
            which was included in the previous version transfer statute.  

            This bill contains a variety of checks and balances to ensure 
            that Napa County is also pursuing affordable housing 
            development in the unincorporated area at the same time that 
            it is funding affordable housing development within cities.  

          4)Napa County's last housing element was due in June of 2009.  
            HCD's review of the draft element found that it was not in 
            compliance with the law, primarily because HCD did not believe 
            that the county had identified adequate sites to support the 
            development of affordable housing.  The county had included a 
            number of sites in its housing element at below the default 
            density of 20 units per acre, and HCD did not believe the 
            county's analysis of those sites was enough to establish their 
            adequacy. The county disagrees with HCD's position and 
            believes that it provided all of the analysis that the law 
            requires. The county adopted the housing element despite HCD's 
            finding that it was not in compliance with the law and was 
            subsequently sued by Latinos Unidos, a farmworker advocacy 
            group. That suit is currently being litigated.
             
           5)Napa County has a sizable affordable housing trust fund that 
            is capitalized through fees on development in the county.  The 
            county has spent over $21 million from this trust fund since 
            1989, almost entirely on projects within the City of Napa.  
            For many of these projects, the county was not able to get 
            "credit" towards meeting its RHNA obligations.  For example, 
            the county has recently providing funding for two projects 
            within the City of Napa with a total of 104 units of low- and 








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            very low-income housing.  However, because of the 
            proportionality requirement, Napa County is not able to 
            transfer 104 units worth of its lower-income RHNA share to the 
            city.

          6)Napa County's next housing element update is due in October, 
            2014.  Prior to that update, the county is seeking legislation 
            that it believes would make it easier for the county to 
            produce a housing element that complies with state law.  This 
            bill is one of two bills that Napa County is sponsoring to 
            provide more flexibility. This Committee previously heard 
          AB 542 (Allen) on April 6, 2011, which passed on a 9-0 vote and 
            was subsequently amended in the Housing Committee.


          7)Support arguments:  This bill allows Napa County to meet up to 
            15% of its existing share 
          of the regional housing need for lower-income households by 
            committing funds for the construction of affordable housing 
            units, and constructing those units in one or more cities 
            within the county.  These provisions allow flexibility for 
            Napa County in meeting requirements for affordable housing 
            given the variety of unique circumstances in the County.

            Opposition arguments:  Opponents, including the California 
            Rural Legal Assistance Foundation and the Western Center on 
            Law and Poverty, argue that AB 679 would undo protections that 
            ensure that a county cannot simply shift its obligations to 
            plan for low-income households to another jurisdiction.  They 
            argue that requirements in current law exist to ensure that 
            the fair share provisions of RHNA are maintained and that 
            every jurisdiction is planning for the housing needs of all 
            income groups. 

          8)This bill was heard by the Assembly Housing and Community 
            Development Committee on April 27, 2011, where it passed on a 
            4-0 vote, with amendments.  

           REGISTERED SUPPORT / OPPOSITION  :   

           Support 
           
          County of Napa

           Opposition 








                                                                 AB 679
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          California Rural Legal Assistance Foundation
          Western Center on Law and Poverty

           
          Analysis Prepared by  :    Debbie Michel / L. GOV. / (916) 
          319-3958