BILL ANALYSIS                                                                                                                                                                                                    Ó



                                                                  AB 679
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          ASSEMBLY THIRD READING
          AB 679 (Allen)
          As Amended  May 2, 2011
          Majority vote 

           HOUSING             4-0         LOCAL GOVERNMENT    6-0         
           
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          |Ayes:|Torres, Hueso, Jeffries,  |Ayes:|Smyth, Campos, Gordon,    |
          |     |Miller                    |     |Hueso, Knight, Norby      |
          |     |                          |     |                          |
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           SUMMARY  :  Allows the County of Napa (County), through October 
          31, 2022, to meet up to 15% of its share of the regional housing 
          need for lower-income households by committing funds for the 
          construction of affordable housing units within one or more 
          cities within the county, if various conditions are met.

           FISCAL EFFECT  :  None

           COMMENTS  :  Every local government in California is required to 
          prepare and adopt a housing element as part of its general plan. 
           The housing element process starts when the Department of 
          Housing and Community Development (HCD) determines the number of 
          new housing units a region is projected to need at all income 
          levels (very low-, low-, moderate-, and above-moderate income) 
          over the course of the next housing element planning period to 
          accommodate population growth and address existing deficiencies 
          in the housing supply.  This number is often referred to as the 
          regional housing needs assessment (RHNA) number.  The council of 
          government (COG) for the region, or HCD for areas with no COG, 
          then assigns every city and county in the region its fair share 
          of the RHNA based on a variety of factors.  The law requires 
          that every jurisdiction receive a share of the RHNA for low- and 
          very low-income households.

          In preparing its housing element, a city or county must show how 
          it plans to accommodate its share of the RHNA.  The housing 
          element must include an inventory of sites already zoned for 
          housing.  If a jurisdiction does not have enough sites within 
          its existing inventory of residentially zoned land to 
          accommodate its entire RHNA, then it must adopt a program to 
          rezone enough land within the first three years of the planning 
          period.  Cities and counties are required to demonstrate that 








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          sites are adequate to accommodate housing for each income group 
          based on the zoning after taking into consideration individual 
          site factors such as property size, existing uses, environmental 
          constraints, and economic constraints.  

          Under current law, counties can transfer a portion of their 
          share of the regional housing need to a city within the county 
          if the city agrees to take on the additional allocation.  In 
          implementing such a transfer, a 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.  The proportionality 
          requirement is consistent with the overall goal of housing 
          element law to ensure that every jurisdiction plans for housing 
          across all income levels and serves to ensure that a county does 
          not pursue transfers simply as a way to remove its obligation to 
          plan for affordable housing. 

          In 1996, Napa County successfully pursued legislation (AB 3452 
          (V. Brown), Chapter 1018, Statutes of 1996) to allow the County 
          to transfer a portion of its lower-income RHNA without a 
          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 the 
          statutory language include 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. 

          The County's special transfer authority was extended in 2000 (AB 
          2430 (Wiggins), Chapter 358, Statutes of 2000), allowing the 
          County to pursue non-proportional transfers through June 30, 
          2007.  AB 2430 (Wiggins) also placed additional conditions on 
          the transfers, including that the number of units transferred 
          could not exceed 40% of the number of lower-income units built 
          in the unincorporated area during the 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 
          2007.  Both of the bills regarding the County's special transfer 
          authority pre-dated the law that allows counties to pursue 








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          transfers but only if the transfer is proportional across income 
          categories.
           
           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 disagreed with 
          HCD and adopted the housing element despite HCD's position that 
          it was not in compliance with the law.  The County was 
          subsequently sued by Latinos Unidos, a farmworker advocacy 
          group.  That suit is currently being litigated.  The County's 
          next housing element is due in October 2014.

          Napa County has a sizable affordable housing trust fund that is 
          capitalized through fees on development in the unincorporated 
          area.  The County has spent over $21 million from this trust 
          fund since 1989, almost entirely on projects within the City of 
          Napa (City).  For many of these projects, the County was not 
          able to get full "credit" towards meeting its RHNA obligations.  
          For example, the County has recently provided funding for two 
          projects within the City with a total of 104 units of low- and 
          very low-income housing.  However, because of the 
          proportionality requirement, the County is not able to transfer 
          104 units worth of its lower-income RHNA share to the City 
          because the City is not willing to absorb a proportional amount 
          of the County's moderate- and above-moderate income RHNA. 

          This bill places a new sunset date of October 31, 2022, on Napa 
          County's special non-proportional transfer authority.  The new 
          sunset date is the end of the County's next housing element 
          planning period.  The bill also makes a minor change to the 
          statute by deleting a requirement that the City that receives 
          the transfer 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.  The 
          bill leaves intact the various checks and balances that ensure 
          that the County can only do non-proportional transfers if 
          affordable housing is also being developed in the unincorporated 
          area of the County, and only if the County adopts a housing 
          element that HCD finds is in compliance with the requirements of 
          the law. 










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           Analysis Prepared by  :    Anya Lawler / H. & C.D. / (916) 
          319-2085 


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