BILL ANALYSIS                                                                                                                                                                                                    

SB 948   04/05/99                                      Page 

                               
       SENATE HOUSING & COMMUNITY DEVELOPMENT COMMITTEE
              Senator Richard Alarcon, Chairman



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|BILL NO:SB 948                        |HEARING: 4/5/99         |
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|AUTHOR:  Alarcon                      |FISCAL:Appropriations   |
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|VERSION: 4/5/99                       |CONSULTANT:   Stivers   |
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                     AFFORDABLE HOUSING

  Background, Existing Law, and Proposed Law  

This bill contains four distinct elements:  

  I.   Housing element challenges  .  Each city and county must  
prepare and adopt a general plan to guide the future growth  
of the community.  Every general plan must contain seven  
elements:  land use, circulation, housing, conservation,  
open-space, noise, and safety.  A housing element must  
identify the community's housing needs and programs to  
satisfy these needs.  After adoption, a city or county must  
submit the housing element to the Department of Housing and  
Community Development (HCD) for review.  HCD must review  
and report its findings to the city or county.

After a city or county adopts its housing element, any  
party may challenge the document's adequacy in either of  
two ways: 
 The party must provide the jurisdiction with a notice  
  citing the deficiencies in the housing element and give  
  the jurisdiction 60 days to correct the deficiencies.   
  After the 60 days expire, the party has one year to file  
  suit. 
 The party must file suit within 60 days of the date HCD  
  makes its findings public. 

While these two provisions were originally intended to be  
separate remedies for challenging inadequate housing  
elements, recent court decisions have ruled them to be in  
conflict.   In one case,  Vineyard Garden Associates v. City  
of Oxnard  (1998), the court ruled that the more general  
first provision allowing a challenge any time after a 60  
day notice to the jurisdiction was rendered moot by the  
more specific second provision which sets a statute of  
limitations 60 days after HCD made its findings public.  

Senate Bill 948 clarifies that a party challenging the  
adequacy of a housing element may file suit within 60 days  
of HCD's review  or  after providing the jurisdiction 60 days  
to correct the cited deficiencies.

I.   Anti-NIMBY law  .  Before proceeding with the  
construction or rehabilitation of a housing project, a  
developer must submit development plans to the city or  
county for approval.   Under state law, a city or county  
must make one of the following findings before denying an  




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affordable housing project:

 The city of county has adopted a housing element, and the  
  project is not needed to meet the jurisdiction's share of  
  regional housing needs for lower-income households;
 The project would have an adverse impact to the public  
  health or safety and there is no way to mitigate or avoid  
  adverse impacts;
 The denial is required to comply with state or federal  
  law;
 Approval of the project would increase the concentration  
  of lower-income households in a neighborhood that already  
  has a disproportionately high number of lower-income  
  households; 
 The project is located on agricultural or resource  
  preservation land or land that does not have adequate  
  water or waste water facilities; or
 The project is inconsistent with the general plan.

Housing advocates argue that these conditions still provide  
a city or county that is averse to affordable housing with  
ample opportunity to deny needed affordable housing  
projects.  

Senate Bill 948 tightens up the findings that a city or  
county must make in order to deny an affordable housing  
project as follows:

 In order to find that the housing is not needed, a city  
  or county's housing element must be in compliance with  
  state law, and the city or county must have met its fair  
  share housing obligations for lower- and moderate-income  
  housing.
 In order to find an over concentration, the project must  
  be in a neighborhood that has a disproportionate share of  
  very low-income housing projects.
 The project must be inconsistent with the general plan  
  and the zoning ordinance.

This bill further defines what is means to "disapprove the  
project" and requires the court to order the local  
government to approve all applications within 90 days if  
the court deems the findings to be inadequate or  
unsupported.

III.   Density bonuses  .  Through local zoning ordinances,  
cities and counties regulate the density of residential  
development.  When a housing developer proposes a  
lower-income housing project, state law requires the local  




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government to offer the developer a density bonus of at  
least 25% or other specified incentives or concessions.   
Because of the size, configuration, or other physical  
characteristics of the site, sometimes developers find it  
difficult or impossible to provide 25% more units.   
Builders want the flexibility to accept less of a density  
bonus when conditions warrant.

Senate Bill 948 clarifies existing law such that a  
developer may opt to accept less than the 25% density bonus  
offered by the jurisdiction if he or she chooses.  SB 948  
further requires the local government to grant the density  
bonus without approval of a general plan amendment, zoning  
change, conditional use permit or other planning decision.

IV.   Ellis Act  .  Local zoning ordinances regulate  
residential land use and densities.  Within residentially  
zoned property, ordinances specify the type of residential  
use:  single family, duplexes, condominiums, apartments,  
residential hotels and other forms of residential housing.   
Property owners must comply with the residential uses  
permitted by the zoning ordinance.

If an owner of rental property want to change the use of  
the property, he or she may have to displace tenants to do  
so.  Under the Ellis Act, no public entity may compel the  
owner  of any rental property to stay in business.   
However, the Act does allow the city or county to regulate  
the subsequent use of the property once it has been  
vacated.

Housing advocates believe that recent court decisions have  
undermined the balance struck under the Ellis Act between  
the rights of rental property owners and the rights of  
local governments to regulate the subsequent use of the  
property once the property has been taken off the market. 

Senate Bill 948 expresses legislative intent to reaffirm  
the right of an owner to withdraw residential property from  
rent or lease, and to reaffirm the right of a local agency  
to impose reasonable conditions on the subsequent use of  
residential property once the property has been withdrawn  
from rent or lease.


  Comments  

1.   Meeting affordable housing needs  .  State officials  
estimate that there is a demand for 250,000 new housing  




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units each year in California, but fewer than 130,000 were  
built last year.  Many economists agree that inadequate  
housing production poses a major long-run threat to the  
state's economic growth.  According to the author, SB 948  
will increase the development of affordable housing by  
reducing barriers at the local level.

2.   Anti-NIMBY law.   In spite of requirements that a local  
government make specific findings in order to deny an  
affordable housing project, 22% of the non-profit housing  
developers responding to a recent survey ranked community  
opposition to affordable housing (known as NIMBY for "Not  
In My Back Yard") as the number one barrier to affordable  
housing development.  The average delay to the affected  
projects was 11.9 months, and the additional costs incurred  
averaged $100,000.  The author believes SB 948 will broaden  
the protections of the Anti-NIMBY law while preserving  
public access to the decision-making process.  

Is the need for affordable housing sufficiently acute to  
further restrict the ability of local governments to deny  
specific housing projects?  If so, would it be more  
effective to require local governments to make more than  
one of the specified findings before denying a housing  
project?

3.   Density bonuses  .  In 1997, the Burbank Housing  
Development Corporation applied to the city of Santa Rosa  
to build an affordable housing project and wanted to use  
the state's density bonus law to increase density above the  
allowable zoning.  Santa Rosa initially required the  
developer to build 25% more units than the general plan  
allowed, even though the developer wanted to use a lesser  
density bonus.  The city also required the developer to  
rezone the property.

The Department of Housing and Community Development  
strongly disagreed with Santa Rosa's interpretation of  
state law and asked the city to reconsider its view.  HCD  
argued that no rezoning was required, stating that the  
density bonus law "imposes what amounts to a statewide  
overlay zone increasing potential densities on all land  
zoned for residential development in California by 25  
percent."  HCD also said that a request for any number of  
units over the applicable zoning is allowed under the law.   


SB 948 clarifies the density bonus requirements so as to  
prevent future misinterpretations.




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4.   Ellis Act.   Since the Ellis Act was adopted in 1986, a  
string of court decisions has undermined the compromise  
reached in Ellis between the rights of a property owner to  
remove rental units from the market and the ability of a  
local government to mitigate the effects of tenant  
displacement and to regulate the subsequent use of the  
property.  The Courts of Appeal in  Javidzad v. City of  
Santa Monica  (1988),  Bullock v. San Francisco  (1990),  First  
Presbyterian Church v. City of Berkeley  (1997), and  Los  
Angeles Lincoln Place Investors, Ltd. v. City of Los  
Angeles  (1997) have barred enforcement of local land use  
ordinances that govern the conversion of residential hotels  
to tourist use and the demolition of residential buildings  
on the grounds that such ordinances interfere with an  
owner's right under the Ellis Act to go out of business.   
Housing advocates argue that as a result of this case law,  
cities have been increasingly at a loss to preserve  
affordable rental housing units.

At the request of Senators Burton and Alarcon, interested  
parties have been meeting to develop a consensus approach  
to revise the Ellis Act.  The working group has not yet  
been able to reach an agreement on amendments, but all  
parties agree to move SB 948 with the current intent  
language.

5.   Housing element challenges  .  Housing advocates argue  
that recent conflicting court rulings need to be clarified  
so that there is certainty over how to challenge a housing  
element that is inadequate to meet the city or county's  
needs for affordable housing.  

  6.   Related Legislation  .  Other bills relating to the  
Anti-NIMBY law and the Ellis Act have been introduced:

   AB 919 (Dutra)  would revise the Anti-NIMBY statute so  
  that a local government must meet not one but three of  
  the specified conditions in order to deny or  
  conditionally approve an affordable housing development.   
  AB 919 was referred to the Assembly Housing and Community  
  Development Committee but has not been set for hearing.

    SB 1106 (Hayden)  would, among other things, amend the  
  Ellis Act to provide that it does not prevent local  
  governments from regulating demolitions, condominium  
  conversions, or compliance with housing codes that  
  adversely affect the preservation and sustainability of  
  affordable housing in their communities.  SB 1106 is  




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  scheduled to be heard in the Senate Housing and Community  
  Development Committee on April 5. 1999.


  Support and Opposition  (3/29/)

  Support  :  A Community of Friends
        Advocates for Affordable Housing in Mountain View  
          and Los Altos
        AFL-CIO Housing Investment Trust
        ASIAN Incorporated
        Association of Homeless and Housing Service  
          Providers of Contra Costa Co.
        Bonita House, Inc.
        Bowman Grove Community Service Planning
        BSA (Barbara Sanders)
        Burbank Housing Development Corporation
        Cabrillo Economic Development Corporation
        Caduceus Outreach Sevices
        California Legislative Council for Older Americans
        California Food Policy Advocates
        California Church Impact
        California Immigrant Welfare Collabarative
        California Rural Legal Assistance Foundation
        Catholic Charities of the Diocese of Santa Rosa
        Central Valley Coalition For Affordable Housing
        CHDC (Nancy Cook)
        Chico City Council
        Chinatown Community Development Center
        Christian Church Homes
        City of East Palo Alto, Rent Stablization Program
        City of Monterey
        City of Salinas
        City of Carlsbad - Housing & Redevelopment  
          Department
        City of Chico/ Homeless Task Force
        Civic Center Barrio Housing Corporation
        Coachella Valley Housing Coalition
        Community Housing Development Corporation of Santa  
          Rosa
        Community Economics, Inc.
        Community Housing       
        Congress of California Seniors
        Corporation for Supportive Hosuing
        Council of Churches of Santa Clara County
        E.M. Schaffran and Company
        EAH
        Eden Housing, Inc.
        EPA Can Do




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        Esperanza Community Housing Corporation
        Fair Housing Council
        First Community Housing
        Friends Committee on Legislation of California
        Friends of the Homeless
        Golden State Mobilehome Owners League
        Graphic Communications Union Retirees
        Gubb & Bashaly LLP, Attorneys and Partners
        Home Base
        Homeless Prenatal Program
        Homes for Life Foundation
        Housing for Independent People, Inc.
        Housing Authority of the City of Santa Barbara
        Housing Rights, Inc.
        Housing Consortium of the East Bay
        Human Assistance, Inc.
        ICF Consulting Group
        IFSN
        Justice Office, Srs. Of St. Joseph
        Lauterbach and Associates Architects
        Legal Aid Foundation of Santa Barbara
        MACSA, Inc.
        Marin City Community Development Corporation
        Marin Housing Council
        Marin Continum of Housing and Services
        Mary Erickson Community Housing
        Mayor Willie Brown, City and County of San  
          Francisco
        Mayor Joe Serna, City of Sacramento
        Mental Health Association of San Francisco
        Mercy Charities Housing California
        Mid Peninsula Housing Coalition
        Napa Valley Community Housing
        National Lawyers Guild
        Nevada County Housing and Community Services
        Non-Profit Housing Association of Northern  
          California
        Oakland Community Housing, Inc.
        Oakland Community Housing Management, Inc.
        OC Homeless Issues Task Force
        Pajaro Valley Housing Corporation
        People's Self-Help Housing Corporation
        Planning and Redevelopment, City of Redwood City
        Plowhares Peace and Justice Center
        Public Law Center
        RCHC (Stan Keasling)
        Religious Wellness with Homeless People
        Renee Franken and Associates, Inc.
        Resources for Community Development




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        Rubicon Programs, Inc.
        Rural California Housing Corporation
        Saben Investments, Inc.
        Sacramento Mutual Housing Association
        SAMCO (Barbara Richards)
        San Francisco Department of Pubic Health
        San Francisco DPH - Housing Services
        San Joaquin Fair Housing
        San Joaquin County Housing Authority
        Santa Clara County
        Santa Monicans for Renter's Rights
        Self-Help Enterprises
        Senior Housing Action Collaborative (SHAC)
        Sentinel Fair Housing
        Shelter, Inc.
        Shelter Partnership, Inc.
        Sisters of St. Joseph of Carondelet
        Sisters of Norte Dame de Namur of California
        Skid Row Housing Trust
        Sober Living Network
        Socialization Thru Empowering Peers (STEP)
        Society of St. Vincent de Paul, Council of L.A.
        South County Housing
        Southern California Association of Non-profit  
          Housing
        SRO Housing Corporation
        St. Joseph Health System
        Tenderloin Neighborhood Development Corporation
        Tenderloin Housing Clinic
        Thai Community Development Center
        The Public Interest Law Project
        The Agora Group
        The Jordan Apartments/JSCO
        Thomas Lauderbach
        Transitional Living and Community Support
        Venice Community Housing Corporation
        West Side Fair Housing Council
        West Sacramento Housing Development Corporation
        West Contra Costa Conservation League
        Western Center on Law and Poverty
        WNC & Associates, Inc.

  Opposition  :  None  
received