Vallejo reworks housing plan after state finds deficiencies

VALLEJO – The city of Vallejo is preparing to resubmit a state-required plan to build new housing over the next seven years after the California Department of Housing and Community Development rejected it in January, citing a number of deficiencies including a shortage of sites identified for low-income housing and a concentration of low-income sites in historically disadvantaged neighborhoods. 

State law requires that the cities and counties across the state submit a new housing element – a component of the city’s general plan that lays out policies and zoning adjustments to accommodate the city’s share of regional housing needs – every eight years. It is one of California’s main planning tools to address the state's housing crisis. 

The city’s housing element for the current cycle, 2023-2031, was due in January 2023 but the city did not submit the plan until November 2023 after making minor adjustments in response to calls for major revisions from housing advocacy groups. 

Paul Thiess of the Sierra Club Solano Group, one of the organizations that provided comments on the first draft, said that the organization is concerned about delays of key programs that are now stretching well into the current planning cycle.

“Vallejo city government is stalling affordable housing while landlords, brokers and developers cash in on the shortage,” Thiess wrote in a Sierra Club Solano Group statement. “A state-mandated Housing Element plan was due 18 months ago. Since then we’ve seen two drafts, neither of which meets State requirements for affordable housing or responds adequately to community concerns.”

The state housing department notified the city of Vallejo that the November submission did not meet state requirements in a letter that included a ten-page appendix detailing the corrections, additional information and analysis needed for full compliance.

Several of the state’s corrections referred to inadequacies that housing advocacy groups had raised in their comments on the first draft. The state housing department pointed out that the city’s draft element identified sites for low-income housing that would contribute to longstanding patterns of inequality in certain neighborhoods.

“The element disproportionately concentrates the lower-income regional housing need allocation (RHNA) in areas with relatively lower median incomes and in areas of high segregation,” state housing officials wrote. “For example, approximately three-fourths of the lower-income RHNA will be accommodated in areas of high segregation and poverty and lower income median incomes.”

State officials also asked for further analysis of the housing needs of farmworkers, a more accurate assessment of the likelihood that parcels identified as potential development sites would actually be developed and for additional data on the ability of accessory dwelling units to fulfill housing needs for various income levels. 

The comments also called for more meaningful programs to prevent displacement of residents who are cost burdened or paying more than 30% of their gross income for housing. In Vallejo, 42.2% of all households are cost burdened and 55.9% of renters are cost burdened, according to U.S. Census data provided in the draft housing element.

The housing element includes a list of programs and policies that the city plans to use to address housing issues identified in various sections of the plan. In their review of those programs and policies, the state asked that the city “refrain from language such as ‘explore’ or ‘study’” and provide discreet timing, commitments and quantified objectives in order to create programs that lead to measurable impacts.

In their revised plan, city officials removed those words from several programs, but kept the vague language in reference to a potential rent stabilization program and Just Cause eviction protections.

In response to the state’s comments regarding the placement of low-income housing in lower income areas with high levels of segregation, the subsequent draft of the housing plan added a new program that will identify 233 additional low-income units in areas east of Interstate 80 that it says will be available for development by December 2026. 

Neighborhoods east of I-80 are less segregated, tend to have higher income levels, and conditions that result in lower rates of asthma and other pollution related diseases.

The subsequent draft also included a program to account for a shortfall in the city’s inventory of potential development sites for low-income units that are required to meet the city's share of the Regional Housing Needs Assessment. The first draft identified a sufficient number of low-income units, but capacity issues raised by the state indicated inadequacies at a significant number of the sites, creating the shortfall. 

The new program will rezone sites to accommodate 469 additional low-income units to meet the city’s requirement of 1,059 low-income units by the time the city’s housing element is fully adopted. Some of the additional units are parcels that will be rezoned to accommodate higher density needed for low-income development but the majority of those units come from a newly identified parcel on the northwest corner of Benicia Road and Columbus Parkway that is expected to accommodate 346 units.

There are a number of state and federal funding programs that either require housing element compliance or consider compliance in the process of awarding grants and other funding. Many of these programs provide crucial support to projects that include low-income units.

The city of Vallejo released the subsequent draft on July 8 for a required public comment period that closes on Friday. Once the comment period closes, the city will submit the subsequent draft including all changes and comments. If the state housing department finds that the subsequent draft complies with California laws the city can move forward with adoption.