Regional Housing Allocations Threaten Open Space

Photo Credit: Matt Burrows

Last week, the Association of Bay Area Governments (ABAG) Executive Board voted to approve housing allocations for Santa Clara County that could result in thousands of homes being located in rural areas. We will be working to keep the County’s rural areas rural and protect our open space from inappropriate residential development.

ABAG’s Action Would Put Unacceptable Amount of Development In Rural Areas

ABAG is a regional planning agency responsible for, among other things, determining the Bay Area’s Regional Housing Needs Allocation (RHNA). RHNA assigns a share of our needed future housing to each city and county based on a methodology approved by ABAG.

The RHNA methodology is supposed to follow good land use and planning principles, including focusing new growth in infill areas near transit, while avoiding sprawl into open space and rural areas. In fact, the state legislation governing RHNA specifically states that “promoting infill development and socioeconomic equity, the protection of environmental and agricultural resources, the encouragement of efficient development patterns, and the achievement of the region’s greenhouse gas reductions targets” is one of the objectives of RHNA.

In spite of this, the RHNA allocations approved by the ABAG Executive Board call for approximately 3,100 housing units to be built in unincorporated Santa Clara County. Aside from the Stanford campus and a few unincorporated “pockets” embedded in cities such as San Jose, the unincorporated area of Santa Clara County is entirely rural, and in fact is nearly all farmland, hillsides and open space. Thus, ABAG is calling for thousands of homes to be built in rural areas, nowhere near public transit, and potentially impacting farmland, open space and wildlife habitat.

We need to build more housing, but we need it in our infill areas, near transit and job centers. Sprawl development is a huge contributor to greenhouse gas emissions, because living out on the edge of cities forces people to drive everywhere they go. Moreover, after the recent wildfires, it should be clear that building more homes in the wildland-urban interface (WUI) is a bad idea.

Advocating To Protect Rural Santa Clara County

Green Foothills has been working since last October, when we first learned about the proposed RHNA allocations, to get the RHNA methodology changed. Together with other environmental organizations, local open space districts, and Santa Clara County staff, we have submitted letters, spoken at ABAG meetings, and met with ABAG staff. Although ABAG staff have reduced the number of housing units allocated to the unincorporated County from 4,100 to 3,100, this is still an unacceptably high number.

There are two potential ways to address this issue. State housing law allows a county to transfer some of its RHNA allocations to cities later in the RHNA process. This is an avenue that could be pursued by Santa Clara County. Another possibility is that the state Department of Housing and Community Development, which will review the RHNA methodology, could find problems with the methodology (e.g. that it fails to protect environmental and agricultural resources) and require ABAG to adjust the numbers accordingly.

We will continue to work with our partners on this issue to ensure that the rural unincorporated areas of Santa Clara County are protected from inappropriate development.

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