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The Novato Homeowners Association has two main goals:

• To protect the value of homes in Novato.
• To protect the character of the city of Novato

To Provide Novato Homeowners with information regarding current events and to advocate for policies that will benefit the approximately 2/3 of Novato residents that are Homeowners.

This letter is submitted as public comment on the Public Comment on Draft Bay Area Plan and Draft Bay Area Plan Draft Environmental Impact Report (State Clearinghouse No. 2012062029).

 Introduction

 State housing law prescribes the Association of Bay Area Governments (ABAG) is responsible to insure Regional Housing Need Allocation (RHNA) are reasonable and reflect past performance and local conditions.  Government Code Section 65584.05H specifies “the council of governments shall have final authority to determine the distribution of the region’s existing and projected housing need.”    ABAG has projected the region’s population and job growth for 2010 to 2040 in the Draft Bay Area Plan for the region and then allocated out this population growth, modified by other factors including jobs, to determine the RHNA for each Bay Area jurisdiction.  We believe the methodology used by ABAG to calculate population growth and jobs is flawed.  We also believe the allocation process to the jurisdictions is also flawed.  The result of both of these flawed processes is excessive RHNA projections that are used to mandate housing that is not required and these projections can have adverse effects on the jurisdictions.  The issues with the projections, as well as details of the adverse effects on jurisdictions, will be detailed later in this document.

 Also at issue is the ABAG “top down” planning model over an extended period of time that attempts to predict and mandate a granular level of planning to the jurisdictions.   The issues that make this a failed planning methodology will also be addressed in detail in this document or attachments.  This planning model also fails to consider critical local issues and conditions such as the fiscal impact on jurisdictions, as well as the impact on schools, public services and infrastructure such as water and sewer.

 Conclusion

 The RHNA numbers provided by ABAG that are the basis for the Draft Plan Bay Area are flawed. This is the result of projections for population, jobs and RHNA used in these reports being inaccurate and significantly overestimated RHNA allocations for the jurisdictions.  The basis for this conclusion is built on an analysis of the overall projections for California, the Bay Area as well as a sample jurisdiction.  Thus, the Draft Bay Area Plan report needs to be discarded and a new report should be completed using correct RHNA allocations to jurisdictions built on accurate projections and take into consideration critical local conditions and issues.

Read more: Public Comment on ABAG - MTC Draft Bay Area Plan

CA Department of Housing and Community Development (HCD)

Dear Mr. Campora: 

            This letter is submitted on behalf of the Novato Homeowners Association (NHA). We represent the interests of residents that live in Novato and own homes throughout Novato. We are part of a grassroots effort to reach out to state and local government to have a voice in the creation of the Housing Element and the update of the General Plan. Our members include participants in the Ad Hoc Working Group that developed the list of sites offered to HCD for the current housing element. We are involved and caring individuals that want to support zoning for affordable housing that blends seamlessly with the existing neighborhoods in Novato. We do not represent developers or any entities that stand to profit from these ventures. 

Read more: Letter to Glen A. Campora