ABAG 2023-2031 RHNA Appeal Request Form | Page 1
2023-2031 Regional Housing Needs Assessment (RHNA) Appeal Request Submit appeal requests and supporting documentation via DocuSign by 5:00 pm PST on July 9, 2021.
Late submissions will not be accepted. Send questions to [email protected]
Jurisdiction Whose Allocation is Being Appealed: _____________________________________________________ Filing Party: HCD Jurisdiction: _______________________________________________________________ Contact Name: ______________________________________ Title: __________________________________________ Phone: _______________________________________________ Email: ________________________________________ APPEAL AUTHORIZED BY:
Name: ________________________________________________
Signature: ___________________________________________ Date: _________________________________________________ PLEASE SELECT BELOW:
Mayor
Chair, County Board of Supervisors
City Manager
Chief Administrative Officer
Other: ________________________________ ____
IDENTIFY ONE OR MORE BASES FOR APPEAL [Government Code Section 65584.5(b)] ABAG failed to adequately consider information submitted in the Local Jurisdiction Survey regarding RHNA Factors (Government Code Section 65584.04(e)) and Affirmatively Furthering Fair Housing (See Government Code Section 65584.04(b)(2) and 65584(d)(5)):
Existing and projected jobs and housing relationship. Sewer or water infrastructure constraints for additional development due to laws, regulatory actions, or decisions made by a provider other than the local jurisdiction. Availability of land suitable for urban development or for conversion to residential use. Lands protected from urban development under existing federal or state programs. County policies to preserve prime agricultural land.
Distribution of household growth assumed for Plan Bay Area 2050. County-city agreements to direct growth toward incorporated areas of county. Loss of units contained in assisted housing developments. Households paying more than 30% or 50% of their income in rent. The rate of overcrowding.
Housing needs of farmworkers.
Housing needs generated by the presence of a university campus within a jurisdiction. Housing needs of individuals and families experiencing homelessness. Loss of units during a declared state of emergency from January 31, 2015 to February 5, 2020. The region’s greenhouse gas emissions targets to be met by Plan Bay Area 2050. Affirmatively furthering fair housing.
ABAG failed to determine the jurisdiction’s Draft RHNA Allocation in accordance with the Final RHNA Methodology and in a manner that furthers, and does not undermine the RHNA Objectives (see Government Code Section 65584(d) for the RHNA Objectives). A significant and unforeseen change in circumstances has occurred in the local jurisdiction or jurisdictions that merits a revision of the information submitted in the Local Jurisdiction Survey (appeals based on change of circumstance can only be made by the jurisdiction or jurisdictions where the change occurred).
DocuSign Envelope ID: 15372DE3-6F74-45AA-B071-F194006C613A
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City of Alameda
Planning Director
City of Alameda
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Andrew Thomas
510-7476881
ABAG 2023-2031 RHNA Appeal Request Form | Page 2
Pursuant to Government Code Section 65584.05, appeals shall be based upon comparable data available for all affected jurisdictions and accepted planning methodology, and supported by adequate documentation, and shall include a statement as to why the revision is necessary to further the intent of the objectives listed in Government Code Section 65584(d). An appeal shall be consistent with, and not to the detriment of, the development pattern in the sustainable communities strategy (Plan Bay Area 2050 Final Blueprint).
Number of units requested to be reduced or added to jurisdiction’s Draft RHNA Allocation:
Decrease Number of Units: ___________ Increase Number of Units: __________
Brief description of appeal request and statement on why this revision is necessary to further the intent of the objectives listed in Government Code Section 65584(d) and how the revision is consistent with, and not to the detriment, of the development pattern in Plan Bay Area 2050. Please include supporting documentation for evidence as needed, and attach additional pages if you need more room.
List of supporting documentation, by title and number of pages
1. ___________________________________________________________________________________________________
2. ___________________________________________________________________________________________________
3. ___________________________________________________________________________________________________ The maximum file size is 25MB. To submit larger files, please contact [email protected] .
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attach files
DocuSign Envelope ID: 15372DE3-6F74-45AA-B071-F194006C613A City of Alameda Appeal Letter (3 pages)
As described in the attached letter, the proposed Regional Housing Needs Allocation for the City of Alameda will result in the construction of housing, including housing for lower income households, in areas of that will be heavily impacted by regular flooding, rising ground water, and increasingly vulnerable to the severe ground shaking and public safety threats that will occur in future seismic events.
The land use patterns resulting from the RHNA are not equitable and do not promote the creation of the sustainable, resilient Bay Area as described in Plan Bay Area 2050, nor do these decisions further the objectives of the RHNA as stated in Government Code Section 65584 (d).
A September 2020 study by Silvestrum Climate Associates entitled THE RESPONSE OF THE SHALLOW GROUNDWATER LAYER AND CONTAMINANTS TO SEA LEVEL RISE documents a significant and unforeseen change and new hazard that merits reconsideration of the RHNA allocation. (Click here)
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DocuSign Envelope ID: 15372DE3-6F74-45AA-B071-F194006C613A DocuSign Envelope ID: 15372DE3-6F74-45AA-B071-F194006C613A DocuSign Envelope ID: 15372DE3-6F74-45AA-B071-F194006C613A