From: Frederick Allebach
To: CityCouncilListPublic; [email protected]
Subject: [EXTERNAL] Public comment on South Santa Rosa Specific Plan (SSRSP) Concerning affordable housing, equity, and anti-displacement actions
Date: Sunday, August 16, 2026 8:31:22 AM
Fred Allebach, SSRSP Engagement Advisory Committee member 8/16/26
Public comment on South Santa Rosa Specific Plan (SSRSP) study sessions. Concerning affordable housing, equity, and anti-displacement actions.
Members of the Santa Rosa City Council and Sonoma County Board of Supervisors, A significant new detail came out at the 8/13/26 Santa
Rosa Planning Commission SSRSP study session.
It was never clear how staff intended to address affordable housing, equity and displacement issues when all that was talked about in study sessions and surveys so far were land use and circulation Alternatives. Staff never explicitly said how and when the Plan would address equity issues. Despite direction by the Council to pay attention to SSRSP equity issues, there is nothing of substance on this in the Preferred Alternative.
Staff has now said that the Affordable Housing and Anti-displacement Strategy (the Strategy) will serve as the basis for any SSRSP equity-oriented programs and policies, and that these programs and policies would be developed separately from and independent of approval of the Preferred Alternative. Staff said the process was to wait and see what the public and various decision maker meetings brought to the table for these equity-based programs and policies.
The Council and the BOS in my opinion, need to press staff on exactly how and when they intend to address Plan-area affordable housing, equity and displacement issues? When will targeted anti-displacement actions be introduced? Will they be binding? I suggest that specific and actionable affordable housing, equity, and anti-displacement actions be required and approved at the same time as the land use and circulation Preferred Alternative.
The less specific the Council and BOS are, the more room there will be to obligate nothing.
Frankly, this whole process seems like an exercise in how to avoid committing to concrete affordable housing, equity, and anti-displacement actions.
Many equity-centered options, including ordinances, have been presented in the Strategy and in public comment. These options address the Three Ps of housing, production, preservation and protection. Specific programs and policies will take staff time and money which needs to be allocated up front or else we risk having a strong description of Plan area affordable housing, equity, and anti-displacement issues but weak tea programs and policies that will in fact
do little.
Decision makers could and IMO should instruct staff to make a chart showing SSRSP affordable housing, equity, and anti-displacement programs and policies generated by the public and the Strategy and also show projected impact and the estimated time and cost to do them. These could be decided on Preferred Alternative approval. Have definite goals in place.
This way, decision makers will have a good range of possible programs and policies to choose from. Instruct staff to vet program and policy ideas brought forth by Legal Aid, NBOP, NAACP Branch, Health Equity Rising, and others. Ensure the public’s concerns are heard, seen, and addressed, this is what engagement should be.
Affirmatively Furthering Fair Housing (AFFH) policy is listed as the top Plan area affordable housing, equity, and displacement mitigation, “...contemporary planning practices aim to address these issues through Affirmative Furthering Fair Housing policies and other equitable development initiatives. These efforts are designed to prevent displacement, promote inclusivity, and ensure that reinvestment benefits all community members, particularly those historically marginalized.”
Strict AFFH compliance should be a condition of Preferred Alternative approval. Make sure staff can't weasel out of addressing Plan area affordable housing, equity, and displacement issues. If we are going to avoid recapping the negative externalities of 1960s urban renewal in the SSRSP, you need to decide that and make it so
. A lot of conditional, non-obligatory
language won’t do the job.
For the following reasons and to adhere to state law, the 6000+ housing units planned for in the SSRSP should be required to match 6th cycle RHNA annual income proportions, 40% for Very Low and Low, 16% for Moderate. “For the 2023-2031 RHNA, recent legislation added a new objective that requires the RHNA plan to “affirmatively further fair housing.” According to Government Code Section 65584(e), this means: “Taking meaningful actions, in addition to combating discrimination, that overcome patterns of segregation and foster inclusive communities free from barriers that restrict access to opportunity based on protected characteristics. Specifically, affirmatively furthering fair housing means taking meaningful actions that, taken together, address significant disparities in housing needs and in access to opportunity, replacing segregated living patterns with truly integrated and balanced living patterns, transforming racially and ethnically concentrated areas of poverty into areas of opportunity, and fostering and maintaining compliance with civil rights and fair housing laws.” For the same reason as above, the Todd Creek annexation area should be rezoned to match the RHNA income spread, not appear as a monolithic block of low-density, exclusionary zoning from which gentrification will emanate out into the Plan area. 2000 contiguous units of single family zoning perpetuates segregation and is likely against AFFH law.
The Affordable Housing and Anti-Displacement Strategy says “risk of displacement within the Plan Area is characterized as high.” “These challenges must be addressed in the South Santa Rosa Specific Plan to ensure that community members can remain in their homes and that new residents can find housing options at the appropriate level of affordability.” Let’s make sure they are addressed in meaningful and actionable ways.
Demographic stats cited in the Strategy are shocking and call for targeted interventions to address the area’s challenges. “The latest Portrait of Sonoma County report reveals that the South Santa Rosa Specific Plan Area has one of the lowest Human Development Indices (HDI) in the county, significantly lower than both the county and state averages.” Decision makers reading and internalizing this data should, in my opinion, be moved to request staff to construct and implement specific, actionable, and required programs and policies that will meaningfully address affordable housing, equity issues, and displacement risk.
Given that adhering to already adopted Housing Element AFFH policies and programs is the top item in the Strategy, what does it mean to “affirmatively further fair housing”? See this summary of AFFH law requirements.
As well, “consequences for failing to conform to Affirmatively Furthering Fair Housing (AFFH) mandates in California—primarily driven by Assembly Bill 686 (2018)—are severe for local jurisdictions, as the state holds unique authority to directly intervene in local planning and zoning. Non-compliance can lead to the revocation of housing element certification, legal action from the Attorney General, significant financial penalties, and a loss of local control over development approvals.”
A few specific suggestions:
Ø The BOS require an Office of Equity, Racial Equity Analysis (REA) of the SSRSP.
Ø Preserving mobile home park (MHP) land use designation is not enough, Closure and Conversion and Rent Stabilization ordinances need updating and strengthening to address the
egregious and abusive behavior of owners like Harmony. Match those of Petaluma.
Ø
MHPs represent 18% of Plan area housing stock, 1000 units of naturally occurring affordable housing, these numbers show a worthy group to invest Plan actionable programs
and policies
Ø The County needs to allocate legal resources to help mobile home park residents in the unincorporated areas of the SSRSP now. The wolf in in the gate Ø If there are excuses for why housing production, preservation, and protection can’t work or cost too much, what are we left with? More than words are needed.
Ø
Hold out for a culturally appropriate and neighborhood-serving commercial center in Moorland and a foot/bike bridge at Robles that will connect with the Plan area park and trail
system
Ø Moorland needs to be annexed into the City, the sooner the better Ø Economic vitality boosting can’t come at the cost of displacing and further cost burdening current lower-income residents in the Plan area.
Ø The Plan needs way better socio-economic balance, not to appear as a Trojan Horse of higher-end economic development proceeding without a clear accounting for its negative
externalities. For example, when Hwy 12 improvements were made in the Springs adding sidewalks, lights, crosswalks etc., residential, and storefront rents went up ASAP.
Ø
A balanced planning approach that clearly puts affordable housing, equity and displacement issues on the table and actionably addresses them is needed. "We don't know where we're going but we have to stick together in case somebody gets there." Ken Kesey
From: Lina Blanco
To: CityCouncilListPublic; [email protected]; Sonoma County Tenants Union Subject: [EXTERNAL] Public Comment on South Santa Rosa Specific Plan (SSRSP) No Displacement for New Development Date: Sunday, August 16, 2026 9:13:03 AM
Dear Santa Rosa City Council and Sonoma County Board of Supervisors, My name is Lina Blanco and I’m a Tenant Organizer at the North Bay Organizing Project and Sonoma County Tenants Union.
At last week’s Santa Rosa Planning Commission, nearly 40 residents of the South Santa Rosa Plan Area attended and forward concerns and need for essential anti-displacement protections in their mobile home parks. Residents of Western and Plaza mobile home parks are primarily immigrant and Spanish-speaking families, veterans, survivors of domestic abuse, single mothers, people living with disabilities, and elders living on fixed incomes.
Folks at these parks are enduring pressures not only from possible displacement from the South Santa Rosa Plan Area, but also from the corporate investor who recently bought their parks, corporate investor Harmony Communities.
In the last 9 months that Harmony has owned their parks, residents have faced an onslaught of intimidation and harassment, including 7-day notices, the overnight removal of 40 essential shade-providing trees, park maintenance neglect, emergency water shut offs and book notices from burst pipes, the turnover of 3 managers, and increases on RV space rents of 200% for the newer tenants. Many of the folks who live in these parks have saved up to buy their mobile homes or RVs after losing their homes in the 2008 financial crisis and the 2017 fires.
This isn’t a standalone event. Five of the nine mobile home parks that Harmony Communities now own in Sonoma County are located in Santa Rosa, and three of those parks are in the Plan Area. They are betting on a jurisdiction where they can turn a profit benefit from weaker mobile home park protections. Now is the time to align yourselves with other jurisdictions like Petaluma, Cotati and Windsor and protect your residents and prevent homelessness.
We support investment in South Santa Rosa. Residents deserve the same infrastructure, services, amenities, and opportunities afforded to residents in the city’s wealthier neighborhoods. But the Plan’s vision of “revitalization,” built primarily around market-rate housing and new commercial investment, risks pricing out the very residents who currently call these neighborhoods home. The City and County must not finally invest in this area, only to make it impossible for existing residents to remain rooted in their community.
If the City and County move forward with the SSRSP, it must include concrete anti- displacement strategies, including:
1. Set baseline targets for preserving and producing housing for extremely low- and very-low-income households.
2. Protect mobilehome parks through MHP-specific land use designations, stronger rent stabilization, and safeguards against park closure or redevelopment. Not all 17 parks in the plan area are currently zoned as MHPs.
3. Expand Just Cause Eviction Protections in Santa Rosa to match or exceed protections for renters in unincorporated Sonoma County.
4. Adopt Rent Stabilization that caps annual rent increases for more housing types at 3%.
5. Create a Rental Registry and Rent Board to track rental housing conditions and inform local policy.
South Santa Rosa is home to primarily immigrant communities, Black, Indigenous communities of color, working-class folks, and seniors on fixed incomes who have built deep roots here and contribute to the fabric of our community. These are also populations already disproportionately impacted by the housing affordability crisis.
Across the Bay
Area, seniors and working families are the fastest-growing unhoused populations, women- of-color-led households face the highest rent-burdens, and single mothers with children
face the greatest risk of eviction.
Residents in the Plan Area work in education, healthcare, agriculture, social services, retail, and manufacturing – workers that sustain the broader economy and care for our community, but whose incomes have not kept pace with the region’s rising housing costs.
Since 2000, median rents in California have increased by 37% while median household incomes have increased by only 7%. In Santa Rosa and throughout the Bay Area, renters are facing the widening gap between incomes and housing costs. The median annual household income in the Plan Area is $60,000, which is 35% below the citywide median of $92,000 and even further below the countywide median of $99,000.
Sixty percent of South Santa Rosa residents are already housing cost-burdened. At a moment when families are already struggling to make ends meet, people need relief, not additional pressure that could push them out of their housing altogether.
When a single new affordable housing unit in Sonoma County costs more than $500,000 to build, it makes little sense to allow existing affordable homes to disappear. We cannot build our way out of the housing crisis while losing the affordable housing we already have.
Acting now can help prevent the displacement of long-term residents and ensure that the unincorporated County doesn’t become a prime target for predatory park owners.
This is an opportunity to pass a strong menu of renter and mobile home park protections, which are a no- or low-cost tool available to jurisdictions to prevent homelessness.
Preserve South Santa Rosa's existing affordable housing, protect existing residents who contribute to the fabric of this place, and prevent families from being pushed to the streets.
No displacement for new development!
Lina Blanco
she/ella • they/elle–what’s this?
Tenant Organizer
Organizadora de Inquilinxs
NORTH BAY ORGANIZING PROJECT
www.northbayop.org
Southern Pomo, Wappo and Coast Miwok lands
Tierras de los Pomo del Sur, los Wappo y los Miwok de la Costa NBOP Projects Proyectos de NBOP
UndocuFund • Sonoma County Tenants Union • North Bay Rapid Response Network • Comida Para Todos NBOP IMPACT REPORT 2023-24 Watch: Who are we? We’re NBOP! From: Ken MacNab
To: CityCouncilListPublic
Cc: Nutt, Jason; City Clerk; Osburn, Gabe; Jones, Jessica; Nicholson, Amy; McKay, Conor; Ben vanZutphen Subject: [EXTERNAL] Comment on Item 4.1 - SSRSP Draft Preferred Alternative Date: Monday, August 17, 2026 8:59:12 AM
Attachments: Item 4.1. - Comments on SSRSP Pref Alternative - 8-18-2026.pdf Mayor Stapp, Councilmembers-
Attached for your review and consideration is a comment letter regarding Item
4.1 on the August 18th City Council meeting agenda. Unfortunately, I will not be able to attend the meeting so please feel free to contact me if you have any questions.
Respectfully-
Ken
Ken MacNab | KMac Advising, LLC
KMac Advising, LLC
2751 Fourth St. #302
Santa Rosa, CA 95405
August 18, 2026
Mr. Mark Stapp
Mayor
City of Santa Rosa
100 Santa Rosa Avenue
Santa Rosa, CA 95404
RE: Item 4.1: South Santa Rosa Specific Plan - Draft Preferred Alternative
Dear Mayor Stapp, Councilmembers:
Thank you for the opportunity to provide comments on the Draft Preferred Alternative for the South Santa Rosa Specific Plan area. I am unable to attend the scheduled Study Session on August 18
th but would like to share the comments below for your consideration. These comments specifically pertain to the “Todd Creek” area – which is generally includes the undeveloped area between Santa Rosa Avenue and Petaluma Hill Road, north of the east fork of Todd Creek.
Flood Mitigation
The City should consider use of parkland to mitigate potential flooding impacts associated with 100- and 500- year flood events. The location of the proposed parks within the Todd Creek area should be evaluated against adopted FEMA flood maps to assess whether the proposed parks are optimally sited to take advantage of potential mitigation opportunities.
Land Use
The City should consider increasing the amount of land designated for Medium-Low residential uses within the Todd Creek area to create additional opportunities for the development of small-lot “for sale” detached and attached missing-middle housing types.
Road Connection to Delores Lane
The City should further assess the feasibility of the proposed road connection to Delores Lane, a private street, from the southwest corner of the Todd Creek area.