Appendix E
City of Sonoma 6th Cycle Housing Element Update
Public Review Draft Comments and Responses
E-66
Sonoma goods are services will tip to the highest possible price points, and a low-wage, unsustainable jobs profile is more likely given existing conditions. o A commitment by the city to foster a more
just, equitable economy would be more important here than nebulous planning claims, that somehow a non-idealistic, bland social engineering “revitalization” based on weak tea HE analysis and Program 21 plans will bring transformational social goods. If the City was actually interested in revitalization and transformational planning, this HE would look A LOT different; revitalize what? How? o The City’s basic plan seems to be a deer in the
headlights and to let the market take care of things, with the minimum HE necessary to pass HCD. The City could direct its “Sustainable Tourism” policy to direct more benefits to workers, “so they can work and live here.” There could be an equity pillar of City planning policy. Staff could be hired and the council say: we want activist, progressive housing policy now. Instead of treading water and playing it safe. o In Access to Opportunity, zoning is not ID’d as
a constraint to AFFH and integration.
o “RHNA sites are mostly distributed in tracts
with moderate to more positive outcomes”, wait a minute! Moderate what? Cumulative TCAC score? This is an intentionally vague statement that is not true, bc the near east side TCAC Block Group is the only Medium resource area, and there are no VL or L RHNA sites there. o “Greater housing choice in Sonoma” is
imagined to effect and fix current low TCAC Ed. scores in the future, housing choice of a presumably VL and L variety; what kind of Agenda Item #2.1:
Appendix E
City of Sonoma 6th Cycle Housing Element Update
Public Review Draft Comments and Responses
E-67
proof of cause and effect is at play here? An invisible hand? o If people are locked into needing to keep low
annual earnings in order to keep low rent units, then they will be trapped by a selfreinforcing low-income, low standards of life conditions loop, and this will not somehow magically “revitalize” and make “more positive economic outcomes.” o All the City’s plans will do here is allow lowwage workers to tread water with locked-in low AMI rent without fear of displacement, as long as they keep annual earnings low to qualify for low rents. That can work to keep essential workers stuck in low wage jobs in the community, but it’s not transformational. o Somehow, a nebulous “opportunity”, of
putting all VL and L units in Hwy 12, will help to raise TCAC educational scores; this is such a weak tea assertion it is unbelievable. What is the source here? There is no attempt in this HE to engage the structural, systemic Valley issues that make for the socioeconomic disadvantage that is cited for low Ed scores; in fact low Ed scores are only the tip of the iceberg of what is being elided by the City here, which is wholeValley segregation in which Sonoma’s east side is one fundamental polarity. o Since affordable by design is assumed by the
City to not be possible, the best any essential worker or missing middle can hope for in terms of econ/ housing advancement would be to get one of the few ADUs that would rent for below 120% AMI. o ADUs can be expected to rent at the top level
of Mod income, or 120% AMI and into Above Mod levels; landlords as a whole have shown they will max prices as much as possible, there may be a few altruistic situations, but very few Agenda Item #2.1:
Appendix E
City of Sonoma 6th Cycle Housing Element Update
Public Review Draft Comments and Responses
E-68
since the common experience of people losing a rental is that they can’t find anything affordable and they are then displaced, and displacement is not tracked. New professionals in town cannot find place to live. o In order to track displacement, the NBOP
tenant’s union should be engaged in the HE and a renter/ tenant registry established. • 4. Disproportionate housing needs
o The intent of the City putting almost all VL and
L RHNA on Hwy 12 is to “add housing to desirable areas and provide a range of housing choices at diff prices to current and future residents. With a broader range of options, housing will become more affordable across the community, which should lessen the housing cost burden, particularly for renters.” o Hwy 12 at 4 Corners with 24 iour traffic is a
“desirable area”? The HE seems to be in a Through the Looking Glass space of narrative creation. o City makes an assumption that more supply,
and a “broader range of housing choices”, specifically 311 choices at the RHNA AMI spread over 8 years, will lower prices and ease renter housing cost burden. This is a rosy, market-based assumption, when in fact, all the market has done is rip people off, and the city has tried and limit supply as much as possible by UGB, SB-9 poison pills and by restrictive zoning that locks in low density for more than half the possible residential areas, in two square mile area. o Why did the City resist the initial 480 RHNA
allocation, have it reduced to 311, not cooperate with the county on a RHNA subregion to address systemic housing disparity issues in the Valley, and not pursue the 725 units/ half deed restricted, Agenda Item #2.1:
Appendix E
City of Sonoma 6th Cycle Housing Element Update
Public Review Draft Comments and Responses
E-69
recommended by the 2019 Housing Our Community series?
o LAFCO has recommended the City look to
expand its UGB and sphere to encompass the Springs area; the Grand Jury housing report took county cities and Sonoma to task for being too passive and inward-looking on housing (see my Grand Jury and LAFCO MSR wrote ups.) o This in spite of a severely constraining UGB
that primarily seeks to protect Green values and open space, the authors of which assume, in circular reasoning, that no amount of new supply will lower prices bc demand for Sonoma’s elite environment is so strong, but demand is strong bc of limited supply… o If new supply at the level of only 311 units will
make a diff in cost burden, imagine what extraUGB annexations and expanding the sphere, and opening up land on Napa Rd (recall the 285 Napa Rd Habitat project that the City UGB made sure would fail) would do for supply and lowering prices? o In fact, the City is defined by a protect small
town character ideology which is fundamentally at odds with being inclusive in meaningful ways and at odds with housing equity, and the HE is a transparent effort to paper over the City Code rules and regs that act counter to many of these above HE assertions about revitalization and transformation etc. The real bull, of low density land use protectionism, is not being taken by the horns by the HE. o Like other Coastal Cal protectors, the City says,
“we’re for AH, just an appropriate scale so it doesn’t mess up our character”, i.e. at a scale where no meaningful AH can be produced, i.e The Green Checkmate.
Agenda Item #2.1:
Appendix E
City of Sonoma 6th Cycle Housing Element Update
Public Review Draft Comments and Responses
E-70
• Site analysis findings
o There are two vacant lots (Armstrong Estates)
on the far east side that will allow development at densities that can foster AH, why are these not considered for HE equity social engineering? By failing to ID these two sites, the HE allows concentrated wealth and white segregation to continue unabated. o There is a Sebastiani ag lot and east side
sphere parcels both big enough for 50-unit, east side projects. These should be top VL and L unit priority in a re-worked site inventory. o The City avoids addressing clear east side
patterns of wealth and white concentrations and says these are not issues. RHNA sites avoid addressing east side econ and racial segregation and give the east side a get out of jail free card on AFFH. o The City says RHNA site inventory does not
burden existing sites of racial and econ homogeneity and that is right, east side gets a pass on integration, and this seems about as far from AFFH as you can get. o Invisible hand investment on Hwy 12 will
somehow magically create opportunities and social goods will be created out of selfishness, bc there is no plan or guarantee that the VL and L sites will be taken up by AH developers, and Program 21 is a weak tea, minimal commitment to see that any AFFH will actually be done. o The HE thesis denies AFFH issues, denies
segregation, denies displacement, underplays and mis-represents east side affluence and white racial concentration. A blindered view is presented that seeks to minimally address HE requirements and not engage the regional and state housing crisis at the level that HCD is hoping for. The Sonoma HE is sophisticated Agenda Item #2.1:
Appendix E
City of Sonoma 6th Cycle Housing Element Update
Public Review Draft Comments and Responses
E-71
version of the mountain lion habitat SB-9 defense scheme, basically finding all the reasons why not to address housing constraints of R-L, low density zoning in service of more integration and more AFFH.
16.34 Page 146
• D. Analysis of contributing factors and fair housing
priorities and goals - In Table 68, displacement risk is ID’d as a fair housing issue; contributing factors are: land use and zoning laws and economic pressure (i.e. UGB, SB-9, R-L and R-R zoning, gentrification and elite tourism economy price inflation. The latter should be ID’d as impediments and constraints to housing. • City priority for displacement risk? Medium/ Low, cites Progs 10,11, 21 and 25; none of these address low density zoning as exclusionary, nor UGB, SB-9 undue constraints to City housing supply. If zoning and land use are not seen as constraints and high priority problems, then they don’t have to be fixed, this is maybe willful denial? • Program 10 is a mitigation, mobile home park rent
stabilization and conversion
o City doing well here, make sure all MHPs are
covered and zoned in the city
o formally add a MHP resident’s right of first
purchase if park comes up for sale, not just for cionid conversions • Program 11 condo conversion
o looks like City is doing OK here
• Program 21 already critiqued that as fundamentally weak tea
• Program 25 MHP senior only occupancy, go for it • Top Three Issues to be addressed in Housing Plan o ONE, basically outlines Program 21, relies in
info and education and enforcement, which the City is not strong on and proposes only annual meeting work, hardly seems like “meaningful actions” These comments related to fair housing, displacement, and diversity have been shared above, and are noted again here.
Agenda Item #2.1:
Appendix E
City of Sonoma 6th Cycle Housing Element Update
Public Review Draft Comments and Responses
E-72
16.35 Page 147
o TWO, “Housing mobility enhancement to
increase access to opportunities and improve access to AH throughout the community.” This is a diffuse, meaning-devoid statement. o THREE, “New housing choices and AH in the
City’s higher opportunity areas and improving opportunity scores.” o Well, if this is a top issue, why such a paucity of
VL and L in R-L and R-R areas?
o Improving TCAC scores will require engaging
with the Springs and addressing the City’s externalized and disadvantaged workforce and their educational and other equity issues, which the HE gives no indication of any effort towards.
These comments related to Program 21, fair housing and diversity have been shared above, and are noted again here.
16.36 Page 148
• The HE continues to say, against actual plans, the City will combat patterns of segregation, will be inclusive, reduce barriers to opportunity for protected characteristics, and do this through a weak effort of passive outreach, low enforcement capability, and infrequent meetings. • City SB-9 ordinance represents a transparent effort to subvert state housing laws to make it more difficult to do lot splits and slightly upzone R-L areas. Given the City’s behavior here and stated intents, HCD should suspect and be alert for other City housing law subversion. • AFFH HE Programs
o Program 1: VL, L and Mod opportunities
“throughout the city”; not born out by RHNA site inventory o Programs 2, 6: facilitate AH construction; no
public display of this since SAHA/ AltaMadrone which itself took more than 10 years to come to fruition, yearly meetings with AH developers not near enough, VL and L sites could just as well go market rate, no active plans known o Program 5: encourage ADUs; ADUs are all at
Mod for site invengory and will likely all be
These comments related to Housing Programs, fair housing, density bonuses, and ADUs have been shared above, and are noted again here.
Agenda Item #2.1:
Appendix E
City of Sonoma 6th Cycle Housing Element Update
Public Review Draft Comments and Responses
E-73
market rate AMI bc landlords have a pattern to max the rent, SB-9 says attainable housing is not possible in Sonoma but wishful ADU policy says it is?; this is not AFFH, it’s a high-rent wolf in sheep’s clothing. HCD should call out the City for an over-reliance on ADUs to mitigate high price points when no evidence shows they will. o Program 7: ensure commercial development
pays a fair share of in lieu fees; city council dialed back assertive Planning Commission effort to make commercial development pay full cost of a unit o Programs 15, 24: support homeless shelters
and transitional housing; city efforts have centered on getting the one shelter as far away from the center of town as possible and even out of town into the Springs; City says the shelter has 10 beds but they are not in use bc of a use permit complaint by a citizen who doesn’t want homeless near his kids; if homelessness is a Valley issue that the City can farm out, need to make other equally critical socioeconomic disparity issues Valley-wide efforts too o Program 27: replace AH units; remains to be
seen if the City can do this, an accountability and tracking process for AH units has recently (under heat from HE process) been set in motion, but chronic staff shortage and lack of enforcement capability; the City needs to make AH a top priority o Program 28: make sure adequate sites
available through 6th cycle; the City apparently has a plenty of sites, only problem, none of the VL and L are in R-L/ R-R areas, site inventory puts huge bulk of VL and L on Hwy 12 and leaves econ and race segregated east side with no changes, all VL and L eggs are in Agenda Item #2.1:
Appendix E
City of Sonoma 6th Cycle Housing Element Update
Public Review Draft Comments and Responses
E-74
one basket, of one or two of these sites fail to produce VL and L there’s no VL and L buffer o Program 19: promote density bonus; this is
fine, but don’t use exclusionary zoning R-L and R-R as de facto redlining, putting all density on Hwy 12 recaps the worst aspects of redlining and 1970s Urban Renewal relocation, if lower income BIPOC are to be included, dense AH unit projects need to be put into R-L and R-R zones, an equity formula can be devised: one 50-unit project for every 500 people-area o Programs 4-15: accommodate specialized
housing types; again, R-L and R-R areas need to be opened up, in a two-square mile city, accommodation for farm workers etc. can’t be off limits in more than half of residential areas; in a stunning lack of creativity and urgency, any effort at farmworker or employee housing has not even been seen, why all these plans all of a sudden if not forced by the state? Will the City view HE and AFFH laws as they do SB-9 etc, as Sacto overreach to be subverted? o Program 20: educate the underserved; if this
will amount to only a largely unseen posting on the City website, what diff will it make? In fact, the underserved have largely been externalized already, necessitating a displacement mitigation program to claw back the displaced and their place in the community, and not call it “growth”; make a tenant registry to track displacement Fred Allebach (8/29/22 – Zoning)
Comments within this letter are sorted by topic.
17.01 Armstrong Estates, additional comments:
• The future development of the parcels east of Armstrong Estates will lead to the extension of Charles Van Damme Way and William Cunningham Avenue, and perhaps to the connection of Appleton Way with East Napa Street. This area, portions of which are currently outside of city limits, has an R-S designation, which calls for somewhat higher densities and a greater variety in lot sizes than what is found These comments related to Armstrong Estates have been shared above, and are noted again here.
Agenda Item #2.1:
Appendix E
City of Sonoma 6th Cycle Housing Element Update
Public Review Draft Comments and Responses
E-75
in the development to the west (Armstrong Estates), which features lots having a minimum area of 20,000 square feet. (Ord. 2003-02 § 3, 2003).” • Here we see code relating to Armstrong Estates, there has to be a minimum lot size of 20,000 sf.
• What other code might there be about Armstrong Estates that keeps it as the top ostentatious wealth area in town? • The Armstrong area is in a Tax Credit, Low Resource Area directly adjacent to TCAC High and Medium Opportunity Areas, this in the R-L low density east side of Sonoma that has zero very-low and low-income integration in the 6th cycle site inventory. Something is wrong with this picture if the base zoning allows for about 100% segregation, and zoning is not identified as a governmental constraint. • Here at Armstrong, there are lots of open land that could integrate the east side but city zoning and possibly also Armstrong CC&Rs are stopping it. • Also stopping integration: Is the city denying there is any pattern of segregation and, that the east side is already essentially an RCAA? More analysis will likely bump east side TCAC scores up, can the city pretend the substance of an RCAA is not there?
17.02 Central East Planning Area:
• A look at Sonoma’s Central-East Planning Area as described in the Sonoma Municipal Code. How such Code prevents the area from addressing patterns of segregation:
• None of the City’s 6th cycle Housing Element’s very-low income and low-income housing site inventory is slated to go in this area, despite the higher TCAC scores that make such areas more desirable for integration of socioeconomically disadvantaged and protected classes. • This area consists of most of Census Tract 1502.04 Block Group 1 (near east side), a TCAC Medium Opportunity Area and Census Tract 1502.04 Block Group 3 (far east side), a TCAC Low Opportunity Area, and a small piece of Census Tract 1502.02 Block Group 3 (east side north/ Sebastiani area) a TCAC High Opportunity Area. Tract 1502.04 Block Group 2 is the near west side with much lower scores and These comments are noted.
Agenda Item #2.1:
Appendix E
City of Sonoma 6th Cycle Housing Element Update
Public Review Draft Comments and Responses
E-76
indicators. If Tract 1502.04 is considered as a whole, Block Group 2 will drag the scores down. • The City’s Central-East Planning Area is essentially the same as the area of the above three hyperlinked Block Groups. From Census Block Group data, this area is 80-95% white, with home values from $800,000 to $2 million, with high levels of educational attainment, equally good TCAC Environmental scores and marginally different economically. The far east side is mixed with out-of-city data that goes out to 8th St. East, this mixing lowers its economic score. TCAC Education scores are lower in the three hyperlinked Block Groups bc out-of-City socioeconomically disadvantaged students for the local school system are mixed into the City’s east side. • Closer analysis would maybe show that higher east side TCAC score is likely, even to the point of all east side Block Groups being an RCAA and TCAC High Resource Area. This might depend on whether one was trying to prove it or not. • From the Municipal Code: Central-East Planning Area
“Existing land uses include: 1. Low density single-family homes; 2. Four neighborhood parks; 3. The Sonoma Community Center; 4. Undeveloped, Sonoma residential property in the sphere of influence; and 5. A cemetery.”
17.03 R-L Zoning, additional comments:
• Default R-L zoning does not allow density above R-L, singlefamily zoning. Why does Chapter 19.44 SMC indicate that "densities do not include density bonuses?"
• No density higher than single-family zoning is allowed, and thus, no affordable housing projects can be allowed because by definition, 50-some units and more than 0.50 acres but less than 10 acres are necessary for an affordable housing project to be allowed in Sonoma, and to pencil. • However, no density bonus can maybe be waived, and large affordable housing projects be allowed in Armstrong Estates:
• “19.44.050 Types of bonuses and incentives allowed. A qualifying residential development project shall be entitled to the following density bonus and other incentives. If a These comments are noted. Comments related to density bonuses, housing segregation and preservation of housing character have been shared above, and are noted again here. .
Agenda Item #2.1:
Appendix E
City of Sonoma 6th Cycle Housing Element Update
Public Review Draft Comments and Responses
E-77
density bonus and/or other incentives cannot be accommodated on a parcel due to strict compliance with the provisions of this development code, the planning commission is authorized to waive or modify development standards as necessary to accommodate all bonus units and other incentives to which the development is entitled.” • Preservation of low-density R-L character is ultimately a subjective choice by the City and this is only in force because three City Council votes agree to it. Very few even think to address Sonoma segregation by looking at the Municipal Code and then wonder why the Housing Element has no very low- and low-income units on the east side referred to above? • There really is no good reason other than to preserve and maintain the white, wealthy status quo that has been advantaged through segregation. There are plenty of working class whites in Sonoma, not many on the east side. • The only difference now between this and overt redlining, is that this Central-East Planning Area has covertly staked out segregatory boundaries through visual, spatial/ design prohibitions and through zoning.
17.04 Segregation, additional comments:
• It’s clear why the SB-9 lot-split/ duplex bill was so strenuously undermined by the City:
• By-right lot splits that ended up with two duplexes and two ADUs “could affect efforts to maintain the character of the area” through significant subdivision of lots. • "Maintaining the character of the area” is a top Sonoma priority, even to the point of denying obvious patterns of segregation. • The desired future has nothing about integration and is all about visual compatibility and maintaining low density suburbia. This sounds like subjective language: “preserve the existing quality and fabric of residential neighborhoods.” • If multi-family units, “Multifamily developments shall require screening and buffering of parking and driveway areas, and noise and light sources.” These comments are noted. Comments related to ADUs have been shared above, and are noted again here.
Agenda Item #2.1:
Appendix E
City of Sonoma 6th Cycle Housing Element Update
Public Review Draft Comments and Responses
E-78
17.05 Additional constraints to affordable housing:
• The general objective for this area, as expressed in SMC
19.20.020, Project planning and design, is to preserve the existing quality and fabric of residential neighborhoods in the Central-East planning area. • Two key issues that could affect efforts to maintain the character of the area include a significant number of parcels that could be subdivided as infill lots, and the site planning and building design techniques employed in their development. Development of the potential infill parcels will mainly need to focus on visual compatibility with the adjacent patterns of site design, building scale, and architectural context.
These comments are noted. Comments related to affordable housing have been shared above, and are noted again here.
Agenda Item #2.1: