Coronado, Solana Beach plead for changes to housing targets in letters sent to the state

The swimming pool at the Coronado Navy Lodge. The city of Coronado opposes the amount of housing it would be forced to plan for under a proposed methodology that allocates housing units to jurisdictions in the county based on jobs and transit.
(Sean M. Haffey)

The cities of Coronado and Solana Beach are appealing to the state to reject a proposed formula for allocating the amount of housing the region must accommodate.

In letters sent last week to the Department of Housing and Community Development, often referred to as HCD, the small coastal cities cited geographic and land-use challenges in meeting long-term, state-mandated quotas.

Both cities say they are already densely developed, built out and face development constraints imposed by the California Coastal Commission, which prioritizes the protection of resources along the state’s coast.

Developed by the San Diego Association of Governments, or SANDAG, the region’s planning agency, the proposed methodology assigns housing units based on the amount of transit and jobs in each jurisdiction across the county.

The state has mandated that all cities and counties must plan for the housing needs of residents; the process is known as the Regional Housing Needs Assessment.

As part of the current planning cycle, SANDAG has been tasked with apportioning nearly 172,000 units for the next eight years. Under the proposed formula, which is under review by HCD, SANDAG would assign Coronado 1,001 units and Solana Beach 875 units.

Only Coronado and Solana Beach have sent comments to the state about the proposed formula and allotments, though other cities across the county, including Lemon Grove, Imperial Beach and National City, previously called on SANDAG to use a more equitable approach.

In its letter, Coronado makes it clear it opposes the fact that the proposed formula takes into account military jobs as a factor used to allocate housing units.

The city states that it “fundamentally disagrees” with the notion that “California cities should be responsible for providing housing for active-duty military personnel employed and housed by the federal government.”

Solana Beach, meanwhile, takes issue with the fact that it would be asked to accommodate housing based on its commuter train station without any modifications to account for the fact that the station serves the broader region. The city suggests that the units it was assigned because of the train station should be equitably distributed.

“While Solana Beach’s train station provides Coaster and Amtrak service, the current methodology fails to recognize that this train station serves a much wider geographic region and a greater commuter population than Solana Beach alone,” the city states.

Coronado’s letter argues that the “unprecedented” inclusion of military jobs results in a drastic increase in the number of housing units the military town would be asked to accommodate in comparison to past planning cycles.

The city points to what it views as several flaws in the formula as a result of the inclusion of military jobs, which account for about 60 percent of jobs in Coronado.

The city argues that the Navy already provides housing for active-duty personnel — both on and off base. And while Coronado would need to accommodate housing for the military force, the Navy’s plans for new housing would not count toward the city’s housing production target, according to the letter.

”...The actual production of new units should also be counted, regardless of whether the units are built by the federal government, local government or the private sector,” the city states.

The city also argues that military jobs “fluctuate significantly based on deployment activity, recruitment numbers and (Department of Defense) decisions to increase or decrease base personnel to meet national defense objectives.”

Among other concerns, Coronado also points to geographic and land-use challenges. The city states that Naval Air Station North Island, Naval Amphibious Base Coronado and Navy Silver Strand Training Complex account for 70 percent of the city’s land, leaving roughly 2 square miles under the city’s land-use authority.

Coronado warns of what it could mean if the state allows SANDAG to use the proposed formula.

“If SANDAG’s RHNA (Regional Housing Needs Assessment) proposal is ultimately adopted, HCD will be effectively endorsing a transfer of responsibility for housing active-duty military from the federal government to local California cities,” the city cautions in its letter.

Solana Beach proposes in its letter an adjustment for small cities, as Mayor David Zito unsuccessfully pushed for during the Sept. 6 meeting in which SANDAG moved forward with the proposed formula. The suggestion would reduce the housing targets of small cities by 55 percent and reassign the units — about 2,600 —to jurisdictions that saw a decrease in their allotments from the previous planning cycle in 2010.

Small cities would be defined as cities less than 5 square miles and/or with a population of less than 28,000 residents.

“An adjustment to the proposed methodology is truly necessary; otherwise, the region will certainly not achieve the construction of its RHNA housing allocation...” Solana Beach argued in its letter.

The proposed formula will return to the SANDAG board for consideration for final adoption after HCD reviews it. The state has about 30 days to complete the review.

---David Hernandez is a reporter for The San Diego Union-Tribune