MTC/ABAG's Draft SCS is Fatally Flawed

Recently in the San Francisco Bay Area, according to the provisions of California's Senate Bill 375 (SB 375), the regional agencies released a draft version of their plan for land use and transportation patterns through the year 2040. The Bay Area's Greenbelt Alliance called regional government agencies MTC and ABAG's draft Sustainable Communities Strategy (SCS) a "...page turner of a land use scenario." 

I agree that it is a comprehensive discussion of the issues faced by planners in the Bay Area. In fact, I would almost call it whiny. Read this paragraph and see if you agree:

The affordable housing production challenge is particularly critical relative to infill development where established

neighborhoods are revitalized with new development in the midst of existing communities, land values are high and planning and entitlement processes are often complex and costly. In addition, construction costs of multi-unit structures continue to escalate, particularly due to the cost of steel and other materials. Financing for infill development remains difficult and the “cost of money” remains relatively high due to the perceived riskiness of multi-family construction and the need for large chunks of capital up front. Urban infill development is also challenging due to the need to assemble sites and the extra costs for site preparation, as well as the extra regulatory hurdles in core areas, such as extensive design reviews. And most recently, there is a new threat of lack of institutional capacity to process housing applications, due to the dissolution of redevelopment agencies and the ongoing fiscal stress in local governments. (page 8)

If it sounds like this may be a prelude to a plan that does not propose solutions to these problems... it is.

For instance, it seems to take a passive, backseat role with regards to planning for the future urban form of employment parks:

Multiple activities and transit at office parks

Office parks have and are expected to continue to accommodate a growing number of employees. However, given the limited land available for new office parks, existing vacant office space, and the preference for walkable, transit-served neighborhoods by a growing number of employers, office parks are expected to grow at a slower pace than in recent decades. Existing office parks are also using less space per worker, providing transit access, and in a few cases adding housing, services and amenities. The emerging private shuttle services run by businesses, particularly in San Mateo and Santa Clara Counties, are expected to grow and improve transit access while lessening, but not fully mitigating increased freeway traffic congestion related to employment growth. (page 15)

Remember -- this is a plan that is legally mandated to attempt to reduce greenhouse gas emissions, specifically from transportation. And yet it takes a laissez-faire approach to one of the most major issues in regional planning in the Bay Area -- the continued growth of auto-dependent low-density employment parks far from transit -- which is known to lead to increased greenhouse gas emissions.

The major issues with the plan also include the low amounts of housing units planned for construction in comparison to population and employment growth over the next three decades. For instance, rather than confront that fact that this region has consistently under-produced housing over the past few decades (as evidenced by high housing prices and high amounts of in-commuting), the plan seeks to reduce the target for new housing production by using gimmicks:

“…the plan takes into account current housing vacancy rates (approximately 6.4%) and fills vacancies first before planning any new construction.”

First issue: The Bay Area likely has among the lowest vacancy rates of the largest regions in the state, and yet, even though it is the last of the major MPOs in California to produce its SCS, it is the first MPO to suggest that filling vacancies can be a reason to reduce the housing target by a six-figure amount.*

Second issue: Even if this were a valid strategy on its face, it misses two important factors:

1) Location: Many of the vacant units are located in undesirable areas, far from transit and job centers. Vacancy rates in walkable neighborhoods near transit with low crime are at normal, even low levels.

2) Demand by unit type: Much of the vacancies are for single family homes, especially those in poor locations. Much of the demand is for townhomes and multifamily units near transit. Just because there is a surplus of the former doesn’t mean that there is no need to construct the latter.

In reading the draft SCS, I see no mention of demand for units by unit type, especially not in the nuanced manner that has become normative in post-SB375 planning in California: Single Family Large Lot, Single Family Small Lot, Townhome and Multifamily. While Dr. A.C. Nelson’s report “The New California Dream” is referenced, his specific demand projections by unit type and by location are ignored. In case readers don't wish to dig too deeply to find them, here they are for the Bay Area (from page 44 of Dr. Nelson's housing unit demand forecast):

New unit Demand 2010–2035

Multifamily: 668,000 (45.10%)

Townhome: 519,000 (35.04%)

Single Family Small Lot: 294,000 (19.85%)

Single Family Large Lot: −526,000 

Total: 956,000

The draft Bay Area SCS (what they call the Jobs-Housing Connection Strategy, or Plan Bay Area, as a part of some nebulous umbrella effort known as OneBayArea) doesn't specifically include targets for housing unit production by unit type. However, Dr. Nelson's estimate of 956,000 new housing units is likely closer to the overall total amount than the 660,000 used in the current draft of the Bay Area's plan. This shortfall will likely be made up by continued exurban sprawl in California's San Joaquin Valley, as well as to much lesser degrees the northern Salinas Valley, the Santa Cruz/Monterey Bay area and Mendocino and Lake counties.

For these reasons alone, this is a fatally flawed plan; but also add to this list the fact that it does not specify where non-TOD growth will occur (beyond while travel analysis zone it will fall in); and that it admits that it fails to provide enough housing to meet potential demand -- to such a degree that job growth will be lowered by ~110k future potential employees as a consequence, as admitted on page 8:

According to Steve Levy, from the Center for Continuing Study of the California Economy, the region could capture another 110,000 jobs of the total national growth. However, the total job growth is constrained by our ability to produce housing, which is ambitiously estimated at 660,000 new units by 2040.

On page 9, the plan admits that it will not seek to current the current imbalance between jobs in the Bay Area and housing outside of the region (mainly in the San Joaquin Valley):

This also assumes that the rate of net in- commuting will remain at 2010 levels, and absorption of about 40,000 existing vacant units. (continued in footnote): The Jobs-Housing Connection Scenario includes an adjustment of 0.7 percent higher employed residents than the numbers forecast by Levy. This adjustment is the result of retaining the 2010 in-commute ratio out to 2040.

Not just retain the current total amount of people commuting into the Bay Area, but actually allow it to increase by retaining the current rate. This will result in an absolute increase in in-commuters, which is not good news to anybody who currently drives in through the Altamont Pass during their morning commute; it will also result in more sprawl in the immediately adjacent San Joaquin Valley, which will not be good news to folks who would prefer to see the agricultural character of that place preserved.

It also flies against what many, including the Natural Resources Defense Council (NRDC) consider to be the primary goals of SB 375 -- to provide housing for all of the potential future residents of a region:

Identify areas sufficient to house all the population of the region, including all economic segments, over the course of the planning period of the regional transportation plan, taking into account net migration into the region, population growth, household formation, and employment growth. This provision is not atypical for growth projections, but SB 375 makes two significant changes. First, the SCS must accommodate all the population growth of the region within the region. Shipping residential growth to adjacent regions is no longer allowed. Second, the population growth projections must include the increased housing demand caused by employment growth. These provisions recognize the crucial linkage between a regional-scale jobs-housing balance and reduced VMT. The housing projects in the first horizon year of the plan (presumably eight years out) must be consistent with the regional housing need identified in the regional housing needs allocation (RHNA) program. This provision is part of the effort to align these programs.

The hope for this plan lies in the basic framework of concentrating growth around transit, and the programs that are being proposed to help make this happen. Let’s hope that future iterations of the plan will build upon this, but address the issues mentioned above…

 ------
* SCAG's SCS mentions that the California Department of Housing and Community Development (HCD) allowed them to reduce their Regional Housing Needs Allocation (RHNA) for the upcoming 8-year cycle by a slight amount to reflect the current elevated vacancy rate, but they don't mention using this vacancy rate to reduce their overall growth control totals to 2035, nor do they use it as an excuse to continue to encourage the growth of current unhealthy in-commuting patterns. SANDAG's SCS does not mention reducing their housing growth targets due to the vacancy rate specifically, though their vacancy rate was only 5.8% in 2010 according to that document. SACOG's SCS mentions accounting for vacancy -- by using a 5% "vacancy factor", which they account for by planning to overbuild housing to account for a future 5% vacancy rate in 2035 and still be able to accommodate all new households. SACOG's approach is the right way to look at the nuances related to vacancy, which is to take responsibility for the fact that there always will be vacant housing units, and to plan to overbuild slightly in order to account for this.