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by Gennady Sheyner / Palo Alto Weekly
Uploaded: Fri, Mar 24, 2023, 6:02 pm 25
Time to read: about 4 minutes
An Arbor Real home in Palo Alto. Embarcadero Media file photo by Olivia Treynor.
Palo Alto will have to revise its plan to add more than 6,000 housing units over the next eight years after the Department Housing and Community Development (HCD) ruled on March 23 that the city’s proposed Housing Element fails to meet state law.
According to a letter that HCD Proactive Housing Accountability Chief Melinda Coy sent to the city, Palo Alto will have to make a host of revisions to its document before it can win state approval. Palo Alto submitted its draft Housing Element to the HCD in late December after nearly two years of public hearings. The letter means it will now have to perform further analysis and consider new housing policies.
The Housing Element is the city’s plan for meeting its state-mandated housing obligation, as set through the state’s Regional Housing Needs Allocation (RHNA) process. In Palo Alto, the allocation totals 6,086 housing units between 2023 and 2031, roughly three times the number in the current eight-year RHNA cycle. Of those, 3,465 would have to be below-market-rate units among various income categories.
Under recent changes in state housing law, the document also must demonstrate the city’s plan to “affirmatively further fair housing,” which means explicitly addressing and combating disparities that have resulted from past patterns of segregation.
The HCD determination was not a surprise. Nearly every city that has submitted its plans to the state agency over the past year was required to make revisions. To date, Redwood City is the only jurisdiction in the Peninsula that has received a passing grade from the state agency.
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Earlier this month, Palo Alto Planning Director Jonathan Lait said that based on other cities’ experiences, he expected the HCD to request revisions. At the March 8 hearing in front of the Planning and Transportation Commission, he said he expected to see a “robust comment letter” from the HCD and that it might take several months for the city to obtain compliance.
“We already knew there are some things where we’ll need to make some adjustments before we even made the submittal,” Lait said at the March 8 meeting.
One area in which the city will have to make revisions is in its plan to affirmatively further fair housing. While the city’s assessment of housing trends focuses on regional data and includes information about various parts of Santa Clara County, the HCD directed city planners to dig deeper and to look at neighborhood trends and “provide appropriate programmatic responses to address ongoing patterns and trends.”
And while Palo Alto’s document identifies “racially concentrated areas of affluence,” it has not provided sufficient analysis on the factors that created the wealth in these neighborhoods, the HCD found.
“For example, the element could examine past land use practices, investments, quality or life relative to the rest of the City and region and then formulate appropriate programs to promote more inclusive communities and equitable quality of life,” the letter states.
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The HCD also directed the city to be more specific in listing the levels of affordability in recently approved housing projects, which can be used as credit in meeting the RHNA allocations. The city divided its pipeline projects into market-rate and below-market-rate projects without detailing the affordability level in the latter category.
The city’s plan for creating 6,086 dwellings in the next eight years includes a host of strategies, including easing density restrictions in existing multifamily districts to allow for more units per acre; exploring construction of housing on city-owned parking lots; working with Stanford on two housing developments at university-owned sites; and encouraging the construction of accessory dwelling units. The most ambitious one, however, is rezoning manufacturing and light-industrial zones around San Antonio Road and Fabian Way to facilitate the replacement of existing commercial buildings with more than 2,000 housing units.
A car makes a right turn onto East Charleston Road from San Antonio Road in Palo Alto. Embarcadero Media file photo by Veronica Weber.
The HCD letter stated that the city needs to do far more work to convince the state agency that its biggest housing policy is actually viable. The city included factors such as development trends, ages of existing structures and community interest, among others, in making its case for the rezoning program.
But the HCD argued in its letter that the city must also include additional information about existing uses that “may constitute an impediment to additional residential development, past experiences converting existing uses to higher density residential development, current market demand for the existing use, existing leases or contracts that would perpetuate the existing use or prevent additional residential development or other relevant information to demonstrate the potential for redevelopment such as expressed owner and developer interest.”
“Based on a complete analysis the element may need to add or revise programs to facilitate redevelopment,” the letter states.
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Similarly, the HCD is requesting more information about creating housing on city-owned parking lots, including a schedule of actions to facilitate the conversion and consideration of alternative sites that can be used if parking-lot sites aren’t identified by a date early in the planning period.
In addition, the city is required to take a deeper look into its own zoning practices and consider potential constraints on constructing housing in all residential zones. The analysis, according to the letter, should “address any impacts on cost, supply, housing choice, feasibility, timing, approval certainty and ability to achieve maximum densities and include programs to address identified constraints.”
The letter comes at a time when Palo Alto and other cities across the state are feeling ever greater pressure to get their Housing Elements certified. Because state law set a Jan. 31, 2023 deadline for Bay Area jurisdictions to get their documents certified, Palo Alto and most other cities are now out of compliance.
In some cities, including Los Altos and Mountain View, developers have proposed housing projects under a “builder’s remedy” provision in state code, which allows projects that exceed zoning regulations to advance without city approval in jurisdictions that are out of compliance with housing laws.
Palo Alto is also part of a group of cities that are facing lawsuits from a coalition of housing advocates over its failure to adopt a certified Housing Element by the Jan. 31 deadline.
Read the full letter from the Department Housing and Community Development:
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by Gennady Sheyner / Palo Alto Weekly
Uploaded: Fri, Mar 24, 2023, 6:02 pm
Palo Alto will have to revise its plan to add more than 6,000 housing units over the next eight years after the Department Housing and Community Development (HCD) ruled on March 23 that the city’s proposed Housing Element fails to meet state law.
According to a letter that HCD Proactive Housing Accountability Chief Melinda Coy sent to the city, Palo Alto will have to make a host of revisions to its document before it can win state approval. Palo Alto submitted its draft Housing Element to the HCD in late December after nearly two years of public hearings. The letter means it will now have to perform further analysis and consider new housing policies.
The Housing Element is the city’s plan for meeting its state-mandated housing obligation, as set through the state’s Regional Housing Needs Allocation (RHNA) process. In Palo Alto, the allocation totals 6,086 housing units between 2023 and 2031, roughly three times the number in the current eight-year RHNA cycle. Of those, 3,465 would have to be below-market-rate units among various income categories.
Under recent changes in state housing law, the document also must demonstrate the city’s plan to “affirmatively further fair housing,” which means explicitly addressing and combating disparities that have resulted from past patterns of segregation.
The HCD determination was not a surprise. Nearly every city that has submitted its plans to the state agency over the past year was required to make revisions. To date, Redwood City is the only jurisdiction in the Peninsula that has received a passing grade from the state agency.
Earlier this month, Palo Alto Planning Director Jonathan Lait said that based on other cities’ experiences, he expected the HCD to request revisions. At the March 8 hearing in front of the Planning and Transportation Commission, he said he expected to see a “robust comment letter” from the HCD and that it might take several months for the city to obtain compliance.
“We already knew there are some things where we’ll need to make some adjustments before we even made the submittal,” Lait said at the March 8 meeting.
One area in which the city will have to make revisions is in its plan to affirmatively further fair housing. While the city’s assessment of housing trends focuses on regional data and includes information about various parts of Santa Clara County, the HCD directed city planners to dig deeper and to look at neighborhood trends and “provide appropriate programmatic responses to address ongoing patterns and trends.”
And while Palo Alto’s document identifies “racially concentrated areas of affluence,” it has not provided sufficient analysis on the factors that created the wealth in these neighborhoods, the HCD found.
“For example, the element could examine past land use practices, investments, quality or life relative to the rest of the City and region and then formulate appropriate programs to promote more inclusive communities and equitable quality of life,” the letter states.
The HCD also directed the city to be more specific in listing the levels of affordability in recently approved housing projects, which can be used as credit in meeting the RHNA allocations. The city divided its pipeline projects into market-rate and below-market-rate projects without detailing the affordability level in the latter category.
The city’s plan for creating 6,086 dwellings in the next eight years includes a host of strategies, including easing density restrictions in existing multifamily districts to allow for more units per acre; exploring construction of housing on city-owned parking lots; working with Stanford on two housing developments at university-owned sites; and encouraging the construction of accessory dwelling units. The most ambitious one, however, is rezoning manufacturing and light-industrial zones around San Antonio Road and Fabian Way to facilitate the replacement of existing commercial buildings with more than 2,000 housing units.
The HCD letter stated that the city needs to do far more work to convince the state agency that its biggest housing policy is actually viable. The city included factors such as development trends, ages of existing structures and community interest, among others, in making its case for the rezoning program.
But the HCD argued in its letter that the city must also include additional information about existing uses that “may constitute an impediment to additional residential development, past experiences converting existing uses to higher density residential development, current market demand for the existing use, existing leases or contracts that would perpetuate the existing use or prevent additional residential development or other relevant information to demonstrate the potential for redevelopment such as expressed owner and developer interest.”
“Based on a complete analysis the element may need to add or revise programs to facilitate redevelopment,” the letter states.
Similarly, the HCD is requesting more information about creating housing on city-owned parking lots, including a schedule of actions to facilitate the conversion and consideration of alternative sites that can be used if parking-lot sites aren’t identified by a date early in the planning period.
In addition, the city is required to take a deeper look into its own zoning practices and consider potential constraints on constructing housing in all residential zones. The analysis, according to the letter, should “address any impacts on cost, supply, housing choice, feasibility, timing, approval certainty and ability to achieve maximum densities and include programs to address identified constraints.”
The letter comes at a time when Palo Alto and other cities across the state are feeling ever greater pressure to get their Housing Elements certified. Because state law set a Jan. 31, 2023 deadline for Bay Area jurisdictions to get their documents certified, Palo Alto and most other cities are now out of compliance.
In some cities, including Los Altos and Mountain View, developers have proposed housing projects under a “builder’s remedy” provision in state code, which allows projects that exceed zoning regulations to advance without city approval in jurisdictions that are out of compliance with housing laws.
Palo Alto is also part of a group of cities that are facing lawsuits from a coalition of housing advocates over its failure to adopt a certified Housing Element by the Jan. 31 deadline.
Read the full letter from the Department Housing and Community Development:
Palo Alto will have to revise its plan to add more than 6,000 housing units over the next eight years after the Department Housing and Community Development (HCD) ruled on March 23 that the city’s proposed Housing Element fails to meet state law.
According to a letter that HCD Proactive Housing Accountability Chief Melinda Coy sent to the city, Palo Alto will have to make a host of revisions to its document before it can win state approval. Palo Alto submitted its draft Housing Element to the HCD in late December after nearly two years of public hearings. The letter means it will now have to perform further analysis and consider new housing policies.
The Housing Element is the city’s plan for meeting its state-mandated housing obligation, as set through the state’s Regional Housing Needs Allocation (RHNA) process. In Palo Alto, the allocation totals 6,086 housing units between 2023 and 2031, roughly three times the number in the current eight-year RHNA cycle. Of those, 3,465 would have to be below-market-rate units among various income categories.
Under recent changes in state housing law, the document also must demonstrate the city’s plan to “affirmatively further fair housing,” which means explicitly addressing and combating disparities that have resulted from past patterns of segregation.
The HCD determination was not a surprise. Nearly every city that has submitted its plans to the state agency over the past year was required to make revisions. To date, Redwood City is the only jurisdiction in the Peninsula that has received a passing grade from the state agency.
Earlier this month, Palo Alto Planning Director Jonathan Lait said that based on other cities’ experiences, he expected the HCD to request revisions. At the March 8 hearing in front of the Planning and Transportation Commission, he said he expected to see a “robust comment letter” from the HCD and that it might take several months for the city to obtain compliance.
“We already knew there are some things where we’ll need to make some adjustments before we even made the submittal,” Lait said at the March 8 meeting.
One area in which the city will have to make revisions is in its plan to affirmatively further fair housing. While the city’s assessment of housing trends focuses on regional data and includes information about various parts of Santa Clara County, the HCD directed city planners to dig deeper and to look at neighborhood trends and “provide appropriate programmatic responses to address ongoing patterns and trends.”
And while Palo Alto’s document identifies “racially concentrated areas of affluence,” it has not provided sufficient analysis on the factors that created the wealth in these neighborhoods, the HCD found.
“For example, the element could examine past land use practices, investments, quality or life relative to the rest of the City and region and then formulate appropriate programs to promote more inclusive communities and equitable quality of life,” the letter states.
The HCD also directed the city to be more specific in listing the levels of affordability in recently approved housing projects, which can be used as credit in meeting the RHNA allocations. The city divided its pipeline projects into market-rate and below-market-rate projects without detailing the affordability level in the latter category.
The city’s plan for creating 6,086 dwellings in the next eight years includes a host of strategies, including easing density restrictions in existing multifamily districts to allow for more units per acre; exploring construction of housing on city-owned parking lots; working with Stanford on two housing developments at university-owned sites; and encouraging the construction of accessory dwelling units. The most ambitious one, however, is rezoning manufacturing and light-industrial zones around San Antonio Road and Fabian Way to facilitate the replacement of existing commercial buildings with more than 2,000 housing units.
The HCD letter stated that the city needs to do far more work to convince the state agency that its biggest housing policy is actually viable. The city included factors such as development trends, ages of existing structures and community interest, among others, in making its case for the rezoning program.
But the HCD argued in its letter that the city must also include additional information about existing uses that “may constitute an impediment to additional residential development, past experiences converting existing uses to higher density residential development, current market demand for the existing use, existing leases or contracts that would perpetuate the existing use or prevent additional residential development or other relevant information to demonstrate the potential for redevelopment such as expressed owner and developer interest.”
“Based on a complete analysis the element may need to add or revise programs to facilitate redevelopment,” the letter states.
Similarly, the HCD is requesting more information about creating housing on city-owned parking lots, including a schedule of actions to facilitate the conversion and consideration of alternative sites that can be used if parking-lot sites aren’t identified by a date early in the planning period.
In addition, the city is required to take a deeper look into its own zoning practices and consider potential constraints on constructing housing in all residential zones. The analysis, according to the letter, should “address any impacts on cost, supply, housing choice, feasibility, timing, approval certainty and ability to achieve maximum densities and include programs to address identified constraints.”
The letter comes at a time when Palo Alto and other cities across the state are feeling ever greater pressure to get their Housing Elements certified. Because state law set a Jan. 31, 2023 deadline for Bay Area jurisdictions to get their documents certified, Palo Alto and most other cities are now out of compliance.
In some cities, including Los Altos and Mountain View, developers have proposed housing projects under a “builder’s remedy” provision in state code, which allows projects that exceed zoning regulations to advance without city approval in jurisdictions that are out of compliance with housing laws.
Palo Alto is also part of a group of cities that are facing lawsuits from a coalition of housing advocates over its failure to adopt a certified Housing Element by the Jan. 31 deadline.
Read the full letter from the Department Housing and Community Development:
Article on this critical topic covers a lot and is published just a few hours after the letter arrived. Impressive.
Looks like a ton of work for City Staff. The State is requiring a lot more detailed data and analysis, as well as complicated new programs.
Maybe most importantly, the State is demanding a lot of specific numeric commitments. I’m curious to see how this could possibly work, since the City can’t force property owners and developers to build, and they won’t do it themselves when it’s not profitable.
The idea that all you have to do is upzone and the market will build massive amounts of housing is definitely gone.
The city has had 4 recent pre screens where developers asked for waivers. Council said maybe but not all to 3 and said no to the 4th.
If they had said yes to all the upzoning we would likely have 4 projects.
I am not arguing that they should have but am arguing council can create feasible projects if they wish.
A while back they turned down a jobs to housing proposal on Fabian Way despite saying this is exactly what they want to happen.
The Fabian Way proposal may come back. Will be interesting to see what council does this time.
Feasible housing projects are being approved in other cities.
We can do it here if we wish
I’m sure you’ve seen Century|Urban’s analysis for San José: Web Link It concludes that high-density multifamily projects are infeasible in nearly all areas of that city. Most of the issues there are also issues here — cost of materials, cost of labor, financing.
Yes, it’s possible to build modest numbers of expensive, small housing units here. Going beyond that looks hard.
I would bet that all 4 of these upzoning requests were for fairly expensive housing.
It’s not really much work at all for the city to tally up what level of income was assigned to the approved projects in the city. Every project that is approved spells this out in terms of low income, very low income, moderate income etc. along with market rate. Palo Alto should also keep a tally of all the subsidized housing projects which exist already in the city and have for years. These very old projects have done a lot for inclusiveness in Palo Alto as to income levels. Many other nearby cities do not have so many subsidized housing projects. If history matters it seems to me it should be ALL history as to what exists to date.
Are the Bay Area cities the only affected by these politically driven ideas thought up by Government personnel? I never see Sacramento noted in any studies. What we have is government peronnel directing actions which have a financial and taxable impact on everyone with no vote by the taxpayers. I thought that was against the law.
These directions are not benefitting the cities affected – they are adversley reducing the tax base of the cities affected. They are adversley affecting the taxpayer’s tax base in their decison to live here then get surprised by the state government as to the direction that the state is going in – backwards.
The state used to have huge wealth. The state used to have well working utilities. The state used to have good transportation. Other states are passing use by here by making good decisions with support of the taxpayers and cities. These people were not on the ballot. They appear to have no recognition that every parameter used to arrive at numbers are no longer valid. They cannot admit the economy has changed.
As PHZ sites, these four projects are required to provide 20% of their units as deed-restricted affordable housing.
The State’s definition of “Low Income” households defaults to 80% of the median income for the area. About 40% of households in Santa Clara County fit that definition, and Palo Alto’s RHNA target for this category is also about 40%.
That means any project around here with only 20% below-market-rate housing is falling drastically short. Doubling that amount of below-market-rate housing, even though it’s not profitable to build, is one of the big unsolved problems with the State’s current approach.
“The State” is taking on protests from multiple cities across the state, north and south about these mandates. Most are making a lot of noise, some are getting covered by local tv media. Palo Alto is one of many not reaching the quotas only here residents seem divided more than most about whether or not this should be done, and how.
The real issue is why is the State doing this? And then who gave them the mandate to do this? The answer of course is the voters. I think it is time that voters paid attention to what they are voting for when it comes to elections. It is easy to think that just voting for liberals will help to get all the problems solved. The answer is that we are in this mess because of voters not paying the attention to exactly what the people they are voting for are planning to do.
Start paying attention everyone.
Since they’re again pushing AD’s as a solution, I think that every past and present Palo Alto politician, CC member, PTC commissioner, lobbyist, planner, developer etc. should step up to the plate and put an ADU on their front lawn and another in their back yard.
We’ve heard from the folks like Mark Andreesen that fund the YIMBY;s heavily and then get caught writing letters opposing multi-family dwellings near their $15.5MN manases,
Don’t be like Mark; show you’re not a hypocritical NIMBY who only spouts YIMBY verbiage until you’re caught by all the local and national media.
So paging all the politicians who “couldn’t wrap their heads around the housing issue” until they had to vote the next day.
How did Mark Berman vote?
Various Southern California cities are adding housing (market rate and some affordable) to shopping centers. Often it replaces parking lots. This could be done at the Stanford Shopping Center, to some extent at least. Underground parking garages are required to replace the lost parking and to create some for the new housing.
I just “love” how all the above comments really know or understand what it’s like to be housing insecure, vulnerable or totally without a non leaky roof. Until you’ve lived w out a solid code enforced true beam and wood pitched roof over your head, you will never ever understand. All the capitulating, yawning , conversational lean to and fro, will never, ever equate to the reality one child or senior experiences without the luxury of a solid roof over head. The fact that HCD is needing better understanding of a Com/Ind/ROLM area, smack along a polluted HWY 101! Hello. Vulnerable to sea level rise from the Bay, as well as soil contamination from God knows what!? It does not take an Ames NASA research analyst to figure this one out. Or more simply, absolutely zero planned amenities for those the “homes” are supposed to be there for. Reality check. And RIP. An 80 year-old senior was mowed down by a killing machine, Ford F 150 at Commercial & Charleston. No visible crosswalk, broad morning lite. Sadly, the elderly gent was just getting his morning constitution in. What loss — a human life in a PAHEWG designated area for … homes for all. Still and yet no area plan for infrastructure, bikes, schools, pedestrians , shopping. Stupid is as stupid does.
“How did Mark Berman vote?”
He voted to increase density soon after he wasted a few hours of 300+ people’s time on a Zoom, claiming he had too many bills before him that hejust couldn’t “wrap his mind around the issue” and was unaware of any of the pesky specifics about which he was asked during the Zoom.
I think we need a grand jury to investigate if Newsome or one of his cronies is raking in cash from developer kickbacks. I’m rapidly becoming GOP as this c*rap goes on. If you don’t make it all below market rate it is obviously impossible to build ourselves out of the lack of affordable housing.
RDR: Stanford defers to their ground lease holders, eg Stanford Shopping Center who wants to build a hotel, not housing in the parking lots. Stanford writes the leases in a way that gives the leasee control and has no interest in doing otherwise because its so profitable.
While the “low income” categories are below 80% of area median income, the state and RHNA have requirements on the cities to also produce housing affordable to “moderate” income levels of between 80% and 120% of area median income. So Palo Alto for example is required to produce 6000 units of housing, 2600 of which are market rate, and then 1000 which are affordable to those household making 80-120% of AMI, meaning that only around 2400 are targeted at some level of “low income” household.
Producing the housing affordable to “moderate” income levels above the poverty level but still not at market rate is an actual part of the requirements put forth to ALL cities. It’s affordable but not for poverty level households.
Any requirement by the state for the city to produce below market housing is an undunded mandate, which I believe is against the state constitution. The city can zone for but does not build. Of course that does not stop the state from trying. Much easier than actually properly funding it with state funds.
How about the city tells the state that they’ll send in a new housing plan once the state fixes the potholes on El Camino?
I hope this results in increase of high rises apartments. Higher zone buildings is the best way for the housing crisis to be addressed.
The number makes no sense. How was that number derived? Did city personnel provide data to this group or did it arrive at that number on it’s own. I think we all need to get to the bottom of how these numbers are arrived at. It did discuss in the papers today that they are actively trying to increase density in the bay area counties but this is absurd. In the Real Estate Section of the weekend papers they have all of the new housing efforts out there now in Norcal. There are a lot of offerings in two-story homes less than $1M in well-planned communities.
We need to get Mr. Berman to report on the process that arrived at this number and why he voted for it. I am sure that Mr. Weiner is the creator of this total mess. The city he comes from – San Francisco is in giant trouble. People do not want to live there. When people and companies leave that reduces the tax base of the city which pays for all of the services.
If any of these politicians have aspirations for higher office then they need to be accountable for taking actions which backfire on the economy. They are dragging this state down. And we are not the 4th or 6th biggest economy in the world. When the Governor makes absurd staement like that he is limiting his future in politics.
All I can do is shake my head at the futility of it all. When this state continues to allow more and more commercial/industrial buildings to be built in areas already lacking adequate housing, yet not require the developer to provide adequate housing/and infrastructure in their plans is it any wonder we end up in the mess we are in? We have LIMITED space available in San Francisco and the entire SF peninsula. I suppose we should applaud the efforts of all the cities to accomodate the state mandates, however as Eeyore states, ” If you don’t make it all below market rate it is obviously impossible to build ourselves out of the lack of affordable housing.” I’m also in agreement with what Bystander said-“And then who gave them the mandate to do this? The answer of course is the voters. It is easy to think that just voting for liberals will help to get all the problems solved. … we are in this mess because of voters not paying the attention to exactly what the people they are voting for are planning to do.” Check out the history of Hong Kong and then imagine it CAN happen here.
@Smrty, totally agree with you about voters not paying attention. This whole housing push is all to keep the political contributions coming from the developers and big tech and little or nothing to do with affordable housing which remains an unfunded mandate and which will get even more expensive to build as interest rates keep rising.
SO tired of well-paid lobbyists and politicians laying guilt trips on the rest of us while they’re focused on providing more market rate housing to those earning above the average income.
First they pushed ADUs as helping to preserve families by letting Grandma and the disabled son stay in Palo Alto. Then the cities ruled rents can’t be discounted or even free for friends and family in need because the city would ASSUME rents were equal to what surrounding properties rented for to strangers so poor Grandma and the disabled son got nothing — if they ever existed beyond the pr campaigns.
Repeal article 34 and let the state get into the business of building housing. Modify Prop 13 and walk back the the burden of property tax to the commercial side like it was before we dropped it onto homeowners. These are known quantities in solving the housing problem.
Horrible article in the SFC 03/30 – “Bill Targets cities that try to stop housing” – Dustin Gardner. Matt Haney – San Francisco is submitting a bill that will involve the Attorny General if cities do not meet their goals. Matt Haney’s city has not met it’s goals. The Chronicle has a huge list of articles concerning this topic which point out the problems being encountered. The SF Board of Supervisors have pointed out the problems with meeting the goals.This article makes it sound like everyone is delibertly avoiding the whole problem. In other articles the SFC has pointed out that the state has received funding but not releaed the funding for cities to use. What a mess – no one reads the papers they work for, the people who submit bills have their own issues in their own cities, and where is the money?
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