Does Sustainable Development Cost Developers Less?

Lewyn is correct when he characterizes Fulton's RPPI report as diametrically opposed to my views. I included the reference as a measure of counterbalance not support.

Fulton's work in Ventura county is technically worthless. Setting aside his confusion of cause and
effect conclusions, Fulton used faulty data. There is no affordability
crisis in Ventura County, prices are rising but time on market is not changing from historical norms.
Were the housing truly unaffordable the reverse would be true. What has
happened is far simpler, housing in Ventura County is far more desirable
-because- of the strict development policies he cites. Fulton is incorrect
that the "plans" do not reflect reality, the truth is that the plans express
planner wishes to produce an unrealistic outcome. The "planned densities"
that are rarely approved were and are not targets they are caps. The
cumulative effect of capped density combined with the inevitable
unanticipated development has actually resulted in increasing densities far
above every General Plan in the County. The "housing shortage" is in fact
nothing more than our MPO, SCAG dumping an excess of housing "demand" on
those the sub-regions with the least political power (or will) to object.
SCAG calls this their "fair share" housing target as part of State mandated
regional planning. Ask yourself where the 12 million LA County residents
would prefer the additional 9 million new residents expected in the existing
region of 16 million would locate?

I won't burden you with the technical analysis of Fulton's 55% housing
shortfall that is only 9% using his own worst case numbers unless you are
interested. Suffice it to say that Fulton's "inner planner" is threatened
by things like Ventura Counties' SOAR and Californias' Prop 13 type
populism. Heck, he's not only a critic, he's on the city council!

Then Solimar President and now Ventura city councilmember
Fulton lied in order to advance an agenda. It's been a long time but let me
dig up my collective refutations of the assumptions used by Fulton. This is
gonna be long but you brought it up and I have done the work. The essence
of the lie is that Fulton tries with statistics to show Ventura County
"closing the door" to its' "fair share" of a then expected massive influx of
SoCal population. The methods he employed were to use the highest numbers
from the largest study areas at the worst case and then compound each and
then extrapolate forward from the highest rates he could assemble. Lucky
for me the last 4 years of data have proven me right and Fulton wrong.

First the math errors:

In “Smart Growth in Action” Fulton wrote:
-----
Ventura County will likely need at least 312,000 housing units
by 2020—a projected increase of 60,000 units (24 percent) over
the 2000 housing stock of 252,000 units. This is close to the
estimate that advocates of SOAR used as they urged citizens to
pass the initiative. Yet, under current policies, the planned
capacity of the county is targeted at somewhere between only
293,500 and 298,500 housing units—an increase of between just
41,500 and 46,500 units, or 16.5 percent and 18.5 percent over
the existing housing stock. This, however, is the highest number
that might be approved. Since 1996, cities in Ventura County have
approved development projects at densities much lower than planned
capacities, generally falling 20 percent below zoned capacities
and 45 percent below General Plan capacities. Thus, the likely
future housing development in the county under current planning
policies and entitlement practices will generate about 33,000
units: 55 percent below the regional planning agency’s housing
target for 2020.
-----

The regional housing “target” for 2020 is 312,000. The shortfall Fulton
projected as 14,500 to 19,500 is a shortfall of (14,500/312,000 to
19,500/312,000) units or 4.6 to 6.3 percent of the theoretical projections.
Even using Fulton's worst case scenario of final approvals trending 20 to
45% below max design densities (not capacities BTW) the shortfall becomes at
his compounded extremes, 80% of (293,500 – 252,000) or 284,000 DUs. And an
inconsequential 9% shortfall using Fultons lowest values for each
projection.

That's the math part were a percentage of a percentage makes for a scary but
mathematically useless number. The real failing in Fulton's planner based
hatred of Ventura County land use policies lies in his presumptions. I said
presumptions not assumptions because that's precisely what is going on. The
regional planners of SoCal are presiding of an insanity projection and they
desperately want Ventura County to join in the insanity so they look less
insane on average.

Recognize the sleight-of-hand baseline Fulton used with his shift to
SCAGs “fair share” recommendations when he mentions “the regional planning
agency’s housing target for 2020” but I find it out of context when there is
no mention of SCAG as being identified as the regional planning agency when
the discussion is supposedly one of Ventura County. Additionally many are
familiar with the “off the record” explanation SCAG has given for the
exporting of “fair share” housing allocations to the outer areas. So, in
short if you want to use scary
numbers like 55% shortfalls you need to make clear that you are changing
measures from the Legal/planning authority of city/county to the
recommendations of the LA dominated coordinating agency that has no planning
power.

From my discussion with Mr. Fulton:
[with permission and apologies for the local color]

Thank you for your comments. Let me clarify our numbers.

1. What is the percentage shortfall?

If I understand your argument, you believe it is misleading for us to
characterize the potential housing shortfall in terms of the projected
increase in housing, rather than the overall amount of housing.

That is:

Currently there are 252,000 housing units and the SCAG housing target, if
one accepts it, is to increase that number by 60,000, to 312,000 units.

Our report states that we believe the plans have an overall capacity of
41,000 to 46,000, and that since projects tend to be approved at somewhere
around 80% of plan capacity, we believe that the actual likely increase in
housing under current plans is about 33,000 units, for a total of 284,000
units, or 28,000 units below the SCAG target..

We note in the report that 33,000 is 55% of 60,000. I believe that you would
have preferred that we state that 284,000 is 91% of 312,000.

I would have no problem with you worst case 55% number -if- you can
reasonably distinguish the stock of 1 year old to 10 year old housing -from-
the existing stock of any age as it relates to this supposedly -separate-
category of total stock. Seeing as once a house is sold for the first time
it becomes part of the total existing stock I think you've set for yourself
a very difficult task. Wouldn't it be much easier to call the shortfall 9%
in your worst case projections rather than assuming as you do an ongoing
pessimistic environment of lowest (below trend) approval rates and highest
(above trend) sustained population growth rates and unprecedented reversal
of demographic (persons per DU) trends?

Once SCAG's [I note, you didn't address Mark Pisano's SCAG excuses]
assignment of "fair share" is adjusted to represent the actual documented
trends (FI, higher persons per DU) and a regional proportional share (rather
than the controversial "fair share") and you acknowledge that your use of
mid-90s rather than the long term basal growth rates for the county and you
account for an average approval rate for new housing and you factor in the
exogenous addition of "unanticipated" housing you will find that not only
does your theoretical shortfall disappear but we have a surplus relative to
trend. Factor in the outstanding pre-approved developments (approx 14,000)
and the theoretical surplus balloons. Example time. Take Oxnard, please.
(Note to trans; Oxnard is the proverbial punching clown of municipalities,
hit it and it comes back for more and never learns.) Oxnards' just
"managed" to "approve" another 402 house west of Patterson Rd. and north of
Gonzales. County policy has been since 1982 that there will be no
development there. Things change for the more and denser as well as for the
less dense.

I know that's a big first sentence (even for a planner ). Let's
deconstruct. (Most is familiar to you but for the benefit of the general
audience.)

-SCAG saying that 312,000 DU are needed.-

Southern California Association of Governments (SCAG) region; Los Angeles
County, Ventura and Orange Counties, San Bernardino and Riverside Counties,
and Imperial County. Where you and I live it is about 300 miles to the other
side of this "region." The regional housing needs is based on the regional
growth. Riverside and San Bernadino counties along with the LA County
Antelope Valley experienced unprecedented growth in the last two decades.
Averaging out future housing demands from such disparate places is the
equivilant of an anorexic and obese person standing on the scale dividing by
two and thinking they are normal. As a specific, sub-region North Los
Angeles County aka the Antelope Valley is expecting a 150% increase 2000 to
2020 adding roughly the entire current population of Ventura county to the
study area. Thus the old joke that I'm sure you've heard in the halls at
SCAG; "Q: What do you get when you combine Ventura, Los Angeles, San
Bernadino, Riverside, Orange and Imperial Counties? Ans: Los Angeles."

IMO your use of the advisory SCAG "fair share" allocation is merely fishing
for the highest believable number.

-The trend to dramatically increasing persons per DU.-

Frankly, except for Oxnard, this surprised me. The 2k census:
http://quickfacts.census.gov/qfd/states/06/06111.html
Showing 3.04 persons per DU basically cuts the future number of DUs by 6%
right upfront and, if the trend continues, another 3-5% every decenial
period.

-The blip in basal growth rates last decade.-

As you know different places grow at different paces. LA has always grown
faster and now Ventura is tossed in with San Bernardino and Riverside as
well. This doesn't change our growth only the expectations of our fair
share as part of a larger place that is suffering quite visibly from their
internal growth. Ventura has recently (1983 to be picky) increased their
population growth rate. Perhaps permanently but once again I find your
projections to be a compounded extreme. Pick the highest housing needs.
Pick the highest historical growth rate. All numerator values. As we see
below your projections then switch from highest projection to lowest
believable projections or data whichever is lower.

-Existing "stock" of demand dependent approvals.-

Plannerspeak, I apologize. As you know there's a popular fiction out there
in the Counties' cities about "limiting annual housing allocations." Yeah
right. You and I know full well that in addition to the ongoing rate of
construction there exists a large pool of pre-approved housing. Were you to
use the approval rate instead of actual housing starts as I said above your
number of shortfall would be wiped out. Another case of choosing the most
extremely favorable number you can find.

-The trend of approving far in excess of CEQA reportage.-

Oxnard (and Camarillo and Moorpark) lie. IMO Camarillo lies the most but
that's only opinion. Oxnard being the most inept at masking their agenda is
the easiest target. Hey as a personal aside, did you know thar community
development director, Matt Winegar now lives down the street from me in
Sterling Hills over in Camarillo? Sends his kids to the Mesa Union School
with mine. There's an endorsement eh?

I believe that the math is correct in both cases. As we were discussing
likely future housing production, we chose, as researchers and analysts
often do, to characterize the potential shortfall in terms of future growth
rather than the base.

Formal mathematics notwithstanding that is not a "housing shortfall." You
are describing a construction shortfall. You want to describe a
construction shortfall? Fine we aren't building housing units at a rate
sufficient to match a mega-regional demand calculation as disproportionately
burdened on our sub-region. That's the extent of your 55% shortfall. For
more perspective put it in context of either the US or just California. If
you do that then you can report Ventura County is ahead of state and
national trends in accommodating their area growth in households.

2. SCAG's role and SCAG's numbers.

SCAG is obligated under state law to allocate needed regional housing on a
jurisdiction-by-jurisdiction basis, and the jurisdictions are obligated
under state law to attempt to meet local housing need in a regional context,
though of course they can challenge SCAG's numbers, which many are doing.

Lets look at which "jurisdictions" (a word for the actual
responsible planning agencies) are objecting to SCAG's (-coordinating- not
responsible for anything more than internal agency) "allocation." Easy, the
politically under represented and the outlying responsible agencies which
"coincidentally" are also the over allocated agencies. Come on. You talk
to Piasno as I do. You know that not only is the SCAG allocation
disproportionate but as a researcher you know their population projections
are questionable.

I hear rumblings at high levels that SCAG has failed to find a purpose that
satisfies anyone. Places like Ventura County are pissed that SCAG blindly
adds Newhall Ranch to RTPs and growth projections, the Valley is pissed that
they can't get answer to any questions that favor their analysis but
negative assessments appear regularly. The whole place is worried that if
SCAG ever gets any power, it will become an LA city political enforcer. The
joke among a lot of us is: Q: What do you get when you combine LA, Orange,
San Berdoo, and Ventura counties? Ans: LA County.

There's a lot to that. Any guesses where the 12 million would vote to
put the new landfill?

In
the meantime, the SCAG figure was the only government-adopted target
available to us on a countywide basis.

Not true. CEQA. Mandatory state documents. 20 year general plans
inclusive. Tom Berg will give them to you if walk in. Need an intro?

It may be that SCAG is "fiddling" with the numbers to export housing to
outlying counties, but we did not believe it was the purpose of this study
to second-guess whatever targets SCAG sets under a process required by state
law.

But you -did resort to second guessing- when the subject was SOAR and the
purpose of SOAR with respect to exactly the same thing. Don't you see the
contradiction? Your assumption that SOAR would not influence trend while
trusting that SCAG was defining the trend. IMO neither is all right or all
wrong BUT I do think consistency is in order and I don't see that in your
projections.

We hope to do more sophisticated housing demand analyses for Ventura
County in the future.

Don't restrict it to just demand. You weren't around in 1988-89 when the
Oxnard 2020 general plan was being "debated." Ralph Shumacher was on the
committee. He later admitted that the CEQA numbers were literally divided
by three so as not to shock the voters. He was right. I got up and said;
"No development west of Patterson" three times and then LAFCO exec Stan
Eisener (sp?) said in support; "what he just said." You know what happened
last month? That's right development west of Patterson that is not in SCAG
or CEQA or Vcounty projections.

In any event, as I have stated repeatedly in public since our report came
out in December,

Doesn't it seem at all worthy of immediate reconsideration given the amount
of objection?

no matter what anyone might think future housing demand in
Ventura County is or should be, our analysis found that likely future
housing production under existing plans is 33,000, which represents only a
13% increase over the current housing stock -- a number likely to be
insufficient over the long term under any scenario.

This is where we can disagree respectfully. I think worst case is not
possible in the real world with so many variables interacting. As a
respected researcher you know that cumulative variation is a small fraction
of the total worst case maximum variation yet you persist on using exactly
that type of worst case. At that you acknowledge that your worst case is
not recursive in that it does not assume any effect of supply restriction on
demand.

3. Assumptions of growth under SOAR

I am a little confused about your comments about the impact of SOAR on urban
growth patterns. In your letter to me, at the very end you seemed to suggest
that we should not have assumed that current growth rates would be
maintained under SOAR.

Yes. I agree it is a nonlinear relationship. I would present in rebuttal
the numerous claims to the contrary. Yours included. This is one of my
objections to your generally evaluation of SOAR.

I would point out that (1) SOAR did not alter zoning
or land-use regulation on a single parcel of land in Ventura County, and (2)
Smart Growth advocates frequently argue that the purpose of urban growth
boundaries such as SOAR's is not to suppress growth but to channel it into
particular geographical locations. I plead guilty to using these as
underlying context assumptions.

Guilty in a good way. I am constantly battling the (1) misperceptions you
correctly describe. SOAR only changes the venue of land use change approval
from the Board/Council to a public majority vote. The first serious
proposals are likely to be Santa Paula Canyons and Moorpark again.

I do, however, resent the Smart Urban Growth (SmUG) parallel advocacy claim.
SOAR is in no way an UGB. You know this and in fact just said so in the
preceding sentence where you make it clear that SOAR did nothing in the way
of Nurbanist rezoning agendas. I would separate the causal truism that SOAR
prevents outward urbanization from the unassociated effect that the
urbanization -must- turn inward. NURBs would like that to be the case but
it is not part nor intent of the SOAR plan. Gerard Kapuscik and I would
love to have you over to discuss this further.

Sorry for the delay in responding. I spent a lot of time looking at your
sprawl_color.pdf looking for enlightenment.

----end fulton exchange----

Likewise, inclusionary zoning mandates--requiring some homes be sold below
market prices at "affordable" rates--leads to cuts in housing supply as well.
See _http://www.rppi.org/ps320.pdf_ (http://www.rppi.org/ps320.pdf)

It's worse than the report indicates. Affordable housing advocates don't
like this but all of their schemes involve
"sharing" as in "we are going to take your money, limit your investment
potential and make your neighborhood less desirable."

The upshot is that it is not "impossible" to restrict housing supply, in
fact it is a frequent occurrence.

I never said anything of the kind. I said it is impossible to have a
persistent housing shortage. It's easy to restrict supply, even demand but
as long as there is a market, there will be no shortage. What you see and
want to call restrictions on supply are actually quality of life and
homeowner asset protections.

Regards,
Robert

[References below]

Adrian Moore
Reason

And?

Seriously. You got low taxes, high equity, admirable quality of life, etc.
I live 50 miles west of Los Angeles so I know. Do you ski? I've got a ski
cabin up in Wrightwood, we could bust some middle aged sized moguls. ;-)

There's a lot of competing interests pushing and pulling SoCal housing
prices. Liberal and/or Conservatives are not among those reasons.

Let me say this loud and clear:

THERE IS NO HOUSING SHORTAGE.

It's impossible. What we have is an excessive and unreasonable
(unsustainable) housing demand. It isn't supply constricted it is demand
overloaded. Big deal. We (you and I) were smart and lucky and in the right
place at the right time. Sue us. Just don't rumble on in with bulldozers
and guns and take our QoL and give it to other people.

I've had my eye on 3 acres on the coast just south of Santa Barbara. My
Brother-in-law bought it for 1/4 million and the only fair thing is that he
sell it to me a fair price or else be forced to subdivide so more can enjoy
what he has.

Regards,
Robert

Publications:

"Smart Growth in Action: Housing Capacity and Development in Ventura
County," a report by Ventura-based Solimar Research Group and the Reason
Public Policy Institute: http://www.rppi.org/ps288.html

"Smart Growth In Action, Part 2: Case Studies In Housing Capacity And
Development From Ventura County, California," by Solimar:
http://www.solimar.org/pdfs/ps311.pdf

"Raising The Roof: California Housing Development Projections and
Constraints, 1997-2020," a report by the California Department of Housing
and Community Development: http://www.hcd.ca.gov/hpd/hrc/rtr/int1r.htm.

"Locked Out: California's Affordable Housing Crisis," by the California
Budget Project:
http://www.cbp.org/2000/r0005loc.htm

"Sprawl Hits the Wall: Confronting the Realities of Metropolitan Los
Angeles," a report by the Southern California Studies Center at USC and the
Brookings Center on Urban and Metropolitan Policy:
http://www.brook.edu/es/urban/la/abstract.htm.

"Out of Reach 2003: America's Housing Wage Climbs," a comparison of wages
and rents in every county in the nation by the National Low Income Housing
Coalition: http://www.nlihc.org/oor_current/

"Farming on the Edge," a report by the American Farmland Trust on the loss
of farmland to urban development:
http://www.farmland.org/farmingontheedge/index.htm

Regional organizations, programs
• Bay Area Alliance for Sustainable Communities :
http://www.bayareaalliance.org/

• California Center for Regional Leadership:
http://www.calregions.org/home.php

• California Futures Network: http://www.calfutures.org/.

• Great Valley Center: http://www.greatvalley.org/

• Joint Venture Silicon Valley: http://www.jointventure.org/

• Metropolitan Forum Project : http://www.metroforum.org/index.php

• San Diego Dialogue: http://www.sandiegodialogue.org/

• Tri-Valley Business Council: http://www.trivalley.org/

• Valley Vision: http://www.valleyvision.org/

• Greenbelt Alliance: http://www.greenbelt.org/

• Placer Legacy Open Space and Agricultural Conservation Program:
http://www.placer.ca.gov/planning/legacy/

• Sonoma County Agricultural Preservation and Open Space District:
http://www.sonoma-county.org/opensp/

• Center for Livable Communities: http://www.lgc.org/center/

Local organizations
• SOAR: http://www.soarusa.org/

• Ventura County Civic Alliance: http://www.vccf.org/civicalliance/

• Ojai Valley Land Conservancy: http://www.ovlc.org/

• Ventura County Planning Division: http://www.ventura.org/planning/

• Ventura County Farm Bureau: http://www.vcfarmbureau.com/

• Ventura Local Agency Formation Commission:
http://www.ventura.lafco.ca.gov/

• Ventura County Transportation Commission:
http://www.goventura.org/

• Ag Futures Alliance: http://www.agfuturesalliance.net/

Industry and professional groups
• National Association of Home builders: http://www.nahb.org/

• California Association of realtors: http://www.car.org/

• California Building Industry Association: http://www.cbia.org/

• American Planning Association, California Chapter:
http://www.calapa.org/

As to free parking:
http://exurbannation.blogspot.com/2005/10/free-parking.html