South Pasadena
A local Watchdog alerted staff at Abundant Housing LA and YIMBY Law that South Pasadena’s preliminary housing element materials and methodologies were not looking good. Our organizations looked into it, and we responded accordingly, speaking to five major problems we observed: Likelihood of Development, ADU projections, ADU affordability, Site Inventory, a proposed Inclusionary Zoning ordinance, and Affirmatively Furthering Fair Housing.
March 10, 2021
Joanna Hankamer
Director, Planning and Community Development City of South Pasadena
1414 Mission Street
South Pasadena, CA 91030
Dear Ms. Hankamer,
We are writing on behalf of Abundant Housing LA and YIMBY Law regarding South Pasadena’s 6th Cycle housing element update. Abundant Housing LA is a pro-housing, nonprofit advocacy organization working to help solve Southern California’s housing crisis, and YIMBY Law’s mission is to make housing in California more accessible and affordable through enforcement of state housing law. We support more housing at all levels of affordability and reforms to land use and zoning codes, which are needed in order to make housing more affordable, improve access to jobs and transit, promote greater environmental sustainability, and advance racial and economic equity.
In September 2020, AHLA shared a letter with you expressing serious concerns about the City’s 2021 Housing Element Update - Preliminary Sites Analysis from the July 21, 2020 Planning Commission Agenda Report. Since September, the City has continued to take steps that are inconsistent with HCD’s instructions and the AFFH requirements of Assembly Bill 686. Rather than accommodating housing growth at all levels of income in good faith, the City appears to be developing a housing element that will placate local opposition to more housing.
The following issues are of particular concern to us:
Planning’s process for selecting sites and assessing their capacity fails to account for parcels’ likelihood of development, and its map of best candidate sites appears to include many sites where redevelopment is extremely unlikely.
Planning continues to make overly optimistic forecasts of future ADU production which are unlikely to be achieved even with aggressive policies.
Planning misinterprets a SCAG analysis of regional ADU affordability to suggest that a significant share of future ADUs in South Pasadena will be affordable to lower-income households, which is unlikely based on local rent data.
Planning indicates that the proposed Inclusionary Housing Ordinance will help the City achieve its lower-income RHNA targets without a clear assurance that this program will be accompanied by adequate zoning densities.
Planning fails to affirmatively further fair housing and break existing patterns of residential segregation in their site selection and their general approach to the housing element update, despite the City Council’s recent adoption of a resolution to acknowledge “past practices of institutionalized racism” and a commitment to being an inclusive community in the present (Item 11, February 17, 2021).
