This time you cannot blame the forces of “slow growth” or the neighbors. In fact, at their January meeting, the neighbors made their peace with the proposed hotel – gaining a key concession in the rear height and a neighborhood improvement fund.
Instead, the extended stay Hyatt House hotel, with its 118 rooms, which the council unanimously approved, is put on hold due to a competitor.
The “group” filing the suit is “Davis Smart Growth Alliance,” but it is pretty clear, once again the name is an “astroturf” organization. The only named entity is Roshan Patel, owner of the Holiday Inn Express and Suites – a nearby competitor to the approved hotel. Mr. Patel had sent a letter in January threatening legal actions.
He wrote at the time, “The City is adding an unsustainable amount of hotel rooms in inappropriate locations without any new demand generators. This will ultimately lead to devastating effects to existing hotels including but not limited to closures, abandoned buildings, homeless encampments, deferred maintenance, blight, and other environmental issues.
“I’d like to remind the Council that adding hotels without any new demand generators is not going to solve any of the [City’s] financial problems and it is not a community benefit for anyone. Please oppose the Hyatt House Hotel based on Davis’s smart growth policies,” he wrote.
Mr. Patel warned, “If the City continues to ignore my concerns, I suggest the City prepares to govern itself accordingly in the Court of law based on an invalid environmental impact report and breaking zoning and land use laws.”
He argued, “The EIR inadequately addresses potential impacts of urban decay of existing hotels in the community. Additionally, based on section 65860 of the California Planning, Zoning, and Development Laws – I have reason to believe the project is in violation of planning and zoning law as the Hyatt House Davis project is not consistent with the city’s General Plan Land Use policies and the South Davis Specific Plan policies.”
Mr. Patel is represented by Patrick Soluri, from the Sacramento-based Soluri Meserve law corporation. Mr. Soluri believes that the council has basically abandoned sound land-use policies in order to chase revenue.
Here we go again. The Embassy Suites hotel was delayed by a lawsuit that led to a reduction in the size of the hotel and the virtual abandonment of the all-important conference center. The 120-room Marriott Residence Inn at 4647 Fermi Place is also caught in a lawsuit, this one regarding the habitat of burrowing owls.
But this current one seems less about land use or the environment and more about competition.
Last year, the city contracted contracted with HVS Consulting & Valuation in order to get an independent assessment of the hotel market demand. HVS concluded that “the near-term development of a conference hotel facility with the addition of an extended stay hotel to be built shortly thereafter would be most beneficial to visitors, the City of Davis, other hotels in the market, and the overall community.”
However, HVS concluded “that the addition of another hotel, specifically another extended-stay facility, would not benefit the market for another four to five years after the initial extended-stay hotel has opened.”
The more optimistic study was the PKF Consulting study, which projected that four new hotels could ultimately generate between $1.5 and $2 million in new revenue for the city just by themselves.
They found that 18,000 square feet of meeting space could include between 500 and 1000 attendees, depending on the type of function. “A hotel with approximately 18,000 square feet of meeting space would typically feature between 350 and 400 guestrooms,” they note. But the Embassy Suites will have just 132 rooms, which means that Davis will need other hotels to complement the Embassy Suites in order “to capture either overflow group demand that is booked at the Embassy Suites (but can’t be accommodated).”
PKF argued that at least three new sites can be “readily absorbed by the market,” and they found “occupancy is projected to increase to 67.0 percent in 2019 and further increase to approximately 70.0 percent in 2020 and 2021. It is at this level we project the Davis hotel market to stabilize. While this stabilized occupancy level is above the annual average occupancy level achieved by the Davis hotel market since 2007, it is in line with the year-to-date performance and is reflective of the growth occurring in Davis.”
But the conference center is no longer planned at this time to accommodate 18,000 square feet of meeting space, and, in January 2016, when the Vanguard met with existing hotel owners, their analysis painted skepticism about the claims of the PKF study.
While the city is looking to new revenue sources to close huge holes in its budget, existing hotel owners are concerned that new facilities will lead to existing hotels closing and the deterioration of certain areas of Davis.
That fear seems to be at least somewhat realistic, but it remains to be seen whether it is a legally actionable one. Moreover, the council had all of this information at their disposal when they approved the project six weeks ago.
For their part, the city doesn’t believe that the lawsuit has merit. But what it does is, once again, delay timelines for construction and opening the new hotel, delay the receipt of tax revenue for the city, and once again increase the cost of business.
It’s one thing if this is done on behalf of the citizens of Davis. But, in this case, the neighbors have no involvement, they made their agreement with the developers and have made their peace.
Planning by litigation is becoming a fact of life in Davis – and not a good one. The people of Davis elect the city council to represent the interests of the community. We have a long process filled with opportunities for citizen engagement.
It is unfortunate that a monied interest can come in at the 13th hour and derail the process in such a self-serving way.
—David M. Greenwald reporting
That’s what I was wondering. Can one sue basically because of competition? It sounds frivolous to me.
It’s time the city turns the tables and takes whatever means it can use to stop actions like this.
Countersue? Somehow make the litigant have to pay a price if they lose a lawsuit.
An ancillary issue to the one Keith has described is how the litigant can prove that “The City is adding an unsustainable amount of hotel rooms in inappropriate locations without any new demand generators.”
How would anyone prove (or disprove) the unsustainability of the additional hotel rooms the Council has approved?
Is the presence or absence of “new demand generators” a reasonable criteria? The litigant appears to be ignoring the level that existing demand generators are contributing to market demand.
Matt, exactly.
Even if the demand weren’t already in place it still could be a case of ‘build it, they will come’.
“Somehow make the litigant have to pay a price if they lose a lawsuit.”
Although I have no intrinsic interest in this issue myself, I see a two edged sword here. Because one sees a particular lawsuit as “frivolous” or “self serving”, do we really want to change our processes based on that perception ? There is a huge danger here if the next time it is you that has what you consider a completely valid grievance, but the city uses the threat of retaliatory damages against you if you lose. Would this not have a chilling effect on the ability to use the courts for completely legitimate redress of grievance ?
It would force litigants to have a valid case before they pursued what are often times frivolous lawsuits. How do you feel about a party being frivolously sued? They will be forced to pay to defend themselves and lose business/revenue, shouldn’t they have recourse to make themselves whole again?
What “grievance”? Were ‘rights’ violated? The ‘right to a corner of the market’?
In my opinion, a hotelier (no any business, for that matter) has no ‘vested right’ in a given level of business/profit.
That’s my thinking. In my view they’ll cloak the lawsuit in CEQA, inadequacy of the MND or something.
CEQA is an essential tool for decision making… but using a hammer to drive a screw is not a good idea…
Keith
My problem is who gets to be the final arbiter of that ever so subjective word “frivolous”. I have been on several occasions named in law suits that were ultimately determined to be unwarranted since the evidence offered was not found to support the claim. On neither occasion did I wish any retribution on the claimant who I felt in each case had basically been convinced by a lawyer that they had a case, when anyone familiar with the situations and acting in the patient’s best interest would have known they did not. I do not blame people who have experienced, or in this case anticipate, a poor outcome from seeking redress. I do blame lawyers for what I consider unethical behavior.
If your suggestion was that there could be some form of definitive criteria agreed upon for what constitutes “frivolous” that was clear and unequivocal, then I would agree with your point. But I do not hold the standard of “I can’t tell you what it is but I know it when I see it” to be adequate.
Ultimately a judge is the arbiter.
“Ultimately a judge is the arbiter.”
Well that is certainly how we do it now. But if that is the case, then the lawsuit would seem to me to be the only way to get to the final judgement of what is “frivolous” and what is not, which does not support anyone’s argument about making “frivolous” lawsuits since the decision is made at the end of the process, rather than early on. If there was more clarity about what is and what is not “frivolous” perhaps fewer people would “roll the dice” hoping for a favorable settlement, thus saving everyone concerned time and money.
Off the top of my head I think England and France make the loser of a civil lawsuit pay the ‘reasonable’ court costs of both parties. Sounds ‘reasonable’ to me.
What is your alternative approach, Tia?
To add to David, ‘and someone has to pay to defend the suit, or be prepared to pay a form of extortion (aka “settlement”). In the meantime the blocked applicant also has to deal with real time/money costs of delay (inc. interest rate changes for financing, CCI, etc.) as the litigation moves forward on its often gastropod pace.’
This particular one may be deemed a “late hit” (in the view of someone in a black robe), if the issue was not brought up during the review, or if it was brought up, and addressed in the public record, during the project review by the City.
In football, a late hit is penalized… see no reason the same shouldn’t be done for this type of litigation… civil suits often have provisions for the plaintiff to pay all the defendant’s costs of litigation, if plaintiff does not prevail…
Honest (general) questions, regarding this statement. For the sake of discussion, I’ll assume that you’re talking about the EIR.
If an issue was brought up, would the “conclusion” be vulnerable in a lawsuit? Or, if the conclusion was that there would be an unavoidable impact, and the city certified the EIR and approved a development regardless, does that put the city at risk in some manner?
Also, what about potential issues that weren’t brought up during an EIR (or the review process), but are brought up later (via a lawsuit)? (Is it necessarily too late to do so, at that point?)
I think I’m diving into legal questions.
On a separate note, I agree with Tia’s response regarding “retaliation”, although I understand the frustrations expressed by some.
So Ron, if your neighbor sued you for something frivolous in civil court because he was able to find a lawyer to take his case and it ended up costing you lots of money and time you would just pass it all off as that’s your neighbor’s right?
An honest question, not meant to be confrontational.
Keith: I kind of wish that I hadn’t added the statement regarding “retaliation”. 🙂 (I thought about that further, before I even saw your response.) I guess that in the case of homeowners, for example, insurance companies would likely be involved. (But, still probably personally costly, in both money and time. Not likely that I’d be very happy in such a situation.)
But, I’m also wondering if the groups that are created to function as the plantiff in such lawsuits protect the underlying individuals from risk (much as corporations do, for business owners). Again, a legal question.
Creating a fake group to hide behind won’t shield an individual from the consequences. It’s not like they created a corporate entity here.
What shields people from consequences is that the Hyatt House wants to start construction this summer, if they take this matter to court, it could take years to resolve. That gives the plaintiffs leverage over the defendants.
Thanks, David.
Are you sure, though? If so, what is the purpose of a “fake group”?
Ron… see David’s answer above. Q.E.D.
Howard:
David’s response didn’t address the question. Why not launch a lawsuit under one’s own name? As noted in the article above, creating an organization apparently does nothing to ensure privacy. Is there some other reason to create such an organization?
(I don’t know what “Q.E.D.” refers to.)
quod erat demonstrandum
In English “that which was to be demonstrated”
It is the last three letters of the San Francisco PBS/NPR affiliate KQED.
To amplify on Matt… WQED was the first community supported TV station in the US… based in Pittsburgh PA… it has been “on air” ~ 6 months longer than me.
As the day’s trivia contribution, the old rule was TV/radio stations east of the Mississippi had call letters starting with W… those west of, with a K…
I’d suggest you don’t throw stones…..
Ron: It’s a political game
David:
O.K. – I’ll take your word for it, even though I don’t see how. (As noted, the name of the organization apparently provides no protection, regarding privacy.) Not sure what purpose it serves, if it doesn’t provide some legal protection.
Overall, I’m not as willing to label this action as a game, especially considering the earlier response from Mr. Patel to Matt, below. The response seems sincere, even if one doesn’t agree with it.
I’d personally prefer the Hyatt proposal to go forward at this point (for what that’s worth).
Regarding some other suggestions that the “loser” pays for all legal costs, I can see the appeal. However, I suppose that it could be a double-edged sword. (I assume that such a system is not automatically in place.)
(On an unrelated note, I think that Keith’s response above was probably intended for a different article/response.)
Think about it – do you want your personal name attached to the court case or would you rather some generic fake group name? It’s a common tactic, but there is no legal protection ultimately.
Keith
I completely understand your example from the way that you have chosen to pose it. But now let’s flip that coin. Let’s suppose that your neighbor has done something that you consider a serious transgression which has harmed you, but which both your neighbor and the judge consider “frivolous”. You lose the case which both you and your lawyer thought had real merit. Now are you happy to have financial penalties attached that you have to pay in addition to having to live with the consequences of your neighbors action ? Again, not snark. Just trying to consider this from both points of view.
Ok, looking at your “flipped coin” example… this is a true story… factual, and I lived it…
Neighbor started to put in a mow strip between our properties… no notification… as the worker was framing it, I noticed a significant encroachment onto my property… a “grievance”, if you will… I talked to the worker and showed him the existing evidence of property line… in broken English, he said I had to talk to his ‘client’… called her, and she said I was wrong and she was proceeding… I told her my expertise as an engineer well grounded in surveying… she yelled at me and hung up (there are reasons why folk use the B-word).
Not fully on topic, but the point is, if there is a problem, it needs to be addressed at the lowest possible level. And early on… had I waited for concrete to be poured, different scenario entirely…
That night, I relocated the forms so as to coincide with the real PL… the worker didn’t recognize that (or figured that he was “covered”), and all was good. Not good for lawyers, but saved me a bunch of money by not going to court… and issue was resolved.
Complicated question Ron…
First, though, the project in question did not have an EIR, but a CEQA process did occur… and a review process to boot.
For certified EIR’s, there is a statute of limitations where it can be challenged… not sure, but kinda’ think it’s 90 days. There are statutes of limitations on many things. Except murder and a few other crimes.
Without knowing the details, would be willing to wager that this has been raised near, but within the SOL (accidental humor)… common tactic by those who primarily want to obstruct. [or extort a “settlement”]
But will need to leave to others how timely this is…
In general, if someone has a ‘bone to pick’, they need to do so before the applicant pulls permits and begins substantial construction, relying on approvals they have obtained. That is the “outside border” of SOL.
Hope that helps…
Thanks, Howard.
In general, it does seem that legal challenges are often complicated and unpredictable. Even laws themselves are not always straightforward (hence, the reliance upon and citations of past judgements, it seems.)
Ron, as Howard has said several times, an EIR is a disclosure document of the environmental impacts. If an environmental issue was not disclosed in the CEQA process (whether EIR or Negative Declaration), then the CEQA report would be either incomplete or inadequate or both. If the issue was actually disclosed, but not adequately assessed then the CEQA report would be either inadequate or inaccurate or both.
It appears that the argument being put forward by the Davis Smart Growth Alliance is an economic one, not an environmental one. It is not clear, from what has thus far been provided, what threat to the environment is being alleged.
Bottom-line, the lawsuit will have to show how “The EIR inadequately addresses potential impacts of urban decay of existing hotels in the community” in order to bring the provisions of CEQA into play.
It is hard to see an impact to the environment connection in the argument that “based on section 65860 of the California Planning, Zoning, and Development Laws – I have reason to believe the project is in violation of planning and zoning law as the Hyatt House Davis project is not consistent with the city’s General Plan Land Use policies and the South Davis Specific Plan policies.”
Thanks, Matt.
Is there a risk to the city if an EIR is improperly certified, and a proposed development is approved based upon that certification? (Same basic question regarding a CEQA report. For example, if a development is approved even though a CEQA report is inadequate or inaccurate?) In such a case, I assume that a “negative declaration” is issued.
Also, what about issues that are addressed (but cannot be mitigated), but the city nevertheless approves a given proposal? (In other words, does that put a city at risk?)
My overall question is, what are the risks that cities face, when approving a development that has gone through a CEQA or EIR process? (That’s the general question that I’m really trying to ask.)
Regarding the hotel in particular, is “urban decay” outside of the scope of CEQA and the negative declaration? Also, what about the other issue brought up, regarding city plans/policies? (I’m honestly not taking sides, just wondering – based upon your statement.)
You mention an EIR in your response, but Howard is stating that one wasn’t performed. (I assume that the “negative declaration” can be used interchangeably, regarding your reference.)
Matt:
My apologies – I see that you’ve already addressed some of my questions in your earlier response.
But, my main question remains – in general, what are the risks that cities face, when approving a development that has gone through a CEQA or EIR process?
Ron, to the best of my knowledge there is no risk to the City, other than the legal cost of responding to the lawsuit as “defendant.” A CEQA lawsuit effectively says “we allege that there is a shortcoming in the disclosure process, and the jurisdiction (in this case the City) must either (A) go back and remedy the shortcoming, or (B) abandon the project or (C) show cause to the court why the allegation is without legal merit.”
I defer to an experienced mind like Howard’s to answer the logical follow-up question regarding whether the City or the project applicant are liable for the additional costs if the City chooses either (A) or (C).
With respect to your “urban decay” question, the plaintiff needs to define what the specific urban decay is likely to be, what the proximal causes of that urban decay are, and whether those proximal causes exist currently or only exist in the case of a condition of “market unsustainability.”
The take-away I got from my face-to-face meeting with Roshan Patel was that there is a considerable similarity between what he is describing as urban decay in hotels and the urban decay that Davis is experiencing in the condition of its roads and bike paths. In both cases the urban is avoidable if timely capital infrastructure maintenance is performed. What Roshan Patel appears to be most concerned about is (A) the cost of keeping his hotel competitive with newer hotels, and (B) competing with more upmarket brand names.
The residential housing market sees a variation of (A) and (B) play out on an ongoing basis. Home buyers have a bias toward homes that have the newest amenities, and the sellers of older homes are faced with the possibility (and cost) of replacing amenities (kitchen and bathroom most notably) long before they have reached the end of their useful life because their visual style/design is not current. The alternative is to reduce the sale price (value) of the home.
It is understandable that Mr. Patel doesn’t want to see the value of his hotel decrease. Nor does he want to see the competitiveness of his hotel decrease. He has two alternatives for achieving those two ends. One alternative is to spend the necessary money to keep his hotel current with the up-to-date expectations of the guests. The other alternative is to deny those guests access to newer hotels that organically include amenity and design features that match those up-to-date guest expectations.
Little if no risk, unless there is substantive evidence of malfeasance… even then more likely the applicant is at risk of proceeding further… for the agency, only real risk is a “do-over” (as I’ve opined before) of the CEQA process, or portions thereof… would be nearly impossible to get “damages” awarded. Not likely that CC members would be imprisoned (maybe 0.00001 chance), either.
It’s called an ‘administrative remedy’… there may be examples for an agency needing to pay (other than defending the litigation) for ‘damages’ or fines… not aware of any to date, and I tend to follow that stuff.
If you are trying to “mine” info, to question risks of any CEQA process, to impugn it, the shaft is empty… the well is dry… there is no there, there.
Some would be inclined to say that if the risk is 0.0004% that you should say “no”… yet, your chances of getting hit by lightning, during your entire lifetime, is ~ 0.008 %… I tend towards a 0.5% risk as worth thinking about if mortality is involved, 1% as to property… and that’s even to think about it. To act on something, my view is somewhere between 45% and 0.5% is acceptable risk for pretty much anything.
In this particular matter, am thinking a 45% risk of a bad outcome, given the facts, is reasonable… suspect the actual risk here, in this matter, is ~2%.
That said, I am not an attorney, nor an actuary…
Thanks, Matt and Howard.
Thought I’d add – at this point, my “personal” preference is that the Hyatt proposal go forward. Seems like “enough” has been done, to satisfy most concerns (based upon what I know, at least).
Still, I don’t “begrudge” the plaintiff, in this case. I recall that he put forward some reasonably compelling concerns on the Vanguard, previously (assuming that I’m recalling the correct article/person). It is somewhat difficult for me to believe that the plaintiff believes there is “no merit” to his complaint. (I would assume that due to litigation, there won’t be any further public statements from the plaintiff.)
Matt – did you meet with Mr. Patel for the purpose of trying to understand and (somehow) help address his concerns? (Actually, what were you trying to accomplish, and was there any significant point of disagreement between you and him, that you recall?)
Clarification: I guess that the plaintiff is an organization, rather than a person. I still don’t understand the legal purpose of creating an organization. (The article above shows that doing so does not ensure privacy.)
Ron, my meeting with Roshan in December was the same kind of ecumenical interactive dialogue on ideas and concepts that try to engage in here in the Vanguard. edited
In this case Mr. Patel had expressed concerns about the validity of public record Transient Occupancy Tax numbers, especially as a measure of market demand for hotel rooms. That dialogue began when I posted the following:
.
To which Mr Patel responded:
.
In addition to providing a detailed response to his points on the Vanguard (see LINK for response), I reached out to him in the following e-mail correspondence to dialogue face-to-face.
[moderator] edited: email address removed, and more.
Was Mr. Patel aware that you were likely to post his email comments out on a public blog?
Don, if you go back and review the December dialogue on this topic you will find the following:
… after which Mr. Patel delved into the specific detail and opinion he shared with me in person when we met. Nothing he and I discussed was confidential.
Further, Mr. Patel’s e-mail address is publicly available on his business card, which is openly, transparently and freely distributed by his staff at Holiday Inn Express.
[moderator] When you post an email address on a public blog, you subject the owner of that email address to spam. I suggest you not do so. We don’t have a policy on the subject, but I remove email addresses whenever I see them unless the owner has obviously given explicit or implicit permission (i.e., posted it intentionally as you have done here).
Ron said . . . “You mention an EIR in your response, but Howard is stating that one wasn’t performed. (I assume that the “negative declaration” can be used interchangeably, regarding your reference.)”
Howard is correct. In this CEQA process no EIR was created.
My response was focused on your question as posed, “Honest (general) questions, regarding this statement. For the sake of discussion, I’ll assume that you’re talking about the EIR.”
Does his filing of this silliness put a stop to the construction? Has a judge made a ruling or is there an injunction in place?
As for the city being harshed… they play this game all the time, picking and choosing what businesses can go where… picking winners and losers.. look at what they did with Ikeda’s proposal. Stopped it because they didnt want to hurt flipping In and Out. They opened this door…
Actually, think we can… it is only a different flavor of “I’ve got mine, and I don’t want to give any of it up”… “I’m here, time to build the moat, pull up the bridge”… there are indeed “no-growthers” (if they feel it impedes on them), and some of those pretend to be “slow growthers” to make folk think they are “reasonable”… they are not “altruistic” in my view.
I believe growth is reasonable, inevitable, and should be ‘measured’… carefully and reasonably.
It’s unfortunate that you think this way. I don’t, nor do I view efforts toward a stable and sustainable population as “personal” or “selfish”.
Overall, it seems that people are starting to realize that growth and development cannot continue indefinitely, anywhere. (Actually, it’s a pretty obvious conclusion, when you consider that land is finite.) Although there’s still lots of “open land” at this point, continued development is already affecting the planet as a whole (including the survivability of other species).
From a “quality of life” perspective, we’re not building new roads, water sources or other infrastructure to support an increased population, either. (And, doing so would have other impacts.)
Ron – How do you propose stopping population growth? Do you think that by not building housing, that people will just go away? If the local population continues to expand, but we make no effort to provide housing, how does that impact the ‘quality of life’ for those who live here? Both those who have a home, and those who don’t?
Mark:
Regarding “stopping population growth”, the rate is slowing down in developed parts of the world. (The U.S. is somewhat of an exception.) If it was up to me, I would encourage further efforts to stabilize population (e.g., via education, availability of birth control, etc.). There is also a cultural/economic change that needs to occur.
I view local “growth control” efforts as sort of a “bottom-up” outcome, as a result of a failure to address continued reliance upon unsustainable growth and development on a broader level – in which continued growth and development is encouraged and relied upon to “solve” challenges. (The “Ponzi Scheme” method of solving challenges.)
Unchecked development accommodates and encourages the unsustainable cycle to continue.
Fine ideas, but it is not ‘up to you’ and even if it were, those efforts will take decades or generations to make a significant difference. While we are waiting, the population of Yolo County will continue to expand at the same roughly 2% per year that we have seen over the past several decades. How are we going to treat those new people when it comes to housing. Are they second-class citizens who don’t deserve an appropriate place to live in your worldview? That is what it sounds like when you propose stopping local development without first changing local population growth. You don’t stop population growth by stopping development, you just force those people into overcrowded conditions in the existing housing infrastructure, reducing the quality of life for everyone.
I agree that ‘unchecked development’ is unsustainable, but equally so is ‘no development.’ I don’t hear anyone advocating for ‘unchecked development’ in Davis, so that is just a straw man argument on your part. If we are looking for sustainable solutions what we need is regulated (or smart) growth that allows for accommodating our share of the population expansion of the region. The best way to do that, while also limiting the destruction of farmland, is to build high-density, multifamily housing. The best way to address the City’s fiscal needs at the same time is to build that housing in mixed-use residential/commercial developments. That is the sustainable approach for both the City and its residents, not your ‘no growth’ fantasy.
Mark:
What you’re failing to acknowledge (repeatedly) is that Davis is accommodating its “fair share” allotment of regional growth. SACOG administers this, as you know. Some seem to be advocating that Davis pursue even more development than that.
Regarding additional growth (pursued unilaterally, by the university), it does seem ironic that some “slow-growth” minded individuals are at the forefront of the effort to encourage the university to take responsibility for its decisions, by housing the increased enrollment. (As you’ve repeatedly acknowledged, your efforts in this area are completely lacking.)
I found it somewhat interesting that you described the proposed “senior development” as “sprawl”, which didn’t meet “local needs” (something to that effect). I’m wondering if this is because you view seniors as not contributing sufficiently to the local economy (compared to other population cohorts). (Honest question.) Given your preferences for more development, I can’t think of any other explanation for your position, since seniors are also a “growing population”. (Note – I haven’t taken a position, regarding that proposed development.) In any case, “seniors need love, too”.
After numerous discussions of this topic on the Vanguard, I would love to know what your understanding is now of this issue.
Mark… AMEN!
Ron… I don’t hear anyone advocating for “unchecked growth”…
As to advocacy for birth control… has some merit, particularly if it can be done retroactively… but won’t say that, as it would be veering off-topic.
As far as acting ‘locally’, that also has some merit… for instance, you could choose not to reproduce… sets an example for others… I’ve done my part… self-sustaining would be 2.0 children per family (and only one of those)… so my parents would have 4 grandchildren. They had 3. Did my part… [end of veering]
Howard:
You’re the one who started this thread, essentially be describing “slow growthers” as selfish.
I would also point out that ANY growth control efforts could inevitably lead to arguments such as yours and Mark’s (e.g., by not completely accommodating potential “market demand”).
Again, sorry that you feel that way. You’re completely misunderstanding motivations. (Normally, not something a “fact-based” individual would do.)
Also – I don’t recall anyone advocating for “no growth” locally, at this point. (Even if that was possible.)
Ron said to Howard . . . “You’re the one who started this thread, essentially be describing “slow growthers” as selfish.”
Ron, reread Howard’s words. He didn’t make any comment about slow growthers. His comment was about the plaintiffs in the lawsuit who already have a foothold in the Davis hotel marketplace. He very clearly labeled them as “no growthers” not “slow growthers” and that any attempt they might make to label themselves as “slow growthers” is a masquerade.
Matt:
Look at the comment that Howard was responding to, at the beginning of this thread.
I think Howard is perfectly capable of making his own statements and clarifying, if desired).
Ron, the quote Howard was responding to was not part of any comment.
Ron… to be clear, the ‘drivers’ for growth are real and regional, as Mark points out.
That’s a fact.
I never said I’d limit myself to facts… last time I checked, am still entitled to opine.
Have seen few facts from you. And that is a fact.
Ron… never used the word ‘selfish’ earlier… if you think this suit is NOT about protecting ‘market share’ of the hotelier, or that there are many in town who want to protect their ‘market share’ be it ease of travel on streets, market value of property owned, perceived ‘quality of life’ and/or “small town feeling”, can’t help you… am not an eye doctor… cannot cure blindness…
Your lack of understanding of the role of SACOG has been firmly established, as has your lack of rational thought regarding development by the University.
No, it is not an honest question. It is just another of your strawman attacks that you fall back on when you don’t have anything constructive to add to the discussion.
I’m sure you cannot, which just proves that you don’t even understand your own arguments. You have argued repeatedly that residential development is a money loser for the City. A development of single-story, detached, single family homes on the periphery is the perfect example of your own argument. From a fiscal perspective, it is probably the worst approach to development that the City could take. It doesn’t matter who lives in the homes (seniors or otherwise) as building this sort of development is a poor use of land and a very bad fiscal decision. I cannot understand how anyone who claims to be in favor of a sound approach to land use could support this project as proposed or fail to understand that it is a prime example of unsustainable development.
Given your interest, I’d suggest that you write an article, regarding SACOG. (Including your conclusions, which seem to vary at times.)
Given your interest Ron, I’d suggest that you also write an article, regarding SACOG. (Including your conclusions.)
Matt:
This issue has already been discussed on the Vanguard, via comments and links. Whenever the issue comes up, it inevitably leads to disagreements regarding ramifications. (Some of which are unknown.) You have presented some of your own conclusions, which were unsupported. I (and at least one other commenter) challenged you regarding this, but it remained unresolved.
But, I agree that it would be a good topic for a Vanguard article. And, it’s overdue. (Not sure if I’m the best person to present it, especially given the disagreements that would result again.)
One thing that is not under dispute is that we are currently meeting SACOG requirements, and a “new round” of such requirements will be established, soon.
Ron said . . . “But, I agree that it would be a good topic for a Vanguard article. And, it’s overdue.”
Then write it. Your perspective and researched facts are what Don is interested in. Numerous others are interested in hearing the results of your research on the topic as well.
There will be disagreements regardless, so who writes it is irrelevant. Hopefully it will be written with Tia’s spirit of not posting to change someone’s mind but rather to present a point of view that may not have been considered previously.
Howard: “Have seen few facts from you. And that is a fact.”
If I make a comment that you believe is not sufficiently supported by facts, you’re free to point that out. (In the case of your statement above, to which I responded, it mostly centered around “opinions”.)
Matt: “Then write it. Your perspective and researched facts are what Don is interested in. Numerous others are interested in hearing the results of your research on the topic as well.”
Maybe I will, at some point. But, Don is the one who brought it up, today. And, let’s be honest. Some are not interested in “hearing the results”, so much as “tearing apart” the research. (That’s already been proven, on a daily basis on the Vanguard. Even regarding relatively simple statements.)
Again, what’s not under dispute is that we’re currently meeting SACOG requirements, and will receive another allocation, shortly. And, some are advocating that we “exceed” those requirements.
Seems to me that those advocating to “exceed” SACOG requirements have the onus to “prove” that such requirements are “not important” – as some have suggested.
I would also suggest that the Vanguard itself (e.g., its professional journalists) has not demonstrated much interest in this area.
No, Ron. You did.
Don:
Technically, that’s true. I did state that we’re currently meeting SACOG “fair share” growth requirements, and followed it up by stating that we’ll receive a new allotment, soon.
You’re the one who suggested that I expand upon that statement.
Also, it probably should be noted that this conversation is starting to veer off-topic, based on the topic of the article.
Ron… respectfully suggest you look up the differences between the words, “allocation”, “suggestions”, “guidelines”, “recommendations”, “requirements”, and “mandates”.
Ron,
Have yet to see anyone here advocating, as a policy, exceeding the SACOG ‘goals’… I know I don’t…
Documentation/citations, please? For,
The SACOG ‘goals’ really comes from what is happening regionally, and mainly looking to have the reality spread across the region…SACOG is not “seeking”/advocating growth for the sake of growth… for some, an inconvenient truth.
I suspect Mark was coming from a similar perspective in his earlier comments…
Ron said . . . “And, some are advocating that we “exceed” those requirements.”
I can not think of a single person who has “advocated” for exceeding the SACOG RHNA requirements. Who specifically do you believe has done so?
Matt:
Already responded, elsewhere on this page.
Ron said . . . “I would also suggest that the Vanguard itself (e.g., its professional journalists) has not demonstrated much interest in this area.”
Your suggestion is noted Ron, but other than you and Eileen Samitz, no one has proactively expressed any interest in the topic. You are the one who brings it up on a regular basis, with the only corroboration you have brought to the dialogue being gut feelings.
Previous discussion on SACOG in which Matt explains the next round of allocations in great detail:
https://davisvanguard.org/2016/09/commentary-city-approach-student-housing/#comment-337148
Don and Matt:
Nope – not gut feelings, but facts (not conjecture, as Matt has engaged in).
The bottom line is that we don’t even know what the next round of SACOG allotments will be. Matt has graciously provided some “guesses”, regarding that. And, the “basis” of those guesses is one of the areas under dispute.
Planning based upon disputed “guesses” is not something I would advocate.
Ron, if you don’t even know what the numeric calculation of the next round will be, what “facts” are you citing? The one “fact” that exists is that there currently are no “facts” regarding the next RHNA allotment.
Your assertion has no integrity.
From the Dictionary
Integrity
the state of being whole and undivided.
Well, let’s hear your “expert opinion”, regarding SACOG, etc. Please set me straight, and I will try to block my “irrational” thoughts, oh enlightened one.
I have no idea what you’re talking about. I made no arguments regarding the proposed senior development, so far.
Very mature, fact-based response to Mark.
Howard:
Strange that you totally disregard Mark’s initial statement, regarding my “lack of rational thought”.
Was not regarding his statement… just your response… which I called, “very mature and fact-based”
Thought I was being civil, without any personal attack. Affirming, even…
Ron –
Others have done an admirable job explaining the role of SACOG to you in the past. You have repeatedly ignored those efforts and have obviously made an active choice not to learn.
Your irrational argument regarding the University is your position that residential development by the University is ‘good’ but the same development in the City is ‘bad.’ You have failed to give any rational explanation for the difference as they both replace farmland with housing, both increase the functional population of the City, and both increase the City’s costs (but only one increases revenues to compensate).
Your failure to understand your own arguments against development is fully explained in my comment above.
Mark:
Your misguided opinion, and leaning toward off-topic. This has all been addressed, previously.
I understand that all of the proposed developments (in excess of those already-approved) exceed the current “fair share” growth allotment. The city does not need to approve any further developments, prior to the next round of SACOG allotments. And yes, I’ve seen plenty of “advocates” on the Vanguard who suggest doing so.
“It is important to note that each jurisdiction is responsible for providing sufficient zoning capacity for the units allocated to all four economic income categories, but is NOT responsible for the construction of these units. The intent of the Housing Element Law is to ensure that jurisdictions do not impede the construction of housing in any income category. Other factors, such as market forces, are well beyond a jurisdiction’s control and have considerable influence over whether or not housing units in each income category are actually constructed.”
The allocations are not for developments or proposed developments. They are just for capacity. Neither SACOG nor the Department of Housing and Community Development (which reviews and regulates each city’s housing plan compliance) can compel a city to grow. They provide incentives for compliance with the housing element plan. They can tell a city how it can achieve compliance. They can’t make a city build housing.
Don:
Not seeing anything here, which conflicts with what I posted.
If the city “uses up” available space by approving developments in advance, that space won’t be available to meet future requirements (e.g., those that will be established in about 3-4 years from now).
You already know that there are consequences (regarding funding for various projects), if SACOG allotments are disregarded. It is irresponsible to suggest otherwise.
You have also previously acknowledged that building in excess of requirements can encourage SACOG to assign a higher number, next time.
These types of ramifications have all been discussed previously, and at length. There is disagreement regarding some of the ramifications, which has never been fully resolved. (Mostly, from those who don’t want to acknowledge reality.)
Strange that you’re allowing this to veer so far off-topic.
I think it’s pretty obvious that there is no interest in an “honest” discussion regarding SACOG allotments.
No city is going to disregard SACOG allocations. They meet them by getting the housing element of the General Plan approved by the DHC. Davis will be compliant. The only “consequences” would be that the city would need to come into compliance, or would not be eligible for some federal grant programs.
It has been stated that one of the factors, among many, in the process of allocations might be the previous growth rate. You and others have repeatedly suggested that it ‘will’ do so. I have been hearing that for several years. I find evidence of Sue Greenwald making this argument nearly a decade ago. So apparently we will always curtail housing until the next allotment for fear that we may increase it.
You keep saying stuff, even when you’ve been shown to be incorrect. That doesn’t actually mean there is any disagreement about facts or analysis. Just that you won’t change your mind and will continue to cite SACOG without any merit or apparent understanding of the process, no matter what, over and over again.
Stop mentioning SACOG, stop using it as a factor when it isn’t, stop misrepresenting SACOG and its impact, and I won’t feel any need to correct you on it.
Give me a break, Ron. I’ve done my homework on this. You haven’t.
Ron said . . . “If the city “uses up” available space by approving developments in advance, that space won’t be available to meet future requirements”
What Ron’s statement omits is that SACOG cannot assign an RHNA allotment for land that does not exist within the City Limits. Land that exists outside the City Limits is the RHNA responsibility of Yolo County.
Agreed. I’m not the one who put forth a “guess”.
Regarding your statement of land that is (currently) outside city limits, I recall that the argument is not as simple as you’re presenting it. (Not by a longshot.)
Again, I would suggest an article, regarding this. I don’t have time to research and refute all of your possible misstatements, today.
And again, it’s not just “me”, regarding disputes related to conclusions that you and Don have put forth.
I still find it “strange”, that Don is encouraging a conversation that’s off-topic. I guess he has some strong feelings, regarding SACOG requirements/allotments.
Ron said . . . “Regarding your statement of land that is (currently) outside city limits, I recall that the argument is not as simple as you’re presenting it. (Not by a longshot.)”
Please provide a linked source for the basis of your recollection. You can’t because that recollection is a figment of your imagination.
This is eerily like your Auditing Community standard for defining conflict of interest. Lots of talk on your part but no corroborated substance.
Matt:
As I mentioned, I don’t have time to research everything, today. (I did not expect to get involved in a long, drawn out challenge regarding a complex topic that Don has allowed to veer off-topic.)
But no – it’s not my imagination. There is a probability of running out of available sites within the city, thereby essentially forcing the city to expand beyond its borders. That will occur, when the city can no longer find spots to meet its SACOG allotments. Possibly as soon as the next round.
Again, it’s not just me stating this. Others have engaged in disagreements with you and Don, as well. Those disagreements can be found in Vanguard archives (possibly including some that Don has referenced, today). If you or anyone would like to find those disputes, I’d suggest starting with the link that Don has provided. If you can’t find it there, I’m pretty sure that you’re capable (and apparently motivated) to search further.
Regarding my statements related to “conflict of interest”, I have pointed out (repeatedly) that I did start posting information to back it up. However, it was deleted as “off-topic”.
SACOG cannot force a city to annex land for development.
Don:
SACOG apparently can’t “force” a city to do anything. However, there can be financial consequences, if fair share growth allotments are disregarded. In addition, there’s no doubt developers just waiting to pursue legal action, in such a scenario.
Ron: Perhaps you should research what SACOG can and cannot do and how they work. Don’s been part of this discussion for a decade ere on the Vanguard and very knowledgeable on this subject.
David:
So have others, and not just those advocating for more development.
Again, if Don, Matt or you believe that anyone is making factually incorrect statements, you’re free to point it out. (In fact, you’re free to make any statement that you desire, of course. However, “guesses” or other conjecture, presented with certainty, are not providing much value to your readers.) In fact, it could lead to erroneous conclusions, thereby negatively impacting decisions regarding planning.
Ron: I believe they have multiple times, they can correct me if I’m wrong, and you have ignored them.
David:
Well, even if you apparently don’t know what they are (and I don’t), I’m sure that they will try, again.
And again, it’s not just me that’s disputed some of the conclusions regarding SACOG.
I’d really encourage a discussion (e.g., a separate article) that includes those who aren’t necessarily trying to promote development, in some manner. (Other than me, this does not include anyone who has participated in this discussion, so far.)
Ron said . . . “Regarding your statement of land that is (currently) outside city limits, I recall that the argument is not as simple as you’re presenting it. (Not by a longshot.)”
Actually, Ron if you read section (2b) of SACOG’s own documents (quoted below), you will find that it is crystal clear.
Matt:
Nowhere in that quote (from the partial list of SACOG determining factors) does it state that available land (that SACOG can consider) must be within current city boundaries.
Also – do you advocate turning over decisions regarding land use within the city to SACOG prematurely, by developing available sites in advance of requirements?
Ron said . . . “Nowhere in that quote (from the partial list of SACOG determining factors) does it state that available land (that SACOG can consider) must be within current city boundaries.”
Actually Ron, once again you are wrong. The word that prescribes and proscribes that limitation is “jurisdiction” in SACOG’s expression “the jurisdiction’s” The City of Davis’ legal jurisdiction is defined by its City Limits.
If the City wants to change that jurisdiction it must apply to LAFCO.
Matt:
Per the section you quoted:
Says nothing more than that. Anything you add to that is superfluous.
Let’s see what actually happens, when easily-developable spots within the city are developed in advance of upcoming allotments (as you’re advocating).
Ron asked . . . “do you advocate turning over decisions regarding land use within the city to SACOG prematurely, by developing available sites in advance of requirements?”
It is impossible to “turn over decisions regarding land use within the city to SACOG prematurely.” SACOG’s current cycle is 2013-2021. There is no legal or procedural way to prematurely get SACOG to change the 2021 date.
Ron said . . . “Let’s see what actually happens, when easily-developable spots within the city are developed in advance of upcoming allotments (as you’re advocating).”
I’m not advocating anything. That is a figment of your imagination. Go back and read my response to Tia.
Bottom-line, you can not find one single statement by me advocating for development in advance of upcoming allotments. If you find one, please copy and paste it here and I will acknowledge your due diligence.
I advocate for an open, transparent, unfettered, inclusive dialogue about each issue that we face as a community. You closed, restricted dialogue that excludes certain voices because they are not consistent with your world view.
Not what I said, in regard to the referenced section from SACOG that you quoted.
Matt: “Bottom-line, you can not find one single statement by me advocating for development in advance of upcoming allotments.”
O.K. – here’s your chance to clarify.
Did you support Nishi? (Seems to me that you did.) Not criticizing you for it, but it was in advance of SACOG allotments.
Also, from what you currently know, do you support the Sterling proposal (in its current proposed form, or in some modified version)? Same question regarding Lincoln 40. (On a related note, what’s your position regarding Trackside’s latest proposal?) And, what about MRIC with up to 850 residential units?
Ron asked . . . “Did you support Nishi? (Seems to me that you did.) Not criticizing you for it, but it was in advance of SACOG allotments.”
Again your ignorance of SACOG RHNA shows itself. Nishi was not in advance of SACOG allotments. In the current 2013-2021 SACOG allotments, Nishi is nowhere to be found. Any consideration of Nishi in the 2013-2021 SACOG RHNA allotments would have only been in the Yolo County allotment, and because Nishi is zoned as an Agricultural parcel, its “number” in the 2013-2021 SACOG RHNA calculation would have been zero.
With that said, you are changing the question in mid-stream to fit your agenda … changing the word “advocate” to the word “support.” They are two radically different concepts. But I will humor you. Did I “advocate” for Nishi? I absolutely did not.
I was very clear on the record about my personal beliefs about Nishi
I supported the democratic process that has created Measure A. I absolutely did not support the February 16th decision establishing the premature June Measure A vote.
As a presumptive elected representative of the people, the only vote that really mattered was whether on February 16th I would have supported the rushed decision to put Nishi on the June ballot. In that high impact vote I would have been representing the people. To be crystal clear, my February 16th vote was/is, “I oppose putting Nishi on the June ballot!”
The principal reason I believed a June Nishi vote was a bad decision was because the financial analysis of the project was not “materially complete and accurate.”
In addition, until all three parties to the agreement had come to the table, I believed (and still believe) the Nishi Development Agreement was also not complete or accurate. The developer and City had done their part, but UCD, was still on the sidelines. No UCD signatures appeared on the signed Development Agreement.
UCD’s financial contribution to the infrastructure construction costs was still unknown. If in the future UCD agreed to contribute to the underpass construction costs, there was nothing written out in the Development Agreement about whether that contribution would go to the City’s Affordable Housing Fund or the developer. Had the ballot been delayed until UCD stepped up, the Development Agreement would have reflected the same three-party status that had defined the project since its inception.
As a result, each individual Measure A ballot cast in June was (in my opinion) a “guess” based on the personal feelings and beliefs of the individual voter. Some voters passionately argued that Nishi’s non-financial benefits trumped Nishi’s financial and procedural issues. Other voters made an equally passionate argument that Nishi’s financial and procedural issues trumped Nishi’s non-financial benefits. It is truly unfortunate that the voters had to “vote blind,” casting their ballot on the basis of politics and promises rather than on the basis of substance.
Bottom-line, the June 2016 June vote on Nishi should never have happened.
Exactly my point, except for your conclusion. It most definitely would have been in advance of SACOG allotments for the city (and apparently, the county). And it would have become part of the city, and thereafter unavailable regarding adherence for future SACOG allotments, after development of the site.
In general, your “advocacy” (and “specialty”, really) often consists of asking pointed questions and making pointed statements, and presenting one side of an argument as “fact”. You’re really quite talented at it.
Ron asked . . . “Also, from what you currently know, do you support the Sterling proposal (in its current proposed form, or in some modified version)? Same question regarding Lincoln 40. (On a related note, what’s your position regarding Trackside’s latest proposal?) And, what about MRIC with up to 850 residential units?”
Based on what I know I do not support the January 19, 2016 Sterling proposal. Further I argued long and hard (and successfully) that the Mitigated Negative Declaration was not a proper CEQA process. It is my understanding that representatives of Rancho Yolo have been meeting with the City and the Sterling development team, and a revised plan satisfactory to all three parties may be forthcoming. I will evaluate the details of that revised plan when they become available.
Lincoln 40 appears to have stalled in the EIR stage, so there doesn’t appear to be anything to have an opinion on with respect to Lincoln 40.
The criteria to judge Trackside against are highly conflicting. The Zoning Code and the Davis Downtown and Traditional Residential Neighborhood Design Guidelines (DDTRNDG) contradict one another. Further, different sections of the DDTRNDG contradict one another. As a result it is impossible to objectively measure the project against a definitive standard. With that said, if you drive around the OED neighborhood there are numerous existing multi-story cinder block apartment houses, and there is at least one three-story residence. Much like what was done in the Rosecreek/Hyatt House situation, the solution to Trackside probably will come either from collaborative discussion or from an update of the Core Area Specific Plan, which I assume will include an update to the DDTRNDG.
There is no MRIC proposal. If, and when, a MRIC proposal resurfaces, I will evaluate its specifics.
Ron said . . . “And yes, I’ve seen plenty of “advocates” on the Vanguard who suggest doing so.”
Name names. I have not seen anyone do what you are alleging. Until you name names all you are doing is exercising your imagination.
I can not think of a single person who has “advocated” for exceeding the SACOG RHNA requirements. Who specifically do you believe has done so?
No idea what you’re referring to. I have stated that we are meeting our current SACOG allocation (via currently-approved developments), and that a new allotment will be established in 3-4 years.
Right back at you.
Well, if that’s what your position, then write an article regarding it, state what you believe is under dispute regarding facts and conclusions, and open up a true discussion with more participants.
You’re the one who challenged me, today. I just made a simple statement, to begin with.
Matt: “Name names. I have not seen anyone do what you are alleging. Until you name names all you are doing is exercising your imagination.”
Anyone who is supporting large-scale residential developments at this time, in excess of those already approved. (For example, Sterling, Lincoln 40.) Probably you, for one (although I realize that you’re always “reluctant” to take a position – despite your pointed questions and statements).
You’re really something. Always pretending that your arguments are strictly “objective and fact-based”, when it’s apparent that you’re only presenting one side of an argument. Really odd, frankly.
Did you mean to say “residential developments”, or “developments including a residential component”? Or did you mean “developments” (no qualifier), as you posted?
Ron said . . . “Anyone who is supporting large-scale residential developments at this time, in excess of those already approved”
To the best of my knowledge your statement is not correct. I believe the numerical facts do not support that conclusion.
If you have any personal moral integrity you will post here in the Vanguard the housing unit data that supports that conclusion on your part.
The City’s RHNA allocation for the 2013-2021 period is 1,066 units, including 422 units affordable to low- and very-low income households. You may want to start by providing an answer to how many total units to-date have been removed from the City’s 2013 list of sites, and how many affordable to low- and very-low income households units to-date have been removed from the City’s 2013 list of sites.
Matt:
You’re the one who’s disputing my statement.
If you believe that additional residential development approvals are needed to meet current SACOG allotments, then let’s see your calculations. If so, how many more approvals are needed, to satisfy the current allotment?
The numbers you’re presenting seem to support my statement, that no additional approvals are needed at this time.
I will check for your response, later.
Ron, your comment shows how little you know about meeting RHNA requirements. Davis has already filed the appropriate paperwork with the State detailing its plan for meeting the current SACOG allotments. As has been pointed out to you over, and over, and over again, SACOG allotments do not relate to units built, they relate to units that are zoned such that they can be built. Lots whose zoning is such that they are able to be used to satisfy the SACOG requirement have no quid pro quo requirement that they be built on. Chiles Ranch is a perfect example. Its zoning was approved two RHNA cycles ago, but as yet, it still stands vacant. Nonetheless, the approved units in Chiles Ranch have counted toward satisfaction of the RHNA requirement. Similarly the hundreds of empty residential lots scattered around the City which have stood vacant, in many cases for decades, all count toward satisfaction of the RHNA allotment, regardless of whether they are built on, or continue to remain as vacant, undeveloped, residential lots.
The words of Luke 4:23 apply.
Matt:
Let’s see you actually answer the question (that you challenged me, on):
If you believe that additional residential development approvals are needed to meet current SACOG allotments, then let’s see your calculations. If so, how many more approvals are needed, to satisfy the current allotment?
The numbers you’re presenting seem to support my statement, that no additional approvals are needed at this time.
Yes – Chiles Ranch (and the Cannery) are helping to meet current SACOG allocations. The Cannery is under construction, and Chiles Ranch is due to be developed, soon. Not sure why you’re bringing that up.
Ron said . . . “If you believe that additional residential development approvals are needed to meet current SACOG allotments, then let’s see your calculations. If so, how many more approvals are needed, to satisfy the current allotment?”
Once again you show how little you understand about SACOG RHNA. The current SACOG RHNA allotments were met in 2013. Full stop, end of story. The prior SACOG RHNA allotments were met in 2008. Full stop, end of story. Any housing activity that is happening now in Davis does not relate to the current SACOG RHNA allotments in any way shape or form.