Opinion: Large Project in Sac Shows Why It’s Too Early to Declare State Housing Policies a Failure

• Being off target in the middle of an eight-year cycle is not the same thing as failure at the end of that cycle.

SACRAMENTO – The partial recirculation of the environmental impact report for the Upper Westside Specific Plan in Sacramento County is a good reminder of two things at once: how messy big housing approvals can be and how premature it is to declare California’s state housing policies a failure halfway through a RHNA cycle.

Upper Westside is a massive proposal: more than 9,300 homes and 3 million square feet of commercial development on 1,532 acres between the western city limits of Sacramento in Natomas and Garden Highway, with a 534-acre agricultural buffer on the western side.

Notably, it is also contentious, drawing opposition from the city of Sacramento, Natomas residents and environmental groups.

What caught my eye is not just the scale, but the process.

Sacramento County has now partially recirculated the draft environmental impact report for the project for six weeks to address changes related to water and traffic. That includes adding Natomas Central Mutual Water District (also referred to as Natomas Central Mutual Water Company) as a potential domestic water supply source for the project, even though the entity currently serves mostly agricultural users in Sacramento County, and revising traffic circulation to remove a connection on Radio Road between Bryte Bend Road and Garden Highway while adding traffic calming on San Juan Road between Garden Highway and El Centro Road to discourage pass-through traffic.

Those changes are not trivial, but they are also not unusual.

Land-use attorney Nick Avdis, who represents the proponents during the entitlement review, said in an email to the Sacramento Business Journal for example, that it is normal to recirculate an EIR when there is new information.

“The County has been methodical and transparent, and these refinements only reinforce the strength of the administrative record and environmental analysis,” he said.

The notice of recirculation makes clear that the core of the project is unchanged. “All other aspects of the proposed Specific Plan would remain unchanged, including land uses, densities, and plans for infrastructure and service delivery,” the notice states. In other words, Upper Westside has not shrunk away; it is still a 9,300-unit, 3-million-square-foot proposal working its way through the system.

For those of us watching Davis’ own Village Farms project and its recirculated EIR over water issues, this should sound very familiar.

A large, controversial greenfield project hits turbulence over water and infrastructure, the EIR gets recirculated, and critics immediately raise red flags and criticize the city and potentially the applicants.

But the Westside example shows that this is a normal part of the process even if it looks clunky and disjointed.

The political backdrop in Sacramento County is also instructive. In August, the Board of Supervisors pulled a final vote on Upper Westside from its agenda a few days before the meeting, citing a need to incorporate more outside input.

Earlier that month, the Sacramento City Council voted 8-1 to oppose the project, citing concerns about traffic impacts, loss of open space and potential strain on city services.

Natomas residents and environmental groups have raised similar objections during the county’s review.

Sacramento County has not yet set another hearing for supervisors to vote on the project. The notice on the recirculated EIR states that a notice of that hearing will be released when one is scheduled. The recirculated document is available for public comment from Dec. 10 to Jan. 27.

Why does this matter to Davis and to the broader conversation about California’s Regional Housing Needs Allocation (RHNA)? Because Upper Westside is exactly the kind of late-cycle, large-scale project that can dramatically change the numbers in the second half of a RHNA period.

On Monday, I argued that the emerging narrative, at least by some critics, is that state housing policies are “failing,” as examining progress at the midpoint of the RHNA cycle is premature and often misleading.

Being off target in the middle of an eight-year cycle is not the same thing as failure at the end of that cycle.

The fact that a jurisdiction appears behind in years three or four does not account for the timing of when big projects like Upper Westside, Village Farms or other specific plans actually receive final approvals and begin to produce units.

In that piece, I noted that the state’s housing shift, including tools like SB 9, SB 35 and stronger RHNA enforcement, is still in its early implementation phase, and that “off target” is a snapshot, not a verdict.

You can read that analysis here:

Upper Westside underscores that point. If a 9,300-unit project comes online in the second half of the RHNA period, it will significantly move Sacramento County’s numbers.

The same logic applies in Yolo County and Davis. Village Farms alone is projected at more than 1,800 housing units. Willowgrove adds potentially another chunk of units, pushing the total over 3000.

If it is approved and built in the back half of the cycle, it will change the city’s RHNA story in exactly the way critics discount when they look only at mid-cycle progress reports.

None of this is to say that the system is functioning perfectly.

Local politics can still block or shrink projects. Environmental and infrastructure issues can delay them for years. Regional equity questions remain unresolved. In the case of Upper Westside, the city of Sacramento’s opposition reflects real worries about traffic, open space and the fiscal impact of growth outside city limits. Those are serious concerns and deserve scrutiny.

But the mere fact that a project is controversial, subject to recirculated EIRs, or delayed for additional hearings does not mean it will never be built.

In California’s current regime, the state’s housing laws, RHNA targets and enforcement mechanisms are designed to push local governments toward exactly these kinds of large-scale approvals, even if they come after years of contention.

From a policy standpoint, the better question is not “Are we already failing?” but “Are jurisdictions positioning themselves to have one or two big, RHNA-shifting projects approved and entitled by the end of the cycle?” For Sacramento County, Upper Westside is clearly one of those bets. For Davis, Village Farms and future peripheral proposals will play a similar role, especially as the city exhausts realistic infill options.

There is a cautionary note here as well.

If jurisdictions wait too long, or if they assume that the state will blink, they may find themselves at the end of the RHNA period with neither enough approvals nor enough pipeline to satisfy HCD. That is a real risk. But it is different from saying, in year four or five, that the entire state housing strategy has already failed because mid-cycle dashboards show “off target” in red.

The Upper Westside EIR recirculation is one more example of what implementation looks like on the ground: imperfect, political, iterative, but still moving. It suggests that the right way to evaluate state housing policies is at the end of the RHNA period, with the full weight of late-cycle approvals and large projects included, not at halftime.

For Davis and for other communities watching these fights, the lesson is to pay attention not just to the noise around recirculated EIRs and delayed hearings, but to the underlying direction of travel. Upper Westside is still a 9,300-unit proposal in the pipeline. If it is ultimately approved, it will be one more data point showing that “off target” in the middle of the cycle is not the same as failure when the clock runs out.

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