Vanguard Analysis: Without Two Peripheral Projects, Davis Cannot Meet Its Housing Requirements

Davis will not meet its state-mandated housing requirements without large-scale peripheral projects like Village Farms and Willowgrove. The city’s housing data shows that the remaining need, especially for lower-income housing, far exceeds what infill development or accessory units can realistically provide.

The data from the city’s own Housing Element Annual Progress Report paints a clear picture. Davis has been assigned a total RHNA obligation of 2,075 units for the 2021–2029 cycle. Through 2025, the city has permitted 963 units, leaving 1,112 still to be produced. On paper, that suggests roughly 46 percent completion.

RHNA compliance depends not on total units but on meeting targets across income categories, and by that measure Davis is far off track.

The most significant gap lies in housing for lower-income residents. 

The city is required to produce 580 units for extremely low- and very low-income households combined. To date, it has produced just 28 extremely low-income units and zero very low-income units. That leaves 262 extremely low-income units and 290 very low-income units still to be built. 

The low-income category shows a similar pattern: 350 units required, only 2 produced, leaving 348 remaining. 

Altogether, Davis still needs more than 900 units of affordable housing across these categories in the next four years.

At the same time, the city has exceeded its moderate-income target and made steady progress on above-moderate, or market-rate, housing—a pattern that reflects the fact that recent infill development is inherently geared toward market-rate production.

Recent housing production has been overwhelmingly above-moderate, with only a negligible share of deed-restricted affordable units.

The issue is straightforward: Davis is producing housing, but not the housing RHNA requires.  I would argue not enough housing, but the real problem is on the affordable side.

Interestingly, accessory dwelling units, which have increased in recent years, are largely counted as above-moderate income due to rent levels. 

Single-family homes fall into the same category. 

Meanwhile, multi-family construction—historically a key source of affordable housing—has declined sharply, and in Davis much of what is built is student-oriented and does little to address RHNA affordability requirements.

This mismatch is compounded by a growing gap between planning and production. 

The city points to thousands of units in the pipeline, including nearly 3,900 units pending entitlement and more than 1,200 entitled but not yet built.

Zoning capacity does not equal RHNA compliance, which increasingly turns on actual permits and completed units—especially for lower-income housing—making the pipeline less a measure of success than a reflection of uncertainty.

Against this backdrop, the role of large-scale projects becomes central. 

Two proposed developments—Village Farms and Willowgrove—would together deliver roughly 610 affordable units. That represents approximately two-thirds of the city’s remaining lower-income RHNA obligation.

Without those projects, there is no foreseeable path toward RHNA compliance.

The city still needs roughly 900 affordable units before 2029. To meet that target, Davis would have to produce more than 200 affordable units per year over the next four years. Again, without those projects it is hard to see how this can be accomplished.

There is no existing mechanism in Davis’ current development pattern that can scale to meet that demand. 

Smaller infill projects and downtown developments, while important, tend to produce limited numbers of affordable units and depend heavily on subsidies. Accessory dwelling units do not meaningfully contribute to lower-income RHNA categories. 

Outside of these two peripheral projects, there is nothing else on the foreseeable horizon capable of delivering affordable housing at scale.

In practice, Davis has three main forms of housing production: small-scale infill and ADUs that are largely market-rate, mixed-use or downtown projects that provide limited affordability, and large peripheral developments—the only projects capable of delivering affordable housing at scale.

Remove that third category, and the system loses its only high-volume mechanism for meeting RHNA affordability requirements.

This is where Measure J enters the analysis, Measure J requires voter approval for peripheral development, effectively creating a gatekeeping mechanism for the very projects that produce the majority of affordable housing.

While that system reflects a longstanding commitment to voter control, it effectively prevents the approval and construction of large-scale projects—leaving Davis reliant on the same limited patterns that have produced just 805 single-family units over the past 17 years.

If Davis continues to underproduce affordable housing while rejecting projects like Village Farms and Willowgrove, the issue will not remain confined to local politics—the state will step in, and that is an outcome no one should want.

Under California housing law, cities are required not only to zone for RHNA, but also to avoid policies that constrain housing production, particularly for lower-income units. 

The state, through the Department of Housing and Community Development and the Attorney General, has increasingly taken an active role in enforcing those requirements. Recent cases signal a shift away from deference to local control and toward a focus on actual outcomes.

In that context, a plausible legal argument emerges: if Davis cannot meet its RHNA obligations because its own voter approval system blocks the projects necessary to do so, then that system may be in conflict with state law.

Such a challenge could come from multiple directions—the Attorney General, state housing agencies, or advocacy groups—and would likely focus on whether Measure J functions as a constraint on housing production.

HCD has already raised these concerns during the last Housing Element approval, signaling that policies like Measure J could undermine the feasibility of the plan and potentially conflict with state housing law.

In recent years, the state has taken an increasingly aggressive posture toward cities that fail to comply with housing law, with HCD and the Attorney General willing to pursue enforcement actions, decertify housing elements, and challenge local policies that stand in the way of meeting RHNA obligations.

In practice, this would mean that the state or a court will step in to override local constraints, effectively stripping Measure J of its ability to block housing and forcing approvals to meet RHNA requirements.

The risk of inaction is straightforward: the state will take away Measure J.

If Davis lacks a credible pathway to produce the remaining 900-plus affordable units, and if the primary barrier to that production is a local policy, the legal vulnerability becomes clear.

This reframes the debate over projects like Village Farms. 

The choice is not between perfect and imperfect developments, but between a small number of large projects that deliver substantial affordable housing and a fragmented system that has produced almost none at the levels required.

Davis’ housing challenge is no longer primarily about whether to build. It is about what kind of housing is built, at what scale, and whether the city’s policies allow that housing to move forward. 

The consequences of failing to answer those questions extend beyond affordability and into the future of local control itself.

The risk is not just that Davis will fall short of its housing targets, but that in doing so it will invite the state or the courts to decide how those targets are met.

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  • David Greenwald

    Greenwald is the founder, editor, and executive director of the Davis Vanguard. He founded the Vanguard in 2006. David Greenwald moved to Davis in 1996 to attend Graduate School at UC Davis in Political Science. He lives in South Davis with his wife Cecilia Escamilla Greenwald and three children.

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29 comments

  1. The problem with this article is with its assumptions, starting with the first sentence, which are “Davis will not meet its state-mandated housing requirements without large-scale peripheral projects like Village Farms and Willowgrove.”

    Even if approved, neither Village Farms nor Willowgrove will deliver a single unit by 2029. The earliest they can possibly be ready to issue the very first building permit is 2030, and that is probably a stretch. Look no further than Bretton Woods which was approved in 2018. It was 7 years before a building permit was issued for that project, and the technical challenges in creating the infrastructure at Village Farms dwarf the technical challenges at Bretton Woods.

    The second assumption the article makes is when it says, “If Davis continues to underproduce affordable housing while rejecting projects like Village Farms and Willowgrove, the issue will not remain confined to local politics—the state will step in, and that is an outcome no one should want.”

    The assumption that makes is that (1) as noted above neither VF nor WG will actually change the reality David paints, and the state knows that, so any judge handling the case will throw it out because what the state would be asking for would produce nothing different than the status quo, and (2) Davis will have enacted or implemented no policies that affected the sites currently in the approved 2021-2029 Housing Element. The state has gone after cities that have enacted impediment policies for projects within that city’s jurisdictional borders, but Davis has not enacted any such policies. The delays many of the certified Housing Element listed projects have encountered have been market and financial factors by parties other than the City not regulatory factors imposed by the City. Is the state going to sue the Federal Reserve for keeping interest rates high? Are they going to sue Don Fouts for willfully delaying Chiles Ranch? Perhaps they should sue the Sacramento Diocese of the Catholic Churbh for not putting its 5-acre parcel at Mace and Montgomery on the market to help settle its child sexual abuse liabilities.

    The bottom line on this article is FUD … sowing fear, uncertainty, and doubt in order to achieve a political outcome.

    1. If I recall, to meet the RHNA requirements; you just need to plan for new housing. Not actually have it built. I believe the city’s track record and likelihood of planned units being built is taken under consideration at the next RHNA cycle go round…unless it’s egregious like planning on a superfund site.

      I recall hearing that one of North Bay cities with a similar voter approved growth limitation as Davis is under fire by the state. So that bares watching closely. As for how state intervention could impact Davis? Something like the Davis Commons residential component that was nixed would have been approved over the protests of the neighborhood (not saying that would have been a bad thing). But basically any residential project proposed in Davis would have little to no local input.

      1. If I’m not mistaken myself, Davis Commons was approved (and has existed for more than 25 years, at this point). And the residential component is on University land – in back of the little mall downtown.

        Are you thinking of the University Mall redevelopment – which was approved by the city (but the developer decided to stick with their original plan to rebuild the commercial mall – without residential development on the upper floors)?

        In other words, the city’s interest (aka, “insistence”) in adding residential actually delayed the redevelopment of the mall at that site by at least a couple of years or so.

        1. Yes, Davis Commons. Delayed but the plan with the residential component that was on the table for approval would have gone through if the state had intervened.

          1. I believe it’s called “The Davis Collection”.

            Again, the city APPROVED residential development within that mall. The developer (who had no plan to include residential, initially) backed out of the residential component themselves AFTER the city approved a residential component.

            I saw the city council meeting myself, when the residential component was approved.

            It was somewhat of a shock when the developer backed out sometime later.

            The result is good, however – and one can “almost” find parking in there (which would have been much more challenging if it also included residential).

            Just the other day, someone commented on NextDoor regarding near-fights over parking at that redeveloped mall.

          2. “Again, the city APPROVED residential development within that mall. The developer (who had no plan to include residential, initially) backed out of the residential component themselves AFTER the city approved a residential component.”

            The residential component was recommended by a city staff person who is no longer here. The developer was reluctant from the start and they were unable to find any development partners willing to do the residential part. The whole idea of residential there was a complete waste of time and delayed the project unnecessarily.

          3. There is a second piece to that though and that is that it’s so difficult to build housing in Davis at scale that the city is basically jumping on every opportunity to do infill because we see how difficult anything else is.

          4. David – that’s the way it’s SUPPOSED to be (even in your own stated view, as well as that of the YIMBYs).

            In other words, promote infill rather than sprawl.

            Yes, it’s more expensive to build infill. And since Davis is not really a very expensive city (compared to someplace like San Francisco), it’s more difficult for infill to “pencil out” compared to San Francisco.

            The YIMBY movement gained traction as a result of pursuing economic development in already-expensive areas. At which point the interests behind the economic development turned against existing residents (and funded the YIMBY organizations).

            Granted, the existing residents probably didn’t complain much, when Google (for example) built their complex. And were happy to see their housing prices rise as a result (right up until the time that a “tech bro” apartment or condo development was approved next-door to them).

            Except for places like Atherton, where the actual owners of those companies are powerful enough to keep out the riff-raff. In other words, the billionaires forcing the millionaires to accommodate the needs created by their companies.

          5. That’s not the point I’m making here. My point was that it would have been a dereliction of duty by the city to not at the very least contemplate what housing across the street from the university might look like.

        2. Shows how stupid of a name it is if I keep screwing it up.

          Hmm….well I guess it goes back to what my other post said that Beggars (Davis) can’t be choosers.

          1. I have trouble with names, myself. Have to look them up almost every time.

            I prefer to call it the “Trader Joe’s Mall”.

            Davis Commons (which includes the residential development that is apparently on UCD land behind the small mall downtown) seems ideal for UCD employees. And extremely convenient in regard to working at UCD, and shopping at the adjacent mall or downtown. Also seems to be a site where cars are only needed if residents travel outside of town.

  2. I received an email just now that says, ”I see in today’s Vanguard, that David has gone back to pretending that Village Farms will deliver affordable housing. Didn’t he admit in yesterday’s article that Roberta Millstein had thoroughly illustrated how those chances were between slim and none?”

  3. I just received an email from David asserting that his position yesterday was not in agreement with Roberta. However Roberta took the trouble in a follow-up Davisite article to illuminate the very specific statements of agreement that David made. I encourage everyone to read that article by Roberta. It can be accessed at https://davisite.org/2026/03/23/an-exchange-over-misleading-village-farms-promises-about-affordable-housing/

  4. Dishonest article, partly for the reasons that Matt provided.

    Also, cities near the coast (where the vast majority of the population lives) are not expanding outward to address RHNA targets. Most of those cities are already more dense than Davis is, and yet they are also managing to submit and receive approval for fake housing plans from the state.

    The absolute failure of the state’s “mandates” is at a scale that is unprecedented in the entire history of “mandates”.

    I really should thank YIMBY Law for tracking this. (They probably didn’t realize it would be cited in this manner.)

    https://cities.fairhousingelements.org/

    Also, I am relatively confident that Davis voters are not going to approve “two” massive sprawling proposals, and probably won’t even approve one – regardless of what David writes. And again, as Matt and others – including Bapu have pointed out – there is no viable funding to actually build Affordable housing.

    Don’t know if either of these proposals even tries to address the housing “mandates” (at lower/middle income levels) in the first place, but any plan submitted to the state which includes Affordable housing at those sites within a given RHNA cycle is “by definition” fake.

      1. Did you not read my comment?

        And are you referring to the already-approved housing element, or some future housing element?

        Go ahead and break down whatever you’re talking about, in regard to the 900 units.

        There is no path with, or without those developments.

        There are only fake paths – just like the path that every other city in California submitted to the state (and received approval for).

        In other words, rezoning existing, developed sites within those cities for proposals that will never be built. (Pretty sure I can do it myself, if you give me a marking pen and a map.)

        Basically, resulting in a fake destruction of large sections of the city, and rebuilding those sites with housing that’s “somehow” cheaper than what’s already there. (Try to make that pencil out, by the way.)

        That’s the plan for the entire state in a nutshell. I can probably create fake plans for every city in the entire state myself within an hour or two.

        1. Ron O
          You’ve avoided the question. Your “solution” of a falling birth rate is decades away until children born today reach their 30s (even if that happens). We have a crisis NOW that is keeping younger people out of houses where they can form families and comfortably have children–that’s why the birth rate has fallen. You’re ignoring the circular (endogenous) forces that are creating the situation you keeping pointing toward. Your solution is akin to controlling the population by starving them. Just because you have your own comfortable abode in Woodland doesn’t mean that we should ignore the plight of those who are younger than us.

          So make a proposal as to how we provide affordable housing for younger workers near their jobs? (And please don’t show you’re ignorance by trying to assert businesses should move to where there are workers–that’s not at all how the economy and society works–that’s a fantasy.)

          1. You’re referring to a different subject, Richard.

            David is referring to fake housing elements. And now that I look at his article more closely, he’s apparently referring to the existing fake housing element in regard to the 900 units. In other words, it’s already been addressed (it just won’t be built).

            As for what you’re referring to, show me a plan that will result in housing in Davis that will cost the same as housing in Woodland. (Neither you or anyone else can even show us a plan that will result in the same cost WITHIN any given city.)

            And again, there is no net increase in hiring at UCD’s Davis campus or in the city. And as soon as they close down a school or two, there will also be less demand from those workers.

            I asked both you and David (several times, now) how much housing prices were reduced (or even kept “in check”) when Mace Ranch, Wildhorse, The Cannery, and Spring Lake were built. And despite being the crux of your argument, neither you nor David have been able to put forth any numbers.

            Davis has about 100 housing units being built right now at Harvest Glen, and another (30?) or so at Pole Line Terrace. The cost is $825,600 for the smallest model at Harvest Glen.

            None of these new developments have anything close to resembling a “backyard”.

          2. Correction/update: Looks like there aren’t any of the 1,472 square foot $825,600 units available right now at Harvest Glen.

            The cheapest one is a 1,736 square foot unit for $913,580.

            https://www.centurycommunities.com/find-your-new-home/california/northern-california-metro/davis/harvest-glen/?utm_source=google_local&utm_medium=organic&utm_campaign=harvest-glen_gmb_ccs&utm_content=california

            So, it does appear that the imaginary, low-income “Davis” workers trying to buy a new house in Davis are out of luck.

            Turns out you can’t buy a house on a Starbucks salary – even a pre-existing house in Woodland for that matter. That “dream” is apparently more dead than the fake housing elements are.

            And apparently, home ownership is not a “human right”, after all.

          3. Limiting housing to control population is Ron O’s preferred outcome. That is why I refer to him as a Malthusian Troll.

          4. Ron G: There’s no need for name-calling. Availability of housing is apparently not what is causing 1.6 kids per couple (nationwide).

            It is interesting, though. In the “old days”, young people had lots of kids while living in shoeboxes. My own family started out that way (in a sense), before I was born. I’m the last one in that brood (they saved the best for last). I don’t even remember when the oldest sibling lived at home (and barely remember the second-oldest being there).

            The young “chicklings” apparently forced out the ones able to fly.

            By the time I came along, the family was in much better shape. I like to think that I timed it that way, on purpose.

            But if you look at those photos of the depression era, for example (with kids) – yikes!

      2. “Show me a path to 900+ without VF or WG”|

        We Fix Measure J in November. Thats the path.

        V isnt going to pass, we know this. Remember the saying about the definition of insanity? Why are we even taking the bait here?

        Lets focus on the solution we have already been talking about for years now to the REAL problem.

        1. You do realize, I’m sure, that eliminating Measure J has less chance than Village Farms or Shriner’s (whatever they call the latter, these days).

          Though I think you and the other 3 people on your group have some chance at defeating Village Farms and encouraging/enabling a more-successful proposal more to your liking a few years down the road.

          Even “I” think that the site will eventually be developed on a scale that sacrifices less farmland. (Perhaps the last successful one ever attempted outside of Davis’ boundaries.)

          Shriner’s is a worse-location than Village Farms.

          1. ” eliminating Measure J has less chance than Village Farms or Shriner’s ”

            Willowgrove (it’s only in the article)

            Tend to agree in terms of voter inclinations, but the most likely path towards eliminating or more likely changing Measure J is still the state or another entity suing.

  5. “Davis’ housing challenge is no longer primarily about whether to build. It is about what kind of housing is built, at what scale, and whether the city’s policies allow that housing to move forward. ”

    Yes, I agree with this statement. However I strongly disagree with the unfounded belief that we MUST accept what is currently being offered as yesterday’s article stated. We have a ready alternative available in the Draft EIRS for both projects. The reasons used to override the Environmentally Preferred Alternatives (4 for VF and 3 for WG) are very lame and have no evidentiary support. (If anyone is interested in challenging the these overrides in court if the projects are approved, please contact me.) Those alternatives both better comply with the City’s CAAP but also provide much more market-rate affordable housing. It should be no more difficult to produce deed-restricted Affordable housing for those options either.

    David, why are you not addressing this failure to pursue the Environmentally Preferred Alternatives? You wrote an article this week pointing out that we need to consider climate change in choosing how to provide housing. Why are you ignoring the very mandate that you expressed in the case of Davis?

    Once entitled and with infrastructure, the developers of VF and WG will be able to sell their property for at least $1.1 million per acre (after adjusting for roads and open space) with development costs of about $200,000/acre based on surveying various research sites. On top of that the sales revenue per acre increases with increased density. That leaves a substantial profit that can be applied to meeting these objectives. The issue is not that the developers will make insufficient profit but rather that we need to demand that they step out of their current MO that has led to the suburban sprawl that created this problem in the first place.

    1. Sure, but the choice the voters must make in this election is what is on the ballot or maybe something else somewhere down the road. Or maybe nothing at all.

    2. Richard, most of what you and your lot fail to accept is that in the case of Davis and proposed projects; beggars can’t be choosers. I mean sure you can shoot down the current proposal. You just need alternative Davis projects and builders that meet your New Urbanist requirements. I’m sure there’s a long list of alternative projects and builders lined up out the front door just clamoring for an opportunity to submit their projects. Because if you don’t have alternatives in hand and you continue to hold up and deny the projects that are actually on the table for approval; you’re going to continue to end up with few new homes built in Davis.

  6. “Vanguard Analysis: Without Two Peripheral Projects, Davis Cannot Meet Its Housing Requirements”

    Ask me if I care.

    “The risk of inaction is straightforward: the state will take away Measure J.”

    How stupid is this argument? If we take ‘action’ by not ‘blocking’ housing, we can keep the tool that ‘blocks’ housing, otherwise, it will be taken away, and we won’t be able to ‘block’ housing anymore.

    I have yet to here a convincing explanation as to why we are legally required to expand our borders just because there is undeveloped land around us.

  7. Public transportation can’t compensate for bad planning.

    Good planning starts with core public transportation infrastructure, either built or fully funded.

    It’s unfortunately partly out of control of the City of Davis to implement a stronger regional public transportation system, which would support additional population without increasing burden on the current system – at the very least, it should improve it… however, at least a couple of current council members and pretty much everyone else at the county level as well as representatives in the state government and House have supported the I-80 thickening which is already going to be headed towards the end of it brief improvement as VF get its first residents. The hundreds of millions used for that project could have been used for improvements to rail services using existing infrastructure. A study that established this was effectively shelled by Caltrans. All of these politicians are complicit in long-term transportation problems in the region. #progressiveexceptfori80

    If the state requires new housing, it needs to provide substantial funding so that the housing does not further worsen local transportation conditions.

    We have met the enemies, and they are:
    * Populism with performative environmentalism and equity;
    * Motonormativity;
    * Hierarchies:
    + Subservience to millionaires who have fleeced generations of parents UC Davis students.
    + The inability of development and engineering staff to stand up for what they know is right;
    + The City’s unfortunate place in the food chain, lower than Caltrans and Union Pacific;
    * WAR! It’s perhaps obvious, but it’s worth noting that, for example, the current daily spending from the USA on the war against Iran could pay for 1000 miles of high-quality cycling infrastructure… every day.

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