In a recent comment to the Vanguard’s article that reports that Davis has only built 805 single family units over the last 17 years, Matt Williams raises a number of thoughtful questions about the city’s recent housing production report, and serious questions deserve serious answers.
But the data in the report—and a growing body of housing research—actually point in a direction quite different from the conclusion Matt appears to draw.
The numbers do not suggest Davis has built too much market-rate housing. If anything, they show the opposite: Davis has built very little housing overall, particularly ownership housing, and the shortage is one of the key drivers of the affordability pressures we see today.
The city’s staff report lays out the basic facts. Between 2009 and 2025, Davis added a total of 2,818 housing units. Over a 17-year period, that averages roughly 166 units per year. Of those, just 805 were single-family homes.
That is about 47 new houses per year in a city of roughly 70,000 people that is home to one of the nation’s major research universities.
Those numbers alone should give pause to anyone arguing that Davis has already produced enough market-rate housing.
The report also provides a breakdown of the types of housing built during that period. Only 28.6 percent of the housing produced since 2009 has been single-family homes, while 56.6 percent has been multifamily rental housing (mostly in the form of student housing) and about 9 percent accessory dwelling units. Multifamily ownership units—condos or similar products—account for only 5.5 percent of the total.
The City Council adopted targets for housing types in a resolution (11-077) back in 2011.
Those targets suggested a mix of roughly 40 to 60 percent single-family housing, 10 to 25 percent multifamily ownership housing, and 30 to 40 percent rental housing.
The actual production numbers fall far short of those targets for ownership housing and far exceed them for rental housing. (I’m not criticizing the prioritization of student housing at that time given housing shortages for students).
The bottom line however is that the data do not show an oversupply of ownership housing in Davis. Indeed, they show a significant shortfall.
Williams also questions the article’s discussion of the 963 housing units permitted so far in the current RHNA cycle.
Of those 963 units, only 28 have been extremely or very low-income units, two have been low-income units, 522 fall into the moderate category, and 411 are categorized as above-moderate income housing. That leaves the city with hundreds of affordable units still to be produced if it is to meet its state-mandated housing targets by 2029.
(Yet Matt Williams then appears at least to oppose two projects that could supply the bulk of those affordable housing units).
It is worth noting that the city’s methodology generally classifies single-family homes as above-moderate income housing.
Most newly built single-family homes are assumed to be purchased by households with above-moderate incomes unless they are explicitly deed-restricted as affordable units.
Williams’ broader point seems to be that building more market-rate housing does not address affordability because many of the jobs being created in Davis are moderately paid. It is an understandable intuition, but one that housing economists increasingly view as incomplete.
Over the past decade, a growing body of research has examined how housing markets actually function. One of the most important findings is the role of what economists call “housing chains” or “filtering.”
The basic idea is straightforward, when a new housing unit is built—even a relatively expensive one—it rarely serves only the household that first moves into it.
Instead, that household vacates a previous home, that home then becomes available to someone else, who in turn leaves another home behind. The process continues through multiple steps, creating what researchers call a moving chain.
Studies examining these chains have found that building 100 new market-rate homes can free up roughly 70 homes elsewhere in the housing market, including units in middle- and lower-income neighborhoods.
The effects ripple through the housing market because people move as their incomes, family circumstances and housing needs change, making housing supply dynamic rather than static.
This dynamic also explains why housing shortages produce the opposite effect.
When cities severely restrict new construction, higher-income households do not disappear. They compete for existing homes instead.
That competition pushes prices upward throughout the market and prevents older housing from becoming more affordable over time.
Economists call this “filtering up,” where older homes fail to become starter homes because demand far exceeds the available supply.
That pattern is visible across California and other high-demand regions, where housing production lags far behind demand, driving up prices for both new and older homes.
The Davis numbers fit squarely within that pattern.
Over the past 17 years, Davis has produced relatively few housing units even as demand has continued to grow due to UC Davis enrollment, regional job growth and the city’s desirability as a place to live.
Matt Williams raises an additional point about employment growth, citing U.S. Census data suggesting that roughly 2,333 jobs were added in Davis during the same period when 2,818 housing units were built.
That comparison misses a key factor: much of the housing built during that time was multifamily housing largely absorbed by UC Davis students rather than the local workforce.
In addition, housing markets operate regionally, not within strict city boundaries, meaning many people who work in Davis live in surrounding communities such as Woodland, Dixon, West Sacramento or Sacramento, while many Davis residents commute elsewhere for work.
The more relevant question is not whether the city added slightly more housing units than jobs over a given period, but whether the overall housing supply keeps pace with regional demand. On that measure, most indicators suggest Davis remains constrained.
Another point worth emphasizing is that new housing is almost always the most expensive housing when it is first built and that has been true throughout modern history.
Over time, however, housing ages and depreciates relative to newer construction. Yesterday’s luxury housing often becomes tomorrow’s middle-class housing and eventually older, more affordable housing.
Much of the affordable housing stock in American cities today was not originally built as subsidized housing but instead became affordable over time as it aged and newer homes were built elsewhere—a process economists call “filtering,” which research has shown accounts for the majority of low-cost housing in the United States as older market-rate homes gradually depreciate and become accessible to lower-income households.
None of this means that subsidized affordable housing is unnecessary.
Far from it. Public investment in affordable housing is essential for households who cannot afford market rents even in a healthy housing market.
But it does mean that limiting overall housing production can make affordability problems worse rather than better.
The Davis housing report also notes another important reality: construction does not occur automatically when projects are approved.
Financing conditions, labor availability, construction costs and interest rates all affect when projects move forward.
That is why housing production often fluctuates significantly from year to year.
A large apartment project may deliver hundreds of units in one year, followed by a slower period as the next project works its way through financing and construction.
That variability is normal in housing markets.
It does not change the underlying trend, which in Davis has been a relatively modest pace of construction over nearly two decades.
Reasonable people can disagree about how Davis should grow and what the right balance of housing types should be.
Any serious discussion should begin with the data, which show that Davis has built relatively little housing overall and significantly less ownership housing than the city’s own targets anticipated.
In that context, the claim that Davis already has enough market-rate housing becomes difficult to sustain.
If anything, the evidence suggests the opposite: the city’s limited housing production has contributed to the affordability pressures many residents feel today.
Increasing housing supply—while also continuing to invest in affordable housing—remains one of the most practical ways to address those pressures over the long term.
That conclusion may feel counterintuitive, but the research and the local data increasingly point in the same direction.
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David Greenwald said … ”Over the past decade, a growing body of research has examined how housing markets actually function. One of the most important findings is the role of what economists call “housing chains” or “filtering.”
The basic idea is straightforward, when a new housing unit is built—even a relatively expensive one—it rarely serves only the household that first moves into it.
Instead, that household vacates a previous home, that home then becomes available to someone else, who in turn leaves another home behind.”
That theory makes sense in a community that is not a single-employer town, especially when that employer is a University. The reason is simple. Universities grant tenure to their professors, and tenure causes those professors and researchers to stay in one place for a very long time.
Additionally, universities are K economies (actually E economies is an even better visual image). The tenured professors are the top bar, snd once there they don’t depart.
The bulk of the university employees are the support staff in the bottom bar, and for the most part they do not earn enough in salary to have the $270,000+ household income needed to afford/qualify for one of the $850,000 and up houses that are the kind of SFRs developers in Davis have built in the past two plus decades.
The middle bar of the E are the kind of people who make David’s “filtering up” system work, but in UC Davis those people don’t filter up, they filter out … going to other communities where they can (1) join a different university or college faculty, often because they know they will not be offered tenure at UCD, and also often that they believe being exposed to different university learning experiences makes their resume more attractive to a tenure-granting college or university, or (2) they can take their built-up intellectual property to the private sector. Unfortunately, neither UCD nor the City of Davis have been able to make that private sector community be Davis.
One only needs to look at the economic impact report(s) done on UCD to see how massively powerful that middle bar of the local E economy is. All you need to do is to put the economic impact into two piles/categories (A) the impact within the City of Davis and (B) the impact beyond the City. The comparison of (A) and (B) is crystal clear. The vast majority of UCD’s economic contributions go to places other than Davis. The moribund and anemic local Davis economy is clear evidence of how thoroughly the people who would make “filtering” happen are going to another town other than Davis in order to “filter up.”
Further evidence, of how little “filtering up” takes place in Davis is shown by the purchase history of the ownership SFRs in The Cannery, where well over half of the buyers came from the Bay Area, and another portion of the buyers were institutional investors purchasing the home in order to rent it to people in the middle bar of Davis E economy.
All this leads to the simple conclusion that (1) “filtering up” has only limited application in Davis, and (2) the only way we are going to get market rate affordable housing is to build smaller houses on smaller lots … housing that the Davis workforce and the bottom bar of UCD’s E Economy can afford to buy.
The biggest problem with your argument is you seem to assume that filtering must occur within Davis itself – whereas in the real world, the chain extends through dozens of moves across multiple cities. Thus, the fact that buyers come from outside of Davis does not invalidate the theory – it demonstrates it, and with that point your argument largely falls apart.
This is true because even if a Bay Area buyer purchases a new home in Davis, the chain still occurs because that buyer vacates a home somewhere else.
In addition, the Davis housing market is embedded in the Sac regional housing market. As such, housing scarcity pushes workers outward and when Davis restricts housing, the result isn’t that they disappear instead they commute from farther way – that is what we are seeing and the byproduct is more traffic and GHG admission.
The Cannery example actually reinforces this point. If we assume that more than half the buyers came from the Bay Area, this suggests that Davis housing demand extends beyond the local workforce and the city is part of a broader regional market.
If you belief the answer is to restrict the suppply that does not eliminate the demand and in fact simply pushes prices higher because it shifts the buyers elsewhere.
So you conclude that “filtering up has limited application in Davis” but that claim is not supported by the evidence – in fact just the opposite.
This is true because even if a Bay Area buyer purchases a new home in Davis, the chain still occurs because that buyer vacates a home somewhere else.
So what you have in that case is someone who lives in an environment in which public transportation is robust and air conditioning may not be needed, who moves to an area that can only be described as “sprawl”.
The fact that they’re “replaced” in their previous housing does not negate the fact that this is resulting in sprawl and greater reliance on cars for the state, overall.
Had they just stayed where they were, this wouldn’t be occurring.
The people leaving the Bay Area are a combination of those who didn’t own houses (and may become “priced out” as a result of the pursuit of the technology industry, for example (assuming that they don’t live in rent-controlled units), and homeowners who want to “cash in” and buy a McMansion in the Sacramento region.
Not sure that the latter in particular is “helping” anything.
The technology industry itself pursues H1 visa (non-citizen) workers.
You assume that the Davis Housing market is embedded, but what is that assumption based on? Housing doesn’t exist in a vacuum. You can just as easily assume that housing exists to support/augment employment.
For decades, if not centuries, we as a planet have cared little about environmental impact, so regional jobs were supported by regional housing, and we incurred VMTs and spewed GHGs in copious amounts. However, unless you are Donald Trump or one of his acolytes, we now are trying to reduce VMTs and GHG emissions, so arguably so regional approach you describe is irresponsible environmentally.
Further, if your argument were correct then the fact that 17,000 people commute into Davis each day to work would be irrelevant … because we are “embedded in the Sacramento region.”
I actually think you have this backwards. Period the fact that roughly 17,000 people commute into Davis each day is not evidence that the housing market isn’t regional, it’s evidence that it is. When a job center doesn’t produce enough housing for its workforce those people live in surrounding communities and commute, which is what we’ve seen. If anything, the commuting pattern strengthens the art document that Davis simply hasn’t built enough housing locally. And those have impacts, including VMT and GHG.
They’re not commuting to Davis, and are almost able to bypass it entirely.
How many Davis workers commute out of the city (not to UCD)?
And why were you advocating for DISC, if you were already concerned about a local housing shortage?
The price differential is what causes people to seek housing outside of Davis. Well, that plus the fact that workers in a given household don’t usually work at the same location.
We’ve been through all of this many, many times now.
By your measure, downtown Sacramento has a shortage of housing. But the reason that Sacramento workers pursue housing in places like Roseville is because they want a normal house, a garage and a yard at a relatively reasonable price, in a good school district, in a safe neighborhood. None of which downtown Sacramento offers. (Actually, there’s some similarity regarding Davis vs. Woodland, but in that case – it has to do with the difference in price.) Those with less money pursue places like Natomas (what a freeway hellhole that’s become. Have you seen it, lately?)
Elk Grove is probably sort of in the “middle” regarding the type of people who pursue housing, there.
But again, unless you have some way to discourage sprawl in other nearby communities, what you advocate is not going to work. This is also the entire problem with the YIMBYs – they advocate for infill, sure. But they’re amazingly silent (at best) regarding discouraging sprawl. (For that matter, those people support the “California Forever” development – which exposes that they don’t actually care about reducing sprawl at all.)
David, you treat housing as if it is a monolith. It isn’t. It has segments and even niches. The segment of $1 million houses is very different than the segment of $500,00 houses. The segment of 900 square foot houses is very different than the segment for 2,200+ square foot houses. How many houses have been built in Davis in the two former segments over the past 10 years, and how many for the two latter segments?
Similarly, housing demand is not monolithic. A two-income household of two DJUSD teachers is very different than a two-income household where one of the income earners is a tenured UCD professor. The first question a real estate broker asks new clients is, “What is your budget?” Or “What can you afford?” Depending on what the answer to those questions is, the broker puts those new clients into one of the different market segments. The vast majority of the 17,000 if asked those questions, will give answers that say they can not afford a $1 million houses, but they can afford a $500,000 house. But since we have almost no such houses in Davis, because none have been built, they are forced to look elsewhere. The demand they represent is determined by the location of their job(s). The fact that they live outside Davis does not change that.
I don’t disagree with Matt overall, but I did notice this:
A two-income household of two DJUSD teachers is very different than a two-income household where one of the income earners is a tenured UCD professor.
The solution to that particular theoretical problem will present itself when DJUSD “right-sizes” itself. At which point, BOTH of those mofos might have to get jobs in the communities where they actually live (and where their services are actually needed), rather that commute to Davis (which has a declining need for such services).
I believe this is my fifth comment, and David has asked me to limit myself to no more than that per article, per day.
Ron O
“How many Davis workers commute out of the city (not to UCD)?”
Here’s your answer that looks at commuting in and out for Davis/UCD as whole (because walking and biking across Russell Blvd, which 70% of UCD employees do, it not commuting “out of town.”)
https://mcubedecon.com/2025/11/24/reconciling-census-on-the-map-commuter-patterns-with-other-employment-data-a-case-study-in-davis/
David Greenwald said … ”The more relevant question is not whether the city added slightly more housing units than jobs over a given period, but whether the overall housing supply keeps pace with regional demand.”
How does that statement make any sense in a world where we are trying very hard to reduce GHGs and VMTs? You want people from the region to move to Davis and then commute to their job(s) outside Davis? You have said some pretty absurd statements over the years David, but that one is possibly the most absurd one ever.
The SFR houses that developers have built in Davis over the last two decades all have prices that require a more than $270,000 household income to afford. Davis has an extreme shortage of those kind of jobs, and as a result we have well over 20,000 people who leave Davis and commute to their well-paid job incurring VMTs in the process and spewing GHGs.
That regional demand generated by jobs elsewhere should be supported by housing near the jobs.
You want people from the region to move to Davis and then commute to their job(s) outside Davis?
That’s what I did. At first, was working within the city of Davis for a government agency. But as I wanted to advance, I had to seek employment elsewhere (Sacramento, in my case).
Unless you’re a tenured professor, a given worker isn’t necessarily tied to their current employer.
People (such as myself) moved to Davis because it was (and still is) CHEAPER than where they’re from, and the difference in regional salaries isn’t that much lower. In fact, the area (Sacramento in particular) offers far opportunities than some place like San Francisco.
But as long as Spring Lake offers cheaper housing, that’s where your lower-income UCD workers are going to choose to live (if they want to buy a new house, at least). It’s easier to get to UCD from Spring Lake (especially the portion that’s adjacent to Highway 113) than it is to get to UCD from WITHIN parts of Davis.
1,600 more housing units to come at the “technology park” in Woodland, adjacent to Highway 113.
There is no housing shortage (local, or otherwise). UCD isn’t even increasing their net number of employees. But there’s nothing stopping them from building housing for their own employees on campus either, as they originally proposed to do. They ALREADY operate a housing development on campus (apparently not limited to students), in back of Davis’ downtown shopping center. Tiny, detached single-family houses, on land owned by UCD.
But again, more housing is not needed in the first place. Presenting meaningless “data” doesn’t change that.
Now, if Davis could control what Woodland builds, you might be able to present an actual argument. But as it is, there is no data whatsoever which shows that there’s a “housing shortage” in Davis.
Correction: I just looked up some information regarding “Aggie Village”, and it doesn’t say who actually owns the land. In any case, here’s what the local Wiki page says regarding the “cottages”:
The cottages are part of the Aggie Village development, and are owned and rented out by the owners of the big houses that share the property. The owners of the houses are required to be UC Davis faculty or staff, but they may choose to rent their cottages to anyone. There are 16 cottages total, four on each end of the development and eight around the center courtyard.”
https://localwiki.org/davis/Aggie_Village_Cottages
And here’s what the local Wiki page says about the entire “village”:
“Aggie Village is a housing development designed to provide a unique neighborhood for UC Davis faculty and staff.”
https://localwiki.org/davis/Aggie_Village
In any case, that small development seems ideal for those who work at UCD, and is one of the first things I noticed when I moved to the area. Perhaps someone can clarify if UCD actually owns the land.
UCD owns the land but it is gerrymandered into the city so that the faculty who live there can participate in the civic life of the city while those who live in student housing elsewhere on campus are excluded from similar participation in the civic life of the city.
All this nonsense about the sourcing of who housing development should be targeted to is nonsense and is reminiscent of the days of red lining, segregation and restrictive deed covenants.
Right when the County is trying to address these out of date methods of discrimination we now have this new demand for who we should be building housing for based on some ideal environmental nonsense that purports to be about minimizing carbon footprints but actually aims to limit social mobility and demonizes outsiders.
I will accept your criticism. I am indeed trying to help the less financially fortunate achieve the dream of home ownership. Without building smaller houses with smaller prices the people in that demographic cohort will not find any homes they can afford to purchase. Your criticism goes both ways. By advocating for the continued building of large footprint high-priced homes, you are discriminating against the majority of the Davis work force.
For example, the starting base salary for a teacher in the Davis Joint Unified School District (DJUSD) is approximately $55,000 per year. This figure reflects updated compensation for the 2023-24 school year as negotiated by the Davis Teachers Association. Two teachers in a household brings the total salary up to $110,000. Under the HUD guidelines that supports $33,000 of annual housing costs. In Davis a $750,000 home with a 90% 6.5% mortgage the housing costs are over $80,000 per year. The only way to bring those $80,000 in housing costs down to the vicinity of $33,000 is to reduce the sales price.
Further, in Yolo County the annual income limit to qualify for Low Income Affordable housing is $63,450 for a two-person household, $71,000 for a three-person household … well below $110,000, so those teachers won’t be eligible for the deed-restricted Affordables.
Do you see how you are discriminating?
Matt said: “(2) the only way we are going to get market rate affordable housing is to build smaller houses on smaller lots … housing that the Davis workforce and the bottom bar of UCD’s E Economy can afford to buy.”
I’m not sure market rate affordable is going to accommodate the bottom rung of the E Economy. If we could get opportunity to the middle rung it would be a good step forward.
But let’s go for it Matt, lets build another project that targets that market. Its not an either or proposition. Its an are we going to build or not question.
Fair enough Ron, but the folks in the middle rung of the E are consistently leaving town because there are no jobs for them here. They finish their academic endeavor and split town. They go where their employment opportunity is. And they often leave town with substantial student loan debt/payments. If you were a 4th year undergrad, or a graduate student TA, or a researcher with one or more patents that you want to exploit in the private sector, would you stay in Davis?
You are generalizing. Its a problem with the naysayers repeatedly making assumptions about why people are making decisions. People make these decisions based on all sorts of personal realities and criteria about where to live.
The average American moves 10 – 12 times in their lifetime.
Building equity in an older or smaller home and then trading that in to purchase a more expensive, newer, or bigger one is very standard. As families grow, most people want more room. They don’t want high density. Where they work vs where they live is less of a factor than it used to be. The major home buying factors are location, schools, and space.
Davis has many amenities that people want, and some home buyers would certainly be willing to move to a more expensive home in Davis once they have the income and savings to do so.
Woodland, West Sac, and Dixon will always be there for cost-conscious home buyers, but they are not the whole market by any stretch. Many of the people buying or renting there, and working in Davis, would like to trade up to live in Davis for any number of reasons.
We often project our own buying preferences onto others when we make blanket statements about what people will or won’t do. Price is the primary factor for some but not all buyers.
Trying to force home builders to build the mix of housing that you prefer simply ends up being another method of obstructing housing development overall. Unless you have a landowner and developer willing to do what you want, your preferences are meaningless. Davis doesn’t have a whole lot of developers clamoring to work in this market, and the city’s reputation as being a difficult place to do business goes back several decades. It isn’t staff, it’s the voters that have cemented the reputation.
Davis home building has not kept pace with regional housing demand. Slicing and dicing the housing and lot sizes is a fruitless exercise based on flawed assumptions, destined to fail because the people who actually control the land and construction aren’t on board with the micro-management that some Davis community members want to exert.
Don
People now live in their homes an average of 13 years and that is lengthening. It was only 7 years just 25 years ago. This slower turnover. This has become a problem because of different policies we’ve adopted. One of those is oversupply of large single family houses that can’t be afforded by younger households no matter how old they are, and an undersupply of the shared wall and smaller square footage housing that they can afford. The studies from the National Association of Home Builders that I have posted here previously back up this observation. Leaving this choice to developers alone is how we got into this mess in the first place, so why do we believe that they will start making the right choice now?
While the “chain purchase” theory sounds good, and I subscribed to it at one point, the problem in Davis is that many/most of the homes that started out “affordable” have been remodeled to appeal to a more expensive market. The vast majority of 1950s houses on my street don’t look much like when they were originally built. That’s where that theory falls apart. It’s obviously not working now because housing has become truly affordable for a long time–it was unaffordable in 2006 during the last building boom. In 2006, only 17% of California households could afford the median price for a house, and we’re approaching that again.
“the folks in the middle rung of the E are consistently leaving town because there are no jobs for them here. ”
Maybe, but its more likely that they leave because there is no housing here for them.
You can’t pay off your student debt if you don’t have a job, and you go where your job search has a successful conclusion. Did you ever move to a city without already having a job there?
My experience has been that my employer demanded that I move to Nashville in order to be close to my job.
That is a small slice of the economy. In Davis there are workers who live in Woodland who, if there was more housing availability that suited their needs, would live here instead. You see them driving to town every morning in cars instead of on e-bikes they might ride if they lived in town.
Actually Ron that group is a very large part of the Davis community and economy.
8,283 Undergraduates earned their degrees
364 Master’s and 422 MFA/Doctoral students earned their degrees
142 DVM students, 34 residents, and 8 Master’s students earned their degrees
That is 9,253 people on the middle bar of the E just in a single year, and another 9,000 the next year and another 9,000 the next and the next and the next. And the total population of the middle bar of the E is 4 times 9,000 … more than 36,000 in all.
Of the non-student population (approximately 43,000 in the last Census) how many move away from Davis each year? It is a fraction of 9,253.
Regarding the Davis economy I’m amazed you haven’t seen what the Davis economy has become. It is a service economy, and if the typical patrons of the service businesses of Davis are a good indication (and of Target as well) the largest group of patrons are the folks in the middle bar of the E.
You see them driving to town every morning in cars instead of on e-bikes they might ride if they lived in town.
Not sure who you think would then move into their houses in Woodland, but I can tell you that the same type of knuckleheads who “drive” their kids to school exist there, as well – blocking traffic and wasting gas. Just as they do in Davis and everywhere else. (Though I will say that they seem to know the “routine”, at least. Unlike me, who sometimes gets unexpectedly stuck behind them on city streets.)
Though it is true that pursuing “families” would result in more teenagers, at least, running over senior citizens on their e-bikes (electric motorcycles). Those knuckleheaded-parents are also in Woodland.
“Gee, I wonder what would happen if I allow my teenage boy to have a 50 mph electric motorcycle, and set him loose on the street and in parks?”
But hey – at least they’re not wasting gas (up until the point that the ambulance is called).
“Regarding the Davis economy I’m amazed you haven’t seen what the Davis economy has become.”
As always it depends on how you define the Davis economy. The city itself is a service economy but if you include the UCD workforce you get a totally different economy. If you include people you never see who work from home on a partial or full time basis you see another economy. If you include people who live in Davis but work regionally you get even a different economy.
Getting back to the subject of this article (which is really about resistance to school closures), is DJUSD going to give back the Patwin campus to the descendants of the Patwin people, when they close that campus?
They’re pretty easy to find, since I understand that they’re operating a casino in the Capay Valley.
In any case, this would really apply some “meaning” to the district’s fake land acknowledgements.