Analysis: What Happens If We Don’t Build the Housing

DAVIS, Calif. — Davis is in real danger of failing to meet the state’s lower-income housing requirements, and the consequences could extend far beyond another disappointing housing report. If the city cannot produce enough affordable housing in the remaining years of the current RHNA cycle, local control over land-use decisions — and potentially the future of Measure J itself — could be at risk.

The city’s 2025 Housing Element Annual Progress Report shows a widening gap between state-required lower-income housing targets and actual production. That gap, in turn, raises a second question: whether Davis can realistically close it without major projects such as Willowgrove and Village Farms. And looming over both issues is a third: whether continued underproduction will place Measure J/R/D under increasing pressure from the state.

The city’s own report offers a snapshot of where Davis stands in the current 2021-2029 Regional Housing Needs Allocation (RHNA) cycle. Under RHNA, Davis must plan for and facilitate 2,075 housing units across income categories, including 290 extremely low-income units, 290 very low-income units and 350 low-income units. That means the city’s lower-income obligation totals 930 units.

Through the end of 2025, however, Davis has permitted only 30 units in those three categories. 

According to the report, that includes 28 units in the combined very low/extremely low categories and just two units in the low-income category. In percentage terms, the city has achieved only about 3.2 percent of its lower-income target with just a few years left in the cycle.

By contrast, Davis has already exceeded its moderate-income allocation and made meaningful progress in above-moderate categories. The report shows 522 moderate-income units and 411 above-moderate units permitted so far, while lower-income production remains dramatically behind.

Looking only at total units is misleading, because California housing law is not concerned only with total units.

The state is especially focused on housing for lower-income households, workers, seniors, residents with disabilities and people most vulnerable to displacement. Producing market-rate units while falling short on affordability does not solve the city’s obligations under RHNA.

The city’s report makes the remaining challenge explicit. 

Davis still must issue permits for 348 more low-income units, 262 more extremely low-income units and 290 more very low-income units before the cycle ends in 2029. In total, more than 900 lower-income units remain outstanding.

That brings us to the second question: where do those units come from?

The city’s own development pipeline suggests the answer depends heavily on its largest proposed projects. 

Among projects pending entitlement approval, staff lists The Nest Apartments with 148 units including 11 affordable units, Promenade (Nishi) with 700 units including 60 affordable units, Willowgrove with 1,250 units including 250 affordable units, and Village Farms Davis with 1,800 units including 360 affordable units. Combined, those pending projects account for 3,898 units and 681 affordable units.

The most important figure may be this: Willowgrove and Village Farms alone account for 610 affordable units, the overwhelming share of lower-income housing in the city’s major pending pipeline.

Despite an approved and certified Housing Element, realistically reaching 930 lower-income units appears fraught without the affordable units proposed in Village Farms and Willowgrove.

In other words, without those two projects — or developments of similar size, affordability mix and readiness — the path to 930 lower-income units becomes difficult to identify.

The city has approved several downtown infill projects, but many appear stalled or delayed, and, even if built, they would provide only limited lower-income housing compared with the scale of the city’s remaining need.

The city has expanded ADU opportunities, created pre-approved ADU plans and updated local ordinances to comply with state law, but the annual report illustrates the limits of relying on those incremental strategies alone.

In 2025, Davis issued permits for 75 total housing units. That included 31 single-family units, 42 accessory dwelling units and just two multifamily rental units. Only two deed-restricted affordable units were included in that year’s total.

At that pace, closing a 900-unit lower-income gap before 2029 would be extraordinarily difficult.

A key question remains whether the Davis Housing Element represents paper compliance or actual housing production.

Davis’ Housing Element was certified by the California Department of Housing and Community Development in February 2024. Certification means the city identified adequate sites, adopted required programs and demonstrated compliance with state planning law.

But certification is not the same as construction, because zoned capacity does not automatically become housing and projects still require financing, environmental review, infrastructure, developer follow-through and, in some cases, voter approval.

That final requirement is where Measure J/R/D enters the picture.

Measure J, later renewed as Measure R and Measure D, requires citywide voter approval before agricultural land at the edge of Davis can be annexed and developed for urban uses. 

For many residents, it is one of the defining civic safeguards in modern Davis history. Supporters argue it protects farmland, limits sprawl and gives the public direct authority over transformative land-use decisions.

Critics argue it imposes delay, uncertainty and political risk that discourage housing proposals before they even reach voters.

In a state confronting a severe housing shortage, they contend, local election requirements can function as barriers to production.

During the Housing Element process, HCD signaled concern in precisely those terms.

As previously reported by the Vanguard, state communications indicated California officials were closely monitoring Davis’ housing compliance and were concerned that Measure J/R/D could function as a barrier to housing production.

The same reporting noted that HCD raised similar concerns during the Housing Element approval process, citing Measure J’s limited track record in producing affordable housing.

A prior Vanguard analysis of the city’s Housing Element correspondence found that the California Department of Housing and Community Development (HCD) directly questioned whether Measure J/R/D functions as a housing constraint.

HCD in December 2021 wrote, “Measure J poses a constraint to the development of housing by requiring voter approval of any land use designation change from agricultural, open space, or urban reserve land use to an urban use designation. Since the ordinance was enacted in March of 2000, four of the six proposed rezones have failed. As the element has identified the need for rezoning to accommodate a shortfall of sites to accommodate the housing need, the element should clarify if any of the candidate sites to rezone would be subject to this measure and provide analysis on the constraints that this measure might impose on the development of these sites.”

Legal Services of Northern California in a separate communication, argued, “The City Council’s recent decision to not put any of the five peripheral development proposals on the ballot for November 2024 proves that Measure J/R/D does limit housing supply because it adds time to the development review process.”

Further, Legal Services argued that “a constraint to housing development exists even when the City may be able to demonstrate sufficient sites to address the RHNA.”

Under California housing law, cities are required to identify and address local constraints to housing production. 

HCD’s concern was not simply philosophical opposition to Measure J, but whether a voter-approval requirement that adds cost, delay and uncertainty could interfere with the city’s ability to meet housing needs.

The city’s response was that Measure J was not an immediate barrier because Davis still had enough infill capacity to remain compliant. 

As the Housing Element stated, “While Measure J adds costs, extends processing times, and has been used to halt development projects that would convert agricultural land to urban development, it is only a constraint to meeting housing needs if the city lacks sufficient infill housing sites.”

But that cushion likely has run out.

In December 2023, then-Mayor Will Arnold warned, “I would just say to those who have said that we will be able to meet our next RHNA cycle numbers without going outside of the city limits… I suggest they tune in or watch the recording of this meeting as we really try to meet our current requirements simply with infill and the difficulty we’re having in doing so.”

HCD’s warning from 2021 warrants renewed attention because the city has made little progress toward its affordable housing obligations while appearing to have exhausted most realistic infill opportunities.

Moreover, the state of California has become increasingly willing to challenge local rules, discretionary processes and growth controls that obstruct state housing goals. What once might have been viewed as purely local policy is now subject to state oversight.

The city itself appears to recognize that risk. 

In 2025, a joint meeting of the Planning Commission and Social Services Commission was convened to examine Measure J/R/D and possible reforms. The Vanguard reported at the time, “Future housing applications are more likely to require voter approval under Measure J/R/D, creating a potential clash between state housing mandates and local growth control.” 

That clash is becoming more concrete as Davis’ lower-income numbers lag.

If the city can meet its RHNA obligations through existing infill sites, entitled projects and voluntary private development, the political pressure on Measure J may ease for now. But if lower-income production continues to trail far behind targets, pressure will grow from multiple directions.

One path would be approving major peripheral projects such as Willowgrove and Village Farms through the existing Measure J process. Another would be amending the ordinance to create exemptions or streamlined treatment for affordable housing. A third possibility would be deeper intervention from Sacramento if state officials conclude local processes are frustrating compliance.

This last possibility is becoming increasingly likely, particularly if voters reject one or both of the 2026 housing projects that will appear on this year’s ballots.

In short, Davis risks losing local control over land-use decisions if it fails to provide sufficient low-income housing, and there does not appear to be a viable path to meeting those obligations without the two large peripheral projects.

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Breaking News City of Davis Land Use/Open Space Opinion

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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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37 comments

  1. You ask what happens?

    Well, first of all, Davis has been, and is continuing to build more housing. Let me know if you want me to rattle-off some of the recently-built, under-construction, or approved developments.

    But what happens if Davis doesn’t approve one or more of the proposed massive peripheral developments? The answer is “nothing other than amusement” regarding the Vanguard’s reaction. And another embarrassing defeat for the officials who support these things, as usual.

    And that ultimately goes for the YIMBY state officials who have established unrealistic, unachievable “mandates” – statewide. You’ll continue to see them back off faster than Trump did, regarding his promise to “end a civilization”.

    “Psyche!”, regarding those gullible-enough to believe it. (Though I have to admit that I was sort of one of them in regard to the power plants and bridges, at least.)

    1. Ron O
      The “developments” you imagine are happening here either 1) target students in purpose-built apartments or 2) are small scale neighborhoods of a few dozen homes. Neither will serve the missing middle market in sufficient scale to address the housing affordability crisis that has enveloped Davis. All of you “facts” are wrong.

      1. Harvest Glen itself consists of 96 housing units, starting at $869K.

        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

        Pole Line Terrace consists of another 30 units (all of them “attached” with no yards and a shared, long driveway) – for $795K.

        https://foutshomes.com/pole-line-terrace/pole-line-terrace-site-and-floor-plans/

        I suspect that neither of these developments will have very much Mello Roos, since they’re well-within existing city boundaries.

        If you want to know what the “middle” is, take the median housing price per sources such as Zillow. That’s your “middle” – and as long as they’re continuing to sell – the people buying them are not “missing”.

        They’re also not “missing” in Atherton, where the average house price is around $8 million.

        No one wants to live in an attached shoebox in Davis, other than students. Not when there’s alternatives available for a lot less money – especially when it comes to “families”.

  2. The premise of this article is incorrect. There’s two false assumptions. First that we must approve developments today and now to meet our 2030 Housing Element requirements. And second that nothing will be build at the Village Farms and Willowgrove sites if we reject the current proposals.

    First, we are on track to have a General Plan Update by 2028, in time to guide the 2030 HE. According to a Planning commissioner we are on track to meet our 2022-29 HE requirements. We will be able to provide direct guidance to developers based on the GP Update so that they can start work by 2030. We probably only lose a year in the end on the development track for these two projects. Given the decades (century?) long impacts of the new housing, we need to get it right.

    Second, the developers can’t just pick up their land and move them to Roseville or Elk Grove. Their money and profits are tied up in the land, not in the houses that will be built there. (The developers put down the infrastructure and then sell tranches of lots to builders.) When we have clear guidance for them, the developers will come back with acceptable proposals to improve their likelihood of electoral success (whatever form that takes.)

    1. Richard – I believe you misunderstand the premise of my article.

      Here are key components:

      Davis has a severe shortfall in lower-income housing production.
      The current pipeline is heavily dependent on Village Farms and Willowgrove.
      If those projects fail, the remaining path becomes difficult to identify.
      Continued failure increases the risk of state intervention and pressure on Measure J.

      Moreover, we are not on track to meet out 2022-29 HE requirements. You don’t need to rely on the word of a Planning Commissioner, where is the affordable housing to meet the 930 units?

      1. Almost no city is “on track” regarding the fake housing targets. So you are correct – they’re not going to be built – anywhere in the state.

        https://cities.fairhousingelements.org/

        One would think that the state itself should have known that in advance, BEFORE they created the fake housing “mandates”. But apparently, they “didn’t do the math” so to speak.

        Personally, I think the state and the YIMBYs should threaten and sue every city in the state – repeatedly. I’d suggest creating a brand new “state-suing agency” (with maybe 100 or so more attorneys) to accomplish this. Sue them all into bankruptcy, and then let the state take on the task of approving developments throughout the entire state (which of course, would also then require the creation of yet ANOTHER state agency).

          1. Reminds me of this (note the word “unjustified”):

            “Speed traps”—defined as using radar on roads with unverified or unjustified speed limits—are illegal for evidence gathering in some states, most notably California, under Vehicle Code § 40801 VC.”

            But ultimately, the legal arguments aren’t going to matter. The housing is still not going to get built – statewide.

            It’s like an enormous “not-so-secret” that the state already knows. The only thing they can do (regarding getting the housing actually built) is to “pretend” that their mandates will be achieved. Essentially, not so different than Trump’s promise to “end a civilization” a couple of weeks ago.

          2. Basically your argument at this point boils down to – violate the law, others may do it too, maybe you’ll get away with it.

          3. An unenforceable law is essentially the same thing as no law. I don’t even know what the actual speed limit is on I-80, but (judging on what I’ve witnessed in reality), it must be around “80 MPH”.

            Now, if any of this heads to court, the outcome is not going to be “up to the state” (or their YIMBY friends).

            And if it heads to an actual jury, I’m quite certain that someone is going to bring up the utter failure of the mandates throughout the state – whether or not it’s a “legal” argument.

            Pretty sure you’re not going to want me on that jury.

      2. David, the current pipeline can’t be heavily dependent on Village Farms, because any possible units there will not happen during the current pipeline.

        Ask the Village Farms team how many units they will pull building permits for on or before August 2029.

        1. You’re applying the wrong legal standard. Again, the requirement is that it be rezoned in order to count for this term, that can happen by passage of the Measure J projects.

    2. “When we have clear guidance for them, the developers will come back with acceptable proposals”
      You have no evidence to support this assertion, nor is there any reason to believe it will happen within the next decade or so.

  3. David Greenwald said … ”Davis still must issue permits for 348 more low-income units, 262 more extremely low-income units and 290 more very low-income units before the cycle ends in 2029. In total, more than 900 lower-income units remain outstanding.

    David, what do you think the chances are that the 360 units of Affordable units at Village Farms will be in a position to pull a building permit by August 2029, the end of this RHNA cycle?

    The answer to that question is “zero chance.” The City has now been working on the Affordable units at WDAAC/Bretton Woods for over seven years, and is no closer to pulling a building permit now than they were in November 2018.

    Village Farms, whether approved or rejected, will not give you the fantasy that you are imagining … the holy grail you seek.

    Further, I believe that because of the very onerous state of financing, both private and public, the State will be hard pressed to penalize jurisdictions for projects that did not go forward because they couldn’t get funding.

    1. I believe you are incorrect that the city needs to pull building permits by August 2029. HCD describes RHNA as requiring local governments to ensure projected housing needs “can be accommodated,” not that every unit must already be permitted or built.

        1. It wasn’t included. However if you look at the city’s HE update from March, and you look at my comment to Ron at 12:25, you see that the city is now heavily relying on those two projects to gain compliance.

          1. Post the link to the update. I’ll look at it.

            With that said, almost everything that appears in the City’s HE documents suffers from the wishful thinking bias of City staff, whose jobs are dependent on the volume of work that comes into the department. A lot of what they say is jobs protection propaganda.

          2. Partially agree on the city’s HE documents. Not sure I buy the quasi-conspiracy theory, but I have my own theory – they were trying to avoid going to the peripheral, i.e. Measure J well with this housing element. The problem was they concocted an unclear and unworkable plan to address the affordable component. In retrospect HCD should not have certified the HE, but it probably doesn’t matter. The city is still going to have to go peripheral to meet their requirements.

  4. David Greenwald said … ”As previously reported by the Vanguard, state communications indicated California officials were closely monitoring Davis’ housing compliance and were concerned that Measure J/R/D could function as a barrier to housing production.”

    The problem with the above statement is that the City’s Community Development department made the same assertion to the Planning Commission, and even said that HCD’s letter was in the meeting packet, but the letter in the packet said nothing of the sort, and when queried Community Development admitted that no such letter existed.

    Which brings us to David Greenwald’s assertion that HCD in December 2021 wrote, “Measure J poses a constraint to the development of housing by requiring voter approval of any land use designation change from agricultural, open space, or urban reserve land use to an urban use designation. Since the ordinance was enacted in March of 2000, four of the six proposed rezones have failed. As the element has identified the need for rezoning to accommodate a shortfall of sites to accommodate the housing need, the element should clarify if any of the candidate sites to rezone would be subject to this measure and provide analysis on the constraints that this measure might impose on the development of these sites.”

    If indeed HCD did write those words, why wouldn’t the document with those words have been provided to the Planning Commission by the Community Development department?

    HCD’s scrutiny of Measure J opposes to be a bunch of smoke and mirrors.

  5. “The current pipeline is heavily dependent on Village Farms and Willowgrove.”

    There is no truth whatsoever to this argument, in regard to the current round of fake “mandates”.

    Moreover, you continue to misrepresent the state’s response to Davis’ approved housing element. The state simply (correctly) noted that a council cannot “count on” developments that are out of its approval/denial authority (and outside of city limits). And this is obviously factually true.

    (As I was typing this, I noticed that Matt made a similar comment above.)

    Even in the absence of something like Measure J, there is no guarantee that every city council throughout the state is going to approve a sprawling development outside of its city limits. In such a case, it could be the councils themselves that are a “hindrance to development” outside of city limits.

    What if any given city council has a majority of elected officials that are similar to me?

    Under this same argument, every voter initiative (such as the one that SOAR has), and every voter-approved urban limit line is a “hindrance to development”.

    Like I said, the state is going to have to take over ALL development decisions, if they’re going to view any particular initiative (or locally-elected body) as a “hindrance” to the type of sprawl that you’d prefer.

    (As a side note, sprawl is still occurring even in cities that apparently aren’t “on track” to meet the fake housing mandates. So apparently, sprawl does not equate with “compliance” with fake mandates.)

    1. “There is no truth whatsoever to this argument, in regard to the current round of fake “mandates”.”

      No truth, huh?

      The Housing Element Progress report… states Davis still needs:

      348 more low-income units
      262 more extremely low-income units
      290 more very low-income units
      And how do they close that gap…

      Projects Pending Entitlement Approval

      The report states:

      Projects Pending Entitlement Approval

      Affordable Units (Low/Very Low) | Total Units
      The Nest Apartments — 11 | 148
      Promenade (Nishi) — 60 | 700
      Willowgrove (Shriner’s) — 250 | 1,250
      Village Farms Davis — 360 | 1,800

      TOTAL — 681 | 3,898

      So you’re wrong, there is a lot of truth to it, because the city is effectively arguing it needs them.

      1. What are you talking about? The current housing element is approved without Willowgrove or Village Farms.

        The city is is the same position as almost every other city in the state (approved housing elements that don’t reflect reality). So your question regarding how they “close that gap” is entirely irrelevant. The REAL question is why is the state approving housing elements that they already KNOW don’t reflect reality and have zero chance at being fulfilled – statewide. That’s sort of the purpose of the YIMBY scoreboard, as well.

        Do you actually think that the state doesn’t already know that their “mandates” are fake? And that they’re simply going to “wake up” at the end of the current cycle, and say to all of the cities – “hey, what happened? We thought you guys were on track”!

        I’d also like to see you respond to Matt’s 12:01 p.m. comment, above.

        1. “The current housing element is approved without Willowgrove or Village Farms.”

          I’ve asked several times for someone to find me a path to 930 that doesn’t include Willowgrove and Village – no one has bothered to respond. Looking back over the certified Housing Element shows it’s as clear as mud and in the city’s update, they seem to acknowledge there is no path without WG and VF. So that appears where we are.

          1. So, what you’re obviously leaving out here is any actual citation from HCD, telling the city to include those two developments in the current cycle or risk de-certification of the current housing element.

            Does such a a communication exist? If so, please post the actual citation.

            But perhaps even more importantly, this would mean (if true) that the next round of RHNA “mandates” has no path forward regarding achievability without a couple additional “Wilowgroves” and “Village Farms” in the next round, since they’re going to be “used up” for the current round allocations.

            And that voters have to continuously vote “yes” for future proposals as well, or risk the ability to vote “no”. (Makes no sense at all. And since this is your implication, I’m not sure what you’re hoping to achieve by “scaring people” into preserving Measure J by voting for Willowgrove and Village Farms, if they have no realistic opportunity to vote “no” for any given proposal (now, or in the future).

            It doesn’t sound like a very effective way to frighten people, in regard to a measure that you essentially claim is doomed unless residents consistently vote “yes”.

          2. There is no path, just as there isn’t for 99% of the other cities within the state.

            But again, show us where the state is requiring the city to approve Willowgrove and Village Farms to address the current RHNA “mandates”.

            If there is no such communication, the only thing that’s “nonsense” here is your claims regarding the state. They’re apparently not even asking the question that you posed, so why would anyone in a position of authority care about a question arising from you?

            Show us the evidence of the communication that you claim to exist. Specifically, where are explicit comments from the state OR the city in which they “offer up” Village Farms and Willowgrove in order to avoid decertification of the current housing element?

            Show us the actual citation; not your opinion.

      2. David, shouldn’t the progress report be focused on the status of sites that are actually in the certified Housing Element rather than sites that are beyond the horizon of August 2029?

        1. In the optimal condition I would agree. The problem again appears to be I don’t see how they got to 930 in the original document and therefore meeting their low income target seems implausible.

          1. They already got to 930; else the housing element wouldn’t have been approved.

            Though they probably could have fit an ADDITIONAL 930 loser housing units on the (12-acre?) Chiles Ranch, if they were so inclined. Or perhaps several thousand of them on Nishi and/or WDAAC.

            Though maybe it’s not the occupants who are “losers” – maybe it’s those subsidizing them. (Sort of like how Davis subsidizes students from other school districts).

            In other words, “will the REAL loser please stand up”?

          2. “They already got to 930; else the housing element wouldn’t have been approved.”

            You might think, but it doesn’t appear to be true

          3. Show us where the state acknowledged its error in counting up units, and what they want the city to do about it (years into the current housing element).

            Again, not referring to your “opinion” – show us the communication between the city and the state regarding the claimed error, and what they’re requiring the city to do about it – especially as it relates to Willow Grove and Village Farms. Include timeframes of communication, EXACTLY what was said (and by whom) and timeframes of corrective action that the state is supposedly requiring in regard to the current housing element. And the consequences (from the state itself – not conjecture, but actual statements from the state) if the city is unable to comply.

            Again, these are your claims – back them up if you want to maintain credibility.

          4. Because you haven’t bothered to look at the document, you’re speaking pig latin

          5. You would think that if they didn’t get there HCD would never have certified the Housing Element.

            I think you are chasing your tail David.

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