In our analysis earlier this week, we found that Davis faces a real risk of falling short of the state’s lower-income housing requirements — a shortfall that could carry significant consequences for local land-use control.
If the city cannot produce enough affordable housing in the remaining years of the current RHNA cycle, it could face increased state intervention and renewed scrutiny of policies like Measure J.
City officials say there are two ways to measure compliance: first, whether enough sites have been designated or zoned to meet RHNA targets, and second, whether those units are actually built across income categories.
Davis has met the first metric, but not clearly the second.
After further discussions with the city and a closer review of the data, the conclusion is difficult to avoid: the city’s ability to meet its lower-income housing obligations appears to rest squarely on whether two large peripheral projects — Willowgrove and Village Farms — are approved and built.
Here we see that the picture is far less reassuring, as Davis’ path to meeting its obligations runs directly through a small number of large, politically uncertain projects.
This has been the point we have raised for quite some time and it explains why HCD certified the city’s Housing Element and yet the city now needs to take steps to actually rezone and build for the allotted low-income housing.
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.
Critically, the city told me, “If Willowgrove is built, when they believe it will be, we could meet our RHNA. If it is not, I don’t know how that will happen.”
But in order for that to matter, first voters must pass Village Farms this June — as those 360 units are clearly counted in the pipeline. And then voters must pass Willowgrove in the fall.
It’s not quite the proverbial inside straight — but it’s close.
The city’s housing dashboard and annual reporting make clear that most smaller projects, particularly infill developments, generate relatively few affordable units. A project may add dozens or even over a hundred homes, but only a small fraction of those will be deed-restricted for lower-income households.
Over time, those incremental gains add up, but they do not come close to closing the gap the state has identified.
Davis’ obligation for lower-income housing is substantial, and the timeline is fixed.
With the current RHNA cycle ending in 2029 and relatively few lower-income units built so far, the remaining years must carry most of the burden — meaning projects must not only be proposed but actually move through approval, financing and construction in time to count.
It is easy to put dots on a map, but actually generating lower-income housing is another matter entirely.
I would argue that this makes large-scale developments like Village Farms and Willowgrove unavoidable in order to reach compliance.
Projects like Village Farms and Willowgrove are not simply additions to the housing supply — they are the primary vehicles through which the city can deliver hundreds of affordable units within a relatively compressed timeframe.
Without them, the math becomes difficult to reconcile. The city’s own analysis makes clear that there is no realistic path to reaching roughly 930 lower-income units without the inclusion of the two large peripheral projects.
The city’s own response makes the point plainly. Officials said they don’t know how the city would meet RHNA without Willowgrove.
A key point is that there isn’t a group of smaller projects ready to step in and produce the same level of affordable housing if these larger developments don’t move forward.
Instead of spreading affordable housing across many projects, Davis is relying on just a few. If those projects move forward, the city has a path to compliance. If they don’t, the gap remains.
Timing makes this even harder. Large projects take years to build, and approval is just the first step. Delays in financing, design or construction can easily push completion past the RHNA deadline. Since the city is already not clearly on track, any delay increases the risk of falling short.
While rezoning satisfies the formal requirement, the state increasingly expects realistic progress toward construction. Approving major projects like the peripheral developments would signal that progress, particularly for lower-income housing where production has lagged.
But getting those approvals in the first place is the difficult part.
Under Measure J/R/D, both Village Farms and Willowgrove require voter approval, which adds a layer of uncertainty not present in many other jurisdictions. State housing officials have already raised concerns that reliance on voter-approved projects can act as a constraint on housing production.
That means the outcome is not solely in the hands of planners or developers, but depends on the electorate — making the city’s reliance on these projects all the more precarious.
At the same time, the stakes of that uncertainty are higher than they have been in previous cycles.
State housing law has evolved to place greater emphasis on enforcement, particularly for lower-income housing.
Jurisdictions that fail to make adequate progress risk losing elements of local control, including exposure to provisions that limit the ability to deny compliant projects.
This has reinforced our view that if the current projects are not approved and the city falls short of its lower-income housing targets, it could invite state intervention or legal challenges to Measure J from outside parties.
None of this suggests that Davis faces the same conditions as other cities. Its voter-approval requirement under Measure J creates a distinct challenge, adding uncertainty that most jurisdictions do not face when trying to meet state housing targets.
As former Mayor Will Arnold and others have noted, Davis is unlikely to meet its housing needs relying solely on infill, acknowledging that “we are going to need to go peripheral” because the city “will not be able to meet our housing needs with infill.”
From our analysis, Davis does not appear to be on track to meet its 2021–29 RHNA targets for lower-income housing.
Without the approval of the two large voter-controlled projects this year, the city lacks a clear and realistic path to meeting those obligations.
If that scenario plays out, the gap between state requirements and local outcomes could expose Measure J to increased scrutiny — and potentially legal challenge — from the state or outside parties.
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Without even reading this article, one can determine that it’s clearly a lie.
Cities either have an approved housing element, or they don’t.
Davis has an approved housing element which doesn’t include the two peripheral proposals.
It’s that simple.
Though it is true that almost none of the approved (but fake) housing elements across the entire state have any chance of being fulfilled. David knows this, already (as do the YIMBY groups, the state, media, etc.). It’s not a secret.
https://cities.fairhousingelements.org/
The fact that David is so willing to put forth articles that he knows are blatantly untrue does not serve the Vanguard (or the proposal itself) very well, to say the least.
Since Ron admits to not reading the article, he missed the explanation of why you can have an approved housing element and still be on track to be out of compliance.
From the city to me: “ There are two metrics for the Housing Element. The first is the city must have enough sites designated/zoned to meet our RHNA numbers. The second is we must keep track of the number of housing units being built each year in each income category. The city has designated/zoned enough sites.”
So basically, in the old days you used the first metric, the city identified enough sites to meet the RHNA numbers and they’re done. That’s not how it works anymore. You have to actually produce the housing or at least show that you’re making progress.
The identified sites are basically dots on a map. The problem is that if those dots are not attached to an active project, the city cannot claim them as progress. And so basically the city when it got its housing element approved put forward sites where the owners had no intention of building housing.
And so the reality is that the city now needs to find additional housing in order to meet its affordable housing requirements and as both my article and the dashboard indicate, there is no realistic path to doing so without the two large peripheral projects.
David, I did read the article (and I read your same claim the other day).
The reality is that the state can simply “de-certify” a housing element that isn’t being implemented. And at this point (rather late in the current cycle, for that matter) – they’d have to de-certify just about every housing element in the state using the criteria you suggest.
You know this, which makes what you’re putting forth a lie.
In addition, this type of argument actually makes your claims regarding the “next round” of fake targets unachievable, as well.
There is no claim, no statement, no evidence WHATSOEVER that the state is “counting on” the two peripheral proposals being approved as a condition of de-certifying Davis’ housing element.
It’s really rather despicable of you to put forth this type of lie. Fortunately, the people who read the Vanguard at least are knowledgeable enough to spot a lie – even if they support the proposals.
I don’t need to read your lies day-after-day, to recognize them immediately. And neither does anyone else.
Your “analyses” are lacking in regard to underestimating your readers/commenters.
Ron O
On one hand, you’re missing the point that we will need something like these projects for the 2030-2037 Housing Element. We can’t meet our allotment and our real needs to address the housing affordability crisis without a big increase in the Davis housing supply.
On the other hand, you are right that this is not an “emergency.” We can delay approval of these projects and get new ones that conform with our General Plan Update that is now more than a year into the process. The developers, who are not the builders, can’t just pick up their acreage and move it to another city. Village Farms is sitting on up to $350 million in potential sales revenues!
You’re mistaken on the latter point – we are – contrary to your claim last week – not on target to meet our low income housing targets for 2021-29.
David: Richard is actually putting forth a point that I purposefully didn’t mention:
That is, how would Davis meet the “next” round of fake housing targets, if Village Farms and Willowgrove uses them up to meet the “current” round of fake housing targets?
If your answer is that Davis would then need a couple more of these monstrosities for each round of fake housing targets in the future (or else it will lose Measure J), I’d suggest that Measure J itself is of no use. Of course, this assumes that your fake claims regarding Measure J vulnerability are correct in the first place.
Maybe ballots should only have one choice regarding Measure J proposals from now on – “yes” only. Seems like that would solve a lot of fake problems.
Are you saying this is your analysis David?
Crickets…🦗🦗🦗🦗🦗🦗
Any premise that this is the only and last opportunity to approve projects on these parcels is false. And a premise that we need these houses NOW! also is false. Both of these projects will take years to get off the ground. Village Farms has a two year delay built in with its current plan because it involves moving a million cubic yards of soil into the northern third. We should instead consider the alternative of deferring approval until the General Plan Update is done.
We eventually need to build projects in new areas, but we first need to finish our General Plan Update (now in process) so we can tell the developers what we want built. Both of these projects are trying to preempt this process so they build what they want rather than what we need.
“We eventually need to build projects in new areas, but we first need to finish our General Plan Update”
The GP update was overdue 20 years ago so it is disengenuous to state that “these projects are trying to preempt this process” when it is in fact it you, Richard (and your friends), who are trying to preempt projects that were both properly proposed under the existing rules.