August 19, 2022
Dear Ms. McKenna and Mr. McBain,
Attached please find comments offered on behalf of landWatch Montery County on the proposed annexation of the Miramonte Specific Plan area to the city of Soledad. The comments focus on the July 14, 2023 Third Submittal.
LandWatch recognizes that annexation of land into Soledad’s city limits is necessary to meet the housing needs of Soledad’s working families. However, few Soledad families can afford the $600,000+ single family homes that make up the majority of the project. More problematically, these are the only kinds of units that will be produced in the first four phases of the project, which will build 771 low-density single family units. At the City’s historic and projected rates of absorption, this represents 13-15 years of development.
LandWatch supports annexation as required for the provision of timely, integrated affordable housing. However, LAFCO should not approve the annexation of the Miramonte Specific Plan area as currently proposed. Its failure to provide sufficient, integrated, and concurrent affordable housing is inconsistent with the Soledad General Plan, its Housing Element, and state law.
SUFFICIENCY: General Plan Policy H-3 provides that the “City of Soledad shall require new residential areas to contain a mix of housing types targeted to very-low, low, moderate, and above moderate households in approximately the proportion that each of these income categories represent in the AMBAG Fair Share Housing Allocation.” This does not merely require the Specific Plan to accommodate the number of units required in the current RHNA cycle, but to ensure that its entire housing mix is proportional to the RHNA mix. The purpose of this policy is to ensure that the Specific Plan area, which constitutes the City’s future growth area, can accommodate future RHNA cycles. The Specific Plan fails to provide sufficient sites under this policy because it does not zone enough sites at the densities required by the State Department of Housing and Community Development (HCD) and by the Soledad Housing element for lower and moderate-income housing.
INTEGRATION: The Specific Plan is also inconsistent with the current Soledad Housing Element because it fails to integrate affordable housing units in each neighborhood and in the “majority of blocks” in these neighborhoods and because it fails to provide for a minimum of 30 percent rental units in each neighborhood. Integration of affordable housing is also required under AB 686, which requires all agencies making land use decisions to affirmatively further fair housing. LAFCO must take cognizance of these inconsistencies under its mandate to consider general plan consistency and its mandate to consider environmental justice.
CONCURRENCY: The Specific Plan is also inconsistent with the mandates in the General Plan, its Housing Element, and the City’s Inclusionary Ordinance to develop affordable housing concurrently with market rate housing. Even though the Specific Plan contemplates concurrent provision of affordable units, its phasing plan precludes this, because it calls for construction of hundreds of units of low-density single-family homes before any higher density areas are developed. Indeed, it is uncertain whether any of the higher density areas will be developed within the 8-year period of the 6th RHNA cycle given that the higher density area is slated for development between phases 5 and 10 of the Specific Plan.
LAFCO should ask the City to revise the Specific Plan to ensure sufficient, concurrent, and integrated provision of affordable housing for Soledad’s working families. This will require the City to revise the site plan to increase and integrate dense development opportunities and to revise the phasing plan to meet the concurrent affordable housing development mandates and to permit fulfillment of 6th Cycle RHNA requirements.
LandWatch also asks LAFCO to require a phased annexation because there is no justification for immediate annexation of 40 to 48 years of housing growth area to the City.
Finally, LandWatch asks that LAFCO require the City to demonstrate its ability to finance infrastructure and public services in the near and medium term and with appropriate assumptions about meeting affordable housing mandates. The City has not done so.
LandWatch would be happy to discuss its comments further with LAFCO or with the City.
Thank you for your consideration,