Blogging Bayport Alameda

December 8, 2011

In your Housing Element

Filed under: Alameda, City Council, Development, Measure A — Tags: , — Lauren Do @ 6:01 am

As mentioned in the comments section under yesterday’s post, the City is going to be rebooting the Housing Element process to bring Alameda’s Housing Element into compliance with the state.  The Housing Element is part of Alameda’s larger General Plan and the State requires that the Housing Element identify sites in Alameda to fulfill Alameda’s allocated Regional Housing Needs Allocation (RHNA).

Previously, it appeared that simply identifying sites was sufficient and that there was no real penalties for jurisdictions that failed to actually build the RHNA identified units.   Now, for every unit unbuilt from each seven year cycle, the balance will “carryover” into the next seven year cycle.  Did I mention the part about how jurisdictions can be sued if they don’t have an approved Housing Element?   And given Alameda’s Measure A elephant in the room, Alameda really doesn’t want to give the State any other reasons to get pissy at Alameda on the subject of housing.

So, the City will be attempting to wrap up this Housing Element process by late next year including identifying certain sites for potential accommodation of housing units.   The point of this process is not just to identify any old site and then just skate its way to the next housing cycle and identify that site again to meet the statutory requirement.   Because of the carryover, this time Staff is suggesting to not identify North Housing and Alameda Point as potential sites since they probably would be unavailable to develop as housing by 2014 when a new cycle would begin.

If you look at the staff report, parcels that are currently zoned residential would simply not yield a sufficient number of units to meet the RHNA number let alone the carryover amount from last cycle.  In fact, the City is banking on relying on rezoning parcels from other uses to residential to meet this need.   Remember the units have to be built during the cycle period or the number of units get carried over.   Interestingly enough on the proposed other uses sites to be potentially rezoned includes the Neptune Pointe site , Alameda Marina and Shipways at Marina Village, the staff report indicates that an application for residential rezoning is anticipated for the last two and of course Neptune Pointe’s new owners have already submitted a letter requesting rezoning.

What possibly could arise out of this process is a renewed discussion about Measure A and its limitations in meeting statutory requirements like the RHNA.   Of course the adoption of the Density Bonus will help out quite a bit in allowing for a diversity of housing types and may be a sufficient program to counter the constraint to multifamily housing that Measure A is, but perhaps in light of the adoption of the Density Bonus it’s time for the City to re-examine the purpose and intent of Measure A.

The first meeting around this topic is scheduled for Monday night’s Planning Board meeting.


  1. I agree with Lauren that a discussion of the housing element is long overdue in Alameda. Housing and jobs in our community are complex issues on which many on all sides are passionate. Thus, it is important that the discussion be based on accurate information. To that end, here are two corrections to Lauren’s clear and informative summary of issues related to the housing element.

    First, there is no requirement that the houses actually be built during the planning period. The City is solely required to zone so that an owner has the right to build housing on their property, but neither the City nor the State can require the owner to build the houses.

    Once property is rezoned, the City must approve any development proposal that is consistent with the new zoning. The zoning process allows the City, residents, and businesses to plan for the evolution of entire neighborhoods, rather than allow cumulative impacts on the community to evolve unpredictably as proposals for each individual parcel are reviewed and approved. Before property can be rezoned, environmental reviews of cumulative impacts on traffic, schools, natural resources and other concerns have to be completed.

    The second correction concerns the very complex, and confusing, topic of density bonuses for building affordable housing. Market rate units in addition to those permitted by the zoning, a density bonus to help finance affordable housing, will not help Alameda meet its Regional Housing Needs Allocation. Only the units permitted by the underlying zoning, before any density bonus, will count towards the Regional Housing Needs Allocations. The legal basis for counting only those units permitted by the underlying zoning is explained in a footnote in the letter from Renewed Hope Housing Advocates to City Manager John Russo. This letter, and other background documents on the housing element, can be viewed from the documents page of the Renewed Hope website at

    Andrew Thomas, City Planning Services Manager, makes clear in his memo to the Planning Board, that the question is no longer whether or not we should produce a housing element that complies with State law. Rather, the question is where and how should we rezone to comply.

    Once we have a housing element certified by the State, Alameda will be more attractive to highly desireable commercial and institutional developments, like the LBNL Second Campus. We will also be in a better position to attract transportation funding from the State and federal governments to improve our transportation systems, including private auto, bus, bicycle and walking. And most of all, we will have a community that is more attractive to the young adults that we need to keep our community vibrant and vital. In short, Alameda will become part of the solution to California’s economic malaise, and we will no longer be a poster child for what ails the California economy and forces more of our families into homeless shelters and our industries to leave.

    Comment by William Smith — December 8, 2011 @ 7:15 am

  2. Bill Smith: Are you sure about the Density Bonus units not counting toward the overall RHNA count? If that’s true then it’s going to be even more difficult for Alameda to identify (and rezone) enough parcels to meet the RHNA number and carryover. Particularly if Alameda Point and North Housing is off the inventory lists.

    Comment by Lauren Do — December 8, 2011 @ 7:22 am

  3. #1 Bill, It’s not helpful to end a commentary on a complicated local issue my making sweeping, disdainful, and inaccurate hyperbolic statements about Alameda being the poster child for what ails California. People aren’t ending up in homeless shelters because Alameda’s housing element is not up to par. People end up in shelters, for the most part, because they don’t have a job – because there are no what? jobs. And our housing element is not causing “industries to leave.” Industries are not leaving because there is nowhere for their workers to live. It’s because they prefer the workers who live in other countries who work for less money. More affordable housing is not going to produce a pool of workers willing to work for $8 a week.

    I agree it would be healthy for the community to have more housing opportunities for young people. Job creation for those same young people is a separate issue.

    Re: Density bonus. If affordable housing units built under the authority of the density bonus law are not counted toward housing goals, that’s nuts. Who came up with that one? Also, if you happened to listen to the update on Alameda Point at last night’s ARRA meeting, you would have heard Jennifer Ott point out that with the 25% affordable housing requirement in force for Alameda Point and the density bonus in place, new housing at Alameda Point will undoubtedly include multi-family housing.

    Comment by Richard Bangert — December 8, 2011 @ 8:28 am

  4. A quick google scan of density bonus and housing elements shows that it can be used in the RHNA count, and if you check the list of communities in compliance, the example cited by Bill (Berkeley) as improperly using the density bonus, is in fact in compliance.

    There is a fine line between using the housing element as a tool to promote more affordable housing, and making it so unatainable that it becomes a barrier to development of any kind, Limiting the means that we have to achieving the RHNA seem to be benefiting the later purpose.

    There is no question that Alameda needs to develop a compliant housing element. If we had one now, we could be eligible to apply for part of the $25 million made available by the State this week for housing related parks. And Alameda sure loves its parks! Kudos to the City for coming back to the issue and working to put in place an achievable housing element.

    Comment by Doug Biggs — December 8, 2011 @ 8:29 am

  5. Lauren,

    Yes I am sure that the density bonus unit will not count toward the overall RHNA requirement. Andrew Thomas, City Planning Services Manager, in his memo citing parcels that could be rezoned does not include density bonus units. Since the density bonus generally provides for a small, 15-25% bonus, whether or not it is included, its overall impact on total housing units is minimal. Its impact on the number of affordable housing units is, however, substantial, as demonstrated by the Boatworks project..

    Here are two relevant footnotes from the letter that Renewed Hope sent to City Manager John Russo in mid-November.

    Density Bonus not Counted (1)
    1 It should be noted in this regard that the use of state density bonus law to achieve multifamily development as was done with the Boatworks project is insufficient to comply with the Housing Element Law obligation to make sites available for development of multifamily housing at appropriate densities. The law requires sites to be available at the requisite densities regardless of a developer chooses to seek a density bonus.

    What does count. Development by Right, defined as (2)
    2 Sites that do not require a conditional use permit, planned unit development permit or other discretionary review prior to seeking a building permit.

    Excerpt from Renewed Hope Letter to City Manager John Russo,

    “Most critically, due to Measure A and the City’s restrictive zoning practices, HCD explains that the element must include a housing action program that will overcome these constraints and make enough sites available as multifamily developable by right to accommodate its needs for lower income housing. Such a program cannot be developed until the City completes an adequate inventory of sites that analyzes the constraints of Measure A and the adequacy of the City’s zoning in relation to accommodating its needs for affordable housing. {Andrew Thomas has prepared a preliminary draft of such an inventory in his background memo to the Planning Board.}”


    Comment by William Smith — December 8, 2011 @ 8:35 am

  6. The most logical method to obtain the housing results William Smith and his organization supports is for Alameda to not meet the state requirements and have the housing element placed under court order.

    Comment by Jack Richard — December 8, 2011 @ 9:12 am

  7. I just clarified with Andrew Thomas about the Density Bonus and RHNA count, he said that every unit counts. But of course the units only count toward their affordability level, so a market rate unit will be a market rate unit and an affordable one will count as an affordable one.

    Comment by Lauren Do — December 8, 2011 @ 9:39 am

  8. Based on the staff report, it doesn’t make sense to argue with the State — the rules are in place, but given the Navy Base closure and the huge jobs-housing imbalance in Alameda, I don’t understand why Alameda is considered to be out of compliance.

    Comment by Karen Bey — December 8, 2011 @ 11:34 am

  9. As I wrote earlier, the density bonus is a complex issue. My initial remarks on the density bonus and those of Doug Biggs and Andrew Thomas all likely oversimplified the application of the density bonus units to to the RHNA (Renewable Housing Needs Allocation). In any case, the density bonus is a secondary issue. I’m encouraged that all commenters recognized that to comply with State Housing law, Alameda must rezone at higher densities, such as those illustrated in the 3rd attachment to the background memo to the Planning Board authored by Andrew Thomas.

    Comment by William (Bill) Smith — December 8, 2011 @ 11:52 am

  10. Bill: it would help your cause if you would refrain from making misleading statements. It seems like a scare tactic, frankly, and to tell you the truth, that sort of tactic isn’t likely to work on this site or with the community at large. It would be better to be clear on what the state requires, so that it will be taken seriously.

    I don’t see how Alameda or any other city has a prayer of reaching its quota of affordable housing without the use of the density bonus, and without an incentive to pursue it. Who’s going to build low or very low income housing? It would probably do your cause more good to promote the density bonus rather than to marginalize it.

    Comment by dlm — December 8, 2011 @ 1:39 pm

  11. DLM and others,

    First of all thank you all for the constructive and civil discussion on the controversial topic of housing in Alameda. Your queries and points have done much to provide a factual basis for the discussion.

    The most immediately relevant point in the discussion is that in Alameda the density bonus does not satisfy State housing laws. We need to rezone to permit the needed density by right.

    Andrew Thomas’s background memo to the Planning Board makes it clear that the density bonus does not suffice to meet State housing requirements. The following two bullet points are from page 6 of the memo:

    • Most of Alameda’s sites on the land inventory are zoned to allow residential densities up to 21 units per acre. The zoning on all of the sites prohibits multi-family housing. However, the Alameda Municipal Code (AMC) Density Bonus Ordinance allows the residential density to be increased to 29 units per acre and the multifamily prohibition to be waived by the Planning Board.

    • Government Code Section 65583.2 (c ) (3)(B) states that if a site is zoned for 30 units per acre it shall be presumed to be appropriately zoned for lower income households by HCD.

    Thus, as the density bonus permits up to 29 units per acre, one shy of the 30 units per acre required by the State, the density bonus as implemented in Alameda apparently does not satisfy the State’s housing requirements. Alameda’s zoning must be altered to allow 30 units per acre to be be built by right.

    I presume that the zoning must be for at least 30 units of per acre before a density bonus is granted. My basis for this presumption is that the density bonus is more like a conditional use permit and not a zoning right. A developer must build a certain type of housing to qualify for the bonus, like a church must meet certain conditions to get a conditional use permit before it can locate in a residential neighborhood. I will check with my contacts in the housing community and see if any of them know if housing permitted soley by a density bonus is more akin under the law to a conditional use permit or to a right.

    Again, thanks for the valuable disucssion that is clarifying the issues for all of us, as we work together as a community to sort out what will work the best to satisfy the State requirements in Alameda.

    Comment by William (Bill) Smith — December 8, 2011 @ 5:17 pm

  12. Alameda has 54 houses in Foreclosure and 167 in Preforeclosure.

    We need housing for these people.

    Probably another couple thousand underwater on their mortgages.

    Pretty soon we will have all government low income housing. Whats the Rush.

    Comment by John — December 8, 2011 @ 6:06 pm

  13. 11. William, is my # 6 not a fact?

    I cast no aspersions if you refuse to answer, but it’s unlikely this community (regardless of your ‘work together’ myth) will ever agree to meet your goals.

    Comment by Jack Richard — December 8, 2011 @ 8:44 pm

  14. All cities are mandated to provide a certain number of affordable housing units. Currently, there is a huge gap between the need for affordable housing units and the funds available.

    Securing the funding for an affordable housing project is a complex, multi-step process, which typically requires applying for and winning grants from county, state and federal programs . It’s gotten harder. There are limited funding sources available, adding that the costs associated with developing are high, up to 25% more than prevailing construction costs due to wage requirements mandated by the State.

    The City is Celebrating the Landing of Target with probably another 1000 potential low income residents with average wages of 10- 14.00 an hour. In 2009, a worker would need to earn $14.97 to afford a one-bedroom apartment and $17.84 to afford a two-bedroom apartment. There has been an increase of 41% from 2000 to 2009 in fair market rent for a two-bedroom unit, according to HUD (National Low Income Housing Coalition, 2009).

    A recent U.S. Conference of Mayors report stated that in every state more than the minimum-wage is required to afford a one or two-bedroom apartment at 30% of his or her income, which is the federal definition of affordable housing. Unfortunately, for 12 million Americans, more then 50% of their salaries go towards renting or housing costs, resulting in sacrifices in other essential areas like health care and savings.

    Homelessness results from a complex set of circumstances that require people to choose between food, shelter, and other basic needs. Only a concerted effort to ensure jobs that pay a living wage, adequate support for those who cannot work, affordable housing, and access to health care will bring an end to homelessness.

    Comment by John — December 8, 2011 @ 9:26 pm

  15. if you really want to understand the Credit Crisis and the Housing Price Conundrum Sal Khan does a world class job of explaining it at the Khan Academy.

    There are great videos on this. I recommend watching these to get a clue on what really happened.

    Credit Crisis

    Videos on the causes and effects of the credit crisis/crunch.

    The housing price conundrum
    Housing price conundrum (part 2)
    Housing Price Conundrum (part 3)
    Housing Conundrum (part 4)
    Mortgage-Backed Securities

    IMortgage-backed securities
    IIMortgage-backed securities
    IIICollateralized Debt Obligation
    13: Does the bailout have a chance of working?
    Credit Default Swaps
    Credit Default Swaps 2
    Wealth Destruction 1
    Wealth Destruction 2

    To cut to the Chase watch the last two

    Wealth Destruction 1 : How bubbles destroy wealth.

    Burning Down The House: What Caused Our Economic Crisis?

    Comment by John — December 8, 2011 @ 9:48 pm

  16. 11: “Most of Alameda’s sites on the land inventory are zoned to allow residential densities up to 21 units per acre .. the Alameda Municipal Code (AMC) Density Bonus Ordinance allows the residential density to be increased to 29 units per acre [and the Govt. Code requires at least 30 units per acre]”.

    Bill — thanks for your response. To tell you the truth, I thought of quoting this same sentence from the Andrew Thomas memo, to demonstrate that the city was not so far out of compliance. I guess it works both ways. In any event, I think it might be simpler to revise the city’s Density Bonus ordinance by whatever means so that it allows construction of 30 units per acre, which would put the city into compliance.

    This is a confusing subject in any event because all of this is hypothetical. As I understand it, in practice it means that the city can’t *prevent* the construction of affordable units, in order to be in compliance w/ state law.

    Also, fyi, as I understand it, a developer who offers to build affordable housing has the automatic *right* to make use of the density bonus. The city has to grant “x” number of bonus units and other “incentives” (?) in exchange, such as fewer parking spaces. So in effect, it’s the developer’s decision, and the additional market rate units would then subsidize the affordable housing.

    Comment by dlm — December 8, 2011 @ 10:25 pm

  17. All,

    My apologies to all for inadvertently contributing to the confusion surrounding the housing element. My thanks to all, especially Lauren, Doug and Darcy, who questioned my assertion that the density bonus units do not count toward the overall RHNA (Regional Housing Needs Allocation) count. That assertion was at best an oversimplification of a complex area of the law.

    My confusion may be due to differences in how the density bonus is applied to units that were built during the immediate past planning period and to zoning of units required for the current planning period. Rather than speculate as to what those differences are, I’ll wait until I hear from someone who really knows before I comment further on the topic. Perhaps a reader of this blog can clear up my confusion?

    Jack’s statement in #6 that a court order is the most logical way to achieve a housing element certified by the State is not necessarily true. Andrew Thomas’s background memo, John’s statement in #14 and many others in this community make a persuasive case for the City to adopt a certified housing element on its own. Perhaps we can persuade the Planning Board and the Council to adopt such an element on behalf of our community. Even should Alameda come under a court order to comply, it is possible to continue to include citizens in the rezoning process. Possible, but likely much more difficult.

    As regular readers of my posts on this blog may know, only my passion for transparency and inclusion in government is greater than my passion for economically and environmentally sustainable development. The readers of this blog who pointed out my lack of understanding of the density bonus are only one of many examples of how my own understanding of issues and policies has been aided by transparent and inclusive discussions.

    Our courts are neither transparent nor inclusive. Thus, I genuinely hope that we Alamedans can find a way to adopt a certified housing element on our own. We all lose control of the outcome if the courts must step in.


    Comment by William Smith — December 8, 2011 @ 10:25 pm

  18. John, (15)

    Thank you for sharing that McCain campaign video. I agree with its attribution of much of the blame for the housing bubble to federal housing policies. Very well done and entertaiing! I’d be curious to know, and would expect, that there were some Republicans who contributed to the housing bubble as well.

    I don’t know a single economist that would hold up our national housing policies as a model for any other country. Does anyone?


    Comment by William Smith — December 8, 2011 @ 10:46 pm

  19. Bill

    It wasn’t meant to be political……Republicans benefited greatly….Democrats…Ect Ect Ect…Lots of people in the cash registar. It was more on policy…..Sal’s stuff at the khan academy leaves the politics out and explains it well.

    When were worried about the State Lauren states ” And given Alameda’s Measure A elephant in the room, Alameda really doesn’t want to give the State any other reasons to get pissy at Alameda on the subject of housing.”

    I think the State has alot larger issues to address regarding housing and its own fiscal condition then worrying about whether cities are in compliance with low income housing especially when Cities are going to come to them for grant and funding money to make this happen.

    Comment by John — December 8, 2011 @ 11:25 pm

  20. John,

    Regarding the housing element, the State, through legislation, has laid the foundation needed for citizens to enforce certification. The State itself rarely goes beyond commenting on housing elements. The housing element case lost by the City of Pleasanton, even though it spent well over $1,000,000 to defend its element (see the background memo for the Dec. 12th housing element item on the Planning Board agenda), is one exception where the State itself got involved in the person of Jerry Brown when he was Attorney General.

    Alameda could be an exception like Pleasanton where the State gets directly involved in enforcement. As Lauren pointed out, because of the ban in our charter on multi-family housing, Alameda’s housing policies have achieved a high level of notoriety throughout the State and the state.

    You imply that the housing element is primarily to address low income housing needs. That is only part of the picture. Most of the housing permitted by the zoning required by housing elements will be market rate when built after construction picks up again. The State needs more market rate housing as well as low income housing, especially near the heart of urban areas, such as where Alameda is located. For an explanation of why, I refer you to the excellent report on California housing in 2011 that is attached to the housing element agenda packet prepared for the Dec. 12th planning board meeting.

    Comment by William Smith — December 9, 2011 @ 5:49 am

  21. If we are going to talk about State level policy and its impact on housing then let’s stir the hornet’s next and start a discussion about Prop 13 and its effects on residential construction.

    Comment by Mike McMahon — December 9, 2011 @ 7:22 am

  22. John:

    As you pointed out, the State has a lot bigger fiscal issues, but still has quite a pot for funding projects that are essential to maintain or improve Alameda’s infrastructure. Given the competition for those limited funds, Alameda will be at a disadvantage if the state has any reason, including an out of compliance Housing Element, to reject Alameda from being awarded those funds.

    Additionally, there seems to be a misunderstanding about the purpose of the Housing Element, while the RHNA addresses low income housing, the RHNA is about housing in general — including market rate housing. In fact, one of overarching purposes of the Housing Element is to be a market driven way to providing more housing stock by removing barriers created by local jurisdictions that would constrain private developers from developing housing. Affordable housing mandates, inclusionary housing laws, those aren’t considered insurmountable constraints or barriers, if you look at the 2009 letter those aren’t included as elements that bring Alameda’s Housing Element out of compliance. What are is the failure to zone for residential and not providing programs to counteract the effect of Measure A. Those are the things that prevent private residential developers from building ALL types of housing, not just affordable housing.

    Comment by Lauren Do — December 9, 2011 @ 7:36 am

  23. Mike,

    Good to hear from you on housing!

    I absolutely agree that Proposition 13 provides Cities such as Alameda with fiscal incentives to recruit businesses and discourage housing. I have heard John Russo mention this fiscal reality on occasion. Change at the state level in our property tax structure would make housing more attractive for cities (and school districts) – but creative and resourceful cities like Alameda can structure housing deals (e.g. Mello-Roos assessments, etc.) that pay for themselves.

    I agree that an in depth discussion of CA property tax policies and city and school finances would be beneficial. I would be very appreciative of anyone who facilitated such a discussion here on Lauren’s blog or elsewhere.

    Comment by William (Bill) Smith — December 9, 2011 @ 8:41 am

  24. In 16, DLM made a suggestion that deserves careful consideration. She stated that we might be able to meet the State housing density bonus requirements by tweaking our density bonus regulations to allow 30 units per acre rather than just 29.

    Even if that turns out to be true, I suggest we also give careful consideration to approving higher density areas in a few areas around town, especially those near existing commercial centers and transit lines.

    There are many benefits that could result from Alameda doubling or tripling the minimum housing density that the State requires on select properties, 30 units per acre. Higher densities on a few properties would mean that fewer non-residential properties would have to be zoned to residential. Zoning entitling properties to higher densities would make those properties easier to develop, especially for nonprofit developers of affordable housing. And, when well-served by transit, especially from the very beginning, such developments would minimize the amount of vehicle traffic per resident.

    Attachment 3 to Item 9B on the agenda for the Dec. 12th Planning Board meeting includes numerous photos of residential property in Alameda that have 40 to 110 homes per acre. 2021 Clinton and 1438 Lafayette are examples of structures that each shelter 7-8 families comfortably at a density of 40 homes per acre. These structures are compatible with, and provide variety to, single family neighborhoods. 916 Union and 716 Santa Clara each provide about 30 homes at a density of about 100 homes per acre.With good landscaping, exterior design (move the fire escape to the back of the building at 716 Santa Clara!!), and maintenance, these larger structures are also compatible with their surrounding neighborhoods.

    The 21 dwellings above the Starbuck’s Coffee Shop at 1364 Park equate to about 54 homes per acre. The 18 dwellings above 1900 and 1912 Encinal equate to 77 homes per acre. Not only are such dwellings on “main street” increasingly attractive to many, young and old alike, they directly benefit the businesses by sharing the building rent, meaning lower rents for all tenants and higher total rent to the owner. And of course, many of these residents will patronize the restaurants and shops just downstairs rather than driving to out-of-town shopping malls.

    So let’s look beyond minimal compliance with State housing law and also take a close look to see if more sweeping changes to State law would provide even more benefits to Alameda.

    Comment by William Smith — December 11, 2011 @ 10:34 am

  25. Bill

    What about the hundreds of apartments right next to the old island HS site. They went in and installed all new windows and sliding doors and they all have remained empty for last five years or more. Right next to the coast guard housing. Wouldn’t these be perfect low income housing. They already exist .

    Comment by John — December 11, 2011 @ 1:14 pm

    • John,

      Thanks for bringing up the housing next to the old Island High School site. I believe you are referring to older Coast Guard housing. The soil remediation (vapor extraction) there is going well so perhaps the end is in sight. I’ll see if someone in Renewed Hope will check in on the status of that housing with Debbie Potter of the Alameda Housing Authority – it may be in their plans already.


      Comment by William Smith — December 11, 2011 @ 1:30 pm

  26. 6. 13: Jack, I believe that Renewed Hope wrote their letter when they believed that the ONLY way we would ever have a compliant Housing Element was going to be through legal action and the courts. Following the recent work of Andrew Thomas and the Planning Board, however, it is clear that another path to compliance exists and the City is now following it.

    I am certain that Renewed Hope and its members and affiliates (like the Sierra Club, to which I belong) would much rather see the City of Alameda achieve compliance with the State of California without the expense and loss of local control that court actions would involve. And as long as we are making progress towards developing a compliant Housing Element the lawyers will have less work. I like that…

    Comment by Jon Spangler — January 5, 2012 @ 1:45 pm

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