Los Gatos Manufactures High Density/Intensity Housing
Just because the 20 year plan covers 2 1/2 RHNA cycles does not lead to the conclusion that the Town should forecast future RHNA allocations and then change the Land Use Element densities and intensities. Covering 2 1/2 cycles of future RHNA allocations is not required by the Government Code. This was simply a manufactured planning assumption and is not supported by any independent forecast of housing demand.
It is our sense that a few people had an agenda, which was to increase housing densities for all land uses. They wanted more dense and intense housing throughout the Town. To do that, they had to change the existing land use categories approved densities and intensities. There are no long term State housing-need forecasts that would support radically increasing housing densities. The Plan Bay Area 2040 projected for Los Gatos growth of only 619 units between 2010 and 2040! That number is published. And under the current 2020 general plan and land uses, there is sufficient capacity to accommodate that growth.
The Town’s own Preferred Land Use Alternative report on page 7 concluded “the range of likely market demand for housing in Los Gatos between 2020 and 2040 is 1,529 (DOF Projection) to 1,954 (ADE projection) units”. If we average the two projections, we get 1,742 units over a 20 year period. That means the Town would need to add 87 units a year to meet forecasted demand. This is a key point to understand – it is all about the rate of housing growth and not the total number! So how do you support increasing the existing densities if there is no official projection for housing demand which would support such a move?
Enter the 2 1/2 cycle RHNA allocation argument. Based on this argument which claims that future RHNA allocations are a good predictor of future housing demand. Keep in mind that there isn’t an independent forecast for future RHNA allocations and no model used by the State in projecting future housing demand includes a future RHNA allocation as an independent forecasting variable to determine future demand for housing. The Town adopted this methodology and then changed every residential land use’s density to allow for adding 187 units a year (3,738 units / 20 years) as opposed to 87 units per year! That is a growth rate that is 2.15x the Town’s own published estimate of what is required. As a resident of Los Gatos, how do you feel about this?
Then the Town had the DEIR study the impact of “potentially” adding only up to 3,738 unit over the next 20 years. This 3,738 number is made up because the model used to determine future housing added was based on an assumed redevelopment percentage of existing developed land. If those percentages are wrong (too low), then the model would project more housing developed which the DEIR didn’t study. There is a major problem with the Town’s DEIR in that we believe the DEIR does not study the full impact of the land use changes at maximum allowable build out. The DEIR only studied a small percentage of the allowable buildout, which does not comply with CEQA. And that percentage buildout is an “estimate” that is not supported by any study.
It is important to understand the downstream impact of cranking up the growth rate in housing based on this manufactured RHNA allocation argument which led to increasing land use densities. The goal of a few people seems to have been to increase residential housing densities Town wide. They created a false demand model which justified these changes.
The LGCA is committed to making sure that ultimately voters will have the ability to have a say in the vision for Los Gatos given the radical changes being proposed.