Security National Master Holding Company, LLC

Proponents Report on the City of Eureka Housing for All and Downtown Vitality Initiative

The Proponents of the “City of Eureka Housing for All and Downtown Vitality Initiative” (“Initiative”) have reviewed and prepared this report responding to the City of Eureka’s “Elections Code 9212 Report” (“City Report”) regarding the Initiative.

On the whole, the City Report presents a biased, and in some cases, false or misleading, analysis of the Initiative and the laws governing affordable housing in California. While certain City officials and staff have publicized their opposition to the Initiative, which was endorsed by nearly 2,000 City voters, the City Report is supposed to present an objective assessment to inform City officials and voters of the likely effects of the Initiative on City finances, land use plans, housing, and other topics. Instead, the City Report is a taxpayer-funded advocacy piece for those City officials and staff whose vision for the City differs from that of the City voters.

This Initiative was born out of years of frustration by local businesses at the City’s refusal to listen to their concerns about the City’s plan to eliminate downtown off-street public parking. The Initiative has been carefully drafted to find a better solution – one where the City can continue to use the City-owned lots to help provide much-needed affordable housing while preserving the safe, convenient public parking that is essential to the continued vitality of the City’s businesses, restaurants, professionals, shops, and cultural and tourist destinations. The Initiative, further, places this important decision about the City’s future where it belongs – in the hands of the City’s voters.

This report has been prepared by the Proponents of the Initiative in accordance with the content requirements of Elections Code Section 9212. The purpose of this report is to provide an objective “second opinion” to the City Report. The information in this report is drawn from City documents, published studies and reports, and input from community members.

Top Benefits of the Initiative

  1. The Initiative makes no change to the City’s overall RHNA allocation, and makes no change to the City’s ability to construct 330 affordable housing units on City-owned property. The Initiative is simple – it allows the City to redevelop City-owned downtown parking lots as currently planned, but requires the developments to preserve the existing parking spaces on those lots. The Initiative does not interfere with the City’s ability to meet its RHNA obligations.
  2. The Initiative will have a positive economic impact on City businesses, retailers, restaurants, professional services, and cultural and tourist destinations by preserving safe, accessible downtown parking. Elimination of these parking lots will mean that customers, patrons, and clients will be relegated to finding on-street parking or to parking at a distant off-street lot. Both options are problematic – on-street parking is not available in volume during typical business hours, and distant parking creates a safety risk, particularly after dark.
  3. The Initiative would give new life to the Jacobs site. The HFA Overlay would allow the site to be redeveloped into a variety of housing types serving all income levels, as well as neighborhood-serving commercial uses such as corner markets, restaurants, and retail shops.
  4. The Initiative recognizes and respects the City’s recent bid award to the Wiyot Tribe Dishgamu Humboldt Community Land Trust (“Wiyot”) to redevelop the City-owned parking lots at 5th and D and 6th and L, and allows the Wiyot to develop low-income housing on those lots without preserving the existing parking spaces.

Top False or Misleading Statements In the City Report

  1. The City Report asserts that the Initiative would invalidate or require recertification of the General Plan Housing Element. This is false. The Initiative does not prohibit the construction of affordable housing on the City-owned lots proposed for redevelopment in the Housing Element, or on any of the 21 City-owned parking lots that would be subject to the Initiative. The Initiative would expressly preserve the ability to build high-density affordable housing on those lots; the only difference between current regulations and the Initiative is that the Initiative would require the City to preserve existing off-street parking spaces when constructing affordable housing on those 21 lots.
  2. The City Report states that the Initiative would require the City to adopt amendments to the City’s Housing Element and then resubmit the Housing Element to the state (HCD) for certification. This is false. The Initiative itself would enact the Housing Element amendments – no further action from the City Council is required. Further, Government Code section 65585(d), which the City Report claims would require the City to resubmit the Housing Element to HCD, only applies to housing element updates undertaken pursuant to another provision of state law, Government Code section 65588, and not amendments enacted by an initiative.
  3. The City Report asserts that the Initiative would “remove the required minimum number of affordable units and minimum building square footage from six of fourteen identified City-owned parcels, and derail the overall goal of 327 deed-restricted affordable units by 2028.” This is misleading. While the Initiative would remove the specific unit count references in General Plan IMP H-34, this was done to correct the City’s own errors and inconsistencies in those numbers. The Initiative would not impact the City’s obligation to plan for the construction of 952 dwelling units through 2027, nor would the Initiative impact the City’s ability to construct 330 of those units on City-owned property or the minimum square footage for those City-owned lots that would be subject to the Initiative.
  4. The City Report, based on analysis performed by a consultant, asserts that requiring affordable housing developers to preserve ground-floor parking would make the developments financially infeasible. This is false. The City’s own Housing Element already calls for the preservation of parking at three of the six sites awarded for development – Site 3 (City Parking Lot – 6th and M), Site 4 (City Parking Lot – 5th and D), and Site 5 (City Hall Parking Lot – 6th and L).1 The last of these is particularly interesting because the City apparently desires to maintain the existing ground level parking for City employees, but does not share the same concern for the employees of local businesses. Moreover, affordable housing with ground-level parking has been constructed all across California, including in Los Angeles, Sacramento, Modesto, and San Jose, among other cities.
  5. The City Report, based on an analysis performed by a consultant, asserts that the Initiative would result in a loss of $566.0 million in one-time construction related output, and the loss of $24.0 million per year in retail spending. This is false and misleading. The consultant’s analysis is based on the flawed assumption that the Initiative would prevent the construction of affordable housing on the City-owned lots – it would not. The analysis also fails to take into account the economic impacts that would result if the Initiative were not adopted, and the City redeveloped the downtown area parking lots without preserving parking. This would result in significant job losses and losses in retail spending.

You can download the full report and press release below.

Housing for All Proponents Report

Proponents of Housing for All Initiative Release Impact Report_Press Release_11.7.23

Posted on in Data, Press Releases. Bookmark the permalink.

Housing for All