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PREVIOUSLY

• ‘Concentrating Poverty’: City of Eureka to File Formal Appeal Over State-Mandated Housing Allocation

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Where should Humboldt County plan to put more low-income housing? If your answer was “nowhere,” sorry. Not an option. For more than 50 years now the State of California has required all local jurisdictions (cities and counties) to plan for the housing needs of everyone in the community. 

It works like this: The California Department of Housing and Community Development (HCD) decides how much housing, at a variety of affordability levels, is needed for each region in the state. Regional governments — in our case, the Humboldt County Association of Governments (HCAOG) — then develop a methodology to allocate those housing units among the various local jurisdictions. 

This process, known as the Regional Housing Needs Allocation (RHNA), happens on an eight-year cycle, and our local turn has arrived again. For Cycle 7, which covers the period of 2027-2035, the state ordered Humboldt County governments to plan for 5,962 new housing units across all income levels. 

The process for accomplishing this chore fairly has gotten increasingly complex over the years as the state keeps adding new statutory objectives. Cycle 7, for example, requires regional governments to factor in “opportunity scores,” a data-driven metric designed to measure access to such resources as education, jobs and reduced pollution.

After accounting for these and many other factors, HCAOG staff came up with a plan, and in December its board of directors adopted a final draft of its allocation methodology. In other words, the board figured out how it should divide the region’s housing allocation among the local jurisdictions, and HCD signed off on the plan.

But local jurisdictions were given the opportunity to appeal. Each of them was fine with the plan except for Eureka, which has been directed to plan for 1,740 new housing units, including 967 units for low-income residents. In January, the city council agreed that this allocation would saddle the county seat with too big a share of the region’s low-income housing units.

Councilmember Renee Contreras-DeLoach said it “feels weird” to “shove people into one spot,” even if it’s under the guise of improving access to opportunities.

The city’s development services director, Cristin Kenyon, explained that Eureka residents’ relatively short work commutes likely played a factor. The city has the lowest average work-based vehicle miles traveled (VMT) of any local jurisdiction, so from the state’s perspective it makes sense to put more low-income housing there.

“[L]iving in a place where you can access your job without a car is helpful if you’re living in poverty,” she said. “It’s part of having access to opportunity. I mean, if you’re going to concentrate poverty anywhere, you would want to do it in an urban area with transit — but I would rather us not concentrate poverty, period.”

The council agreed and unanimously directed staff to file a formal appeal.

Tomorrow afternoon, the HCAOG board will hold a public hearing to consider that appeal.

“This is kind of a novel process for us to be working through here at HCAOG,” Executive Director Brendan Byrd said when reached by phone this morning. 

A staff report prepared for Thursday’s appeal hearing takes a deep dive into the data that informed HCAOG’s allocation methodology, complete with graphs showing how high- and low-income housing gets distributed in the plan as well as the existing high- and low-income housing stock in each jurisdiction and more.

The report does not take a position on Eureka’s appeal, and Byrd said that’s intentional. 

“The intent is to be thoughtful and put objective information forward as best we can get it,” he said. Thursday’s hearing represents “the public’s opportunity to comment, the board’s opportunity to consider the information and Eureka’s opportunity to present their case for an appeal. … From my mind, we’re talking about an objective measurement, and there are other pieces in the process that we as staff feel should happen before we say, ‘This is what we think.’”

Eureka’s appeal letter argues that HCAOG gave too much weight to the city’s short average work commute. It doesn’t challenge the total number of housing units assigned to the city; rather, it says Eureka was improperly assigned a higher share of below-moderate-income housing despite having a lower opportunity than other county jurisdictions. 

“In this context, further reducing the proportion of Moderate and Above-Moderate housing assigned to Eureka risks reinforcing income imbalance rather than promoting a more integrated and economically diverse housing stock,” the appeal letter argues.

The appeal letter doesn’t get specific about how Eureka’s RHNA should be adjusted; it just asks the HCAOG board for a “rebalancing.”

HCAOG’s eight-member board of directors includes the mayors of Eureka, Arcata, Fortuna, Blue Lake and Trinidad, one councilmember apiece from Rio Dell and Ferndale and, representing the county, Supervisor Steve Madrone.

After considering Eureka’s appeal and public feedback at tomorrow’s meeting, the board will have 45 days to issue a certified written decision accepting, rejecting or modifying the appeal. Since the board meets monthly, that means it will have to make that decision before its April 16 meeting, Byrd explained.

“The point here is to provide the data from an objective perspective,” he said about tomorrow’s hearing. “Then the board can consider that and provide their direction.”

The meeting, which is scheduled to begin at 4:30 p.m. Thursday, will be held in the council chamber at Eureka City Hall, 531 K Street. You can find a Zoom link and links to all of the relevant documents on HCAOG’s website.