Public Comments on RHNA Appeals

Consultation has concluded

While this courtesy page to submit comments is closed, you still have until August 30th to submit your comments on Fairfax's RHNA numbers. To submit your comment between August 21 and August 30, please email ABAG directly at rhna@bayareametro.gov.

Prior to August 21st, you could use this page's public comment form below to share your thoughts on the Regional Housing Needs Allocation (RHNA) appeal letters submitted by cities, towns, and the County of Marin. Your comments will be shared with the Association of Bay Area Governments (ABAG) on August 30 when they consider public comments affiliated with appeal letters received from cities, towns, and unincorporated areas.

This webpage is a courtesy clearinghouse for public comments. Residents and employees in cities, towns, and unincorporated areas throughout Marin County can submit comments below on appeals to the RHNA numbers that have been submitted by a city, town, or the County of Marin. EMC Planning Group will combine all comments in a single report that will be shared with the public and submitted directly to the Association of Bay Area Governments on behalf of the public at large throughout all communities within Marin County. We will also send an email to share the report with anyone who either submits a comment or subscribes to this page.

The RHNA appeals period for jurisdictions ended on July 9th. Click here to read the Town of Fairfax's submitted appeal letter. To receive notifications directly from ABAG throughout the appeals timeline, you can sign up on the ABAG website. ABAG will accept comments on submitted appeals from jurisdictions, HCD, and members of the public for 45 days following the end of the appeals filing period. All comments must be filed by 5:00 p.m. PST on August 30, 2021. ABAG will not accept late comments.

Under State law, appeals may only be considered under a narrow set of circumstances. There are three main topics for appeal consideration. ABAG is now accepting public comments on appeals that have been submitted by jurisdictions. The following circumstances define the three main topics for appeal consideration by ABAG.

First, an appeal may have been submitted that focused on the point that ABAG has failed to consider local planning factors. Eligible planning factors are listed below.

  • Existing or projected jobs-housing balance
  • Sewer or water infrastructure constraints on additional development
  • Availability of land suitable for urban development or for conversion to residential use
  • Lands protected from urban development under existing federal or state programs
  • County policies to preserve agricultural land
  • Distribution of household growth assumed for purposes of comparable period of regional transportation plans
  • County-city agreements to direct growth toward incorporated areas of County
  • Loss of units in assisted housing developments
  • High housing cost burdens
  • Rate of overcrowding
  • Housing needs of farmworkers
  • Housing needs created by university campus in jurisdiction
  • Loss of units during state of emergency
  • Regional greenhouse gas emission targets
  • Affirmatively furthering fair housing

Second, an appeal may have been filed that focused on the point that ABAG failed to calculate the City’s RHNA allocation in accordance with the ABAG'S State-approved RHNA Methodology.

Third, an appeal may have filed that describes an unforeseen change in circumstances that warrants a change in the RHNA allocation.

Find your jurisdiction appeal letter below to learn the position that your city, town, or county has taken, and add your voice to the discussion by filling out the public comment form below.

While this courtesy page to submit comments is closed, you still have until August 30th to submit your comments on Fairfax's RHNA numbers. To submit your comment between August 21 and August 30, please email ABAG directly at rhna@bayareametro.gov.

Prior to August 21st, you could use this page's public comment form below to share your thoughts on the Regional Housing Needs Allocation (RHNA) appeal letters submitted by cities, towns, and the County of Marin. Your comments will be shared with the Association of Bay Area Governments (ABAG) on August 30 when they consider public comments affiliated with appeal letters received from cities, towns, and unincorporated areas.

This webpage is a courtesy clearinghouse for public comments. Residents and employees in cities, towns, and unincorporated areas throughout Marin County can submit comments below on appeals to the RHNA numbers that have been submitted by a city, town, or the County of Marin. EMC Planning Group will combine all comments in a single report that will be shared with the public and submitted directly to the Association of Bay Area Governments on behalf of the public at large throughout all communities within Marin County. We will also send an email to share the report with anyone who either submits a comment or subscribes to this page.

The RHNA appeals period for jurisdictions ended on July 9th. Click here to read the Town of Fairfax's submitted appeal letter. To receive notifications directly from ABAG throughout the appeals timeline, you can sign up on the ABAG website. ABAG will accept comments on submitted appeals from jurisdictions, HCD, and members of the public for 45 days following the end of the appeals filing period. All comments must be filed by 5:00 p.m. PST on August 30, 2021. ABAG will not accept late comments.

Under State law, appeals may only be considered under a narrow set of circumstances. There are three main topics for appeal consideration. ABAG is now accepting public comments on appeals that have been submitted by jurisdictions. The following circumstances define the three main topics for appeal consideration by ABAG.

First, an appeal may have been submitted that focused on the point that ABAG has failed to consider local planning factors. Eligible planning factors are listed below.

  • Existing or projected jobs-housing balance
  • Sewer or water infrastructure constraints on additional development
  • Availability of land suitable for urban development or for conversion to residential use
  • Lands protected from urban development under existing federal or state programs
  • County policies to preserve agricultural land
  • Distribution of household growth assumed for purposes of comparable period of regional transportation plans
  • County-city agreements to direct growth toward incorporated areas of County
  • Loss of units in assisted housing developments
  • High housing cost burdens
  • Rate of overcrowding
  • Housing needs of farmworkers
  • Housing needs created by university campus in jurisdiction
  • Loss of units during state of emergency
  • Regional greenhouse gas emission targets
  • Affirmatively furthering fair housing

Second, an appeal may have been filed that focused on the point that ABAG failed to calculate the City’s RHNA allocation in accordance with the ABAG'S State-approved RHNA Methodology.

Third, an appeal may have filed that describes an unforeseen change in circumstances that warrants a change in the RHNA allocation.

Find your jurisdiction appeal letter below to learn the position that your city, town, or county has taken, and add your voice to the discussion by filling out the public comment form below.