Centennial staff urges DRCOG to correct data gaps in regional housing needs assessment under SB 24-174

Centennial staff on July 15 told the City Council that the Denver regional housing needs assessment prepared by the Denver Regional Council of Governments (DRCOG) and tied to Senate Bill 24-174 allocates 7,300 housing units to Centennial for the next decade but contains data differences the city wants addressed. Melanie Ward, the city's manager of development, foresight and infrastructure readiness, told the council the DRCOG assessment “allocates a 10‑year housing need to Centennial of 7,300 units” and recommends the Denver region build roughly 223,000 units over the next decade toward a broader 500,000‑unit target by 2050. Ward said DRCOG used a HUD (U.S. Department of Housing and Urban Development) permit dataset that shows about 1,700 units permitted in Centennial over the past decade; Centennial’s internal permitting records show almost 3,000 units permitted over the same period, an undercount Ward characterized as roughly 42 percent. The DRCOG work is part of implementation of Senate Bill 24-174, cited by staff as the Sustainable Affordable Housing Assistance Act (also called the Housing Planning Act). Ward said the statute requires a housing needs assessment by the end of 2026 and gives jurisdictions the option to use either a local or a regional assessment. The statute also calls for comprehensive plan updates to add a water supply and strategic growth element and for a housing action plan, but those later steps await state rulemaking, Ward said. Ward told the council that the state’s Department of Local Affairs (DOLA) suggested updates Centennial could add to its 2022 local housing needs assessment, including disaggregating housing need by income and adding a geographic analysis of displacement risk. She said DRCOG’s process accepts public comment and defines a 60‑day comment window that DRCOG set from July 14 through Sept. 12, 2024. Council members raised several clarifying questions. Mayor Jack Pico asked whether staff could supply updated permit and pipeline counts to show projects under construction or approved since 2021; Ward said the city could and recommended including those more current pipeline figures in comments to DRCOG. Council member Sheehan asked for a definition of “displacement risk”; Ward replied it means areas where development may price existing residents out of their homes. Council member Austin asked whether units in the private market counted as “new” housing for DRCOG’s model; Ward said DRCOG appears to be focusing on the projected number of households rather than simple turnover, and staff will ask DRCOG for model details. Staff proposed four formal comments for DRCOG: provide updated permitted‑unit counts to correct the undercount; reconcile local growth rates with DRCOG allocations that appear to assume Centennial will grow at the same rate as Arapahoe County and the Southeast submarket; include undeveloped and underdeveloped land capacity in DRCOG’s assessment; and note Centennial’s local analysis that shows a surplus of rental housing for households earning $50,000–$75,000 and a surplus of ownership units for households earning more than $100,000. If the council agrees, Ward said staff would edit the draft comments and submit them to DRCOG by the Sept. 12 deadline and would return to council later with proposals for comprehensive plan updates and for the housing action plan once the state finalizes rules. No formal vote was taken; council members indicated support for allowing staff to finalize and submit comments to DRCOG. The discussion took place during the council’s study session; the city did not adopt new policy or a local housing action plan at the meeting.