County receives 2024 housing progress report, staff flags VMT court ruling and seeks SANDAG grant

The San Diego County Board of Supervisors on April 23 received the county's 2024 General Plan and Housing Element Annual Progress Report, heard staff brief the board on housing production figures and legal constraints posed by recent court decisions on Vehicle Miles Traveled (VMT), and authorized staff to apply for a SANDAG Smart Growth Incentive Program grant to fund targeted planning in transit-served areas.

Staff presented key counts used in the state's progress measures: 1,088 housing units in unincorporated areas were issued building permits in 2024 and 954 units were completed and ready for occupancy. The county reported progress toward its Regional Housing Needs Allocation (RHNA) for the unincorporated area of 6,700 units: 430 units were categorized as above-moderate income, 224 as moderate, 285 as low (about 99% of the county's low-income goal), and 149 as very low (about 24% of the very-low-income goal).

The report and staff presentation emphasized that very-low-income units remain the hardest to build and typically require subsidy. Rami Tully, interim assistant director of Planning and Development Services, summarized the county's pipeline and programs, including free preapproved ADU plans, SB 9 streamlining, and funding for affordable projects coordinated by Housing and Community Development Services. "We're among the first counties in the state to earn a pro-housing designation," Tully said, while warning that multiple factors affect production.

A central focus of the discussion was a recent Court of Appeal ruling that struck down aspects of the county's Transportation Study Guide (TSG). County counsel explained the ruling invalidated the county's broader "infill" and small-project exemptions from VMT analysis, while leaving intact the county's 15% below-regional-average VMT threshold. "The Court of Appeal agreed with the petitioners that there was insufficient evidence supporting those infill exemptions," county counsel said. Staff said the county has filed a petition for rehearing and is evaluating whether to seek review in the California Supreme Court; staff also said they will return to the board with options for a VMT mitigation program.

Developers, business groups and housing advocates urged the board to act to preserve or expand pathways that speed housing production. Laurie Holt Feiler of the Building Industry Association warned that insufficient housing is pushing workers to commute into the region. Evan Strong of the San Diego Regional Chamber of Commerce said county and state policies, especially around VMT, have hindered development and asked the board to remove barriers.

Several public commenters, including members of planning groups from rural communities, expressed concern about the county's regulatory approach and about enforcement staffing: the Fallbrook Community Planning Group asked the board to select the no-project alternative for the county's cannabis program draft EIR, and other speakers pressed for more deed-restricted very-low-income housing and for zoning and code clarity.

Board members pressed staff on next steps. "Per previous board direction, staff continues to evaluate potential options for a VMT mitigation program and will return in the winter," staff said. Supervisor Joel Anderson asked whether the county could revert to a different VMT approach; county counsel responded the board can change thresholds but would need to weigh legal risk. "The board has the power to adopt nearly any threshold it wants," counsel said, adding that advice about risks would be provided in closed session if requested.

The board unanimously voted to receive the GPAPR, accept the staff presentation, and authorize application for the SANDAG Smart Growth Incentive Program grant and related CEQA exemptions and policy waivers (motion moved by Supervisor Montgomery Stepp; second by Supervisor Anderson). The grant request would support planning in a proposed Buena Creek specific plan coordinated with the North County Transit District and would request a waiver of Board Policy B-29 (full cost recovery) to accept the grant.

What this means: The county reported steady production in some income bands but remains far short on very-low-income units. The Court of Appeal ruling narrowed some of the county's VMT pathways; staff plans to propose mitigation or other options later this year. The SANDAG grant application would fund targeted planning intended to facilitate VMT-efficient development near transit.

The board directed staff to return with further policy proposals, including work on a VMT mitigation program and an inclusionary housing ordinance.

Ending: Staff said the county will continue both locally led actions (affordable projects on county land, ADU facilitation) and policy work to respond to the court ruling. The board received the report and asked for follow-up sessions focused on pipeline, zoning updates and concrete measures to increase very-low-income housing production.