Coronado must plan for its mandated 912 additional housing units soon or risk prosecution, state officials say.
After 18 months of noncompliance with the city’s new housing allocation, the matter could be turned over to the state Attorney General, warned a Dec. 14 letter from the California Department of Housing and Community Development (HCD).
Potential penalties include fines of up to $100,000 per month, loss of state funding, and loss of local land use. The letter gave city officials until Jan. 14 to respond.
“The City will respond to HCD’s Notice of Violation letter shortly after the new year,” said Richard Grunow, the city’s community development director. “We will provide HCD with an update on our efforts to develop a compliant housing element, and we will invite HCD staff to meet with us in Coronado to discuss how 912 new housing units can be accommodated, given Coronado’s unique geographic and regulatory constraints.”
California law mandates that jurisdictions adapt zoning to allow for more housing, an effort to address the statewide housing crisis. The number of units required in each eight-year cycle is determined by the San Diego Association of Governments (SANDAG).
In the current housing cycle, Coronado is slated to zone for 912 new housing units – at least half of them for moderate- and low-income earners. This number dwarves previous assessments: In 2010, Coronado was assigned just 50 new units under SANDAG’s regional housing needs assessment (RHNA).
The current cycle’s end – and thus, Coronado’s deadline for the changes – is in 2029.
“Given our small size, built-out parcels and geographic and regulatory constraints, developing the plan has been a thorough and iterative process,” said Tina Friend, city manager, who reiterated that Coronado intends to work with the state to develop an acceptable plan.
Critics of the plan say that rezoning for that many units would change the character of Coronado, a city of 20,000 people spread across 32.5 square miles. After receiving its assessment in 2020, Coronado attempted to appeal, but was struck down by a population-weighted vote by other members of SANDAG. By a tally vote, the appeal would have been granted.
Coronado and three other municipalities sued, asserting that the weighted votes for the RHNA resulted in a biased plan that didn’t account for the constraints of smaller cities. SANDAG argued that only lawmakers – not courts – could overturn RHNA. A Superior Court dismissed the case in June 2022, saying SANDAG was immune from judicial review.
In 2021, the city submitted a plan to zone for 344 new units of housing rather than the full 912, a proposal that the HCD rejected.
“Jurisdictions without a substantially compliant housing element cannot rely on inconsistency with zoning and general plan standards as a basis for denial of a housing project for very low-, low-, or moderate income households,” the HCD letter stated.
In fact, state law allows landowners to take advantage of California density bonuses for low-income housing regardless of whether their projects align with city zoning. The Coronado City Council is expected to revise its code to reflect these laws in its January meeting.
Coronado City Planning Commissioner Jon Ryan mentioned in the commission’s Dec. 13 meeting that the U.S. Navy is a potential source of help for the issue. North Island Naval Station comprises 5,000 acres, and Coronado hosts several military housing communities. However, that may not be feasible.
“While it is theoretically possible to meet a portion of Coronado’s RNHA of 912 units on Navy property, the Navy has not expressed any plans to develop new housing in Coronado in the near future,” Grunow said. “HCD would only accept housing on Navy property if it were likely to be developed during the current eight-year housing cycle.”
Low-income households are divided into low, very low, and extremely low income earners based on how much of the area median income (AMI) they earn. SANDAG slated for 108,036 units total in San Diego County, to be allocated among earners as shown below.
| Income Group | Percentage of AMI | Share | Percent of new units | Number of units in Coronado |
| Extremely low income | 0-30 | 12,380 | 11 | 100 |
| Very low income | 31-50 | 15,169 | 14 | 128 |
| Low income | 51-80 | 17,311 | 16 | 146 |
| Moderate income | 81-120 | 19,319 | 18 | 164 |
| Above moderate income | >121 | 43,837 | 41 | 374 |
In San Diego County, the AMI is $106,900, while the median home price in Coronado is $2.6 million. Households qualifying as the various income earning groups are classified as follows:
| Family Size | Low income | Very low income | Extremely low income |
| 1 | $72,900 | $45,550 | $27,350 |
| 2 | 83,300 | 52,050 | 31,250 |
| 3 | 93,700 | 58,550 | 35,150 |
| 4 | 104,100 | 65,050 | 39,050 |
| 5 | 112,450 | 70,300 | 42,000 |
| 6 | 120,800 | 75,500 | 45,300 |
| 7 | 129,100 | 80,700 | 48,450 |
| 8 | 137,450 | 85,900 | 51,550 |
