Measure D Squeeze: Six Growth Slots Awarded as ADU Demand Surges in Half Moon Bay

Half Moon Bay's Planning Commission awarded six coveted Measure D growth allocations — nearly all for accessory dwelling units — while flagging deeper tensions over a voter-approved growth cap that may be out of step with a city whose population hasn't budged in a quarter century. Commissioners also accepted the annual housing progress report, pressing staff to forecast whether the city can hit its state housing targets before a March 17 Council presentation.

• Six Measure D allocations awarded from a pool of 21 applicants; 15 deferred to transfers or 2027

• Commission recommends Council slash the transfer wait from six months to 30 days

• Housing element freshly certified, but commissioners flag builder's remedy risk citing Pacifica's troubles

• Planning Director says builder's remedy doesn't apply in the coastal zone — commissioners aren't fully reassured

• Staff planner departure forces yet another senior planner recruitment in a stretched department

Growth Cap Meets ADU Boom

Half Moon Bay's 1999 voter-approved Measure D caps limits residential growth to 1% annually, with an optional additional 0.5% for units in the downtown area, for a total of 1.5% growth This year, the math got tight: 17 of those 23 outside-of-downtown allocations were already reserved for the 940 Main Street affordable housing project, leaving just six slots for everyone else.

Twenty-one applicants submitted requests for 26 allocations. Seventy-five percent of those requests were for ADUs.

Why it matters: The lopsided demand reveals a city where the dominant form of new housing is backyard cottages, not subdivision homes — yet those ADU builders are competing under a decades-old framework designed for a different era of growth.

Where things stand: Staff planner Ocoee Wilson presented the scoring results, explaining that ADUs have a built-in advantage. "ADUs are pretty heavily incentivized via the criteria. Some of the criteria provide points for just having an ADU. Some contribute to the density factor, which plays into the scoring," said Ocoee Wilson, staff planner.

Five ADU applicants received allocations outright. A sixth allocation went to 544 Filbert Street — but only for the ADU portion of a combined single-family home and ADU application, leaving the property owner waiting for the second allocation through the transfer process.

The 544 Filbert Debate

David Beaumont, a public commenter representing the Carry Trusts at 544 Filbert, pushed back on staff's recommendation. He argued the Commission should invert the partial allocation — awarding the single-family home slot first so the owner could begin design review while waiting for the ADU allocation. He also questioned why ADUs remain subject to Measure D at all, noting that the state Department of Housing and Community Development informed Half Moon Bay in October 2024 that counting ADUs under local growth-control ordinances violates state law.

Commissioner Christopher DelNagro picked up on a related thread, asking whether single-family homes and ADUs receive different priority in the scoring. Staff confirmed they do not — but the criteria effectively favor ADUs through density and bonus points.

A Growth Cap With No Growth

Commissioner DelNagro challenged the fundamental math behind Measure D, noting that the city's population hasn't increased since the 2000 census. "I did go back and look at the population of Half Moon Bay. We have not grown by 1% per year at all since 2000. In fact, we haven't grown at all since 2000," he said.

Planning Director Leslie Lacko confirmed that City Council has directed staff to recalculate allocations using actual census population data for next year. "That would be the result, is that there would be fewer allocations," she said — meaning the bottleneck could actually tighten.

Chair David Gorn offered a counterpoint: the gap between allocations granted and homes actually built is the real issue. "All this work on the ranking system is important, but everyone on the list can have a Measure D. It's just that they have to wait till September 1 because of the code," he said, noting that unused downtown allocations typically transfer to the outside-of-downtown pool and could cover all 15 deferred applicants.

Cutting the Wait

Vice Chair Rick Hernandez zeroed in on that six-month transfer wait. "Why do we wait until September to go back to the City Council to do a reallocation? Is it possible that we can do this in 30 days?" he asked.

Staff confirmed the timeline is set by code but could be shortened with a Council action. Vice Chair Hernandez also noted that Council has already provided direction to assign half allocations for ADUs and zero for junior ADUs in future Measure D code amendments — changes that could further reshape the system.

Decisions: The Commission voted 3-0 (For: Chair Gorn, Vice Chair Hernandez, Commissioner DelNagro; Absent: Commissioner Jacob Rems, Commissioner Steve Ruddock) to approve the Measure D scoring, award the partial allocation to 544 Filbert as staff recommended, and add a recommendation that City Council shorten the transfer reallocation period from six months to approximately 30 days if administratively feasible.

What's next: Planning Director Leslie Lacko noted that Measure D code amendments required by the housing element are already in progress but will be separated from the larger rezoning effort to avoid delays. Council will consider the Commission's recommendation on the shortened transfer timeline. The 15 deferred applicants will wait for downtown surplus transfers — potentially as early as 30 days after the start of the allocation year if Council acts on the recommendation.

Housing Targets Loom as Commissioners Eye Builder's Remedy Risk

Staff member Scott Phillips presented the annual housing element and general plan progress report — the third of eight required during the city's 2023–2031 RHNA cycle. The housing element was certified by HCD just last month.

The basics: RHNA (Regional Housing Needs Allocation) is the state-mandated number of housing units each jurisdiction must plan for across income levels. Cities that fall out of compliance risk losing local land-use control through the "builder's remedy" provision, which allows developers to bypass local zoning if they include affordable units.

Why it matters: Building permits issued in the reporting period were modest — a fourplex at Creekside, four single-family homes, and 11 ADUs. Key pipeline projects include essential worker housing at 555 Kelly, Stone Pine Cove, and Creekside, but commissioners questioned whether the pace is sufficient. HCD now also requires the city to track acutely low and extremely low income categories, adding reporting complexity.

Where things stand: Vice Chair Hernandez pushed hardest, invoking a cautionary tale from a neighboring city. "I think you look at what's going on in Pacifica with the builder's remedy problem they're having there with this massive project. I think it's something we want to try to avoid if at all possible," he said.

He pressed staff to go beyond backward-looking data. "I think more importantly for City Council, I know they're going to want to see the likelihood that we're going to hit our number. And that kind of opens up a conversation around what we can do to make sure we get there," he said.

The other side: Planning Director Leslie Lacko offered a legal firewall: "Builder's remedy does not apply in the coastal zone," she said — a position the city maintains but that remains legally untested against aggressive HCD enforcement.

Commissioner DelNagro was skeptical of the entire RHNA framework. "I'm not sure I know of any city that hits their number. I don't think I can name a single one," he said.

Decisions: The Commission voted 3-0 (For: Chair Gorn, Vice Chair Hernandez, Commissioner DelNagro; Absent: Commissioner Rems, Commissioner Ruddock) to acknowledge receipt of the report and direct staff to include a RHNA compliance forecast — projecting foreseeable pipeline projects against targets — when presenting to City Council on March 17.

What's next: Staff will prepare the forecast for the March 17 Council presentation. The city's coastal-zone defense against builder's remedy remains untested, making proactive compliance tracking a higher-stakes exercise than in inland jurisdictions.

Minor Items

• Harbor district RV park compliance: Planning Director Leslie Lacko reported the RV park near Surfers Beach — subject to complaints from El Granada resident Brigitte Bauer — is largely in compliance with its city permit. Staff found only a minor violation involving an overdue usage report and identified signage improvements exceeding permit requirements.

• Pillarcitos Creek fence extension: The interim public works director secured property owner permission to extend the previously approved Pillarcitos Creek fence to Belleville. A CEQA biological consultant is evaluating whether existing environmental coverage applies to the extension.

• New planner hires and departure: Two new planners (associate and assistant level) were hired to fill vacancies left by the former housing coordinator and senior planner. However, staff planner Ocoee Wilson announced her departure for a senior planner position at another city, requiring the department to restart its senior planner recruitment.

• Upcoming agenda items: A storage unit proposal at 925 San Mateo Road (Curly and Reds) and a Verizon cell tower on Carter Hill are expected at a future meeting.

• Draft minutes deferred: Approval of prior meeting minutes was continued because Vice Chair Hernandez was absent from that meeting and Chair Gorn recused from part of it, leaving insufficient members to approve.