Analysis: What Happens If We Don’t Build the Housing

By David Greenwald April 27, 2026

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DAVIS, Calif. — Davis is in real danger of failing to meet the state’s lower-income housing requirements, and the consequences could extend far beyond another disappointing housing report. If the city cannot produce enough affordable housing in the remaining years of the current RHNA cycle, local control over land-use decisions — and potentially the future of Measure J itself — could be at risk.

The city’s 2025 Housing Element Annual Progress Report shows a widening gap between state-required lower-income housing targets and actual production. That gap, in turn, raises a second question: whether Davis can realistically close it without major projects such as Willowgrove and Village Farms. And looming over both issues is a third: whether continued underproduction will place Measure J/R/D under increasing pressure from the state.

The city’s own report offers a snapshot of where Davis stands in the current 2021-2029 Regional Housing Needs Allocation (RHNA) cycle. Under RHNA, Davis must plan for and facilitate 2,075 housing units across income categories, including 290 extremely low-income units, 290 very low-income units and 350 low-income units. That means the city’s lower-income obligation totals 930 units.

Through the end of 2025, however, Davis has permitted only 30 units in those three categories. 

According to the report, that includes 28 units in the combined very low/extremely low categories and just two units in the low-income category. In percentage terms, the city has achieved only about 3.2 percent of its lower-income target with just a few years left in the cycle.

By contrast, Davis has already exceeded its moderate-income allocation and made meaningful progress in above-moderate categories. The report shows 522 moderate-income units and 411 above-moderate units permitted so far, while lower-income production remains dramatically behind.

Looking only at total units is misleading, because California housing law is not concerned only with total units.

The state is especially focused on housing for lower-income households, workers, seniors, residents with disabilities and people most vulnerable to displacement. Producing market-rate units while falling short on affordability does not solve the city’s obligations under RHNA.

The city’s report makes the remaining challenge explicit. 

Davis still must issue permits for 348 more low-income units, 262 more extremely low-income units and 290 more very low-income units before the cycle ends in 2029. In total, more than 900 lower-income units remain outstanding.

That brings us to the second question: where do those units come from?

The city has expanded ADU opportunities, created pre-approved ADU plans and updated local ordinances to comply with state law, but the annual report illustrates the limits of relying on those incremental strategies alone.

In 2025, Davis issued permits for 75 total housing units. That included 31 single-family units, 42 accessory dwelling units and just two multifamily rental units. Only two deed-restricted affordable units were included in that year’s total.

At that pace, closing a 900-unit lower-income gap before 2029 would be extraordinarily difficult.

A key question remains whether the Davis Housing Element represents paper compliance or actual housing production.

Davis’ Housing Element was certified by the California Department of Housing and Community Development in February 2024. Certification means the city identified adequate sites, adopted required programs and demonstrated compliance with state planning law.

But certification is not the same as construction, because zoned capacity does not automatically become housing and projects still require financing, environmental review, infrastructure, developer follow-through and, in some cases, voter approval.

That final requirement is where Measure J/R/D enters the picture.

Measure J, later renewed as Measure R and Measure D, requires citywide voter approval before agricultural land at the edge of Davis can be annexed and developed for urban uses. 

For many residents, it is one of the defining civic safeguards in modern Davis history. Supporters argue it protects farmland, limits sprawl and gives the public direct authority over transformative land-use decisions.

Critics argue it imposes delay, uncertainty and political risk that discourage housing proposals before they even reach voters.

In a state confronting a severe housing shortage, they contend, local election requirements can function as barriers to production.

During the Housing Element process, HCD signaled concern in precisely those terms.

As previously reported by the Vanguard, state communications indicated California officials were closely monitoring Davis’ housing compliance and were concerned that Measure J/R/D could function as a barrier to housing production.

The same reporting noted that HCD raised similar concerns during the Housing Element approval process, citing Measure J’s limited track record in producing affordable housing.

A prior Vanguard analysis of the city’s Housing Element correspondence found that the California Department of Housing and Community Development (HCD) directly questioned whether Measure J/R/D functions as a housing constraint.

HCD in December 2021 wrote, “Measure J poses a constraint to the development of housing by requiring voter approval of any land use designation change from agricultural, open space, or urban reserve land use to an urban use designation. Since the ordinance was enacted in March of 2000, four of the six proposed rezones have failed. As the element has identified the need for rezoning to accommodate a shortfall of sites to accommodate the housing need, the element should clarify if any of the candidate sites to rezone would be subject to this measure and provide analysis on the constraints that this measure might impose on the development of these sites.”

Legal Services of Northern California in a separate communication, argued, “The City Council’s recent decision to not put any of the five peripheral development proposals on the ballot for November 2024 proves that Measure J/R/D does limit housing supply because it adds time to the development review process.”

Further, Legal Services argued that “a constraint to housing development exists even when the City may be able to demonstrate sufficient sites to address the RHNA.”

Under California housing law, cities are required to identify and address local constraints to housing production. 

HCD’s concern was not simply philosophical opposition to Measure J, but whether a voter-approval requirement that adds cost, delay and uncertainty could interfere with the city’s ability to meet housing needs.

The city’s response was that Measure J was not an immediate barrier because Davis still had enough infill capacity to remain compliant. 

As the Housing Element stated, “While Measure J adds costs, extends processing times, and has been used to halt development projects that would convert agricultural land to urban development, it is only a constraint to meeting housing needs if the city lacks sufficient infill housing sites.”

But that cushion likely has run out.

In December 2023, then-Mayor Will Arnold warned, “I would just say to those who have said that we will be able to meet our next RHNA cycle numbers without going outside of the city limits… I suggest they tune in or watch the recording of this meeting as we really try to meet our current requirements simply with infill and the difficulty we’re having in doing so.”

HCD’s warning from 2021 warrants renewed attention because the city has made little progress toward its affordable housing obligations while appearing to have exhausted most realistic infill opportunities.

Moreover, the state of California has become increasingly willing to challenge local rules, discretionary processes and growth controls that obstruct state housing goals. What once might have been viewed as purely local policy is now subject to state oversight.

The city itself appears to recognize that risk. 

In 2025, a joint meeting of the Planning Commission and Social Services Commission was convened to examine Measure J/R/D and possible reforms. The Vanguard reported at the time, “Future housing applications are more likely to require voter approval under Measure J/R/D, creating a potential clash between state housing mandates and local growth control.” 

That clash is becoming more concrete as Davis’ lower-income numbers lag.

If the city can meet its RHNA obligations through existing infill sites, entitled projects and voluntary private development, the political pressure on Measure J may ease for now. But if lower-income production continues to trail far behind targets, pressure will grow from multiple directions.

One path would be approving major peripheral projects such as Willowgrove and Village Farms through the existing Measure J process. Another would be amending the ordinance to create exemptions or streamlined treatment for affordable housing. A third possibility would be deeper intervention from Sacramento if state officials conclude local processes are frustrating compliance.

This last possibility is becoming increasingly likely, particularly if voters reject one or both of the 2026 housing projects that will appear on this year’s ballots.

In short, Davis risks losing local control over land-use decisions if it fails to provide sufficient low-income housing, and there does not appear to be a viable path to meeting those obligations without the two large peripheral projects.

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