Abstract
Public participation is a core component of federal and state fair housing law implementation, but its effectiveness at Affirmatively Furthering Fair Housing (AFFH) remains understudied. In this paper, we analyze the public engagement processes of eight southern California municipalities as they developed a newly mandated AFFH component for their 2021–2029 housing element update. We evaluate the timeline of plan development, outreach efforts, websites, surveys, meeting sufficiency, and the efforts to make public meetings inclusive. We find that they budgeted insufficient time for participation and provided insufficient information about this complex planning process. The two cities with more extensive public processes created fair housing programs that are meaningful, but they are also the more affluent cities in the sample therefore it is not possible to ascribe causality. We propose that AFFH law should standardize outreach processes, assist cities that have fewer resources, and conduct representative surveys on behalf of localities.
Keywords
Introduction
In 2018, California's Assembly Bill 686 required local governments to Affirmatively Furthering Fair Housing (AFFH). They would have to take meaningful actions to “address significant disparities in housing needs and in access to opportunity, replace segregated living patterns with truly integrated and balanced living patterns, transform racially and ethnically concentrated areas of poverty into areas of opportunity, and foster and maintaining compliance with civil rights and fair housing laws” (California Department of Housing and Community Development 2021, 14). This requirement is important in a state like California, where cities and counties must regularly update their general plan's housing element that consists of policies, programs, and actions that govern housing development decisions during the subsequent 8 years.
In order to fulfill the AFFH mandate, the California Department of Housing and Community Development (HCD) also requires municipalities to put forth a “diligent effort to include public participation from all” (California Department of Housing and Community Development 2021, 21). HCD asks local governments to use varied methods to reach a range of stakeholders, including low-income residents with acute housing needs, non-English speakers, and people with limited access to technology. HCD holds local knowledge and community participation as essential to identifying and removing jurisdiction-specific impediments to fair housing. HCD cannot verify that each jurisdiction's fair housing analysis fully and accurately reflects disparities, so public scrutiny and feedback during engagement should complement state agency oversight to identify mistakes or obfuscations in the local plan and induce local policy reform, at least in theory. Yet housing elements are complex technical documents. Public scrutiny depends on an accessible update process that allows for community participation.
Our research, therefore, seeks to answer three questions. (1) How did municipalities in southern California address the state requirement for public participation in the analysis of fair housing problems and the development of programs to address them? (2) Did cities with more inclusive participation efforts have programs that are more meaningful and more potentially integrative 1 land use plans? (3) Did the municipalities that needed to change their land use plans more substantially to meet fair housing goals, that is, the more segregated ones, have more inclusive participation efforts?
To answer these questions, we analyze how eight municipalities—Santa Monica, Montebello, Fontana, Huntington Beach, Chula Vista, Simi Valley, Pasadena, and Downey—conducted public participation around fair housing for their housing element update. We selected these case studies from southern California municipalities to observe how variation in levels of segregation by race/ethnicity and household incomes shaped participation. The fourth section details our selection methodology, which identifies comparable cities that vary across specific characteristics. We analyzed six dimensions of these cities’ public participation processes: the timeline, outreach, websites, surveys, public meeting sufficiency, and public meeting inclusivity.
We find that cities generate and incorporate public participation for their housing element in widely different ways, and commit different amounts of resources to the effort. For example, Santa Monica held nearly 30 public meetings whereas Huntington Beach held four. The biggest hurdles to meaningful participation we find are the timeline of public engagement, which is too short, and housing element websites, which are inadequate. We argue, therefore, that the wide leeway given to cities on public engagement contributes to inconsistent processes and suboptimal outcomes. Without clear and sufficient information about the role of AFFH in the housing element, and without enough time for communities to learn about and provide input on housing element drafts, public participation cannot fulfill its expected role.
In response to our second research question, we find suggestive evidence that cities with more accessible public participation processes put forward AFFH programs that would make more progress on the goals of fair housing law. However, this correlation across a small sample of cities does not mean there is a causal relationship between accessible participation and plan content. It is just as possible that some municipalities simply both had accessible participation efforts and developed strong programs.
Finally, to answer the third question, we do not observe a correlation between the accessibility of cities’ public participation processes and their level of segregation or household incomes. Of the two worst performing cities, one was high-income and one was low-income. These findings are of course only suggestive, given the limits of eight case studies, but they are provocative and merit future research since the implementation of fair housing law at present depends on successful public participation, in addition to knowledgeable staff and elected officials committed to achieving the goals.
Background on AFFH in California
In 2018, partially in response to the Trump administration's rescission of the federal AFFH requirement, California adopted Assembly Bill 686: the AFFH Law (2018 Cal. Legis. Serv. Ch. 958). California's law replicated the language that the federal government adopted on AFFH in 2015, bringing the same AFFH goals into state law. The state also follows the same decentralized procedural logic as federal policy, that is, local governments must analyze fair housing issues within their jurisdiction and develop meaningful actions to address problems that the analysis uncovers. A core component of this approach is community engagement, both in identifying contributors to disparate outcomes and in developing programs to address them (Steil and Kelly 2018). By codifying the federal 2015 AFFH requirement into state law, implementation in California has national relevance.
One distinguishing feature of California's pre-existing housing policy landscape is a requirement that cities and counties update the housing element of their general plan every 8 years and submit for review and certification by HCD (Cal. Gov’t Code § 8899.50). The state added an AFFH requirement to this process in 2019, applicable to future housing element updates. Housing element update deadlines are staggered by region in the state to allow HCD time to review them. Sacramento and San Diego were the first regions that had to submit housing element updates—in April 2021—followed by the remaining southern California jurisdictions, 2 which had to submit theirs in October 2021.
However, HCD did not release detailed guidelines for the AFFH requirement until April 2021, months after most municipalities had started their housing element update process and a week after some local governments’ final submission deadlines. Before these guidelines, HCD issued broad guidelines in 2020 and individual HCD staff provided guidance in an ad hoc manner to cities and consultants about AFFH requirements. Local government staff and their consultants often discuss their housing element update with HCD staff. Our interviews with planners and consultants suggested that advice about AFFH varied across HCD staffers. The delay in issuing formal guidelines presumably impacted how local governments conducted community engagement. Moreover, guidelines for participation are just that, guidelines, and do not require cities to conduct extensive outreach.
California Government Code 65583(c)(9) now requires local governments to make “a diligent effort to include public participation from all economic segments of the community.” HCD defines a diligent effort as use of outreach activities that deploy a variety of methods, incorporate broad and proactive marketing (including targeted areas of need), and promote language access and accessibility for persons with disabilities (California Department of Housing and Community Development 2021). HCD's housing element public participation page adds that municipalities should present all information transparently, make it available on a project website and in meetings, and that city staff should take time to make the public understand critical information (California Department of Housing and Community Development n.d.).
Public Participation in Planning Processes
The AFFH rule explicitly encourages and implicitly depends on a successful public engagement process. Community members are expected to inform planners of fair housing issues, potential remedies, and their preferences for policy action.
The idea of public participation in planning encompasses a wide range of activities and degrees of potential influence on decisions. City planners did not routinely invite public participation until the late 1960s after movements for civil rights and against urban renewal and freeway construction forced planning processes to open up (Uddin and Alam 2022). Relatedly, Arnstein's seminal work (1969) clearly distinguishes public input from engagement, which implies redistributing power from those who hold it to those who do not. Revisiting Arnstein's article on its 50th anniversary, Schively Slotterback and Lauria (2019) outline how engagement depends on social interaction among participants to build social capital, having participants generate knowledge and solve problems together, and engage in an ongoing process rather than a meeting or one-time opinion poll.
Historically, few municipalities in California have conducted public engagement processes in the ideal manner envisioned by planning scholars (e.g., Quick and Feldman 2011). Nor does HCD's guidance on AFFH instruct them to do so, as the language in the AFFH advisory is more aligned with consultation as described by Arnstein (California Department of Housing and Community Development 2021).
Even assuming that municipalities agree with the ideals of inclusion in participation (Quick and Feldman 2011), in practice, participation efforts can fail to engage people for many reasons. Technical language, complicated processes, and uncertainty around the value of being involved can foster skepticism among community members toward the value of participation (Creighton 2005). Competing demands on people's time also limits participation in planning processes to certain groups. Recent empirical research (Einstein, Glick and Palmer 2019; Sahn 2024) shows that most public participation processes privilege the views of more affluent, older homeowners rather than the broad interests of a community.
The planning literature offers various approaches to ameliorating the limitations of municipal planning and public input processes, including the approach to outreach, information dissemination, and meeting format (Abbot 2020; Creighton 2005; Mandarano 2015). We consider these, as well as the handbook by Creighton (2005), a commonly used text in planning curricula, in developing our evaluation metrics in the Methodology section. Certainly, we know that the way cities conduct public processes matters.
This paper contributes to understanding the impact of mandates for public participation in diverse local contexts (Berke, Lyles and Smith 2014). Brody, Godschalk and Burby (2003) find that planning mandates increase attention to public participation, though effectiveness varies based on six principles: who administers the participation, whether and how clear its objectives are, the timing, the degree of targeting to specific groups, techniques for participation, and what information cities disseminate. Schively Slotterback (2008) also found mandates to be more successful depending on the timing of outreach and who was consulted. We provide new evidence on these questions.
Case Selection
One of the primary goals of AFFH is to create integrated and balanced neighborhoods. Given the role of land use planning in segregation (Lens and Monkkonen 2016) and the tendency of a vocal minority to dominate public participation (Einstein, Glick and Palmer 2019; Trounstine 2020), we hypothesize that more segregated places are likely to address the participation requirement of AFFH with more laxity than less segregated places. Thus, we selected case study cities that varied by their level of racial/ethnic segregation measured at two spatial scales: intrametropolitan and intramunicipal. We measure intrametropolitan segregation using the share of non-Hispanic White residents and intramunicipal segregation using a dissimilarity index for non-Hispanic White residents.
To compare somewhat similar cities that vary across levels of segregation and median household incomes, we focused on the municipalities in southern California with a population between 40,000 and 500,000 (108 municipalities out of 218). We ranked them along the two dimensions of segregation, and then selected two municipalities from each of four groups (high-high, high-low, low-high, and low-low).
We selected the pairs of cities in each group by the expected difficulty in updating their housing element, one high difficulty and one low difficulty. We measured this challenge using a ratio between the number of housing units the city has to accommodate in their 2021 Housing Element and the number of housing units for which they stated they have capacity in their 2014 Housing Element. The higher this ratio, the more rezoning a city will likely need to undertake to meet its statutory obligations. For example, the city of Chula Vista reported a capacity for over 24,000 new units in its 2014 housing element, and in preparation for the 2021 update the state required its plan to accommodate only 11,000 new units. Thus, the city would be able to meet this target without making any changes to its land use plan. Downey, on the other hand, was required to accommodate over 6,500 new units in its 2021 plan, and in 2014, it had reported a capacity for only 1,400.
Figure 1 is a map of our case study cities’ locations. Figure 2 shows how the 108 medium-sized southern California municipalities score on these two measures, and where our case studies lie on this metric. We provide segregation scores and additional descriptive characteristics of our case study municipalities in Table 1 in Appendix A.

Location of case study cities in southern California.

Regional and internal segregation measures for southern California cities. Source. Authors with U.S. Bureau of the Census (2021).
As a result of our selection strategy, the case study municipalities vary in terms of segregation by race/ethnicity, median household incomes, location in the region, and their reputation for political antipathy toward housing. Huntington Beach, for example, is notorious for rejecting state intervention in local affairs (Stahl 2019), whereas Santa Monica has a progressive constituency that should be more inclined to embrace an AFFH mandate (Clavel 2011). A final advantage of this sample is that we can connect this study of participation to a recent evaluation of the quality of AFFH programs in these cities (Monkkonen, Barrall and Echavarria 2024).
The study's focus is on southern California because of the shared regional timeline in housing element updates. The regional timeline for southern California was earlier than other large urban regions in the state, such as the San Francisco Bay Area Region. 3 Although there could be some differences in how northern California cities conducted their public participation, the findings from southern California nonetheless reflect how the new AFFH state mandate informed public participation methods for the latest housing element cycle in half of the state.
Methodology for Assessing the Housing Element Update Process
We develop our evaluation of public participation accessibility based on three principles: sufficiency of information, clarity of communication, and the inclusiveness of avenues for input. Two necessary conditions for effective public input are the clear communication of sufficient information (Creighton 2005; Laurian 2003) and avenues for public input that are open to all members of a community (Brody, Godschalk and Burby 2003; Day 1997). We also consider whether municipalities use technology to enhance participation (Evans-Cowley and Hollander 2010).
Our evaluation of the accessibility of the housing element update process is divided into six dimensions: (1) the timeline, (2) outreach, (3) websites, (4) surveys, (5) meeting sufficiency, and (6) meeting inclusivity. For each dimension, we score each city from one (least inclusive) to five (most inclusive). This score is the average of subscores on several questions (between three and six) for each dimension. Two separate coders evaluated each dimension, discussed discrepancies, and averaged their results to arrive at the final score. We do not weigh questions when combining them for summary scores, as we have no basis for weighting some more than others. We recognize that assigning the equal weight is itself a weighting decision, and that a quantified evaluation of action has inherent subjectivity. Nonetheless, we have strived to be consistent and welcome future research that builds on this effort.
The data we used to evaluate the timeline, outreach, websites, surveys, and meeting sufficiency are municipal housing element websites, social media accounts, the public participation section of the housing element itself, and correspondence with HCD about the housing element. To evaluate public meeting inclusivity, we reviewed videos of public meetings.
Our analysis focuses only on what the city does, not on the level of community response or individual reactions to public meetings. Assessing the perspective of participants or potential relationships between the number of public comments and the accessibility of the public process was beyond the scope of this project (Brody 2003). This is a limitation as cities with more comments may have done a better job at facilitating participation or simply have residents more inclined or able to comment. For example, in their meetings, Simi Valley and Huntington Beach had roughly a dozen comments even though they did not have a highly accessible public process. Montebello, Santa Monica, and Fontana had less than 10, and Pasadena had 21.
Below, we discuss the literature used to develop our evaluation criteria, and the main questions that inform our scoring for each dimension of analysis. The protocols we developed are available in Appendix B. Appendix C presents the component scores and reasoning for each question for each city.
Timeline
Early, targeted meeting notices give stakeholders such as advocacy and neighborhood groups ample time to prepare for, promote, and participate in public meetings (Institute for Local Government 2007). Creighton (2005) also emphasizes the critical nature of how a public participation process is conducted. We combine the answers of six questions to score cities’ housing element participation timelines. Some examples of these questions are: Did the city make public outreach and materials (such as the draft housing element) available in a timely manner for residents to participate? Did the city schedule public meetings and other outreach early enough for project staff time to incorporate their feedback into the housing element?
Outreach
Municipal governments must communicate to residents what public process is occurring and how they can give their input. Best practice emphasizes the importance of outreach for reaching a diverse group of stakeholders, especially residents who do not typically participate in the planning process (Creighton 2005). Effective outreach uses local and multiethnic media (City of Seattle n.d.); online media such as email marketing, newsletters, and social media to reach younger and broader demographics (Fredericks and Foth 2013); and traditional media such as fliers, television ads, newspaper ads, and bulletin boards to connect to those with limited access to technology (Institute for Local Government 2007). Using an array of communication strategies may pull in stakeholders from different backgrounds and increase the number of perspectives (Bergstrom et al. 2014). Outreach also includes strategies such as focus groups, task forces, and partnerships with community organizations to solicit feedback from targeted stakeholders.
Our main evaluative questions for outreach are: Did the city use a variety of outreach methods to raise awareness and gather input from a diverse group of stakeholders? Did the city target outreach to residents of protected classes and the organizations that represent them? Are fliers, mailers, and other public announcements about the housing element clear and informative?
Websites
Project websites are now one of the most common ways to share information about planning processes and gather community input (Local Housing Solutions 2025). Project websites should communicate in a nontechnical manner to provide an understanding of existing conditions, the proposed plan or project, and the approval process (Abbot 2020). Our evaluation of housing element websites therefore considers five different questions related to whether the website provides sufficient information to learn about the process, requirements, and ways to get involved. Sufficiency is primarily about how much information is given about these different components of the process.
Surveys
The growing evidence that public comments are biased toward small segments of a population suggests that surveys, especially representative surveys, give a more accurate portrait of resident opinions and preferences. Input from different sources yields differing perspectives on projects (Brown and Eckold 2019), and surveys can be especially effective at obtaining the perspective of minority populations (Kashem and Gallo 2023).
We evaluated cities based on two main questions about their surveys. Did they disseminate a housing element survey outside of meetings to inquire about existing housing conditions and community members’ needs? Are the questions written clearly and related to fair housing?
Meeting Sufficiency
The primary venue for public input into planning processes is the public meeting, despite the fact that cities accept input through other means, for example, emails and letters. For the housing element update, project staff inform the community, answer questions, and solicit public comment in meetings. Therefore, to facilitate participation cities must hold a sufficient number of meetings, which in turn must be as accessible as possible.
The place and time planners hold meetings partly determine their accessibility (City of Seattle n.d.). If held on weekday evenings, attendance will be harder for people with children, people who work evenings, and those who rely on transit to travel. Conducting multiple meetings at different sites, times, and days of the week increases their accessibility (Creighton 2005). The constraints imposed by the COVID-19 pandemic demonstrated how, despite not being universally accessible, online community meetings open new avenues for participation (Afzalan and Muller 2018; Einstein et al. 2022).
Meeting sufficiency refers not only to how many meetings a city held but also the days, times, formats used (online or in-person), the locations, and whether the city also consulted specific stakeholders and community groups.
Meeting Inclusivity
The content of a public meeting can have substantial bearing on the success of the overall process since it is often a primary site for informing and collecting input (Creighton 2005). We evaluate four aspects of meetings: the presentation, facilitation, technology, and focus on AFFH. We assess accommodations like languages used, translation services, childcare, and food, which reduce the barriers to participation (Institute for Local Government 2007).
Experts recommend that presenters clearly describe the agenda, frame the topic of discussion, establish ground rules for participation, and explain how the city uses public input to inform decision-making (Local Housing Solutions 2025). Real-life accounts and plain language can ground abstract policy issues, especially content that informs participants of past and existing racial/ethnic and economic disparities, and increases transparency and participants’ abilities to address disparities in a plan (Bergstrom et al. 2014). Technology can enhance both the dissemination of information and collecting of input, and visual aids like graphs and maps help communicate ideas (Institute for Local Government 2007).
Facilitation refers to the way planners’ behavior promotes engagement, and a good facilitator encourages participation from all participants and validates participation by summarizing what a discussion, responding to questions, using engaged body language, and asking clarifying questions (Carp 2004; Institute for Local Government 2007). Staff can organize the public comment segment to facilitate participation, for example by dividing participants into small groups or by using polls to capture feedback from more respondents (City of Seattle n.d.). Lastly, planners can also create opportunities for community members to submit comments after the meeting, through a project voicemail or email (Institute for Local Government 2007).
The criteria and questions we use to assess these four aspects of public meeting inclusivity are:
Presentation materials: Did the presentation use clear language? Were presentation slides clearly designed and did they use effective graphs, images, and infographics to make it easy to understand housing concepts and challenges? Did the city offer the meeting presentation in relevant non-English languages? Technology: Did the municipalities’ use of technology facilitate or hinder the meeting's accessibility? Facilitation: Did the public comment period offer time to capture all participant comments? Were a variety of media available to share comments (e.g., video, phone, and chat)? Were all participants treated and integrated equally regardless of the medium they used? Focus on AFFH: How much of the meeting focused on AFFH?
Evaluating AFFH Programs
We match our evaluation of participation with two measures of plan quality described in detail in Monkkonen, Barrall and Echavarria (2024). That article assesses the potential impact of AFFH programs in these cities’ housing elements, evaluating their timelines, measurable objectives, and whether or not the program represents meaningful action. They rank programs as meaningful if they have high potential for impact based on their level of resource commitment, number of households assisted, and/or the degree to which they change policies to advance fair housing goals. The assessment produces numerical values for each program, based on potential impact, and summarizes program scores for each municipality.
Additionally, Monkkonen, Barrall and Echavarria (2024) calculate a Fair Housing Land Use Score (FHLUS) for each municipality's housing element sites inventory—parcels that the city has identified as available for housing development. The FHLUS quantifies the distribution of sites across neighborhoods ranked by median household income, to assess whether plans will advance the fair housing goal of integrated and balanced neighborhoods. The measure varies from −1 to +1, with lower scores indicating sites are more concentrated in lower-income neighborhoods.
We use these two measures to assess whether there is a correlation between inclusive public participation efforts and plan quality.
Results
This section synthesizes the findings, and Table 1 summarizes the overall assessment scores and components. Pasadena and Santa Monica had the most accessible public processes (scoring above four); Chula Vista, Downey, Fontana, and Huntington Beach scored between 3.1 and 3.7; and Montebello and Simi Valley scored poorly (below three). Again, Appendix C provides detail on each city's component scores.
Housing Element Update Process Evaluation.
Source. Authors.
We describe our evaluation of each component below, highlighting the highest and lowest scores in each category to illustrate the range of outcomes on participation.
Timeline
Most cities scored fair (between three and four) on their timeline. Santa Monica scored highest on the process timeline as it held its first meeting in 2019, months before any other city in our study and almost 2 years before the housing element was due. Montebello did poorly, hosting its first meeting only 5 months before the update was due to the state.
Figure 3 presents steps in timeline for seven of our case study cities. 4 We do observe a wide range in the timing of cities’ public engagement processes—Santa Monica held its first meeting in 2019 whereas Montebello did not start until mid-2021—as well as in how close the publication of the AFFH guidelines is to the deadline for housing element submittal.

Housing element timeline for case study cities. Source. Authors.
Several cities started the housing element discussion over a year before submissions were due. Yet they did not issue public notices in advance of meetings, or released draft housing elements with little time for residents to review and provide input. Fontana, for example, started their process in mid-2020, but released a draft housing element only a few days before the related meeting to discuss it. Huntington Beach also started the process early but did not give advance notice of meetings, and presented residents with a draft the same month it was due to HCD.
Outreach
The clarity, content, and diversity of outreach efforts varied to a small degree among cities, scores ranged between 3.1 and 4.2. Santa Monica and Pasadena scored the highest but still had some deficiencies. Montebello and Huntington Beach scored the lowest, although their outreach materials met the minimum expectations for content and clarity, using clear language in social media posts and providing information on the purpose of public meetings (City of Huntington Beach 2021a).
Other municipalities, including Fontana, had ample outreach materials, earning them a higher rating, but fell short of the top score due to their use of jargon. Fontana published fliers in two different formats and languages, and included housing element meeting information, a Zoom link and phone number, and staff contact information (City of Fontana 2021a; City of Fontana 2021b). The city also produced a flier that served as a useful FAQ (City of Fontana 2021c; City of Fontana 2021d), and a social media video that explained the importance of the process and how to get involved (City of Fontana 2020). The video effectively engaged the viewer and stood out in a social media feed.
Websites
The best housing element websites had a plethora of resources in multiple languages, including prerecorded presentations and recordings of meetings, background information about the process and context, and clear definitions of technical terms. Pasadena and Santa Monica scored highest in this category (4.7 and 5.0), and Huntington Beach and Simi Valley the lowest (1.8 and 1.2).
The least helpful websites are a single webpage each. The Simi Valley page, for example, has no materials aside from the draft housing element. The Montebello page hosts basic resources like the previous housing element, the new draft, meeting recordings, and presentation slides. However, the page is difficult to find—the only link to it is through the General Plan update website. Further, the webpage is not accessible to non-English speaking residents (City of Montebello n.d.) despite 71 percent of the city's residents speaking a language other than English at home (U.S. Bureau of the Census 2021). The Huntington Beach housing element site is several pages long, but lacks resources or background information. Meeting video recordings and presentation slides were available, but the site was rudimentary and unintuitive.
Surveys
Simi Valley and Montebello scored lowest on their surveys (1.0 and 2.5). Simi Valley did not conduct a survey, and Montebello's survey did not ask about community housing needs, nor did it ask about fair housing topics. We gave three cities—Chula Vista, Downey, and Pasadena—a five on their surveys because they used online questionnaires that combined multiple-choice, rating scale, and open-ended formats to inquire in multiple languages about the needs of senior citizens, displacement, homelessness, housing discrimination, and overcrowding.
Meeting Sufficiency
In terms of meeting sufficiency, Santa Monica, Huntington Beach, and Downey all scored high (fours and a five), whereas Simi Valley and Montebello scored low (1.5 and 2.3 respectively). Santa Monica hosted 27 meetings in total, including three meetings for the general public. The city convened two working groups, one focused on housing stability and the other on housing production. On the other hand, Huntington Beach and Downey only hosted four meetings, two in English and two in Spanish. Downey engaged with technical stakeholders from the Los Angeles chapter of the Urban Land Institute to discuss policy and zoning with the development community. Huntington Beach hosted an in-person meeting when COVID-19 cases were declining as a way to engage their Spanish-speaking residents (City of Huntington Beach 2021b).
Neither Simi Valley nor Montebello held meetings for the general public, they only met with groups of specific stakeholders. Staff gave residents space to comment at these meetings, but no meetings were aimed at a nontechnical audience. Montebello updated its General Plan in tandem with the housing element and held an in-person vision charrette that included a discussion of the housing element), also on a weekday evening. Neither municipality accommodated Spanish-speaking residents, especially striking in Montebello where 71 percent of residents speak a language other than English at home (U.S. Bureau of the Census 2021). 5
Meeting Inclusivity
Table 2 summarizes the scores for the four measures of meeting inclusivity. Overall, Pasadena and Fontana scored the highest, above a four, and the others above a three.
Meeting Quality Evaluation.
Source. Authors.
Note. AFFH = Affirmatively Furthering Fair Housing.
Technology
The COVID-19 pandemic led many municipalities to hold meetings online, meaning the deployment of technology shaped the quality of participation. Pasadena, Fontana, and Simi Valley offered multiple ways to participate in meetings, and scored the highest in this category. Fontana's meeting could be viewed on Zoom, cable television, and live on YouTube. Pasadena and Fontana also allowed participants to call in to online meetings. Pasadena and Simi Valley dedicated a small portion of their presentations to instructing participants on how to use the video conferencing functions (City of Pasadena 2021a), which may have helped less tech-savvy participants. Pasadena and Simi Valley each offered a separate meeting in Spanish.
Montebello, Santa Monica, Huntington Beach, Downey, and Chula Vista all had shortcomings that undermined access to meetings. Meetings in Montebello and Santa Monica were only available through online video streams, sharply limiting accessibility for those without appropriate technology. To improve accessibility for online meetings, Huntington Beach and Santa Monica provided a presentation slide that instructed participants on how to use the video platform. No technical difficulties occurred during the Montebello or Santa Monica meetings.
Difficulties with online meeting software hindered the effectiveness of Huntington Beach's public meeting. The city used the same Zoom link for both the English and Spanish meeting, and after introductions, the facilitator asked English and Spanish participants to enter separate breakout rooms. Participants had difficulty entering the breakout room, delaying the meeting by several minutes (City of Huntington Beach 2021c, 6:30–12:22). Additionally, late participants for the English-language meeting joined the Spanish meeting, interrupting it until the host could reassign them.
Presentation
All municipalities scored fair or above on their meeting presentations. Pasadena scored highest because they hosted well-organized meetings with attention given to Spanish speakers. They used clean, straightforward slide designs and visuals that effectively communicated complex housing concepts and challenges. Simi Valley and Huntington Beach scored lowest. Although they hosted well-organized meetings with simple and well-organized slides, designs, and visuals, their presentations included planning jargon and gave AFFH only minimal consideration. Simi Valley provided no accommodations for Spanish-speaking residents (City of Simi Valley 2021).
Facilitation
Facilitators performed well, soliciting questions in a respectful manner and creating an environment conducive to participation, and all cities scored relatively high in this area. Pasadena scored highest because the facilitator encouraged participation, allowed ample time to record all public comments, and gave multiple ways for attendees to engage in the meeting. Santa Monica scored lowest. The five facilitators had a neutral, professional demeanor, yet they only addressed a few public comments and provided just one way to participate in the meeting: submitting comments through the Q&A function of the webinar. Attendees could not see the questions, so it was unclear whether staff addressed all questions or how they selected questions.
Focus on AFFH
Several cities (Santa Monica, Montebello, and Pasadena) dedicated a substantial amount of meeting time to AFFH, including either several slides and/or a quarter of the meeting's time. Pasadena's presentation, for example, discussed AFFH concepts and goals multiple times. Of the three questions guiding the meeting, the third focused on where new housing should be located and how to provide housing opportunities for individuals with disabilities and members of protected classes (City of Pasadena 2021b).
Huntington Beach and Simi Valley scored lower because they discussed AFFH very little. For example, in their first meeting Huntington Beach staff did not mention AFFH at all, though they discussed some AFFH concepts obliquely (City of Huntington Beach 2021d, 6:40). In a later meeting, staff dedicated only one presentation slide to AFFH (City of Huntington Beach 2021e, 46:53–48:14).
Connection Between Participation and Plans
Table 3 reports the summary of participation alongside findings from research on AFFH programs and land use plans (Monkkonen, Barrall and Echavarria 2024) for an overlapping set of municipalities. The table shows suggestive evidence that municipalities with a better participation process also developed more meaningful AFFH programs. The two municipalities with the lowest participation scores—Montebello and Simi Valley—had low program scores, whereas the municipalities with the highest participation scores—Pasadena and Santa Monica—had among the highest program scores.
Evaluation of Process, Programs, and Land Use Plans.
Source. Authors, Monkkonen, Barrall and Echavarria (2024).
Notes. Overall process score is from Table 1. The summary program score is from Monkkonen, Barrall and Echavarria (2024) and reflects the potential impact of the AFFH programs. The FHLUS is from Monkkonen, Barrall and Echavarria (2024) and measures the concentration of housing element sites in a city's lower-income neighborhoods (a lower score is more concentrated).
AFFH = Affirmatively Furthering Fair Housing.
It is unclear what the effect of the public engagement was on the programs, however, and likely that some of this observed relationship stems from these being cities with greater planning capacity and the political will to commit to both effective outreach and engagement, as well as to develop strong housing programs. Moreover, both high-scoring cities had a negative and low FHLUS, meaning that their land use plans will concentrate future low-income housing development in their lower-income neighborhoods. These findings show the need for continued research on the role of participation in plan development.
Finally, we note that there is no observable association between cities’ incomes nor their demographic makeup and the accessibility of the housing element update process. Among the eight cities we study, those with more homeowners tended to have less accessible processes, and larger cities had more accessible processes. The sample size is too small to draw conclusions about correlations, but the lack thereof merits further research. Moreover, given that public processes may be associated with the government's capacity and population size, our sample of medium-sized cities is not ideal to test this hypothesis.
Discussion
Public conversations about neighborhood change can be challenging, especially when focused on the legacy of land use policies that segregated cities in the first place. Current zoning in most cities is incompatible with fair housing goals of fostering inclusive communities with creating integrated and balanced neighborhoods as cities often prioritize protecting residential neighborhoods, that is, single-family neighborhoods, from urban growth. Histories of racism in land use planning raise difficult questions about who is responsible for their redress, to what extent, and in what ways. An accessible planning process that requires public discussion of these topics is laudable, but it does not guarantee positive outcomes.
We find a wide range of participation outcomes in our eight case studies, which we sort into three groups. The first group (Simi Valley, Huntington Beach, and Montebello) is demographically diverse from one another, but all did a poor job at creating a creating an inclusive participation process. The second group (Fontana, Downey, and Chula Vista) complied with the mandate of public participation unevenly across the six dimensions we evaluated—doing some things well and others poorly. The third group (Pasadena and Santa Monica) performed well in their efforts to engage residents and the broader community to analyze, discuss, and address fair housing problems.
Simi Valley and Huntington Beach are cities with characteristics of exclusionary suburbs—majority non-Hispanic White populations in a region that is only 30 percent non-Hispanic White (Southern California Association of Governments 2022). These two cases illustrate how cities can fulfill the public participation requirement with minimal efforts at inclusiveness. Simi Valley ignored many basic elements into which other cities put substantial resources, whereas Huntington Beach has vigorously opposed the changes AFFH implies (Szabo 2021, 2024). Both cities had relatively vocal residents who opposed changes required by the state government. In these two cases, the participation component did not advance AFFH goals. Simi Valley's housing element was finally certified by HCD in May 2023, almost 2 years past the deadline. Worse still, Huntington Beach now has a compliant housing element, but the city council has not adopted it. The city has earned notoriety through multiple lawsuits against the state over housing. On the other hand, Montebello, a majority-renter city with high poverty rates and few non-Hispanic White residents, also had inaccessible public participation, in large part because of resource constraints.
Downey, Fontana, and Chula Vista conducted some aspects of the participation successfully but several others unsuccessfully. For example, Fontana had strong outreach but did not release a draft housing element until shortly before the public meeting, giving community members limited time to review it. Chula Vista and Downey had good surveys, but their meetings were less accessible than other cities.
Finally, the local governments of Pasadena and Santa Monica committed substantial resources to robust public participation in their housing element update, with a focus on AFFH. In these cities, the combination of government effort and active participation represents what might be an ideal outcome under the current AFFH guidelines.
Conclusion and Recommendations
The mandate to include AFFH in California's housing element update has potential to advance fair housing goals because of the role land use planning has had in creating and maintaining segregation. This paper evaluated public engagement in the housing element update process vis-à-vis fair housing. We found that both affluent and low-income municipalities can have deficient and inaccessible processes, and that some affluent and segregated cities are committed to running an accessible public process.
Our analysis of municipal response to the AFFH requirement yields recommendations for state and federal implementing agencies in four broad areas, recommendations that would both make participation more inclusive and make the job of local planning staff and HCD reviewers easier.
First, HCD should clarify what constitutes a “diligent effort” at soliciting public input. Current guidelines (California Department of Housing and Community Development 2021) provide some suggestions but there is room for improvement. A mandated participation timeline, for example, would clarify when cities should host meetings in order to provide sufficient time for input on each step in the housing element process. The state should advise cities on what information attendees should receive and when attendees should answer specific questions.
Second, implementing state and federal agencies should provide more assistance to local governments with educational materials. Requiring each local government to prepare presentations and explanations for planning concepts and processes is wasteful and inequitable for smaller cities. Standardizing the process will not only prevent some cities from performing poorly but also save them time and money.
Third, and perhaps most importantly, higher levels of government—the states or regional councils of government—should fund representative surveys to inform analyses of fair housing. Without representative surveys, public input will continue to suffer from the overrepresentation of affluent homeowners. Statistically representative surveys can be costly but state and federal government can fund them and make the results public.
Finally, state and federal agencies should provide additional resources to lower-income municipalities. The case of Montebello suggests that some cities would have more accessible processes with additional resources. In fact, a third party could achieve economies of scale by running standardized public meetings for a large number of municipalities, rather than asking every local government to create their own process or hire their own consultant.
The procedural logic of self-assessment to achieve local fair housing reform faces a fundamental challenge: exclusionary suburbs may be unwilling to voluntarily change land use and local housing policy. The state (and federal) mandate does not create binding minimal expectations for goals, nor do they establish the methods for cities to achieve them. In many municipalities, some members of the public oppose fair housing. Without clear expectations, therefore, public participation is unlikely to produce positive changes in most cities. Nonetheless, the performance of cities with more accessible processes—particularly Santa Monica and Pasadena—does suggest that the state can support better processes and outcomes in places with willing community members.
Supplemental Material
sj-docx-1-uar-10.1177_10780874251362716 - Supplemental material for A Weak Link in Efforts to Affirmatively Furthering Fair Housing? Evaluating Public Engagement Processes in Housing Plan Development in Southern California
Supplemental material, sj-docx-1-uar-10.1177_10780874251362716 for A Weak Link in Efforts to Affirmatively Furthering Fair Housing? Evaluating Public Engagement Processes in Housing Plan Development in Southern California by Paavo Monkkonen, Erik Felix, Shane Phillips, Moira O’Neill and Michael Lens in Urban Affairs Review
Footnotes
Acknowledgments
We appreciate the Robert Wood Johnson Foundation for their generous support of this research project, the many planning staff and consultants from the eight case study cities for their time and cooperation with this research, anonymous reviewers for the suggested revisions, and Claudia Bustamante for creating the timeline in
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Declaration of Conflicting Interests
The authors declared no potential conflicts of interest with respect to the research, authorship, and/or publication of this article.
Funding
The authors disclosed receipt of the following financial support for the research, authorship, and/or publication of this article: This work was supported by the Robert Wood Johnson Foundation.
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