THE REGIONAL HOUSING NEEDS ASSESSMENT MEETING
On Monday, the Intergovernmental meeting for the Regional Housing Needs Assessment (RHNA) occurred in Mountain Village. A company called EPS was hired to perform the study, which is now required under state law as a pre-condition for the state to provide any assistance for affordable housing. The essential point of the study is to make an informed determination of the “housing gap” in each region. Put plainly, the housing gap is the number of units needed to bridge the gap between present housing units available and the projected current and future needs.
THE COMEDY OF “ERRORS”
Let’s start with some unfortunate logistical snafus during Monday’s meeting. For those of you who tried to log on via Zoom, the link provided by the Town of Mountain Village (that we passed along) was incorrect.
To make matters worse, because other technical issues delayed the start of the meeting, the meeting ended with no public comment allowed. Because of this, the public missed out on expressing themselves, and our local leaders missed out on hearing ideas and thoughts from a very engaged, informed, and experienced public in a live, interactive forum. These comments could have led to a better discussion of the subject matter.
The organizers also did not make an information packet available before the session for the public or our local decision-makers. The absence of a packet presented a significant barrier to running a productive work session.
THE BIG (AND RELEVANT) PICTURE
While holding a work session without providing materials is a flawed methodology, the silver lining is that we were able to more quickly understand the essence and higher-level meaning of the complex data presented. As such, we provide some of our high-level observations and commentary from the cheap seats of the meeting.
EPS presented its conclusion for the housing gap using two different methodologies. The first method followed the methodology of the 2018 RHNA, the last regional housing assessment done for the area. The second methodology followed the procedures and criteria outlined by a recently passed bill at the Colorado State level, SB24-174, a bill that EPS acknowledged it had a hand in crafting and an interesting fact we leave open for you all to interpret. The table below summarizes these bottom-line housing gap numbers, with an additional implication for each.
|
By 2033 |
By 2033 |
|
| EPS Projected Housing Gap 1 |
888
|
1,114
|
| # People Added to Population 2,4 |
2,664 people |
3,342 people |
| 2025 County Population 3 |
7,981 people |
7,981 people |
| % Increase in County Population 4 |
~33% increase in population |
~42% increase in population |
| Average Population Increase Per Year 4 |
333 people |
418 people |
| 1 From 2/10/25 EPS presentation.
2 Land Use Code §6: “Population Density”: 3 people per unit w/ floor area between 900 & 1,500sf.3 2025 County population estimate, per Colorado DOLA State Demography Office 4 Added population figures are ONLY for the subsidized housing population, not the TOTAL population. |
||
According to EPS’s calculations:
- To keep up with the demand for subsidized housing, we must increase our available subsidized housing stock by between 888 and 1,114 units by 2033.
- By extension, we will increase our population by between 2,664 and 3,342 people by 2033. Importantly, this is just the increase due to people moving to town to live in subsidized housing, not the total population increase.
- This represents an increase in County population between 333 and 418 people per year, again just an increase due to people moving to the area and living in subsidized housing.
In stark contrast to the numbers presented above, the recently completed San Miguel County East End Master Plan states that “…population growth within the County is estimated to total 435 people between 2022 and 2027”. This represents a growth of approximately 87 people per year. Compare this to 418 people per year EPS is suggesting, and you see the EPS implications to be ~480% greater (not a typo) than the figures projected by the State Demography Office – figures recently accepted and published by the County themselves. And, yet again, EPS’s figures are just for people moving into subsidized housing and do not include anyone moving to the area renting or living in free market units.
WANTS vs. NEEDS
Without a packet, a draft study, or even raw data to analyze, it is not feasible to dive deeply into a data-critical analysis of the EPS reporting. With many qualified people in this community to do so, we can almost promise that a deep dive will be forthcoming. However, even without, some statements and reactions to questions by EPS were observed that likely provide a telling story.
However, the big red flag immediately appears to be the language used in the housing survey prepared and sent by EPS. The survey asked whether the person(s) surveyed would want a house in the region “…if they could afford it”? If you were to ask almost anyone in the working class if they wanted, say, a daily massage, a live-in chef, a private jet, a house on Kauai….or yes, a home in the Telluride region “if they could afford it,” what kind of answers would you likely get? The hypothetical, leading, and downright absurd question on which the EPS survey is based leads to absurd results and telegraphs that EPS has created a housing “wants” assessment, not a housing “needs” assessment.
DEMAND vs. QUALIFIED DEMAND
EPS also did not analyze the qualifications of those surveyed for housing needs (whoops, “wants”). Again, this wants assessment does not consider “qualified demand,” meaning of those polled, how many were financially qualified to occupy the subsidized housing built to accommodate them?
- For renters, how many could afford rent and endure lease terms?
- For buyers, how many could afford the debt load of a new purchase? Stated differently, how many could qualify (and afford) a loan, whether simply the down payment, principal, interest, and mortgage insurance associated with a loan, not to mention all the expenses related to homeownership?
While anecdotal, those of you who have paid attention to the vacant units that exist in our present-day inventory of subsidized housing are witnessing this disconnect between “wants” and “qualified needs” or “qualified demand” – our words and no one else’s. In fact, we recently heard Town Council persons reasonably frustrated by the fact that two units in the Voo Doo subsidized housing project remained vacant five months after the project’s completion. Notably, this project was built exclusively during the present housing “crisis” – their words and not ours.
PUBLIC POLICY
Regarding studies like this RHNA, one might easily be distracted by the data presented and lose sight of the forest for the trees.
The question is whether it is inevitable that we accept the type of growth figures it suggests. Is it appropriate to formulate public policy and start the planning process of building 1,114 units immediately, simply because we spent what is assumed to be a considerable amount on an EPS study that says “keep building”?
- The folks in the “housing at all costs” camp will answer yes.
- The critical thinkers, folks with vast experiential knowledge, true environmentalists, and valuers of resort town quality of life will clearly say no.
At a minimum, to formulate public policy on subsidized housing stock, we must have a housing-qualified needs assessment, not another “wants” assessment that steers us in the wrong direction or gets buried in a file for future reference.
…and…
We must have a publicly available, accurate inventory and understanding of existing and in-progress housing projects, as well as a thorough knowledge of the build-out for the remaining properties in the region without alteration to current zoning.
…and…
We must simultaneously diligently study traffic and road infrastructure, water supply and distribution, wastewater infrastructure and capacity, solid waste disposal, school capacity, healthcare access, air quality, coexistence with wildlife, and various other parameters and criteria that are lumped into this truly unique region’s “technical” carrying capacity.
…and…
Lastly, we must also take a hard look inward to determine what our “social” carrying capacity will look like. How will grocery shopping function and feel? How will short-distance daily commutes to work operate (i.e., traffic, an overlap between technical and social capacity)? How will running simple errands or grabbing a bite to eat function? What is our tolerance for noise and light pollution? How will the ski area function? Planning for the “normal” demographer to project population ebbs and flows is one thing. It is quite another to follow a housing “wants” assessment that encourages massive spikes in population…and expect the region to perform on the same level that we all enjoy.
STAY TUNED – MORE TO COME
Since it is acknowledged that the above is a commentary based solely on the presentations at Monday’s I.G. session, and without the benefit of a packet or study, clearly we need (there’s that word again!) to dive deeper into the data and text of EPS’s study to further analyze and comment on this important subject. We urge you all to first and foremost demand more than Cliff’s notes so we can all critically analyze this consequential study and write, speak, petition, or whatever it takes to get your voices heard.
As always, thanks for your engagement and for humoring this long read. If you have any questions or suggestions, please do not hesitate to contact us at info@lastdollarcollective.com.
