Residents and a regional housing group opposed a Pasadena proposal to require affordable units in buildings as small as five apartments at a Planning Commission hearing Wednesday, Sept. 9.

City staff recommends lowering the threshold for the Inclusionary Housing Ordinance (IHO) from 10 units to five. Developers of projects with five to nine units would have to set aside one unit at a moderate-income price. The existing 20% affordable requirement for projects of 10 or more units would stay in place.

Opponents say the math doesn't work.

Only 38 units in buildings of that size were built citywide between 2019 and 2025, according to a staff report prepared by Jason Mikaelian, acting director of planning and community development. That averages fewer than seven units per year. The same report estimated that had the lower threshold been in place, 17 additional affordable units would have been required across 17 approved projects since 2020.

Abundant Housing LA, a Los Angeles-based advocacy organization, submitted a formal letter urging the commission to reject the change. Executive Director Azeen Khanmalek warned in the letter that the rule could backfire, stifling the small-scale "missing middle" housing Pasadena already struggles to produce.

"Twenty percent of zero is zero," wrote Pasadena resident Thomas Tai in a separate comment letter.

Michael Canavan, a District 6 resident, argued in his own letter that the policy could yield just one or two moderate-income units per year. Canavan noted that Pasadena still needs 1,283 moderate-income units to meet its state-mandated Regional Housing Needs Assessment (RHNA) goals through 2029. He also pointed out that small rental projects don't qualify for a state density bonus based on moderate-income units alone, and that landlords would have to verify tenant incomes annually.

P.A. Brown, also from District 6, wrote in opposition on Tuesday, Sept. 8, calling the proposal counterproductive. Brown's letter calculated that the rule would have produced only six affordable units over six years, a figure lower than the staff report's 17-unit estimate, which counted approved projects rather than completed buildings.

The proposal originated with the city's Economic Development and Technology Committee (EdTech), which directed staff in October 2025 to explore the lower threshold after a feasibility study found no support for raising the current 20% requirement. Staff acknowledged in the report that a separate feasibility analysis for the lower threshold is still underway.

The hearing was a continuation from Aug. 12, when the item was opened but no testimony was taken. The commission's vote has not been confirmed as of publication.

The proposal still requires City Council approval. Staff said the feasibility analysis will be completed before the amendments reach the council, but no hearing date has been set.