City of Barstow 2021-2029 Housing Element
Quick Guide to Revisions Made in Response to HCD Comments on Previous Submittal
March 16, 2022 HCD Comments City Revisions / Responses
1a
Extremely Low-Income Households:
The element was generally not revised to
address this requirement and must still
analyze the housing needs of projected and
existing extremely low income households.
Please see HCD’s prior review for additional
data and information on this issue.
The City updated the housing needs for extremely lowincome (ELI) households throughout element.
Updates include:
- Appendix B, p. B-23, Analysis of overpayment,
overcrowding, and future need
- Housing Plan, p. 19, Adding quantified extremely
low income objectives for 2021-2029
1b
Housing Conditions:
The element now reports data on the housing
units in need of rehabilitation in addition to
identifying the age of the housing stock.
However, it must still estimate the number of
units in need of rehabilitation and in need of
replacement. For example, the analysis could
include information from a recent windshield
survey, estimates from code enforcement, or
information from other local organizations.
The City expanded discussion of housing conditions and
substandard housing throughout the element.
Updates include:
- Housing Plan, 19, adding quantified objectives for
housing rehabilitation for 2021-2029
- Appendix B, p. B-11 adding estimates of housing
condition and substandard housing
- Appendix D, p. D-54, adding information on
substandard housing
- Appendix D, p. D-68–73, adding contributing factors
and programs to address housing conditions
2a
Sites Inventory:
The element must identify and analyze sites
for fostering inclusive communities and
Affirmatively Furthering Fair Housing. The
element discusses identified sites for lowerincome households but should also discuss the number of units for all income groups,
evaluate the magnitude of the impact,
describe any isolation of the sites that
address the RHNA and address whether sites
improve/ exacerbate each fair housing issue.
The City updated Appendix E, Sites Analysis and Inventory to revise sites, methodology, and fair housing implications.
Updates include:
- Appendix E, p. E-2 to E-3, adding planned and
entitled projects credited toward the RHNA
- Appendix E, p. E-4 to E-7, revising methodology for
site inventory to address the RHNA
- Appendix E, p. E-8 to E-10, revising sites to include only vacant sites and mapping their locations
- Appendix E, p. E-11 to E-14, addressing the fair
housing implication of sites re: segregation,
integration, isolation, and access to opportunity
2b
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2c
Local Data and Knowledge, and Other
Relevant Factors:
The element should incorporate local data
and knowledge of the city into the AFFH
section. To meet this requirement, the
element should provide local data not
captured in regional, state, or federal data.
The element must include other relevant
factors that contribute to fair housing issues
in the city. The element can analyze historical
land use and investment practices or other
information and demographic trends.
The City updated Appendix D to include local data and
knowledge and how it influences housing in Barstow.
Updates include:
- Appendix D, p. D-65 adding the results of a housing
survey issued after the housing element was
adopted to clarify key issues
- Appendix D, p. D-66-67, adding a discussion of
contemporary issues, including addressing
disparities in opportunity, resulting from the City’s
past decisions on growth and development.
City of Barstow 2021-2029 Housing Element
Quick Guide to Revisions Made in Response to HCD Comments on Previous Submittal
March 16, 2022 HCD Comments City Revisions / Responses
2d
Goals, Priorities, Metrics, and Milestones:
The element must be revised to add or
modify goals and actions based on the
outcomes of a complete analysis. Goals and
actions must specifically respond to the
analysis and to the identified and prioritized
contributing factors to fair housing issues and
must be significant and meaningful enough to
overcome identified patterns and trends.
Actions must have metrics and milestones as
appropriate and must address housing
mobility enhancement, new housing choices
and affordability in high opportunity areas,
place-based strategies for community
preservation and revitalization and
displacement protection.
The City revised Appendix D and the Housing Plan to
include additional goals and actions to reflect the local priorities related to fair housing issues.
Updates include:
- Appendix D, p. D-68-D-70, Set forth five new
contributing factors based on revised work.
- Appendix D, p. D-71-72, prepared a fair housing
matrix documenting factors, issues, programs,
geographical areas, metrics, and timetable.
- Appendix D, p. D-73, included a map of some of the
key improvements planned for the City
- Housing Plan, p. 7, adding Program #5 to reduce
disparities in economic development
- Housing Plan, p. 14, adding Program #16 to address
focused capital improvement planning
- Housing Plan, p. 15, adding Program #19 to improve
environmental and community health
- Housing Plan, p. 16, adding Program #20 to explore
temporary and permanent workforce housing
3a
Processing and Permit Procedures:
The element mentions a Site Plan Review
where projects are reviewed to determine
the type of approval (e.g., ministerial, staff
review and Planning Commission review
through public hearing). However, the
element does still not fully address this
requirement. While the element should also
describe procedures for a typical single family
and multifamily project. The analysis should
address the approval body, number of public
hearings, approval findings, and any other
relevant information. The element should add
or modify programs, as appropriate, based on
the outcomes of a complete analysis to
address constraints. Please see HCD’s prior
review for information.
The City updated Appendix C to include information on
local permitting practices, steps, and timelines.
Updates include:
- Appendix D, p. C-18 and C-19, clarifying the project
application review process, site plan review, design
review, approval findings, and timeframes
- Appendix D, p. C-19, clarifying the typical process
and timeframe required for a single-family and
multiple-family project including reviewing body
- Housing Plan, p. 6, includes action item to create
objective design standards in Program #4
- Housing Plan, p. 15, contains action to annually
evaluate review process to ensure timeliness as
stated in Program #17
3b
Housing for Persons with Disabilities:
The element now further describes why a
conditional use permit (CUP) is required for
group homes for seven or more persons but
generally was not revised to evaluate the CUP
as a constraint on housing for persons with
disabilities. Further, the element must still
address the exclusion of these uses from
several residential zones. The element should
The City updated Appendix C to include information on
local permitting practices, steps, and timelines.
Updates include:
- Appendix C, p. C-7, clarifying the need to correctly
define residential care facilities per state law.
- Appendix C, p. C-7, clarifying the findings required
for approving large residential care facilities
City of Barstow 2021-2029 Housing Element
Quick Guide to Revisions Made in Response to HCD Comments on Previous Submittal
March 16, 2022 HCD Comments City Revisions / Responses
evaluate the impacts of these requirements
and include programs to address identified
constraints, such as amending zoning to allow
these uses in all residential zones and replace
or revise CUP procedures to permit group
homes for seven or more persons with
objectivity to facilitate approval certainty.
- Housing Plan, Program #12 (p. 11-12) commits the
City to correctly define residential care facilities,
and allow in all residential zones per state law.
- Housing Plan, Program #12 (p. 11-12) commits to
conditionally allow large facilities in all zones that
allow housing but will evaluate and modify any
findings that serves as a constraint to ensure
objectivity and certainty in the approval process.
4 Beneficial Impact:
To have a beneficial impact in the planning
period and address housing element goals,
programs must be revised with discrete
timelines and specific commitment.
Specifically, Program 2 (Downtown Barstow)
should commit to how often (e.g., at least
annually and ongoing) the City will contact
developers.
The City has updated the programs, specifically Downtown Barstow (Program #2) specific commitments and time
frames to address this comment.
Updates include:
- Housing Plan, Program #2, p. 5, committing to
contact developers on an annual and ongoing basis
- Revised other housing programs as needed
5 Quantified Objectives:
The element now provides a summary of
quantified objectives for new construction;
however, it must also provide quantified
objectives for rehabilitation and conservation
by income group, including ELI households.
The City has updated the Housing Plan to include these
objectives. Updates include:
- Housing Plan, p.19, adding quantified objectives for
rehab and conservation by income group, including
ELI households. Reference included to Table D-5 for
objectives for fair housing
6 Diligent Effort at Outreach:
While the element lists the programs that
were added or modified following workshops,
online surveys, and meetings (Appendix F), it
still should summarize public comments,
including future comments and describe how
comments were considered and incorporated
into the element. Further, moving forward,
the City should employ additional methods
for public outreach efforts in the future,
particularly to include lower-income and
special needs households and neighborhoods
with higher concentrations of lower-income
households.
Appendix F, Stakeholder Engagement, was significantly
expanded to include additional public engagement efforts and show how the results are incorporated into the update.
Examples of updates include:
- Comments raised at the October 2021 adoption
hearing for the element, additional public outreach
done after HCD’s last element review, and revisions
made (beyond state law compliance) as a result of
comments from the additional public outreach