STATE OF CALIFORNIA - BUSINESS, CONSUMER SERVICES AND HOUSING AGENCY GAVIN NEWSOM, Governor
DEPARTMENT OF HOUSING AND COMMUNITY DEVELOPMENT
DIVISION OF HOUSING POLICY DEVELOPMENT
651 Bannon Street, Suite 400
Sacramento, CA 95811
(916) 263-2911 / FAX (916) 263-7453
www.hcd.ca.gov
March 18, 206
Elizabeth Oba, Director
Planning and Building Services
City of Bellflower
16600 Civic Center Dr
Bellflower, CA 90706
RE: City of Bellflower’s Housing Element Implementation – Corrective Action Letter
Dear Elizabeth Oba:
The California Department of Housing and Community Development (HCD) has reviewed the City of Bellflower’s (City) obligations under the housing element and hereby issues its written findings that the City has failed to implement Program 27 (Ensure Adequate Sites to Accommodate the RHNA) to rezone adequate sites to satisfy its Regional Housing Needs Allocation (RHNA) shortfall.1
Housing Element Law
HCD must review any action or failure to act by a City that it determines to be inconsistent with an adopted housing element or section 65583 generally, and it must issue written findings to the City accordingly.2 HCD must give the City a reasonable time, no longer than 30 days, to respond to these findings.3 If HCD does not receive a written response from the City within 30 days, or the response does not demonstrate that the program action has been implemented, then HCD will revoke its findings that the City’s housing element substantially complies with Housing Element Law.4
Additionally, HCD may notify the California Office of the Attorney General when a City takes actions that are inconsistent with an adopted housing element or Government Code sections 65583 and 65915, among other laws.5
1 Gov. Code, § 65583, subd. (c)(1)(A),§ 65583.2, subd. (h) and (i). 2 Gov. Code, § 65585, subd. (i)(1).
3 Gov. Code, § 65585, subd. (i)(1)(A).
4 Gov. Code, §65585, subd. (i)(1)(B).
5 Gov. Code, § 65585, subd. (j).
3-C
Elizabeth Oba, Director
Findings
On September 9, 2022, HCD found the City’s housing element in substantial compliance with housing element law. HCD based its finding of substantial compliance on, among other things, a commitment to implement Program 27. This program is committed to rezone adequate sites to satisfy its RHNA shortfall pursuant to Government code section 65583, subdivision (c)(1)(A).
On March 14, 2025, HCD sent the City a Letter of Inquiry requesting an update on the City’s progress implementing rezone actions on Program 27 The City responded on April 28, 2025 informing HCD that Program 27 had been completed according to the timeline established in the City’s housing element through Resolution No. 25-09 and Ordinance No. 1442. HCD met with City staff on July 23, 2025, and the City provided additional rezone documentation July 28, 2025.
On October 16, 2025, HCD sent the City a Letter of Technical Assistance informing the City that revisions to the submitted ordinances would be required to ensure that all sites are being rezoned to satisfy the City’s lower-income RHNA shortfall and thereby meet statutory requirements. The City responded to the Letter of Technical Assistance on December 18, 2025, stating that the HOOZ regulations, without further amendment, already satisfies housing element law. The City’s response demonstrates compliance with none of the requirements of state law enumerated in HCD’s October 16, 2025 letter.
Specifically, the City has not provided documentation that demonstrates that it permits owner-occupied and rental multifamily uses by-right for developments in which at least 20 percent or more of the units are affordable to lower income households on sites being rezoned to accommodate the lower income RHNA shortfall. The City has also failed to demonstrate that mixed-use rezone sites being used to accommodate the City’s lower-income RHNA shortfall permit 100 percent residential development and require a minimum of 50 percent of the square footage in a mixed-use development to be residential. Finally, the City has not shown that rezones sites to meet the lower- income RHNA shortfall meet the minimum density threshold of 20 dwelling units per acre as required in Government Code section 655893.2, subdivision (h).
Based upon the above reasoning, HCD finds that the City has failed to implement this program actions within the statutorily required timeframe.
Elizabeth Oba, Director
Next Steps
HCD requests that the City review this correspondence and provide a written response to these findings within 30 days and no later than April 17, 2026. HCD will review and consider the City’s written response before taking any action authorized by Government Code section 65585, subdivisions (i) and (j). As noted below, such action may include revoking HCD’s finding that City’s housing element is in substantial compliance with Housing Element Law and/or referral to the California Office of the Attorney General.
HCD provides the City until April 17, 2026 to provide a written response to these findings. If you have questions or need additional information, please contact Stephanie Chan of our staff at [email protected]
Sincerely,
Melinda Coy
Housing Accountability Unit Chief