Brentwood City Council
August 30, 2022

Table 2 – Vision for the Future
Affordable housing for all who want to live here, who are born and raised her and would like to remain here but can’t because either to expensive or not enough good / high paying jobs! Lower density, do not want a repeat of mistakes made in Pittsburg and then Antioch Affordable housing so people at all income levels can live in Brentwood. Higher density allowed to achieve this vision.

Affordable homes for the middle class that make $100k to $130k and save money and pay taxes but still can’t afford a home here in Brentwood
Cap construction at 75,000 homes, condos. There is a real need for improved external maintenance of yards, common areas (Garin Parkway from Balfour to 2nd street). Many yards are poorly maintained creating a blight in Brentwood
Walnut Creek with broad open plazas and a vibrant downtown with stores and restaurants Consistent growth while maintaining that small town feel.

I envision Brentwood being a safe happy community that is affordable for younger people to achieve the "American Dream".

Housing and infrastructure need to expand at the same time. Vasco is a significant artery for many commuters that live in Brentwood but must commute to higher-paying jobs. Rising commute times make it harder to stay in Brentwood. Pay for higher housing closer to work or commute 2 hours and miss out on time with your family and community.

Availability
More affordable housing.

Affordable housing market and less competitive
More mixed housing projects to promote diversity, equity and inclusion. Include affordable housing, senior housing, multigenerational housing, as well as housing for people with disabilities together for a better mix.

Affordable places to live. More business, like better restaurants, recreation.

I would like mixed use, mixed income neighborhoods that are designed to be walkable and not rely on driving so much, and which encourage community and connection rather than isolation and disconnection. I would like more accessible and affordable housing for people who work in Brentwood and young people who grew up here who can't afford to live here. Smaller entry level first time buyer homes for young families and more affordable rental housing. affordable housing programs for all
I see Brentwood maintaining the slow growth of housing, maintaining most of its agricultural spaces alive
Brentwood ha crecido mucho en los últimos años y pues ya se mira como una ciudad porque hay cada día mas casas y por lo consiguiente económicamente ha incrementado cada día más y eso significa que también contará con muchas fuentes de empleo
Affordable housing for every type of income and retirees!!! I see Brentwood as a city leading in housing homeless people in the smartest and sustainable way possible. A city where inequality is low.

That there will be equal housing for all
Affordable housing options
More Below market rate homes
I would like to see much mote mixed use housing in areas like downtown and the Streets of Brentwood
DRAFTsity allowed to sity allow
ney and pay taxes but ney and pay
roved external maintenance of ved external maintena
any yards are poorly maintained any yards are poorly maintaine with stores and restaurants with stFT
at is affordable for younger people to achieve at is affordable for younger same time. Vasco is a significant artery for man e. Vasco is a signi ommute to higher-paying jobs. Rising commute t paying jo r higher housing closer to work or commute 2 ho r higher housing closer to work ommunity. mmunity. AFT
d less competitive
cts to promote diversity, equity rsity, equity and inclusion. In nerational housing, as well as housing for people nerational housing, as well as hous RA to live. More business, like better restaurants, r to live. More business, like better rest mixed use, mixed income neighborhoods that are mixed use, mixed income neighborhoods tha o much, and which encourage community and c o much, and which encourage community and ection. I would like more accessible and affordab n. I would like more accessible and affordab twood and young people who grew up here who young people who grew up here who me buyer homes for young families and more aff for young f affordable housing programs for all affordable housing programs fRA D I see Brentwood maintaining the slow grow
aliveDR
Brentwood ha crecido mucho en los ú ecido mucho en los ú día mas casas y por lo consiguiente lo co
que también contará con much á con DR
Affordable housing for every Affordable housing for ev
I see Brentwood as a city I see Brentwood as a cit
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City of Brentwood
2023-2031 Housing Element Update

Table 2 – Vision for the Future
My vision includes the various types of housing identified above integrated in such a way that agriculture is viable
General note I don't know the definition of several categories mentioned above such as "fair housing " . I believe the terms have meaning to special interest growth at may be at odds to society at large.

Poder aceder a ellas ya que la gente que está comprado es de otros lados y los que vivimos a quw I por años no podemos debidos a Los Altos precios
Affordable housing rent and sale
The lack of affordable housing in the San Francisco Bay Area is one of the defining social issues of our time and place. According to recent US Census data, nearly one quarter of households in our Brentwood community pays more than half of their monthly income toward housing – far above a sustainable level. These individuals and families teeter at the precipice of homelessness, where one missed paycheck or unexpected expense could plunge them into instability that would affect every aspect of their lives and reverberate throughout the community.

A mixed-income model places priority on housing and serving low-income persons while integrating members of other socioeconomic groups. By bringing these populations together, housing is stabilized for middle and low-income persons. Vision: An inclusive mixed-income community that features low-income supportive housing, low-income senior housing, middle-income rental units, first time home buyer housing, and student housing complementing existing large single-family homes.

No more building without emergency services to support. No one is homeless! No more huge box-like apartments. Make apartments pleasant to look at and less like institutional buildings
We protect the available affordable housing and look for opportunities to add more that can be well maintained in areas that are properly zoned.

Well balanced to the community that SERVES US. "Work Here, Live Here". Equal opportunity for all regardless of status
More affordable housing available maybe multi family homes. Less unaffordable large single family homes. I am glad to see more apartments units are being built this year.

Housing availability to enable homeless to be taken off of the streets, or at least removed because Brentwood has housing available for them. Affordable senior living is a huge deal as well.

My fear is my adult kids will not be able to afford to live here, even with being highly educated and having good jobs. Brentwood is just too expensive, especially for single people. I'd like to see there be at least affordable rental homes/apartments/condos for this upcoming generation and future generations.

In placing high density housing consider placing it by services needed for that community such as groceries and transportation.

Juicy cultural and racial. Affordable or sub sized housing More family single story homes
Affordable housing!
Affordable housing especially condominiums and townhomes instead of continuing to build large homes on small lots.

As a single woman over age 65, I would like to see more affordable housing for purchase. It seems that most homes in this city are two-story dwellings. I would like to see a better selection of single story homes. We seem to be returning to a multi-generational lifestyle as we care for parents, or fordable hou
le wom DRsing e
My fear is my adult kids will not be able to afford fear is my adult kids will n having good jobs. Brentwood is just too expen having good jobs. Brentwood i be at least affordable rental homes/apartm be at least affordable rental home DRAFTh as "fair hous h as "fair to society at large. to socie
que vivimos a quw I que vivimoT
f the defining social issues of our f the defining social issues of o uarter of households in our uarter of
come toward housing come to – far above a
e precipice of homelessness, where one e precip
em into instability that would affect every em into instability that w ommunity. mmunity
and serving low ving low-income persons while integratin income per nging these populations together, housing is opulations tog s. Vision: An inclusive mixed ve mixed-income community low-income senior housing, middle-income rent
t housing complementing existing large single ousing complementing existing large s -fa T
cy services to support. No one is homeless! vices to support. No one is homeless! AF nts. Make apartments pleasant to look at and le apartments pleasant to look at and le affordable housing and look for opportunities to fordable housing and look for opportunities to at are properly zoned. at are properlyRA
e community that SERVES US. "Work Here, Live e community that SERVES US. "Wo tus
ble housing available maybe multi family homes ble housing available maybe multi family hom m glad to see more apartments units are being b
g availability to enable homeless to be taken off ability to enable homeless to be taken off ntwood has housing available for them. Affordab housing available for them. Affordab generations.DR
In placing high density housing consid ensity housing consid groceries and transportation. porta DR
Juicy cultural and racial. Afford Juicy cultural and racial.

More family single story ho More family single story
Affordable housing!
s on small lo
City of Brentwood
2023-2031 Housing Element Update

Table 2 – Vision for the Future
perhaps as adult children need to move back in with families. Floorplans to accommodate this lifestyle would probably be popular.

Equal housing for low and moderate income households
Safe and affordable
Please preserve the farms for the next generation.
affordable, well-planned, planting of many trees
Provide housing of all types only if the streets and service sector can sustain them. For example, if you plan to build housing of any type in north east part of town, then Lone Tree needs to expand from Fairview to Brentwood Blvd. and not in piecemeal fashion.

We need lots of housing. Let’s use every inch of open space to get people into homes they can afford.

Using infill to create a dense urban area with large greenspace and convenient public transit for intown and out-of-town access

A BEAUITIFUL WORLD
affordable homes where a family income of over 100k a year can still afford to buy a home in Brentwood.

In order to maintain a livable community, it is important to provide services for seniors who may have disabilities, as Bentwood has a history which is founded on the young people who could afford to buy where they grew up in past generations and who now wish to remain comfortably as they age and disabilities arise for them. Brentwood also needs to make room for those with disabilities who prefer the agriculture and history that Brentwood offers in a Family-centered community. Affordable housing for first-time buyers sustains the latter two visions for the next century.

More affordable housing for seniors. The opportunity to buy lot mobile house is on.

I think you should build more affordable housing. I think you should build up and it should be mixed housing, with some subsidized and some affordable. People with disabilities need special help. I suppose they would be happy in multi-story buildings with elevators. Parks and transportation also super important to be in the mix.

More schools for the ever growing community and families that will be our future Less new building that is expanding on agricultural land without first improving expansion of new business and road improvements.

AFFORDABLE housing especially for
Seniors and disabled
Bedroom community with viable resources and amenities supporting the city.

Better services for farmworkers with more protections for the farmworker vs the farmer.

More affordable housing. Continued maintenance of parks. Maintain balance of housing and open space.

Get away from McMansions and provide units that are reasonable in size - nothing over 2000 sq feet.

Better than this bedroom community drowning in oversized, cookie cutter houses that nobody but implants can afford
We need more low income housing
I envision Brentwood’s housing providing affordable housing for families and singles. affordable with a fair mix of open space, farms, single family, apts and condos. special emphasis on services for 65 + and veterans.

Future housing in Brentwood should be fair and affordable for residents already living here, along with those looking to move to this area.

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00k a year can still afford to buy a home in ear can still afford to important to provide services for seniors who m ide servi ch is founded on the young people who could af ch is founded on the young peopl s and who now wish to remain comfortably as th and who now wish to remain comforta od also needs to make room for those with disab o needs to make room for those with dis rentwood offers in a Family offers in a Family-centered communit ustains the latter two visions for the next centur ter two visions for the next cent AF or seniors. The opportunity to buy lot mobile hou ortunity to buy lot mobile hou RA more affordable housing. I think you should bui more affordable housing. I think y subsidized and some affordable. People with dis subsidized and some affordable. Pe uld be happy in multi-story buildings with elevat ngs w nt to be in the mix. nt to be RA
ols for the ever growing community and families ols for the ever growing community and familie w building that is expanding on agricultural land ding that is expanding on agricultural land ness and road improvements. ad improvements
FFORDABLE housing especially for RDABLE housing especia Seniors and disabled Seniors and disaDR
Bedroom community with viable resources Bedroom community with viable r Better services for farmworkers with mo Better services for farmworkers with DR More affordable housing. Continued housing. Continued
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City of Brentwood
2023-2031 Housing Element Update

Table 2 – Vision for the Future
No overcrowding. Condos which provide affordable home ownership Less housing Until emergency services can be caught up to national standards. No more new housing until the fire department and emergency services can respond inner efficient manner. smart, well rounded growth.

Improved infrastructure to support that growth.

Mostly single family homes, with increased condo and apartment opportunities Smaller homes, walk-able.

There has been more than enough single family homes built in town over the last 20 years. I have yet to see any single family home projects not allowed even on irreplaceable farmland; it seems like every single open space is being built on. We need infill building of apts for low income & younger people.

Please, do not forget our teachers! Currently a teacher on a single income canNOT afford to buy a house in Brentwood. People move to Brentwood also because of our great schools and incredible teachers. It is a shame that with the current state of things teachers might be pushed to live outside of the great city of Brentwood.

KEEP OUR FARMLANDS, ORCHARDS, AND AGRICULTURE STRONG. THIS GIVES BRENTWOOD IT'S VALUE!
A home where I can continue to raise my kids. At this rate it’s too expensive for young families we need more affordable housing to make Brentwood more diverse Not putting too many homes in one area and building more schools More smaller homes like condos or townhomes.

I have teenager, and I want them to be able to afford to buy a house or condo in the future.

Please only build the absolute minimum number of houses required to fulfill state demands, until such time as the state returns control of housing decisions to the city.

My Vision of Brentwood with regards to housing is hopeful but only if we’re able to get people into city council and on boards and commissions to get the right kind of developers and builders in our city to build enough housing to satisfy the demand
Higher concentration of multi family housing downtown to bring greater vitality and viability to the area
I’d like Brentwood to continue to be a place where teachers and firefighters and single income families can find housing and live where they work. I’d like my kids to be able to come back here after college and be able to get an apartment. This isn’t happening anymore.

A nice mix of houses and condos for all income levels.

High tech city with access to BART
Brentwood needs to maintain its charm and a small town feel - a town that is safe and family friendly where our children should be able to ride bikes and walk home without adult supervision when they are old enough. Home prices should not be impacted by bringing in mixed house. For these $1M+ homes we pay quite a bit of taxes to have that environment.

More mixed use types, condos, SFH. Basically any housing Please keep low income housing out of Brentwood. We moved away from the Bay Area because of the crime that came with it in our neighborhoods and schools. Thank you Less building overall. More focus on town cleanliness and emergency response time.

Brentwood is a safe bedroom community with senor citizens and large families. Brentwood has an excellent police department, offers plenty of parks to the residents, provides an excellent vision for the future, and needs to remain in this condition going forward. The City needs to be smart in how it DRAem to be able to afford to buy a house or condo to afford to buy a house or cond AFTew es
ver the last 20 years. I have yet e last 20 years. I have eable farmland; it seems like every eable farmland; it seems like eve s for low income & younger people.
ngs teachers might be pushed ngs teachers might be push use of our great schools and incredible use of our great schoo ngle income canNOT afford to buy a
to live outside TF
ULTURE STRONG. THIS GIVES BRENTWOOD IT'S RONG. THIS GIVE T AF ds. At this rate it’s too expensive for young fami ds. At this rate it’s too expensiv Brentwood more diverse Brentwood m AF
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ute minimum number of houses required to fulf ber of houses required to fulf eturns control of housing decisions to the city. eturns control of housing decisions RA ood with regards to housing is hopeful but only i ood with regards to housing is hop n boards and commissions to get the right kind o n boards and commissions to get the r h housing to satisfy the demand h housing to satisfy the dRA centration of multi family housing downtown to entration of multi family housing downtown to e Brentwood to continue to be a place where te ood to continue to be a place where te milies can find housing and live where they work ousing and l college and be able to get an apartment. This is college and be able to get an a A nice mix of houses and condos for all inco A nice mix of houses and condosRD High tech city with access to BART
Brentwood needs to maintain its char s to maintain its char where our children should be able shou
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City of Brentwood
2023-2031 Housing Element Update

Table 2 – Vision for the Future
deploys these state mandates where it will be a win win for the current residents and allow the City to meet these requirements without the residents seeing any difference from today's lifestyle.

Continue to be a beautiful small town that is family oriented.

Don’t build more than our streets can handle. Don’t put low income housing near upper class neighborhoods
A vibrant multi culture/racial city
There is nothing wrong with building more houses, condos, etc but we already know how congested Vasco and H-4 even during pandemic. I hope that Brentwood, Antioch, Oakley, and Disco Bay would pay attention to the already very congested traffic in these two major roads before even talking about more houses.

Keep Brentwood a small town environment
Save farms. Build better roads. Less development.

Infrastructure that meets new housing. Eg street improvement, highway access.

Executive style homes and Ranches
Brentwood needs to be the next Pleasanton and Livermore and not Antioch. Brentwood should focus on smart high end growth. We need luxury homes like Ruby Hill in Pleasanton. Brentwood should be known for beautiful organic farms, farm to table restaurants, and high end homes. Many people are moving from Silicon Valley here to raise a family and want a nice home with lots of space. We don’t need more apartments, low income housing, gas stations, car washes, or liquor stores to bring down Brentwood. The seniors that live here and spend there money want to live in a nice area that they feel safe in. Let’s not cater to the people that don’t put money back into Brentwood all they do is increase crime and cause property values to fall.

Stop growing. U are ruining the city ot was.

Brentwood should focus on home ownership for upper middle class families with careers.

I would like to see a focus on larger lot sizes and emphasis on higher end housing.

Housing areas where they look like well maintained parks. affordable housing for people with incomes below $75,000 per year - so that means rent or mortgages below $2000 per month.

I'm concerned about too much density in the City. I would like to see more housing for those with disabilities and that need support. I think developers will put as much housing on a lot that possible (that is their business motivation), but Brentwood can be choosy now with what type of housing is available. The City will need to continue to have viable open space for our residents.

More townhomes for 1st time homebuyers. Housing for persons with disabilities. Maintaining current zoning
I'm not in agreement with any policies or legislation that would dictate to homeowners to rent rooms to people of low, or no income against their will.

Mixed Cost housing in same subdivision, don't build the "projects" will all subsidized Housing in the same area.

As Brentwood will inevitably expand my vision will be to keep our community to the same standards.

Considering developments location and the impact on schools, parks and traffic. Main streets are becoming very difficult to go through during high volume times (weekends, after work). Stores are becoming more crowded. If more affordable housing becomes more accessible- it needs to have standards that reflect Brentwood. Clean landscaping and upkeep and a park.

Lots of variety.

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Livermore and not Antioch. Brentwood should f nd not Antioch omes like Ruby Hill in Pleasanton. Brentwood sh in Pleasa o table restaurants, and high end homes. Many p o table restaurants, and high end h e a family and want a nice home with lots of spac a family and want a nice home with lot housing, gas stations ng, gas stations, car washes, or liquor stor , car washes, or liquor st here and spend there money want to live in a ni spend there money want to live in a ni he people that don’t put money back into Brent t don’t put money back into Bre roperty values to fall. AFT
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ocus on home ownership for upper middle class ocus on home ownership for upper e a focus on larger lot sizes and emphasis on hig e a focus on larger lot sizes and emphas s where they look like well maintained parks. s where they look like well maintained parks housing for people with incomes below $75,000
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concerned about too much density in the City. I bout too much density in the City. I isabilities and that need abilities and that need support. I think develo (that is their business motivation), but Brentw (that is their business motivatio available. The City will need to continue to available. The City will need to co DR More townhomes for 1st time homebuy mes for 1st time homeb zoning DR
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City of Brentwood
2023-2031 Housing Element Update

Table 2 – Vision for the Future
do not become Antioch
Vibrant small businesses, especially healthy and diverse restaurants. Please no more fast food. We have more than enough of those.

Stop making it a bedroom community. Please look into more smarter housing no more sprawl…seems the developers give Brentwood money and the city replies “Yes to all your demands!” We have enough housing so far. We need services to support the community that’s here I would like the see a slow in development in Brentwood. Also, I would like to see primarily single family homes. What drew me to Brentwood in the first place was the open spaces and minimal apartment/condo complexes. I would like to see more large lot homes such as ranchettes.

Brentwood needs to promote housing that continues to showcase the charm and character it has been known for, that of a bedroom community surrounded by farm to table markets, and suburbia.

Too many apartments, and low income housing will bring transients, and more crime.

I would just encourage that affordable housing be spread out through the city not just built on one side of the city.

I love the open space here a d would hate to see it all consumed by housing. Brentwood is special because it is not inundated with folks from neighboring cities.

Slow growth. some apartments. Special needs is great. Support for ne'er-do-wells is bad. Do not want turn into Antioch.

Many homes in Brentwood are already orientated to the over 50 people . I think a community like Rossmore is needed for the people of advancing age and health problems. There are many people are in that age group and more are coming. They need a city that can accommodate them. They need a quiet area where they can have their declining years of their life in safe environment. Many of the surrounding areas can accommodate the younger se.t
In the future there will be so many houses and so much traffic people will move on to more affordable housing and a small town (like this used to be).

I think we have to many houses already. No more building. We don’t have the Infrastructure or land left to build anymore.

I believe that we should curtail building in Brentwood in terms of housing. I think it would be more beneficial to provide more open space, Improve bike and walking access to all parts of Brentwood.

Create/develop a youth recreation Center, along the lines of a girls and boys club or YMCA type facility.

Keeping of open space. Love the farms and open fields.

Single parents being able to afford housing on a single income without having to go through low income housing. More jobs and less single family home developments. More fire departments and middle/high schools to accommodate the growth of students from all these homes.

Match the housing to the employed and non-employed (including retired) residents. With a proper match and amount of housing, commuting could and should be minimized.

I would love to see more affordable housing options. Providing this will bring much needed diversity and new ideas to the city.

A selection of duplexes or 4-plexes that allow ownership at a lower cost.

We are doing better than the adjacent cities around, we should keep managing what we done.

Specially the crime issue.

Brentwood need a nice shopping mall, instead more houses. Shopping Mall which will bring different people, different business into Brentwood , Brentwood will become a destination for people to visit. re doing bett DRAFT the cr
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dy orientated to the over 50 people . I think orientated to the over 50 people . I thin a co e of advancing age and health problems. There a ancing age and health problems. There are coming. They need a city that can accommo city that can accommo have their declining years of their life in safe ing years of their life in safe env commodate the younger se.t ommodate the younger se.t
and a small town (like this used to be). and a small town (like this used to b be so many houses and so much traffic people w be so many houses and so much tAF R to many houses already. No more building. We d buildin
nymore. nymore RA
hat we should curtail building in Brentwood in te at we should curtail building in Brentwood in te ial to provide more open space, Improve bike an provide more open space, Improve bike an ate/develop a youth recreation Center, along the a youth recreation Center, along the Keeping of open space. Love the farms and op Keeping of open space. Love the acility. cility. RA D
Single parents being able to afford housing Single parents being able to afford income housing. More jobs and less sing g. More jobs and less s middle/high schools to accommodat ols to accommodat DR
Match the housing to the employ to the
match and amount of housing, match and amount of ho
I would love to see more af I would love to see more
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selection of duplex
City of Brentwood
2023-2031 Housing Element Update

Table 2 – Vision for the Future
I would like to keep Brentwood environmentally pleasant, unsaturated with less homes and people, and provides a feeling of breathe-ability. I would like to see more greenery (grass and trees), uncongested streets in and out of the community, a place of safety and security.

Realtors who don’t steer the mid to low income families who want live in safe neighborhoods and not be judge solely because you don’t have 3 times amount of income to cover an income check there are a lot of prejudice and racist’s realtors and home owners and have experienced this first hand for many months because of the pandemic made it tailored to realtors to only approve those who have pre qualified for housing in the area.
continue with a healthy farm community for years to come Mix of nicely maintained housing for people who take pride in where they live.

Stop the growth of expensive housing. Even senior housing is expensive in Brentwood. Our roads and schools are not equipped for this influx. We also don’t have careers out here.

We need to stick to the plan. Look at what land we have left and decide if the way they are zoned makes sense.

A good mix of something for everyone.

Affordable and attractable business policy
for companies to move and provide employment opportunities for the residents.

Keeping what farm land that we can and also build homes that are affordable to the working families that work in our area
Back to base for each unit/house have job in town
Safe and attractive neighborhoods complimented by well maintained parks, trails and open space The use of property as it was zoned.

Infrastructure balance, there must be enough supermarkets, shops, water, to support all of the homes being built.

Spread out, well planned communities that focus on families. A town that is not filled with low income apartments, where families feel safe and value the town I would prefer more affordable housing in the form of Condos vs. Apartments.

I envision growth in the area of homeownership opportunities for low-income families, such as myself, whose hearts belong to Brentwood, without changing the landscape and small town vibe we've always appreciated.

Thank you
We need to adhere to the plan that has been set. Do no rezone locations.

Build the technology park to attract businesses
Controlled growth
Housing that families can afford and keeping neighborhoods clean and safe. Neighborhood watch and housing that doesn’t exceed the capacity of our schools. No over development.

Nice
Preserve our farm town. Don't push our farmers out just to build homes. We are a beautiful small farm town, the soil here is fruitful. Build homes on bigger lots. Stop trying to overcrowd. Homes are on top of each other now.

Retain the current look and feel of the community, and only increase the density as mandated by state law.

Controlled housing that considers and plans for limited services such as water, parking, fire, police and schools. Brentwood should not over build new homes where/when services are already over he currDRAFTs
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ods complimented by well maintained parks, tra ented by well maintained parks, tra as zoned. RA
there must be enough supermarkets, shops, wat there must be enough supermarke planned communities that focus on families. A to planned communities that focus on fam ments, where families feel safe and value the tow ments, where families feel safe and value th fer more affordable housing in the form of Cond fer more affordable housing in the form of Con n growth in the area of homeownership opportu owth in the area of homeownership opportu elf, whose hearts belong to B earts belong to Brentwood, without od, without e've always appreciated. eciated.

Thank you
We need to adhere to the plan that has bee We need to adhere to the plan thRA D Build the technology park to attract busi Build the technology park to attract b Controlled growth
Housing that families can afford a es can
housing that doesn’t exceed th housing that doesn’t exce Nice
Preserve our farm town
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City of Brentwood
2023-2031 Housing Element Update

Table 2 – Vision for the Future
used. Services should be increased as housing is built and be ready as new homes come on the market.

Housing prices stabilize. Not as many "cookie cutter" houses.

Less apartments. Less crime. Less affordable housing. Fewer homeless encampments and no additional transitional housing programs. Zero tolerance for drug dealers and gangs moving into the city. If more housing needs to be added, gated 55+ communities are the best choice. Assisted living facilities are needed. Remaining open spaces should be preserved as parks or green areas.

More single story homes since we need them as we age. We don’t want them only in age restricted communities. Too many apartments now being built Stop that. Some sort of central shopping. Maybe a two story enclosed mall. Too hot and cold here for an open one. More police and fire personnel.

More grocery store options. Like Whole Foods Stop building out all the open space. no to low cost housing in Brentwood, it will lower the market value of houses here in Brentwood Slow it down. It won’t be sustainable.

Maintain that small town feel.

Home value growth
Family oriented housing mostly made up of multi-generational and single family with the bare minimal multi-family (apartments) and low income properties to meet State requirements.

Keep Brentwood as rural as possible
We moved here to get away from over populated towns and traffic. In the 4years we have been here the town has already started to lose its rural charm.

No section 8
I would like to see more affordable housing options, but I am not in favor of more building. I would like to see the agricultural área preserved.

No more condos/apartments, no low income housing, or new housing. We are streets and our schools are congested enough.

Comfortable family homes with space for plants
Less than 70,000 population would be best
Our city is already bursting at the seams. We don’t have the emergency services or support systems in place to build any more residential housing whether it’s apartments, single family homes, etc. We need more police to deal with all the riff raff making it’s way into Brentwood. This city is losing its charm. A moratorium is what we need on all future home building. This state has gotten so lost!!! More parks, sports complexes, open space. Schools, roads, and infrastructure need to increase in order to keep up with the increase of housing.

Ingress and egress surrounding the schools are a mess and should be addressed. 30 minutes to drop off/ pick up at a school within the city is unacceptable and is based on poor planning and lack of city government action.

An increase in affordable housing and low income complexes drive down home value and make the commute into and out of the city less tolerable.

Increase the police budget so retail theft, homelessness, and blight can be addressed properly.

The vision is a clean, safe, crime free city, where families that can afford to live here have a place they can relate to and want to be productive, contributing members of the community.

DR
More parks, sports complexes, open space. More parks, sports complexes, op order to keep up with the increase of ho order to keep up with the increase of Ingress and egress surrounding the surro
off/ pick up at a school within t ool w
government action.

An increase in affordab An increase in afforda
mmute into and o DRAFT the p
T
s and no s and no
ngs moving into the ngs mov
choice. Assisted living choice. Assi
s or green areas.T
t them only in age restricted them only in age restri
e sort of central shopping. Maybe e sort of central shopping. May More poli More p ce and fire personnel.
et value of houses here in et value
ut all the open space. ut all th
BrentwoodTF A
ulti-generational and single family with the bare and single w income properties to meet State requirements w income properties to meet Stat AF ver populated towns and traffic. In the 4years we opulated towns and traffic. In the 4year ose its rural charm. al cha
fordable housing options, but I am ptions, but I am not in favor o favor o ral área preserved. al área presRA
rtments, no low income housing, or new housin rtments, no low income housing, o sted enough. sted en
mily homes with space for plants mily homes with space f 0,000 population would be best
is already bursting at the seams. We don’t have eady bursting at the seams. We don’t have e to build any more residential housing whether ny more residential housing whether eed more police to deal with all the riff raff maki o deal with charm. A moratorium is what we need on all fu charm. A moratorium is what wRA D City of Brentwood
2023-2031 Housing Element Update

Table 2 – Vision for the Future
No water, no electricity, no more housing, until those issues are solved.

Continue the feeling of a small community with rural farming areas close by. Maintain law and order by minimizing densely populated areas.

I would prefer that if Brentwood grows it does so to the East. Additionally, I hope that jobs come with the growth as not to further increase traffic on Hwy 4 and Vasco Rd.

We’d like Brentwood to continue to be an environment that is safe for our children and elderly and the whole community. That our surroundings are kept clean and neat and safe, with homeowners willing to do their share in the work of keeping Brentwood a city that we are all proud to call Home. 3x's the land for every house built - meaning you keep Brentwood green Small town feel.

Brentwood doesn't need more housing. Brentwood needs more long term jobs.

No more housing!!!!! No big box stores!!! Follow through with the Brentwood Blvd plan get rid of all that crappy homes and stores and revamp it all we should look like Danville or Alamo not Concord! Prioritize the farms highlight all the farms all the time. No more football player owned farms he left us anyway! Force knightsen to clean up or take them over.

Brentwood is beautiful the way she is. No more homes, apartments, senior facilities. No more developers in Brentwood. We see what they do when you don't succumb to their wants (Deer Ridge) I would like the city to consider building of new homes/apartments done. We are stretching our resources too thin. Water resources and emergency services.

Stop building high density housing and creating new issues: increasing the use of resources such as water (apparently there isn’t enough for those who already live here and pay to be here, many 20+ years), emergency services, roads, and empty malls/buildings. It appears the city needs people who better understand business.

I moved my family to Brentwood from the South Bay because of its charm, young family oriented, open spaces, suburban and rural. We wanted to get away from the crowd and chaos of a metropolitan city. I would so much would like to keep Brentwood this way. Opening Brentwood to affordable housing will definitely change the environment, and will bring in more crime to our city.

Let’s keep Brentwood as is.
would like to see better maint of existing housing and support of same Less trac houses. Larger yards on new build single family I hope for Brentwood to remain a small and safe community for families.

I would like to see no more houses. And definitely no apartments.

Less growth and more investments in infrastructure. Better commuter experience on Vasco, more public transit, more schools. Cannot blindly build dwellings without FIRST addressing infrastructure needs. To do so is lunacy.

No more is necessary. Leave the community as is. The road infrastructure can barely manage the Brentwood infrastructure as is.

Leave it as it is now
I think we need to create more workplaces locally before building more homes.

Slow it down....infrastructure is not maintained to add any more high density housing! Halted. Too much development and losing community feel and atmosphere.

Not enough water in the entire state, let alone Brentwood, no new building should be initiated.

Brentwood's current housing situation is fine, it would be good to encourage builders to allow for more room between properties so people can adequately store garbage cans/basketball hoops or DRAFTw an
hat jobs come w hat jobs cT
dren and elderly and ren and el
safe, with homeowners safe, with homeow
e are all proud to call Home. are all proud to call HoT eenFT
re long term jobs. re long t
with the Brentwood Blvd plan get rid of all with the Brentwood Blv uld look like Danville or Alamo not Concord! uld look like Danville or Ala e. No more football player owned farms he left u o more football player o m over. FT
y do when you don't succumb to their wants (D y do when you don't succumb t e homes, apartments, senior facilities. No more ents, senio T AF
of new homes/apartments done. We are stretc of new homes/apartments done. We and emergency services. emergency services
g and creating new issues: increasing the use of r ating new issues: increasing the use of r nough for those who already live here and pay to ose who already live here and pay to roads, and empty malls/buildin y malls/buildings. It appears the ss.
p Brentwood as is. Brentwoo
ousing will definitely change the environment, a ousing will definitely change the environment, ty. I would so much would like to keep Brentwoo ty. I would so much would like to keep Br rban and rural. We wanted to get away from the rban and rural. We wanted to get aw Brentwood from the South Bay because of its ch Brentwood from the South Bay beAF R like to see better maint of ex ee better maint of existing housing and s trac houses. Larger yards on new build single f Larger yards on new build single f DR I hope for Brentwood to remain a small and saf I hope for Brentwood to rema I would like to see no more houses. And def I would like to see no more house D Less growth and more investments in inf tments in
public transit, more schools. Cannot b ore schools. Cannot b needs. To do so is lunacy.DR
No more is necessary. Leave th ry. Le
Brentwood infrastructure as Brentwood infrastructur
Leave it as it is now
think we need to cre
it down....inf
Too mu
City of Brentwood
2023-2031 Housing Element Update

Table 2 – Vision for the Future
even recreational vehicles to minimize the need for additional storage facilities around town. Also, the impact on the roadways leading in and out of Brentwood need to be addressed before additional housing. Those of us who have commuted for years on Vasco have seen our commute increase by over an our each way. Please work with government agencies to open up Vasco and the congestion before increasing housing. There are not enough high compensation jobs in Brentwood/Oakley/Antioch to afford the increasing home prices so we are forced to commute.

Less people and apartments
A balance of businesses vs homes vs traffic impact studies that support continuation of building density and what infrastructure the city plans to relieve congestion ~ growth is inevitable and so is balance.

I believe the city is becoming overcrowded...it is too condensed; with more people/housing units, you will need additional services and roads.

Model the issuance of housing permits similar to Livermore For Brentwood to get their infrastructure up to par and to stop big developers from ruining our once small town. I left the big city for the small town Brentwood was back in 2003.

No more building of any housing. Cap the population at current levels. Even better, reduce the population so the character of the area is preserved.

Everyone who is able to afford a house in Brentwood should be able to get one.

We create addition problem when we try to artificially impose our will on the market.

Maintain Brentwood small town feel
Please stop building car washes and gas stations. You have put so many gas stations into the city of Brentwood and probably don't even understand what underground storage tanks do to the surrounding area. You have congested this area with nothing but crappy little stores that can't stay open you have ruined the small town feel of Brentwood. Stop it. I moved back here to feel at home and you guys have ruined the city stop building bull crap. Stop lowering the value of my home with affordable housing, And filling every nook and cranny with apartments when we can't even travel to the grocery store without waiting in line for 45 minutes because the connectivity in the city is not good. You have ruined Brentwood please fix it
Smart housing, which includes but is not limited to:

Future proof infrastructure
Future proof roads
Strategic ares of growth
Stop building!! Ruining Brentwood.

No more housing. Keep our small town feel. Keep our quality neighborhoods. No more houses, impacting our schools and making more traffic!
Less people because its already overcrowded
To many people and everywhere crowded and nothing for people to do.

Stop building houses. Put a program in place that owners of rental properties need to maintain their landscaping or risk being fined. Build more schools to support the growth that is already happening and planned. Do not allow SB9 to infect our housing communities and drive our property values down.

We enjoy living in Brentwood, because, for the last several years, it has been a peaceful “small town” - good for raising a family. However, in recent years, crime has gone up, EMS services are inadequate, and traffic is increasing. Our city needs more commercial and retail growth and no more new housing y livinDRAFs and gas stations. You have put so many gas sta tions. You have put so many gas sta n't even understand what underground storage and what underground storage ve congested this area with nothing but crapp e congested this area with nothin y the small town feel of Brentwood. Stop it. I mov the small town feel of Brentwood. ruined the city stop building bull crap. Stop lowe ruined the city stop building bull cra ng, And fil ng, And ling every nook and cranny with apart ry nook and cranny wi tore without waiting in line for 45 minutes beca tore without waiting in line for 45 minutes be have ruined Brentwood please fix it ave ruined Brentwood please fix it AFTa ncrease ncreas
the congestio the con
ced to commute. ced to com T
continuation of building ontinuation of building
growth is inevitable and so is
d; with more people/housing units, you FT
ore
nd to stop big developers from ruini to stop big developers fr ng our once entwood was back in 2003. was back in 2003. FT
ulation at current levels. Even better, reduce the nt levels. Ev eserved.AF
Brentwood should be able to get one. Brentwood should be able to get on try to artificially impose our will on the market. y to artificially impose our will on the m el
housing, which includes but is , which includes but is not limited to:
ure proof infrastructure astructure
uture proof roads ture proo
Strategic ares of growth RA D
Stop building!! Ruining Brentwood. Stop building!! Ruining Brentwood DR No more housing. Keep our small town ng. Keep our small tow impacting our schools and making m ools and making m DR Less people because its already o e its a
To many people and everywh To many people and ever
Stop building houses. Put a Stop building houses. Pu
landscaping or risk bein
d planned. Do not D
City of Brentwood
2023-2031 Housing Element Update

Table 2 – Vision for the Future
(especially high density housing). Keep Brentwood great by keeping it a family-friendly city with a “small town” feel.

My vision is that the homelessness is going to get out of control it seems that its not being deal with.

Less apartments, more family homes. Brentwood is not meant to house this many people with infrastructure that can’t support it.

The future of Brentwood is not looking great for families. You're showing pictures of fields and trees and all you want to do is develop and ruin this community. we have adequate housing and need more business/commercial property Certainly not to build the monstrosity on Lone Tree and O’Hara. Planners need to be mindful of the entire space to be occupied and the surrounding area. For example, we have an over abundance of gas stations and car washes for our fair city. It’s almost as if the people who approved one after the other had zero knowledge that what they were approving was already present. Case in point, there are 3-4 gas stations and/or car washes within a few blocks of each other on the very same road (located on Brentwood Blvd between Sand Creek and Lone Tree).

Have a larger minimum lot size. Keep the urban boundary. Improve roadways to alleviate congestion.

Less affordable for criminals and illegals
A sanctuary for low income seniors with lots of family's with master community development integration, parks, trees as always
Restricted and well thought out planning, the city is getting very congested and quality of life is being impaired.
make street lights, roads and highways more smooth and safe Limited housing development. Brentwood is getting crowded and has traffic congestion. Keep land and farm open for agriculture. Need more green and open space areas.

I would like to see Brentwood capped at 80K-90K population. The infrastructure can't withstand much more without creating more local jobs. Traffic is becoming unbearable as it is now. Housing needs to stick to the general plan with a mix of single family, low income, senior, and disability housing. We need more areas for kids to get involved (community centers or sports programs offered by the city.

More high-level income housing. Limiting low income housing and apartment. Encouraging new businesses, restaurants.

Continue with similar to current Master Plan. Keep high density housing projects on outskirts or near high density urbanized areas (away from single family residences). Keep single family projects to 2 or story units maximum and high density to 3 story buildings. Do not urbanize residential areas.

Minimize affordable housing projects to prevent violent crime migrating from neighboring cities.

My vision would be that Brentwood provides safe and clean neighborhoods. Homes where families can have a good education for their children. Seniors and veterans have affordable housing in a community that is supportive.

Community where residents themselves take pride in their city and ensures it is clean, well taken care of not liter filled and in state of disgrace, but could rubies to welcome families year after year to take part and experience our farms and community.

No more traffic. Less building, more open space. Quit using more and more water, before we all have to ration.

Respecting current zoning to keep neighborhoods in tact. Peoples life savings have been spent in the types of neighborhoods in which they want to live either for raising their families or living in retirement.

DRAFTng deal ng deaT
eople with eople w
ures of fields and trees ures of fields
ty
nners need to be mindful of the
le, we have an over abundance of
e people who approved one after the
was already present. Case in point, there was already present. ks of each other on the very same road ks of each other on the ve Lone Tree). ne Tree) FT
oundary. Improve roadways to alleviate congest mprove roadways T AF s of family's with master community developme s of family's with master comm ning, the city is getting very congested and quali the city is getting very congested and q ighways more smooth and safe e smooth and safe
ent. Brentwood is getting crowded and has traffi getting crowded and has traffi ulture. Need more green and open space areas. ulture. Need more green and open RA entwood capped at 80K entwood capped -90Kpopulation. The inf popul ut creating more local jobs. Traffic is becoming u ut creating more local jobs. Traffic is o the general plan with a mix of single family, lo o the general plan with a mix of single fam e need more areas for kids to get involved (comm e need more areas for kids to get involved (com y. RA
high-level income housing. Limiting low income l income housing. Limiting low income sinesses, restaurants. urants.

Continue with similar to current Ma Continue with similar to curreRster Plan. K high density urbanized areas (away from sing high density urbanized areas (aw story units maximum and high density to 3 story units maximum and high dens Minimize affordable housing projects t dable housing projects DR My vision would be that Brentwood e that Brentwood
can have a good education for th ucatio
community that is supportive community that is suppo
Community where residen Community where resid
of not liter filled and in of not liter filled and in
rt and experience
ore traffic. L
ationDR
City of Brentwood
2023-2031 Housing Element Update

Table 2 – Vision for the Future
Enough low income houses for family and seniors
Protect important farmland east and south of Brentwood. Build between Brentwood and Antioch / Oakley borders to the west where land isn't being actively cultivated.

No new development until infrastructure is in place. Public transportation, schools and fire services.

No more gas stations, 7-11 type stores or Grocery outlets need to be built. We need good restaurants, which are few and far between.

Plenty of green space and healthy food sources within east access of neighborhoods We need units that a single senior can afford with marginal retirement No more developments.

More mid-priced single family homes. Limit the amount of section eight allowed in the city ! More oversight for properties that are not being maintained (ie: overgrown vegetation, too many vehicles on the street, degraded concrete & weathered structures) ! Possible tiny home communities
My family has lived in Brentwood since the 30s. I've seen many changes, We Should 1st. develop better infrastructure of our city to accommodate more housing of any kind. Without more Schools, Fire and Emergency Services the CITY is putting their tax paying Citizens that they already have at RISK!
Renew the senior housing proposal at Balfour and Deer Valley. It was great I would like to see single family homes,not a congested Brentwood.

Keeping a small family oriented town.

Safe, recreational and affordable City with farmland and parks.

A family oriented community with a quality standard of living. Large police officer pool, upscale restaurants, etc,
Keeping low income housing to a minimum.

Small, safe community with an emphasis on parks and recreation Keep it nice. No more traffic, No more housing, A cap on property taxes for retired seniors.

Please enforce ordinances that prohibit parking boats RVs inoperable vehicles large work trucks and trailers in driveways and on streets!
A crime less community where we can raise families safely, and where dwellers care and keep their properties kept up
Stop building period, until some roads in and out are planned Not to look like Emeryville or Berkeley. Have room to park cars in driveways. Houses spread out and not up.

Affordable housing for seniors (65+). Duplexes and condos for purchase.

Affordable single story condos for seniors
I think best for me if Brentwood city they will allow to build a shopping mall like in Concord Provide affordable housing to the senior community
Increase the number of senior housing options
Quality, well- maintained and safe neighborhoods featuring green belts and parks Protected farmlands adjoining smaller developments. Brentwood is growing too fast Less low income apartments- more single family homes.

Housing for seniors
ty, well
d farm DRAFT -
Ant
nd fire services nd fire s
eed good restaurants eed goodT
borhoods borhoodFT
on eight allowed in the city ! on eight More
ergrown vegetation, too many vehicles
! FT
g their tax paying
more housing of any kind. Without more Schoo
seen many changes, We Should 1st. develop many changes, We Sh ng of any kind.

Citizens that they already hav Citizens t
T
alfour and Deer Valley. It was great lfour and Deer Valley. It was greatFT A es,not a congested Brentwood. t a congested Brentw
own.
able City with farmland and parks. rmland and parks.A
nity with a quality standard of living. Large polic ity with a quality standard of living. Large polic RA e housing to a minimum. e housing to a minim
munity with an emphasis on parks and recreati munity with an emphasis on parks and re o No more traffic, No more housing, A cap on pro No more traffic, No more housing, A cap on p nforce ordinances that prohibit parking boats RV rce ordinances that prohibit parking boats RV s in driveways and on streets! ways and on streets!
rime less community where we can raise familie munity where we can raise familie properties kept up properties kepDR
Stop building period, until some roads in and Stop building period, until some D Not to look like Emeryville or Berkeley. H Not to look like Emeryville or Berkel not up. DR
Affordable housing for seniors (65+ g for seniors (65+
Affordable single story condos f ory co
I think best for me if Brentw I think best for me if Bren Provide affordable housi
crease the number
mai
City of Brentwood
2023-2031 Housing Element Update

Table 2 – Vision for the Future
A Lot Less!!!! Brentwood is not longer the close nit family friendly community. Too many people over running the City. Bring big jobs, not more houses!!!!
I would like to see a slow growth in Brentwood. I do not want any more traffic and crowding here.

There is not enough water for new homes and all the families they will bring. Our water needs to go to our farms. I do not want to lose the small town atmosphere and relative safety in our community. single family homes with NO low income or any other government assistance A community of single family homes for sale, not to rent. More enforcement requiring owners to abide by Brentwood 's housing codes, rules and regulations (e g. Cars parked on the driveway, not the grass or in front of neighbor's homes, no work vehicles of a certain size parked on or near the homes, require all home owners to take care of their landscapes) If the City of Brentwood regularly maintains the medians, streets and parks; the homeowners should be required to as well. Move all apartments and low income housing units to areas outside the city boundaries.

No re-zoning. No further congestion / overcrowding. In most cases, we are already there. Way too much stagnant traffic around schools- especially elementary schools throughout the day. Prevent school overcrowding. Brentwood has grown way too fast. Enforcement is seriously lacking. It seriously diminishes benefits of time and money spent.

Keep the agricultural uniqueness of Brentwood, NO STACK AND PACK CRAP. We do not want Brentwood to turn into Dublin. Single family homes with yards for children and pets (that is why people drive hours for commute) to have the opportunity for a small town life. PLEASE DON'T DESTROY IT. With little to no employment in Brentwood, keep it small with the hometown feel. Please consider the HWY 4 road noise in any future development and please stop catering to the builders to develop the land from farm to profit.

Single family neighborhoods that are not affected by crime and homeless vagrants upscale housing and shopping similar to Walnut Creek or Pleasant Hill.

I would like Brentwood to maintain its small town atmosphere but develop into a destination city for its farms and vineyards and shopping
Small home town feel where neighbors know and talk to each other.

More quality homes owned by good members of society
Local control with no state or federal interference.

Restrain the building of new houses as much as possible to maintain the quality of life in our city A safe place for families, with good schools . A place where homeowners are responsible and respect their neighbors and their community.

More single family dwellings on larger lots.

Do not over built the area
I would love to see more housing built in Brentwood with improvements to the roads (wider/better) Larger homes with larger lots & well manicured neighborhoods. Maintain the cleanliness of the City.

Brentwood is currently an escape from the tightly packed housing issues of the inner Bay Area, and is also extraordinarily safe. Please oppose urbanization of this lovely city. Maintain open spaces as much as possible, continue to use funding for public works and beautification measures. There's a reason why even this survey maker chose to make the background pictures of Brentwood as flowering trees and the Deer Ridge/Shadow Lakes neighborhoods.

Dwell with Nature's Harmony
Keep the building of new homes limited…Don’t want this city to turn into a low income area…keep it family oriented with slow steady we’ll thought our growth that is good for the hard working families of this community.

DRN
A safe place for families, with good schools . A p A safe place for families, with g DRAFTwding he wding h ater needs to g ater nee
y in our community.T
nt requiring owners to nt requiring owne
arked on the driveway, not the ked on the driveway, n
ze parked on or near the homes, parked on or near the home ty of Brentwood regularly maintains
quired to as well. Move all apartments
oo fast. Enforcement is seriously lacking. It serio
entary schools throughout the day. Prevent ntary schools throughout most cases, we are already there. Way too most cases, we are alread Enforcement is serio
daries. TF
ave the opportunity for a small town life. PLEASE e the opportunity for a small town life. mily homes with yards for children and pets (that mily homes with yards for children a ood, NO STACK AND PACK CRAP. We do not want PACK CRA
T
yment in Brentwood, keep it small with the hom in Brentwood, keep it small with the ho n any future development and please stop cater e development and please stop cater o profit. AF
ds that are not affected by crime and homeless v that are not affected by crime and homeless v RA hopping similar to Walnut Creek or Pleasant Hill. ar to Walnut Creek or ood to maintain its small town atmosphere but d ood to maintain its small town atmo eyards and shopping
own feel where neighbors know and talk to eac own feel where neighbors know and talk to e lity homes owned by good members of society y homes owned by good members of society ontrol with no state or federal interference. with no state or federal interference. R strain the building of new houses as much as pos ng of new ho DR their neighbors and their community. their neighbors and their commun D More single family dwellings on larger lot More single family dwellings on larg Do not over built the area the ar
I would love to see more housing b more
Larger homes with larger lots & Larger homes with larger Brentwood is currently an e Brentwood is currently a
also extraordinarily safe. also extraordinarily safe
s possible, continue
even this surv
e Deer RiD
City of Brentwood
2023-2031 Housing Element Update

Table 2 – Vision for the Future
More affordable single family homes
Family oriented safe quiet place
Majority single family housing that caters to families and provides a safe environment for kids to walk city and play in parks.

No high-density or transitional / transient apartments
Less building period. Enough already. Keep some open space as we are already crowded.

I would like to see more upscale housing with upscale shopping centers. Brentwood is a great city with amazing housing as it is, but would love to see this city as people is Southern California see their Brentwood.

Stop allowing developers to have tiny lots with houses built right to the edge of lot lines. Stop building low income/affordable homes. Lets try to be a Danville of east county, NOT like Antioch.

Stop the growth of apartments/condominium complexes and put controls on renters/landlords that require the upkeep of their properties.

Smart growth. Not these ramrod developer friendly builds Bigger lot sizes for housing that will be approved. No more houses, concentrate on bringing businesses to the area.

Clean safe city free of the homeless California scorge
No more apartments and no more low cost housing.

Safe place to raise a family
That we don’t add too much condensed housing, especially in established neighborhoods. They weren’t planned for that.

We need more entry level homes such as condos and townhomes rather than all of these apartments.

There are way too many apartments on shady willow.

We also need to attract higher income levels with larger lots. We need a mix of people in Brentwood, we shouldn’t only be attracting low income, we should attract a variety of income level citizens.

The future is bleak. Governmental intervention has ruined Brentwood. It is probably too late. Stop.

Repent. Fire all managers and consultants now. Restore common sense and an open market and society will self-regulate.

Do not rezone single-family areas into cramped and overcrowded apartment/condo areas. People move to Brentwood to get AWAY from the super densely populated inner Bay Area. Don't let Brentwood turn into San Jose.

Do not over build the area!
to stay safe and secure
No high-density developments.

Currently, 0 lot high volume housing projects without upgrades to infrastructure is diminishing the value of current homes. We need more commerce not homes housing shouldn’t adversely affect roadways that still need upgrades, ie; Lone Tree to O’hara. please fix this roadway.

Parkways need to be considered before any more new developments are built. The traffic is terrible.

It takes a long time just to travel from one side of town to the other because of all the cars.

Good neighborhood, lower crime, no homeless view, no panhandlers, create middle and upper income jobs, not in any particular order
Continue the path of developing a community that is safe, excellent educational opportunities and supportive of the Arts.
eighborDRAFTfor kids to for kids T
dy crowded.
rentwood is a great city rentwood is a great
s Southern California see their Southern California see t to the edge of lot lines. Stop building
t county, NOT like Antioch. t county,FT
nd put controls on renters nd put controls on ren /landlords that TF builds
No more houses, concentrate on bringing ouses, concentr AFT nia scorge nia s AF
cost housing. ost housing.
densed housing, especially in established neighb using, especially in established neighb homes such as condos and townhomes rather th dos and townhomes rather th y apartments on sha y apartments dy willow. willow.
ract higher income levels with larger lots. We nee ract higher income levels with large will self
e all managers and e all ma
elf
eak. Governmental intervent eak. Governmental inte
-regulate. regul
y be attracting low income, we should attract a v y be attracting low income, we should a consultants now onsult
ion has ruined Bre
. Restore com
ruined
ore coAF R
ot rezone single-family areas into cramped and o
ove to Brentwood to get AWAY from the super d d to get AW Brentwood turn into San Jose. Brentwood turn into San Jose Do not over build the area!RD
to stay safe and secure to stay safe and secur
No high-density developments. develop DR
Currently, 0 lot high volume hous h volu
value of current homes. We ne value of current homes. W housing shouldn’t adversely housing shouldn’t advers
fix this roadway. fix this
arkways need to be
kes a long time D
City of Brentwood
2023-2031 Housing Element Update

Table 2 – Vision for the Future
Brentwood is a beautiful growing community for working families. We love the beautiful parks and downtown. I love that the trails are clean and safe. I would hope to see Brentwood continue down the path of being a family-oriented town geared toward working families. We do not need affordable living, homeless shelters, apartments which will inevitably bring in crime and blight from Antioch and Pittsburgh.

Don’t change R-1-10. No rezoning. Keep Brentwood as is. WORK ON DEVELOPING COMMERCE AND BRINGING IN GOOD PAYING JOBS. If special interest groups or government agencies or new regulations are forcing Brentwood to change then put a moratorium on Housing and work on developing good paying jobs and resume housing later. JOBS HERE FIXES EVERYTHING!!! I’d like to see the general plan followed, it is only fair to the people who bought housing for their specific zone. I worked hard and saved money, planned and bought my house. It is not fair to after the fact change the zoning of it for the surrounding neighborhoods. I’d like to see the general plan followed.

Less apartments, more single family homes. Clean, safe, well maintained neighborhoods. No homeless.

I would like to see mix-use housing with transit access nearby the Bart Extension, and bus pick-up areas.

I would like to see housing projects mixed into large areas of open space, so our neighborhoods have trees, parks, and more open space. Lots that are small, and are stacked upon one another look very much like a Daily City or a large city plan. I know we can much better! Slow down before we become another Antioch
No more new homes until water is worked out
Single family homes, construction no taller than2 stories Suburban living
Family friendly, safe
Big lots for families, space in schools, no traffic
Brentwood has always been a family community. There are so many different dynamics of families these days you need a variety of housing options.

No more building. No more new housing. Stop. Enjoy the Brentwood hills and small town.

I would hope to see Brentwood remain a family community with most homes owned by families and less homes owned and rented out by developers and investors. less hotels/low income housing.

Family homes with strong community bonds.

Slow down the building! The city is expanding far too quickly and we are not equipped to deal with it on so many aspects - traffic is heavier, roads are wearing out, less parking, not enough grocery stores/restaurants. Seems the city is too focused on housing and not how to SUPPORT that housing.

Less housing and more upscale commercial and business opportunities. Plus more activities of things to do in the area. Wineries, high end restaurants, indoor and outdoor sports recreational centers, bring back golf courses, concert venues, fun centers such as Top Golf, batting cages, etc.

Stop building homes and start bringing in more businesses, i.e. jobs, jobs, jobs. Stop building grass - filled parks (we don't need anymore parks) and build sports complex (large indoor facility that can host basketball, volleyball, soccer, etc.)., if run properly, this can be a large source of revenue.

No more apartments and no more high density low income housing.

A clean safe community to raise my children
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s that are small, and are stacked upon one anoth that are small, and are stacked upon o know we
into large areas of open space, so our neighborh into large areas of open space, so access nearby the Bart Extension, and bus pick
can much better! can much
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ys you need a variety of housing options. you need a variety of housing options. ore building. No more new housing. Stop. Enjoy ng. No more new housing. Stop. Enjoy R would hope to see Brentwood remain a family co e Brentwoo less homes owned and rented out by developer less homes owned and rented DR less hotels/low income housing. D
Family homes with strong community bo Family homes with strong community Slow down the building! The city is ex uilding! The city is ex on so many aspects- traffic is hea tra
stores/restaurants. Seems the c stores/restaurants. Seem DR Less housing and more upsc Less housing and more u
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City of Brentwood
2023-2031 Housing Element Update

Table 2 – Vision for the Future
Please keep Brentwood a city where people who work hard, raise families, and contribute to their society live. Please remove section 8. With the expansion of BART into Antioch, the park and ride near Dainty Ave, and the recession, the homeless and criminal population who come from the Bay Area have infilitrated our great city and many like minded individuals who’s income pays for the city’s taxes are likely to leave if this issue continues. Many folks here have been here all our lives and enjoy the small city Brentwood is.

Low density housing north of sand creek, med/high density should only be in areas where infrastructure can accommodate (new development in southern Brentwood, etc). Lone tree is already too congested.

The future of housing in Brentwood should focus on affordability while maintaining it's family oriented charm.

Brentwood need more housing tracks like Trilogy
I like Brentwood with single family home
Single house dwellings
Quit building transcient apartments. Brentwood was always a family oriented community and is now being destroyed by the leftist ideology.

I would like to see housing development slow down in Brentwood. We are out building our resources and it shows.

To not be ruined with low income housing or to have multiple family dwellings in the middle of single family home neighborhoods
Attention to maintaining beautiful neighborhoods and walkways. It’s disappointing to shop around in the brand new developments and they are crammed in with a loss of the priority of also having beautiful spaces within a neighborhood.

Leave it alone. Affordable housing brings crime and lower property value. Plus, I shouldn’t have to pay for me to live in Brentwood and then for another family. Government should stay out of it.

Don’t bring in a flood of low income tax payer funded housing. That brings nothing but crime and lower home values for the people that work hard to live here. stop building so much housing especially low income, just bring rift raft. we need better stores and security
Single family housing. No apartments or condos. Larger parks for children to play. Keeping the small town vibe.

Single family homes only and no multi family homes but only after traffic concerns are resolved to accommodate more homes, especially local highways and freeways. safe, family oriented housing environment
I would like to see more affordable single family homes.

Family neighborhoods, available apartments/condos for rent, low-income or homelessness housing available but NOT located next to higher income housing, Keep Brentwood a upper-middle class community; do not allow it to become another Antioch or Pittsburg. Focus on keeping the community safe and focus housing on upper-middle class and seniors.

We do NOT need more "affordable" housing and rentals occupied by homeless and criminals! Maintain a clean neighborhood, family life activities and respectful community Limited apartments. So disappointed with Brentwood building apartments near Pioneer Elementary without vote of residence!
Shame on you for devaluing our homes and communities.

Dpart
ain a clean DR
Single family homes only and no multi family Single family homes only and no accommodate more homes, especially loca accommodate more homes, especi DRAFTnd e Bay A
or the city’s ta or the c
ves and enjoy the ves andT
n areas where
ood, etc). Lone tree is already ood, etc). Lone tree is a while maintaining it's family FT
was always a family oriented commu s a family oriented nity and is n AFT ow down in Brentwood. We are out building our ow down in Brentwood. We are AF using or to have multiple family dwellings in the g or to have multiple family dwellings in iful neighborhoods and walkways. It’s disappoin hoods and walkways. It’s disappoin s and they are crammed in with a loss of the pri ammed in with a loss of the pri neighborhood. neighbo
n Brentwood and then for another family. Gove n Brentwood and then for another fa able housing brings crime and lower property va able housing brings crime and lowAF R flood of low flood of income tax payer funded housing. T me tax payer funded ho values for the people that work hard to live here values for the people that work hard to live h RA ing so much housing especially low income, just g so much housing especially low income, just y
gle family housing. No apartments or condos. Lar sing. No apartments or condos. Lar own vibe. wn vibe.DR
safe, family oriented housing environm ented housing environm I would like to see more affordable s more affordable s Family neighborhoods, available ds, a
available but NOT located nex available but NOT locate
Keep Brentwood a upper Keep Brentwood a uppe
Pittsburg. Focus on kee
e do NOT need mo D
City of Brentwood
2023-2031 Housing Element Update

Table 2 – Vision for the Future
Stop with Government handouts. Let families take care of their own. We have enough housing. No more apartments, condos, section 8 or high density housing, just brings in more of those who DO NOT own or care about Brentwood or others. Get a job, go to school, work to buy a home. Do not tax others and give to those who do not earn it. Help our Veterans who volunteered to serve not illegals or those who choose not to serve in armed forces. Brentwood was a nicer place to live 40 years ago.

More housing just brings more problems. More government brings more people who do not work.

People come to Brentwood and bring their city ways and Democrat values with them and destroy what was once beautiful and more open and free. I will move if Brentwood keeps building and it will so I will move. Say NO to State housing requirements or eliminate or change them. Do not take the Money. Do what Brentwood residents want NOT what Sacramento or Washington DC wants. But I see what is going on in Brentwood and it will not stop. Brentwood has become Democrat cesspool just like Antioch,Pittsburg, Oakland, SF, etc. More crime, more homeless, more drugs, more ungodly, more Government control and that is what Democrats LOVE, control because they know better than the people. Brentwood used to be Republican 40+ years ago. Less government, more freedoms and more farms. People knew each other. Brighter Future of Brentwood is gone so housing does not matter. Look at San Francisco that is Brentwoods future. Yes I will move and take my values and money to a place that offers more peace and freedom than the cesspool that Brentwood will become if it doesnt reverse course and stop building anything but single family homes. Want higher density housing move to another city and take your values there. But when government gets involved it costs more to do little when compared to private industry. Government does not have to make a profit but forces private people to and then takes what they have and calls it good. I work for government and try to make changes but too many people high up are corrupt and greedy or truly beleive they are doing good but are blind or sinful in there ways. God Help us. Thank you for listening. Know it will probably not make a difference but I still have hope and it's NOT in Brentwood! High end housing to balance out what is forced upon us by state regulations.

Limit housing, too much housing and crime now with not enough utilities and infrastructure to support it.

No Rezone
Building new houses needs to slow down. Where is all the water going to come from for all those new houses when the state is telling homeowners to stop using water Stop Building without First developing Freeway and Road infrastructures to support the expansion of future building. Traffic congestion is very high due to poor road infrastructure to support the expansion of people. Stop the traffic issues caused by housing development. Stop using up all the open land. Hence why we settled in Brentwood.

It is growing too fast. Too many new housing tracks that are not affordable.

Safe housing that can accommodate the varied needs of all the community including the homeless.

Safe and happy Brentwood
Housing, living, recreational areas all equal and accessible to all citizens Brentwood is already overcrowded. Water is becoming scarce. Roads are overcrowded. We don’t need more houses.

Do not turn Brentwood into Antioch or Pittsburg ie, low income housing, increased crime and homelessness.

Current status for family housing
Structured short term housing for homeless
ot turn Brent DRAFTh
o not ta o not t
serve not illeg serve no
to live 40 years ago. to live 40
le who do not work. le who do n
with them and destroy with them and de
ood keeps building and it will od keeps building and
change them. Do not take the change them. Do not take th o or Washington DC wants. But I
ood has become Democrat cesspool
ore homeless, more drugs, more ungodly,
OVE, control bec OVE, con ause they know better than e the rs ago. Less government, more freedoms and s ago. Less government, m re of Brentwood is gone so housing does not rentwood is gone so s future. Yes I will move and take my values an es I will move an freedom than the cesspool that Brentwood will cesspool
g anything but single family homes. Want highe g anything but single family hom your values there. But when government gets in our values there. But when governme private industry. Government does not have to te industry. Government does not have takes what they have an at they have and calls it good. I work f any people high up are corrupt and greedy or tr gh up are corrupt and greedy or sinful in there ways. God Help us. Thank you fo ys. God Help us. Thank you fo ference but I still have hope and it's NOT in Bren erence but I still have hope and it' T
balance out what is forced upon us by state regu balance out what is forced upon us RA much housing and crime now with not enough much housing and crime now with no new houses needs to slow down. Where is all th houses needs to slow down. Where is all th es when the state is telling homeowners to stop e state is telling homeowners to stop op Building without First developing Freeway an out First dev future building. Traffic congestion is very high future building. Traffic conges expansion of people. Stop the traffic issues expansion of people. Stop the tra open land. Hence why we open land. Hence wh settled in Bren ettled in DR It is growing too fast. Too many new fast. Too many new Safe housing that can accommoda an acc
Safe and happy Brentwood Safe and happy Brentwo
Housing, living, Hou recreationa reatio
Brentwood is already ov Brentwood is already o
ed more houses.
sness.

City of Brentwood
2023-2031 Housing Element Update

Table 2 – Vision for the Future
No more development. People sell/rent out their own houses, not management companies.

Brentwood’s small town, farm feel is what draws people here and the city’s plans of development has completely uprooted our culture through destroying our land, water, and resources. Just for more money. Very sad.

I would like to see a stricter imposition on curbing housing expansion. Our schools are busting at the seams, our fire and emergency services are overworked, and our streets are becoming more and more congested. We are destroying the fabric of our community. We need to plan for more grocery stores, restaurants, and small businesses. Every open square inch of dirt does not need to be filled with some sort of housing just because we can.

Brentwood is an agricultural town. That’s what makes it special. Once you build on every acre of open space, our agricultural heritage will be gone forever. Preserve that which makes Brentwood special and beautiful.

Much like the current California Costal Commission, I would like to see near zero future home development of any type if an effort to retain the rural and agricultural nature of this valley. Look at how beautiful our coastline has remained, from Santa Barbara to the far north coast.

To stop over building. This once quaint town was never meant to be this size with the infrastructure currently in place Its dangerous to drive on most roads and certainly over highway 4 and Vasco. Take a deep breath and let other cities build out while we figure out how to fix our roadway and supporting elements. And for Gods Sake, leave the farms and open hills as is, please! Only housing that is supported fully by infrastructure, e.g., no over-crowding of schools, sufficient fire and police protection, no increase in traffic (our commute traffic situation is already not conducive to a healthy lifestyle). Well thought-out neighborhoods that put the top priority as the residents' wellbeing (both existing and future residents). Perhaps mixing neighborhoods with all ranges of income levels would be the best plan to ensure the highest quality of life for all.

A place where you can own property and enjoy peace from persons in your personal business.

No low income housing! Vey few apartments. We do not want to become the next Anitoch or Oakland.

A community with housing for all groups and all incomes.

High or higher density house if should have close highway 4 access so that our main roads are not jammed up. It’s sensible to build near the highway. Do not approve high density housing on the east side of town. Also, infrastructure such as schools, police, fire and roads must be supported as the city population grows. Parking should be considered with all housing development because households own multiple cars.

I feel that currently Brentwood has sufficient housing. The City is also maxed out on gas stations, fast food restaurants and 7/11, Quick Stop type stores. Brentwood should try to enhance the City with High Tech employment work complexes to provide living wage employment opportunities and reduce the need to commute as the City of Livermore has done.

At this point in Brentwood's development we need to focus on balancing housing and jobs. NO MORE residential building until infrastructure and jobs catch up.

Housing developments with enough green space at all income levels to enable human thriving.

No more @#%% homes.... Let's be like southern CA and run out of water...

No low income housing close to nice neighborhoods please Less retirement communities, more family based housing.

Affordable options for our children as they become working adults. Housing programs/ options for our homeless.
ousing development
ncomeDRA
higher density house if should have close highw r density house if should have close highw med up. It’s sensible to build near the highway. sensible to build near the highway. de of town. Also, infrastructure such as schools e of town. Also, infrastruc population grows. Parking should be consider population grows. Parking sho own multiple cars. RAFTop
st for m
s are busting at the s are bu
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does not need to be filled does not need to be fiT
Once you build on every acre of
serve that which makes Brentwood FT
nta Barbara to the far north coast.
l and agricultural nature of this valley. Look at and agricultural nature of u
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ld like to see near zero future home ld like to see near zero f TF ke, leave the farms and open hills as is, please! , leave the farms and open hills as is, p t while we figure out how to fix ou
most roads and certainly over highway 4 and Vas
as never meant to be this size with the infrastruc nt to be this siz ainly ove
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by infrastructure, e.g., no over rastructure, e.g., no ov -crowding of scho ing of sc e in traffic (our commute traffic situation is alre
ght-out neighborhoods that put the top priority borhoods that put the top priorit nd future residents). Perhaps mixing neighborho . Perhaps mixing neighborho an own property and enjoy peace from persons i an own property and enjoy peace f the best plan to ensure the highest quality of life the best plan to ensure the highesAF R ousing! Vey few apartments. We do not want to ousing! Vey few apartments. We do no ity with housing for all groups and all incomes. ty with housing for all groups and all incomes.

D
I feel that currently Brentwood has suffi rently Brentwood has su food restaurants and 7/11, Quick Stop and 7/11, Quick Stop High Tech employment work comp ment w
the need to commute as the Cit the need to commute as DR At this point in Brentwood's At this point in Brentwoo
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City of Brentwood
2023-2031 Housing Element Update

Table 2 – Vision for the Future
We need more fire and police before we expand housing.

Limited housing, I don’t want Brentwoood to have overgrowth and be like all those other cities in the East Bay. The beauty of this city is that it has open spaces. Stop developing! same as now. more golf courses
Growing with thoughts toward the future. Traffic and balance should be held in mind, thinking about our agricultural history and treating it with the respect it deserves.

LIMIT MORE HOUSING AS MUCH AS POSSIBLE , TOO MUCH TRAFFIC, CRIME ETC A good balance of jobs-related developments and single family housing. DRAFTciti mind, thinking about mind, th
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Brentwood 2023-2031 Housing Element
Appendix C: Summary of Community Engagement C-6
C.3 Joint CityCouncil and Planning CommissionWorkshop
This section contains all materials created for the June 1, 2022, joint Planning Commission and City Council workshop. Participants had the opportunity to make public comments verbally or in written form through the Zoom chat. A recording of the workshop is available in both English and Spanish on the Housing Element Update webpage: https://brentwoodhousingelement.com/. DRAFTnd C ten form t ten form
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Please join us to learn about the City’s proposed strategies to accommodate RHNA and the new policies that will be added to the Housing Element to maintain compliance with State laws and requirements.

When: Wednesday June 1, 2022 at 6:00PM
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QSAFT JOINT WORKSHOP AGENDA ITEM NO. 2
Meeting Date: June 1, 2022
Subject Title: Update and discussion of the 6th Cycle Housing Element Update, Regional Housing Needs Allocation (RHNA) sites strategies, and implications of new State legislation on the City’s policies and programs.

Prepared By: Ines Galmiche, Kimley Horn
Jennifer Hagen, Senior Planner
Submitted By: Alexis Morris, Community Development Director Erik Nolthenius, Planning Manager

PURPOSE AND RECOMMENDATION
This workshop includes an update and summary of RHNA and the sites strategies being used to identify sites to accommodate the City’s “fair share,” as well as a brief summary of key changes in Housing Element Law and possible implications as to City programs. The workshop will include a staff presentation, as well as public comments and City Council/Planning Commission discussion. No direction or action is being requested as part of this workshop.

PREVIOUS ACTION
The City Council authorized execution of an agreement for consulting services with Kimley-Horn to assist with preparation of the 2023-2031 (6th RHNA Cycle) Housing Element Update on October 12, 2021.

On April 14, 2022, staff presented an introduction to the Housing Element Update at a joint City Council/Planning Commission workshop.

BACKGROUND
The Housing Element is part of the City’s General Plan and is a comprehensive statement by the community of its current and future housing needs, including proposed actions to f acilitate the provision of housing to meet those needs at all income levels. State law requires periodic updating of the Housing Element; and thus, the element reflects the State’s housing goal of "attaining decent housing and a suitable living environment for every California family," as well as incorporating the unique concerns of the community. The current Housing Element, which was adopted by the City Council and certified by the State in 2015, covers the planning period from 2015 to 2022 (5th Cycle). The next Housing Element Update (the 6th Cycle) must be adopted by January 2023, to address the 2023-2031 planning period.

DISCUSSION
6th Cycle RHNA Process and Status
As part of the update, HCD requires each jurisdiction in the State to demonstrate capacity to meet their local “fair share” of the assigned Regional Housing Needs Allocation (RHNA), including total housing units across a series of affordability categories. The RHNA is then determined and assigned through a process led by HCD and regional Councils of Governments DRAFTg Element Update g Eleme , Regional Region
ategies, and implicationsof new
programs. progra
evelopment Director ent Director
ManagerAF
ON
e and summary of RHNA and the s summary of RHNA a ites strate he City’s “fair share “fair s ,” as well as a brief summ nd possible implications mplications as to City progra
on, as well as public comments and City Coun ic comments and City Coun n or action is being requested as part of this as
ON
cil authorized execution of an agreement for c authorized execution of an agreeme preparation of prepar the 2023-2031 (6th RHNA Cy
2, 2021.
pril 14, 2022, staff presented an introduction 2, staff presented an introduction ouncil/Planning Commission work ncil/Planning Commissio shop.

BACKGROUND
The Housing Element is part of the C The Housing Element is part of th the community of its current and futu of its current and fut the provision of housing to mee housing to mee
updating of the Housing Elem updating of the Housin
"attaining decent housing an "attaining decent housin
as incorporating the uniq
was adopted was ado by the City the Ci
m 2015 to 2022
ted by Janua
O
(for the Bay Area, this is ABAG/MTC). The City of Brentwood has been allocated 1,522 units at various income levels for the upcoming cycle.

As a key component of the updated Housing Element, the City must document, through a detailed, parcel-specific inventory, that there are sufficient sites available at the time of adoption of the element to accommodate the entirety of its RHNA. The adequacy of the sites inventory will be evaluated by the State Department of Housing and Community Development (HCD).

Although HCD will review the entire inventory, it pays particular attention to sites identified to accommodate the City’s lower-income RHNA, based on criteria intended to show the various sites’ realistic capacity to develop residential uses during the eight-year planning period of the Housing Element.

It is important to note that identifying sites to accommodate the RHNA is a planning requirement; it is not a mandate or quota for the City to construct housing units. While the City must report annually on production of housing relative to its RHNA numbers, there are no direct penalties at this time for failing to meet the allocation. That being said, there are more indirect consequences. For example, recent State law has implemented streamlining requirements and reduced local discretion over approval of housing projects, some of which is specifically targeted at jurisdictions whose housing production has fallen short of the RHNA.

Table 1 summarizes the 6th Cycle RHNA for the City of Brentwood. The RHNA is distributed among the following income categories, each of which represent relative affordability to households as a proportion of the Countywide Area Median Income (AMI).

Table 1: RHNA Allocation Breakdown
Income Category Percentage of Area
Median Income
Brentwood RHNA
Extremely Low Income (ELI)* <30% 402 Very Low Income (VLI)* 31-50% Low Income (LI) 51-80% 232
Moderate Income (MI) 81-120% 247
Above-Moderate Income (AMI) >120% 641
Total 1,522 Units
* The RHNA does not split out Extremely-Low and Very-Low Income Units; however, jurisdictions are required to account for both categories in the Housing Element’s Quantified Needs Assessment, typically assuming an even split between units in each income category.

Analysis of Existing/Baseline Zoning Capacity
In order to provide a comprehensive analysis of the City’s existing zoning capacity, staff has identified the following components to address the City’s 6th Cycle RHNA, discussed in f urther detail below.
x Existing Residential Zoning - This includes parcels zoned for residential uses with capacity to add new housing units within the City’s single-family and multi-family residential zoning districts.1
x Capacity in existing Specific Plans - This includes parcels within the PA-1 Specific Plan, Brentwood Boulevard Specific Plan, and Downtown Specific Plan that allow for residential uses with capacity to add new housing units. 1 Although all vacant or underutilized residential parcels may be included within the inventory, the focus will be on sites that can accommodate the largest number of below market rate housing at the highest densities. Therefore, not all residentially zoned sites will be listed.

DR
he RHNA does not split out Extremely oes not split out Extremely DRAFTt, me of ad me of a
he sites inven he sites
evelopment (HCD evelop
on to sites identified to on to sites
nded to show the various nded to show t
year planning period of the ear planning period
modate the RHNA is a planning modate the RHNA is a planning nstruct housing units. While the City
o its RHNA numbers, there are no direct
n. That being said, there are more indirect
s implemented streamlining mplemented streamlinin requirements an ng projects, some of which is specifically targ ects, some of whic s fallen short of the RHNA. of the RHNA
A for the City of A for t Brentwood. The RHNA is dis Th es, each of which represent relative affordab s, each of which represent relative Countywide Area Median Income (AMI). ntywide Area Median Income (AMI). reakdown RArcentage of Ar
dian IncomeABrent
ome (ELI)* <30% RA
e (VLI)*31-50% AR
LI) 51-80% RA
ncome (MI) ncome 81-120% RA
Moderate Income (AMI) oderate Income (AMI) >120% DRA-Low a urisdictio sdictions are required to account for both c ns are required to Needs Assessment, typically assuming an Needs Assessment, typically DR Analysis of Existing/Baseline Zonin DR
In order to provide a comprehensi vide a comprehensi
identified the following componen wing componen
detail below. d
x Existing Reside
capacity to ad y to ad
residential zo
Capaci
x Pipeline Projects - The “pipeline” of residential projects already entitled or expected to be entitled in the coming one- to two-year period, including projects under construction but which would not have building permits finaled by June 30, 2022. 2 This includes new projects to be approved under the City’s revised Affordable Housing Ordinance. x ADU Production - Other anticipated housing production, including ADU’s. HCD has issued a determination to allow local jurisdictions to “count” ADU production as a component of the sites inventory, based on a formula that considers the average annual number of ADU permits issued in the city over the last three years, multiplied over the Housing Element’s eight-year planning period.3
Together, existing residentially-zoned properties, pipeline projects, and ADUs constitute a baseline of zoned capacity that can accommodate the City’s RHNA. The difference between this number, and the RHNA in each category, represents the “buffer” in each category. Table 2 below summarizes the results of staff’s initial evaluation of existing residential development capacity and the difference between that number and the RHNA.

While changes may still be made before finalizing the baseline number of units and overall capacity, the initial analysis indicates that the City’s existing land use and zoning regulations allow adequate housing development to meet the full RHNA and that the City may thus not need to rezone any parcels. This initial analysis will be confirmed as staff finalizes the sites inventory.

If rezoning is determined to be needed, it is likely to be a small number of parcels.

Table 2: Summary of Preliminary Analysis of RHNA and Sites Strategies Summary of Preliminary Analysis of RHNA and Sites Strategies Very LowIncome
LowIncomeModerateIncome
Above
ModerateIncomeTotal
2023-2031 RHNA
Allocation 402 232 247 641 1,552
RHNA Strategies Under Existing Zoning
Projects Currently in
the Pipeline 17 39 1,481 1,537
PA-1 (Innovation
Center) 498 1,024 429 1,951
Vacant Residential
Land 134 44 835 1,013
Projected ADU
Production 80 41 14 135
Total Unit Potential 729 1,148 2,759 4,636
Buffer 15% 365% 330% 199%
2 The Housing Element 6th RHNA Cycle reporting period technically begins on July 1, 2022, meaning that units for which building permits are finaled (i.e., approved for occupancy) on or after this date, can be included in the 2023-2031 inventory.
3 ABAG has prepared a preliminary ADU Affordability Report, currently under review by HCD, intended as a basis to allocate ADU production into the various RHNA affordability categories. If HCD accepts the report’s analysis, ADU’s would be permitted to be counted at the following income levels: 30% Very Low Income, 30% Low Income, 30% Moderate Income, 10% Above Moderate Income. The inventory assumes this allocation, but it may need to be adjusted based on HCD’s direction.

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nance.
ng ADU’s. HCD h
ADU production as a ADU prod
iders the average annual iders the averag
ee years, multiplied over the e years, multiplied o
e projects, and ADUs constitute a e projects, and ADUs constitute a y’s RHNA. The difference between this
s the “buffer” in each category. Table 2
luation of existing residential development luation of existing resid and the RHNA. d the RH
inalizing the baseline number of units and baseline nu
at the City’s existing land use and zoning re g land u
o meet the full RHNA o meet t andthat the City th may t alysis will be confi will be con rmed as stafffinalize finaliz s the eded, it is likely to be a small number of parc it is likely to be a small number of pa minary Analysis of ysis o RHNA and Sites Strate A and Sites Stra ry Analysis of RHNA and Sites Strategies HNA and Sites Strategies RA Very Lo
Income
wmeAM
RA
HNA RA02
NA Strategies Under Exi R
cts Currently in ently in
Pipeline 17 RD
PA-1 (Innovation Innov
Center) 498 DR
Vacant Residential Vacant Residentia
Land 134 DR
Projected ADU
Production
ntial
Buffer
ousing Ele
which
h
Policies and Program Considerations and Implications of New State Law As part of the Housing Element Update, staff will provide an evaluation and review of the existing policies and programs, which will provide the implementation status of the current Housing Element programs. The purpose of this is to evaluate which programs have been successful and should be continued, and which programs have been ineffective and should be eliminated or modified. The evaluation is required by state law and will also include a comprehensive review of existing policies and programs to determine if there are any gaps to be addressed, or programs that could be considered for inclusion in the Housing Element to better meet community housing goals and to verify that all new legislative requirements are being addressed and are integrated into the Housing Element update.

In recent years, the State has adopted a significant amount of new housing-related legislation, which will influence and shape the current Housing Element Update. These include but are not limited to the following:
x Housing Crisis Act (SB 330) - Makes changes to land use and zoning law to encourage housing production, by, among other things, limiting the scope of local review of qualifying housing projects to objective standards only, limiting the number of public hearings for projects, and shortening review timeframes. x Adequate Housing Element Sites (AB 1397) - Strengthens local governments’ obligation to identify a supply of adequate sites available to meet their share of regional housing needs at all income levels, and make those sites available early in the housing element planning period with access to public infrastructure.
x No-Net-Loss (SB 166) - Requires jurisdictions to maintain adequate sites to continuously accommodate its remaining regional housing needs allocation throughout the housing element planning period.

An initial analysis of the existing programs indicate that some modifications or additions to our current goals and policies will be required to reflect changes in State law and provide more specificity in terms of City actions. Modified or new program actions that will need to be addressed in the Housing Element will include the following:
x Facilitation of Accessory Dwelling Unit production and monitoring – New legislation (AB 68, AB 881, SB 13, AB 587, AB 670, AB 671) requires Cities to promote the development of ADUs and establish streamlined approval processes for ADU applications. As future ADU development is proposed as a strategy to accommodate RHNA, the City must establish specific actions to facilitate development over the next eight years.
x Farmworker and Employee Housing – California Health and Safety Code Sections 17021.5 and 17021.6 require agricultural employee housing to be permitted by-right, without a conditional use permit (CUP), in single-family zones for six or fewer persons and in agricultural zones with no more than 12 units or 36 beds. x Senate Bill 35 Streamlining Procedures - Streamlines multifamily housing project approvals, at the request of a developer, in a city that fails to issue building permits for its share of the regional housing need by income category. In an SB 35 City, approval of a qualifying housing development on qualifying site is a ministerial act, without CEQA review or public hearings.

DRAFTh
nd sho
l also inclu
re are any gaps to b re are an
sing Element to better sing Elem
requirements are being requirements
new housing new ho -related legislation, gislatio
Update. These include but are not Update. These include but are not s to land use and zoning law to encourage
hings, limiting the scope of local review limiting the scope ve standards only, limiting the ards only, limitin number of p review timeframes.
es (AB 1397) es (AB 1 - Strengthens local governmen ens local uate sites available to meet their share of re ate sites available to meet their shar , and make those sites available early in the make those sites available early in th cess to public infrastructure blic infrastructure.
66) - Requires jurisdictions to maintain adeq urisdictions to maintain adeq s remaining regional housing needs alloca s remaining regional housing n ning period.
sis of the existing programs indicate that of the existing programs indicate t so s and policies s and p will be required to be r reflectch in terms of City actions. n terms of City actions. Modified or ne ed in the Housing the Hou Element will include the fo
x Facilitation of Accessory Dwellin Facilitation of Ac
legislation (AB 68, AB 881, SB 13, A 68, AB
the development of ADUs and the development of AD
applications. As future ADU d ations. As future AD
RHNA, the City must establ he City must estab
eight years.
x Farmworker and E r an
17021.5 and 1702 nd 17
without a condi without a cond
and in agricu
Senate
pro
x Safety Element Update and Environmental Justice Policies – SB 1035 requires that the City revise the Safety Element to identify flood hazards and address the risk of f ire hazards in certain lands upon each revision of the Housing Element. SB 1000 requires that the City incorporate environmental justice policies within the General Plan. x Density Bonus Ordinance Update – AB 2753 requires local governments to provide determinations to developers regarding the amount of density bonus for which a development is eligible, all reductions in parking requirements for which the applicant is eligible and whether the applicant has provided adequate information for the local government to make a determination regarding any requested incentives, concessions, waivers or reductions in required parking. AB 2372 authorizes cities or counties to grant a developer of an eligible housing development under the State Density Bonus Law a floor area ratio bonus in lieu of a bonus based on dwelling units per acre. Additionally, SB 1227 allows student housing projects where at least 20 percent of the units are affordable for lower income students to receive a 35 percent density bonus, as well as requires the development to provide priority to students experiencing homelessness. x Affirmatively Further Fair Housing – AB 686 requires a public agency to administer its programs and activities relating to housing and community development in a manner to affirmatively further fair housing and not take any action that is inconsistent with this obligation. Additionally, an assessment of fair housing practices must now be included in upcoming housing elements.
x Low-Barrier Navigation Center – AB 101 requires local governments to provide “by right,” CEQA-exempt approvals to certain qualifying navigation centers that move persons experiencing homelessness into permanent housing, as well as creates additional incentives for cities to comply with their mandates to plan for sufficient housing under Housing Element law.

NEXT STEPS
As noted, the creation of the sites inventory is an important initial step in the Housing Element process. Following this meeting, staff and the consultant team will continue to develop and refine the analysis of existing sites and solidify the existing capacity that can be used to address our RHNA.

Staff also notes that in addition to working on reviewing the sites inventory and goals and policies, staff and the consultant team are continuing to advance other components of the Housing Element. These include:
x Conclusion and summary of input from the initial on-line community survey. The survey will continue to be posted through Friday, June 10th and staff encourages everyone who wished to participate to please visit https://brentwood.info/housing_element_survey As of Friday May 27th, there have been 459 submissions of the Community Survey. x Completion of the Public Review Draft of the 2023-2031 Housing Element Update that will address all of the mandatory informational requirements and analyses supporting the Housing Element, including findings of the required housing needs assessment; analysis of constraints to housing; and evaluation of existing Housing Element policies and programs. This draft report is anticipated to be published and presented to the City Council and Planning Commission in July ahead of submission to California Department of Housing and Community Development (HCD).

DRAFTan.
nments to pro nments
bonus for which bonus
which the applicant is which the
information for the local information for
ed incentives, concessions, ed incentives, conces
rizes cities or counties to grant rizes cities or counties to g er the State Density Bonus Law a er the State Density Bonus Law dwelling units per acre. Additionally, dwelling units per acre. Additionally, e at least 20 percent of the units are
a 35 percent density bonus a 35 percent density , as well as to students experiencing homelessness. o students experiencing AB 686 requires a public agency to administe equires a public ousing and community development in a ma mmunity de
and not take any action that is inconsisten action th
ssment of fair housing practices must now b ssment of fair housing practices on Center – AB 101 requires local govern
pt approvals to certain qualifying navigati to certain qualifying naviga ncing homelessness into permanent hou to permanent hou
tives for cities to comply with their mandates tives for cities to comply with th ng Element law. ng Element law.
e creation of the sites inventory in is an importa impo Following this meeting, staff and the cons
he analysis of existing sites and solidify the e alysis of existing sites and solidify the e HNA.

Staff also notes that in addition to workin Staff also notes that in addi policies, staff and the consultant team , staff and the consulta Housing Element. These include:
x Conclusion and summary n and summary
will continue to be poste e to b
wished to participate articip
As of Friday May 2 ay May
x Completion o
will addres
Housing
co

CONCLUSION
Staff is recommending that the City Council and Planning Commission review, discuss, and receive public comments on the Housing Element Update RHNA sites strategies, and implications of new State legislation on the City’s policies and programs. No direction or action is being requested as part of this workshop. DRAFTn
Brentwood 2023-2031 Housing Element
Appendix C: Summary of Community Engagement C-7
C.4 Joint CityCouncil and Planning CommissionWorkshop
This section contains all materials created for the July 21, 2022, City Council workshop. Participants had the opportunity to make public comments verbally or in written form through the Zoom chat. A recording of the workshop is available in both English and Spanish on the Housing Element Update webpage:
https://brentwoodhousingelement.com/. DRAFTrtic
chat. A rec chat. A
nt Update webpa nt Upda
JULY 21, 2022

SPECIAL CITY COUNCIL AGENDA
*IMPORTANT NOTICE ABOUT PUBLIC COMMENTS AND MEETING PARTICIPATION* UPDATED APRIL 21, 2022
Consistent with Contra Costa County Health orders, and in accordance with California Government Code Section 54953(e) concerning teleconference meetings, this City Council meeting will be held exclusively via teleconference, using the Zoom video conferencing system. At this time, public participation will be available exclusively via telephone or teleconference, using the Zoom video conferencing system.

How to View and Participate
The public is invited to participate in the City Council meeting and offer comments of up to 3 minutes (or as may otherwise be determined by the Council) using any of the following methods:

1. Zoom: www.brentwoodca.gov/vcc or Zoom Webinar ID: 760 1397 0037 Phone Numbers:

Dial (for higher quality, dial a number based on your current location):

US: +1 720 707 2699 or +1 253 215 8782 or +1 346 248 7799 or +1 646 558 8656 or +1 301 715 8592 or +1 312 626 6799 or 888 788 0099 (Toll Free) or 833 548 0276 (Toll Free) or 833 548 0282 (Toll Free) or 877 853 5247 (Toll Free)
As the City Council Chamber will not be open to the public, individuals may view and participate in the meeting with this link. During the meeting, each period for public comment will be announced, and participants may use the “Raise Hand” feature on Zoom to request to speak. The meeting host will call on you, by name, and enable your microphone when it is your turn to speak.

In order to ensure the orderly administration of the meeting using this method, providing your name is encouraged, but is not required. (If you need instructions on how to use this feature, please contact the City Clerk by noon of the meeting date at [email protected] or 925.516.5182.)
The public may view the meeting via one-way video feed by selecting the video option at the City Council Agendas’ link on the City webpage at www.brentwoodca.gov

2. Telephone
If you wish to comment during the meeting via telephone, you may “raise your hand” virtually on most devices by pressing *9, and you will be called upon when it is your time to speak. After speaking, please press *9 again to remove the “raise your hand” feature. If that feature does not work on your device, please email [email protected] in advance of the meeting where possible. The request must contain in the subject line “Request to Speak – Agenda Item #” and should include name and full phone number that will be used to call in. In order to ensure the orderly administration of the meeting using this method, providing your name is encouraged, but is not required.

3. E-mail
Public comments can also be submitted via e-mail to [email protected]. Any public comments received up until 3:00 p.m. of the meeting date will be:
 distributed to the Council via email before the meeting,  posted online for public inspection at https://www.brentwoodca.gov/councilmeetingonline, and
 later summarized in the meeting minutes.

Public comments received after 3:00 p.m. of the meeting date, but prior to the start of the meeting, will be emailed to the City Council,
DRAFT
posted online within one day following the
IPATION* IPATIO
lifornia Government Code lifornia Gove
eting will be held exclus eting will be held ively
ime, public participation will be me, public participation deo conferencing system.
and offer comments of up to 3 minutes (or
the following methods: the following method
ebinar ID: binar ID 760 1397 0037
based on your current location): your current loc
5 8782 or +1 346 248 7799 or +1 646 558 86 46 248 779
or 888 788 0099 (Toll Free) or 833 548 0276 (T Free) o
53 5247 (Toll Free) 53 5247 (
will not be open to the public, individuals may v ot be open to the public, individuals ma ink. During the meeting, each period for pu ring the meeting, each period for pu ants may use the “Raise Hand” feature on Zoom the “Raise Hand” feature on Zoom on you, by name, and enable your microphone w and enable your microphone w the orderly administration of the meeting using he orderly administration of the meeting using ged, but is not required. (If you need instructio If you ne ct the City Clerk by noon of the meeting dat ct the City Clerk by noon of the 5182.)
ublic may view the meeting via one ublic may view the mee -way vide way v City Council Agendas’ link on the City webpa
Telephone
If you wish to comment during the meeting to comment
most devices by pressing *9, and you w most devices by press speaking, please press *9 again to rem peaking, please press *9 work on your device, please email c rk on your device, please possible. The request must conta e. The request must co should include name and full p clude name and full p
orderly administration of the inistration of the
is not required.

3. E-mail
Public comments
comments rece
 distri
 po
JULY 21, 2022

SPECIAL CITY COUNCIL AGENDA
PAGE 2 OF 2
meeting, and will be summarized in the meeting minutes. The City cannot guarantee that its network, website, and/or the Zoom system will be uninterrupted. In the event of an interruption to the broadcasting of the meeting using the telephone or internet-based options listed above, the City Council will take no further action on items on the agenda until public access to the meeting via either option is restored. To ensure that the City Council receives your comments prior to taking action, you are strongly encouraged to submit them in advance of the meeting by 3:00 p.m.

As e-mails containing public meeting comments are part of the official record, note that personal contact information may be published if it is included with your e-mail.

The Closed Captioning provided via Zoom is auto generated. It is not the official record and is provided as a convenience.

Pursuant to Section 54956 of the California Government Code, a special meeting of the City Council is hereby called for JULY 21, 2022, at 6:00 p.m. or as soon thereafter as possible.

Following the staff presentation of the agenda item, and before direction is provided, public comment will be taken.

CALL TO ORDER/ROLL CALL: A special meeting of the City Council A. Housing Element Update - Introduction of and direction to staff regarding the analysis of existing residential zoning capacity within the City including review of a list of potential sites under consideration for inclusion in the Housing Element Sites Inventory for the 2023-2031 (6th Cycle) Housing Element Update, as well as an evaluation of site inventory and affordability assumption strategies to address the City’s Regional Housing Need Allocation (RHNA). (Alexis Morris/Jennifer Hagen)

ADJOURNMENT

POSTING STATEMENT
On July 7, 2022, a true and correct copy of this agenda was posted on the City Hall Bulletin Board, outside City Hall, 150 City Park Way, Brentwood, CA 94513 and at our website www.brentwoodca.gov A complete packet of information is available for public review at City Hall or on our website at www.brentwoodca.gov DRAFTn inter
listed abo listed a
ccess to the mee ccess to
our comments prior t our com
ance of the meeting by ance of the
official record, note that personal official record, note that pe r e-mail. ma
erated. It is not the official record and is
he California Government Code, ornia GovernmenFT
City Council is hereby called for s hereby ca
p.m. or as soon thereafter as possible. reafter a AF
of the agenda item agenda ite , and before directio efore dir L: A special meeting of the City Council eeting of the City Council t Update - Introduction of and direction to staff re and dire oning capacity within the City including review oning capacity within the City inc ion for inclusion in the Housing Element Sites In ion for inclusion in the Housing Eleme g Element Update, as well as an evaluation of g Element Update, as well as an evaluatio s egies to address the City’s Regional Ho the City’s Regional H Morris/Jennifer Hagen ris/Jennifer Hagen)

OURNMENTDRPOS
OnJuly 7, 2022, a true and correct copy 22, a true and correct outside City Hall, 150 City Park Way, Br 150 City Park Way, B A complete packet of informatio of in
www.brentwoodca.gov D

MEMORANDUM
DATE: July 6, 2022
TO: Mayor and City Council

FROM: Jennifer Hagen, Senior Planner
Alexis Morris, Community Development Director
SUBJECT: July 21, 2022 Housing Element Workshop Executive Summary Workshop Objectives
At the July 21, 2022 Workshop, staff is requesting the City Council’s input and direction on the list of sites to be carried forward for analysis in the Housing Element Update. The workshop is intended to accomplish the following objectives:

1. Present the initial framework for the site inventory, including HCD accepted assumptions and principles that may be used to develop the inventory.

2. Introduce the analysis of existing residential zoning capacity within the city, including the preliminary site list from which the site inventory will be compiled, and evaluation of the number of units for which additional sites may be needed to address the City’s RHNA utilizing three different strategies that include varying affordability assumptions and ADU projection assumptions.

3. Receive direction from the City Council on which Site Inventory Strategy, as described in the Site Inventory and Affordability Assumption Strategies section of this report, to move forward with when preparing affordability projections and the Draft Housing Element Update.

Developing the Site Inventory
The attached staff report provides background information on the framework for the site inventory, including HCD accepted assumptions and principles as outlined in the HCD Site Inventory Guidebook, which is attached for reference.

To move forward in the planning process in drafting the Housing Element Update, it is imperative that the City Council provide direction on which strategies should be used in forming baseline site inventory and affordability assumptions. Important things to consider when selecting the baseline site inventory strategy are:

1. Planning for vs. constructing housing: The City is not required to build housing, but is required to plan for sufficient housing to meet its regional housing need. All of the strategies summarized below utilize the City’s existing General Plan designations and do not require any changes to the General Plan.

DRAFTctor
hop Executive Exe SummaryFT
questing the City Council’s y Council’ input and directio alysis in the Housing Element Update. The
bjectives:
ork for the site inventory, including HCD acc the site inventory, including HCD ac y be used to develop the inventory. o develop the inventory. lysis of existing residential zoning capacity w sis of existing residential zoning capacity w e list from which the site inventory will be co e list from which the site invento nits for which additional sites may be need nits for which additional sites m ree different strategies that include varying different strategies that include on assumptions. on ass
eceive direction dire from the City Council on om the City Council on whi the Site Inventory e Invento and Affordability Assump
forward with when preparing affordabili with when preparing affordabili Update.

Developing the Site Inventory DR
Theattached staff report provides report provide
inventory, including HCD accepted ing HCD accepted
Inventory Guidebook, which is at ok, w
To move forward in the To move forward in th
imperative that the City C imperative that the City
aseline site invento
ecting the baselin
lannin

2. Importance of a buffer and “no net loss” requirements: Each time the City approves a project on a site listed in the housing element, it must compare the project with both the number of units shown in the housing element and the projected income level. If either the project has fewer units than shown in the housing element, or the units are developed at a different income level, the City must demonstrate that it still has enough properly zoned sites to meet the RHNA at all income levels. If there are not enough properly zoned sites in the inventory, the City must identify and make available additional sites within 180 days, which may require rezoning.

3. Penalties for not constructing all units assigned by the RHNA: If fewer units are built in the City than included in the City’s RHNA, at present the only consequence is that developers may submit applications under SB 35, which is described in further detail in the report.

4. Penalties for not having a Housing Element Approved by HCD: Cities with non-compliant Housing Elements may be referred by HCD to the Attorney General or may be sued by private parties. Certain state housing funds also require that the City have a housing element approved by HCD. If a court agrees that the housing element does not comply with state law, the court may restrict the City’s ability to approve certain projects or order the City to approve certain projects, and the City would likely be required to pay attorney’s fees to the successful plaintiffs.

The attached staff report includes a draft site inventory table and map for reference that shows existing vacant/underutilized residential parcels, their buildable acreage, zoning and land use designations, and allowable and mid-range densities.

There are also three potential strategies identified that would allow the City to move forward with the provided draft site inventory that would not require any rezoning of sites within the City at this time. Staff has provided analysis of each strategy that includes a description of the scenario’s affordability assumptions, the buffer each strategy would provide, the likelihood of HCD acceptance, the likelihood of requiring no net loss, and CEQA implications. The strategies provided are only a sample of the strategies and assumptions that could be utilized to address the City’s RHNA. There will be an opportunity at June 21st workshop to use in real time, a model to make affordability and site assumption adjustments as necessary. A summary of each of the three identified strategies are included on the following page. DRAFThe till has till has
e are not en e are n
and make availab and ma
A: If fewer units are built in If fewer units ar FT
th only consequence is
h is described in further deta
proved by HCD: Cities with non proved by HCD: Citie -compliant to the Attorney General or may be sued by
ds also require that the City have a housin also require that the grees that the housing element does not co hat the housing el he City’s ability to approve certain projects o ity to approv ects, and the City would likely be require y would
plaintiffs. plainti
a draft site inventory table and map for refe aft site inventory table and map for re sidential parcels, their buildable acreage, z their buildable acreage, z and mid-range densities e den .
tential strategies ential stra identified ntified that would allow that w th e inventory that would not require any u rezo
as provided analysis of each strategy tha as provided analysis of each s dability assumptions, the buffer each strate dability assumptions, the buffer eac nce, the likelihood of requiring no net loss, a nce, the likelihood of requiring no net los re only a sample of the strategies and assu e only a sample of the strategies and assu s RHNA. There will be an opportunity at Jun NA. There will be an opportunity at Jun ke affordability and site assumption adjustm bility and site assumption adjustm ee identified strategies are ategies are included on the fo Strategy 1 Strategy 2 Strategy 3
Description No Rezoning Required,
Reduced Affordability
with Increased ADU
Assumptions
No Rezoning Required,
HCD Approved
Methodology
No Rezoning Required,
HCD Approved
Methodology with
Conservative
Affordability
Assumptions
HCD-supported No Yes Yes
Affordability
Assumptions*
21% Low and Very
Low, and 6% Moderate
100% Low and Very
Low, and 100%
Moderate
30% Low and Very
Low, and 10%
Moderate
Affordable Unit
Potential
VL/L: 635 units
Mod: 264 units
AMod: 4,183 units
Total: 5,082 units
VL/L: 2,321 units
Mod: 851 units
AMod: 1,775 units
Total: 4,947 units
VL/L: 755 units
Mod: 347 units
AMod: 1,405 units
Total: 4,947 units
Buffer 0% Low/Very Low,
7% Moderate-, and
553% Above Moderate
266% Low/Very Low,
245% Moderate-, and
177% Above Moderate
19% Low/Very Low,
40% Moderate-, and
500% Above Moderate
No Not Loss
Implications
Highly likely to trigger
no net loss
Least likely to trigger no
net loss
More likely than
Strategy 2 to trigger no
net loss
*Affordability assumptions are based on the site inventory with the assumption that sites that allow 30 du/ac (default density) or more can accommodate capacity for lower-income units and sites that allow 15 to 25 du/ac can accommodate capacity for moderate-income units.
5th Cycle Housing Element Sites
Lastly, for reference purposes, staff has included the adopted 2015 5th Cycle Housing Element Sites Inventory, broken down between multi-family and single-family residential parcels. Staff has included columns that indicate their buildable acreage, zoning and land use designations, the stated capacity in the previous inventory, whether the sites were developed during the planning period, how many units were developed, whether the site is recommended to be carried over into the current cycle, and if not carried over, why. It should be noted that staff is not recommending to carry over any sites that do not yield a minimum of 10 units. DRAFTng proved
odology
servati
Affordabil
Assumption
YeFT
y and Ve
0%
: 1,775
4,947 u
units
units
M
AM
To T AFow/Very Low, AFerate-, and
ModeraFT A
ger AFLeast likely to trigger no
net loss FSt
net AF
d on the site inventory with the assumption that sites t nventory with the assumption that sites t ate capacity for lower-income units and sites that allow income units and sites that allo derate-income units. AF R
Element Sites
rence purposes, staff has included the adop rence purposes, staff has included the ory, broken down between multi broken down betwe -family and mily a ded columns that indicate their buildable ac d columns that indicate their buildable ac ted capacity inthe previous inventory, wh
ning period, how many units were develop how many units were develop rried over into the current cycle, and if not ried over into the curren not recommending to carry over any sites th not recommending to carry ov

CITY COUNCIL WORKSHOP AGENDA ITEM A
Meeting Date: July 21, 2022
Subject Title: Housing Element Update - Introduction on the analysis of existing residential zoning capacity within the city including review of a list of potential sites under consideration for inclusion in the Housing Element Site Inventory for the 2023-2031 (6th Cycle) Housing Element Update, as well as an evaluation of Site Inventory and affordability assumption strategies needed to address the City’s Regional Housing Need Allocation (RHNA).

Prepared By: Jennifer Hagen, Senior Planner
Submitted By: Alexis Morris, Community Development Director Erik Nolthenius, Planning Manager

PURPOSE AND RECOMMENDATION
Work is proceeding on the 2023-2031 (6th Cycle) Housing Element Update, which among other components, will include an updated inventory of sites that can accommodate the City’s Regional Housing Need Allocation (RHNA). As a starting point for creating the Housing Element Updated Site Inventory, staff has identified a list of sites that under the existing General Plan and Zoning designations allow for residential development at various densities. Staff has provided a map (Attachment 4) and list identifying each site (Attachment 3), as well as a calculation of the estimated yield of units for each based on the mid-point density allowed in each Zoning District or General Plan designation.

Workshop Objectives
At tonight’s workshop, staff requests the City Council’s input and direction on the list of sites to be carried forward for analysis in the Housing Element Update. This workshop is intended to accomplish the following objectives:

1. Present the initial framework for the site inventory, including HCD accepted assumptions and principles that may be used to develop the inventory.

2. Introduce the analysis of existing residential zoning capacity within the city including the preliminary site list from which the site inventory will be compiled, and evaluation of the number of units for which additional sites may be needed to address the City’s RHNA utilizing three different strategies that include varying affordability assumptions and ADU projection assumptions.

3. Receive direction from the City Council on which Site Inventory Strategy, as described in the Site Inventory and Affordability Assumption Strategies section of this report, to move forward with when preparing affordability projections and the Draft Housing Element Update.

DRAFTalysis of existing residential alysis of existing resi ofa list of potential sites under a list of potential sites ement Site Inventory for the
Update, as well as an Update, evaluation of ation of
tion strategies tra needed to address the
tion (RHNA). tion (RH
Development Director t Director
ng ManagerAF
TION
3-2031 (6th Cycle) Housing Element Update th Cycle) Housing Element Update n updated inventory of sites that can ac nventory of sites that can a llocation (RHNA). As a starting point for crea . As a starting point for crea , staff has identified a list of staff has identified a list of sites that unde ations allow for residential development a ations allow for residential dev (Attachment (Attachm 4) and list identifying and list identifyin each si he estimated yield of units for each based he estimated yield of units for each District or General Plan designation.
op Objectives bjectives R
night’s workshop, staff requests the City Cou City Cou
carried forward for ana for analysis in the Housing ly
accomplish the following objectives: accomplish the following obje

1. Present the initial framework for ent the initial framewor and principles that may be us

2. Introduce the analysis o e an
preliminary site list fro site l
number of units fo units
utilizing three dif
projection ass
Receive
Si
2 PREVIOUS ACTION
The City Council authorized execution of an agreement for consulting services with Kimley-Horn to assist with preparation of the 2023-2031 (6th RHNA Cycle) Housing Element Update on October 12, 2021.

On April 14, 2022, staff presented an introduction to the Housing Element Update at a joint City Council/Planning Commission workshop.

On June 1, 2022, staff presented an update on the Housing Element Update including Regional Housing Needs Allocation (RHNA) site strategies, and implications of new State legislation on the City’s policies and programs. The City Council directed staff to return with a draft site inventory when available for review.

BACKGROUND
The Housing Element is part of the City’s General Plan and is a comprehensive statement by the community of its current and future housing needs, including proposed actions to facilitate the provision of housing to meet those needs at all income levels. The current Housing Element, which was adopted by the City Council and certified by the State in 2015, covers the planning period from 2015 to 2022 (5th Cycle). The next Housing Element Update (the 6th Cycle) must be adopted by January 2023, to address the 2023-2031 planning period1 .
6th Cycle RHNA
As has been previously outlined to the City Council, the City has been assigned a 6th Cycle RHNA of 1,522 housing units at various levels of affordability. As a key component of the updated Housing Element, the City must document, through a detailed, parcel-specific inventory, that there are sufficient sites available today to accommodate the entirety of its RHNA. If the City does not have enough adequate sites identified and currently zoned to accommodate the assigned RHNA, additional sites will need to be identified and ultimately rezoned.

The adequacy of the site inventory will be evaluated by the State Department of Housing and Community Development (HCD). Although HCD will review the entire inventory, it pays particular attention to sites identified to accommodate the City’s lower-income RHNA, based on criteria intended to show the various sites’ realistic capacity to develop during the eight-year planning period of the Housing Element.

Ramifications of Failure to Meet RHNA
At present, there is no requirement that enough homes be constructed in a city or county to meet the community’s RHNA. If fewer units are built in the City than included in the City’s RHNA, at present the only consequence is that developers may submit applications under SB

35. SB 35 allows developers to submit housing developments meeting certain requirements, including specified percentages of affordable housing and payment of prevailing wages, if fewer units are being constructed in the city to meet its above moderate, very low, or low-income RHNA requirements. Projects eligible for SB 35 must be approved ministerially without CEQA review under strict timelines. In the current 5th cycle, most jurisdictions in California, including Brentwood, are subject to SB 35. Brentwood must streamline projects that apply for SB 35 approval, set aside at least 50% of units for lower-income residents, and meet all of the other requirements. To date, no such project has been submitted to the City.

HCD has also formed the Housing Accountability Unit (HAU) to investigate violations of housing laws and may refer violators to the Attorney General. HCD has emphasized that it expects cities 1 It should be noted that although January 31, 2023 is the statutory deadline to have the Housing Element adopted for our jurisdiction, there is a 120-day grace period that is allowed in order to gain compliance with HCD DRAFTe at a jo e at a j
ate including includ Regional
new State legislation on new State leg
to return with a draft site
and is a comprehensive statement by
, including , includ proposed actions to facilitate sed actions to facilitate come levels. The current Housing Element,
ied by the State in 2015, covers the plannin d by the State in 2015, Housing Element g Eleme Update (the pdate 6th Cycle) mus 3-2031 planning period ning period1
.
the City Council City Counc , the City has been assigne as been various levels of affordability. As a key c ous levels of affordability. As a key e City must document, through a deta must document, through a deta fficient sites available today to accommod available today to accommod not have enough adequate h adequate sitesidentified
gned RHNA, additional sites will need to b ned RHNA, additional sites will need to b of the site inventory will be evaluated by the of the site inventory will be evaluated Development (HCD). Although HCD will Development (HCD). Although HCD w ttention to sites identified to accommodate t tention to sites identified to accommodate ntended to show the various sites’ realistic ded to show the various sites’ realistic ng period of the Housing Element. of the Housing Element.

Ramifications of amifications Failure to Meet ure to M RHNA DR At present, there is no requirement that At present, there is no require meet the community’s RHNA. If fewer If DR
RHNA, at present the only consequ
s developers to s Dperce
units are being constru
RHNA requirements. Pr
review under strict tim
rentwood re subje
oval, set aside
ments. To
3 to implement the programs included in their housing elements. To date, its emphasis has been on programs that propose changes in zoning.

FRAMEWORK CONSIDERATIONS FOR DEVELOPING THE SITES INVENTORY The following outlines some of the key assumptions and “building blocks” that provide the framework for developing the sites inventory that are both acceptable to HCD and were used to develop the analysis presented to the City Council on June 1st.

Zoning Capacity and Density Assumptions for Initial Inventory City staff and the consultant team have evaluated the City’s residential land inventory (i.e. sites zoned for residential use “today” with capacity to accommodate additional development) starting with a review of the adopted 2015 (5th Cycle) Housing Element Site Inventory which is included in Attachment 6a and 6b for reference. In addition to the existing capacity, staff and the consultant team also reviewed the “pipeline” of residential projects already entitled in the coming one- to two- year period and Accessory Dwelling Unit projections (ADU projections are described in greater detail further in the report). This comprehensive list of sites with associated map are included as Attachment 3 and 4, and together, constitute a baseline of properties that can potentially accommodate at least a portion of the City’s RHNA. A map of the City showing all properties that have general plan designations that allow for residential development has been included for reference as Attachment 2. It should be noted that the PA-1 Specific Plan, Brentwood Boulevard Specific Plan, and Downtown Specific Plan have multiple areas which allow for residential and mixed use development under the various designations, but only have one General Plan designation for the entire specific plan area; therefore, the General Plan map does not depict all of the residential sites allowed under the specific plans. “No Net Loss” Law and Housing Buffer
HCD recommends identifying sites with zoning capacity sufficient to provide between 15 and 30 percent more units than the identified lower income RHNA, often called the housing “buffer”2 .

This is to ensure that the City has enough properly zoned sites throughout the eight-year planning period. Under a provision of state law called the “no net loss” law, each time the City approves a project on a site listed in the housing element, it must compare the project with both the number of units shown in the housing element and the projected income level. If either the project has fewer units than shown in the housing element, or they are developed at a different income level, the City must demonstrate that it still has enough properly zoned sites to meet the RHNA at all income levels. For instance, if a site is identified as suitable for 100 lower income units, but a project is proposed with 100 units but only 10 lower income units, then the City must show that it still has enough properly zoned sites to accommodate its lower income RHNA. If there are not enough properly zoned sites in the inventory, the City must identify and make available additional sites within 180 days, which may require rezoning. A buffer is particularly important for sites shown as suitable for lower income housing.

General Plan Consistency
In addition to including a buffer, staff recommends maintaining consistency with the General Plan to estimate potential unit capacity for the sites, using an “average or mid-point” density for all sites. Alternatively, the City could require a minimum density on each site and use that to calculate realistic capacity3
. The mid-point assumption can be supported by the General Plan and past project approvals (development at or above the mid-point density).

Based on guidance provided by HCD for higher-density housing sites, the inventory needs to reflect a realistic capacity that takes account aspects like physical constraints, necessary on-site infrastructure and circulation, parking, and development standards like height and setback requirements. Using an average or mid-point density for high-density sites will help to align the 2 Page 22 of the HCD Sites Inventory Guidebook included as Attachment 1 3 Page 19 of HCD Sites Inventory Guidebook included as an Attachment 1 DRAFTp
d were
l land inventory (i.e. sites l land inventor
tional development)starting
ite Inventory which is included ite Inventory which is inc existing capacity, staff and the existing capacity, staff and ojects already entitled in the coming ojects already entitled in the coming nit projections nit proje (ADU projections are
omprehensive list of sites with associated
her, constitute a baseline of properties that
the City’s RHNA he City’s . A map of the City showin A map ions that allow for residential development at allow for reside

2. It should be noted that the PA be noted tha -1 Specifi Downtown Specific Plan fic Plan have multiple are
elopment elopm under the various designations de , b
entire specific plan area entire specific ; therefore,the Gen al sites allowed under the specific plans es allowed under the specific plans. ng Buffer RA
ng sites with zoning capacity sufficient to pr ning capacity sufficient to pr the identified lower income RHNA, often c
at the City has enough properly zoned si at the City has enough prope nder a provision of state law called the “no nder a provision of state law cal ect on a site listed in the housing element ect on a site listed in the housing ele , it f units shown in the housing element and th f units shown in the housing element an fewer units than shown in the housing elem
evel, the City must demonstrate that it still h the City must demonstrate that it still h A at all income levels. For instance, if a site come levels. For instance, if a site ts, but a project is proposed with 100 units b t is propose show that it still has enough properly zoned how that it still has enough there are not enough properly zoned site there are not enough properly available ava additional sites within 180 da dditional sites within 1 important for sites shown as suitable important for sites shown as suitable General Plan Consistency isten D
In addition In to including a bu ding
Plan to estimate potential otenti
all sites. Alternatively, t all sites. Alternatively,
alculate realistic cap
past project ap
on guida
ealis
4 initial inventory with these realistic capacity assumptions going forward, and not be overly aggressive in the assumed capacity for particular sites.

Default Densities and Capacity Assumptions by Affordability Level The inventory process requires the City to identify the density ranges at which each site will be developed. As discussed previously, staff has recommended using an “average or mid-point” density for all sites, including low, medium and high-density ranges to not be overly aggressive.

With respect to the various income categories for which the inventory must show adequate capacity, State law provides for a “default density4
” which is a zoning density which can be
assumed to be suitable to yield the potential capacity for lower-income housing units. In Brentwood, the default density for units to be projected as lower-income units in the inventory is 30 dwelling units per acre (du/ac). There is no default density for moderate-income units, but districts allowing less than 30 du/ac, in the range of 15 to 25 du/ac, may be appropriate.

Although not explicitly stated by HCD, based on past performance and peer city assumptions, the City is making the informed assumption that sites zoned at less than 30 du/ac, in the range of 15 to 25 du/ac, have the potential to accommodate capacity for moderate-income units.

Per HCD guidelines (Attachment 1), the City may project all units in the inventory that allow 30 du/ac (default density) or more as affordable for lower-income. Any site designated to accommodate lower income housing must also be between 0.5 acres – 10 acres and be projected to accommodate at least 16 units. The City has three land use designations that can accommodate residential development at this default density that would qualify for lower-income development including the R-VHD and two designations within the Innovation Center Specific Plan (PA-1), (Transit Village/Mixed-Use and Multi-Family Very High Residential).

As discussed later in this report, depending on the assumptions made, the majority of the lowerincome RHNA could be addressed within PA-1 using HCD’s recommendations, as well as a significant proportion of above-moderate units on other existing higher density housing sites, without requiring any rezoning. It is a policy decision for the City Council as to how to best allocate affordability assumptions for sites at various densities in various locations.

ANALYSIS OF EXISTING ZONING CAPACITY
The following outlines the City’s RHNA, the components that make up the current sites inventory, and how the projected shortfall is calculated. 6th Cycle RHNA
Table 1 summarizes the 6th Cycle RHNA for the City of Brentwood. The RHNA is distributed among the following income categories, each of which represent relative affordability to households as a proportion of the Countywide Area Median Income (AMI). 4 Sometimes called “Mullin densities” after the author of AB 2348, Statutes of 2004, which originated these requirements.

DRAFTh s
e or m
verly aggres verly ag
must show adequate must sh
ng density which can be
-income housing units come housing . In
ncome units in the inventory is ncome units in the invent y for moderate m -income units, but e units,
to 25 du/ac, may be appropriate propriate.
rformance and peer city assumptions,
zoned at less than 30 du/ac, in the range
e capacity for moderate-income units.
ay project all units in the inventory that allow units in the AF able for lower-income. Any site designa
ust also be between 0.5 acres een 0.5 – 10 acre
units. The City has three land use designatio land u
nt at this t at this default density defau that would qualify would q fo andtwodesignations within the Innovatio designations within the Innova ed-Use and Multi and M -Family Very High Residen
eport, depending on the g on t assumptions made
addressed addres within PA-1using HCD’s reco
of above-moderate units on other existing moderate units on o any rezoning. It isa policy decision for the decis
bility assumptions for sites at various densitie bility assumptions for sites at various

OF EXISTING ZONING CAPACITY OF EXISTING ZONING CAP
owing outlines the City’s RHNA, the com g outlines the City’s RHNA, the com ory, and how the projected shortfall is calcul how the projected shortfall is calcul h Cycle RHNADR
Table 1summarizes the 6th CycleRHNA
amongthe following followin income categor come ca
households as a proportion of the Co households as a proportion of the C 5 Table 1: RHNA Allocation Breakdown
Income Category Percentage of Area
Median Income
Brentwood RHNA
Extremely Low Income (ELI)* <30%
402 Very Low Income (VLI)* 31-50%
Low Income (LI) 51-80% 232
Moderate Income (MI) 81-120% 247
Above-Moderate Income (AMI) >120% 641
Total 1,522 Units
Analysis of Existing/Baseline Zoning Capacity
In order to provide a comprehensive analysis of the City’s existing zoning capacity, staff has utilized the following components to address the City’s 6th Cycle RHNA, discussed in further detail below.

Existing Residential Zoning
This includes parcels zoned for residential uses with capacity to add new housing units within the City’s single-family and multi-family residential zoning districts. Although all vacant or underutilized parcels that currently maintain zoning or general plan designations that allow residential development may be included within the inventory, staff recommends that the focus be on sites that can accommodate the largest amount of below market rate housing at the highest densities. Therefore, not all residentially zoned sites will need to be listed on the final inventory. A map of all parcels with a general plan designation that allows for residential development (excluding PA-1 and Specific Plan areas as noted above) is included for reference.

Capacity in Existing Specific Plans
This includes vacant or underutilized parcels within the PA-1 Specific Plan5 that allow for residential development with capacity to add new housing units.

Pipeline Projects
Pipeline Projects are defined as residential projects already entitled, under review, or expected to be entitled during the eight year planning period, including projects under construction but which would not have building permits finaled by June 30, 2022.6 This includes new proposed projects to be approved under the City’s revised Affordable Housing Ordinance. Although HCD allows Pipeline Projects to include projects currently under review, staff has only included entitled projects that have received City approval.

ADU Production
HCD has issued a determination to allow local jurisdictions to “count” ADU production as a component of the sites inventory based on a formula that considers the average annual number of ADU permits issued in the City over the last three years, multiplied over the Housing Element’s eight-year planning period. In 2019 the City issued nine permits, in 2020 the City issued 20 permits, and in 2021 the City issued 16. In the first six months of 2022, the City has only issued 2 new ADU permits. Since the City has not been able to show that there is currently an upward trend in ADU production, the average from 2019, 2020, and 2021 would need to be 5 Estimated capacity within PA-1 is based on draft revisions that the Planning Commission recommended for City Council approval on June 21, 2022, which will be reviewed by the City Council in July 2022. 6 The Housing Element 6th RHNA Cycle reporting period technically begins on July 1, 2022, meaning that units for which building permits are finaled (i.e., approved for occupancy) on or after this date, can be included in the 2023-2031 inventory.

DRAFT22 Uni
’s existing zoning capacity, ’s exist staff has aff has s 6th Cycle RHNA Cy , discussed in further
ses with capacity to add new housing units pacity to add residential zoning districts. distric Although all v
intain zoning or general plan designations intain zoning or general pla ded within the inventory, ded within th staff recommends taff reco e the largest he largest amount of below market rate market t all residentially zoned sites will identially zoned sites need to be ed to b cels with a general plan designation that general plan designation that 1 and Specific Plan areas Plan areas as noted above)
pecific Plans
nt or underutilized nt or underutiliz parcels withinthe PA opment with capacity to add new housing un pacity to add new ho ojects
Projects are defined as residential projects a jects are defined as residential projects a entitled during the eight year planning perio
ch would not have building permits finaled b have building permits finaled b rojects to be approved under the City’s ojects to be approved und revis allows Pipeline Projects to include projec allows Pipeline Projects to in entitled projects that have received City a entitled projects that have receive ADU Production
HCD has issued a determinatio a det
component of the sites invento component of the sites i of ADU permits issued in of ADU permits issued
Element’s eight Eleme -year pla year p
ssued 20 permits, an
y issued 2 new A
ward trend D
6 used for future projections. This would allow the City to project 15 ADU’s per year over the next eight years for a total of 135 new units. Kimley-Horn strongly recommends this approach to projection – more aggressive projection approaches attempted by other cities Kimley-Horn has worked with have not been approved by HCD.

As stated in the report previously presented to the City Council on June 1st, ABAG has prepared a preliminary ADU Affordability Report, currently under review by HCD, intended as a basis to allocate ADU production into the various RHNA affordability categories. If HCD accepts the report’s analysis, ADU’s would be permitted to be counted at the following income levels: 30% Very Low Income, 30% Low Income, 30% Moderate Income, and 10% Above Moderate Income.

Follow-up or verification of affordability levels would not be required if utilizing these accepted income levels. Utilizing these assumptions, the City would be able to count the following ADU production shown in Table 2.

Table 2: Summary of Projected ADU Production by Affordability Income Category ABAG Affordability
Assumptions
Projected ADU Production
Very Low Income (VLI) 30% 40
Low Income (LI) 30% 41
Moderate Income (MI) 30% 40
Above-Moderate Income (AMI) 10% 14
Total 135 Units
These assumptions can potentially be adjusted if the City Council wants to consider including strong policies and programs to encourage the development of ADUs. Discussion of how the numbers may be adjusted and what types of programs may be considered are discussed further in the Site Inventory and Affordability Assumption Strategies section of the report.

Together, existing residentially-zoned properties, pipeline projects, and ADUs constitute a baseline of zoned capacity that can accommodate the City’s RHNA. The difference between this number, and the RHNA in each category, represents the remaining need in each category.

Table 3 below summarizes the results of staff’s initial evaluation of pipeline projects and ADU production assumptions. The table also includes the total existing residential development capacity; however, the capacity has not been assigned affordability assumptions until further direction is provided as discussed in the Site Inventory and Affordability Assumption Strategies section of the report. Notably, the unit numbers presented in the following tables represent calculated capacity within the City’s existing General Plan and zoning designations, rather than a specific obligation to meet a portion of the City’s RHNA on specific sites. DRAFTG has p ded as a bas ded as
f HCD accepts t f HCD
ng income levels: 30 ng incom %
Above Moderate Income. e Modera
d if utilizing these accepted d if utilizing these a
le to cou le to co nt the following ADU ollowing
Affordability Afforda FT
dability
ns FT
cted A FT
30% 40 TF A
30% 41
30% 40
10% 14 A5 Units AF
ntially be adjusted if the City Council wants djusted if the City Council wants ms to encourage the development of ADUs ge the development of ADUs d and what types of programs may be consi
nd Affordability Assumption Strategies sectio nd Affordability Assumption Stra ng residentially ng resi -zoned properties, pipeline zoned properties, ned capacity that can accommodate the City ned capacity that can accommodate the nd the RHNA in each category, represents d the RHNA in each category, represent below summarizes the results of staff’s initi
ction assumptions. The table also include umptions. The table also include acity; however, the capacity the capa has not been
irection is provided as discussed in the Site rection is provided as disc section of the report n of the re . Notably, the unit n Notably calculated capacity within the City’s exis within the City a specific obligation to meet a portion a specific obligation to meet a portio 7 Table 3: Summary of Preliminary Capacity Analysis of RHNA and SiteStrategies Very LowIncome
LowIncomeModerateIncome
Above
ModerateIncomeTotal Units
2023-2031 RHNA
Allocation 402 232 247 641 1,552
RHNA Strategies Under Existing Zoning
Projects Currently in
the Pipeline 2 0 966 968
Projected ADU
Production 80 41 14 135
Remaining Need 552 206 -- 449
PA-1 (Innovation
Center) -- -- -- 2,222
Vacant Residential
Land -- -- -- 1,622
Total Unit Potential 82 41 980 4,947
Buffer/Gap -87% -83.5% 153% 319%

IMPACTS OF THE AFFORDABLE HOUSING ORDINANCE
At the June 1, 2022 Joint Workshop, concerns were also raised questioning whether the City could include projected affordable units that may be gained from low density housing developments as part of the City’s updated Affordable Housing Ordinance. While it may seem counterintuitive, HCD does not permit affordable units required through the City’s Affordable Housing Ordinance to be counted as “projected” units in the Sites Inventory unless they are proposed or approved as part of a specific housing development. These units are; however, able to be counted toward the City’s RHNA once a project is approved by the City. According to HCD’s Housing Element Site Inventory Guidebook (2020) (Attachment 1):

The analysis of ‘appropriate zoning’ should not include residential buildout projections resulting from the implementation of a jurisdiction’s inclusionary program or potential increase in density due to a density bonus, because these tools are not a substitute for addressing whether the underlining (base) zoning densities are appropriate to accommodate the RHNA for lower income households.

There are currently approximatively 10 residential developments under review with a total of 633 units currently proposed. If all of these projects were approved as currently proposed, the City would gain an additional 15 low- and very-low income units and 39 moderate income units. As noted above, although these projects are currently under review and are eligible to be included as Pipeline Projects, staff has only included entitled projects that have received City approval as Pipeline Projects.

On June 21, 2022, the Planning Commission recommended changes to the City’s Affordable Housing Ordinance to require a 13% affordable housing obligation for ownership and rental projects (3% Very Low / 4% Low / 6% Moderate). They also recommended changes to limit the option to pay a fee in lieu of constructing the required units to residential developments of 5-9 units, and removing the in lieu payment option for single-family residential development of 10 or more units. The proposed changes are tentatively scheduled to be presented to the City Council on July 12, 2022 for review and adoption.

DRAFT1,5
6 968
14 135 FT449
-- 2,222 FT
-- -- 1,622TFA41 980FT A %
FA
d toward the City’s RHNA once a project is a d toward the City’s RHNA once a ed as part of a ed as part of a
be counted as “projected” units in the Site be counted as “projected” unit es not permit
City’s updated Affordable Housing Ordinan
dable units that may be gained from lo
hop, concerns were also raised questioning

HOUSING ORDINANCE
specific

OUSING ORD
concerns were also raised questioni
affordable units required thro
its that may be gained from lo
ed Affordable Housing Ordina
ordable units required thro
housing developme housin
F
Element Site Inventory Guidebook (2020) (A
nalysis of ‘appropriate zoning’ should not in alysis of ‘appropriate zoning’ should not in ulting from the implementation of a jurisdict from the implementation of a jurisdict ncrease in density due to a density bonus, b density due to a density bonus, b addressing whether the underlining (b ddressing whether th accommodate the RHNA for lower incom accommodate the RHNA There are currently approximatively 10 There are currently approximativel 633 units currently proposed. If all o ntly proposed. If all the City would gain an additiona ain an additiona
income units. As noted above, oted
eligible to be included as P ded
have received City approv have received City appr
n June 21, 2022, t
ing Ordinanc
(3% Ve
pay
8 SITE INVENTORY AND AFFORDABILITY ASSUMPTION STRATEGIES On June 1, 2022, staff presented the City Council and Planning Commission with an update on the Housing Element Update process, a description of the sites strategies, and a preliminary analysis that showed that the City has enough sites to meet the City’s RHNA obligation without having to rezone any parcels. This is a highly unusual position for communities in the sixth housing element cycle. Because the RHNA for most communities has increased significantly compared with the fifth cycle, most need to rezone substantial areas at higher densities. For instance, the total sixth cycle RHNA for Marin County is five times as large as in the fifth cycle.

The City Council reviewed the preliminary site strategies including initial assumptions and directed staff to return with a more detailed report on the sites inventory including a comprehensive draft sites inventory of every parcel when available for review. At this meeting, specific concerns were also raised regarding staff’s initial recommendation to assume that sites meeting the minimum default density of 30 du/ac be assumed to include 30% low income units and 10% moderate income units. Based on this feedback, staff has provided a comprehensive list of sites under consideration to be included in the draft sites inventory (attached for reference) and has three strategies for the City Council’s review and consideration. All three strategies include the same baseline for pipeline projects and existing residential inventory parcels, however, each will provide different affordability assumptions, and one with different ADU projections.

The strategies provided are only a sample of the strategies and assumptions that could be utilized to address the City’s RHNA. There will be an opportunity at June 21st workshop to use in real time, a model to make affordability and site assumption adjustments as necessary. A summary of the three identified strategies are included in Attachment 5 and below in Table 4 followed by a detailed discussion of each.

Table 4: Strategy Summaries
Strategy 1 Strategy 2 Strategy 3
Description No Rezoning Required,
Reduced Affordability
with Increased ADU
Assumptions
No Rezoning Required,
HCD Approved
Methodology
No Rezoning Required,
HCD Approved
Methodology with
Conservative
Affordability
Assumptions
HCD-supported No Yes Yes
Affordability
Assumptions*
21% Low and Very
Low, and 6% Moderate
100% Low and Very
Low, and 100%
Moderate
30% Low and Very
Low, and 10%
Moderate
Affordable Unit
Potential
VL/L: 635 units
Mod: 264 units
AMod: 4,183 units
Total: 5,082 units
VL/L: 2,321 units
Mod: 851 units
AMod: 1,775 units
Total: 4,947 units
VL/L: 755 units
Mod: 347 units
AMod: 1,405 units
Total: 4,947 units
Buffer 0% Low/Very Low,
7% Moderate-, and
553% Above Moderate
266% Low/Very Low,
245% Moderate-, and
177% Above Moderate
19% Low/Very Low,
40% Moderate-, and
500% Above Moderate
No Not Loss
Implications
Highly likely to trigger
no net loss
Least likely to trigger no
net loss
More likely than
Strategy 2 to trigger no
net loss
*Affordability assumptions are based on the sites inventory with the assumption that sites that allow 30 du/ac (default density) or more can accommodate capacity for lower-income units and sites that allow 15 to 25 du/ac can accommodate capacity for moderate-income units.

DRAFT os
in
ed sign ed sig
her densities her den
s in the fifth cycle s in the
initial assumptions and initial assum
ites inventory including a ites inventory incl
ble for review. At this meeting, ble for review. At this me mmendation to assume that sites mmendation to assume that s ed to include 30 ed to in % low income units me unit
k, staff has provided a comprehensive
the draft sites inventory (attached for
uncil’s review and consideration cons . All three
e projects and existing residential invento projects and existing affordability assumptions, and ility assumptions, one with diffe mple of the strategies and assumptions th mple of the strategies and as There will be an opportunity at June 21 here will be an opportunity at June st work rdability and site assumption adjustments lity and site assumption adjustmen strategies are included in Attachment 5 an
sion of each.
mmariesRA
Strategy 1 Strat RDANo Rezoning Re
Afford
reased ADU DRAAssumptions DRANo Rez
CD Ap
Method RD
HCD-supportedDRo
D
Affordability
Assumptions* DRLow an
Low, and 6% M D
Affordable Unit
Potential
VL/ DMod
AM DRTot
Buffer 0
9 Only strategies 2 and 3 of the aforementioned options currently create the capacity necessary to meet RHNA with a buffer consistent with HCD recommendations. Strategy 1 is presented to illustrate what the inventory may look like using affordability assumptions that are more conservative and more closely track the proposed Affordable Housing Ordinance (3%, 4%, 6%), and other strategies by which Brentwood can pursue meeting the RHNA obligation, although additional adjustments would be required. Strategy 1 is not recommended due to its reliance on ADU’s, a strategy HCD has repeatedly disapproved. Table 5 below summarizes the affordability assumptions under each strategy followed by a more detailed analysis of each strategy.

Table 5: Affordability and Default Densities by General Plan Designation Density Category Density Range Income Level Potentially Accommodated in Inventory
Above-Mod. Mod. Low
Strategy 1 Affordability Assumptions
Low - Medium Density < 15 du/ac 100%
High Density 15 – 25 du/ac 70% 6%
Very High Density > 30 du/ac 60% 6% 21%
Strategy 2 Affordability Assumptions
Low - Medium Density < 15 du/ac 100%
High Density 15 – 25 du/ac 0% 100%
Very High Density > 30 du/ac 0% 0% 100%
Strategy 3 Affordability Assumptions
Low - Medium Density < 15 du/ac 100%
High Density 15 – 25 du/ac 70% 30%
Very High Density > 30 du/ac 60% 10% 30%
Strategy 1: Reduced Affordability with Increased ADU Assumptions ADU Assumptions
As indicated in the report, HCD allows ADU projections based on previous production averages projected over the next 8-year cycle. In order to increase these assumptions, the City would be required to include additional incentives, documented in new programs that could facilitate the added production. Additional programs that could be included to incentivize additional ADU production could include the following:
x programs to waive ADU plan check and permit fees;
x pre-approved ADU plans to streamline the project application and review process and reduce upfront project costs;
x promotion of ADUs through handouts, simplified application forms; and x exploration of a program to provide ADU funding assistance to homeowners that provide affordability covenants.

In addition to these programs, the City would be required to document and clearly justify to HCD how and why the City believes that these programs would work as well as creating a monitoring program to track ADU and JADU creation and affordability levels throughout the planning period. The program would require the City to monitor the development of accessory units at all DRAFTt
(3%, 4% (3%, 4
ligation, alth ligation
ue to its reliance ue to its
arizes the affordability
of each strategy strateg .

Designation Design TF
come Le
ccomm TF
Mod. FT A6%
ns A
du/ac 00% FA
5 – 25 du/ac RA0% 100 RA
> 30 du/acRA0%
ability AssumptRA
Density < 15 du/acRA10
ty 15 – 25 du/ac RA70% Density > 30 du/ac RA6
RD
rategy 1: Reduced Affordability with ed AffordRIncreas DR ADU Assumptions
As indicated in the report, HCD allows report, HCD allo projected over the next 8 he nex -year cycle r cycle
required to include additional inc e additional inc
added production. Additional added production. Add
production could include the production could include
x programs to waive to wai
x pre-approved A roved A
reduce upfro
promotion
xplora
10 income levels and track progress annually. If ADUs are not approved and permitted at the rate anticipated in the City’s increased projections, the City would need to adopt additional incentives within 2 years of the original incentives, and every two years subsequent, until ADU construction matches ADU projections.

Staff has reviewed the City’s current Municipal Code regulations, residential development trends, and overall characteristics of residential properties within the city and does not believe that with added programs and an increased effort to highly encourage and incentivize ADU production throughout the city that there is additional realistic capacity and believes that doubling the current projections to a total of 30 ADUs per year would be rejected by HCD.

Although strategies similar to this have been approved in limited capacity within California, in those cases analysis and growth trends were typically provided to show a growing trend in production right up to adoption of the Housing Element. Since Brentwood is unable to show any substantial growth in production in the past six months to a year, adequate justification is not likely in this case. If increased assumptions were to still be considered, possible revised ADU production and assumptions are shown below in Table 6.

Table 6: Summary of Projected ADU Production by Affordability Income Category ABAG
Affordability
Assumptions
Original ADU
Productions
Increased ADU
Productions
Very Low Income (VLI) 30% 40 80
Low Income (LI) 30% 41 82
Moderate Income (MI) 30% 40 80
Above-Moderate Income
(AMI)
10% 14 28
Total 135 Units 270 Units
High and Very High Density Affordability Assumptions
In addition to higher ADU projections, Strategy 1 includes assumptions of 27% affordable units (9% very low-, 12% low-, and 6% moderate-income units) on all sites meeting the minimum default density of 30 du/ac. This assumption would be above what is required as part of the City’s Affordable Housing Ordinance, but would provide more conservative estimates and be more closely aligned with the City’s RHNA requirements. However, in this scenario the City would be most likely to need to modify affordability assumptions, or upzone additional sites during the planning period because the remaining undeveloped sites would be projected to provide few affordable units.

Table 7 below summarizes the results of initial evaluation of existing residential development capacity utilizing Strategy 1 capacity assumptions. Strategy 1 would result in the following projected capacity which would include a zero percent buffer in the lower income category: DRAFTl devel l deve does not be does n
nd incentivize AD nd ince
city and believes that city and
uld be rejected by HCD. uld be rejected
apacity within California, in apacity within Calif
d to show d to sho a growing trend in wing tre
Brentwood is unable to show any Brentwood is unable to show a a year, adequate justification is not a year, adequate justification is no be considered, possible revised ADU

6. ion by Affordability by AffordabilityFT A
ptio AFTOriginal ADU AFoduction FT A
30% 40 80 AF
30% 41 F8
AF
30% 40 FA
10% 14
FARTotal A135 R
gh Density Affordability Assumptions gh Density Affordability Assumption igher ADU projections, Strategy 1 includes igher ADU projections, Strategy 1 inc w-, 12%low-, and 6% moderate-income un come
nsity of 30 du/ac. This assumption would sity of 30 du/ac. This assumption would ffordable Housing Ordinance, but would p ble Housing Ordinance, but would p e closely aligned with the City’s RHNA req gned with the City’s RHNA req ould be most likely to need to modify affo uld be most likely to ne during the planning period because the re during the planning period b provide few affordable units.

Table 7 below summarizes the res summarizes the res
capacity utilizing Strategy Strate 1 cap
projected capacity which would projected capacity which 11 Table 7: Summary of Strategy 1 Capacity Analysis

Very
LowIncome
LowIncomeModerateIncome
Above
ModerateIncomeTotal
2023-2031 RHNA
Allocation 402 232 247 641 1,552
Strategy 1 Capacity Under Existing Zoning
Projects Currently in the
Pipeline 2 0 966 968
Projected ADU Production 162 81 27 270
Remaining Need 471 166 -- 314
PA-1 (Innovation Center) 377 133 1,712 2,222
Vacant Residential Land 94 50 1,478 1,622
Total Unit Potential 635 264 4,183 5,082
Units +/- and Buffer/Gap
% 1 unit, 0% 17 units, 7% 3,542 units,
553%
3,844 units,
227%
CEQA Implications under Strategy 1
If Strategy 1 is chosen, no rezoning would be required and although affordability assumptions would be modified, all density assumptions would continue to be based on existing General Plan designations and therefore the Housing Element Update may be exempt from CEQA, pursuant to Section 15061(b)(3) of the State CEQA Guidelines, similar to Strategy 1 and 2.

Strategy 2: No Rezoning Required, HCD Approved Methodology Strategy 2 utilizes the preliminary analysis of RHNA and site strategies as presented in the HCD Guidebook. Based on HCD guidelines, the City may make assumptions up to 100% lowerincome affordability for all sites allowing 30 du/ac or more, and 100% moderate-income affordability for all sites allowing between 15-25 du/ac. Although utilizing this approach would require additional analysis and justification of the sites designated for lower income housing, this is the typical assumption that most communities in California have used. Utilizing this method would also provide the City with the largest buffer in the very low- and low-income categories.

Table 8 below summarizes the results of initial evaluation of existing residential development capacity utilizing Strategy 2 capacity assumptions. Strategy 2 would result in the following projected capacity which would include a large buffer in each income category: DRAFT966 968 27 270 FT314
133 1,712 2,222TF
50 1,478 1,622TF
264 4,183 5,082 FT Aunits, 7% AFT3
FT A
ning Required
b)(3) of the State CEQA Guidelines,
fore the Housing Element Update may be
assumptions would continue to be based o
ng would be required and although affordab
, HCD Approved Methodology
would be required and although affor
tions would continue to be based o
ousing Element Update may be
te CEQA Guidelines,
proved M
similar t
FT RA
s the preliminary analysis of RHNA and site s the preliminary analysis of RHNA ased on HCD guidelines, the City may m ased on HCD guidelines, the City ma ordability for all sites allowing ordability for all sites allowi 30 du/ac lity for all sites allowing for all sites allowing between 15-25 du/ additional analysis and justification of the s nal analysis and justification of the s he typical assumption that umption tha most communitie
ould also provide the City with provide the City w the largest bu Table8 below summarizes the results low summarizes the r capacity c utilizing Strategy ng Stra 2capacit capac
projected capacity which y whic would inc
12 Table 8: Summary of Strategy 2 Capacity Analysis
Very LowIncome
LowIncomeModerateIncome
Above
ModerateIncomeTotal
2023-2031 RHNA
Allocation 402 232 247 641 1,552
Strategy 2 Capacity Under Existing Zoning
Projects Currently in
the Pipeline 2 0 966 968
Projected ADU
Production 80 41 14 135
Remaining Need 552 206 -- 449
PA-1 (Innovation
Center) 1,793 429 0 2,222
Vacant Residential
Land 446 381 795 1,622
Total Unit Potential 2,321 851 1,775 4,947
Units +/- and
Buffer/Gap % 1,687 units, 266% 604 units,
245%
1,134 units,
177%
3,844 units,
219%
Strategy 2 could also be proposed with fewer sites and a smaller buffer, although this would be more likely to trigger no net loss. If that occurred, however, the City would be able to make a finding that additional properly zoned sites are available in the City.

CEQA Implications under Strategy 2
If Strategy 2 is chosen, no rezoning would be required and all density assumptions would be based on existing General Plan designations; therefore, the Housing Element Update would be exempt from CEQA review, pursuant to Section 15061(b)(3) of the State CEQA Guidelines, which provides that a project is exempt from CEQA if the activity is covered by the common sense exemption that CEQA applies only to projects which have the potential for causing a significant effect on the environment. However, HCD may require that other programs be included that could require additional CEQA review.

Strategy 3: No Rezoning Required, HCD Approved Methodology with Conservative Affordability Assumptions
Strategy 3 utilizes the preliminary analysis of RHNA and sites strategies as presented in the initial sections of this report. As stated above, based on HCD guidelines the City may make assumptions up to 100% lower-income affordability for all sites allowing 30 du/ac or more, and 100% moderate-income affordability for all sites allowing up to 20 du/ac. However, a more conservative assumption would project 30% low-income affordability and 10% moderate-income affordability for very high-density sites and 30% moderate-income affordability for high-density sites. Since not all sites are likely to develop at even this level of affordability, the City would need to carefully monitor development to ensure that it retains adequate sites at all times for the lower and moderate income categories. Because each site would be projected to have fewer affordable units, the City would be more likely to need to modify assumptions or up zone additional sites later in the planning period. A 100% affordable housing development would greatly assist in meeting the City’s RHNA.

DRAFT966 968
14 135 FT9
F
429 0 2,222TF
381 795 1,622TFA1
AFT1
FT A
266 1,1
17FA
General Plan designations General Plan desi
sen, no rezoning would be required and all sen, no rezoning would be req der Strategy
rly zoned sites are available in the City.
oss. If that occurred, however, the City wou
ed with fewer sites and a smaller buffer, altho
y 2
fewer sites and a smaller buffer, alth
occurred, however, the City wou
are available in the City.
; therefore theref , the H
F
CEQA review, pursuant to Section 15061(b rsuant to Section 15 des that a des tha project is exempt from CEQA if is exempt from CEQA emption that CEQA applies only to project mption that CEQA applies only to project ant effect on the environment. However, ect on the environment. However, ded that could require additional CEQA revie ld require additional CEQA revie Strategy 3: No Rezoning Required Req , HCD A DR
Assumptions
Strategy 3 utilizes the preliminary es the preliminary
initial sections of this report. this r As
assumptions up to 100%lowe
100% moderate-income aff come
conservative assumption conservative assumptio
affordability for very hi
s. Since not all
to carefully
d mod
13 Table 9 below summarizes the results of initial evaluation of existing residential development capacity utilizing Strategy 3 capacity assumptions. Strategy 3 would result in the following projected capacity which would include a minimum 19% buffer in the lower income category:

Table 9: Summary of Strategy 3 Capacity Analysis
Very LowIncome
LowIncomeModerateIncome
Above
ModerateIncomeTotal
2023-2031 RHNA
Allocation 402 232 247 641 1,552
Strategy 3 Capacity Under Existing Zoning
Projects Currently in
the Pipeline 2 0 966 968
Projected ADU
Production 80 41 14 135
Remaining Need 552 206 -- 449
PA-1 (Innovation
Center) 539 223 1,460 2,222
Vacant Residential
Land 134 83 1,405 1,622
Total Unit Potential 755 347 3,845 4,947
Units +/- and
Buffer/Gap % 121 units, 19% 100 units,
40%
3,204 units,
500%
3,844 units,
219%
CEQA Implications under Strategy 3
If Strategy 3 is chosen, no rezoning would be required and all density assumptions would be based on existing General Plan designations; therefore, the Housing Element Update would be exempt from CEQA, pursuant to Section 15061(b)(3) of the State CEQA Guidelines, which provides that a project is exempt from CEQA if the activity is covered by the common sense exemption that CEQA applies only to projects which have the potential for causing a significant effect on the environment. However, HCD may require that other programs be included that could require additional CEQA review.

NEXT STEPS
As noted, the creation of the site inventory is an important initial step in the Housing Element Update process. Following this meeting, staff and the consultant team will continue to develop and refine the analysis of existing sites and solidify the existing capacity that can be used to address the City’s RHNA. Based on where staff and the consultant team currently are in the analysis, a revised schedule and timeline has been prepared for Strategies 1, 2, and 3. A summary of the revised schedule is included below. DRAFTe 641 1
FT
ning
966 968 FT
41 14 135 FT
206 -- TF
223 1,460 2,222TFA83 1,405 AF
5 3,84FA
19% 100 unit
40%
04 unit
0%
A
Strategy 3
n, no rezoning would be required and all de , no rezoning would be require eneral Plan designations eneral Plan des ; therefore there , the Hou QA, pursuant to Section 15061(b)(3) of th pursuant to Section 15061(b project is exempt from CEQA if the activit project is exempt from CEQA if the hat CEQA applies only to projects which hav hat CEQA applies only to projects which h the environment. However, HCD may requ e environment. However, HCD may requ equire additional CEQA review. additional CEQA review.

EXT STEPS T STE
As noted, the creation of the site As noted, the creation of the inventory Update process. Following this meeting, . Following this and refine the analysis of existing site and refine the analysis of existing address the City’s RHNA.Based o
analysis, a revised schedule an d schedule an
summary of the revised schedu
14 It should be noted that although January 31, 2023 is the statutory deadline to have the Housing Element adopted for our jurisdiction, there is a 120-day “grace period” that is allowed in order to gain compliance with HCD. Under Strategies 1, 2, or 3, Brentwood would be utilizing this 120- day grace period to gain certification.

Staff also notes that in addition to working on reviewing the site inventory and goals and policies, staff and the consultant team are continuing to advance other components of the Housing Element. These include:
x Summary of input from the initial on-line community survey. The survey concluded on Friday, June 10th and included a total of 526 responses. A comprehensive summary of the survey results will be presented to the City Council when available. x Completion of the Public Review Draft of the 2023-2031 Housing Element Update that will address all of the mandatory informational requirements and analyses supporting the Housing Element, including findings of the required housing needs assessment; analysis of constraints to housing; and evaluation of existing Housing Element policies and programs. This draft report is anticipated to be published and presented to the City Council and Planning Commission in August ahead of submission to HCD.

CONCLUSION
To move forward in the planning process in drafting the Housing Element Update, it is imperative that the City Council provide direction on which strategies should be used in forming baseline site inventory and affordability assumptions. Staff is recommending that the City Council review, discuss, and receive public comments on the Housing Element Update RHNA sites strategies and provide direction to staff on which of the above site strategies to move forward with in order to complete the public review draft of the Housing Element.

Attachments

1. HCD Site Inventory Guidebook

2. Residential General Plan Map

3. Draft Site Inventory Excel Sheet

4. Draft Site Inventory Map

5. Strategy 1-3 Site Analysis Tables

6. 5th Cycle Housing Element Site Inventory Analysis
a. Multi-Family Sites
b. Single-Family Sites
Task Timeframe
City Council Workshop July 21, 2022
Publish Public Review Draft August 2022
Joint City Council and Planning Commission Meeting –
Public Review Draft
August 2022
Internally Review Community Input/Feedback and Make
Revisions
Early September 2022
First HCD Submittal Mid-September 2022
Response to HCD Comments and Revisions Mid-December 2022 2nd Submission of Draft Housing Element to HCD February 2023 Response to HCD Comments and Revisions April 2023
3rd Submission of Draft Housing Element to HCD if needed May 2023 HCD Letter of Substantial Compliance May 2023
Adoption Public Hearings May 2023 DRAFT2023 is the statutory deadline to have the Ho e statutory dead s a 120-day “grace peri ace period” that is allowed in
egies 1, 2, or 3, Brentwood would be utilizin ntwood w
n to working on reviewing the site invento orking on reviewing the site invent tant team are continuing to advance othe are continuing to advance othe clude:
put from the initial on put from the -line community com surve 10th and included a total of 526 responses and included a total of 52 y results will be presented to the City Council y results will be presented to the Cit pletion of pletion the Public Review Draft of the 20 ic Review Draft of the 2 l address address all of the mandatory informational e mandatory informational Housing Element, including findings of the r g Element, including findings of the r of constraints to housing; and evaluati
programs. This draftreport is anticip
Council and Council a Planning Commission i anning C

CONCLUSION
To move forward in t rd in he planning
imperative that the City Council p City
baseline site inventory and baseline site inventory
Council review, discuss, an uncil review, discuss
sites strategie sites s s and prov nd pr
orward with in ord
ments
CD Sit
id
T
ember 2022 ember 2
September 2022
d-December 2022TF
Februa
April 2023 AprFT
ed FTM
May 2023 TF
2023 T

STATE OF CALIFORNIA - BUSINESS, CONSUMER SERVICES AND HOUSING AGENCY

DEPARTMENT OF HOUSING AND COMMUNITY DEVELOPMENT

DIVISION OF HOUSING POLICY DEVELOPMENT
2020 W. El Camino Avenue, Suite 500
Sacramento, CA 95833
(916) 263-2911 / FAX (916) 263-7453
www.hcd.ca.gov
-XQH, 2020
MEMORANDUM FOR: Planning Directors and Interested Parties FROM: Megan Kirkeby, Acting Deputy Director
Division of Housing Policy Development
SUBJECT: Housing Element Site Inventory Guidebook
Government Code Section 65583.2
The housing element of the general plan must include an inventory of land suitable and available for residential development to meet the locality’s regional housing need by income level. The purpose of this Guidebook is to assist jurisdictions and interested parties with the development of the site inventory analysis for the 6th Housing Element Planning Cycle and identify changes to the law as a result of Chapter 375, Statutes of 2017 (AB 1397), Chapter 958, Statutes of 2018 (AB 686), Chapter 664, Statutes of 2019 (AB 1486), and Chapter 667, Statutes of 2019 (SB 6). The Guidebook should be used in conjunction with the site inventory form developed by the California Department of Housing and Community Development (HCD). These laws introduced changes to the following components of the site inventory:
x Design and development of the site inventory (SB 6, 2019) x Requirements in the site inventory table (AB 1397, 2017 AB 1486, 2019) x Capacity calculation (AB 1397, 2017)
x Infrastructure requirements (AB 1397, 2017)
x Suitability of nonvacant sites (AB 1397, 2017)
x Size of site requirements (AB 1397, 2017)
x Locational requirements of identified sites (AB 686, 2018) x Sites identified in previous housing elements (AB 1397, 2017) x Nonvacant site replacement unit requirements (AB 1397, 2017) x Rezone program requirements (AB 1397, 2017)
The workbook is divided into five components: (Part A) identification of sites; (Part B) sites to accommodate the lower income RHNA; (Part C) capacity analysis; (Part D) non-vacant sites; and (Part E) determination of adequate sites.

If you have any questions, or would like additional information or technical assistance, please contact the Division of Housing Policy Development at (916) 263-2911. DRAFTuty Director uty Dire y Development y Deve
Site Inventory ite Inv Guidebook uidebo
de Section 65583.2 AF
must include an inven
to meet the locality’s region
Guidebook is to assist jurisdictions and in isdiction
inventory analysis entory analysis for the 6 f th Housing Ele Housing the law as a result of w as a result of Chapter Chapte 375, Statu es of 2018 (AB 686), AB 6 Chapter 664, Statut
es of 2019 (SB 6). The Guidebook should
form developed by the form developed by the California Califo Depart pment (HCD). These laws introduced cha aws int
he site inventory:
and development of the site inventory (SB and development of the site inventory ( irements in the site inventory table (AB 1 ements in the site inventory table (AB 1 pacity calculation (AB 1397 calculation (AB 1397, 2017) nfrastructure requirements (AB 1397, 20 e requirements (AB 1397, 20 Suitability of nonvacant sites (AB 1397 Suitability of nonvacan x Size of site requirements (AB 1397, Size of site requirements x Locational requirements of identif nal requirements of i x Sites identified in previous hou ified in previous ho x Nonvacant site replacement te replacement
x Rezone program requirem am re
The workbook is divided The workbook is divid
to accommodate the lo to accommodate the
es; and (Part E) d
have any
e
Table of Contents
BACKGROUND AND PURPOSE ........................................................................................ 3 Housing Element Site Inventory Requirements ................................................................ 3 SITE INVENTORY GUIDEBOOK FRAMEWORK ................................................................ 4 Guidebook Structure......................................................................................................... 4 PART A: IDENTIFICATION OF SITES................................................................................. 5 Step 1: Identification of Developable Sites ....................................................................... 5 Step 2: Inventory of Sites.................................................................................................. 7 Step 3: Infrastructure Availability ...................................................................................... 7 Step 4: Map of Sites ......................................................................................................... 8 Step 5: Determination of Consistency with Affirmatively Furthering Fair Housing ............ 8 Step 6: Sites by RHNA Income Category ......................................................................... 9 Step 7: Environmental Constraints ................................................................................. 10 PART B: SITES TO ACCOMMODATE LOW AND VERY LOW- INCOME RHNA ............. 11 Step 1: Sites Used in Previous Planning Periods Housing Elements ............................. 11 Step 2: Zoning Appropriate to Accommodate Low- and Very Low- Income RHNA ........ 13 Step 3: Size of Sites ....................................................................................................... 15 PART C: CAPACITY ANALYSIS........................................................................................ 19 Step1: Utilizing minimum densities to calculate realistic capacity of sites....................... 19 Step 2: Utilizing factors to calculate realistic capacity of sites ........................................ 19 PART D: NONVACANT SITES .......................................................................................... 24 Step 1: Description of the nonvacant site ....................................................................... 25 Step 2: Nonvacant site analysis methodology ................................................................ 25 Step 3: Reliance on nonvacant sites to accommodate more than 50 percent of the RHNA for lower income households .......................................................................................... 26 Step 4: Program and policy requiring replacement of existing affordable units .............. 28 PART E: DETERMINATION OF ADEQUATE SITES......................................................... 30 Step 1: Consider any alternative means of meeting the RHNA ...................................... 30 Step 2: Determine whether there is sufficient capacity to accommodate the RHNA for the jurisdiction by income. .................................................................................................... 32 Step 3: Adequate Sites Program .................................................................................... 33 ATTACHMENT 1: SUMMARY OF NEW LAWS REFERENCED IN THE GUIDEBOOK .... 39 ATTACHMENT 2: GOVERNMENT DRAFT CODE SECTION 65583.2 .......................................... 40 .......
........... ........ ........
.......................... .......... ...
..................................... ..................... .. 7 ....................... .... ...................... ......... 7 .................................................. .. 8 vely Furthering Fair Housing vely Fu ............ ......... 8 .................................................... ........................... ......... 9 ............................................................. ................................

W AND VERY LOW VERY LOW- INCOME RHNA INC ...
ng Periods Housing Elements using Ele .............. AF ommod Very Lo
............................................................. ..................................................

SIS........................................................ ................................................ m densities to calculate realistic capacity o calculate realistic capacity tors to calculate realistic capacity of sites ors to calculate realistic capacity of sites CANT SITES ......................................... ........................ cription of the nonvacant site cription of the nonva ................. .......

Nonvacant site analysis methodology ....
3: Reliance on nonvacant sites to accom eliance on nonvacant sites to accom lower income households ome household .................... DR Step 4: Program and po
PART E: DETERMINATION OF ADEQ
Step 1: Consider any alternative onsider any alternativ Step 2: Determine whether th mine whether th
jurisdiction by income. ....

Step 3: Adequate Sites Step 3: Adequate S
ATTACHMENT 1: SU
TACHMENT 2:

Site Inventory Guidebook Page 3 May 2020

BACKGROUND AND PURPOSE
Housing Element Site Inventory Requirements
Scarcity of land with adequately zoned capacity is a significant contributor to increased land prices and housing development costs. A lack of adequately zoned sites exacerbates the already significant deficit of housing affordable to lower income households. An effective housing element provides the necessary conditions for conserving, preserving and producing an adequate supply of housing affordable at a variety of income levels and provides a vehicle for establishing and updating housing and land-use strategies to reflect changing needs, resources, and conditions. Among other things, the housing element establishes a jurisdiction’s strategy to plan for and facilitate the development of housing over the five-to-eight year planning period by providing an inventory of land adequately zoned or planned to be zoned for housing and programs to implement the strategy.

The purpose of the housing element’s site inventory is to identify and analyze specific land (sites) that is available and suitable for residential development in order to determine the jurisdiction’s capacity to accommodate residential development and reconcile that capacity with the jurisdiction’s Regional Housing Need Allocation (RHNA). The available and suitable sites are referred to as “adequate sites” throughout this Guidebook. The site inventory enables the jurisdiction to determine whether there are sufficient adequate sites to accommodate the RHNA by income category. A site inventory and analysis will determine whether program actions must be adopted to “make sites available” with appropriate zoning, development standards, and infrastructure capacity to accommodate the new development need.

Sites are suitable for residential development if zoned appropriately and available for residential use during the planning period. If the inventory demonstrates that there are insufficient sites to accommodate the RHNA for each income category, the inventory must identify sites for rezoning to be included in a housing element program to identify and make available additional sites to accommodate those housing needs early within the planning period.

Other characteristics to consider when evaluating the appropriateness of sites include physical features (e.g., size and shape of the site, improvements currently on the site, slope instability or erosion, or environmental and pollution considerations), location (e.g., proximity to and access to infrastructure, transit, job centers, and public or community services), competitiveness for affordable housing funding (e.g., Low Income Housing Tax Credit scoring criteria), and likelihood or interest in development due to access to opportunities such as jobs and high performing schools1. When determining sites to include in the inventory to meet the lower income housing need, HCD recommends that a local government first identify development potential in high opportunity neighborhoods. This will assist the local government in meeting its requirements to affirmatively further fair housing and ensure developments are more competitive for development financing. 1 Please Note: Significant increases in the housing capacity of the residential land inventory of the housing element could also warrant planning for updating of other elements, including the land use, safety, circulation elements and inclusion of an environmental justice element or environmental justice policies. The housing element must include a program describing the means by which consistency will be achieved with other general plan elements and community goals (GC 65583(c)(8)).

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Site Inventory Guidebook Page 4 May 2020

SITE INVENTORY GUIDEBOOK FRAMEWORK
The following is a Guidebook designed to assist a jurisdiction through the site inventory analysis required by Housing Element Law. Use of the Guidebook is not required for a determination of compliance by HCD. The Guidebook is intended to facilitate the jurisdiction in determining if adequate sites are available by income category to accommodate the jurisdiction’s share of the RHNA or if rezoning or other program actions are needed. Areas of the law that are newly added since the beginning of the 5th housing element cycle are marked with the designation *NEW*.

Guidebook Structure
PART A: IDENTIFICATION OF SITES
General characteristics of suitable sites identified in the inventory, including zoning, infrastructure availability, and environmental constraints, among others.

PART B: SITES TO ACCOMMODATE LOW AND VERY LOW- INCOME RHNA Analysis to determine if sites are appropriate to accommodate the jurisdiction’s RHNA for low- and very low-income households.

PART C: CAPACITY ANALYSIS
Description of the methodology used to determine the number of units that can be reasonably developed on a site.

PART D: NONVACANT SITES
Analysis to determine if nonvacant sites are appropriate to accommodate the jurisdiction’s RHNA.

PART E: DETERMINATION OF ADEQUATE SITES
After consideration of the above analysis and any alternate methods to accommodate RHNA, the determination of whether sufficient sites exist to accommodate RHNA or if there is a shortfall requiring a program to rezone additional sites. DRAFTy to program a progra
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Site Inventory Guidebook Page 5 May 2020
PART A: IDENTIFICATION OF SITES
Step 1: Identification of Developable Sites
Government Code section 65583.2(a)
Generally, a site is a parcel or a group of parcels that can accommodate a portion of the jurisdictions RHNA. A jurisdiction must identify, as part of an inventory, sites within its boundaries (i.e., city limits or a county’s unincorporated area)2 that could have the potential for new residential development within the eight- or five-year timeframe of the housing element planning period.

Types of sites include:
x Vacant sites zoned for residential use.
x Vacant sites zoned for nonresidential use that allow residential development. x Residentially zoned sites that are capable of being developed at a higher density (nonvacant sites, including underutilized sites).
x Sites owned or leased by a city, county, or city and county. x Sites zoned for nonresidential use that can be redeveloped for residential use and a program is included to rezone the site to permit residential use.

Pending, approved, or permitted development:

Projects that have been approved, permitted, or received a certificate of occupancy since the beginning of the RHNA projected period may be credited toward meeting the RHNA allocation based on the affordability and unit count of the development. For these projects, affordability is based on the actual or projected sale prices, rent levels, or other mechanisms establishing affordability in the planning period of the units within the project (See Part E). For projects yet to receive their certificate of occupancy or final permit, the element must demonstrate that the project is expected to be built within the planning period.

Definition of Planning Period: The “Planning period” is the time period between the due date for one housing element and the due date for the next housing element (Government Code section 65588(f)(1).) For example, the San Diego Association of Governments’ 6th Cycle Planning Period is April 15, 2021 to April 15, 2029.

Definition of Projection Period: “Projection period” is the time period for which the regional housing need is calculated (Government Code section 65588(f)(2).). For example, the San Diego Association of Governments’ 6th Cycle Projection Period is June 30, 2020 to April 15, 2029. End definitions
Please note, sites with development projects where completed entitlements have been issued are no longer available for prospective development and must be credited towards the RHNA based on the affordability and unit count of the development. “Completed entitlements” means a housing development or project which has received all the required land use approvals or entitlements necessary for the issuance of a building permit. This 2 In some cases, jurisdictions may want to include sites anticipated to be annexed in the planning period.

Annexation is considered a rezoning effort to accommodate a shortfall of sites. For more information on annexation please see Part E, Step 3.
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Site Inventory Guidebook Page 6 May 2020
means that there is no additional action required to be eligible to apply and obtain a building permit.

Jurisdictions may choose to credit sites with pending projects since the beginning of the RHNA projection period towards their RHNA based on affordability and unit count within the proposed project but must demonstrate the units can be built within the remaining planning period. Affordability must be based on the projected sales prices, rent levels, or other mechanisms establishing affordability in the planning period of the units within the project.

Census definition of a unit: A housing unit is a house, an apartment, a group of rooms, or a single room occupied or intended for occupancy as separate living quarters. Separate living quarters are those in which the occupants do not live and eat with other persons in the structure and which have direct access from the outside of the building or through a common hall. Living quarters of the following types are excluded from the housing unit definition: dormitories, bunkhouses, and barracks; quarters in predominantly transient hotels, motels, and the like, except those occupied by persons who consider the hotel their usual place of residence; quarters in institutions, general hospitals, and military installations, except those occupied by staff members or resident employees who have separate living arrangements.

Student/University Housing: Please be aware, college and university student housing may be considered noninstitutional group quarters and not a housing unit for purposes of meeting the RHNA. According to the census, college/university student housing includes residence halls and other buildings, including apartment-style student housing, designed primarily to house college and university students in group living arrangements either on or off campus. These facilities are owned, leased, or managed by a college, university, or seminary or can be owned, leased, or managed by a private company or agency.

Residents typically enter into “by the bed” leases (i.e., single-liability leases). Another distinguishing factor is that the unit is not available for rent to non-students. For further information on whether university housing meets the definition of a housing unit, please contact the Department of Finance at (916) 323-4086. End definitions Exempt entity-controlled sites (state excess sites, military, university, and tribal land) HCD recognizes that the development of new housing on exempt entity sites (land controlled by exempt federal, state, or tribal entities) can meet a portion of a jurisdiction’s RHNA. However, sites located on land controlled by exempt entities are analyzed differently because the jurisdiction may not have control over the planning, permitting, and decision-making processes of land owned by another public entity.

Sites controlled by exempt entities can be used to accommodate RHNA when documentation can be provided that demonstrates the likelihood that the planned housing will be developed within the current RHNA/housing element cycle. Adequate documentation can vary due to differences in the planning processes on land controlled by exempt federal, state, or tribal entities. The following are examples of documentation that demonstrates the likelihood of housing being developed on sites outside the control of a local government. In each of these examples, the units would have to meet the U.S.

Census Bureau (Census) definition of a housing unit:

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Site Inventory Guidebook Page 7 May 2020
x Agreement with the entity controlling the land that grants the jurisdiction authority regarding approving, permitting, certifying occupancy, and/or reporting new units to the California Department of Finance.
x Documentation from the entity controlling the land that demonstrates planned housing has been approved to be built within the current RHNA cycle. x Data pertaining to the timing of project construction and unit affordability by household income category.
x If the site is listed on the Department of General Services Real Estate Excess State Property map located EO N-06-19 Affordable Housing Development webpage.

Step 2: Inventory of Sites
Government Code section 65583.2(b)
Provide a parcel specific inventory of sites that includes the following information for each site:
x *NEW* Assessor parcel number(s).
x Size of each parcel (in acres).
x General plan land use designation.
x Zoning designation.
x For nonvacant sites, a description of the existing use of each parcel (See Part D) x *NEW* Whether the site is publicly owned or leased.
x Number of dwelling units that the site can realistically accommodate (See Part C) x *NEW* Whether the parcel has available or planned and accessible infrastructure (Part A: Step 3).
x *NEW* The RHNA income category the parcel is anticipated to accommodate (See Part A: Step 5).
x *NEW* If the parcel was identified in a previous planning period site inventory (Part B: Step 1).
*NEW* Please note pursuant to Chapter 667, Statutes of 2019 (SB 6), the site inventory must be prepared using the standards, form, and definitions adopted by HCD. HCD has prepared a form and instructions for this purpose that includes space for the information above and commonly provided optional fields. Starting January 1, 2021, local governments will need to submit an electronic version of the site inventory to HCD on this form along with its adopted housing element.
*NEW* Pursuant to Chapter 664, Statutes of 2019 (AB 1486), at Government Code section 65583.2(b)(3), if a site included in the inventory is owned by the city or county, the housing element must include a description of whether there are any plans to sell the property during the planning period and how the jurisdiction will comply with the Surplus Land Act Article 8 (commencing with Section 54220) of Chapter 5 of Part 1 of Division 2 of Title 5.

Step 3: Infrastructure Availability
Government Code section 65583.2(b)(5)(B)
Determine if parcels included in the inventory, including any parcels identified for rezoning, have sufficient water, sewer, and dry utilities available and accessible to support housing development or whether they are included in an existing general plan program or other mandatory program or plan, including a program or plan of a public or private entity to secure sufficient water, sewer, and dry utilities supply to support housing development on the site in time to make housing development realistic during the planning period. Dry utilities include, at minimum, a reliable energy s
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Site Inventory Guidebook Page 8 May 2020
home and could also include access to natural gas, telephone and/or cellular service, cable or satellite television systems, and internet or Wi-Fi service.

If Yes: Provide an analysis in the housing element describing existing or planned water, sewer, and other dry utilities supply, including the availability and access to parcels on the site inventory, distribution facilities, general plan programs or other mandatory program or plan (including a program or plan of a public or private entity to secure water or sewer service) to support housing development on the site. The housing element must include sufficient detail to determine whether the service levels of water delivery/treatment systems and sewer treatment facilities are sufficient and have the capacity to accommodate development on all identified sites in order to accommodate the RHNA. For example, the water supply should be a reliable supply that meets federal and state drinking water standards.

Please note sites identified as available for housing for above moderate-income households can still be in areas not served by public sewer systems.

If No: Include a program in the housing element that ensures access and availability to infrastructure to accommodate development within the planning period. If this is not possible, the site is not suitable for inclusion in the site inventory or in a program of action identifying a site for rezoning.

Step 4: Map of Sites
Government Code section 65583.2(b)(7)
Provide a map that shows the location of the sites included in the inventory. While the map may be on a larger scale, such as the land use map of the general plan, the more detailed the map, the easier it will be to demonstrate the sites meet new requirements pursuant to Chapter 958, Statutes of 2018 (AB 686) as stated below.

Step 5: Determination of Consistency with Affirmatively Furthering Fair Housing Government Code section 65583.2(a)
*NEW* Pursuant to AB 686, for housing elements due on or after January 1, 2021, sites must be identified throughout the community in a manner that affirmatively furthers fair housing opportunities (Government Code Section 65583(c)(10)).

Affirmatively Furthering Fair Housing means “taking meaningful actions, in addition to combating discrimination, that overcome patterns of segregation and fosters inclusive communities free from barriers that restrict access to opportunity based on protected characteristics. Specifically, affirmatively furthering fair housing means taking meaningful actions that, taken together, address significant disparities in housing needs and in access to opportunity, replacing segregated living patterns with truly integrated and balanced living patterns, transforming racially and ethnically concentrated areas of poverty into areas of opportunity, and fostering and maintaining compliance with civil rights and fair housing laws. The duty to affirmatively further fair housing extends to all of a public agency’s3 3 Public Agencies include the state, including every state office, officer, department, division, bureau, board, and commission, including the California State University, a city, including a charter city, county, including a charter county, city and county, and a redevelopment successor agency, a public housing authority created pursuant to the Housing Authorities Law, a public housing agency, and any other political subdivision of the state that is a grantee or subgrantee receiving funds provided by the United States Department of Housing and Urban Development (Government Code section 8899.5(a)(2).

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Site Inventory Guidebook Page 9 May 2020
activities and programs relating to housing and community development.” (Government Code section 8899.50(a)(1)).

For purposes of the housing element site inventory, this means that sites identified to accommodate the lower-income need are not concentrated in low-resourced areas (lack of access to high performing schools, proximity to jobs, location disproportionately exposed to pollution or other health impacts) or areas of segregation and concentrations of poverty.

Instead, sites identified to accommodate the lower income RHNA must be distributed throughout the community in a manner that affirmatively furthers fair housing. One resource the jurisdiction could use when completing this analysis is the California Tax Credit Allocation/California Department of Housing and Community Development Opportunity Maps, which can be accessed at https://www.treasurer.ca.gov/ctcac/opportunity.asp.

Particularly, the jurisdiction should consider the barriers and opportunities identified in its assessment of fair housing pursuant to Government Code section 65583(c)(10). HCD plans to release a technical assistance memo to assist jurisdictions in addressing AB 686 requirements in their housing element in the Summer of 2020.

Jurisdictions should also consider integrating this analysis with the requirements of Government Code 65302(h), as added by SB 1000 (Statutes of 2016), which requires the preparation and adoption of an Environmental Justice element or equivalent environmental justice-related policies, objectives, and goals throughout other elements of their general plan, to address the needs of disadvantaged communities. More information on Environmental Justice elements can be found on the Governor’s Office of Planning and Research Website.

Step 6: Sites by RHNA Income Category
Government Code section 65583.2(c)
*NEW* Identify which RHNA income category that each site in the inventory is anticipated to accommodate. On the site inventory, specify whether the site or a portion of the site is adequate to accommodate lower income housing, moderate-income housing, or above moderate-income housing. Sites can accommodate units for more than one income category. However, the inventory should indicate the number of units of each income category, and together the total of units attributed to each income category may not exceed total units attributed to the site, so that no unit is designated for more than one income category. This requirement is particularly important because the No Net Loss Law (Government Code section 65863) requires adequate sites be maintained throughout the planning period to accommodate the remaining RHNA by income category. For more information, please consult the HCD’s memo on No Net Loss Law.

HCD Best Practices for selecting sites to accommodate the lower income RHNA:

When determining which sites are best suited to accommodate the RHNA for lower income households, the jurisdiction should consider factors such as:
x Proximity to transit.
x Access to high performing schools and jobs.
x Access to amenities, such as parks and services.
x Access to health care facilities and grocery stores.
x Locational scoring criteria for Low-income Housing Tax Credit (TCAC) Program funding. x Proximity to available infrastructure and utilities.

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Site Inventory Guidebook Page 10 May 2020
x Sites that do not require environmental mitigation.
x Presence of development streamlining processes, environmental exemptions, and other development incentives.

Step 7: Environmental Constraints
Government Code section 65583.2(b)(4)
Provide in the analysis a general description of any known environmental or other features (e.g., presence of floodplains, protected wetlands, oak tree preserves, very high fire hazard severity zones) that have the potential to impact the development viability of the identified sites. The housing element need only describe those environmental constraints where documentation of such conditions is available to the local government. This analysis must demonstrate that the existence of these features will not preclude development of the sites identified in the planning period at the projected residential densities/capacities. This information need not be identified on a site-specific basis. However, local governments will find it beneficial to describe site specific environmental conditions when demonstrating site suitability and realistic buildout capacity of each site, as these types of impediments to building must be considered when determining how many residential units can be developed on the site.

NEXT STEP:
x If the site is selected to accommodate its low or very-low income RHNA, move to Part B: Sites to Accommodate Low and Very-Low Income RHNA.
x If the site accommodates moderate or above-moderate RHNA, move to Part C:

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PART B: SITES TO ACCOMMODATE LOW AND VERY LOW- INCOME RHNA Step 1: *NEW* Sites Used in Previous Planning Periods Housing Elements Government Code section 65583.2(c)
Determine if the site identified to accommodate the low- and very low-income RHNA pursuant to Part A, Step 6 was used in the previous planning period4. Generally, previously identified sites refer to parcels that were identified in a previous housing element’s site inventory to accommodate any portion of any income category of the jurisdiction’s RHNA, as follows:

For a nonvacant site: Included in a prior planning period’s housing element (e.g., 5th cycle housing element)
For a vacant site (see definition of vacant site on page 21): Included in two or more consecutive planning periods (e.g., 5th cycle and 4th cycle housing element) If Yes: move to Step 1A
If No: move to Step 2
Unusual Circumstances
Sites rezoned or identified for rezoning to accommodate a RHNA shortfall Previously identified sites can also include sites that were subject to a previous housing element’s rezone program but that were ultimately not rezoned. For example: a previous housing element’s rezone program to address a shortfall of sites for lower income households committed to rezone four acres to R-4 zoning, and identified five candidate sites for rezoning, A through E, and each site was two acres in size. If the program was completed in the prior planning period and four acres were rezoned, only those sites rezoned are considered “previously identified.” However, if none or fewer than four acres were rezoned, all the non-rezoned sites identified as candidate sites would be considered as “previously identified.”
Sites rezoned to a higher density as part of a general plan update (not needed to accommodate a shortfall)
Due to updates in the prior planning period to the general plan or other planning activities, such as the creation of a specific plan, some sites previously identified in the housing element may have been rezoned allowing a higher density, and therefore increasing the potential housing capacity of the site. Because the zoning characteristics of this site have changed, it can be considered a new site for the purposes of the housing element inventory. This is only the case if it was not utilized to accommodate a shortfall of sites to accommodate the RHNA. End unusual circumstances
4 Sites in unincorporated areas in a nonmetropolitan county without a micropolitan area are exempt from this step. This includes the unincorporated parts of Alpine, Amador, Calaveras, Colusa, Glenn, Mariposa, Modoc, Mono, Plumas, Sierra, Siskiyou
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Site Inventory Guidebook Page 12 May 2020
Step 1A:

Indicate in the housing element site inventory that this parcel was used in a prior housing element planning period.

Step 1B:

Include a program in the housing element requiring rezoning within three years of the beginning of the planning period to allow residential use by right at specified densities (see Step 2) for housing developments in which at least 20 percent of the units are affordable to lower income households. This program can be an overlay on these specific sites. Please be aware that the intent of this requirement is to further incentivize the development of housing on sites that have been available over one or more planning periods. The application of the requirement should not be used to further constrain the development of housing. As such, housing developments that do not contain the requisite 20 percent would still be allowed to be developed according to the underlying (base) zoning but would not be eligible for “by right” processing. However, the jurisdiction would have to make findings on the approval of that project pursuant to No Net Loss Law (Government Code section 65863) and proceed to identify an alternative site or sites pursuant to that law. Sites where zoning already permits residential “use by right” as set forth in Government Code section 65583.2 (i) at the beginning of the planning period would be considered to meet this requirement.

Definition of Use By Right (Government Code section 65583.2 (i)) By right means the jurisdiction shall not require:
x A conditional use permit.
x A planned unit development permit.
x Other discretionary, local-government review or approval that would constitute a “project” as defined in Section 21100 of the Public Resources Code (California Environmental Quality Act “CEQA”).

However, if the project requires a subdivision, it is subject to all laws, including CEQA.

This does not preclude a jurisdiction from imposing objective design review standards.

However, the review and approval process must remain non discretionary and the design review must not constitute a “project” as defined in Section 21100 of the Public Resources Code. For example, a hearing officer (e.g., zoning administrator) or other hearing body (e.g., planning commission) can review the design merits of a project and call for a project proponent to make design-related modifications, but cannot exercise judgment to reject, deny, or modify the “residential use” itself. (See McCorkle Eastside Neighborhood Group v.

City of St. Helena (2019) 31 Cal.App.5th 80.)
For reference, CEQA applies when a governmental agency can exercise judgment in deciding whether and how to carry out or approve a project. This makes the project “discretionary” (CEQA Guidelines, §15357.) Where the law requires a governmental agency to act on a project using fixed standards and the agency does not have authority to use its own judgment, the project is called “ministerial,” and CEQA does not apply. (CEQA Guidelines, §§ 15268(a), 15369.)
DRAFT
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Site Inventory Guidebook Page 13 May 2020
Sample Program:

Provide Adequate Sites for Lower Income Households on Nonvacant and Vacant Sites Previously Identified
The City of X will rezone to allow developments by right pursuant to Government Code section 65583.2(i) when 20 percent or more of the units are affordable to lower income households on sites identified in Table A to accommodate the lower income RHNA that was previously identified in past housing elements. Specifically, the City will rezone the nonvacant sites identified on Table A previously identified in the 5th cycle housing element, and the vacant sites identified on Table A as previously identified for both the 5th and 4th cycle housing elements.

Objective: Create opportunity for at least X units of rental housing for lower income households
Responsible Agency: Community Development Department
Timeline: Sites rezoned by (a specific date, no more than three years from the beginning of the planning period)
Funding Source(s): General fund
Step 2: Zoning Appropriate to Accommodate Low- and Very Low- Income RHNA Government Code section 65583.2(c)(3)
Determine if the zoning on the site is appropriate to accommodate low- and very lowincome (termed together as “lower”) housing.

The statute allows jurisdictions to use higher density as a proxy for lower income affordability, as long as certain statutory requirements are met. Parcels must be zoned to allow sufficient density to accommodate the economies of scale needed to produce affordable housing. To make this determination, the statute allows the jurisdiction to either demonstrate that the zoning allows a specific density set forth in the statute (default density)5 or to provide an analysis demonstrating the appropriateness of the zoned densities of the site identified to accommodate the lower RHNA.

Step 2A: Does the parcel’s zoning allow for “at least” the following densities? x For an incorporated city within a nonmetropolitan county and for a nonmetropolitan county that has a micropolitan area: sites allowing at least 15 units per acre. x For an unincorporated area in a nonmetropolitan county not included in the first bullet:
sites allowing at least 10 units per acre.
x For a suburban jurisdiction: sites allowing at least 20 units per acre. x For a jurisdiction in a metropolitan county: sites allowing at least 30 units per acre. “At least” means the density range allowed on the parcel by the zone has to include the default density. For example, if a jurisdiction has a default density of 30 units per acre and the zone allows for range of 24 – 35 units per acre, the zoning is considered appropriate to accommodate the RHNA for lower income households. This is different than the program standard outlined in Part E which requires a minimum of a specific density in the allowed 5 Sometimes called “Mullin densities” after the author of AB 2348, Statutes of 2004, which originated these requirements.

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Site Inventory Guidebook Page 14 May 2020
density range in the zone. To determine the default density for jurisdictions, please refer to HCD Memorandum: Default Density Standard Option (2010 Census Update).

If Yes: Move to Step 3
If No: Move to Step 2B
Step 2B: Can the analysis demonstrate the appropriateness of the zoning to accommodate housing?
Provide an analysis demonstrating how the allowed densities facilitate the development of housing to accommodate the lower income RHNA. The analysis shall include, but is not limited to, factors such as market demand, financial feasibility, and information based on development project experience within a zone or zones, or at densities that accommodate housing for lower income households.

Information gathered from local developers on densities ideal for housing development in the community and examples of recent residential projects that provide housing for lower income households is helpful in establishing the appropriateness of the zone. Other information could include land costs, market demand for various types of affordable housing, and the gap between typical market rents and subsidized rents. It is recognized that housing affordable to lower income households requires significant subsidies and financial assistance. However, for this analysis, identifying examples of subsidized housing projects alone is not sufficient to demonstrate the adequacy of a zone and/or density to accommodate the housing affordable to lower income households. In particular, identification of older project(s) or one-off projects that cannot be easily duplicated is not sufficient to demonstrate a development trend.

The analysis of “appropriate zoning” should not include residential buildout projections resulting from the implementation of a jurisdiction’s inclusionary program or potential increase in density due to a density bonus, because these tools are not a substitute for addressing whether the underlining (base) zoning densities are appropriate to accommodate the RHNA for lower income households. Additionally, inclusionary housing ordinances applied to rental housing must include options for the developer to meet the inclusionary requirements other than exclusively requiring building affordable units on site.

While an inclusionary requirement may be a development criterion, it is not a substitute for zoning. The availability of density bonuses is also not a substitute for an analysis, since they are not a development requirement, but are development options over the existing density, and generally require waivers or concessions in development standards to achieve densities and financial feasibility.

If Yes: Move to Step 3
If No: Site is not appropriate to accommodate lower income. Reclassify pursuant to Part A, Step 5. DRAFTg to ac
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s shall include, but FT
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If No: Site is not appro Site is not appr
ep 5.

Site Inventory Guidebook Page 15 May 2020
Housing Overlays
Affordable housing or zoning overlays are a zoning tool that allows jurisdictions to modify existing zoning to allow for or require certain types of residential development, or development at certain densities, on a parcel without modifying the standards of the underlying zoning district. Usually, they have specific requirements and conditions (e.g., a percentage of the development must be deed-restricted as affordable to lower income households for a specific number of years) that must be met in order for a developer to take advantage of the overlay. These are often combined with incentives to encourage developers to utilize the overlay. Jurisdictions use overlays to help promote a specific type of development, and to increase densities without having to go through a rezoning procedure on the actual parcel and can be more useful when issues such as density and affordable housing become contentious. To ensure the overlay is considered zoning and not just a development incentive, the overlay must demonstrate the following:
x There is no additional discretionary action needed above what is required in the base zone (i.e., a conditional use permit or other review) for a developer to take advantage of overlay.
x Development standards are consistent with those needed to allow for the density allowed under the overlay. Development standards for use exclusively in the overlay may be needed in order to ensure maximum allowable densities can be achieved. x The developer can access State Density Bonus Law in addition to using the densities allowed in the overlay. For example, if the underlying zoning allows a maximum density of 15 units per acre, but the overlay allows a maximum density of 25 units per acre, and if the developer is using the overlay and wants to use State Density Bonus Law, the density bonus is calculated assuming the base density is 25 units per acre.

If the overlay has conditions such as an affordability requirement, incentives should be sufficient and available to make development feasible and more profitable than the underlying zoning.

For an affordable housing overlay, the element should describe affordability threshold requirements to utilize the overlay (i.e., percentage of units and levels of affordability which must be met to develop at the increased densities). Please note, the jurisdiction should talk with for-profit and nonprofit developers to determine an appropriate mix of incomes that make development feasible in their community. For example, a 100 percent affordability requirement may act as a constraint to using the overlay depending on the level of subsidy required per unit and the availability of funding to support the level of affordability or available incentives. End Housing Overlay
Step 3: Size of Sites
Government Code section 65583.2(c)(2)(A), (B), and (C)
*NEW* Is the size of the site appropriate to accommodate housing for lower income households?
To achieve financial feasibility, many assisted housing developments using state or federal resources are between 50 to 150 units. Parcels that are too small may not support the number of units necessary to be competitive and to access scarce funding resources.

Parcels that are large may require very large projects, which may lead to an over concentration of affordable housing in one location, or may add cost to a project by DRAFTdition
ower inco ower in
or a developer t or a dev
to encourage to enco
p promote a specific type p promote a s
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n issues such as density and n issues such as densit
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ded above what is required in the base
review) for a developer to take advantage eview) for a developer with those needed to allow for the densit e needed to a ment standards for use exclusively in the for use e
e maximum allowable densities can be ac e maximum allowable densit e Density Bonus Law in addition to using e Density Bonus Law in addition xample, if the underlying zoning allows a ple, if the underlying zoning allow he overlay allows a maximum density of 2 ay allows a maximum density of 2 g the overlay and wants to use State Den y and wants to use State De culated assuming the base density is 25 u g the base density is 25 u onditions such as an affordability require onditions such as an affordab ailable to make development feasible and ailable to make development fe ning.
fordable housing overlay, the element sh rdable housing overlay, the element sh ements to utilize the overlay (i.e., percent to utilize the overlay (i.e., percent st be met to develop at the increased den develop at the increased den ith for-profit and nonprofit developers to profit and nonprof make development feasible in their com make development feasible D requirement may act as a constraint requirement may act as a cons required per unit and the availabili required per unit and the availab available incentives. End Housi
Step 3: Ste Size of Sites
Government Code sect Government Code se
EW* Is the size o
eholds?De
Site Inventory Guidebook Page 16 May 2020
requiring a developer to purchase more land than is needed, or render a project ineligible for funding. If the size of the site is smaller than one half acre or larger than 10 acres, the following analysis is required.

If the parcel is more than 0.5 acres or less than 10 acres, is the size of the site automatically considered appropriate to accommodate lower income RHNA? Not necessarily. If the size of the parcel in combination with the allowable density and accompanying development standards cannot support a housing development affordable to lower income households, further analysis and programs may be needed to demonstrate the suitability of that site to accommodate the portion of the RHNA for lower income households. End Question and Answer
Is the size of the parcel under 0.5 acres?
If Yes: Move to Step 3A
Is the size of the parcel over 10 acres?
If Yes: Move to Step 3B
If No to Both: Move to Part C: Capacity Analysis
Step 3A: Sites smaller than 0.5 acres
A parcel smaller than one half acre is considered inadequate to accommodate housing affordable to lower income households, unless the housing element demonstrates development of housing affordable to lower income households on these sites is realistic or feasible. While it may be possible to build housing on a small parcel, the nature and conditions (i.e., development standards) necessary to construct the units often render the provision of affordable housing infeasible. The housing element must consider and address the impact of constraints associated with small lot development on the ability of a developer to produce housing affordable to lower income households. To demonstrate the feasibility of development on this type of site, the analysis must include at least one of the following:
x An analysis demonstrating that sites of equivalent size were successfully developed during the prior planning period with an equivalent number of lower income housing units as projected for the site.
x Evidence that the site is adequate to accommodate lower income housing. Evidence could include developer interest, potential for lot consolidation, densities that allow sufficient capacity for a typical affordable housing project, and other information that can demonstrate to HCD the feasibility of the site for development. For parcels anticipated to be consolidated, the housing element must include analysis describing the jurisdiction’s role or track record in facilitating small lot consolidation, policies or incentives offered or proposed to encourage and facilitate lot consolidation, conditions rendering parcels suitable and ready for consolidation such as common ownership, and recent trends of lot consolidation. The housing element should include programs promoting, incentivizing, and supporting lot consolidations and/or small lot development. x A site may be presumed to be realistic for development to accommodate lower income housing need if, at the time of the adoption of the housing element, a development affordable to lower income households has been proposed and approved for development on the site.

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Site Inventory Guidebook Page 17 May 2020
The housing element must also describe existing and proposed policies or incentives the jurisdiction will offer to facilitate development of small sites. Examples of program incentives for lot consolidation include deferring fees specifically for consolidation, expediting permit processing, providing flexible development standards such as setback requirements, reduced parking or increased heights, committing resources for development of affordable housing on small sites, or increasing allowable density, lot coverage or floor area ratio.

Step 3B: Sites larger than 10 acres
Parcels larger than 10 acres are considered inadequate to accommodate housing affordable to lower income households, unless the housing element demonstrates development of housing affordable to lower income households on such sites was successful during the prior planning period, or there is other evidence that the site is realistic and feasible for lower income housing.

Definition of a Large Site
For purposes of this requirement, “site” means that portion of the parcel designated to accommodate lower income housing needs. For example, a parcel greater than 10 acres in size could have to be split zoned, have an overlay zone with identified boundaries, or be identified in a specific plan that provides for subdivision of the parcel. If the specified boundaries of the site identified to accommodate the RHNA for lower income is less than 10 acres in size, then the large site analysis would not be required. However, the analysis must describe how the development will work on the site, including opportunities and timing for specific-plan development, further subdivision, or other methods to facilitate the development of housing affordable to lower income households on the identified site within the planning period. End definition
To demonstrate the feasibility of development on this type of site, the analysis must include at least one of the following:
x An analysis demonstrating that sites of equivalent size were successfully developed during the prior planning period with an equivalent number of lower income housing units as projected for the site.
x Evidence that the site is adequate to accommodate lower income housing. Evidence may include developer interest, proposed specific-plan development, potential for subdivision, the jurisdiction’s role or track record in facilitating lot splits, or other information that can demonstrate to HCD the feasibility of the site for development. The housing element should include programs promoting, incentivizing, and supporting lot splits and/or large lot development.
x A site may be presumed to be realistic for development to accommodate lower income housing need if, at the time of the adoption of the housing element, a development affordable to lower income households has been proposed and approved for development on the site. DRAFTerage
modate housing modate hous
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s that portion of the parcel designated to hat portion of the par s. For example, a parcel greater than 10 ample, a parce an overlay zone with identified boundarie with ide
es forsubdivision ofthe parcel. If the the pa spe
accommodate the RHNA for lower accommodate the RHNA for low incom site analysis would not be require analysis would not be required. Howe d. H opment will work on the site will work on the site, including opp including op ent, further subdivision, or other methods subdivision, or other methods affordable to lower income households o seholds o
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Site Inventory Guidebook Page 18 May 2020
Specific Plans, Master Plan, and other Subdivisions
To utilize residential capacity in Specific Plan areas, areas under a Master Plan, or a similar multi-phased development plan, the housing element must identify specific sites by parcel number and demonstrate that the sites are available and suitable for development within the planning period. The analysis should include the following information:
x Identify the date of approval of the plans and expiration date. x Identify approved or pending projects within these plans that are anticipated in the planning period, including anticipated affordability based on the actual or projected sale prices, rent levels, or other mechanisms establishing affordability in the planning period of the units within the project.
x Describe necessary approvals or steps for entitlements for new development (e.g., design review, site plan review, etc.).
x Describe any development agreements, and conditions or requirements such as phasing or timing requirements, that impact development in the planning period. End information on planned development.

The housing element must also describe existing and proposed policies or incentives the jurisdiction will offer to facilitate development of large sites. Examples of facilitation include expedited or automatic approval of lot splits or creation of new parcels, waivers of fees associated with subdivision, or expedited processing or financial assistance with the development of infrastructure required to develop the site.

NEXT STEP:
x Move to Part C: Capacity Analysis DRAFTanticipated in the anticipa e actual or projected sale e actual or p
ability in the planning period ability in the planniT
ts for new development (e.g.,
nditions or requirements such as nditions or require
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Capacity Analysis n
Site Inventory Guidebook Page 19 May 2020
PART C: CAPACITY ANALYSIS
Government Code Section 65583.2(c) requires, as part of the analysis of available sites, a local government to calculate the projected residential development capacity of the sites identified in the housing element that can be realistically be achieved. The housing element must describe the methodology used to make this calculation. Jurisdictions have two options to make this calculation.
x Utilize minimum densities (Step 1)
x Utilize adjustment factors (Step 2)
Step1: Utilizing minimum densities to calculate realistic capacity of sites Government Code section 65583.2(c)(1)
If the jurisdiction has adopted a law, policy, procedure, or other regulation that requires the development of a site to contain at least a certain minimum residential density, the jurisdiction can utilize that minimum density to determine the capacity of a site. For purposes of this analysis, the use of either gross or net acreage is acceptable but should be consistent with the standard the jurisdiction typically uses for determining allowable units for a residential development project. For example:

Site Description Value
Size of site (Gross acreage) 3 acres
Zoning Residential Multifamily
Allowable density 20 (required minimum) – 30 dwelling units per acre
Realistic capacity utilizing minimum 3 X 20 = 60 units
Please note, to meet this standard on a zone that allows for multiple uses, the general plan or zoning must require the specified minimum number of residential units on the identified sites regardless of overlay zones, zoning allowing nonresidential uses, or other factors potentially impacting the minimum density. Otherwise, the capacity of the site must be calculated using the factors outlined in Step 2.

Step 2: Utilizing factors to calculate realistic capacity of sites Government Code section 65583.2(c)(2)
The housing element must describe the methodology used to determine the number of units calculated based on the following factors:
x Land use controls and site improvements requirements, x *NEW* The realistic development capacity for the site, x *NEW* Typical densities of existing or approved residential developments at a similar affordability level in that jurisdiction,
x *NEW* The current or planned availability and accessibility of sufficient water, sewer, and dry utilities. DRAFThave
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Site Inventory Guidebook Page 20 May 2020
Applicable land-use controls and site improvement requirements The analysis must consider the imposition of any development standards that impact the residential development capacity of the sites identified in the inventory. When establishing realistic unit capacity calculations, the jurisdiction must consider the cumulative impact of standards such as maximum lot coverage, height, open space, parking, on-site improvements such as sidewalks or easements, and floor area ratios. The analysis should consider any development standards or the cumulative effect of development standards that would limit the achievable density on a site. For example, if a mixed-use zone requires commercial on the ground floor and has a height limit of three stories along with lot coverage and other development standards, the density that can actually be achieved on that site might be less than the maximum allowable density.

The capacity of a site should also be adjusted for areas that cannot be developed due to environmental factors such as hazards, wetlands, or topography that cannot be mitigated.

The capacity of sites subject to specific plans, overlays or other modifications of the base zoning should be adjusted to reflect those factors. For purposes of this analysis, it is recommended that the jurisdiction start with the gross acreage and adjust the buildable acreage accordingly to reach net buildable acreage.

Form Based Codes
To estimate capacity for sites in jurisdictions that have adopted form-based codes, the element should describe the relationship between general plan land-use designation and the form-based code and density assumptions used to determine capacity. Specifically, describe where residential development is allowed, how density requirements found within the general plan are incorporated, how the zoning designations under the form-based code relate to the land-use designations of the general plan, identify potential densities, and consider development standards such as bulk, height, and build-to requirements, buildings types, and use requirements. The element could include examples of recently built projects and densities to support the analysis. End Form Base Codes Realistic development capacity for nonresidential, nonvacant, or overlay zoned sites The capacity calculation must be adjusted to reflect the realistic potential for residential development capacity on the sites in the inventory. Specifically, when the site has the potential to be developed with nonresidential uses, requires redevelopment, or has an overlay zone allowing the underlying zoning to be utilized for residential units, these capacity limits must be reflected in the housing element. Factors used to make this adjustment may include the following:
x Performance standards mandating a specified portion of residential development in mixed use or nonresidential zones (e.g., residential allowed only above first floor commercial).
x The likelihood for residential development such as incentives for residential use, market demand, efforts to attract and assist developers, or allowance of 100 percent residential development.
x Local or regional residential development trends in the same nonresidential zoning districts.
x Local or regional track records, past production trends, or net unit increases/yields for redeveloping sites or site intensification. This estimate may be based on the rate at which similar parcels were developed during the previous planning period, with T
analys
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Site Inventory Guidebook Page 21 May 2020
adjustments as appropriate to reflect new market conditions or changes in the regulatory environment. If no information about the rate of development of similar parcels is available, report the proportion of parcels in the previous housing element’s site inventory that were developed during the previous planning period. For example, if past production trends indicate that two out of three similar sites were developed for residential use, and one out of three similar sites was developed for commercial use, an initial estimate of the proportion of new development which is expected to be residential would be two-thirds, i.e., 0.67.
x Local or regional track records, trends, or build out yields for redeveloping sites or site intensification.

In addition, the housing element should include monitoring programs with next-step actions to ensure sites are achieving the anticipated development patterns. The programs should identify modifications to incentives, sites, programs, or rezoning the jurisdiction will take should these strategies not yield the expected housing potential.

Typical densities of existing or approved residential developments at a similar affordability level in that jurisdiction
While using typically built densities to determine realistic capacity has long been an option to be used as an adjustment factor, the statute now requires this factor to be adjusted based on approved project by affordability level. For example, if a site is identified to accommodate the lower income RHNA, it should use project densities for housing affordable to lower income households developed either locally or regionally to determine typical densities6. Using this adjustment factor may result in utilizing different capacity methodologies for above moderate-, moderate-, and lower income sites.

Current or planned availability and accessibility of sufficient water, sewer, and dry utilities The capacity methodology must be adjusted to account for any limitation as a result of availability and accessibility of sufficient water, sewer, and dry utilities (i.e., if the capacity of the site could be limited because a development would have to use a septic system, if there are any septic tank requirements or restrictions that constrain capacity, or limitations on water hook-ups). See Part A, Step 3 for more information on infrastructure requirements.

Example Capacity Calculation
Here is an example of the actual capacity calculation for a particular site in the inventory.

The methodology analysis must describe how each of these adjustments was generated per the analysis requirements above. The factors used below are based on the factors outlined in the statute. The percentages and how the factors are applied will vary depending on the unique circumstance in each jurisdiction. 6 In using this adjustment factor, because of the use of density bonus, it may be possible that trends demonstrate typical densities higher than the maximum allowable densities, especially for housing affordable to lower income households. On a case-by-case basis, it may be appropriate to utilize increased densities due to density bonuses when determining the adjustment factor in the capacity methodology.

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Site Inventory Guidebook Page 22 May 2020
Site Description
Size of site 2.5 acres
Zoning Residential Mixed-Use
Allowable density 20 – 45 dwelling units per acre
RHNA affordability Lower income
Existing Use Nonvacant, single storefront
Infrastructure availability Yes, no constraints
Environmental constraints None known
Capacity Factors Adjustment Reasoning
Land Use Controls and
Site Improvements
95% For net acreage due to on-site
improvements including sidewalks,
utility easement
Realistic capacity of the
site
55% 55% adjustment based on past
development trends for residential
redevelopment in the residential
mixed-use zones, and programs to
incentivize development in this zone.

Typical densities 95% Affordable housing projects are built out to almost maximum density
Infrastructure availability No adjustment Not applicable, no constraint Environmental constraints No adjustment No known site constraint Realistic capacity utilizing factors = (2.5 X 45)( .95)(.55)(.95) = 56 units Realistic Capacity = 56 Units
No Net Loss Law
In estimating realistic capacity on sites in the sites inventory, jurisdictions may want to consider No Net Loss Law. This law was amended by Chapter 367, Statutes of 2017 (Senate Bill 166), which requires sufficient adequate sites to be available at all times throughout the RHNA planning period to meet a jurisdiction’s remaining unmet housing needs for each income category. To comply with the No Net Loss Law, as jurisdictions make decisions regarding zoning and land use, or development occurs, jurisdictions must assess their ability to accommodate new housing in each income category on the remaining sites in their housing element site inventories. A jurisdiction must add additional sites to its inventory if land use decisions or development results in a shortfall of sufficient sites to accommodate its remaining housing need for each income category. In particular, a jurisdiction may be required to identify additional sites according to the No Net Loss Law if a jurisdiction rezones a site or if the jurisdiction approves a project at a different income level than shown in the sites inventory. Lower density means fewer units than the capacity assumed in the site inventory.

To ensure that sufficient capacity exists in the housing element to accommodate the RHNA throughout the planning period, it is recommended the jurisdiction create a buffer in the housing element inventory of at least 15 to 30 percent more capacity than required, especially for capacity to accommodate the lower income RHNA. Jurisdictions can also create a buffer by projecting site capacity at less than the maximum density to allow for some reductions in density at a project level.

DRAFT
End no net loss law explanation.

TF
age due to on-site
ment including sidewalks
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development trends development trend
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realistic capacity on sites in the sites inv realistic capacity on sites in the sites No Net Loss Law. This law was amended o Net Loss Law. This law was amended e Bill 166), which requires sufficient adequ 166), which requires sufficient adequ ghout the RHNA planning period RHNA planning period to meet eds for each income category. To comply ds for each income ca make decisions regarding zoning and lan make decisions regarding z assess their ability to accommodate n assess their ability to accomm D remaining sites in their housing elem remaining sites in their housing e sites to its inventory if land use d ntory if land use d sites to accommodate its rema odate
jurisdiction may be required jurisdiction may be req
a jurisdiction rezones a s a jurisdiction rezones
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ut t
Site Inventory Guidebook Page 23 May 2020
NEXT STEP:
x If the parcel is nonvacant, including underutilized sites (see definition of vacant site on page 22), move to Part D: Nonvacant Sites Analysis
x If not, move to Part E: Determination of Adequate Sites DRAFT
Site Inventory Guidebook Page 24 May 2020
PART D: NONVACANT SITES
Local governments with limited vacant land resources or with infill and reuse goals may rely on the potential for new residential development on nonvacant sites, including underutilized sites, to accommodate their RHNA. Examples include:
x Sites with obsolete uses that have the potential for redevelopment, such as a vacant restaurant.
x Nonvacant publicly owned surplus or excess land; portions of blighted areas with abandoned or vacant buildings.
x Existing high opportunity developed areas with mixed-used potential. x Nonvacant substandard or irregular lots that could be consolidated. x Any other suitable underutilized land.

Local governments can meet other important community objectives to preserve open space or agricultural resources, as well as assist in meeting greenhouse gas emission-reduction goals, by adopting policies to maximize existing land resources and by promoting more compact development patterns or reuse of existing buildings.

Definition of a Vacant Site
A vacant site is a site without any houses, offices, buildings, or other significant improvements on it. Improvements are generally defined as development of the land (such as a paved parking lot, or income production improvements such as crops, high voltage power lines, oil-wells, etc.) or structures on a property that are permanent and add significantly to the value of the property.

Examples of Vacant Sites:
x No improvement on the site (other than being a finished lot). x No existing uses, including parking lots.
x Underutilized sites are not vacant sites.
x Sites with blighted improvements are not vacant sites. x Sites with abandoned or unoccupied uses are not vacant sites. End definition If the inventory identifies nonvacant sites to address a portion of the RHNA, the housing element must describe the realistic development potential of each site within the planning period. Specifically, the analysis must consider the extent that the nonvacant site’s existing use impedes additional residential development, the jurisdiction's past experience converting existing uses to higher density residential development, market trends and conditions, and regulatory or other incentives or standards that encourage additional housing development on the nonvacant sites. DRAFTch as a va ch as a ighted areas with ighted are
d potential poten .
onsolidated onsolid .
munity objectives to preserve open space
eting greenhouse gas emission-reduction
ng land resources land resources and by promoting more b existing buildings buildings. AF
y houses, offices, buildings, or other sign ouses, offices, buildings, or other ments are generally re generally defined as defined developme ncome production ductio improvements ovements such as
c.) or structures on a property that are pe roperty that are pe ue of the property. ue of the
ant Sites: ant Site
ovement on the site (other than being a fin ovement on the site (other than being a isting uses, including parking lots ting uses, including parking lots. derutilized sites are zed sites are not vacant sites. DR Sites with blighted improvements are ghted impro not
Sites with abandoned or unoccupied u ites with abandoned oRD If the inventory identifies nonvacant If the inventory identifies nonvac element must describe the realist describe the realis
period. Specifically, the analys
use impedes additional resi use impedes additiona
converting conv existing uses t g us
conditions, and regulat conditions, and regula
ousing developme
Site Inventory Guidebook Page 25 May 2020
Step 1: Description of the nonvacant site
Government Code Section 65583.2(b)
As stated in Part A, the site inventory must describe the specific existing use on the site, such as a surplus school site, auto shop, restaurant, single family residence, nursery, etc.

Additional details, such as whether the use is discontinued, land to value information, age and condition of the structure, known leases, developer or owner interest, whether the property is currently being marketed, degree of underutilization, etc., are useful for demonstrating the potential for the site to be redeveloped within the planning period (See Step 2).

Step 2: Nonvacant site analysis methodology
Government Code section 65583.2(g)(1)
Provide an explanation of the methodology used to determine the development potential.

This methodology can be done on a site-specific basis by utilizing factors (e.g., common ownership, valuation, age, etc.) in common that demonstrate the potential for residential development within the planning period, or a combination of both approaches. The methodology shall consider factors including:

Existing Uses:

Include an analysis that demonstrates the extent to which existing uses may constitute an impediment to additional residential development. Among other things, this analysis includes considerations for the current market demand for the existing use, *NEW* an analysis of any known existing leases or other contracts that would perpetuate the existing use or prevent redevelopment of the site for additional residential development, and could include other market conditions that would encourage redevelopment of the property. For example, an analysis might describe an identified site as being developed with a 1960’s strip commercial center with few tenants and expiring leases and, therefore, a good candidate for redevelopment, versus a site containing a newly opened retail center, an active Home Depot, the only grocery store in the city, etc. that is unlikely to be available for residential development within the planning period.

Development Trends:

The inventory analysis should describe development and/or redevelopment trends in the community as it relates to nonvacant sites, i.e., the rate at which similar sites have been redeveloped. This could include a description of the local government’s track record and specific role in encouraging and facilitating redevelopment, adaptive reuse, or recycling to residential or more intensive residential uses. If the local government does not have any examples of recent recycling or redevelopment, the housing element should describe current or planned efforts (via new programs) to encourage and facilitate this type of development (e.g., providing incentives to encourage lot consolidation or assemblage to facilitate increased residential-development capacity). The results of the analysis should be reflected in the capacity calculation described in Part C, above.

Market Conditions:

Housing market conditions also play a vital role in determining the feasibility or realistic potential of nonvacant sites for residential development. The nonvacant sites analysis should include an evaluation of the impact of local market conditions on redevelopment or reuse strategies. For example, high land and construction costs, combined with a limited supply of available and developable land, may indicate conditions “ripe” for more intensive, compact and infill development or redevelopment and reuse.

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whethe
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ermine the development potential
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mbination of both appro
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s the extent to which existin
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ent market demand for the existing
s or other contracts that would pe RAFite for additional residential de RAuld encourage redevelopm might describe an identified site as being might describe an identified s enter with few tenants and expiring leases enter with few tenants and exp development, versus a site containing a n development, versus a site cont Depot, the only grocery store in the city, e Depot, the only grocery store in the development within the planning period. development within the planning period opment Trends t Trends: DR
inventory analysis should describe nalysis shou deve
ommunity as it relates to nonvacant sites lates to
redeveloped. This could include a desc inclu
specific role in encouraging and facil specific role in encouraging and residential or more intensive resid
examples of recent recycling or ent recycling or
current or planned efforts (via current or planned effo development (e.g. dev , providi pro
facilitate increased resid facilitate increased res
reflected in the capac reflected in the capa
et Conditio
markDf
Site Inventory Guidebook Page 26 May 2020
Availability of Regulatory and/or other Incentives:

The analysis should describe existing or planned financial assistance, incentives or regulatory concessions to encourage residential development on nonvacant sites. Many local governments develop partnerships with prospective developers to assist in making redevelopment/reuse economically feasible. Examples of these incentives include:
x Organizing special marketing events geared towards the development community. x Identifying and targeting specific financial resources. x Allowing streamlined or by right development application processing for infill sites. x Reducing appropriate development standards.

Absent a track record or development trends to demonstrate the feasibility of a recycling or redevelopment strategy, the housing element should describe existing or planned financial assistance or regulatory relief from development standards that will be provided sufficient to encourage and facilitate more intensive residential development on the identified nonvacant sites.

Step 3: *NEW* Reliance on nonvacant sites to accommodate more than 50 percent of the RHNA for lower income households
Government Code Section 65583.2(g)(2)
Determine if more than 50 percent of the lower income RHNA is on nonvacant sites. x Calculate the sum of lower income RHNA capacity on vacant sites and other alternatives not related to capacity on nonvacant sites (e.g., accessory dwelling units, vacant sites to be rezoned (see Part E)).
x Subtract that sum from the total lower income RHNA to get the amount of RHNA needed to be accommodated on nonvacant sites.
x Determine if this number is greater than 50 percent of the RHNA.

Example calculation for a jurisdiction with a lower income RHNA of 500:

Adjustment Factor Number of units
Proposed Lower Income Project 50
Accessory Dwelling Unit Capacity (affordable to lower) 15 Capacity on Vacant Sites 100
Total Capacity (not related to non-vacant sites) 165
RHNA on Nonvacant sites 500 - 165 = 335
Percentage of Lower Income RHNA accommodated
on Nonvacant sites
335/500 = 77%
If Yes: Move to Step 3A
If No: Move to Step 4 DRAFTt commun t comm
sing for infill sites sing for i .
e the feasibility of a recycling or e the feasibility of a recyc cribe existing or planned financial cribe existing or planned finan ards that will be p ards th rovided sufficient ufficien to development on the identified develop
es to accommodate more than 50 perc
s
2)
of the lower of the low income RHNA is on nonvaca NA is o income RHNA capacity on vacant e RHNA capacity on vacant sites a o capacity on nonvacant sites on nonvacant sites (e.g., acce oned (see Part E)).
om the total lower m the total lower income RHNA to get t commodated on nonvacant sites. commodated on nonvacant si his number is greater than 50 percent p of t
culation for a jurisdiction with a lower inco sdiction with a lower RA nt Facto DRwer Income Pro
Accessory Dwelling Unit Capacity (afforda cessory Dwelling Unit RD Capacity on V t Sites DR
Total Capacity (not related to non apacity (not related to -va DRonvacant sites Percentage of Lower f Low Income
on Nonvacant sites DR
If Ye Move to Step 3A
f No: Move to Step D4
Site Inventory Guidebook Page 27 May 2020
Step 3A:

If a housing element relies on nonvacant sites to accommodate 50 percent or more of its RHNA for lower income households, the nonvacant site’s existing use is presumed to impede additional residential development, unless the housing element describes findings based on substantial evidence that the use will likely be discontinued during the planning period. The housing element must include the following:
x As part of the resolution adopting the housing elements, findings stating the uses on nonvacant sites identified in the inventory to accommodate the RHNA for lower income is likely to be discontinued during the planning period and the factors used to make that determination. This can be included in the body or in the recital section of the resolution.

Example: WHEREAS, based on <name factors here (e.g., expiring leases, dilapidated building conditions, etc.)>, the existing uses on the sites identified in the site inventory to accommodate the lower income RHNA are likely to be discontinued during the planning period, and therefore do not constitute an impediment to additional residential development during the period covered by the housing element. x The housing element should describe the findings and include a description of the substantial evidence they are based on.

In general, substantial evidence includes facts, reasonable assumptions predicated upon facts, and expert opinion supported by facts. An example of substantial evidence would be a nonvacant site with a grocery store and with a building lease expiring in a year, and evidence that the store has entered into a lease to relocate to another site subsequent to the lease expiring.

Examples of substantial evidence that an existing use will likely be discontinued in the current planning period include, but are not limited to:
- The lease for the existing use expires early within the planning period, - The building is dilapidated, and the structure is likely to be removed, or a demolition permit has been issued for the existing uses,
- There is a development agreement that exists to develop the site within the planning period,
- The entity operating the existing use has agreed to move to another location early enough within the planning period to allow residential development within the planning period.
- The property owner provides a letter stating its intention to develop the property with residences during the planning period.

If multiple sites make up a common existing use and the same factors affect each of the sites, the same findings can be used for each of the sites (e.g., an abandoned shopping mall with sites under common ownership that will not be restored to commercial use located in an area where there is recent residential development). The “substantial evidence” would indicate the existing use will not impede further residential development or that the existing use will be discontinued during the planning period. In this type of situation, use of the same findings for each of the multiple sites would be appropriate.

DRAFTating the uses o ating th
RHNA for lower incom RHNA fo
factors usedto make tha
cital section of the resolution. cital section of the
e.g., expiring leases, dilapidated expiring leases, dilapida sites identified in the site inventory to sites identified in the site inventor to be discontinued to be d during the planning lanning FT ediment to additiona
e housing element.
he findings and include a description of th gs and include on.
e includes facts, reasonable assumptions e includes facts, reasonable ass on supported by facts. supported by fac An example of sub ample o e with a grocery store grocery store and with a building with a building the store has entered into a lease to rel has entered into a lease to rel ase expiring.
bstantial evidence that an existing use w bstantial evidence that an exi ing period include ing period includ , but are not limited to e not :
ease for the existing use expires early wit ease for the existing use expires early e building is buildin dilapidated, idated, and the structure and the structur permit has been issued for the existing us t has been issued for the existing us There is a development agreement tha
period, perio
- The entity operating the existing u The entity operating t enough within the planning per ough within the plann
planning period. ng perio
- The property owner provi erty owner provi
residences during the p s duri
If multiple sites make es m
the sites, the sam
shopping mall w
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bstanti
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Site Inventory Guidebook Page 28 May 2020
However, the same finding for multiple sites in a specific area may not be appropriate if their characteristics widely vary. For example, nonvacant sites with differing existing uses and lacking in common ownership, whether contiguous or located in the same general area, may not rely on a generalized analysis. While the sites may be located in an area with common economic issues, individual owners may not wish to sell their property or redevelop their site with residential uses. In addition, each site’s existing use, e.g., grocery store, retail shop, parking lot, and offices, may have lease agreements of different lengths of time or the owner may not wish to relocate or redevelop the site with a more intensive residential use. In this type of situation, use of the same findings for the multiple sites would not be appropriate.

Step 4: *NEW* Program and policy requiring replacement of existing affordable units Government Code Section 65583.2(g)(3)
The housing element must include a program in the housing element and policy independent of the housing element requiring the replacement of units affordable to the same or lower income level as a condition of any development on a nonvacant site consistent with those requirements set forth in Density Bonus Law (Government Code section 65915(c)(3).) Replacement requirements shall be required for sites identified in the inventory that currently have residential uses, or within the past five years have had residential uses that have been vacated or demolished, and:
x Were subject to a recorded covenant, ordinance, or law that restricts rents to levels affordable to persons and families of low or very low-income, or x Subject to any other form of rent or price control through a public entity’s valid exercise of its police power, or
x Occupied by low or very low-income households
For the purpose of this program “previous five years” is based on the date the application for development was submitted.

Please note, until 2025, pursuant to Government Code section 66300(d) (Chapter 654, Statutes of 2019 (SB 330)), an affected city or county shall not approve a housing development project that will require the demolition of residential dwelling units regardless of whether the parcel was listed in the inventory unless a) the project will create at least as many residential dwelling units as will be demolished, and b) certain affordability criteria are met. A listing of affected cities and counties can be found at https://www.hcd.ca.gov/community-development/accountability-enforcement/statutorydeterminations.shtml.

DRAFTsite’s e site’s
e lease e lease
to relocate or o relo
type of situation, use type of s
ate. FT
nt of existing affordabl
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very households
f this program “previous five years” is bas f this program “previous five y nt was submitted.
te, until 2025 unti , pursuant to rsuant to Government C of 2019 (SB 330)), an affected city or co DRproject that will require the demo hether the parcel was
many residential dwelling u
met. A listing of affected cities
https://www.hcd.ca.gov/community https://www.hcd.ca.gov/commun determinations.shtml.

Site Inventory Guidebook Page 29 May 2020

SAMPLE PROGRAM
Program X: Replacement Unit Program
XXXX will adopt a policy and will require replacement housing units subject to the requirements of Government Code section 65915, subdivision (c)(3) on sites identified in the site inventory when any new development (residential, mixed-use or nonresidential) occurs on a site that is identified in the inventory meeting the following conditions:
x currently has residential uses or within the past five years has had residential uses that have been vacated or demolished, and
x was subject to a recorded covenant, ordinance, or law that restricts rents to levels affordable to persons and families of low or very low-income, or x subject to any other form of rent or price control through a public entity’s valid exercise of its police power, or
x occupied by low or very low-income households
Funding: General Funds
Responsible Parties: Planning and Community Development Department Objectives: In order to mitigate the loss of affordable housing units, require new housing developments to replace all affordable housing units lost due to new development.

Timeframes: The replacement requirement will be implemented immediately and applied as applications on identified sites are received and processed, and local policy shall be adopted by <DATE>. End of Sample Program
NEXT STEP:
x Move to Part E: Determination of Adequate Sites
s ide
onreside onresid
conditions: conditio
had residential uses that had residenT
at restricts rents to levels at restricts rents to leve come, or come
ough a public entity’s valid exercise ough a public entity’s valid exercis ds
munity Development Department opment De
oss of affordable housing units, require ne oss of affordable housing uni able housing units lost due to new develo ble housing units lost due to new requirement will be implemented immed ement will be implemented immed es are received and processed, and loca eived and processed, and loca d of Sample Program RA
art E: Determination of Adequate Sites art E: Determination of Adequate S Site Inventory Guidebook Page 30 May 2020
PART E: DETERMINATION OF ADEQUATE SITES
The last step in this process is a determination of whether the housing element demonstrates sufficient land suitable and available for residential development to meet the locality’s housing need for each designated income level or if further program actions are required to accommodate a shortfall.

Step 1: Consider any alternative means of meeting the RHNA Government Code section 65583.1
The housing element may satisfy its RHNA requirement though a variety of methods other than identifying sites. The following is a description of those alternative methods. x Units permitted, built, entitled or pending: (See Part A, Step 1) x Potential for accessory dwelling units (ADU) or junior accessory dwelling units (JADU):

The jurisdiction can count the potential for the development of ADUs within the planning period. The analysis is based on the following factors:
- the number of ADUs or JADUs developed in the prior planning period - community need and demand for these types of housing units - the resources and/or incentives available that will encourage the development of ADUs
- the availability of ADUs and JADUs for occupancy, rather than used as offices or guest houses
- the unit must meet the Census definition of a housing unit, which can be found on the U.S. Census Bureau website, and be reported to the Department of Finance as part of the annual City and County Housing Unit Change Survey - the anticipated affordability of these units. The purpose of this analysis is to determine the appropriate RHNA income category to be accommodated through ADU and JADU development.

Affordability can be determined in a number of ways. As an example, a community could survey existing ADUs and JADUs for their current market rents and consider other factors such as square footage, number of bedrooms, amenities, age of the structure and general location, including proximity to public transportation. Another method could examine current market rents for reasonably comparable rental properties to determine an average price per square foot in the community. This price can be applied to anticipated sizes of these units to estimate the anticipated affordability of ADUs and JADUs. Available regional studies and methodology on ADU affordability can also be a resource to determine the likely affordability mix for ADUs and JADUs.
- other relevant factors as determined by HCD.

In addition, the housing element must describe and analyze any currently adopted ordinance and other factors that could affect ADU and JADU development within the planning period. At a minimum, the housing element should analyze whether the ordinance conforms with state ADU and JADU requirements and any additional development standards (i.e., setbacks, maximum unit sizes, lot coverage, etc.) adopted by the local government, zones allowing ADUs, fees and exactions, and any other potential constraints impacting the development of ADUs and JADUs.

DRAFTa variety of methods other a variety of met
lternative methods. ernative methods.

A, Step 1) A, Step
nior accessory dwelling units (JADU):
development of develop ADUs within the planning
ng factors: g facto
eloped in the prior planning period the prior plann
these types of housing units f housing
s available that will encourage the develo s available that will encoura nd JADUs for occupancy for occup , rather than use her than he Census definition of a housing unit, wh
Bureau website, and be reported to the D e, and be reported to the D ual City and County Housing Unit Change
ed affordability of these units. The purpos ed affordability of these units. e the appropriate RHNA income category e the appropriate RHNA income nd JADU development. nd JADU developme
fordability can be determined in a numbe rdability can be determined in a numbe could survey existing ADUs and JADUs survey existing ADUs and JADUs other factors such as square footage, tors such as square footage, structure and general location, inclu structure and gene method could examine method could examin current m
properties to determine an ave perties to determine
price can be applied to antic an be applied to an
affordability of ADUs and ity of ADUs and
ADU affordability dabili can
ADUs and JADUs.
- other relevant f other relevant
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ng
Site Inventory Guidebook Page 31 May 2020
Impact of New Accessory Dwelling Unit Laws
Since 2017, the Legislature has passed a series of new laws that significantly increase the potential for development of new ADUs and JADUs by removing development barriers, allowing ADUs through ministerial permits, and requiring jurisdictions to include programs in their housing element that incentivize their development. As a result, using trend analysis when estimating the potential for development may not accurately reflect the increased potential for these units. To account for this increased potential, HCD recommends the following options when performing this analysis:
x Use the trends in ADU construction since January 2018 to estimate new production.

This is a conservative option to only account for the effect of the new laws without local promotional efforts or incentives (safe harbor option). x Where no other data is available, assume an average increase of five times the previous planning period construction trends prior to 2018. This option is a conservative estimate based upon statewide data on ADU development since the implementation of the new laws (safe harbor option).
x Use trends from regional production of ADUs.
x Include programs that aggressively promote and incentivize ADU and JADU construction.
x Other analysis (reviewed on a case-by-case basis).

Potential affordability of these units must still be calculated per the analysis outlined on the previous page. In addition to the above options, the element should also include a monitoring program that a) tracks ADU and JADU creation and affordability levels, and b) commits to a review at the planning cycle mid-point to evaluate if production estimates are being achieved. Depending on the finding of that review, amendments to the housing element may be necessary, including rezoning pursuant to Government Code 65583.2 (h)and (i). End ADU explanation
x Alternative Adequate sites: Under limited circumstances, a local government may credit up to 25 percent of their adequate sites requirement per income category through existing units that will be:
- substantially rehabilitated
- in a multifamily rental or ownership housing complex of three or more units that are converted from non affordable to affordable rental
- preserved at levels affordable to low- or very low-income households, where the local government has provided those units with committed assistance For more information on this option, please refer to HCD’s Building Blocks Webpage x Manufactured housing, manufactured housing park hook-ups, floating homes/live aboard berths: In certain circumstances a jurisdiction can utilize the potential for new manufactured housing either in a manufactured housing park or on large properties in rural areas, or new floating home/liveaboard berths with sewer and water hook ups. In cases of a manufactured home park or in floating home/liveaboard berth marinas, the jurisdiction may count new spaces with infrastructure hook-ups intended for permanent residential occupancy and reported to the Department of Finance. Potential for manufactured homes in rural areas should be analyzed using the same factors as those DRAFTde
ng tren ng tre
t the increas t the in
recommends the recomm
estimate new production. estimate new produT
ct of the new laws without local ct of the new laws withou age increase of five times the
or to 2018. This option is a conservative
development since the implementation o
ADUs.
promote and incentivize ADU and JADU centivize
case-by-case basis). case
e units must still be calculated per the an must still be calculated per the an to the above options, the element should e options, the element shou a) tracks ADU and JADU creation and a and JADU creation and a at the planning cycle mid-point to evaluat poin
epending on the finding of that review, am epending on the finding of tha e necessary, including rezoning pursuant e necessary, including rezoning p d ADUexplanationRA Dve Adequate sites: Under limited circ DRrcent of their adequate sites re existing units that will b
- substantially rehabilitat
multifamily rental or o
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at le Dnme
For more Fo informatio ormat
Manufactured
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Site Inventory Guidebook Page 32 May 2020
for potential ADUs, including establishing the market rate affordability of the units and crediting them to the appropriate RHNA category. In addition, the analysis should indicate if appropriate water and sewer infrastructure is available to support the development.
x Former military housing: Sites that contain permanent housing units located on a military base undergoing closure or conversion as a result of action pursuant to the Defense Authorization Amendments and Base Closure and Realignment Act (Public Law 100-526), the Defense Base Closure and Realignment Act of 1990 (Public Law 101-510), or any subsequent act requiring the closure or conversion of a military base may be identified as an adequate site if the housing element demonstrates that the housing units will be available for occupancy by households within the planning period of the housing element. No sites containing housing units scheduled or planned for demolition or conversion to nonresidential uses shall qualify as an adequate site. x In consultation with HCD, other alternatives may be considered, such as motel conversions, adaptive reuse of existing buildings, or legalization of units not previously reported to the Department of Finance.

Step 2: Determine whether there is sufficient capacity to accommodate the RHNA for the jurisdiction by income.

Government Code Section 65583(a)(3)
The following table is an example of that calculation:

Adjustment Factor Very Low Low Moderate Above
Moderate
RHNA 300 200 165 465
Entitled, Permitted, or Constructed
Project Projects
50 50 0 200
Accessory Dwelling Unit Potential 10 15 15 10
Adequate Sites Alternative
Preservation
20 16
Multifamily Residential
R-3 (Vacant)
75 50
Mixed Use MU (Nonvacant) 75 50 50
Multifamily Residential (Vacant) R-2 75
Single-Family (Vacant) R-1 200
Spring Valley Specific Plan 150 250
Total 230 181 290 660
Shortfall/Surplus -70 -19 +125 +195
While the jurisdiction has sufficient sites to accommodate its RHNA for moderate- and above moderate-income units, it has a shortfall of 89 units to accommodate its lower income need. The jurisdiction would be required to include a program in the housing element to accommodate that shortfall. DRAFTted o
ursuant
nment A
of 1990
ersion of a m
nt demonstrates th FT
lds within the planning
nits scheduled or planned for
ll qualify as an adequate site.
ay be co , s
ings, or legalization of AFT
ufficient capacity to accommodate the city to ac
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ervation
te Sites Alternative Sites Alternative
Dwelling Unit Potentia
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R-3 (Vacant RD
Mixed Use MU (Nonvacant) vacant) DR
Multifamily Residential (Vacan
Single-Family (Vacant) R y (Vaca -1
DRpecifi
Total
Shortfall/Surplus
While the While th jurisdiction sdiction
ve moderate-i
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to a
Site Inventory Guidebook Page 33 May 2020
If Yes: Congratulations, the site inventory analysis is complete If No: Move to Step 3
Step 3: Adequate Sites Program
Government Code section 65583(f) and Government Code section 65583.2(h) Where the inventory of sites does not identify adequate sites to accommodate the RHNA for lower income households, a program must be included to identify sites that can be developed for housing within the planning period. The housing element should include an inventory of potential sites for rezoning. Those sites must meet the adequate sites requirements in terms of the suitability and availability outlined above.

General Program Requirements
A jurisdiction’s adequate sites program must accommodate 100 percent of the shortfall of sites necessary to accommodate the remaining housing need for housing for very low- and low-income households during the planning period and include the following components:
x Permit owner-occupied and rental multifamily uses by right for developments in which 20 percent or more of the units are affordable to lower income households. By right means local government review must not require a conditional use permit, planned unit development permit, or other discretionary review or approval. x Permit the development of at least 16 units per site. x Ensure sites within suburban and metropolitan jurisdictions — as defined by Government Code Section 65583.2(c)(3)(B)(iii) and (iv) — permit a minimum of 16 dwelling units per acre for incorporated cities within nonmetropolitan/rural counties and nonmetropolitan counties with micropolitan areas or 20 dwelling units per acre for suburban and metropolitan jurisdictions.
x Ensure a) at least 50 percent of the shortfall of low- and very low-income regional housing need can be accommodated on sites designated for exclusively residential uses, or b) if accommodating more than 50 percent of the low- and very low-income regional housing need on sites designated for mixed-uses, all sites designated for mixed-uses must allow 100 percent residential use and require residential use to occupy at least 50 percent of the floor area in a mixed-use project.

Timing
Rezones due to a shortfall from the current planning period:

A locality’s ability to accommodate needed housing during the planning period requires designating appropriate zoning as early as possible. Generally, however, a rezoning should occur no later than three years and 120 days from the beginning of the planning period. A one-year extension to the deadline to complete required rezoning may be allowed if a local government has completed rezoning at sufficient densities to accommodate at least 75 percent of the units for very-low and low-income households. Also, the jurisdiction must determine after a public meeting that substantial evidence supports findings and adoption of a resolution that the rezone deadline was not met due to one of the following reasons:
x Action or inaction beyond the control of the local government of any other state, federal, or local agency.
x Infrastructure deficiencies due to
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Site Inventory Guidebook Page 34 May 2020
x The local government must undertake a major revision to its general plan in order to accommodate the housing-related policies of a sustainable communities strategy or an alternative planning strategy adopted pursuant to Section 65080.

The jurisdiction must provide HCD a copy of the resolution and findings along with: - a detailed budget and schedule for preparation and adoption of required rezoning within one year of the adoption of the resolution, - plans for citizen participation, and - expected interim actions to complete the rezoning, and any revisions to the general plan (Government Code section 65583(f).

Consequences for Failing to Complete Rezoning Deadline:

If a local government fails to complete all rezoning’s by the prescribed deadline, a local government may not disapprove a housing development project7, nor require a conditional use permit, planned unit development permit, or other locally imposed discretionary permit, or impose a condition that would render the project infeasible, if the housing development project:
• Is proposed to be located on a site included in a housing element program to be rezoned.
• Complies with applicable objective general plan and zoning standards and criteria, including design review standards, described in the rezone program action.

However, any subdivision of the site is subject to the Subdivision Map Act.

A jurisdiction may disapprove a housing development or approve it upon the condition that the project be developed at a lower density only if it makes written findings supported by substantial evidence on the record that both of the following conditions exist:
• The housing development project would have a specific, adverse impact upon the public health or safety8.
• There is no feasible method to satisfactorily mitigate or avoid the adverse impact.

The local government may also be subject to enforcement actions by HCD, including a determination that the housing element no longer complies with the requirements of state law and referral to the Attorney General pursuant to Government Code section 65585(i) and (j).
7 “Housing development project” is defined a project to construct residential units for which the project developer provides sufficient legal commitments to the appropriate legal agency to ensure the continued availability and use of at least 49 percent of the housing units for very-low, low-, and moderate-income households with an affordable housing cost or affordable rent. 8 “Specific, adverse impact” means a significant, quantifiable, direct, and unavoidable impact, based on objective, identified written public health or safety standards, policies, or conditions as they existed on the date the application was deemed complete.

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Site Inventory Guidebook Page 35 May 2020
Housing Accountability Act and the Housing Element
The Housing Accountability Act (Government Code section 65589.5) establishes state overarching policy that a local government not deny, reduce the density of, or make infeasible housing development projects, emergency shelters, or farmworker housing that are consistent with objective local development standards and contribute to meeting housing need. Jurisdictions without a housing element in compliance with State Housing Element Law or without a complete site inventory are further limited in the ability to deny a housing development application.

Among other requirements (including those related to housing development regardless of affordability levels), the Housing Accountability Act states that a local agency shall not disapprove or condition approval in a manner that renders the housing development project infeasible, including through the use of design review standards, for development of an emergency shelter or a housing development project for very low, low-, or moderateincome households unless it makes written findings, based upon a preponderance of the evidence in the record, as to one of the following:
x The jurisdiction has adopted a housing element in substantial compliance with Housing Element Law and the jurisdiction has met or exceeded its share of the RHNA for the planning period for the income category proposed for the housing development project. x The project would have a specific, adverse impact upon the public health or safety, and there is no feasible method to satisfactorily mitigate or avoid the specific adverse impact without rendering the development unaffordable to low- and moderate-income households or rendering the development of the emergency shelter financially infeasible.
x The denial of the project or imposition of conditions is required in order to comply with specific state or federal law, and there is no feasible method to comply without rendering the development unaffordable or rendering the development of the emergency shelter financially infeasible.
x The project is proposed on land zoned for agriculture or resource preservation, or which does not have adequate water or wastewater facilities to serve the project. x The project is inconsistent with both the jurisdiction’s zoning ordinance and general plan land use designation, unless the housing development project is proposed on a site that is identified as suitable or available for very low, low-, or moderate-income households in the jurisdiction’s housing element, or if the local agency has failed to identify in the inventory of land in its housing element sites that can be developed for housing within the planning period and are sufficient to provide for the jurisdiction’s share of the regional housing need for all income levels pursuant to Section 65584. “Housing for very low, low-, or moderate-income households” means where at least 20 percent of the total units are or will be sold or rented to lower income households or 100 percent of the units will be sold or rented to persons and families of moderate income, or persons and families of middle income. DRAFT End Housing Accountability Act explanation. ho
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Site Inventory Guidebook Page 36 May 2020
Rezoned due to an unaccommodated need from previous planning period9:

Pursuant to Government Code section 65584.09, if the jurisdiction failed to make adequate sites available to accommodate the regional housing need in the prior planning period, the jurisdiction must zone or rezone sites to accommodate any unaccommodated need within the first year of the planning period. If more than one year has lapsed since the beginning of the planning period, the housing element cannot be found in compliance with Housing Element Law until the required zoning or rezoning is complete and the housing element is amended to reflect the necessary rezoning.

Annexation
If the jurisdiction must rely on annexation to accommodate its RHNA, the housing element must include a program committing to completing the annexation within three years of the planning period. In addition, the housing element must also include an evaluation of the suitability of the annexed sites, including the following information:
x Consistency with Local Agency Formation Commission (LAFCO) policies x Actions to pre-zone prior to annexation
x Descriptions of the zone, density, development standards and design requirements x The anticipated housing capacity allowed by each site x Timeline to complete annexation which is early enough in the planning period to facilitate development of annexed sites (e.g., within the first three years of the planning period)
x Analysis of the suitability and availability of sites, including identification of any sites currently under Williamson Act contracts
x Demonstrated compliance with the requirements of the adequate sites program requirements of Government Code section 65583.2, subdivisions (h) and (i) Please note, if the potential for annexation was not included in the RHNA allocation methodology, a portion of the county’s allocation may be transferred to the city pursuant to Government Code section 65584.07(d). This transfer of RHNA would require an amendment to the housing element to ensure that any additional RHNA can be accommodated on sites within the inventory. End annexation explanation. 9 Sometimes called the AB 1233 consequence.

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Site Inventory Guidebook Page 37 May 2020
Sample Rezone Program:

To accommodate the remaining lower-income RHNA of 89 units, the City of X will identify and rezone a minimum of 4.5 acres of vacant land to the R3 zoning district, allowing exclusively residential uses and a minimum of 20 units per acre to a maximum of 30 units per acre by June 30, 2024. Rezoned sites will permit owner-occupied and rental multifamily uses by right pursuant to Government Code section 65583.2(i) for developments in which 20 percent or more of the units are affordable to lower income households and will be selected from sites 20 through 30 in the parcel listing (Appendix A). As reflected in Appendix A, each site has the capacity to accommodate at least 16 units and will be available for development in the planning period where water, sewer, and dry utilities can be provided.

Objective: Create opportunity for at least 89 units of multifamily housing for lower income households
Responsible Agency: Community Development Department
Timeline: Sites rezoned by June 30, 2024
Funding Source(s): General fund
Other program ideas for increasing capacity or facilitating development on identified sites:
x Up-zone existing neighborhoods in areas of opportunity or in high quality neighborhood transit areas at appropriate densities to facilitate development of housing. x Increase maximum allowable residential densities in existing residential, commercial, and mixed-use zones and modify development standards, such as height limitations to ensure maximum density can be achieved.
x Establish minimum densities — Designate minimum densities of development to ensure that existing available land is not underutilized.
x Allow and encourage mixed-use zoning — Permit housing in certain nonresidential zones either as part of a mixed-use project or as a standalone residential use. x Rezone underutilized land from nonresidential to residential to expand the supply of available residential land.
x Institute flexible zoning — Allow various residential uses within existing nonresidential zones without requiring rezoning or conditional approvals. x Redevelop and/or recycle underutilized existing land to more intensive uses. x Convert obsolete, older public/institutional/commercial/industrial buildings to residential use through adaptive reuse and/or historic preservation. x Over-zone — Create a surplus of land for residential development during the current planning period of at least 20 percent more than the locality’s share of the regional housing need. Over-zoning compensates for urban land left vacant due to ownership and development constraints and creates a real surplus. A sufficient supply of land beyond the time frame of the housing element helps prevent land shortages from bidding up land costs.
x Allow and promote small and irregular-size lot development.

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Site Inventory Guidebook Page 38 May 2020
x Consolidate lots — Facilitate combining small residential lots into larger lots to accommodate higher-density development.
x Increase height limitations — At a minimum, allow three stories in multifamily zones. x Increase Floor Area Ratios — Allow for larger buildings on smaller lots and/or more units per lot by reducing the floor area ratio (total lot area divided by the total building area).
x Identify publicly owned land suitable for affordable housing development and sell parcels for $1 (with consideration of the Surplus Land Act as amended by AB 1486, Statutes of 2019).
x Facilitate development by encouraging staff outreach to owners of potential sites and affordable housing developers to discuss needs and constraints in the jurisdiction. x Adopt incentives such as a super density bonus or by right approval for housing that meets community objectives, such as housing near transit, affordability, housing that meets the needs of special populations, etc.
x Adopt a specific plan that streamlines CEQA compliance.

Common Program Questions and Answers for Shortfall Zoning:

Q: How do I establish the density range for a rezone site? A: The density range is set at the minimum density (either 16 or 20 dwelling units per acre, depending on the jurisdiction). While there is no specific maximum density requirement, the range must include the density that was identified as appropriate to accommodate housing affordable to lower-income households (Part B, Step 2).

However, jurisdictions should not set the minimum and maximum density range at the same density (e.g., 20 units per acre minimum as both a minimum and maximum density).

If identifying a narrow density range, the housing element must analyze the range as a potential governmental constraint on housing development, including potential impacts resulting from site constraints, financial considerations, and other development factors.

Q: If a development is proposed with less than 20 percent affordability to lower income, can the jurisdiction approve it?
A: Yes, however, the project would not qualify for the by right provisions of this law unless the underlining zone already permitted housing by right. This, and all housing development projects, is subject to the Housing Accountability Act. In addition, the jurisdiction may be subject to No Net Loss Law provisions.

Q: How is the 20 percent calculated when State Density Bonus Law is added? A: This 20 percent calculation is based upon the total number of units in the development including additional units provided by a density bonus. This calculation methodology is consistent with several other pieces of housing laws, including the Streamlined Ministerial Approval Process (Government Code section 65913.4) and the Housing Accountability Act.

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Site Inventory Guidebook Page 39 May 2020
ATTACHMENT 1: SUMMARY OF NEW LAWS REFERENCED IN THE

GUIDEBOOK
AB 1397, Low (Chapter 375, Statutes of 2017): The law made a number of revisions to the site inventory analysis requirements of Housing Element Law. In particular, it requires stronger justification when nonvacant sites are used to meet housing needs, particularly for lower income housing, requires by right housing when sites are included in more than one housing element, and adds conditions around size of sites, among others.

AB 686, Santiago (Chapter 958, Statutes of 2018): The law ensures that public entities, including local governments, administer their programs relating to housing and urban development in a manner affirmatively to further the purposes of the federal Fair Housing Act and do not take any action that is materially inconsistent with its obligation to affirmatively further fair housing. It also requires that housing elements of each city and county promote and affirmatively further fair housing opportunities throughout the community for all persons regardless of race, religion, sex, marital status, ancestry, national origin, color, familial status, or disability, and other characteristics protected by the California Fair Employment and Housing Act, Government Code Section 65008, and any other state and federal fair housing and planning law. AB 686 requires jurisdictions to conduct an assessment of fair housing in the housing element, prepare the housing element site inventory through the lens of affirmatively furthering fair housing, and include program(s) to affirmatively further fair housing.

SB 6, Beall (Chapter 667, Statutes of 2019): Jurisdictions are required to prepare the site inventory on forms developed by HCD and send an electronic version with their adopted housing element to HCD. HCD will then send those inventories to the Department of General Services by December 31 each year. The law (?) authorizes HCD to review, adopt, amend, and repeal the standards, forms, or definitions to implement this subdivision and subdivision (a) of Section 65583.

AB 1486, Ting (Chapter 644, Statutes of 2019): The law expanded the definition of surplus land and added additional requirements on the disposal of surplus land. In addition, local agencies must send notices of availability to interested entities on a list maintained by HCD. This list and notices of availability are maintained on HCD's website. Local agencies must also send a description of the notice and subsequent negotiations for the sale of the land, which HCD must review, and within 30 days submit written finding of violations of law.

Violations of the Surplus Land Act can be referred to the Attorney General. Finally, it adds a requirement in Housing Element Law for the jurisdiction to identify which of the sites included in the inventory are surplus property.
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Site Inventory Guidebook Page 40 May 2020
ATTACHMENT 2: GOVERNMENT CODE SECTION 65583.2
As of January 1, 2020
(a) A city’s or county’s inventory of land suitable for residential development pursuant to paragraph (3) of subdivision (a) of Section 65583 shall be used to identify sites throughout the community, consistent with paragraph (9) of subdivision (c) of Section 65583, that can be developed for housing within the planning period and that are sufficient to provide for the jurisdiction’s share of the regional housing need for all income levels pursuant to Section 65584. As used in this section, “land suitable for residential development” includes all of the sites that meet the following standards set forth in subdivisions (c) and (g):
(1) Vacant sites zoned for residential use.
(2) Vacant sites zoned for nonresidential use that allows residential development. (3) Residentially zoned sites that are capable of being developed at a higher density, including sites owned or leased by a city, county, or city and county. (4) Sites zoned for nonresidential use that can be redeveloped for residential use, and for which the housing element includes a program to rezone the site, as necessary, rezoned for, to permit residential use, including sites owned or leased by a city, county, or city and county.
(b) The inventory of land shall include all of the following:
(1) A listing of properties by assessor parcel number.
(2) The size of each property listed pursuant to paragraph (1), and the general plan designation and zoning of each property.
(3) For nonvacant sites, a description of the existing use of each property. If a site subject to this paragraph is owned by the city or county, the description shall also include whether there are any plans to dispose of the property during the planning period and how the city or county will comply with Article 8 (commencing with Section 54220) of Chapter 5 of Part 1 of Division 2 of Title 5.
(4) A general description of any environmental constraints to the development of housing within the jurisdiction, the documentation for which has been made available to the jurisdiction. This information need not be identified on a site-specific basis. (5) (A) A description of existing or planned water, sewer, and other dry utilities supply, including the availability and access to distribution facilities. (B) Parcels included in the inventory must have sufficient water, sewer, and dry utilities supply available and accessible to support housing development or be included in an existing general plan program or other mandatory program or plan, including a program or plan of a public or private entity providing water or sewer service, to secure sufficient water, sewer, and dry utilities supply to support housing development. This paragraph does not impose any additional duty on the city or county to construct, finance, or otherwise provide water, sewer, or dry utilities to parcels included in the inventory. (6) Sites identified as available for housing for above moderate-income households in areas not served by public sewer systems. This information need not be identified on a sitespecific basis. (7) A map that shows the location of the sites included in the inventory, such as the land use map from the jurisdiction’s general plan, for reference purposes only.

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general description of any environmental description of any environmental hin the jurisdiction, the documentation for ction, the documentation for urisdiction. This information need not be urisdiction. This informatio (5) (A) A description of existing or plan (5) (A) A description of existing including the availability and access including the availability and acce (B) Parcels included in the inve ded in the inve
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Site Inventory Guidebook Page 41 May 2020
(c) Based on the information provided in subdivision (b), a city or county shall determine whether each site in the inventory can accommodate the development of some portion of its share of the regional housing need by income level during the planning period, as determined pursuant to Section 65584. The inventory shall specify for each site the number of units that can realistically be accommodated on that site and whether the site is adequate to accommodate lower income housing, moderate-income housing, or above moderate-income housing. A nonvacant site identified pursuant to paragraph (3) or (4) of subdivision (a) in a prior housing element and a vacant site that has been included in two or more consecutive planning periods that was not approved to develop a portion of the locality’s housing need shall not be deemed adequate to accommodate a portion of the housing need for lower income households that must be accommodated in the current housing element planning period unless the site is zoned at residential densities consistent with paragraph (3) of this subdivision and the site is subject to a program in the housing element requiring rezoning within three years of the beginning of the planning period to allow residential use by right for housing developments in which at least 20 percent of the units are affordable to lower income households. An unincorporated area in a nonmetropolitan county pursuant to clause (ii) of subparagraph (B) of paragraph (3) shall not be subject to the requirements of this subdivision to allow residential use by right. The analysis shall determine whether the inventory can provide for a variety of types of housing, including multifamily rental housing, factory-built housing, mobilehomes, housing for agricultural employees, supportive housing, single-room occupancy units, emergency shelters, and transitional housing. The city or county shall determine the number of housing units that can be accommodated on each site as follows:
(1) If local law or regulations require the development of a site at a minimum density, the department shall accept the planning agency’s calculation of the total housing unit capacity on that site based on the established minimum density. If the city or county does not adopt a law or regulation requiring the development of a site at a minimum density, then it shall demonstrate how the number of units determined for that site pursuant to this subdivision will be accommodated.
(2) The number of units calculated pursuant to paragraph (1) shall be adjusted as necessary, based on the land use controls and site improvements requirement identified in paragraph (5) of subdivision (a) of Section 65583, the realistic development capacity for the site, typical densities of existing or approved residential developments at a similar affordability level in that jurisdiction, and on the current or planned availability and accessibility of sufficient water, sewer, and dry utilities. (A) A site smaller than half an acre shall not be deemed adequate to accommodate lower income housing need unless the locality can demonstrate that sites of equivalent size were successfully developed during the prior planning period for an equivalent number of lower income housing units as projected for the site or unless the locality provides other evidence to the department that the site is adequate to accommodate lower income housing. (B) A site larger than 10 acres shall not be deemed adequate to accommodate lower income housing need unless the locality can demonstrate that sites of equivalent size were successfully developed during the prior planning period for an equivalent number of lower income housing units as projected for the site or unless the locality provides other evidence to the department that the site can be developed as lower income housing. For purposes of this subparagraph, “site” means that portion of a parcel or parcels designated to accommodate lower income housing needs pursuant to this subdivision.

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Site Inventory Guidebook Page 42 May 2020
(C) A site may be presumed to be realistic for development to accommodate lower income housing need if, at the time of the adoption of the housing element, a development affordable to lower income households has been proposed and approved for development on the site.
(3) For the number of units calculated to accommodate its share of the regional housing need for lower income households pursuant to paragraph (2), a city or county shall do either of the following:
(A) Provide an analysis demonstrating how the adopted densities accommodate this need.

The analysis shall include, but is not limited to, factors such as market demand, financial feasibility, or information based on development project experience within a zone or zones that provide housing for lower income households.
(B) The following densities shall be deemed appropriate to accommodate housing for lower income households:
(i) For an incorporated city within a nonmetropolitan county and for a nonmetropolitan county that has a micropolitan area: sites allowing at least 15 units per acre. (ii) For an unincorporated area in a nonmetropolitan county not included in clause (i): sites allowing at least 10 units per acre.
(iii) For a suburban jurisdiction: sites allowing at least 20 units per acre. (iv) For a jurisdiction in a metropolitan county: sites allowing at least 30 units per acre. (d) For purposes of this section, a metropolitan county, nonmetropolitan county, and nonmetropolitan county with a micropolitan area shall be as determined by the United States Census Bureau. A nonmetropolitan county with a micropolitan area includes the following counties: Del Norte, Humboldt, Lake, Mendocino, Nevada, Tehama, and Tuolumne and other counties as may be determined by the United States Census Bureau to be nonmetropolitan counties with micropolitan areas in the future. (e) (1) Except as provided in paragraph (2), a jurisdiction shall be considered suburban if the jurisdiction does not meet the requirements of clauses (i) and (ii) of subparagraph (B) of paragraph (3) of subdivision (c) and is located in a Metropolitan Statistical Area (MSA) of less than 2,000,000 in population, unless that jurisdiction’s population is greater than 100,000, in which case it shall be considered metropolitan. A county, not including the City and County of San Francisco, shall be considered suburban unless the county is in an MSA of 2,000,000 or greater in population in which case the county shall be considered metropolitan.
(2) (A) (i) Notwithstanding paragraph (1), if a county that is in the San Francisco-OaklandFremont California MSA has a population of less than 400,000, that county shall be considered suburban. If this county includes an incorporated city that has a population of less than 100,000, this city shall also be considered suburban. This paragraph shall apply to a housing element revision cycle, as described in subparagraph (A) of paragraph (3) of subdivision (e) of Section 65588, that is in effect from July 1, 2014, to December 31, 2028, inclusive.
(ii) A county subject to this subparagraph shall utilize the sum existing in the county’s housing trust fund as of June 30, 2013, for the development and preservation of housing affordable to low- and very low-income households.
(B) A jurisdiction that is classified as suburban pursuant to this paragraph shall report to the Assembly Committee on Housing and Community Development, the Senate Committee on DRAFTnal
nty sha nty sh
ccommodate this nee ccommo
arket demand, financial arket demand
ence within a zone or zones ence within a zone
to accommodate housing for lower to accommodate housing for lo an county and for a nonmetropolitan an county and for a ng at least 15 units per acre. ng at least 15 units per ropolitan county not included in clause (i) an county not incl allowing at least 20 units per acre. allowing at least 20 units pe litan county: sites allowing at least 30 un an county: sites allowing at least n, a metropolitan county, nonmetropolita etropolitan county, nonmetropolita h a micropolitan area shall be as determi olitan area shall be as determi A nonmetropolitan county with a micropol tan county with a micropol l Norte, Humboldt, Lake, Mendocino, Nev Norte, Humboldt, Lake, Mendocino, Nev r counties as may be determined by the r counties as may be determi olitan counties with micropolitan areas in olitan counties with micropolitan t as provided in paragraph (2), a jurisdict t as provided in paragraph (2), a juris ction does not meet the requirements of c tion does not meet the requirements of ph (3) of subdivision (c) and is located in 3) of subdivision (c) and is located in han 2,000,000 in population, unless that 0,000 in population, unless that 0,000, in which case it shall be considere 00, in which case it s and County of San Francisco, shall be co and County of San Francis of 2,000,000 or greater in population of 2,000,000 or greater in pop in metropolitan.
(2) (A) (i) Notwithstanding parag hstanding parag
Fremont California MSA has a MS
considered suburban. If thi considered suburban.
less than 100,000, this c less than 100,000, this
to a housing element to a housing element
bdivision (e) of S
sive.
nty
Site Inventory Guidebook Page 43 May 2020
Housing, and the Department of Housing and Community Development regarding its progress in developing low- and very low income housing consistent with the requirements of Section 65400. The report shall be provided three times: once, on or before December 31, 2019, which report shall address the initial four years of the housing element cycle, a second time, on or before December 31, 2023, which report shall address the subsequent four years of the housing element cycle, and a third time, on or before December 31, 2027, which report shall address the subsequent four years of the housing element cycle and the cycle as a whole. The reports shall be provided consistent with the requirements of Section 9795.
(f) A jurisdiction shall be considered metropolitan if the jurisdiction does not meet the requirements for “suburban area” above and is located in an MSA of 2,000,000 or greater in population, unless that jurisdiction’s population is less than 25,000 in which case it shall be considered suburban.
(g) (1) For sites described in paragraph (3) of subdivision (b), the city or county shall specify the additional development potential for each site within the planning period and shall provide an explanation of the methodology used to determine the development potential. The methodology shall consider factors including the extent to which existing uses may constitute an impediment to additional residential development, the city’s or county’s past experience with converting existing uses to higher density residential development, the current market demand for the existing use, an analysis of any existing leases or other contracts that would perpetuate the existing use or prevent redevelopment of the site for additional residential development, development trends, market conditions, and regulatory or other incentives or standards to encourage additional residential development on these sites.
(2) In addition to the analysis required in paragraph (1), when a city or county is relying on nonvacant sites described in paragraph (3) of subdivision (b) to accommodate 50 percent or more of its housing need for lower income households, the methodology used to determine additional development potential shall demonstrate that the existing use identified pursuant to paragraph (3) of subdivision (b) does not constitute an impediment to additional residential development during the period covered by the housing element. An existing use shall be presumed to impede additional residential development, absent findings based on substantial evidence that the use is likely to be discontinued during the planning period.
(3) Notwithstanding any other law, and in addition to the requirements in paragraphs (1) and (2), sites that currently have residential uses, or within the past five years have had residential uses that have been vacated or demolished, that are or were subject to a recorded covenant, ordinance, or law that restricts rents to levels affordable to persons and families of low or very low income, subject to any other form of rent or price control through a public entity’s valid exercise of its police power, or occupied by low or very low income households, shall be subject to a policy requiring the replacement of all those units affordable to the same or lower income level as a condition of any development on the site.

Replacement requirements shall be consistent with those set forth in paragraph (3) of subdivision (c) of Section 65915.
(h) The program required by subparagraph (A) of paragraph (1) of subdivision (c) of Section 65583 shall accommodate 100 percent of the need for housing for very low and low-income households allocated pursuant to Section 65584 for which site capacity has not been identified in the inventory of sites pursuant to paragraph (3) of subdivision (a) on sites that shall be zoned to permit owner-occupied and rental multifamily residential use by right DRAFTember
ment cycle ment cy
uirements of Se uireme
on does not meet the on does not mee
MSA of 2,000,000 or greater SA of 2,000,000 or
an 25,000 in which case it shall an 25,000 in which case it ision (b), the city or county shall
ach site within the planning period and
y used to determine the development used to determine the ctors including the extent to which existin including the exte ditional residential development, the city’s idential devel g existing uses to higher density resident to highe
mand for the existing use, an analysis of a mand for the existing use, an ld perpetuate the existing use or prevent d perpetuate the existing use or p tial development, development trends, m evelopment, development trends, tives or standards to encourage addition standards to encourage addition s.
nalysis required in paragraph (1), when a alysis required in paragraph (1), when a cribed in paragraph (3) of subdivision (b) of sub
using need for lower income households, using need for lower income ho tional development potential shall demon tional development potential shall rsuant to paragraph (3) of subdivision (b) rsuant to paragraph (3) of subdivision residential development during the perio residential development during the perio g use shall be presumed to impede additi shall be presumed to impede additi ngs based on substantial evidenc on substantia e that th that th anning period. anning pe
(3) Notwithstanding any other law, and (3) Notwithstanding any othe and (2), sites that currently have res and (2), sites that currently have residential uses that have been v s that have been v
recorded covenant, ordinance, nt, ordinance,
families of low or very low in families of low or very
a public entity’s valid exer a public entity’s valid e
households, shall be su households, shall be
ffordable to the sam
placement requ
ision (c)
o
Site Inventory Guidebook Page 44 May 2020
for developments in which at least 20 percent of the units are affordable to lower income households during the planning period. These sites shall be zoned with minimum density and development standards that permit at least 16 units per site at a density of at least 16 units per acre in jurisdictions described in clause (i) of subparagraph (B) of paragraph (3) of subdivision (c), shall be at least 20 units per acre in jurisdictions described in clauses (iii) and (iv) of subparagraph (B) of paragraph (3) of subdivision (c) and shall meet the standards set forth in subparagraph (B) of paragraph (5) of subdivision (b). At least 50 percent of the very low and low-income housing need shall be accommodated on sites designated for residential use and for which nonresidential uses or mixed uses are not permitted, except that a city or county may accommodate all of the very low and lowincome housing need on sites designated for mixed uses if those sites allow 100 percent residential use and require that residential use occupy 50 percent of the total floor area of a mixed-use project.
(i) For purposes of this section and Section 65583, the phrase “use by right” shall mean that the local government’s review of the owner-occupied or multifamily residential use may not require a conditional use permit, planned unit development permit, or other discretionary local government review or approval that would constitute a “project” for purposes of Division 13 (commencing with Section 21000) of the Public Resources Code.

Any subdivision of the sites shall be subject to all laws, including, but not limited to, the local government ordinance implementing the Subdivision Map Act. A local ordinance may provide that “use by right” does not exempt the use from design review. However, that design review shall not constitute a “project” for purposes of Division 13 (commencing with Section 21000) of the Public Resources Code. Use by right for all rental multifamily residential housing shall be provided in accordance with subdivision (f) of Section 65589.5. (j) Notwithstanding any other provision of this section, within one-half mile of a SonomaMarin Area Rail Transit station, housing density requirements in place on June 30, 2014, shall apply.
(k) For purposes of subdivisions (a) and (b), the department shall provide guidance to local governments to properly survey, detail, and account for sites listed pursuant to Section 65585.
(l) This section shall remain in effect only until December 31, 2028, and as of that date is repealed.
(Amended (as amended by Stats. 2018, Ch. 958, Sec. 3) by Stats. 2019, Ch. 664, Sec.

15.5. (AB 1486) Effective January 1, 2020. Repealed as of December 31, 2028, by its own provisions. See later operative version amended by Sec. 16.5 of Stats. 2019, Ch. 664.) DRAFTeet th b). At least b). At le
modated on sites modated
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he very low and low he very low an -
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oval that would constitute a “project” for al that would constitu Section 21000) of the Public Resources 21000) of the P
ect to all laws, including, but not limited t s, including nting the Subdivision Map Act. A local ord nting the Subdivision Map exempt the use from design review. How exempt the use from design re e a “project” for purposes of Division 13 (c “project” for purposes of Division Resources Code. Use by right for all renta ces Code. Use by right for all rent provided in accordance with subdivision n accordance with subdivision other provision of this section, within one of this section, within one sit station, housing density requirements sit station, housing density re es of subdivisions (a) and (b), the departm es of subdivisions (a) and (b), the d s to properly survey, detail, and account s to properly survey, detail, and accou s section shall remain n shall remain in effect only until ealed.
(Amended (as amended by Stats. 2018, (Amended (as amended by

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dŽƚĂů EKd
^
&ŝŶĂůϮϬϮϯͲϮϬϯϭZ,E ϰϬϮ ϮϯϮ Ϯϰϳ ϲϰϭ ϭ͕ϱϱϮWŝƉĞůŝŶĞWƌŽũĞĐƚ Ϭ ϵϲϲ ϵϲϴWƌŽũĞĐƚĞĚhWƌŽĚƵĐƚŝŽŶ ϴϭ Ϯϳ ϮϳϬdŽƚĂůWŝƉĞůŝŶĞWƌŽũĞĐƚƐĂŶĚhΖƐ ϴϭ ϵϵϯ ϭ͕Ϯϯϴ/ŶŶŽǀĂƚŝŽŶĞŶƚĞƌ^ƉĞĐŝĨŝĐWůĂŶ ϭϯϯ ϭ͕ϳϭϮ Ϯ͕ϮϮϮsĂĐĂŶƚZĞƐŝĚĞŶƚŝĂů>ĂŶĚ ϱϬ ϭ͕ϰϳϴ ϭ͕ϲϮϮdŽƚĂů džŝƐƚŝŶŐŽŶŝŶŐĂƉĂĐŝƚLJ ϭϴϯ ϯ͕ϭϵϬ ϯ͕ϴϰϰdŽƚĂůhŶŝƚWŽƚĞŶƚŝĂů Ϯϲϰ ϰ͕ϭϴϯ ϱ͕ϬϴϮhŶŝƚƐKǀĞƌͬhŶĚĞƌ ϭϳ ϯ͕ϱϰϮ ϯ͕ϴϰϰWĞƌĐĞŶƚKǀĞƌͬhŶĚĞƌ ϳй ϱϱϯй ϮϮϳй ^ƚƌĂƚĞŐLJϭ
ϵϰ
ϭϲϰ
^ƚĞƉϭ͗
ŽƵŶƚWƌŽũĞĐƚƐŝŶƚŚĞWŝƉĞůŝŶĞĂŶĚ

ƐƚŝŵĂƚĞhΖƐ
^ƚĞƉƐƚŽĐĐŽŵŵŽĚĂƚĞ
Z,E
^ƚĞƉϮ͗
/ĚĞŶƚŝĨLJ
džŝƐƚŝŶŐŽŶŝŶŐĂƉĂĐŝƚLJ
ϰϳϭϲϯϱ
ϭ
Z&d^ŝƚĞƐŶĂůLJƐŝƐ^ƵŵŵĂƌLJdĂďůĞ
ϲͬϮϯͬϮϬϮϮ
^ƚƌĂƚĞŐLJϭ͗ZĞĚƵĐĞĚĨĨŽƌĚĂďŝůŝƚLJǁŝƚŚ
/ŶĐƌĞĂƐĞĚhƐƐƵŵƉƚŝŽŶƐ
/ŶĐůƵĚĞƐϮϭй>ŽǁsůĂŶĚϲйDŽĚĂĨĨŽƌĚĂďŝůŝƚLJĂŶĚ ĂŐŐƌĞƐƐŝǀĞhĂƐƐƵŵƉƚŝŽŶƐ
^ĐĞŶĂƌŝŽƵŝůĚĞƌͲKƉƚŝŽŶƐƚŽDĞĞƚZ,E
/ŶĐůƵĚĞƐZĞnjŽŶŝŶŐ͍
ƐƐƵŵĞĚ>ŽǁͬsĞƌLJ>ŽǁͲ/ŶĐŽŵĞĨĨŽƌĚĂďŝůŝƚLJ
ƐƐƵŵĞĚDŽĚĞƌĂƚĞͲ/ŶĐŽŵĞĨĨŽƌĚĂďŝůŝƚLJ
ƐƐƵŵĞĚйŽĨDŝdžĞĚͲhƐĞdƌĂŶƐŝƚsŝůůĂŐĞǁŚŝĐŚŝƐZĞƐŝĚĞŶƚŝĂů WƌŽũĞĐƚĞĚhWƌŽĚƵĐƚŝŽŶZĂƚĞ;ƉĞƌLJĞĂƌŽǀĞƌϴͲLJĞĂƌƉĞƌŝŽĚͿ ^ƚĞƉϯ͗
ŽŵƉĂƌĞƚŽZ,EĂŶĚƌĞĂƚĞƵĨĨĞƌ
Ϯ
ϭϲϮϯϳϳ
Ϭй
"UUBDINFOU

DRŶƚŝĂů
RhŶŝƚƐKǀĞ ĞƌĐĞŶƚKǀĞƌͬh ĚƌĞĂƚĞƵĨĨĞƌ
DRAsĂĐĂŶƚZĞƐŝĚĞŶƚŝĂů>ĂŶĚ ŶƚZĞƐŝĚĞŶƚ ŝŶŐŽŶŝŶŐĂƉĂĐŝƚLJDRϵϰ ϰϳϭDRAĂƚŝŽŶĞŶƚĞƌ^ƉĞĐŝĨŝĐWůĂŶ ĂƚŝŽŶĞŶƚĞ ϯϳϳ AŶĞWƌŽũĞĐƚƐ
RAFT LJ ǁ >ŽǁRAFDŽĚĞƌĂƚĞ /ŶĐŽŵĞ DŽĚ /ŶĐŽŵĞ Ϯϯ Ϯ ϲϰϭ
Ϭ
ƌŽĚƵĐƚŝŽŶ ϴϭ
ĂƌŝŽƵŝůĚĞƌͲ
/ŶĐůƵĚĞƐZĞnjŽŶŝŶŐ͍ /ŶĐůƵĚ
ƐƐƵŵĞĚ>ŽǁͬsĞƌLJ>ŽǁͲ/ŶĐŽŵĞĨĨŽƌĚĂďŝůŝƚLJ ǁͬsĞƌLJ>ŽǁͲ/ŶĐŽŵĞĨĨŽƌĚ ƐƐƵŵĞĚDŽĚĞƌĂƚĞͲ/ ƐƐƵŵĞĚDŽĚĞƌĂƚĞͲ/ŶĐŽŵĞĨĨŽƌĚĂďŝůŝƚLJ ŶĐŽŵĞĨĨŽ ƐƐƵŵĞĚйŽĨDŝdžĞĚͲhƐĞdƌĂŶƐŝƚsŝůůĂŐĞǁŚŝĐŚŝƐZĞƐŝĚĞŶƚŝĂů sŝůůĂŐĞ WƌŽũĞĐƚĞĚhWƌŽĚƵĐƚŝŽŶZĂƚĞ;ƉĞƌLJĞĂƌŽǀĞƌϴͲLJĞĂƌƉĞƌŝŽĚͿ WƌŽũĞĐƚĞĚhWƌŽĚƵĐƚŝŽŶZĂƚĞ;ƉĞƌLJĞĂƌŽǀĞƌ ϭϲϮ
Ϯ

AFT R D
EŽ
ϭϬϬй
Ϭй
ϴϬй
ϭΎ;ϮϬϭϴͲϮϬϮϭǀĞƌĂŐĞWƌŽĚƵĐƚŝŽŶͿ

džƚƌĞŵĞůLJ
>ŽǁͬsĞƌLJ>Žǁ
/ŶĐŽŵĞ
>Žǁ/ŶĐŽŵĞ
DŽĚĞƌĂƚĞ
/ŶĐŽŵĞ
ďŽǀĞ
DŽĚĞƌĂƚĞ
/ŶĐŽŵĞ
dŽƚĂů EKd
^
&ŝŶĂůϮϬϮϯͲϮϬϯϭZ,E ϰϬϮ ϮϯϮ Ϯϰϳ ϲϰϭ ϭ͕ϱϱϮWŝƉĞůŝŶĞWƌŽũĞĐƚ Ϭ ϵϲϲ ϵϲϴWƌŽũĞĐƚĞĚhWƌŽĚƵĐƚŝŽŶ ϰϭ ϭϰ ϭϯϱdŽƚĂůWŝƉĞůŝŶĞWƌŽũĞĐƚƐĂŶĚhΖƐ ϰϭ ϵϴϬ ϭ͕ϭϬϯ/ŶŶŽǀĂƚŝŽŶĞŶƚĞƌ^ƉĞĐŝĨŝĐWůĂŶ ϰϮϵ Ϭ Ϯ͕ϮϮϮsĂĐĂŶƚZĞƐŝĚĞŶƚŝĂů>ĂŶĚ ϯϴϭ ϳϵϱ ϭ͕ϲϮϮdŽƚĂů džŝƐƚŝŶŐŽŶŝŶŐĂƉĂĐŝƚLJ ϴϭϬ ϳϵϱ ϯ͕ϴϰϰ
dŽƚĂůhŶŝƚWŽƚĞŶƚŝĂů ϴϱϭ ϭ͕ϳϳϱ ϰ͕ϵϰϳhŶŝƚƐKǀĞƌͬhŶĚĞƌ ϲϬϰ ϭ͕ϭϯϰ ϯ͕ϴϰϰ WĞƌĐĞŶƚKǀĞƌͬhŶĚĞƌ Ϯϰϱй ϭϳϳй Ϯϭϵй
Z&d^ŝƚĞƐŶĂůLJƐŝƐ^ƵŵŵĂƌLJdĂďůĞ
^ƚƌĂƚĞŐLJϮ ϲͬϮϯͬϮϬϮϮ
^ƚƌĂƚĞŐLJϮ͗EŽZĞnjŽŶŝŶŐZĞƋƵŝƌĞĚ͕
,ƉƉƌŽǀĞĚDĞƚŚŽĚŽůŽŐLJ
/ŶĐůƵĚĞƐdŽƚĂůĨĨŽƌĚĂďŝůŝƚLJĂƚϭϬϬй͕ŶŽƌĞnjŽŶŝŶŐ͕ĂŶĚƐĂĨĞͲŚĂƌďŽƌh ĂƐƐƵŵƉƚŝŽŶƐ
^ĐĞŶĂƌŝŽƵŝůĚĞƌͲKƉƚŝŽŶƐƚŽDĞĞƚZ,E
/ŶĐůƵĚĞƐZĞnjŽŶŝŶŐ͍
ƐƐƵŵĞĚ>ŽǁͬsĞƌLJ>ŽǁͲ/ŶĐŽŵĞĨĨŽƌĚĂďŝůŝƚLJ
ƐƐƵŵĞĚDŽĚĞƌĂƚĞͲ/ŶĐŽŵĞĨĨŽƌĚĂďŝůŝƚLJ;ŽŶ>Žǁͬs>Ϳ
ƐƐƵŵĞĚйŽĨDŝdžĞĚͲhƐĞdƌĂŶƐŝƚsŝůůĂŐĞǁŚŝĐŚŝƐZĞƐŝĚĞŶƚŝĂů WƌŽũĞĐƚĞĚhWƌŽĚƵĐƚŝŽŶZĂƚĞ;ƉĞƌLJĞĂƌŽǀĞƌϴͲLJĞĂƌƉĞƌŝŽĚͿ ^ƚĞƉϯ͗
ŽŵƉĂƌĞƚŽZ,EĂŶĚƌĞĂƚĞƵĨĨĞƌ
Ϯϲϲй
ϴϬ
ϭ͕ϳϵϯ
Ϯ
Ϯ͕ϮϯϵϮ͕ϯϮϭ
ϭ͕ϲϴϳ
ϰϰϲ
ϴϮ
^ƚĞƉϭ͗
ŽƵŶƚWƌŽũĞĐƚƐŝŶƚŚĞWŝƉĞůŝŶĞĂŶĚ

ƐƚŝŵĂƚĞhΖƐ
^ƚĞƉƐƚŽĐĐŽŵŵŽĚĂƚĞ
Z,E
^ƚĞƉϮ͗
/ĚĞŶƚŝĨLJ
džŝƐƚŝŶŐŽŶŝŶŐĂƉĂĐŝƚLJ
"UUBDINFOU

DRĞŶƚŝĂů
RhŶŝƚƐKǀ WĞƌĐĞŶƚKǀĞƌͬh ƚŝŶŐŽŶŝŶŐĂƉĂĐŝƚLJ ĚƌĞĂƚĞƵĨĨĞƌ DRϮ͕Ϯϯϵ
RAĂĐĂŶƚZĞƐŝĚĞŶƚŝĂů>ĂŶĚ ĂŶƚZĞƐŝĚĞŶƚ ϰϰϲ AƚŝŽŶĞŶƚĞƌ^ƉĞĐŝĨŝĐWůĂŶ ƚŝŽŶĞŶƚĞ ϰ ϭ͕ϳϵϯ AŶĞWƌŽũĞĐƚƐ
RAFT LJ ǁ >ŽǁRAFDŽĚĞƌĂƚĞ /ŶĐŽŵĞ DŽĚ /ŶĐŽŵĞ Ϯϯ Ϯ ϲϰϭ
Ϭ ϵ
ŽĚƵĐƚŝŽŶ ϰϭ
ƌŝŽƵŝůĚĞƌͲ
/ŶĐůƵĚĞƐZĞnjŽŶŝŶŐ͍ /ŶĐůƵĚĞ
ƐƐƵŵĞĚ>ŽǁͬsĞƌLJ>ŽǁͲ/ŶĐŽŵĞĨĨŽƌĚĂďŝůŝƚLJ ǁͬsĞƌLJ>ŽǁͲ/ŶĐŽŵĞĨĨŽƌĚ ƐƐƵŵĞĚDŽĚĞƌĂƚĞͲ/ŶĐŽŵĞ ĞĚDŽĚĞƌĂƚĞͲ/ŶĐŽŵĞĨĨŽƌĚĂďŝůŝƚLJ;ŽŶ>Žǁͬs>Ϳ ĨĨŽƌĚĂďŝ ƐƐƵŵĞĚйŽĨDŝdžĞĚͲhƐĞdƌĂŶƐŝƚsŝůůĂŐĞǁŚŝĐŚŝƐZĞƐŝĚĞŶƚŝĂů sŝůůĂŐĞǁ WƌŽũĞĐƚĞĚhWƌŽĚƵĐƚŝŽŶZĂƚĞ;ƉĞƌLJĞĂƌŽǀĞƌϴͲLJĞĂƌƉĞƌŝŽĚͿ WƌŽũĞĐƚĞĚhWƌŽĚƵĐƚŝŽŶZĂƚĞ;ƉĞƌLJĞĂƌŽǀĞƌ ϴϬ
Ϯ

AFT R D
EŽ
ϯϬйϭϬйϴϬй
ϭΎ;ϮϬϭϴͲϮϬϮϭǀĞƌĂŐĞWƌŽĚƵĐƚŝŽŶͿ

džƚƌĞŵĞůLJ
>ŽǁͬsĞƌLJ>Žǁ
/ŶĐŽŵĞ
>Žǁ/ŶĐŽŵĞ
DŽĚĞƌĂƚĞ
/ŶĐŽŵĞ
ďŽǀĞ
DŽĚĞƌĂƚĞ
/ŶĐŽŵĞ
dŽƚĂů EKd
^
&ŝŶĂůϮϬϮϯͲϮϬϯϭZ,E ϰϬϮ ϮϯϮ Ϯϰϳ ϲϰϭ ϭ͕ϱϱϮWŝƉĞůŝŶĞWƌŽũĞĐƚ Ϭ ϵϲϲ ϵϲϴWƌŽũĞĐƚĞĚhWƌŽĚƵĐƚŝŽŶ ϰϭ ϭϰ ϭϯϱdŽƚĂůWŝƉĞůŝŶĞWƌŽũĞĐƚƐĂŶĚhΖƐ ϰϭ ϵϴϬ ϭ͕ϭϬϯ/ŶŶŽǀĂƚŝŽŶĞŶƚĞƌ^ƉĞĐŝĨŝĐWůĂŶ ϮϮϯ ϭ͕ϰϲϬ Ϯ͕ϮϮϮsĂĐĂŶƚZĞƐŝĚĞŶƚŝĂů>ĂŶĚ ϴϯ ϭ͕ϰϬϱ ϭ͕ϲϮϮdŽƚĂů džŝƐƚŝŶŐŽŶŝŶŐĂƉĂĐŝƚLJ ϯϬϲ Ϯ͕ϴϲϱ ϯ͕ϴϰϰdŽƚĂůhŶŝƚWŽƚĞŶƚŝĂů ϯϰϳ ϯ͕ϴϰϱ ϰ͕ϵϰϳhŶŝƚƐKǀĞƌͬhŶĚĞƌ ϭϬϬ ϯ͕ϮϬϰ ϯ͕ϴϰϰWĞƌĐĞŶƚKǀĞƌͬhŶĚĞƌ ϰϬй ϱϬϬй Ϯϭϵй Z&d^ŝƚĞƐŶĂůLJƐŝƐ^ƵŵŵĂƌLJdĂďůĞ
^ƚƌĂƚĞŐLJϯ ϲͬϮϯͬϮϬϮϮ
^ƚƌĂƚĞŐLJϯ͗EŽZĞnjŽŶŝŶŐZĞƋƵŝƌĞĚ͕
,ƉƉƌŽǀĞĚDĞƚŚŽĚŽůŽŐLJǁŝƚŚŽŶƐĞƌǀĂƚŝǀĞ
ĨĨŽƌĚĂďŝůŝƚLJƐƐƵŵƉƚŝŽŶƐ
/ŶĐůƵĚĞƐϯϬй>ŽǁsůĂŶĚϭϬйDŽĚĨĨŽƌĚĂďŝůŝƚLJ͕EŽZĞnjŽŶŝŶŐ͕ĂŶĚ^ĂĨĞͲ ,ĂƌďŽƌhƐƐƵŵƉƚŝŽŶƐ
^ĐĞŶĂƌŝŽƵŝůĚĞƌͲKƉƚŝŽŶƐƚŽDĞĞƚZ,E
/ŶĐůƵĚĞƐZĞnjŽŶŝŶŐ͍
ƐƐƵŵĞĚ>ŽǁͬsĞƌLJ>ŽǁͲ/ŶĐŽŵĞĨĨŽƌĚĂďŝůŝƚLJ
ƐƐƵŵĞĚDŽĚĞƌĂƚĞͲ/ŶĐŽŵĞĨĨŽƌĚĂďŝůŝƚLJ
ƐƐƵŵĞĚйŽĨDŝdžĞĚͲhƐĞdƌĂŶƐŝƚsŝůůĂŐĞǁŚŝĐŚŝƐZĞƐŝĚĞŶƚŝĂů WƌŽũĞĐƚĞĚhWƌŽĚƵĐƚŝŽŶZĂƚĞ;ƉĞƌLJĞĂƌŽǀĞƌϴͲLJĞĂƌƉĞƌŝŽĚͿ ^ƚĞƉϯ͗
ŽŵƉĂƌĞƚŽZ,EĂŶĚƌĞĂƚĞƵĨĨĞƌ
ϴϬ
ϱϯϵ
ϭϵй
Ϯ
ϴϮ
ϭϯϰϲϳϯϳϱϱ
ϭϮϭ
^ƚĞƉϭ͗
ŽƵŶƚWƌŽũĞĐƚƐŝŶƚŚĞWŝƉĞůŝŶĞĂŶĚ

ƐƚŝŵĂƚĞhΖƐ
^ƚĞƉƐƚŽĐĐŽŵŵŽĚĂƚĞ
Z,E
^ƚĞƉϮ͗
/ĚĞŶƚŝĨLJ
džŝƐƚŝŶŐŽŶŝŶŐĂƉĂĐŝƚLJ
"UUBDINFOU

DRƚŝĂů
RhŶŝƚƐKǀĞƌ ƌĐĞŶƚKǀĞƌͬhŶ ŶĚƌĞĂƚĞƵĨĨĞƌ
DRAsĂĐĂŶƚZĞƐŝĚĞŶƚŝĂů>ĂŶĚ ŶƚZĞƐŝĚĞŶƚŝĂ ŶŐŽŶŝŶŐĂƉĂĐŝƚLJDRϭϯϰ ϲϳϯDRAFT LJ ǁ >Žǁ RAFDŽĚĞƌĂƚĞ /ŶĐŽŵĞ DŽĚ /ŶĐŽŵĞ ϮϯϮ ϲϰϭ
Ϭ
ƌŽĚƵĐƚŝŽŶ ϰϭ
ŝŶĞWƌŽũĞĐƚ
ǀĂƚŝŽŶĞŶƚĞƌ^ƉĞĐŝĨŝĐWůĂŶ ǀĂƚŝŽŶĞŶƚ
ŶĂƌŝŽƵŝůĚĞƌͲ
/ŶĐůƵĚĞƐZĞnjŽŶŝŶŐ͍ /ŶĐůƵĚ
ƐƐƵŵĞĚ>ŽǁͬsĞƌLJ>ŽǁͲ/ŶĐŽŵĞĨĨŽƌĚĂďŝůŝƚLJ ŽǁͬsĞƌLJ>ŽǁͲ/ŶĐŽŵĞĨĨŽƌĚĂ ƐƐƵŵĞĚDŽĚĞƌĂƚĞͲ/ ƵŵĞĚDŽĚĞƌĂƚĞͲ/ŶĐŽŵĞĨĨŽƌĚĂďŝůŝƚLJ ŶĐŽŵĞĨĨŽ ƐƐƵŵĞĚйŽĨDŝdžĞĚͲhƐĞdƌĂŶƐŝƚsŝůůĂŐĞǁŚŝĐŚŝƐZĞƐŝĚĞŶƚŝĂů sŝůůĂŐĞ WƌŽũĞĐƚĞĚhWƌŽĚƵĐƚŝŽŶZĂƚĞ;ƉĞƌLJĞĂƌŽǀĞƌϴͲLJĞĂƌƉĞƌŝŽĚͿ WƌŽũĞĐƚĞĚhWƌŽĚƵĐƚŝŽŶZĂƚĞ;ƉĞƌLJĞĂƌŽǀĞ ϴϬ
ϱϯϵ
Ϯ

AFT R D
EŽ
Ϯϭй
ϲй
ϴϬй
ϮΎ;ϮϬϭϴͲϮϬϮϭǀĞƌĂŐĞWƌŽĚƵĐƚŝŽŶͿ

džƚƌĞŵĞůLJ
>ŽǁͬsĞƌLJ>Žǁ
/ŶĐŽŵĞ
>Žǁ/ŶĐŽŵĞ DŽĚĞƌĂƚĞ
/ŶĐŽŵĞ
ďŽǀĞ
DŽĚĞƌĂƚĞ
/ŶĐŽŵĞ
dŽƚĂů EKd
^
&ŝŶĂůϮϬϮϯͲϮϬϯϭZ,E ϰϬϮ ϮϯϮ Ϯϰϳ ϲϰϭ ϭ͕ϱϱϮ
WŝƉĞůŝŶĞWƌŽũĞĐƚ Ϭ ϵϲϲ ϵϲϴWƌŽũĞĐƚĞĚhWƌŽĚƵĐƚŝŽŶ ϴϭ Ϯϳ ϮϳϬdŽƚĂůWŝƉĞůŝŶĞWƌŽũĞĐƚƐĂŶĚhΖƐ ϴϭ ϵϵϯ ϭ͕Ϯϯϴ/ŶŶŽǀĂƚŝŽŶĞŶƚĞƌ^ƉĞĐŝĨŝĐWůĂŶ ϭϯϯ ϭ͕ϳϭϮ Ϯ͕ϮϮϮsĂĐĂŶƚZĞƐŝĚĞŶƚŝĂů>ĂŶĚ ϱϬ ϭ͕ϴϳϵ Ϯ͕ϬϮϯ dŽƚĂů
džŝƐƚŝŶŐŽŶŝŶŐĂƉĂĐŝƚLJ ϭϴϯ ϯ͕ϱϵϭ ϰ͕ϮϰϱdŽƚĂůhŶŝƚWŽƚĞŶƚŝĂů Ϯϲϰ ϰ͕ϱϴϰ ϱ͕ϰϴϯhŶŝƚƐKǀĞƌͬhŶĚĞƌ ϭϳ ϯ͕ϵϰϯ ϰ͕ϮϰϱWĞƌĐĞŶƚKǀĞƌͬhŶĚĞƌ ϳй ϲϭϱй Ϯϱϯй ^ƚƌĂƚĞŐLJϭ
ϭϲϰ
ϵϰ
^ƚĞƉϭ͗
ŽƵŶƚWƌŽũĞĐƚƐŝŶƚŚĞWŝƉĞůŝŶĞĂŶĚ

ƐƚŝŵĂƚĞhΖƐ
^ƚĞƉƐƚŽĐĐŽŵŵŽĚĂƚĞ
Z,E
^ƚĞƉϮ͗
/ĚĞŶƚŝĨLJ
džŝƐƚŝŶŐŽŶŝŶŐĂƉĂĐŝƚLJ
ϰϳϭϲϯϱ
ϭ
Z&d^ŝƚĞƐŶĂůLJƐŝƐ^ƵŵŵĂƌLJdĂďůĞ
ϲͬϮϯͬϮϬϮϮ
^ƚƌĂƚĞŐLJϭ͗ZĞĚƵĐĞĚĨĨŽƌĚĂďŝůŝƚLJǁŝƚŚ
/ŶĐƌĞĂƐĞĚhƐƐƵŵƉƚŝŽŶƐ
/ŶĐůƵĚĞƐϮϭй>ŽǁsůĂŶĚϲйDŽĚĂĨĨŽƌĚĂďŝůŝƚLJĂŶĚ ĂŐŐƌĞƐƐŝǀĞhĂƐƐƵŵƉƚŝŽŶƐ
^ĐĞŶĂƌŝŽƵŝůĚĞƌͲKƉƚŝŽŶƐƚŽDĞĞƚZ,E
/ŶĐůƵĚĞƐZĞnjŽŶŝŶŐ͍
ƐƐƵŵĞĚ>ŽǁͬsĞƌLJ>ŽǁͲ/ŶĐŽŵĞĨĨŽƌĚĂďŝůŝƚLJ
ƐƐƵŵĞĚDŽĚĞƌĂƚĞͲ/ŶĐŽŵĞĨĨŽƌĚĂďŝůŝƚLJ
ƐƐƵŵĞĚйŽĨDŝdžĞĚͲhƐĞdƌĂŶƐŝƚsŝůůĂŐĞǁŚŝĐŚŝƐZĞƐŝĚĞŶƚŝĂů WƌŽũĞĐƚĞĚhWƌŽĚƵĐƚŝŽŶZĂƚĞ;ƉĞƌLJĞĂƌŽǀĞƌϴͲLJĞĂƌƉĞƌŝŽĚͿ ^ƚĞƉϯ͗
ŽŵƉĂƌĞƚŽZ,EĂŶĚƌĞĂƚĞƵĨĨĞƌ
Ϯ
ϭϲϮϯϳϳ
Ϭй
"UUBDINFOU

DRA ^ŝƚĞƐŶĂůLJƐŝƐ^ƵŵŵĂƌLJdĂďůĞ ĞĚƵĐĞĚĨĨŽƌĚĂďŝůŝƚLJǁŝƚŚ ĚƵĐĞĚĨĨŽƌĚĂďŝůŝƚLJǁŝƚŚ hƐƐƵŵƉƚŝŽŶƐ йDŽĚĂĨĨŽƌĚĂďŝůŝƚLJĂŶĚ ƌĚĂďŝůŝƚLJĂŶĚ RƐƵŵƉƚŝŽŶƐ 
ƐƐƵŵĞĚйŽĨD ƐƐƵ
WƌŽũĞĐƚĞĚhWƌŽĚ WƌŽ
DRA> ϮϯϮ Ϯϰϳ
A
Ğ
DŽĚĞƌĂƚĞ
/ŶĐŽŵĞ
RA D Ϭ ϵϲϲ ϮRAFϴϭ Ϯϳ
AFϭϲϮ
ϴ
Fϵϯ ϭ͕Ϯϯϴ
Aϭϯϯ ϭ͕ϳϭϮ Ϯ͕ϮϮϮ
Fϭ͕ϳϭϮ Ϯ͕ϮϮϮ
Aϯϳϳ ϱϬ
Fϭ͕ϴϳϵ Ϯ͕ϬϮϯ ϭ͕ϴϳϵ
AFTϯ͕ϱϵϭAFϮϲϰAFT͕ϱϴϰAFϭϳ ϰ͕Ϯϰ
F RAT
EŽ
ϭϬϬй
Ϭй
ϴϬй
ϭΎ;ϮϬϭϴͲϮϬϮϭǀĞƌĂŐĞWƌŽĚƵĐƚŝŽŶͿ

džƚƌĞŵĞůLJ
>ŽǁͬsĞƌLJ>Žǁ
/ŶĐŽŵĞ
>Žǁ/ŶĐŽŵĞ
DŽĚĞƌĂƚĞ
/ŶĐŽŵĞ
ďŽǀĞ
DŽĚĞƌĂƚĞ
/ŶĐŽŵĞ
dŽƚĂů EKd
^
&ŝŶĂůϮϬϮϯͲϮϬϯϭZ,E ϰϬϮ ϮϯϮ Ϯϰϳ ϲϰϭ ϭ͕ϱϱϮ
WŝƉĞůŝŶĞWƌŽũĞĐƚ Ϭ ϵϲϲ ϵϲϴWƌŽũĞĐƚĞĚhWƌŽĚƵĐƚŝŽŶ ϰϭ ϭϰ ϭϯϱdŽƚĂůWŝƉĞůŝŶĞWƌŽũĞĐƚƐĂŶĚhΖƐ ϰϭ ϵϴϬ ϭ͕ϭϬϯ/ŶŶŽǀĂƚŝŽŶĞŶƚĞƌ^ƉĞĐŝĨŝĐWůĂŶ ϰϮϵ Ϭ Ϯ͕ϮϮϮsĂĐĂŶƚZĞƐŝĚĞŶƚŝĂů>ĂŶĚ ϯϴϭ ϭ͕ϭϵϲ Ϯ͕ϬϮϯdŽƚĂů džŝƐƚŝŶŐŽŶŝŶŐĂƉĂĐŝƚLJ ϴϭϬ ϭ͕ϭϵϲ ϰ͕ϮϰϱdŽƚĂůhŶŝƚWŽƚĞŶƚŝĂů ϴϱϭ Ϯ͕ϭϳϲ ϱ͕ϯϰϴhŶŝƚƐKǀĞƌͬhŶĚĞƌ ϲϬϰ ϭ͕ϱϯϱ ϰ͕ϮϰϱWĞƌĐĞŶƚKǀĞƌͬhŶĚĞƌ Ϯϰϱй Ϯϯϵй Ϯϰϱй Z&d^ŝƚĞƐŶĂůLJƐŝƐ^ƵŵŵĂƌLJdĂďůĞ
^ƚƌĂƚĞŐLJϮ ϲͬϮϯͬϮϬϮϮ
^ƚƌĂƚĞŐLJϮ͗EŽZĞnjŽŶŝŶŐZĞƋƵŝƌĞĚ͕
,ƉƉƌŽǀĞĚDĞƚŚŽĚŽůŽŐLJ
/ŶĐůƵĚĞƐdŽƚĂůĨĨŽƌĚĂďŝůŝƚLJĂƚϭϬϬй͕ŶŽƌĞnjŽŶŝŶŐ͕ĂŶĚƐĂĨĞͲŚĂƌďŽƌh ĂƐƐƵŵƉƚŝŽŶƐ
^ĐĞŶĂƌŝŽƵŝůĚĞƌͲKƉƚŝŽŶƐƚŽDĞĞƚZ,E
/ŶĐůƵĚĞƐZĞnjŽŶŝŶŐ͍
ƐƐƵŵĞĚ>ŽǁͬsĞƌLJ>ŽǁͲ/ŶĐŽŵĞĨĨŽƌĚĂďŝůŝƚLJ
ƐƐƵŵĞĚDŽĚĞƌĂƚĞͲ/ŶĐŽŵĞĨĨŽƌĚĂďŝůŝƚLJ;ŽŶ>Žǁͬs>Ϳ
ƐƐƵŵĞĚйŽĨDŝdžĞĚͲhƐĞdƌĂŶƐŝƚsŝůůĂŐĞǁŚŝĐŚŝƐZĞƐŝĚĞŶƚŝĂů WƌŽũĞĐƚĞĚhWƌŽĚƵĐƚŝŽŶZĂƚĞ;ƉĞƌLJĞĂƌŽǀĞƌϴͲLJĞĂƌƉĞƌŝŽĚͿ ^ƚĞƉϯ͗
ŽŵƉĂƌĞƚŽZ,EĂŶĚƌĞĂƚĞƵĨĨĞƌ
Ϯϲϲй
ϴϬ
ϭ͕ϳϵϯ
Ϯ
Ϯ͕ϮϯϵϮ͕ϯϮϭ
ϭ͕ϲϴϳ
ϴϮ
ϰϰϲ
^ƚĞƉϭ͗
ŽƵŶƚWƌŽũĞĐƚƐŝŶƚŚĞWŝƉĞůŝŶĞĂŶĚ

ƐƚŝŵĂƚĞhΖƐ
^ƚĞƉƐƚŽĐĐŽŵŵŽĚĂƚĞ
Z,E
^ƚĞƉϮ͗
/ĚĞŶƚŝĨLJ
džŝƐƚŝŶŐŽŶŝŶŐĂƉĂĐŝƚLJ
"UUBDINFOU

DRA ŝƚĞƐŶĂůLJƐŝƐ^ƵŵŵĂƌLJdĂďůĞ EŽZĞnjŽŶŝŶŐZĞƋƵŝƌĞĚ͕ ŽZĞnjŽŶŝŶŐZĞƋƵŝƌĞĚ͕ ĞĚDĞƚŚŽĚŽůŽŐLJ ŶŽƌĞnjŽŶŝŶŐ͕ĂŶĚƐĂĨĞͲŚĂƌ Ő͕ĂŶĚƐĂĨĞ ďŽƌh Rƌh ŶƐ ƐƐƵŵĞĚ Ɛ ƐƐƵŵĞĚйŽĨD ƐƐƵ WƌŽũĞĐƚĞĚhWƌŽĚƵ WƌŽDRA> ϮϯϮ Ϯϰϳ A
Ğ
DŽĚĞƌĂƚĞ
/ŶĐŽŵĞ
RA D Ϭ ϵϲϲ ϮRAFϰϭ ϭϰ
AFϴϬ
ϰ
FϵϴϬ ϭ͕ϭϬϯ
AϰϮϵ
F
Ϭ Ϯ͕ϮϮϮ
AFϭ͕ϳϵϯ ϯϴϭ ϭ͕ϭϵϲ Ϯ͕ϬϮϯ
Fϭ͕ϭϵϲ
Aϲ
Fϭ͕ϭϵϲ
AϴϱϭAFTϭϳϲAFϲϬϰ ϰ͕Ϯϰ
F RAT
EŽ
ϯϬйϭϬйϴϬй
ϭΎ;ϮϬϭϴͲϮϬϮϭǀĞƌĂŐĞWƌŽĚƵĐƚŝŽŶͿ

džƚƌĞŵĞůLJ
>ŽǁͬsĞƌLJ>Žǁ
/ŶĐŽŵĞ
>Žǁ/ŶĐŽŵĞ DŽĚĞƌĂƚĞ
/ŶĐŽŵĞ
ďŽǀĞ
DŽĚĞƌĂƚĞ
/ŶĐŽŵĞ
dŽƚĂů EKd
^
&ŝŶĂůϮϬϮϯͲϮϬϯϭZ,E ϰϬϮ ϮϯϮ Ϯϰϳ ϲϰϭ ϭ͕ϱϱϮ
WŝƉĞůŝŶĞWƌŽũĞĐƚ Ϭ ϵϲϲ ϵϲϴWƌŽũĞĐƚĞĚhWƌŽĚƵĐƚŝŽŶ ϰϭ ϭϰ ϭϯϱdŽƚĂůWŝƉĞůŝŶĞWƌŽũĞĐƚƐĂŶĚhΖƐ ϰϭ ϵϴϬ ϭ͕ϭϬϯ/ŶŶŽǀĂƚŝŽŶĞŶƚĞƌ^ƉĞĐŝĨŝĐWůĂŶ ϮϮϯ ϭ͕ϰϲϬ Ϯ͕ϮϮϮsĂĐĂŶƚZĞƐŝĚĞŶƚŝĂů>ĂŶĚ ϴϯ ϭ͕ϴϬϲ Ϯ͕ϬϮϯ dŽƚĂů
džŝƐƚŝŶŐŽŶŝŶŐĂƉĂĐŝƚLJ ϯϬϲ ϯ͕Ϯϲϲ ϰ͕ϮϰϱdŽƚĂůhŶŝƚWŽƚĞŶƚŝĂů ϯϰϳ ϰ͕Ϯϰϲ ϱ͕ϯϰϴhŶŝƚƐKǀĞƌͬhŶĚĞƌ ϭϬϬ ϯ͕ϲϬϱ ϰ͕ϮϰϱWĞƌĐĞŶƚKǀĞƌͬhŶĚĞƌ ϰϬй ϱϲϮй Ϯϰϱй Z&d^ŝƚĞƐŶĂůLJƐŝƐ^ƵŵŵĂƌLJdĂďůĞ
^ƚƌĂƚĞŐLJϯ ϲͬϮϯͬϮϬϮϮ
^ƚƌĂƚĞŐLJϯ͗EŽZĞnjŽŶŝŶŐZĞƋƵŝƌĞĚ͕
,ƉƉƌŽǀĞĚDĞƚŚŽĚŽůŽŐLJǁŝƚŚŽŶƐĞƌǀĂƚŝǀĞ
ĨĨŽƌĚĂďŝůŝƚLJƐƐƵŵƉƚŝŽŶƐ
/ŶĐůƵĚĞƐϯϬй>ŽǁsůĂŶĚϭϬйDŽĚĨĨŽƌĚĂďŝůŝƚLJ͕EŽZĞnjŽŶŝŶŐ͕ĂŶĚ^ĂĨĞͲ ,ĂƌďŽƌhƐƐƵŵƉƚŝŽŶƐ
^ĐĞŶĂƌŝŽƵŝůĚĞƌͲKƉƚŝŽŶƐƚŽDĞĞƚZ,E
/ŶĐůƵĚĞƐZĞnjŽŶŝŶŐ͍
ƐƐƵŵĞĚ>ŽǁͬsĞƌLJ>ŽǁͲ/ŶĐŽŵĞĨĨŽƌĚĂďŝůŝƚLJ
ƐƐƵŵĞĚDŽĚĞƌĂƚĞͲ/ŶĐŽŵĞĨĨŽƌĚĂďŝůŝƚLJ
ƐƐƵŵĞĚйŽĨDŝdžĞĚͲhƐĞdƌĂŶƐŝƚsŝůůĂŐĞǁŚŝĐŚŝƐZĞƐŝĚĞŶƚŝĂů WƌŽũĞĐƚĞĚhWƌŽĚƵĐƚŝŽŶZĂƚĞ;ƉĞƌLJĞĂƌŽǀĞƌϴͲLJĞĂƌƉĞƌŝŽĚͿ ^ƚĞƉϯ͗
ŽŵƉĂƌĞƚŽZ,EĂŶĚƌĞĂƚĞƵĨĨĞƌ
ϴϬ
ϱϯϵ
ϭϵй
Ϯ
ϴϮ
ϭϯϰϲϳϯϳϱϱ
ϭϮϭ
^ƚĞƉϭ͗
ŽƵŶƚWƌŽũĞĐƚƐŝŶƚŚĞWŝƉĞůŝŶĞĂŶĚ

ƐƚŝŵĂƚĞhΖƐ
^ƚĞƉƐƚŽĐĐŽŵŵŽĚĂƚĞ
Z,E
^ƚĞƉϮ͗
/ĚĞŶƚŝĨLJ
džŝƐƚŝŶŐŽŶŝŶŐĂƉĂĐŝƚLJ
"UUBDINFOU

DRA ^ŝƚĞƐŶĂůLJƐŝƐ^ƵŵŵĂƌLJdĂďůĞ
ϯ͗EŽZĞnjŽŶŝŶŐZĞƋƵŝƌĞĚ͕ ͗EŽZĞnjŽŶŝŶŐZĞƋƵŝƌĞĚ͕ ƚŚŽĚŽůŽŐLJǁŝƚŚŽŶƐĞƌǀĂƚŝǀĞ ŽĚŽůŽŐLJǁŝƚŚŽŶƐĞƌǀĂƚŝ
LJƐƐƵŵƉƚŝŽŶƐ
ŽƌĚĂďŝůŝƚLJ͕EŽZĞnjŽŶŝŶŐ͕ĂŶĚ LJ͕EŽZĞnjŽŶ ^ĂĨĞͲ
ŵƉƚŝŽŶƐ
ƐƐƵŵĞĚйŽĨ ƐƐƵ
WƌŽũĞĐƚĞĚhWƌŽĚ WƌŽ
DRA> Ğ DŽĚĞƌĂƚĞ /ŶĐŽŵĞ
ARϮϯϮ ϮϰϳARFϬ ϵϲϲ Ϯ
RAFϰϭ
Fϭϰ ϭ
AFϴϬ
FϬ ϭ͕ϭϬϯ ϮϮϯ
Aϱϯϵ ϭ͕ϰϲϬ
FϮ͕ϮϮϮ
AFϴϯAϭ͕ϴϬϲ
FϮ͕ϬϮϯ
AFTϲ ϯ͕ϮϲϲAF RϯϰϳAFTϰ͕Ϯϰϲ FT AϭϬϬ ϰ͕Ϯϰ
FAT
/HJHQG

6LWHV'HYHORSHG'XULQJWK&\FOH
6LWHV1RW'HYHORSHGDQG1RW&DUULHG
2YHUWRWKHWK&\FOH
$31 *3 =21( $FUHV 1RWHV
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Brentwood 2023-2031 Housing Element
Appendix C: Summary of Community Engagement C-8
C.5 Flyers/Outreach Materials
This section contains all outreach materials distributed to the community providing notice of the Housing Element Update process and opportunities for participation. DRAFTof th Brentwood 2023-2031 Housing Element
Appendix C: Summary of Community Engagement C-9
DRAFT
Brentwood 2023-2031 Housing Element
Appendix C: Summary of Community Engagement C-10
DRAFT
Brentwood 2023-2031 Housing Element
Appendix C: Summary of Community Engagement C-11
DRAFT
Brentwood 2023-2031 Housing Element
Appendix C: Summary of Community Engagement C-12
DRAFT
Brentwood 2023-2031 Housing Element
Appendix C: Summary of Community Engagement C-13
DRAFT
Brentwood 2023-2031 Housing Element
Appendix C: Summary of Community Engagement C-14
DRAFT
Brentwood 2023-2031 Housing Element
Appendix C: Summary of Community Engagement C-15
DRAFT
Brentwood Buzz
for your families. Please consider completing a short survey to help update the City's Housing Element: Housing Element Survey
Your feedback will help shape plans for the future of housing in Brentwood. The survey is intended to assist in creating policies and programs that appropriately address the housing needs of current and future Brentwood residents while at the same time respecting state laws.

We are also pleased to announce the launch of the webpage for the housing element project, Housing Element Update, which is translatable to Spanish and Chinese.

Please visit the website to get informed about the update, to review FAQs, download project documents, reports, and view a project schedule including upcoming public meetings and other opportunities for engagement.

Parks & Open Space Ballot Measure:

City Council has also directed staff to prepare a ballot measure crafted to protect - where allowed by state law - parks and open spaces from future development. If approved, specific properties will require a ballot measure to change permitted uses covered by the measure.

Details of the land use ballot measure will be discussed at upcoming City Council meetings. The goal is to complete work on the measure by the August deadline so that it can appear on the November 2022 ballot. Background from initial discussions during the April 26, 2022, City Council meeting can be viewed online by following this link: City Council Video Recording Thank you for taking the time to read our newsletter. We encourage your input and involvement in issues that affect your community, and this month I am focused on several land use issues that will benefit from your input.

Housing Element Update:

Based on California state law, the City of Brentwood is updating its 2023-2031 Housing Element, which establishes policies and programs to address housing needs at all income levels throughout the community. Many of you are concerned about the City’s future growth and the various issues tied to expansion, which include ensuring affordable housing options May 2022
Stay Connected with the City of Brentwood
brentwoodca.gov cityofbrentwood brentwoodca.gov
City Manager's Message
Thank You,
City Manager Tim Ogden
City of Brentwood
[email protected]
DRAFting a short survey to help u ey to help u
Ruture of housing in Bre ng
and programs that approp ely ad
sidents while at the same ti pe
o announce the launch of the R
pdate, which is translatable to Span
bsite to get informed about the
ep nd view a project schedule i
s for engagement. s fo
s & Open Space Ballot Measure: Open S t
y Council has also directed staff to p y Cou il h irect y state law - parks and open y state law ate parks and o ire a ballot measure to ch ir allot measure t
of the land use ballot f the land f the la use ba
complete work o compl te work
022 ballot. Ba 02 ba t.
viewed
AFTo read our new
olvement in i ues that
nth I am focused o
from y
pdate:
rnia state law, the City of Brent nia state law, the City of Bren 23-2031 Housing E 23-2031 Housing Element, which 23-2031 ms to address housing nee dress
commu
the City’s future growth a
sion, which include ensuring a nsuring afford uring a
7:00 PM - City Council Meeting
brentwoodca.gov cityofbrentwood brentwoodca.gov
View Agenda
View Agenda
Tuesday, May 24, 2022
7:00 PM
City Council Meeting
brentwoodca.gov/vcc

VIEW CALENDAR
Upcoming
Public Meetings
Tuesday, May 10, 2022
5:00 PM
Visit our Online Calendar
for All Upcoming Events
and Meetings
Zoom Link to City
Council Meetings
5:00 PM - Operating Budget
Workshop
page 2 of 7 May 2022
Workshop on Upcoming City Budgets Open
to Citizen Input
What's New
The City Council will conduct a Zoom workshop at 5 p.m.

Tuesday, May 10, to discuss the draft 2022/23 - 2023/24 Operating Budget. The workshop is an opportunity for the public and the City Council to provide feedback on the
proposed budget. The operating budget outlines funding for the full range of services provided by the City, including police; parks and recreation; public works; economic development; planning; building; community enrichment; engineering and inspection; housing; general administrative services; water and wastewater utilities; and the collection and disposal of refuse.

The budget also specifies funding needed to implement
strategic initiatives included in the City’s 2022/23 - 2023/24 Strategic Plan. Any changes resulting from the workshop will be incorporated into the final budget document, scheduled for consideration at the City Council’s June 14 meeting. The Operating Budget Draft will be available on May 3, 2022.

If you have questions or would like more information, please contact Christine Andrews at [email protected]

MEETING INFO
Want to Stay Connect
with the City of Brentwood?
Subscribe to Receive Our
Newsletter and Other City
News

SUBSCRIBE
Concerts in the Park Returns June 17
6/17: Club 90 (90's jams
and beyond)
6/24: Big City Swing
Committee (Swing, jazz,
and blues)
Concerts in the Park Series
will make its return on Friday
June 17, 2022. Bring the whole
family for a free evening of
music, dancing, and fun.

VIEW FULL
LINEUP
DRAFT c
ur Online Calenda
pcoming Eve
eetings
m work
draft
p is an op ity
to provide fee ack o
ating budget outlines fundin
provided by the City, including po clu
public works; economic develop d
community enrichment; engineer nity enrichment; eng nric g; general administrative ser a
ties; and the collection an th
dget also specifies fund g nee
c initiatives included in the
Plan. Any changes resultin
orated into the final b
for consideration at RA
Operating Budget p g
you have questio
ontact Christine An
onnect
wood?
e to Receive Our
sletter and Other DR
brentwoodca.gov cityofbrentwood brentwoodca.gov

FOLLOW BPD ON

FACEBOOK
page 3 of 7
Brentwood Police Dispatchers Honored During Telecommunicators Week Although they are rarely seen by the
public, police dispatchers serve as the
first line of communication for both
police and emergency services. They
are responsible for gathering vital
information from callers to help first
responders form an early
understanding of what they will face
when they arrive at the site of an
emergency call.

They are essential to public safety and
act as the lifeline for officers and citizens during dangerous incidents and encounters. They take calls from citizens, relay information to and from officers and record calls for service among other important functions.

Skills in multitasking, teamwork, communication and decision-making — essential to the position — make dispatchers invaluable members of the community.

The Brentwood Police Department
has 11 outstanding dispatchers who
serve their city day in and day out.

Today and every day, the City and its
citizens thank them for their
commitment to the community and
its officers.

Since the Brentwood Dispatch Center
opened in March of 2017, dispatchers
have taken more than 431,772 calls for
service, and 81,333 of those were 911
DRAFT
calls.

AFTng Telecommunicator g Telecommunicators W g Te ee
Although they are rarely seen Although they are rarely seen are public, police dispatchers ser
first line of first line of communicatio first line o
police and emerge
e resp
mation from ation
responders sponders
understandin understa und ndin
when the h
emer
The
or officers and citizens during d
itizens, relay information to and
tant functions.
teamwo
— make dispatchers inv DR
brentwoodca.gov cityofbrentwood brentwoodca.gov
page 4 of 7
The City of Brentwood is enrolled in the
new federal Low Income Household Water
Assistance Program (LIHWAP) which will
provide financial assistance to low-income
Californians to help manage their
residential water and/or wastewater utility
costs. LIHWAP offers a one-time payment
to help pay past-due drinking water and
wastewater bills.

The program is administered by the
California State Department of Community
Assistance with Water/Sewer Bills Available for Low Income Households Services and Development (CSD). Eligible households need to apply in order to receive assistance. Eligibility varies depending on income, household size, place of residence, and other factors. To see if you are eligible, please visit Low Income Water Assistance Program on the CSD website.

LIHWAP is scheduled to be available for households to apply in May 2022. To be notified via email when LIHWAP launches, sign up on the California Department of Community Services and Development website.

If you are behind on your energy bills, CSD also administers the Low Income Home Energy Assistance Program.

Yokut Park Soon to Get Its Own Book Box
In 2019, the Parks and Recreation Commission approved and installed book boxes in three Brentwood parks. The boxes allow the public to borrow, keep, or add to the collections. A fourth will soon go up in Yokut Park. Book boxes are now in Creekside, Monarch and Orchard Parks.

Creekside Park
1010 Claremont Dr
Monarch Park
760 Bella Drive
Orchard Park
40 Griffith Lane
“We read to know that we are not alone.” — C.S. Lewis
“The more that you read, the more things you will know. The more you learn, the more places you’ll go!” — Dr. Seuss

DRAFTHW
tance
help
and/or
P offers a on
past-due drinkin
ter b
program is administered
ifornia State Department of Comm
eholds need to ap
e, household siz AFw Income W
or households to apply in M
on the A
California Department p
D also administers the
okut Park Soon to Get
ks a
ekside Park ks de Park
remont Dr em

LEARN MORE
The East Contra Costa Historical Museum will
re-open to the public on May 7, 2022 at 2 p.m.

The Museum will be open from 2 p.m. - 4 p.m.
every Saturday and 3rd Sunday 2 p.m. - 4 p.m.
thru October 2022.

Re-opening of East Contra Costa
Historical Museum
brentwoodca.gov cityofbrentwood brentwoodca.gov

VIEW MAP
page 5 of 7
Harvest Time in Brentwood farms are now open for the 2022 u-pick season. Early cherry varieties are available for u-pick or pre-pick. Did you know that Brentwood offers over 20 varieties of locally grown cherries? We hope residents can enjoy this year's crop by visiting our local farms or farm stands. Beat the crowds and take advantage of the farm's weekday u-pick
hours! Harvest Time in Brentwood provides an interactive online map for easy navigation.

Brentwood Farms Open for U-Pick
The City recently went live with a
new website, enhancing the digital
front door. Enhancements include
a user-friendly interface; easy
navigation; mobile friendly
features; events and news sections
to keep residents informed about
important information; and an
improved search function, just to
New Website Provides an Improved Intro to the City of Brentwood name a few. We welcome any feedback you may have regarding our website. Please email feedback to [email protected].

DRAFT
Costa Historical Museum will
he pu c on May 7, 2022 at 2 p.m
eum will be open from m will b n f
Saturday and 3rd Sunday 2 rday andund
u Octobe 20
East Contra C
rical Museum
The City recently went live w
bsite, enhancing the
door.
a usernavig
feature
keep r
tant
improved
to the City of Brentw
ou may have regardin
twoodca.g
As businesses compete to
retain top talent, employee
training and development is
more important than ever.

During their careers,
Brentwood employees receive
annual ALICE Training®, which
uses option-based, proactive
survival strategies to prepare
for violent critical incidents.
brentwoodca.gov cityofbrentwood brentwoodca.gov
page 6 of 7 May 2022
Brentwood
Connect 24/7
Helpful Resources
The Brentwood Connect 24/7
mobile app gives residents
and business owners direct
access to City staff, services
and resources that make our
City work.

LEARN MORE

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LEARN MORE
Come One! Come All! The
Brentwood Senior Center is
hosting a free Health &
Resource Fair on Thursday,
May 26 from 1-4 p.m. The fair
Senior Health &
Resource Fair
We Are Hiring
will provide seniors with valuable information about health, wellness, utility savings programs, nutrition, and much, much more.

Accounting Specialist
Dance/Gymnastics Instructor
Information Systems Specialist
Lifeguard
Police Dispatcher II
Recreation Leader III - Front Desk
The training was first introduced in 2019 with a 100-percent completion rate. Once 2022 training is complete, employees will receive the ALICE recommended quarterly training. This is just one of the many benefits offered to Brentwood
employees. To learn more about careers with the City, visit the Career Opportunities page. DRAFT Some Current Opening Includes:

AFT R
usinesses compete to
in top talent, employee
raining and development n
more important than ever.

Duringtheir careers,
Brentwood emplo Brentwood Brent
nnual ALICE Train
ses option-based,
survival strategies
usiness owners direct
pp gives residents
ect 24/7 for violent critica
AFT
cess to City staff, servic
nd resources that make o
MORE
One! C
ntwood
osting a f
Resource Fair Thurs
May 26 from 1-4 p.m. The
o
e A
valuable information about hea ab
ngs pr and
c
will
is jus
brentwoodca.gov cityofbrentwood brentwoodca.gov
page 7 of 7
Registration is still open for the City's free spring
neighborhood clean-up events in May. Clean-up began on
April 30. Other events will be on May 7, May 14, and May 21.

Brentwood residents who have an active garbage account
are invited to participate. Residents can bring up to 2 cubic yards (one pickup truck load or a small utility load) of unwanted household items. These can include – free of
charge – general yard waste, appliances, furniture,
mattresses, metal, computers, TVs and other electronic
waste. In order to participate, residents must register online.

For more information, including calendar dates for the spring Neighborhood Clean-Up
and fall cleanups, go to the Neighborhood Clean-Up Events page of the City website. The page also has a link to a more extensive list of acceptable items.

Brentwood Welcomes New and Coming Soon Businesses
Guadalajara Taqueria (561 1st Street)
Himalayan Salt Cave (8065 Brentwood Blvd Suite 2)
Salt and Fig (225 Oak Street)
Yum Cha Boba & More (380 W. Country Club Drive)
Bonchon Korean Fried Chicken To-Go
Jollibee
Club Pilates
Station 16 Seafood Seafood & Bar
The Cheese Steak Shop
The City of Brentwood Economic Development Department
would like to welcome a few new and coming soon
businesses.

New Businesses:

Coming Soon Businesses:

Business is
If you have questions about how to open a business in Brentwood, please send an email to [email protected]. DRAFTa
ve ga
can br
r a sm
hese can in
waste, appliance
puters, TVs and other
cipate, residents must register
n-Up Events page of the City webs
n, including calendar dates for the
p pg T AFptable ms.
w and Coming Soo RAGuadalajara Taqu
Himalayan Salt
Salt and Fig (225
Yum Cha Boba & Ron Kor
St
T
y of Brentwood Economic D
ike to welcome a few ne
s.
esse
Coming Soon Busin DR
s is
you have questions abou u e question ue ut ho
omicdevelopment@b developm d ve p@br
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Overview of Recent State Legislation and Potential Applicability to the City of Brentwood (Legislation Passed During 2021 and Effective January 1, 2022) Summary of Statewide Housing Legislation
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verview of 2021 Housing Legislation Research and Evaluation Process 'XULQJDEURDGYDULHW\RIKRXVLQJOHJLVODWLRQSDVVHGWKDWFRXOGSRWHQWLDOO\DIIHFWORFDO MXULVGLFWLRQVOLNHWKH&LW\RI%UHQWZRRGDVZHOODVPDQ\RIWKHSXEOLFDQGSULYDWHHQWLWLHVZKR DUHLQYROYHGLQ&DOLIRUQLD¶VKRXVLQJLQGXVWU\7KHILUVWVWHSLQWKHUHVHDUFKSURFHVVZDVWRUHYLHZ LQIRUPDWLRQSXEOLVKHGE\WKH*RYHUQRU¶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¶VIRXUKRXVLQJSULRULWLHVWKHVH SULRULWLHVDUHXVHGDVDIUDPHZRUNWRKHOSDQDO\]HDQGFDWHJRUL]HHDFKELOODVVXPPDUL]HGEHORZ 
x 6WUHDPOLQLQJ±6WUHDPOLQLQJWKHEXLOGLQJRIQHZKRPHV± Legislation to reduce the time that it takes to secure land use approvals and streamline environmental review for infill housing, subject to certain labor provisions depending on the size of development.
x 3URGXFWLRQ±%UHDNLQJGRZQEDUULHUVWREXLOGKRXVLQJHVSHFLDOO\$IIRUGDEOH+RXVLQJ± Legislation to help make housing more affordable by catalyzing the production of Accessory Dwelling Units (ADUs), smaller homes (duplexes), small developments (up to 10 units), student housing and helping to plan and fund more deeply affordable housing developments. x )DLU+RXVLQJ±$GGUHVVLQJV\VWHPLFELDVE\HOHYDWLQJIDLUKRXVLQJSULQFLSOHV± Legislation to help ensure that local governments affirmatively further fair housing (AFFH) and that various components of the housing transaction process, such as appraisals and title reporting, avoid discrimination to protected classes. x $FFRXQWDELOLW\± +ROGLQJORFDOJRYHUQPHQWVDFFRXQWDEOHWRGRWKHLUMRELQFOXGLQJ PDLQWDLQLQJDQGUHSRUWLQJ3ODQQLQJ +RXVLQJ'DWD±
Legislation to require local jurisdictions to facilitate housing production (for example, through the Housing Element process), preserve housing and address other statewide housing goals/needs while providing State agencies with additional oversight, authority and enforcement to hold local governments accountable.
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Exhibit 1
Summary Matrix of Housing Legislation and Applicability to Brentwood – Senate Bills Effective 1/1/22
Bill Information and Applicability to Brentwood
Bill # Sponsor
Streamlining
Production
Affordable Housing
Fair Housing
Planning & Hsg Data
Accountability
Applies
to City?
Bill Title or Summary
Description Overview of Key Bill Provisions
Senate Bills
SB 8 Skinner X X X X X Likely Housing Crisis Act of 2019- Extension/Update
Amends and extends key provisions of the Housing Crisis Act of 2019 (SB 330) until January 1, 2030. Helps expedite affordable and market-rate construction by providing early vested rights, limiting ad hoc fee increases on housing, barring local governments from reducing the number of homes that can be built, and cutting the time it takes to obtain discretionary project approvals. Modifies definition of "housing development project" to include those that involve no discretionary approvals or build a single dwelling unit. Modifies requirements regarding replacement housing, relocation and tenant right to return. Provides that receipt of a density bonus does not constitute a valid basis on which to find a proposed housing development inconsistent, noncompliant, or nonconforming with an applicable plan, program, policy, ordinance, standard, requirement or similar provision Extends the Act’s sunset by five years to January 1, 2034.

SB 9 Atkins X X X Likely Duplex and Lot Splits Allows a homeowner to split their lot and construct a second unit on every property zoned for single-family homes in California or convert their existing single-family home to a duplex, provided certain criteria are met.

SB 290 Skinner X X X Likely Density Bonus Law
Amendents; Student
Housing
Makes several changes to Density Bonus Law. Redefines "total units" to include inclusionary housing units and exclude units added by state or local density bonus in calculating the density bonus and incentives/concessions.

Removes "specific adverse impact on the physical environment" as a basis for denying a concession, incentive, waiver, or deduction of development standard. Expands the types of for-sale moderate-income housing units that can benefit from a density bonus. Allows student housing developments that reserve at least 20 percent of their units for lower-income students to access one incentive or concession under Density Bonus Law and requires jurisdictions to report the number of units for lower-income students in such developments in their annual progress report.

SB 478 Weiner X X Likely Minimum Floor Area Ratio
(FAR)/Lot Coverage
Standards
Prohibits a local agency from imposing a floor area ratio standard that is less than 1.0 on a housing development project that consists of 3 to 7 units, or less than 1.25 on a housing development project that consists of 8 to 10 units.

SB 591 Becker X X LIkely Senior citizens:
intergenerational housing
developments
Allows intergenerational housing development that includes seniors if both requirements are met: a) Affordable to lower income households as specified; b) 80% of the dwelling units are occupied by at least one senior citizen and up to 20% of the dwelling units may be occupied by at least one caregiver or transition age youth.

SB 728 Hertzberg X X Likely Density Bonus Law:
purchase of density bonus
units by nonprofit
Broadens Density Bonus Law to ensure a "qualified nonprofit housing corporation" can purchase for-sale units in an approved housing development project to preserve continued affordability for lower income homeowners.

SB 791 Cortese X X X Likely Establishment of California Surplus Land Unit
Establishes HCD California Surplus Land Unit to provide technical assistance to local agencies and developers to facilitate the development and construction of housing on local surplus land, including the provision of regulations, rules, advice, and support.
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91 Cortese X X X Likely DREstablishment of Calif Establ Surplus Land Unit Surplus La
Density Bonus Law:
purchase of density bonus
units by nonpro un fit
DR
tzberg X X Likely erg X X Likely DRABro
Allows intergene
lower income
up to 20% DRASenior citizens:
intergenerational housing
developments de DRX X LIkely X LIkely
DRAProhibits a local agency from a local ag
project that consists of 3 t consists
units. RA
Minimum Floor Area Ratio um Floor
(FAR)/Lot Coverage R)/Lot Cov
Standards tandardsR
X LikelyRAMakes several changes to Density Bonus Law. Redefin Makes several changes to Density Bonus Law. Redefi exclude units added by state or local density bonus i
Removes "specific adverse impact on the physic
waiver, or deduction of development standard waiver, or deduction can benefit from a density bonus. Allows s n benefit from units for lower-income students to acce s for lower
jurisdictions to report the number of ctions to
report. RA
Density Bonus Law
Amendents; Student
HousingRAF
Allows a homeowner to split their lot and construct a second unit o Allows a homeowner to split their lot and construct a second unit in California or convert their existing single-family home to a du A nd Lot Splits AFT
nd extends key provisions of the Housing Crisis Act of 2019 (SB 330) until January 1, 2 s key provisions of the Housing Crisis A e affordable and market-rate construction by providing early vested rights, limiting ad h market-rate construction by prov sing, barring local governments from reducing the number of homes that can be built, a rnments from reducing the akes to obtain discretionary project approvals. Modifies definition of "housing developm roject approvals. M those that involve no discretionary approvals or build a single dwelling unit. Modifies y approvals or replacement housing, relocation and tenant right to return. Provides that receipt o enant right to constitute a valid basis on which to find a proposed housing development inco constitute a valid basis on which to find a proposed ho nonconforming with an applicable plan, program, policy, ordinance, standa nonconforming with an applicable plan, program, policy, or Extends the Act’s sunset by five years to January 1, 2034. AFT Senate Bi
Overview of Key Bill Provisions ill Pr TF
DRAFT
Exhibit 1
Summary Matrix of Housing Legislation and Applicability to Brentwood – Senate Bills Effective 1/1/22 Bill Information and Applicability to Brentwood
Bill # Sponsor
Streamlining
Production
Affordable Housing
Fair Housing
Planning & Hsg Data
Accountability
Applies
to City?
Bill Title or Summary
Description Overview of Key Bill Provisions
Senate Bills
SB 7 Atkins X X Unlikely Jobs and Economic
Improvement Through
Environmental Leadership
Act
Extends and expands expedited administrative and judicial review process under CEQA to include smaller projects as well as large, multi-benefit housing, clean energy, and manufacturing projects, provided they met certain requirements, including provisions related to labor.

SB 10 Weiner X X Unlikely Housing development: 10
Unit Upzonings
Creates a voluntary process for local governments to streamline the upzoning of parcels by passing an ordinance prior to January 1, 2029 to zone any parcel for up to 10 units in a "transit-rich area" or "urban infill site" without triggering environmental review under CEQA.
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DRAFTnd expands expedited administrative and judicial review process under CEQA to include s expedited administrative and judicial as large, multi-benefit housing, clean energy, and manufacturing projects, provided the enefit housing, clean energy, an uirements, including provisions related to labor. visions related to labor.FT ills Effective
Overview of Key Bill Provisions ill Pr TF
Creates a voluntary process for local governments to streamline the upzoning of pa cal governmen prior to January 1, 2029 to zone any parcel for up to 10 units in a "transit-rich ar arcel for up to triggering environmental review under CEQA. AFT
Exhibit 2
Summary Matrix of Housing Legislation and Applicability to Brentwood – Assembly Bills Effective 1/1/22 Bill Information and Applicability to Brentwood
Bill # Sponsor
Streamlining
Production
Affordable Housing
Fair Housing
Planning & Hsg Data
Accountability
Applies
to City?
Bill Title or Summary
Description Overview of Key Bill Provisions
AB 68 Quirk-Silva X X X Likely Statewide Housing Plans, Annual Reports by HCD
Revises and modernizes the quadrennial Statewide Housing Plan and expands HCD's annual reporting requirements. Authorizes HCD to use data collected by the Homeless Coordinating and Financing Council in compiling the Statewide Housing Plan. Requires HCD to develop and publish an annual report on its website by December 31 each year, which will include specified information on grants awarded by HCD and regarding land use oversight actions taken by HCD against local agencies for housing violations related to the Housing Accountability Act, Housing Crisis Act, affirmatively furthering fair housing (AFFH), SB 35 streamlining, Permanent Supportive Housing streamlining, and Low Barrier Navigation Center streamlining.

AB 215 Chiu X X X Likely Planning and Zoning Law:

Housing Element. Violations
and enforcement
Increases oversight and accountability for cities that are underperforming on housing production, including adding SB 8 to the list of housing laws that the Attorney General (AG) can enforce. Specifies that existing statutes of limitation of three years apply to any action or proceeding brought by the AG or HCD. Requires local agencies to make draft revisions of the housing element available for public comment for 30 days and must consider and incorporate public comments prior to submission to HCD for review. If public comments are received, cities must take at least 10 business days after the 30-day public comment period to consider and incorporate the comments.

Expands AG's authority to independently seek action and grants HCD the ability to hire or appoint other counsel if AG does not pursue action against a local agency that has allegedly violated certain housing laws, inclusive of the HCA, AFFH policies (AB 686), SB 35 Streamlining, Permanent Supportive Housing streamlining (AB 2162) and Low Barrier Navigation Center streamlining(AB 101).

AB 345 Quirk-Silva X X X Likely ADUs: separate conveyance Facilitates ADUs by removing requirement for a local agency to first pass an ordinance allowing the conveyance of an ADU separately from a primary residence before such conveyance occurs and permits an ADU to be sold or conveyed separately from the primary residence to a qualified buyer (low and moderate income households as defined in Health and Safety Code Section 50093) in limited circumstances. Helps qualified non-profits sell ADUs to low and moderate income households in two ways: 1) requires local governments to allow such sales and 2) increases the clarity and efficacy of legal agreements between the homeowners.

AB 491 Ward X X X Likely Same housing access:
affordable and market rate
units
Requires that a mixed-income residential building provide the same access to common entrances, areas and amenities for affordable units as market rate units, and affordable housing units should not be isolated within that building to a specific floor or an area on a specific floor in any residential building with five or more residential dwelling units.

AB 571 Mayes X X Likely Planning and zoning, liimits
fees on affordable housing
per Density Bonus Law
Prohibits a local government from charging affordable housing impact fees, including inclusionary zoning fees, public benefit fees, and in-lieu fees on deed-restricted affordable units that are part of a project eligible for a density bonus under Density Bonus Law.

AB 602 Grayson X X Likely Development Impact Fee
nexus study standards and
procedures
Imposes additional standards and procedures for agencies adopting impact fees. Requires agencies to identify an existing and proposed level of service for public facilities and information supporting the agency's actions in increasing fees and requires agencies to impose fees on a housing development proportionately to the square footage of the development or make findings to use a different methodology that ensures smaller developments are not charged disproportionate fees.

AB 634 Carrillo X X Likely Density Bonus Law:
affordability restriction
Allows a local government to require an affordability period longer than 55 years for units that qualify a developer for a density bonus.
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602 Grayson X Grayso
AB 634 Carrillo X XDRDen
a
Development Impact Develo
nexus study stand nexus stud
procedures DRX Likely
Planning and zoning, liimits
fees on affordable housing
per Density Bonus Law pe
es X X Likely DRAPro
Requires that a m
amenities for a
building to a
dwelling DRASame housing access:
affordable and market rate
units DRX X X Likely
DRAFacilitates ADUs by removing requirement f acilitates ADUs b of an ADU separately from a primary res an ADU sep
conveyed separately from the primar eyed sepa
defined in Health and Safety Code d in Health
to low and moderate income h nd modera
increases the clarity and ef the clarity RA
ADUs: separate conveyance ADUs: sepRLikelyRAFIncreases oversight and accountability for cities that ar SB 8 to the list of housing laws that the Attorney General ( limitation of three years apply to any action or proceeding brou make draft revisions of the housing element available for public c incorporate public comments prior to submission to HCD for rev take at least 10 business days after the 30-day public comm Expands AG's authority to independently seek action a
AG does not pursue action against a local agency tha
HCA, AFFH policies (AB 686), SB 35 Streamlining
Low Barrier Navigatio
RA Law:
t. Violations Violations
ent RAFTodernizes the quadrennial Statewide Housing Plan and expands dernizes the quadrennial Statewide Housing Pla HCD's annual reporting s. Authorizes HCD to use data collected by the Homeless Coordinating HCD to use data collected by the H and Financing g the Statewide Housing Plan. Requires e Housing Plan. Requires HCD to develop HCD to and publish an annual report o mber 31 each year, which will include specified information on grants awarded by which will include specified i HCD se oversight actions taken by HCD against local agencies for housing violations related against local Accountability Act, Housing Crisis Act, affirmatively furthering fair housing (AFFH), S s Act, affirmat Supportive Housing streamlining, and Low Barrier Navigation Center streamlining. d Low Barrier AFTBills Effecti Overview of Key Bill Provisions ill Pr TF
RAF D
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Exhibit 2
Summary Matrix of Housing Legislation and Applicability to Brentwood – Assembly Bills Effective 1/1/22 Bill Information and Applicability to Brentwood
Bill # Sponsor
Streamlining
Production
Affordable Housing
Fair Housing
Planning & Hsg Data
Accountability
Applies
to City?
Bill Title or Summary
Description Overview of Key Bill Provisions
AB 721 Bloom X X X Likely Covenants and restrictions:
limitations for affordable
housing
Generally makes recorded covenants that limit residential development unenforceable against qualifying affordable housing developments and ensures that restrictive covenants do not curtail the type and density of development otherwise permitted by local zoning on a property.

AB 787 Gabriel X X LIkely Planning and Housing
Element: moderate-income
conversions counted toward
Expands existing law that permits jurisdictions to claim credit for up to 25 percent of their RHNA from the conversion of existing housing units to include moderate income households, provided certain criteria are met.

AB 803 Horvath X X Likely Home Revitalization Act,
Housing Density
Removes the ability for local agencies to require setback requirements between units beyond that required by the State Building Code, establish a minimum home size, or require enclosed or covered parking beyond that allowed by Density Bonus Law.

AB 838 Friedman X Likely State Housing Law:
enforcement response to
complaints
Seeks to ensure that tenants can receive timely inspections of their rental unit and explicitly prohibits a local government from placing unreasonable conditions on the inspection of rental housing. Also seeks to ensure other parties are given notice of violations and provides that, if a tenant submits a complaint to a city or county, the local government is required to cite any violations and provide free copies of inspection reports to the individual who submitted a complaint and others who may be impacted. Requires a local government to act as quickly as they would when conducting a final building inspection. Prohibits a local government from refusing to communicate with a tenant in order to avoid complying with the inspection requirements.

AB 1029 Mullin X X X Likely Housing Element: prohousing local policies, preservation
Requires HCD to consider making preservation of affordable housing into a pro-housing policy for purposes of their regulations, which may lead to the revisions in their approach to the pro-housing designation, as the current scoring system does not give credit for the preservation of affordable housing or other measures that keep housing affordable. Requires HCD to establish a pro-housing designation for local jurisdictions and defines “prohousing local policies” to mean policies that facilitate the planning, approval, or construction of housing, Requires that jurisdictions designated pro-housing and have an adopted housing element in substantial compliance according to HCD must be awarded additional points or preference in the scoring of program applications.

AB 1043 Bryan X Likely Housing programs: rental
housing developments,
affordablility levels
Adds a new subset of lower income households called "acutely low Income" households, who earn 15 percent of AMI and whose rents can be no greater than 30 percent of the 15 percent AMI level.

AB 1174 Grayson X X X Likely Reforms to SB 35's
Streamlined Ministerial
Process for Post-Approval
Changes and Permits
Specifies that the "shot clock" for a development or modifications is paused when a project is sued, and clarifies that subsequent permit applications must only meet the objective standards that were in place when the project was initially approved.

AB 1304 Santiago X X Likely Affirmatively further fair
housing (AFFH), Housing
Element, Inventory of
land
Ensures that local governments must affirmatively further fair housing (AFFH) in their jurisdictions. Clarifies enforcement language and makes clear that local governments must analyze racial segregation patterns within their own jurisdiction as well as within the broader region, in addition to historical factors and current policies that contribute to fair housing issues. Strengthens the existing requirement that the housing element sites inventory affirmatively further fair housing by requiring the local government to state how the inventory in fact does this. 9 &E
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Overview of Key Bill Provisions ill Pr TF
es recorded covenants that limit residential development unenforceable against qualifyin recorded covenants that limit residential develo elopments and ensures that restrictive covenants do not curtail the type and density of nts and ensures that restrictive covenant e permitted by local zoning on a property. local zoning on a property. d
pands existing law that permits jurisdictions to claim credit for up to 25 percent of their ermits jurisdictions to cl conversion of existing housing units to include moderate income households, provided units to include m Act, Removes the ability for local agencies to require setback requirements between Removes the ability for local agencies to require setb State Building Code, establish a minimum home size, or require enclosed or State Building Code, establish a minimum home size, or by Density Bonus Law. by Density Bonus
using Law:
cement response to
omplaints
Seeks to ensure that tenants can receive timely inspections of th government from placing unreasonable conditions on the inspe parties are given notice of violations and provides that, if a parties are given notice of violations and provides local government is required to cite any violations and p local government is required to cite any violations and who submitted a complaint and others who may be
they would when conducting a final building inspe
with a tenant in order to avoid complying with with a tenant in orde Likely Housing Element: pro- Likely Housing Elem
housing local policies, sing local p
preservation
Requires HCD to consider making prese HCD
regulations, which may lead to the re ations, wh
scoring system g system does not give cre
housing affordable. Requires affordable
housing local policies” to m ocal policie
that jurisdictions design tions desi
according to HCD m
X Likely Housing programs: rental ely Housing programs: rental housing developments, ho
affordablility levels
Adds a new
AMI and AMI and
rayson X X ayson X X X Likely Reforms to SB 35's X Likely Streamlined Ministerial S
Process for Post-Approv Proc
Changes and Permits Change
S
AB 1304 Santiago S X X Likely Affirmatively furth X X Likely Affirmatively housing (AFFH ousing (AFF
Element, I ment, I
land DRAFT
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Exhibit 2
Summary Matrix of Housing Legislation and Applicability to Brentwood – Assembly Bills Effective 1/1/22 Bill Information and Applicability to Brentwood
Bill # Sponsor
Streamlining
Production
Affordable Housing
Fair Housing
Planning & Hsg Data
Accountability
Applies
to City?
Bill Title or Summary
Description Overview of Key Bill Provisions
AB 1398 Bloom X X X Likely Accelerating By-Right
Rezoning Requirements for
Non-Compliant Housing
Elements
Imposes new zoning and site analysis requirements to encourage housing production and to affirmatively further fair housing. Reduces the allowable time period to one year (from 3.33 years) to complete rezoning of sites to accommodate a jurisdiction’s regional housing need If the jurisdiction does not adopt a housing element that HCD has found to be in substantial compliance within 120 days of its due date and prohibits the housing element from being found in substantial compliance until that rezoning is completed.

AB 1466 McCarty X X Likely Real property, removal of
unenforceable discriminatory
restrictions
Requires a title insurance company involved in any transfer of real property and that provides a deed or other documents to identify whether any of the documents contain unlawfully restrictive covenants and, if found, record a specified modification document with the county recorder. Makes changes to the existing process of recording a restrictive covenant modification, as provided.

AB 1584 OmniBus X X Likely Housing Omnibus,
limitations on covenants for
ADU Zoning
Restricts contractual development controls that mirror AB 721 by declaring unenforceable any covenant, condition and restriction (CC&R) contained within a deed, contract, security instrument or other instrument that prohibits, effectively prohibits or restricts the construction or use of an ADU on a lot zoned for single-family use.

AB 447 Grayson X X Indirect Tax credit (LIHTC)
expansion for at-risk
properties
Revises and updates the list of eligible government assistance programs that count towards the "at risk" designation under the state LIHTC program. Allows the CTCAC to allocate tax credits to a wider range of affordable housing developments that are at risk of losing their affordability requirements and converting to market rate housing.

AB 948 Holden X Indirect Bureau of Real Estate:

Appraisers, disclosures,
demographic information
Contains requirements for disclosures in transactions, required pre-licensing and continuing education, and the addition of clear language in the Fair Employment and Housing Act that discrimination based upon protected classes in the provision of appraisal services is unlawful.

AB 1095 Cooley X X Indirect Equity in state and local
programs for affordable
homeownership
Creates parity between affordable homeownership and rental projects in state funding programs. Clarifies that projects eligible for AHSC funding include owner-occupied housing, in addition to rental housing. Requires the Strategic Growth Council (SGC) to adopt guidelines or selection criteria that include both affordable rental and owner-occupied units and allows SGC to include guidelines or criteria for the award of funds to projects that provide home ownership opportunities for low-income individuals in notices of funding availability released after July 1, 2022.

AB 1297 Holden X Indirect State Infrastructure and
Economic Development
Bank: public and economic
development facilities,
housing
Expands the IBank's financing authority to include financing projects with a housing component when it is required for the operation of an economic or public development facility, and no part of the housing component is financed with tax-exempt bonds. The housing component could include but is not limited to rental housing, employee housing and student housing.
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Bank: public and econom Ban
development facilities develop
housing
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owner-occupied
provide hom
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DRAContains requirements for disclosure ains requir
addition of clear language in the F n of clear
classes in the provision of app in the pro RA
Bureau of Real Estate: eau of Rea
Appraisers, disclosures, sers, disc
demographic information raphic inR
Indirect IndRARevises and updates the list of eligible government designation under the state LIHTC program. All designation under the affordable housing developments that are at fordable housing rate housing. e housing. RA
Tax credit (LIHTC)
expansion for at-risk expan
propertiesR
rect RAFRestricts contractual development controls that mirror AB 721 by and restriction (CC&R) contained within a deed, contract, sec effectively prohibits or restricts the construction or use of effectively prohibits or restricts the construction or u RA Omnibus, tions on covenants for
ADU ZoningRAFRequires a title insurance company involved in any transfer of real property and th involved in an documents to identify whether any of the documents contain unlawfully restrict documents to identify whether any of the documents a specified modification document with the county recorder. Makes change a specified modification document with the county record restrictive covenant modification, as provided. restrictive covenanA inatory AFToning and site analysis requirements to encourage housing production and to affirmativ ning and site analysis requirements to encourag Reduces the allowable time period to one year (from 3.33 years) to complete rezoning es the allowable time period to one year ( odate a jurisdiction’s regional housing need If the jurisdiction does not adopt a housing ction’s regional housing need If the ound to be in substantial compliance within 120 days of its due date and prohibits the h ntial compliance within 120 d eing found in substantial compliance until that rezoning is completed. mpliance until that rez AFTBills Effecti Overview of Key Bill Provisions ill Pr TF
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DŽŶƚŚϬϬ͕ϮϬϮϭ DŽŶƚŚϬϬ͕ϮϬϮϭ February 17, 2022
Summary of 2021 Legislative Session Housing Bills
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,ŽƵƐŝŶŐ
ůĞŵĞŶƚĚĞĂĚůŝŶĞƐ͘^ƉĞĐŝĨŝĐĂůůLJ͕ϮϭϱƉƌŽǀŝĚĞƐƚŚĂƚ
ƚŚĞĨŝƌƐƚĚƌĂĨƚŽĨĂŚŽƵƐŝŶŐĞůĞŵĞŶƚŵƵƐƚďĞŵĂĚĞĂǀĂŝůĂďůĞĨŽƌ ƉƵďůŝĐƌĞǀŝĞǁĂŶĚĐŽŵŵĞŶƚĨŽƌĂƚůĞĂƐƚϯϬĚĂLJƐ͘/ĨĂŶLJƉƵďůŝĐ ĐŽŵŵĞŶƚƐĂƌĞƌĞĐĞŝǀĞĚ͕ƚŚĞůŽĐĂůŐŽǀĞƌŶŵĞŶƚŵƵƐƚƚĂŬĞĂƚ ůĞĂƐƚϭϬďƵƐŝŶĞƐƐĚĂLJƐĂĨƚĞƌƚŚĞϯϬͲĚĂLJƉƵďůŝĐĐŽŵŵĞŶƚƉĞƌŝŽĚ ƚŽĐŽŶƐŝĚĞƌĂŶĚŝŶĐŽƌƉŽƌĂƚĞƚŚĞĐŽŵŵĞŶƚƐ͘dŚŝƐŵƵƐƚďĞĚŽŶĞ ďĞĨŽƌĞƐƵďŵŝƚƚŝŶŐƚŚĞĚƌĂĨƚŚŽƵƐŝŶŐĞůĞŵĞŶƚƚŽ,ĨŽƌ ƌĞǀŝĞǁ͕ŽƚŚĞƌǁŝƐĞ,ǁŝůůŶŽƚƌĞǀŝĞǁƚŚĞĚƌĂĨƚ͘^ƵďƐĞƋƵĞŶƚ ĚƌĂĨƚƐŵƵƐƚďĞƉŽƐƚĞĚĞůĞĐƚƌŽŶŝĐĂůůLJĂŶĚƚŚŽƐĞŝŶƚĞƌĞƐƚĞĚŵƵƐƚ ďĞƉƌŽǀŝĚĞĚŶŽƚŝĐĞĂƚůĞĂƐƚϳĚĂLJƐďĞĨŽƌĞƐƵďŵŝƚƚŝŶŐƚŽ,͘ ĚĚŝƚŝŽŶĂůůLJ͕ϮϭϱĞdžƚĞŶĚƐƚŚĞƚŝŵĞƚŚĂƚ,ŚĂƐƚŽƌĞǀŝĞǁ ƚŚĞĨŝƌƐƚĚƌĂĨƚŽĨƚŚĞŚŽƵƐŝŶŐĞůĞŵĞŶƚƚŽϵϬĚĂLJƐĂŶĚƌĞŝƚĞƌĂƚĞƐ ƚŚĂƚŝƚŚĂƐϲϬĚĂLJƐƚŽƌĞǀŝĞǁĂŶLJƐƵďƐĞƋƵĞŶƚĚƌĂĨƚƐ͘
ϮϭϱĂůƐŽƉƌŽǀŝĚĞƐ,ǁŝƚŚĂƵƚŚŽƌŝƚLJƚŽĐŽŶƚƌĂĐƚǁŝƚŚĂŶ ŝŶĚĞƉĞŶĚĞŶƚĂƚƚŽƌŶĞLJƚŽƐƵĞũƵƌŝƐĚŝĐƚŝŽŶƐŽǀĞƌŚŽƵƐŝŶŐůĂǁ ǀŝŽůĂƚŝŽŶƐǁŚĞƌĞƚŚĞƚƚŽƌŶĞLJ'ĞŶĞƌĂůŚĂƐĚĞĐůŝŶĞĚƚŽďƌŝŶŐ ƐƵŝƚŽƌƌĞƉƌĞƐĞŶƚ,͘>ĂƐƚůLJ͕ŝƚĞdžƚĞŶĚƐƚŚĞƐƚĂƚƵƚĞŽĨ ůŝŵŝƚĂƚŝŽŶƐƚŽƚŚƌĞĞLJĞĂƌƐĨŽƌĂĐƚŝŽŶƐďƌŽƵŐŚƚďLJƚŚĞƚƚŽƌŶĞLJ 'ĞŶĞƌĂůŽƌ,ŽƌƉƵƌƐƵĂŶƚƚŽĂŶŽƚŝĐĞŽĨǀŝŽůĂƚŝŽŶŝƐƐƵĞĚďLJ ,ƌĞŐĂƌĚŝŶŐŚŽƵƐŝŶŐůĂǁƐ͘
ĨĨŝƌŵĂƚŝǀĞůLJ&ƵƌƚŚĞƌŝŶŐ&Ăŝƌ,ŽƵƐŝŶŐ͘dŚĞ&&,ůĞŐŝƐůĂƚŝŽŶ ƉƌŝŵĂƌŝůLJĐŽĚŝĨŝĞƐƌĞƋƵŝƌĞŵĞŶƚƐĂůƌĞĂĚLJŝŵƉŽƐĞĚďLJ,ΖƐ &&,'ƵŝĚĞůŝŶĞƐ͘ϭϯϬϰƌĞƋƵŝƌĞƐůŽĐĂůŐŽǀĞƌŶŵĞŶƚƐƚŽ ĂĚŵŝŶŝƐƚĞƌƚŚĞŝƌƉƌŽŐƌĂŵƐĂŶĚĂĐƚŝǀŝƚŝĞƐƌĞůĂƚŝŶŐƚŽŚŽƵƐŝŶŐŝŶĂ ŵĂŶŶĞƌƚŽĂĨĨŝƌŵĂƚŝǀĞůLJĨƵƌƚŚĞƌĨĂŝƌŚŽƵƐŝŶŐ͘^ŝŵŝůĂƌůLJ͕ϭϯϵϴ ƉƌŽǀŝĚĞƐƚŚĂƚƚŚĞƐŝƚĞŝŶǀĞŶƚŽƌLJĂŶĚĂŶĂůLJƐŝƐĐŽŶƚĂŝŶĞĚŝŶ ŚŽƵƐŝŶŐĞůĞŵĞŶƚƐŵƵƐƚŝŶĐůƵĚĞĚŝƐĐƵƐƐŝŽŶŽĨƚŚĞƌĞůĂƚŝŽŶƐŚŝƉ ďĞƚǁĞĞŶƚŚĞŝĚĞŶƚŝĨŝĞĚƐŝƚĞĂŶĚƚŚĞũƵƌŝƐĚŝĐƚŝŽŶΖƐĚƵƚLJƚŽ ĂĨĨŝƌŵĂƚŝǀĞůLJĨƵƌƚŚĞƌĨĂŝƌŚŽƵƐŝŶŐ͘ϭϯϵϴĂůƐŽƌĞƋƵŝƌĞƐƚŚĂƚ ĂŶLJ&&,ĂŶĂůLJƐŝƐŝĚĞŶƚŝĨLJĂŶĚĞdžĂŵŝŶĞƉĂƚƚĞƌŶƐ͕ƚƌĞŶĚƐ͕ĂƌĞĂƐ͕ ĚŝƐƉĂƌŝƚŝĞƐ͕ĂŶĚŶĞĞĚƐďŽƚŚǁŝƚŚŝŶƚŚĞũƵƌŝƐĚŝĐƚŝŽŶĂŶĚ ƌĞŐŝŽŶĂůůLJ͘ŶLJĂƐƐĞƐƐŵĞŶƚƐƐŚŽƵůĚŝŶĐůƵĚĞůŽĐĂůĂŶĚƌĞŐŝŽŶĂů ŚŝƐƚŽƌŝĐĂůŽƌŝŐŝŶƐĂŶĚĐƵƌƌĞŶƚƉŽůŝĐŝĞƐĂŶĚƉƌĂĐƚŝĐĞƐĨŽƌ ŝĚĞŶƚŝĨŝĞĚĨĂŝƌŚŽƵƐŝŶŐŝƐƐƵĞƐ͘
ZĞnjŽŶŝŶŐ͘/ŶĂĚĚŝƚŝŽŶƚŽƚŚĞ&&,ĐŚĂŶŐĞƐ͕ϭϯϵϴŝŵƉŽƐĞƐ ŶĞǁƌĞnjŽŶŝŶŐƌĞƋƵŝƌĞŵĞŶƚƐŽŶũƵƌŝƐĚŝĐƚŝŽŶƐ͘/ĨĂũƵƌŝƐĚŝĐƚŝŽŶ ĚŽĞƐŶŽƚĂĚŽƉƚĂŚŽƵƐŝŶŐĞůĞŵĞŶƚƚŚĂƚ,ŚĂƐĨŽƵŶĚŝŶ ƐƵďƐƚĂŶƚŝĂůĐŽŵƉůŝĂŶĐĞǁŝƚŚŝŶϭϮϬĚĂLJƐŽĨƚŚĞŚŽƵƐŝŶŐĞůĞŵĞŶƚ ĚƵĞĚĂƚĞ͕ƚŚĞĂŐĞŶĐLJŶŽǁŚĂƐŽŶĞLJĞĂƌĨƌŽŵƚŚĞŚŽƵƐŝŶŐ ĞůĞŵĞŶƚĚƵĞĚĂƚĞƚŽĐŽŵƉůĞƚĞƌĞnjŽŶŝŶŐŽĨƐŝƚĞƐ͘WƌĞǀŝŽƵƐůLJ͕ƚŚĞ ĂŐĞŶĐLJŚĂĚƚŚƌĞĞLJĞĂƌƐĂŶĚϭϮϬĚĂLJƐƌĞŐĂƌĚůĞƐƐŽĨƚŚĞĚĂƚĞƚŚĞ ĞůĞŵĞŶƚǁĂƐĨŽƵŶĚŝŶĐŽŵƉůŝĂŶĐĞ͘/ĨƚŚĞŚŽƵƐŝŶŐĞůĞŵĞŶƚ ƌĞƋƵŝƌĞƐƌĞnjŽŶŝŶŐĂŶĚŝƚŝƐŶŽƚĐŽŵƉůĞƚĞĚǁŝƚŚŝŶŽŶĞLJĞĂƌŽĨ ƚŚĞŚŽƵƐŝŶŐĞůĞŵĞŶƚĚƵĞĚĂƚĞ͕,ŵĂLJƌĞǀŽŬĞĂŶLJĨŝŶĚŝŶŐƐŽĨ ĐŽŵƉůŝĂŶĐĞŝƚŚĂƐƉƌĞǀŝŽƵƐůLJŵĂĚĞ͘WƌŝŽƌƚŽƌĞǀŽŬŝŶŐŝƚƐ ĨŝŶĚŝŶŐƐ͕,ŵƵƐƚŝƐƐƵĞŝŶĐŽŶƐŝƐƚĞŶĐLJĨŝŶĚŝŶŐƐĂŶĚŐŝǀĞƚŚĞ ůŽĐĂůĂŐĞŶĐLJĂŶŽƉƉŽƌƚƵŶŝƚLJƚŽƌĞƐƉŽŶĚ͘&ŝŶĂůůLJ͕ŝĨĂŚŽƵƐŝŶŐ ĞůĞŵĞŶƚŝƐĂĚŽƉƚĞĚŵŽƌĞƚŚĂŶŽŶĞLJĞĂƌĂĨƚĞƌƚŚĞĚƵĞĚĂƚĞ͕ŝƚ ĐĂŶŶŽƚďĞĨŽƵŶĚƚŽďĞŝŶĐŽŵƉůŝĂŶĐĞƵŶƚŝůƚŚĞĂŐĞŶĐLJŚĂƐ ĐŽŵƉůĞƚĞĚĂŶLJƌĞƋƵŝƌĞĚƌĞnjŽŶŝŶŐ͘
ϭϯϵϴĂůƐŽĞůŝŵŝŶĂƚĞƐϰͲLJĞĂƌŚŽƵƐŝŶŐĞůĞŵĞŶƚĐLJĐůĞƐĨŽƌůŽĐĂů ŐŽǀĞƌŶŵĞŶƚƐƚŚĂƚĨĂŝůƚŽĂĚŽƉƚĂŚŽƵƐŝŶŐĞůĞŵĞŶƚǁŝƚŚŝŶϭϮϬ ĚĂLJƐŽĨƚŚĞĚƵĞĚĂƚĞ͘^ƚĂƌƚŝŶŐǁŝƚŚƚŚĞϲƚŚĐLJĐůĞ͕ĂĚŽƉƚŝŽŶŽĨĂ ŚŽƵƐŝŶŐĞůĞŵĞŶƚƚŚĂƚ,ĨŝŶĚƐƚŽďĞŝŶƐƵďƐƚĂŶƚŝĂůĐŽŵƉůŝĂŶĐĞ ǁŝƚŚƐƚĂƚĞůĂǁǁŝůůďĞĚĞĞŵĞĚƚŽƐĂƚŝƐĨLJƚŚĞϰͲLJĞĂƌŚŽƵƐŝŶŐ ĞůĞŵĞŶƚƌĞƋƵŝƌĞŵĞŶƚ͘
ŶŶƵĂůWƌŽŐƌĞƐƐZĞƉŽƌƚƐ͘^ϮϵϬƌĞƋƵŝƌĞƐũƵƌŝƐĚŝĐƚŝŽŶƐƚŽ ŝŶĐůƵĚĞŝŶƚŚĞŝƌĂŶŶƵĂůƌĞƉŽƌƚƐƚŚĞŶƵŵďĞƌŽĨƵŶŝƚƐŝŶĂƐƚƵĚĞŶƚ ŚŽƵƐŝŶŐĚĞǀĞůŽƉŵĞŶƚĨŽƌůŽǁĞƌͲŝŶĐŽŵĞƐƚƵĚĞŶƚƐĨŽƌǁŚŝĐŚĂ ĚĞǀĞůŽƉĞƌǁĂƐŐƌĂŶƚĞĚĂĚĞŶƐŝƚLJďŽŶƵƐ͘^ϵƌĞƋƵŝƌĞƐ
&E
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,QIRUPDWLRQDO6XPPDU\DQG2YHUYLHZRQ1HZ
Appendix 1
Housing Bills Housin
Žƌ
ƵďůŝĐ
ƚĂŬĞĂƚ
ŵŵĞŶƚƉĞƌŝŽĚ
ŚŝƐŵƵƐƚďĞĚŽŶĞ
ĞŶƚƚŽ,ĨŽƌ
ǁƚŚĞĚƌĂĨƚ͘^ƵďƐĞƋƵĞŶƚ ƚŚĞĚƌĂĨƚ͘^Ƶ
ůLJĂŶĚƚŚŽƐĞŝŶƚĞƌĞƐƚĞĚŵƵƐƚ ůLJĂŶĚƚŚŽƐĞŝŶƚĞƌĞƐ
ĂLJƐďĞĨŽƌĞƐƵďŵŝƚƚŝŶŐƚŽ,͘ LJƐďĞĨŽƌĞƐƵďŵŝƚƚŝŶŐƚŽ
ĚƐƚŚĞƚŝŵĞƚŚĂƚ,ŚĂƐƚŽƌĞǀŝĞǁ ĚƐƚŚĞƚŝŵĞƚŚĂƚ,ŚĂƐƚŽ ƵƐŝŶŐĞůĞŵĞŶƚƚŽϵϬĚĂLJƐĂŶĚƌĞŝƚĞƌĂƚĞƐ
ŽƌĞǀŝĞǁĂŶLJƐƵďƐĞƋƵĞŶƚĚƌĂĨƚƐ͘
ƉƌŽǀŝĚĞƐ,ǁŝƚŚĂ ƌŽǀŝĚĞƐ, ƵƚŚŽƌŝƚLJƚŽĐŽŶƚƌĂĐƚǁŝƚŚĂŶ ƵƚŚŽƌŝƚLJƚŽ ĚĞŶƚĂƚƚŽƌŶĞLJƚŽƐƵĞũƵƌŝƐĚŝĐƚŝŽŶƐŽǀĞƌŚŽƵƐŝŶŐůĂǁ ĚĞŶƚĂƚƚŽƌŶĞLJƚŽƐƵĞũƵƌŝƐĚŝĐƚŝŽŶƐŽǀĞƌ ƚŝŽŶƐǁŚĞƌĞƚŚĞƚƚŽƌŶĞLJ'ĞŶĞƌĂůŚĂƐĚĞĐůŝŶĞĚƚŽďƌŝŶ ƚŝŽŶƐǁŚĞƌĞƚŚĞƚƚŽƌŶĞLJ'ĞŶĞƌĂůŚĂƐĚĞĐůŝŶĞ ƵŝƚŽƌƌĞƉƌĞƐĞŶƚ,͘>ĂƐƚůLJ͕ŝƚĞdžƚĞŶĚƐƚŚĞƐƚĂƚƵƚĞŽĨ ƵŝƚŽƌƌĞƉƌĞƐĞŶƚ,͘>ĂƐƚůLJ͕ŝƚĞdžƚĞŶĚƐƚŚĞƐƚĂƚƵƚĞŽ ůŝŵŝƚĂƚŝŽŶƐƚŽƚŚƌĞĞLJĞĂƌƐĨŽƌĂĐƚŝŽŶƐďƌŽƵŐŚƚďLJƚŚĞ
'ĞŶĞƌĂůŽƌ,ŽƌƉƵƌƐƵĂŶƚƚŽĂ 'ĞŶĞƌĂůŽ ŶŽƚŝĐĞŽĨǀŝŽůĂƚ ŶŽƚŝĐĞ ƌĞŐĂƌĚŝŶŐŚŽƵƐŝŶŐůĂǁƐ͘ ƌĞŐĂƌĚŝŶ
ĞůLJ&ƵƌƚŚĞƌŝŶŐ&Ăŝƌ,ŽƵƐŝŶ ĞůLJ&ƵƌƚŚĞƌŝŶŐ&Ăŝƌ,ŽƵƐŝ
ĞƐƌĞƋƵŝƌĞŵĞŶDƚƐĂ
ϭϯϬϰƌĞ
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ŶƚŝĨŝĞĚƐŝƚĞĂŶĚ ŶƚŝĨŝĞĚƐŝƚ ƚŚĞũƵƌŝƐĚŝĐƚŝŽŶΖƐĚƵƚLJƚŽ ŝƐĚŝĐƚŝŽŶΖƐ ĨƵƌƚŚĞƌĨĂŝƌŚŽƵ ĨƵƌƚŚĞƌĨ ƐŝŶŐ͘ϭϯϵϴĂůƐŽƌĞƋƵŝƌĞƐƚŚĂƚ ĂůƐŽƌĞƋƵ ĂŶĂůLJƐŝƐŝĚĞŶƚŝĨLJĂŶĚĞdžĂŵŝŶĞƉĂƚƚĞƌŶƐ͕ƚƌĞŶĚƐ͕ĂƌĞĂƐ͕ ĂŶĂůLJƐŝƐŝĚĞŶƚŝĨLJĂŶĚĞdžĂŵŝŶĞƉĂƚƚĞƌŶƐ͕ƚƌĞŶĚ ƌŝƚŝĞƐ͕ĂŶĚŶĞĞĚƐďŽƚŚǁŝƚŚŝŶƚŚĞũƵƌŝƐĚŝĐƚŝŽŶĂŶĚ
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DŽŶƚŚϬϬ͕ϮϬϮϭ DŽŶƚŚϬϬ͕ϮϬϮϭ February 17, 2022
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o ĚĞǀĞůŽƉŵĞŶƚƉƌŽũĞĐƚƚŚĂƚĐŽŶƐŝƐƚƐŽĨĂ
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DŽŶƚŚϬϬ͕ϮϬϮϭ DŽŶƚŚϬϬ͕ϮϬϮϭ February 17, 2022
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ŽƌƉŽƌĂƚŝŽŶĂƌŝŐŚƚƚŽƌĞƉƵƌĐŚĂƐĞ͖ ŽƌĂƚŝŽŶĂƌŝŐŚƚƚŽƌĞƉƵƌĐŚĂƐĞ͖ ƚLJƐŚĂƌŝŶŐĂŐƌĞĞŵĞŶƚ͕ĂƐƐƚĂƚƵƚŽƌŝůLJĚĞĨŝŶĞĚ͖ ŐƌĞĞŵĞŶƚ͕ĂƐƐƚĂƚƵƚŽƌŝůLJĚĞĨŝŶĞĚ͖ ĨĨŽƌĚĂďŝůŝƚLJƌĞƐƚƌŝĐƚŝŽŶƐ ĨĨŽƌĚĂďŝůŝƚLJƌĞƐƚƌŝĐ ŽŶƚŚĞƐĂůĞĂŶĚĐŽŶǀĞLJĂŶĐĞ ŶƚŚĞƐĂůĞ ŽĨƚŚĞƉƌŽƉĞƌƚLJƚŚĂƚĞŶƐƵƌĞƚŚĞƉƌŽƉĞƌƚLJǁŝůůďĞ ŽĨƚŚĞƉƌŽƉĞƌƚLJƚŚĂƚĞŶƐƵƌĞƚŚĞƉƌŽƉĞƌƚ ƉƌĞƐĞƌǀĞĚĨŽƌůŽǁĞƌͲŝŶĐŽŵĞŚŽƵƐŝŶŐĨŽƌĂƚůĞĂƐ ƉƌĞƐĞƌǀĞĚĨŽƌůŽǁĞƌͲŝŶĐŽŵĞŚŽƵƐŝŶŐĨŽƌĂƚů LJĞĂƌƐ͘
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DŽŶƚŚϬϬ͕ϮϬϮϭ DŽŶƚŚϬϬ͕ϮϬϮϭ February 17, 2022
ĂŶĚ;ϯͿŽƚŚĞƌƉŽůŝĐŝĞƐŝŶƚŚĞĨĞĞƐƚƌƵĐƚƵƌĞ
ĞŶƐƵƌĞƚŚĂƚƐŵĂůůĞƌĚĞǀĞůŽƉŵĞŶƚƐĂƌĞŶŽƚ
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ϲ͘ /ĨƚŚĞũƵƌŝƐĚŝĐƚŝŽŶŝƐĂΗůĂƌŐĞũƵƌŝƐĚŝĐƚŝŽŶ͕ΗŵĞĂŶŝŶŐĂ ĐŽƵŶƚLJǁŝƚŚĂƉŽƉƵůĂƚŝŽŶŽĨĂƚůĞĂƐƚϮϱϬ͕ϬϬϬƉĞŽƉůĞŽƌ
ĂŶLJĐŝƚLJǁŝƚŚŝŶƐƵĐŚĂĐŽƵŶƚLJ͕ƚŚĞĐŝƚLJŽƌĐŽƵŶƚLJŵƵƐƚ
ĂĚŽƉƚĂĐĂƉŝƚĂůŝŵƉƌŽǀĞŵĞŶƚƉůĂŶ͖
ϳ͘ dŚĞƐƚƵĚLJŵƵƐƚďĞĂĚŽƉƚĞĚĂƚĂƉƵďůŝĐŚĞĂƌŝŶŐǁŝƚŚĂƚ ůĞĂƐƚϮϬͲĚĂLJƐΖŶŽƚŝĐĞ͕ĂŶĚƚŚĞůŽĐĂůĂŐĞŶĐLJŵƵƐƚŶŽƚŝĨLJ ĂŶLJŵĞŵďĞƌŽĨƚŚĞƉƵďůŝĐǁŚŽƌĞƋƵĞƐƚĞĚŶŽƚŝĐĞŽĨ
ƚŚĞĚĂƚĞŽĨƚŚĞŚĞĂƌŝŶŐ͖ĂŶĚ
ϴ͘ dŚĞƐƚƵĚLJŵƵƐƚďĞƵƉĚĂƚĞĚĂƚůĞĂƐƚĞǀĞƌLJĞŝŐŚƚ;ϴͿ
LJĞĂƌƐ͕ďĞŐŝŶŶŝŶŐ:ĂŶƵĂƌLJϭ͕ϮϬϮϮ͘
ŶLJŵĞŵďĞƌŽĨƚŚĞƉƵďůŝĐ͕ŝŶĐůƵĚŝŶŐĂŶĂƉƉůŝĐĂŶƚĨŽƌĂŚŽƵƐŝŶŐ ĚĞǀĞůŽƉŵĞŶƚƉƌŽũĞĐƚ͕ŵĂLJƐƵďŵŝƚĞǀŝĚĞŶĐĞƚŚĂƚƚŚĞĐŝƚLJ͕ ĐŽƵŶƚLJ͕ŽƌůŽĐĂůĂŐĞŶĐLJŚĂƐĨĂŝůĞĚƚŽĐŽŵƉůLJǁŝƚŚƚŚĞ
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ŽŶƐŝĚĞƌƚŚĞƚŝŵĞůLJ ŽŶƐŝĚĞƌƚŚĞƚŝŵĞůLJ
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ĞƐƐĂƌLJŝŶůŝŐŚƚŽĨĞǀŝĚĞŶĐĞ
ƚLJ͕ĐŽƵŶƚLJ͕ŽƌƐƉĞĐŝĂůĚŝƐƚƌŝĐƚŵƵƐƚ;ϭͿƌĞƋƵĞƐƚ
ƌƚŽƉƌŽǀŝĚĞƚŽƚĂůĂŵŽƵŶƚŽĨĨĞĞƐĂŶĚĞdžĂĐƚŝŽŶƐ ŵŽƵŶƚŽĨĨĞĞ ĚǁŝƚŚĂƉƌŽũĞĐƚƵƉŽŶƚŚĞŝƐƐƵĂŶĐĞŽĨĂĐĞƌƚŝĨŝĐĂƚĞŽĨ ĚǁŝƚŚĂƉƌŽũĞĐƚƵƉŽŶƚŚĞŝƐƐƵĂŶĐĞŽ ƉĂŶĐLJŽƌƚŚĞĨŝŶĂůŝŶƐƉĞĐƚŝŽŶ͕ǁŚŝĐŚĞǀĞƌŽĐĐƵƌƐůĂƐƚ͕ĂŶ ƉĂŶĐLJŽƌƚŚĞĨŝŶĂůŝŶƐƉĞĐƚŝŽŶ͕ǁŚŝĐŚĞǀĞƌŽĐĐ ͿŝĨƚŚĞĚĞǀĞůŽƉĞƌƉƌŽǀŝĚĞƐƚŚŝƐŝŶĨŽƌŵĂƚŝŽŶ͕ƉŽƐƚƚŚŝƐ ƚŚŝƐŝŶĨŽƌŵĂƚŝŽŶ͕ƉŽƐƚƚŚ ŝŶĨŽƌŵĂƚŝŽŶŽŶŝƚƐǁĞďƐŝƚĞ͘dŚĞŝŶĨŽƌŵĂƚŝŽŶƉŽƐƚĞĚ
ũƵƌŝƐĚŝĐƚŝŽŶΖƐǁĞďƐŝƚĞŵƵƐƚďĞ ũƵƌŝƐĚŝĐƚ ƵƉĚĂƚĞĚĂƚůĞĂƐƚƚǁ ƉĚĂƚĞĚ ƚƚŚĞũƵƌŝƐĚŝĐƚŝŽŶŵĂLJŝŶĐůƵĚ ƚƚŚĞũƵƌŝƐ ĞĂĚŝƐĐůĂŝŵĞƌ ĚŝƐĐů ŶƐŝďůĞĨŽƌƚŚĞĂĐĐƵƌĂĐLJŽĨƚŚĞŝŶĨŽƌŵ ŶƐŝďůĞĨŽƌƚŚĞĂĐĐƵƌĂĐLJŽĨƚŚĞŝŶĨŽ ĞǀĞůŽƉĞƌƐĂƌĞŶŽƚƌĞƋƵŝƌĞĚƚ ĞƋƵŝƌĞĚ
FTǀĞŶƚĂůŽĐĂůĂŐĞŶĐLJĨƌŽŵ ǀĞŶƚĂůŽ
ĚŝĨĨĞƌĞŶƚĨĞĞƐĨŽƌĚŝĨĨĞƌĞŶƚƚLJƉ ĚŝĨĨĞƌĞŶƚĨĞĞƐ
ŽŶĂůůLJ͕ƚŚĞƐĞŶĞǁƐƚƵĚLJƌĞƋƵŝƌĞŵĞŶƚƐ ŽŶĂůůLJ͕ƚŚĞƐĞŶĞǁƐƚƵ ĞĞƐŽƌĐŚĂƌŐĞƐĨŽƌǁĂƚĞƌĂŶĚƐĞǁĞƌƐĞƌǀŝĐĞƐ ƐŽƌĐŚĂƌŐĞƐĨŽƌǁĂƚĞƌĂŶĚ ϲϬϮĚŝƌĞĐƚƐ,ƚŽĐ ϲϬϮĚ ƌĞĂƚĞĂƚĞŵƉůĂƚĞ͕ďLJ:ĂŶƵĂƌLJϭ ďLJ:ĂŶƵĂƌ Ϯϯ͕ƚŚĂƚŵĂLJďĞƵƐĞĚďLJůŽĐĂůũƵƌŝƐĚŝĐƚŝŽŶƐƚŽĚĞƐŝŐŶƚŚ ŝŵƉĂĐƚĨĞĞŶĞdžƵƐƐƚƵĚŝĞƐ͘dŚĞƚĞ ŵƉĂĐƚĨĞĞŶĞdžƵƐƐƚƵĚŝĞƐ͘dŚĞ ŵƉůĂƚĞŵƵƐƚŝŶĐůƵĚĞ ĨŽƌĐĂůĐƵůĂƚŝŶŐƚŚĞĨĞĂƐŝďŝůŝƚLJŽĨŚŽƵƐŝŶŐďĞŝŶŐďƵŝů ĐĂůĐƵůĂƚŝŶŐƚŚĞĨĞĂƐŝďŝůŝ ŐŝǀĞŶĨĞĞůĞǀĞů͘ ĞĞůĞǀĞů͘
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AFŝŵƉŽƐŝƚŝŽŶŽĨĂĨĨŽƌĚĂďůĞŚŽƵ ŝŵƉŽƐŝƚŝŽŶŽĨĂĨĨŽƌĚĂďůĞŚŽ ƐŝŶŐŝŵ ŝŶĐůƵƐŝŽŶĂƌLJnjŽŶŝŶŐĨĞĞƐĂŶĚŝŶͲ ŝŶĐůƵƐŝŽŶĂƌLJnjŽŶŝŶŐĨĞĞƐĂŶĚŝŶ ĚĞǀĞůŽƉŵĞŶƚΖƐĂĨĨŽƌĚĂďůĞƵ ǀĞůŽƉŵĞŶƚΖƐĂĨĨŽƌĚĂďůĞƵ
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DŽŶƚŚϬϬ͕ϮϬϮϭ DŽŶƚŚϬϬ͕ϮϬϮϭ February 17, 2022
ŝƐĚĞĨŝŶĞĚƚŽŝŶĐůƵĚĞďŽƚŚůŽǁͲĂŶĚŵŽĚĞƌĂƚĞͲŝŶĐŽŵĞƵŶŝƚƐ͘ EŽƚŚŝŶŐŝŶϰϵϭƉƌŽŚŝďŝƚƐƚŚĞĚĞǀĞůŽƉŵĞŶƚŽĨĂƐĞƉĂƌĂƚĞ ƐƚƌƵĐƚƵƌĞǁŝƚŚĂůůĂĨĨŽƌĚĂďůĞŚŽƵƐŝŶŐƵŶŝƚƐ͘
ZĞƐƚƌŝĐƚŝǀĞŽǀĞŶĂŶƚƐ͘ƵƌŝŶŐƚŚŝƐƐĞƐƐŝŽŶ͕ƚŚĞ>ĞŐŝƐůĂƚƵƌĞ ĂĚĚƌĞƐƐĞĚƌĞƐƚƌŝĐƚŝǀĞĐŽǀĞŶĂŶƚƐĂƐďĂƌƌŝĞƌƐƚŽƚŚĞĚĞǀĞůŽƉŵĞŶƚ ŽĨŚŽƵƐŝŶŐ͘&ŝƌƐƚ͕ϳϮϭĂůůŽǁƐƚŚĞŽǁŶĞƌŽĨĂƐƚĂƚƵƚŽƌŝůLJ ĚĞĨŝŶĞĚĂĨĨŽƌĚĂďůĞŚŽƵƐŝŶŐĚĞǀĞůŽƉŵĞŶƚƚŽƌĞĐŽƌĚĂƌĞƐƚƌŝĐƚŝǀĞ ĐŽǀĞŶĂŶƚŵŽĚŝĨŝĐĂƚŝŽŶƚŽŵĂŬĞŝŶŽƉĞƌĂďůĞĂƌĞĐŽƌĚĞĚ
ĐŽǀĞŶĂŶƚ͕ĐŽŶĚŝƚŝŽŶ͕ŽƌƌĞƐƚƌŝĐƚŝŽŶƚŚĂƚƌĞƐƚƌŝĐƚƐƚŚĞŶƵŵďĞƌ͕ ƐŝnjĞ͕ŽƌůŽĐĂƚŝŽŶŽĨƚŚĞƌĞƐŝĚĞŶĐĞƐƚŚĂƚŵĂLJďĞďƵŝůƚŽŶĂ ƉƌŽƉĞƌƚLJ͕ŽƌƚŚĂƚƌĞƐƚƌŝĐƚƐƚŚĞŶƵŵďĞƌŽĨƉĞŽƉůĞŽƌĨĂŵŝůŝĞƐ ǁŚŽŵĂLJƌĞƐŝĚĞŽŶƚŚĞƉƌŽƉĞƌƚLJ͘dŽƋƵĂůŝĨLJ͕ƚŚĞŽǁŶĞƌŽĨƚŚĞ ĂĨĨŽƌĚĂďůĞŚŽƵƐŝŶŐĚĞǀĞůŽƉŵĞŶƚŵƵƐƚƐƵďŵŝƚƚŚĞŵŽĚŝĨŝĐĂƚŝŽŶ ĚŽĐƵŵĞŶƚ͕ĂůŽŶŐǁŝƚŚƐƵƉƉŽƌƚŝŶŐĚŽĐƵŵĞŶƚĂƚŝŽŶ͕ƚŽƚŚĞ
ĐŽƵŶƚLJƌĞĐŽƌĚĞƌ͘dŚĞĐŽƵŶƚLJƌĞĐŽƌĚĞƌŵƵƐƚĨŽƌǁĂƌĚƚŚĞ
ĚŽĐƵŵĞŶƚĂƚŝŽŶƚŽƚŚĞĐŽƵŶƚLJĐŽƵŶƐĞůǁŚŽŵƵƐƚŵĂŬĞĂ
ĚĞƚĞƌŵŝŶĂƚŝŽŶǁŚĞƚŚĞƌ͕ĂŵŽŶŐŽƚŚĞƌƚŚŝŶŐƐ͕ƚŚĞŽƌŝŐŝŶĂů ƌĞƐƚƌŝĐƚŝǀĞĐŽǀĞŶĂŶƚĐŽŶƚĂŝŶƐĂŶƵŶůĂǁĨƵůƌĞƐƚƌŝĐƚŝŽŶŝŶ ǀŝŽůĂƚŝŽŶŽĨϳϮϭĂŶĚƚŚĞƉƌŽƉĞƌƚLJƋƵĂůŝĨŝĞƐĂƐĂŶĂĨĨŽƌĚĂďůĞ ŚŽƵƐŝŶŐĚĞǀĞůŽƉŵĞŶƚ͘dŚĞŝŶƚĞŶĚĞĚŝŵƉĂĐƚŽĨϳϮϭŝƐƚŽ ĞŶƐƵƌĞƚŚĂƚƌĞƐƚƌŝĐƚŝǀĞĐŽǀĞŶĂŶƚƐĚŽŶŽƚĐƵƌƚĂŝůƚŚĞƚLJƉĞĂŶĚ ĚĞŶƐŝƚLJŽĨĚĞǀĞůŽƉŵĞŶƚŽƚŚĞƌǁŝƐĞƉĞƌŵŝƚƚĞĚŽŶĂƐŝƚĞďLJƚŚĞ ůŽĐĂůnjŽŶŝŶŐ͘
^ŝŵŝůĂƌůLJ͕ϭϱϴϰŵĂŬĞƐǀŽŝĚĂŶĚƵŶĞŶĨŽƌĐĞĂďůĞĂŶLJ
ĐŽǀĞŶĂŶƚ͕ƌĞƐƚƌŝĐƚŝŽŶ͕ŽƌĐŽŶĚŝƚŝŽŶƚŚĂƚΗĞĨĨĞĐƚŝǀĞůLJƉƌŽŚŝďŝƚƐŽƌ ƵŶƌĞĂƐŽŶĂďůLJƌĞƐƚƌŝĐƚƐΗĐŽŶƐƚƌƵĐƚŝŽŶŽƌƵƐĞŽĨƋƵĂůŝĨLJŝŶŐ ĂĐĐĞƐƐŽƌLJĚǁĞůůŝŶŐƵŶŝƚƐŽƌũƵŶŝŽƌĂĐĐĞƐƐŽƌLJĚǁĞůůŝŶŐƵŶŝƚƐŽŶ ƐŝŶŐůĞͲĨĂŵŝůLJƌĞƐŝĚĞŶƚŝĂůůŽƚƐ͘&ŽƌƚŚĞƉƵƌƉŽƐĞƐŽĨƚŚĞůĂǁ͕ ƌĞĂƐŽŶĂďůĞƌĞƐƚƌŝĐƚŝŽŶƐĂƌĞƚŚŽƐĞƚŚĂƚĚŽŶŽƚƵŶƌĞĂƐŽŶĂďůLJ ŝŶĐƌĞĂƐĞĐŽŶƐƚƌƵĐƚŝŽŶĐŽƐƚƐ͕ĞĨĨĞĐƚŝǀĞůLJƉƌŽŚŝďŝƚĐŽŶƐƚƌƵĐƚŝŽŶ͕ ŽƌĞdžƚŝŶŐƵŝƐŚƚŚĞĂďŝůŝƚLJƚŽŽƚŚĞƌǁŝƐĞĐŽŶƐƚƌƵĐƚ͘hŶůŝŬĞϳϮϭ͕ ϭϱϴϰΖƐƉƌŽǀŝƐŝŽŶƐĂƵƚŽŵĂƚŝĐĂůůLJǀŽŝĚƚŚĞĞĨĨĞĐƚŽĨĂŶLJ ΘZƐƚŚĂƚĐŽŶĨůŝĐƚǁŝƚŚŝƚƐƉƌŽǀŝƐŝŽŶƐ͖ƚŚĞŽǁŶĞƌŽĨƚŚĞ ƉƌŽƉĞƌƚLJŶĞĞĚŶŽƚƚĂŬĞĂŶLJĂĚĚŝƚŝŽŶĂůĂĐƚŝŽŶ͘
tŚŝůĞƐŝŵŝůĂƌƉƌŽǀŝƐŝŽŶƐǁĞƌĞƉĂƐƐĞĚŝŶϮϬϭϵĂŶĚϮϬϮϬƚŚĂƚ ĂŵĞŶĚĞĚŝǀŝůŽĚĞΑΑϰϳϰϬ͕ϰϳϰϭΘϰϳϱϭƚŽƉƌŽŚŝďŝƚƚŚĞƐĞ ƚLJƉĞƐŽĨΘZƐĨƌŽŵďĞŝŶŐŝŵƉŽƐĞĚďLJŚŽŵĞŽǁŶĞƌƐΖ
ĂƐƐŽĐŝĂƚŝŽŶƐĂŶĚĐŽŵŵŽŶŝŶƚĞƌĞƐƚĚĞǀĞůŽƉŵĞŶƚƐ͕ϭϱϴϰ ĂŵĞŶĚƐŝǀŝůŽĚĞΑϳϭϰ͘ϯƚŽǀŽŝĚĂŶLJŽĨƚŚĞƐĞΘZƐ͕
ƌĞŐĂƌĚůĞƐƐŽĨƚŚĞŝƌŽƌŝŐŝŶ͘ϭϱϴϰƐĞƌǀĞƐƚŽƌĞŝŶĨŽƌĐĞ ƉƌĞǀŝŽƵƐůLJĂĚŽƉƚĞĚůĞŐŝƐůĂƚŝŽŶ͘
ŽŶǀĞLJĂŶĐĞŽĨhƐ͘WƌĞǀŝŽƵƐůLJ͕ƚŚĞůĂǁƉĞƌŵŝƚƚĞĚ
ũƵƌŝƐĚŝĐƚŝŽŶƐƚŽĐŚŽŽƐĞƚŽĂůůŽǁƐĞƉĂƌĂƚĞĐŽŶǀĞLJĂŶĐĞŽĨĐĞƌƚĂŝŶ ĂĐĐĞƐƐŽƌLJĚǁĞůůŝŶŐƵŶŝƚƐ;hƐͿďLJĂĚŽƉƚŝŽŶŽĨĂůŽĐĂů ŽƌĚŝŶĂŶĐĞ͘^ϯϰϱƌĞƋƵŝƌĞƐůŽĐĂůĂŐĞŶĐŝĞƐƚŽĂůůŽǁĨŽƌƐĞƉĂƌĂƚĞ ĐŽŶǀĞLJĂŶĐĞŽƌƐĂůĞŽĨƚŚĞƐĞhƐ͘
dŽƐĞƉĂƌĂƚĞůLJĐŽŶǀĞLJĂŶh͕ŝƚŵƵƐƚŵĞĞƚƚŚĞĨŽůůŽǁŝŶŐ ƌĞƋƵŝƌĞŵĞŶƚƐ͗
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ŚŝŶŐƐ͕ƚŚĞŽƌŝŐŝŶĂů ŚŝŶŐƐ͕ƚŚĞ
ĂǁĨƵůƌĞƐƚƌŝĐƚŝŽŶŝŶ ĂǁĨƵůƌĞƐƚƌŝĐƚŝŽŶ
ƉĞƌƚLJƋƵĂůŝĨŝĞƐĂƐĂŶĂĨĨŽƌĚĂďůĞ ĞƌƚLJƋƵĂůŝĨŝĞƐĂƐĂŶĂĨĨ ŶƚĞŶĚĞĚŝŵƉĂĐƚŽĨϳϮϭŝƐƚŽ ĞŶĚĞĚŝŵƉĂĐƚŽĨϳϮϭ ŽǀĞŶĂŶƚƐĚŽŶŽƚĐƵƌƚĂŝůƚŚĞƚLJƉĞĂŶĚ ƐĚŽŶŽƚĐƵƌƚĂŝůƚŚĞƚLJ ĞŶƚŽƚŚĞƌǁŝ ŽƚŚĞƌǁŝƐĞƉĞƌŵŝƚƚĞĚŽŶĂƐŝƚĞďLJƚŚĞ
ϭϱϴϰŵĂŬĞƐǀŽŝĚĂŶĚƵŶĞŶĨŽƌĐĞĂďůĞĂŶLJ ŵĂŬĞƐǀŽŝĚĂŶĚƵŶĞŶĨŽƌĐĞ ĂŶƚ͕ƌĞƐƚƌŝĐƚŝŽŶ͕ŽƌĐŽŶĚŝƚŝŽŶƚŚĂƚΗĞĨĨĞĐƚŝǀĞůLJƉƌŽŚŝďŝƚ ŽŶƚŚĂƚΗĞĨĨĞĐƚŝǀĞ ŶƌĞĂƐŽŶĂďůLJƌĞƐƚƌŝĐƚƐΗĐŽŶƐƚƌƵĐƚŝŽŶŽƌƵƐĞŽĨƋƵĂůŝĨLJŝŶŐ ƌƵĐƚŝŽŶŽƌƵƐĞŽĨƋƵĂůŝĨLJ ĂĐĐĞƐƐŽƌLJĚǁĞůůŝŶŐƵŶŝƚƐŽƌũƵŶŝŽƌĂĐĐĞƐƐŽƌLJĚǁĞůůŝŶŐ
ƐŝŶŐůĞͲĨĂŵŝůLJƌĞƐŝĚĞ ƐŝŶŐůĞͲĨĂ ŶƚŝĂůůŽƚƐ͘&ŽƌƚŚĞƉƵƌƉŽƐĞƐŽĨ Ɖ ĂƐŽŶĂďůĞƌĞƐƚƌŝĐƚŝŽŶƐĂƌĞƚŚŽƐĞƚŚĂƚĚŽŶŽƚ ĂƐŽŶĂďůĞƌĞƐƚƌŝĐƚŝŽŶƐĂƌĞƚŚŽƐĞƚŚĂƚĚ ƐĞĐŽŶƐƚƌƵĐƚŝŽŶĐŽƐƚƐ͕ĞĨĨ ƐĞĐŽŶƐƚƌ
FT
ĞĐƚŝǀĞůLJƉ ĞĐƚŝǀĞůLJ
ŝƐŚƚŚĞĂďŝůŝƚLJƚŽŽƚŚĞƌǁŝƐĞ ĞƌǁŝƐĞ
ǀŝƐŝŽŶƐĂƵƚŽŵĂƚŝĐĂůů
ŽǀŝƐŝŽŶƐ͖ƚŚĞŽǁŶĞƌŽĨ ŽǀŝƐŝŽŶƐ
ŶLJĂĚĚŝƚŝŽŶĂůĂĐƚŝŽŶ͘ ŶLJĂĚĚŝƚŝŽŶĂůĂ
ŝƐŝŽŶƐǁĞƌĞƉĂƐƐĞĚŝŶϮϬϭϵĂŶĚϮϬϮϬƚŚĂƚ ŝŶϮϬϭϵĂ
ŽĚĞΑΑϰϳϰϬ͕ϰϳϰϭΘϰϳϱϭƚŽƉƌŽŚŝďŝƚƚŚĞƐĞ ŽĚĞΑΑϰϳϰϬ͕ϰϳϰϭΘϰϳϱϭƚŽƉƌŽŚ ΘZƐĨƌŽŵďĞŝŶŐŝŵƉŽƐĞĚďLJŚŽŵĞŽǁŶĞƌƐΖ
ƚŝŽŶƐĂŶĚĐŽŵŵŽŶŝŶ ƚŝŽŶƐĂŶĚ ƚĞƌĞƐƚĚĞǀĞůŽƉŵĞŶƚƐ͕ϭϱϴϰ Ɛ͕ϭϱϴϰ ĞŶĚƐŝǀŝůŽĚĞΑϳϭϰ͘ϯƚŽǀŽŝĚĂŶLJŽĨƚŚĞƐĞΘZƐ͕
ƌĞŐĂƌĚůĞƐƐŽĨƚŚĞŝƌŽƌŝŐŝŶ͘ϭϱϴϰƐĞƌǀĞƐƚŽƌĞŝŶĨŽƌĐĞ ƌĞŐĂƌĚůĞƐƐŽĨƚŚĞŝƌŽƌŝŐŝŶ͘ϭ ƉƌĞǀŝŽƵƐůLJĂĚŽƉƚ ǀŝŽƵƐůLJĂĚ ĞĚůĞŐŝƐůĂƚŝŽŶ͘ ĚůĞŐŝƐůĂƚ ŽŶǀĞLJĂŶĐĞŽĨhƐ ĐĞŽĨh ͘WƌĞǀŝŽƵƐůLJ͕ƚŚĞůĂǁ AFũƵƌŝƐĚŝĐƚŝŽŶƐƚŽĐŚŽŽƐĞƚŽĂůůŽǁƐĞƉĂƌĂ ŽĐŚŽŽƐĞƚ ĂĐĐĞƐƐŽƌLJĚǁĞůůŝŶŐƵŶŝƚƐ;hƐ ĂĐĐĞƐƐŽƌLJĚǁĞůůŝŶŐƵŶŝƚƐ; ͿďLJ ŽƌĚŝŶĂŶĐĞ͘ ŽƌĚŝŶĂŶĐĞ ^ϯϰϱƌĞƋƵŝƌĞƐůŽĐĂ ƵŝƌĞƐůŽĐ
ĐŽŶǀĞLJĂŶĐĞŽƌƐĂůĞŽĨƚŚĞƐĞ ŶǀĞLJĂŶĐĞŽƌƐĂůĞŽĨƚŚĞƐĞ
dŽƐĞƉĂƌĂƚĞůLJĐŽŶǀĞ
ƌĞƋƵŝƌĞŵĞŶƚƐ͗
x dŚĞ
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DŽŶƚŚϬϬ͕ϮϬϮϭ DŽŶƚŚϬϬ͕ϮϬϮϭ February 17, 2022
x /ĨƌĞƋƵĞƐƚĞĚďLJĂƵƚŝůŝƚLJƉƌŽǀŝĚŝŶŐƐĞƌǀŝĐĞƚŽƚŚĞ
ƉƌŝŵĂƌLJĚǁĞůůŝŶŐƵŶŝƚ͕ƐĞƉĂƌĂƚĞǁĂƚĞƌ͕ƐĞǁĞƌ͕Žƌ
ĞůĞĐƚƌŝĐĂůĐŽŶŶĞĐƚŝŽŶƚŽƚŚĂƚƵƚŝůŝƚLJĨŽƌƚŚĞh͘
ϯϰϱĂůƐŽƌĞƋƵŝƌĞƐƚŚĂƚĂŶLJƚĞŶĂŶĐLJŝŶĐŽŵŵŽŶĂŐƌĞĞŵĞŶƚ͕ ĂƐŽƵƚůŝŶĞĚĂďŽǀĞ͕ƚŚĂƚŝƐƌĞĐŽƌĚĞĚĂĨƚĞƌĞĐĞŵďĞƌϯϭ͕ϮϬϮϭ͕ ŝŶĐůƵĚĞƚŚĞĨŽůůŽǁŝŶŐ͗
x ĞůŝŶĞĂƚŝŽŶŽĨĂůůĂƌĞĂƐŽĨƚŚĞƉƌŽƉĞƌƚLJƚŚĂƚĂƌĞĨŽƌ ƚŚĞĞdžĐůƵƐŝǀĞƵƐĞŽĨĂĐŽƚĞŶĂŶƚ͖
x ĞůŝŶĞĂƚŝŽŶŽĨĞĂĐŚĐŽƚĞŶĂŶƚΖƐƌĞƐƉŽŶƐŝďŝůŝƚLJĨŽƌƚŚĞ ĐŽƐƚƐŽĨƚĂdžĞƐ͕ŝŶƐƵƌĂŶĐĞ͕ƵƚŝůŝƚŝĞƐ͕ŐĞŶĞƌĂů
ŵĂŝŶƚĞŶĂŶĐĞĂŶĚƌĞƉĂŝƌ͕ŝŵƉƌŽǀĞŵĞŶƚƐ͕ĂŶĚĂŶLJ
ŽƚŚĞƌĐŽƐƚƐ͕ŽďůŝŐĂƚŝŽŶƐ͕ŽƌůŝĂďŝůŝƚŝĞƐĂƐƐŽĐŝĂƚĞĚǁŝƚŚ ƚŚĞƉƌŽƉĞƌƚLJ͖ĂŶĚ
x WƌŽĐĞĚƵƌĞƐĨŽƌƚŚĞƌĞƐŽůƵƚŝŽŶŽĨĚŝƐƉƵƚĞƐĂŵŽŶŐƚŚĞ
ĐŽƚĞŶĂŶƚƐďĞĨŽƌĞůĞŐĂůĂĐƚŝŽŶ͘
dŽƚŚĞĞdžƚĞŶƚƚŚĂƚũƵƌŝƐĚŝĐƚŝŽŶƐŚĂǀĞĂĚŽƉƚĞĚůŽĐĂůƉŽůŝĐŝĞƐ ƌĞŐĂƌĚŝŶŐƚŚĞƐĞƉĂƌĂƚĞĐŽŶǀĞLJĂŶĐĞŽƌƐĂůĞŽĨƚŚĞƐĞƚLJƉĞƐŽĨ hƐ͕ϯϰϱǁŽƵůĚŽǀĞƌƌŝĚĞĂŶLJĐŽŶĨůŝĐƚŝŶŐƉƌŽǀŝƐŝŽŶƐ͘ ^ƚĂƌƚĞƌ,ŽŵĞĞǀĞůŽƉŵĞŶƚ͘ϴϬϯ͕Žƌ^ƚĂƌƚĞƌ,ŽŵĞ
ZĞǀŝƚĂůŝnjĂƚŝŽŶĐƚ͕ƐĞĞŬƐƚŽŵĂŬĞŝƚĞĂƐŝĞƌƚŽĚĞǀĞůŽƉƐŵĂůůĞƌ͕ ŵŽƌĞĂĨĨŽƌĚĂďůĞŚŽŵĞƐƚŽŝŶĐƌĞĂƐĞŚŽŵĞŽǁŶĞƌƐŚŝƉ͘ϴϬϯ ĞůŝŵŝŶĂƚĞƐŵŝŶŝŵƵŵůŽƚƐŝnjĞƐƚŽĞŶĐŽƵƌĂŐĞnjĞƌŽůŽƚůŝŶĞ ĚĞƚĂĐŚĞĚŚŽŵĞƐĂŶĚƌĞƋƵŝƌĞƐĂƉƉƌŽǀĂůŽĨƉƌŽũĞĐƚƐƚŚĂƚ
ƉƌŽƉŽƐĞƚŚĞƐĞƚLJƉĞƐŽĨŚŽŵĞƐĂŶĚŵĞĞƚĐĞƌƚĂŝŶŽƚŚĞƌĐƌŝƚĞƌŝĂ͘ dŚĞƉƌŽƉŽƐĞĚĚĞǀĞůŽƉŵĞŶƚŵƵƐƚ͕ĂŵŽŶŐŽƚŚĞƌƌĞƋƵŝƌĞŵĞŶƚƐ͕ ŵĞĞƚƚŚĞĨŽůůŽǁŝŶŐƌĞƋƵŝƌĞŵĞŶƚƐ͗
x dŚĞƐŝƚĞƚŽďĞĚĞǀĞůŽƉĞĚŵƵƐƚďĞŝŶĂŵƵůƚŝĨĂŵŝůLJ
ƌĞƐŝĚĞŶƚŝĂůnjŽŶĞ͕ƐƵďƐƚĂŶƚŝĂůůLJƐƵƌƌŽƵŶĚĞĚďLJƋƵĂůŝĨŝĞĚ ƵƌďĂŶƵƐĞƐ͕ĂŶĚĂƚůĞĂƐƚĨŝǀĞĂĐƌĞƐŝŶƐŝnjĞ͖
x dŚĞƉƌŽũĞĐƚŵƵƐƚƉƌŽƉŽƐĞƚŽĚĞǀĞůŽƉƐŝŶŐůĞͲĨĂŵŝůLJ
ŚŽŵĞƐŽŶĨĞĞƐŝŵƉůĞŽǁŶĞƌƐŚŝƉůŽƚƐ͖
x dŚĞƉƌŽũĞĐƚŵƵƐƚĐŽŵƉůLJǁŝƚŚĞdžŝƐƚŝŶŐĚĞŶƐŝƚLJ͕ŚĞŝŐŚƚ ƌĞƋƵŝƌĞŵĞŶƚƐĂŶĚƐĞƚďĂĐŬƐŝŶƌĞůĂƚŝŽŶƚŽŽƚŚĞƌƐŝƚĞƐ͖
x dŚĞƉƌŽƉŽƐĞĚĚĞǀĞůŽƉŵĞŶƚŵƵƐƚďĞǁŝƚŚŝŶƚŚĞ
ďŽƵŶĚĂƌŝĞƐŽĨĂũƵƌŝƐĚŝĐƚŝŽŶƚŚĂƚŚĂƐĂĚŽƉƚĞĚĂ
ĐŽŵƉůŝĂŶƚŚŽƵƐŝŶŐĞůĞŵĞŶƚ͘
ůŽĐĂůĂŐĞŶĐLJŶĞĞĚŶŽƚŵŝŶŝƐƚĞƌŝĂůůLJĂƉƉƌŽǀĞƉƌŽũĞĐƚƐƚŚĂƚ ŵĞĞƚĂůůƚŚĞĐƌŝƚĞƌŝĂŝŶϴϬϯ͕ďƵƚŝƚŵƵƐƚĂƉƉƌŽǀĞƚŚĞ ĂƉƉůŝĐĂƚŝŽŶƐŽůŽŶŐĂƐƚŚĞĚĞǀĞůŽƉŵĞŶƚĐŽŵƉůŝĞƐǁŝƚŚŶŽŶͲ ĐŽŶĨůŝĐƚŝŶŐůŽĐĂůƐƚĂŶĚĂƌĚƐĂŶĚǁŽƵůĚŶŽƚŚĂǀĞĂƐƉĞĐŝĨŝĐ͕ ĂĚǀĞƌƐĞŝŵƉĂĐƚŽŶƉƵďůŝĐŚĞĂůƚŚĂŶĚƐĂĨĞƚLJƚŚĂƚĐĂŶŶŽƚďĞ ƐĂƚŝƐĨĂĐƚŽƌŝůLJŵŝƚŝŐĂƚĞĚ͘ůŽĐĂůĂŐĞŶĐLJŵĂLJŝŵƉŽƐĞĐŽŶĚŝƚŝŽŶƐ ŶŽƚŝŶĐŽŶĨůŝĐƚǁŝƚŚƚŚĞůĂǁ͕ĞdžĐĞƉƚƚŚĂƚŝƚ͗
x DĂLJŶŽƚŝŵƉŽƐĞƐĞƚďĂĐŬƌĞƋƵŝƌĞŵĞŶƚƐďĞƚǁĞĞŶ
ďƵŝůĚŝŶŐƐ͕ĞdžĐĞƉƚĂƐƌĞƋƵŝƌĞĚďLJƚŚĞƐƚĂƚĞƵŝůĚŝŶŐ
ŽĚĞ͖
x DĂLJŶŽƚŝŵƉŽƐĞĂŵŝŶŝŵƵŵůŽƚƐŝnjĞ͖
x DĂLJŶŽƚƌĞƋƵŝƌĞĐŽǀĞƌĞĚŽƌĞŶĐůŽƐĞĚƉĂƌŬŝŶŐ͖ĂŶĚ
x DĂLJŶŽƚƌĞƋƵŝƌĞƚŚĞĨŽƌŵĂƚŝŽŶŽĨĂŚŽŵĞŽǁŶĞƌΖƐ
ĂƐƐŽĐŝĂƚŝŽŶ͘
dŚĞƵƚŝůŝƚLJŽĨϴϬϯŝƐůŝŬĞůLJƚŽďĞůŝŵŝƚĞĚŐŝǀĞŶŝƚƐŶĂƌƌŽǁ ĂƉƉůŝĐĂƚŝŽŶĂŶĚƐƚƌŝĐƚĐƌŝƚĞƌŝĂ͘

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ĞŶƐƵƌŝŶŐƐĂĨĞĂŶĚŚĂďŝƚĂďůĞŚŽƵƐŝŶŐĨŽƌƚĞŶĂŶƚƐ͕ϴϯϴ ŝŵƉŽƐĞƐŽŶĐŝƚŝĞƐĂŶĚĐŽƵŶƚŝĞƐŶĞǁƌƵůĞƐĨŽƌƚŚĞĞŶĨŽƌĐĞŵĞŶƚ ŽĨĐŽŵƉůĂŝŶƚƐŽĨƐƵďƐƚĂŶĚĂƌĚďƵŝůĚŝŶŐĐŽŶĚŝƚŝŽŶƐŽƌůĞĂĚ ŚĂnjĂƌĚǀŝŽůĂƚŝŽŶƐ͘&ŝƌƐƚ͕ϴϯϴƌĞƋƵŝƌĞƐƚŚĂƚůŽĐĂůĂŐĞŶĐŝĞƐ ŝŶƐƉĞĐƚƚŚĞƉƌŽƉĞƌƚLJŝŶƋƵĞƐƚŝŽŶĂƐƉƌŽŵƉƚůLJĂĨƚĞƌƌĞĐĞŝƉƚŽĨĂ ĐŽŵƉůĂŝŶƚĂƐƚŚĞLJǁŽƵůĚĂƌĞƋƵĞƐƚĨŽƌĨŝŶĂůŝŶƐƉĞĐƚŝŽŶ͘ &E
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ŽƉƚĞĚůŽĐĂůƉŽůŝĐŝĞƐ ŽƉƚĞĚůŽĐĂ
ŽƌƐĂůĞŽĨƚŚĞƐĞƚLJƉĞƐŽĨ ŽƌƐĂůĞŽĨƚŚĞƐĞƚLJ
ŶLJĐŽŶĨůŝĐƚŝŶŐƉƌŽǀŝƐŝŽŶƐ͘ ŶLJĐŽŶĨůŝĐƚŝŶŐƉƌŽǀŝƐŝŽŶ
ŵĞŶƚ͘ϴϬϯ ŵĞŶƚ͘ ͕Žƌ^ƚĂƌƚĞƌ,ŽŵĞ Ğƌ,Žŵ R
ĞŬƐƚŽŵĂŬĞ ƚŽŵĂŬĞŝƚĞĂƐŝĞƌƚŽĚĞǀĞůŽƉƐŵĂůůĞƌ͕
ŚŽŵĞƐƚŽŝŶĐƌĞĂƐĞŚŽŵĞŽǁŶĞƌƐŚŝƉ͘ϴϬϯ
ŝŶŝŵƵŵůŽƚƐŝnjĞƐƚŽĞŶĐŽƵƌĂŐĞnjĞƌŽůŽƚůŝŶĞ ĞŶĐŽƵƌĂŐĞnj ŚŽŵĞƐĂŶĚƌĞƋƵŝƌĞƐ ŚŽŵĞƐĂŶĚƌĞƋƵŝƌĞ ĂƉƉƌŽǀĂůŽĨƉƌŽũĞĐƚƐƚŚĂƚ ŽǀĂůŽĨƉƌŽ ŽƐĞƚŚĞƐĞƚLJƉĞƐŽĨŚŽŵĞƐĂŶĚ ŽƐĞƚŚĞƐĞƚLJƉĞƐŽĨŚŽŵĞƐĂŶ ŵĞĞƚĐĞƌƚĂŝŶŽƚŚĞƌĐƌŝƚĞ ƚĐĞƌƚĂŝŶ dŚĞƉƌŽƉŽƐĞĚĚĞǀĞůŽƉŵĞŶƚŵƵƐƚ͕ĂŵŽŶŐŽƚŚĞƌƌĞƋƵ
ŵĞĞƚƚŚĞĨŽůůŽǁŝŶŐƌĞƋƵŝƌĞŵĞŶƚƐ͗
x dŚĞƐŝƚĞƚŽďĞĚĞǀĞůŽƉĞĚŵƵƐƚďĞŝŶ dŚĞƐŝƚĞƚŽďĞĚĞǀĞůŽƉĞĚŵƵƐ ƌĞƐŝĚĞŶƚŝĂůnjŽŶĞ͕ƐƵďƐƚĂŶƚŝĂůůLJƐƵ ĂůůLJ
ƵƌďĂŶƵƐĞƐ͕ĂŶĚĂƚůĞĂƐƚĨŝǀĞ ƚĨŝǀĞ
FTŽƉŽƐĞƚŽĚĞǀĞůŽƉƐŝŶŐůĞ Ž
ŵƉůĞŽǁŶĞƌƐŚŝƉůŽƚƐ͖ ŵƉůĞŽǁŶĞƌƐŚ
ŵƵƐƚĐŽŵƉůLJǁŝƚŚĞdžŝƐƚŝŶŐĚĞŶƐŝƚLJ͕ŚĞŝŐ ŵƵƐƚĐŽŵƉůLJǁŝƚŚĞdžŝƐ ŵĞŶƚƐĂŶĚƐĞƚďĂĐŬƐŝ ŶƚƐĂŶĚ ŶƌĞůĂƚŝŽŶƚŽŽƚŚĞƌƐŝƚĞƐ͖ ŶƌĞůĂƚŝŽŶ ƉƌŽƉŽƐĞĚĚĞǀĞůŽƉŵĞŶƚŵƵƐƚďĞǁŝƚŚŝŶƚŚĞ ƉƌŽƉŽƐĞĚĚĞǀĞůŽƉŵĞŶƚŵƵƐƚďĞǁŝƚŚ ŽƵŶĚĂƌŝĞƐŽĨĂũƵƌŝƐĚŝĐƚŝŽŶƚŚĂƚŚĂƐĂĚŽƉƚĞĚĂ ŽƵŶĚĂƌŝĞƐŽĨĂũƵƌŝƐĚŝĐƚŝŽŶƚŚĂƚŚĂƐĂĚŽƉƚĞĚ ĐŽŵƉůŝĂŶƚŚŽƵƐŝŶŐĞůĞŵĞŶƚ͘ ĐŽŵƉů
ůŽĐĂůĂŐĞŶĐLJŶĞĞĚŶŽƚŵŝŶŝƐƚĞƌŝĂůůLJĂƉƉƌŽǀĞƉƌŽũĞĐƚ ůŽĐĂůĂŐĞŶĐLJŶĞĞĚŶŽƚŵŝŶŝƐƚ ŵĞĞƚĂůůƚŚĞĐƌŝƚĞƌŝĂŝŶ ĞƚĂůůƚŚĞĐƌŝƚĞƌŝĂŝŶϴϬϯ͕ďƵƚŝƚŵƵƐƚĂƉƉƌŽǀ ϴ ĂƉƉůŝĐĂƚŝŽŶƐŽůŽŶŐĂƐƚŚĞĚĞǀ ƚŝŽŶƐŽůŽŶŐĂƐƚ ĞůŽƉŵĞŶƚĐŽŵƉ ĐŽŶĨůŝĐƚŝŶŐůŽĐĂůƐƚĂŶĚĂƌĚƐĂŶ ůŽĐĂůƐƚĂŶ ĚǁŽƵůĚŶŽƚŚ ĂĚǀĞƌƐĞŝŵƉĂĐƚŽŶƉƵďůŝĐŚĞĂůƚŚĂŶĚƐĂ ƚŽŶƉƵďů
ƐĂƚŝƐĨĂĐƚŽƌŝůLJŵŝƚŝŐĂƚĞĚ͘ůŽĐĂ ƐĂƚŝƐĨĂĐƚŽƌŝůLJŵŝƚŝŐĂƚĞĚ͘ůŽ ůĂŐĞ ŶŽƚŝŶĐŽŶĨůŝĐƚǁŝƚŚƚŚĞůĂǁ͕ĞdžĐ ŶŽƚŝŶĐŽŶĨůŝĐƚǁŝƚŚƚŚĞůĂǁ͕Ğdž x DĂLJŶŽƚŝŵƉŽƐĞƐĞ
ďƵŝůĚŝŶŐƐ͕ĞdžĐĞ ƵŝůĚŝŶŐƐ͕ĞdžĐĞ
ŽĚĞ͖
x DĂLJŶŽ
x DĂ
x
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DŽŶƚŚϬϬ͕ϮϬϮϭ DŽŶƚŚϬϬ͕ϮϬϮϭ February 17, 2022
DŽƌĞŽǀĞƌ͕ĂŐĞŶĐŝĞƐĐĂŶŶŽƚŝŵƉŽƐĞƵŶƌĞĂƐŽŶĂďůĞĐŽŶĚŝƚŝŽŶƐ͕ ƐƵĐŚĂƐƚŚĂƚƚŚĞƚĞŶĂŶƚďĞĐƵƌƌĞŶƚŽŶƌĞŶƚŽƌŝŶĐŽŵƉůŝĂŶĐĞ ǁŝƚŚƚŚĞŝƌƌĞŶƚĂůĂŐƌĞĞŵĞŶƚ͕ŽŶƌĞƐƉŽŶĚŝŶŐƚŽƐƵďƐƚĂŶĚĂƌĚ ďƵŝůĚŝŶŐĐŽŵƉůĂŝŶƚƐ͘
hƉŽŶŝŶƐƉĞĐƚŝŽŶ͕ƚŚĞĂŐĞŶĐLJŵƵƐƚĚŽĐƵŵĞŶƚĂŶLJǀŝŽůĂƚŝŽŶƐ ĂŶĚƐƵďƐƚĂŶĚĂƌĚĐŽŶĚŝƚŝŽŶƐ͘dŚĞƌĞĂĨƚĞƌ͕ƚŚĞĂŐĞŶĐLJŵƵƐƚ ŝŶĨŽƌŵƚŚĞŽǁŶĞƌŽĨƚŚĞƉƌŽƉĞƌƚLJŽĨĂŶLJǀŝŽůĂƚŝŽŶƐĂŶĚ ƌĞƋƵŝƌĞĚĐŽƌƌĞĐƚŝǀĞĂĐƚŝŽŶƐĂŶĚƐĐŚĞĚƵůĞĂƚŝŵĞĨŽƌ
ƌĞŝŶƐƉĞĐƚŝŽŶƚŽĞŶƐƵƌĞĐŽŵƉůŝĂŶĐĞǁŝƚŚƚŚĞĐŽƌƌĞĐƚŝǀĞĂĐƚŝŽŶƐ͘ &ŝŶĂůůLJ͕ƚŚĞĐŝƚLJŽƌĐŽƵŶƚLJŵĂLJŶŽƚĐŽůůĞĐƚĂĨĞĞĨƌŽŵƚŚĞ ƉƌŽƉĞƌƚLJŽǁŶĞƌĨŽƌƚŚĞŝŶƐƉĞĐƚŝŽŶŽƌƚŚĞƌĞƉŽƌƚĂŶĚŵƵƐƚ ƉƌŽǀŝĚĞĨƌĞĞ͕ĐĞƌƚŝĨŝĞĚĐŽƉŝĞƐŽĨŝŶƐƉĞĐƚŝŽŶƌĞƉŽƌƚƐĂŶĚĐŝƚĂƚŝŽŶƐ ƚŽĂŶLJǁŚŽƌĞƋƵĞƐƚƐƐƵĐŚĐŽƉŝĞƐ͘
ůŽĐĂůĂŐĞŶĐLJŝƐŶŽƚƌĞƋƵŝƌĞĚƚŽĐŽŶĚƵĐƚĂŶŝŶƐƉĞĐƚŝŽŶǁŚĞƌĞ ;ϭͿƚŚĞĐŽŵƉůĂŝŶƚĚŽĞƐŶŽƚĂůůĞŐĞŽŶĞŽƌŵŽƌĞƐƵďƐƚĂŶĚĂƌĚ ĐŽŶĚŝƚŝŽŶƐ͕Žƌ;ϮͿĂƉƌĞǀŝŽƵƐĐŽŵƉůĂŝŶƚ͕ƐƵďŵŝƚƚĞĚďLJĂƚĞŶĂŶƚ͕ ƌĞƐŝĚĞŶƚ͕ŽƌŽĐĐƵƉĂŶƚĂďŽƵƚƚŚĞƐĂŵĞƉƌŽƉĞƌƚLJ͕ǁĂƐ
ĚĞƚĞƌŵŝŶĞĚƚŽďĞĨƌŝǀŽůŽƵƐŽƌƵŶĨŽƵŶĚĞĚďLJĂŶŝŶƐƉĞĐƚŽƌŝŶƚŚĞ ůĂƐƚϭϴϬĚĂLJƐ͘
/ŶƚĞƌŐĞŶĞƌĂƚŝŽŶĂů,ŽƵƐŝŶŐ͘^ϱϵϭƐĞĞŬƐƚŽĨĂĐŝůŝƚĂƚĞƚŚĞ ĞƐƚĂďůŝƐŚŵĞŶƚŽĨŝŶƚĞƌŐĞŶĞƌĂƚŝŽŶĂůŚŽƵƐŝŶŐƚŽďĞŶĞĨŝƚƐĞŶŝŽƌ ĐŝƚŝnjĞŶƐǁŚŽŶĞĞĚƐƉĞĐŝĂůůŝǀŝŶŐĞŶǀŝƌŽŶŵĞŶƚƐĂŶĚƐĞƌǀŝĐĞƐ͘dŚĞ ŶĞǁůĂǁƉƌŽǀŝĚĞƐƚŚĂƚĂŶŝŶƚĞƌŐĞŶĞƌĂƚŝŽŶĂůŚŽƵƐŝŶŐ
ĚĞǀĞůŽƉŵĞŶƚŵĂLJďĞĞƐƚĂďůŝƐŚĞĚƚŽƉƌŽǀŝĚĞŚŽƵƐŝŶŐƵŶŝƚƐĨŽƌ ƐĞŶŝŽƌĐŝƚŝnjĞŶƐ͕ĐĂƌĞŐŝǀĞƌƐ͕ŽƌƚƌĂŶƐŝƚŝŽŶĂŐĞLJŽƵƚŚŝĨ͕ĂŵŽŶŐ ŽƚŚĞƌƐ͕ƚŚĞĨŽůůŽǁŝŶŐƌĞƋƵŝƌĞŵĞŶƚƐĂƌĞŵĞƚ͗
x ƚůĞĂƐƚϴϬƉĞƌĐĞŶƚŽĨƚŚĞŽĐĐƵƉŝĞĚƵŶŝƚƐĂƌĞŽĐĐƵƉŝĞĚ ďLJĂƚůĞĂƐƚŽŶĞƐĞŶŝŽƌĐŝƚŝnjĞŶ͕ǁŚŝĐŚŝƐĚĞĨŝŶĞĚĂƐĂ
ƉĞƌƐŽŶϱϱLJĞĂƌƐŽĨĂŐĞŽƌŽůĚĞƌ͖
x hƉƚŽϮϬƉĞƌĐĞŶƚŽĨƚŚĞŽĐĐƵƉŝĞĚƵŶŝƚƐĂƌĞŽĐĐƵƉŝĞĚ
ďLJĂƚůĞĂƐƚŽŶĞƐƚĂƚƵƚŽƌŝůLJĚĞĨŝŶĞĚĐĂƌĞŐŝǀĞƌŽƌ
ƚƌĂŶƐŝƚŝŽŶĂŐĞLJŽƵƚŚ͕ĚĞĨŝŶĞĚĂƐĂƉĞƌƐŽŶǁŚŽŝƐϭϴƚŽ ϮϰLJĞĂƌƐŽĨĂŐĞĂŶĚŝƐĞŝƚŚĞƌĂĐƵƌƌĞŶƚŽƌĨŽƌŵĞƌĨŽƐƚĞƌ LJŽƵƚŚŽƌĂĐƵƌƌĞŶƚŽƌĨŽƌŵĞƌŚŽŵĞůĞƐƐLJŽƵƚŚ͖
x dŚĞĚĞǀĞůŽƉŵĞŶƚŝƐĂĨĨŽƌĚĂďůĞƚŽƐƚĂƚƵƚŽƌŝůLJĚĞĨŝŶĞĚ
ůŽǁĞƌͲŝŶĐŽŵĞŚŽƵƐĞŚŽůĚƐ͖ĂŶĚ
x dŚĞΘZƐŽƌǁƌŝƚƚĞŶƉŽůŝĐLJĨŽƌƚŚĞĚĞǀĞůŽƉŵĞŶƚƐĞƚ
ĨŽƌƚŚƚŚĞůŝŵŝƚĂƚŝŽŶƐŽŶŽĐĐƵƉĂŶĐLJ͕ƌĞƐŝĚĞŶĐLJ͕ŽƌƵƐĞ͘
^ϱϵϭŝƐƉĂƌƚŝĐƵůĂƌůLJŝŵƉŽƌƚĂŶƚďĞĐĂƵƐĞŝƚĂůůŽǁƐĚĞǀĞůŽƉĞƌƐ ƚŚĂƚŚĂǀĞĐĞƌƚĂŝŶĨƵŶĚƐŽƌƚĂdžĐƌĞĚŝƚƐĚĞƐŝŐŶĂƚĞĚĨŽƌĂĨĨŽƌĚĂďůĞ ƌĞŶƚĂůŚŽƵƐŝŶŐƚŽĞdžƉĂŶĚŽĐĐƵƉĂŶĐLJƚŽŝŶĐůƵĚĞŶŽƚŽŶůLJƐĞŶŝŽƌ ĐŝƚŝnjĞŶƐ͕ďƵƚĂůƐŽĐĂƌĞŐŝǀĞƌƐĂŶĚƚƌĂŶƐŝƚŝŽŶĂůLJŽƵƚŚ͘ ^ƵƌƉůƵƐ>ĂŶĚhŶŝƚ͘^ϳϵϭĐƌĞĂƚĞƐƚŚĞĂůŝĨŽƌŶŝĂ^ƵƌƉůƵƐ>ĂŶĚ hŶŝƚǁŝƚŚŝŶƚŚĞĞƉĂƌƚŵĞŶƚŽĨ,ŽƵƐŝŶŐĂŶĚŽŵŵƵŶŝƚLJ
ĞǀĞůŽƉŵĞŶƚ͘dŚĞƉƵƌƉŽƐĞŽĨƚŚĞhŶŝƚŝƐƚŽĨĂĐŝůŝƚĂƚĞ
ĚĞǀĞůŽƉŵĞŶƚĂŶĚĐŽŶƐƚƌƵĐƚŝŽŶŽĨƌĞƐŝĚĞŶƚŝĂůŚŽƵƐŝŶŐŽŶůŽĐĂů ƐƵƌƉůƵƐůĂŶĚ͕ǁŚŝĐŚŝƐĚĞĨŝŶĞĚĂƐůĂŶĚĚĞĐůĂƌĞĚƐƵƌƉůƵƐďLJĂ ůŽĐĂůĂŐĞŶĐLJ͕ƉƵƌƐƵĂŶƚƚŽ'Žǀ͘ŽĚĞΑΑϱϰϮϮϬ͕ĞƚƐĞƋ͕͘ŽƌďLJĂ ƐĐŚŽŽůĚŝƐƚƌŝĐƚ͕ƉƵƌƐƵĂŶƚƚŽ
ĚƵĐ͘ŽĚĞΑΑϭϳϰϱϱ͕ĞƚƐĞƋ͘dŚĞ
hŶŝƚŵĂLJĞŶŐĂŐĞŝŶƚŚĞĨŽůůŽǁŝŶŐĂĐƚŝǀŝƚŝĞƐŝŶƚŚĞĨƵƌƚŚĞƌĂŶĐĞ ŽĨŝƚƐƉƵƌƉŽƐĞ͗
x &ĂĐŝůŝƚĂƚĞĂŐƌĞĞŵĞŶƚƐďĞƚǁĞĞŶŚŽƵƐŝŶŐĚĞǀĞůŽƉĞƌƐ
ĂŶĚůŽĐĂůĂŐĞŶĐŝĞƐƐĞĞŬŝŶŐƚŽĚŝƐƉŽƐĞŽĨƐƵƌƉůƵƐůĂŶĚ͖
x WƌŽǀŝĚĞĂĚǀŝĐĞŽƌƚĞĐŚŶŝĐĂůĂƐƐŝƐƚĂŶĐĞĂŶĚƐĞƌǀŝĐĞƐƚŽ ůŽĐĂůĂŐĞŶĐŝĞƐǁŝƚŚƐƵƌƉůƵƐůĂŶĚŽƌĚĞǀĞůŽƉĞƌƐƐĞĞŬŝŶŐ
ƚŽĚĞǀĞůŽƉŚŽƵƐŝŶŐŽŶƚŚĞƐƵƌƉůƵƐůĂŶĚ͖
x ŽůůĂďŽƌĂƚĞǁŝƚŚŽƚŚĞƌƌĞůĞǀĂŶƚƐƚĂƚĞĂŐĞŶĐŝĞƐ͕ƐƵĐŚ
ĂƐƚŚĞĂůŝĨŽƌŶŝĂ,ŽƵƐŝŶŐ&ŝŶĂŶĐĞŐĞŶĐLJŽƌƚŚĞ
ĂůŝĨŽƌŶŝĂdĂdžƌĞĚŝƚůůŽĐĂƚŝŽŶŽŵŵŝƚƚĞĞ͕ƚŽĂƐƐŝƐƚ
ŚŽƵƐŝŶŐĚĞǀĞůŽƉĞƌƐĂŶĚůŽĐĂůĂŐĞŶĐŝĞƐǁŝƚŚŽďƚĂŝŶŝŶŐ
ŐƌĂŶƚƐ͕ůŽĂŶƐ͕ƚĂdžĐƌĞĚŝƚƐ͕ĂŶĚŽƚŚĞƌƚLJƉĞƐŽĨĨŝŶĂŶĐŝŶŐ͖ x ŽůůĞĐƚĂŶĚĐŽŵƉŝůĞĚĂƚĂŽŶŚŽƵƐŝŶŐƉƌŽĚƵĐƚŝŽŶŽŶ
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ƐƉĞĐƚŝŽŶǁŚĞƌĞ
ŽƌĞƐƵďƐƚĂŶĚĂƌĚ
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Brentwood 2023-2031 Housing Element
Appendix D: Glossary of Housing Terms D-1
Glossary of Housing Terms
Appendix D
Brentwood 2023-2031 Housing Element
Appendix D: Glossary of Housing Terms D-2
Appendix D: Glossary of Housing Terms
Above Moderate-Income Household. A household with an annual income usually greater than 120 percent of the area median income adjusted by household size, as determined by a survey of incomes conducted by a city or a county, or in the absence of such a survey, based on the latest available legibility limits established by the U.S. Department of housing and Urban Development (HUD) for the Section 8 housing program.

Accessory Dwelling Unit (ADU). An ADU is a residential unit that provides independent living facilities for one or more persons and includes separate kitchen, sleeping, and bathroom facilities. An ADU may be a part of, attached to, or detached from a single-family, two-family, or multifamily residence and is subordinate to the principal residence. An ADU also includes an efficiency unit, as defined in Section 17958.1 of the Health and Safety Code, and a manufactured home, as defined in Section 18007 of the Health and Safety Code.

Agricultural Housing. Dwellings and/or living quarters for farm laborers, or other types of dwellings determined to be substantially similar to the above by the Director of Community Development.

Affirmatively Furthering Fair Housing (AFFH). Affirmatively Furthering Fair Housing (AFFH) is a legal requirement that federal agencies and federal grantees further the purposes of the Fair Housing Act. AFFH means "taking meaningful actions, in addition to combating discrimination, that overcome patterns of segregation and foster inclusive communities free from barriers that restrict access to opportunity based on protected characteristics. Specifically, affirmatively furthering fair housing means taking meaningful actions that, taken together, address significant disparities in housing needs and in access to opportunity, replacing segregated living patterns with truly integrated and balanced living patterns, transforming racially and ethnically concentrated areas of poverty into areas of opportunity, and fostering and maintaining compliance with civil rights and fair housing laws.

Apartment. An apartment is a multifamily building of three or more individual residential units that is under single ownership. An apartment may have one or more rooms in an apartment house or dwelling occupied, intended, or designated for occupancy by one family for sleeping or living purposes and containing one kitchen.

Area Median Income (AMI). The midpoint of a geographic area’s income distribution, to account for regional differences in cost of living.

Assisted Housing. Generally multi-family rental housing, but sometimes single-family ownership units, whose construction, financing, sales prices, or rents have been subsidized by federal, state, or local housing programs including, but not limited to Federal Section 8 (new construction, substantial rehabilitation, and loan management set-asides), Federal Sections 213, 236, and 202, Federal Sections 221 (d) (3) (below-market interest rate program), Federal Sections 101 (rent supplement assistance), CDBG, FmHA Sections 515, multi-family mortgage revenue bond programs, local redevelopment and in lieu fee programs, and units developed pursuant to local inclusionary housing and density bonus programs.
eater
survey of inc survey o
est available legibi est avai
(HUD) for the Section 8 (HUD) for
es independent living facilities for es independent living faciliti bathroom facilities. An ADU may be a bathroom facilities. An ADU may be family, or multifamily residence and is
es an efficiency unit, as defined in Section
red home, as defined in Section 18007 of the
uarters for farm laborers, or other types of d rm laborers, above by the Director of Community Developme r of Com
(AFFH). Affirmatively Furthering Fair Housing . Affirmatively Furthering Fair Ho nd federal grantees further the purposes of the Fa ral grantees further the purposes of the F ns, in addition to combating discrimination, tha on to combating discrimination, tha ve communities free from barriers that restrict a free from barriers that restrict a cs. Specifically, affirmatively furthering fair hou s. Specifically, affirmatively furthering fair hou ther, address significant disparities in housing ne ther, address significant disparities d living patterns with truly integrated and ba d living patterns with truly integra nically concentrated areas of poverty into are nically concentrated areas of poverty i ompliance with civil rights and fair housing laws ompliance with civil rights and fair housing law ent. An apartment is a multifamily building of apartment is a multifamily building of er single ownership. An apartment may have on rship. An apartment may have on ccupied, intended, or designated for occupan ccupied, intended, or design containing one kitchen. containing one kitch
Area Median Income (AMI) come (A . The midp he mid
regional differences in cost of living. in cost of living.

Assisted Housing Ass . Generally m enera
whose construction, financ whose construction, fina
ousing programs inclu ousing programs incl
bilitation, and lo
(3) (below
HA S
Brentwood 2023-2031 Housing Element
Appendix D: Glossary of Housing Terms D-3
Below-Market-Rate (BMR). Any housing unit specifically priced to be sold or rented to low- or moderateincome households for an amount less than the fair-market value of the unit. Both the State of California and the U.S. Department of Housing and Urban Development set standards for determining which households qualify as “low income” or “moderate income.” The financing of housing at less than prevailing interest rates.

Boarding House. A housing unit used for residential purposes, other than a hotel, where lodging and meals are provided for compensation for five or more non-transient persons, who are not living as a single housekeeping unit. All residents are be counted when determining the number of persons lodging in a boarding house, including managers, landlords, or building superintendents. A Boarding House is considered to be a Multifamily Dwelling.

Build-Out. That level of urban development characterized by full occupancy of all developable sites in accordance with the General Plan; the maximum level of development envisioned by the General Plan.

Build-out does not assume that each parcel is developed to include all floor area or housing units possible under zoning regulations.

Caretaker Residence. Permanent or temporary housing that is secondary or accessory to the primary use of the property. Such dwellings are used for housing a caretaker employed full-time on the site of a nonresidential use where a caretaker is needed for security purposes or to provide 24-hour care or monitoring of facilities, equipment, or other conditions on the site.

Community Care Facility. A 24-hour residential facility maintained and operated to provide nonmedical residential care, day care or homefinding agency services for children, adults, or children and adults, including, but not limited to, the developmentally disabled, physically handicapped, mentally disordered, or incompetent persons, and includes any residential facility, day facility and homefinding agency. A Community Care Facility may be located in any type of residence.

Community Development Block Grant (CDBG). A grant program administered by the U.S. Department of Housing and Urban Development (HUD) on a formula basis for entitled communities and administered by the State Department of Housing and Community Development (HCD) for non-entitled jurisdictions. This grant allots money to cities and counties for housing rehabilitation and community development, including public facilities and economic development.

Condominium. A multi-family building where the units are individually owned, and the common space is owned collectively by condominium unit owners. A condominium structure may have two or more units.

Covenants, Conditions, and Restrictions (CC&Rs). A term used to describe restrictive limitations that may be placed on property and its use, and which usually are made a condition of holding title or lease.

Deed. A legal document which affects the transfer of ownership of real estate from the seller to the buyer.

Density Bonus. The allocation of development rights that allow a parcel to accommodate additional square footage or additional residential units beyond the maximum for which the parcel is zoned, usually in exchange for the provision or preservation of an amenity at the same site or at another location.

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ss than pre ss than
l, where lodging and meals l, where lodgi
who are not living as a single who are not living a
e number of persons lodging in a e number of persons lodgin erintendents. A Boarding House is erintendents. A Boarding House by full occupancy of all developable sites in
of development envisioned by the General Plan f development envisioned ped to include all floor area or housing units poss include all floor area rary housing that is secondary or accessory to the rary housing that is secondary or a for housing a caretaker employed full-time on t or housing a caretaker employed full-t eeded for security purposes or to provide 24-hou for security purposes or to provide 24-ho onditions on the site. on the
24-hour residential facility maintained and ope l facility maintained and ope re or homefinding agency services for children e or homefinding agency service ited to, the developmentally disabled, physically ited to, the developmentally disabl persons, and includes any residential facility, d persons, and includes any residential fa are Facility may be located in any type of residen are Facility may be located in any type of resid nity Development Block Grant (CDBG) velopment Block Grant (CDBG). A grant p ing and Urban Development (HUD) on a formula n Development (HUD) on a formula e State Department of Housing and Community e State Department of Hous grant allots money to cities and counties fo grant allots money to cities an including public facilities and economic dev including public facilities and econom Condominium. A multi-family buildin multi-family buildin owned collectively by condominiu y cond
Covenants, Conditions, and Covenants, Conditions, an
be placed on property an
A legal docum
Brentwood 2023-2031 Housing Element
Appendix D: Glossary of Housing Terms D-4
Density, Residential. The number of permanent residential dwelling units per acre of land. Densities specified in the General Plan may be expressed in units per gross acre or per net developable acre.

Developable Land. Land that is suitable as a location for structures and that can be developed free of hazards to, and without disruption of, or significant impact on, natural resource areas.

Discretionary Action. An action or approval which requires the exercise of judgment or deliberation when the City decides to approve or disapprove a project.

Down Payment. Money paid by a buyer from his own funds, as opposed to that portion of the purchase price which is financed.

Duplex. A building on a single lot containing two dwelling units each of which is totally separated from the other by a shared wall that extends from the foundation to the roof.

Dwelling Unit (DU). One or more habitable rooms that are designed and/or used as independent living quarters for one family, with facilities for living, eating and sleeping, with no more than one kitchen facility consisting of one or more of the following: sink, cooking facility or refrigerator (except that two kitchens are allowed where the habitable floor area of the dwelling is 8,000 square feet or larger), and at least one bathroom, and where all such habitable areas have access to each other from within the building. Any detached structure or portion of a dwelling which has a separate entry and is separate from that dwelling, containing a full bathroom including a water closet, basin, and shower or bathtub or containing a half bathroom including a water closet and basin, the area of which half bathroom exceeds 20 square feet, shall also be considered a dwelling or dwelling unit.

Elderly Housing. Typically, one- and two-bedroom apartments or condominiums designed to meet the needs of persons 62 years of age and older or, if more than 150 units, persons 55 years of age and older, and restricted to occupancy by them.

Emergency Shelter. A facility that provides temporary, short-term housing, with minimal supportive services, for individuals or families experiencing homelessness, provided that no facility is used as temporary, short-term housing by any individual or family for more than 30 consecutive days.

Supplemental services may include food, counseling, and access to other social programs. No individual or household may be denied emergency shelter because of an inability to pay.

Extremely Low-Income Household. A household with an annual income that is less than 30 percent of the area median family income adjusted by household size, as determined by a survey of incomes conducted by a city or a county, or in the absence of such a survey, based on the latest available eligibility limits established by the U.S. Department of Housing and Urban Development (HUD) for the Section 8 housing program.

Fair Market Rent. The rent, including utility allowances, determined by the United States Department of Housing and Urban Development for purposed of administering the Section 8 Program.

Family. The term “Family” is defined by the Brentwood Municipal Code as the functional equivalent of a traditional family, whose members are an interactive group of persons jointly occupying a single dwelling DRAFTeveloped evelope
s.
ment or deliberation when ment or delib
sed to that portion of the purchase sed to that portion of the purch nits each of which is totally separated from
ion to the roof. ion to th
that are designed and/or used as independent designed and/or u ating and sleeping, with no more than one kitche ng, with no nk, cooking facility or refrigerator (except that t nk, cooking facility or refrigera a of the dwelling is 8,000 square feet or larger), a a of the dwelling is 8,000 square feet o ble areas have access to each other from within reas have access to each other from w dwelling which has a separate entry and is separa which has a separate entry and is separa uding a water closet, basin, and shower or bath closet, basin, and shower or b closet and basin, the area of which half bathro the area of which half bathro dwelling or dwelling unit. dwelling or dwelling unit.
ypically, one- and two-bedroom apartments or ypically, one- and two-bedroom apart s 62 years of age and older or, if more than 150 s 62 years of age and older or, if more tha d to occupancy by them.
ency Shelter. A facility that provides tempora
vices, for individuals or families experiencing duals or fam temporary, short-term housing by any indivi emporary, short-term housin Supplemental services may include food, cou Supplemental services may include or household may be denied emergency s or household may be denied emergen Extremely Low-Income Household me Ho
area median family income adjus area median family incom by a city or a county, or in th by a city or a county, or i established by the U.S. De established by the U.S. D
gram.
ket Rent
dU
Brentwood 2023-2031 Housing Element
Appendix D: Glossary of Housing Terms D-5
unit including the joint use of and responsibility for common areas, sharing household activities and responsibilities such as meals, chores, household maintenance, and expenses. If the dwelling unit is rented, this means that all adult residents have chosen to jointly occupy the entire premises of the dwelling unit, under a single written lease for the entire dwelling, with joint use and responsibility of the premises, and the makeup of the household occupying the unit is determined by the residents of the unit rather than by the landlord or property manager.

General Plan. A comprehensive, long-term plan mandated by State Planning Law for the physical development of a city or county and any land outside its boundaries which, in its judgment, bears relation to its planning. The plan shall consist of seven required elements: land use, circulation, open space, conservation, housing, safety, and noise. The plan must include a statement of development policies and a diagram or diagrams illustrating the policies.

Goal. A general, overall, and ultimate purpose, aim, or end toward which the City will direct effort.

Green Building. Green or sustainable building is the practice of creating healthier and more resourceefficient models of construction, renovation, operation, maintenance, and demolition. (U.S.

Environmental Protection Agency)
Historic Preservation. The preservation of historically significant structures and neighborhoods until such time as, and in order to facilitate, restoration and rehabilitation of the building(s) to a former condition.

Historic Property. A historic property is a structure or site that has significant historic, architectural, or cultural value.

Household. All those persons—related or unrelated—who occupy a single housing unit. (See “Family.”) Housing and Community Development Department (HCD). The State agency that has principal responsibility for assessing, planning for, and assisting communities to meet the needs of low- and moderate-income households.

Housing Element. One of the seven State-mandated elements of a local general plan, it assesses the existing and projected housing needs of all economic segments of the community, identifies potential sites adequate to provide the amount and kind of housing needed, and contains adopted goals, policies, and implementation programs for the preservation, improvement, and development of housing. Under State law, Housing Elements must be updated every five years.

Housing Payment. For ownership housing, this is defined as the mortgage payment, property taxes, insurance, and utilities. For rental housing this is defined as rent and utilities.