Brentwood City Council
February 13, 2024

Brentwood 2023-2031 Housing Element
Section 2: Community Profile 2-4
Figure 2-2: Racial and Ethnic Composition
Source: American Community Survey, Table DP05, 5-Year Estimates, 2019.

Table 2-3: Racial/Ethnic Composition
Jurisdiction
White
(NonHispanic)Black
American
Indian and
Alaska Native
Asian
Native
Hawaiian or
Other Pacific
Islander
Some
Other
Race
Two or
More
Races
Hispanic
or Latino
(of any
Race)
Antioch 27.8% 21.5% 0.7% 11.7% 0.9% 15.7% 8.9% 33.2%
Brentwood 52.2% 7.8% 0.5% 10.5% 0.5% 9.5% 7.9% 22.9%
Oakley 41.2% 9.8% 1.0% 6.5% 0.9% 16.4% 8.6% 35.8%
Pittsburg 19.1% 15.4% 0.8% 16.7% 0.6% 21.9% 9.2% 43.4%
Contra Costa
County 43.8% 8.7% 0.5% 16.7% 0.5% 10.9% 6.8% 25.6%
Source: American Community Survey, Table DP05, 5-Year Estimates, 2019.

Table 2-4 shows that between 2010 and 2019 certain racial and ethnic groups experienced significant changes. The Brentwood population that identifies as American Indian/Alaska Native increased by 400 percent from 2010 to 2019. The population that identifies as Asian had the second largest increase (41.9 percent) followed by the population that identifies as Black (39.3 percent). The Hispanic or Latino (of any race) population decreased by 15.2 percent, and the White (Non-Hispanic) population decreased by 5.4 percent.

Table 2-4: Changes in Racial and Ethnic Composition (2010 – 2019) Race/Ethnicity 2010 2015 2019
Change
2010 to
2015
Change
2015 to
2019
Change
2010 to
2019
White (Non-Hispanic) 55.2% 55.5% 52.2% 0.5% -5.9% -5.4% Black 5.6% 5.1% 7.8% -8.9% 52.9% 39.3%
American Indian and
Alaska Native 0.1% 0.1% 0.5% 0.0% 400.0% 400.0%
Asian 7.4% 8.2% 10.5% 10.8% 28.0% 41.9%
Native Hawaiian or Other
Pacific Islander 0.4% 0.2% 0.5% -50.0% 150.0% 25.0%
Some Other Race 0.5% 0.0% 0.2% -100.0% 0.2% -60.0%
Two or More Races 3.9% 5.8% 5.4% 48.7% -6.9% 38.5%
Hispanic or Latino* 27.0% 25.1% 22.9% -7.0% -8.8% -15.2% *Of any race.

Source: American Community Survey, Table DP05, 5-Year Estimates, 2010, 2015, and 2019.

White
(NonHispanic)Black
American
Indian and
Alaska
Native
Asian
Native
Hawaiian
or Other
Pacific
Islander
Some
Other
Race
Two or
More
Races
Hispanic
or Latino
(of any
Race)
Brentwood 52.2% 7.8% 0.5% 10.5% 0.5% 9.5% 7.9% 22.9%
Contra Costa County 43.8% 8.7% 0.5% 16.7% 0.5% 10.9% 6.8% 25.6%

0.0%

10.0%

20.0%

30.0%

40.0%

50.0%

60.0%

Brentwood 2023-2031 Housing Element
Section 2: Community Profile 2-5
B. Economic Characteristics
In addition to demographics and culture, economic characteristics may also indicate different housing needs. Employment and income trends may indicate a need for more housing units at particular affordability levels. Providing a variety of housing units at all affordability levels is critical in ensuring all community members have their needs met.

Reporting and analyzing economic characteristics of a community is an important component of the Housing Element. The data provides valuable insight into the Brentwood community’s ability to access the housing market and to afford housing. Specifically, incomes associated with different employment sectors and the number of workers in a household may affect housing affordability and choice. Local employment growth is also linked to local housing demand, and vice versa. Therefore, to consider a healthy balance between jobs and housing, it is important to consider the employment characteristics of a community.

1. Employment and Wage Scale
Employment can directly affect the housing needs for a city as employment and income provides the ability for a population to purchase housing and may direct the types of housing residents can afford.

Table 2-5 outlines employment growth forecast from 2015 through 2040 for Brentwood and the surrounding jurisdictions. The City of Brentwood is forecasted to experience an employment growth of approximately 51.9 percent (9,915 persons) through 2040, which is greater than the County’s estimated employment growth of 15 percent. In comparison to the surrounding jurisdictions, Brentwood has the largest projected employment change between 2015 to 2040. The figures listed in Table 2-5 outline economic growth in comparison to the forecasted population growth shown in Table 2-1. The City of Brentwood is projected to experience the largest population growth through 2040, with a significantly greater percentage than the other jurisdictions; during this same timeframe, the City’s projected employment growth is estimated to also increase at a greater rate than nearby jurisdictions.

Table 2-5: Employment Growth Trends, 2015-2040
Jurisdiction 2015 2020 2025 2030 2035 2040 Change
2015-2040
Numeric
Change
2015-2040
Antioch 52,475 53,060 53,250 55,185 59,340 61,020 16.3% 8,545 Brentwood 19,115 19,450 19,655 21,345 28,080 29,030 51.9% 9,915 Oakley 16,135 16,120 16,250 21,470 21,420 23,080 43.0% 6,945 Pittsburg 33,770 34,495 34,280 33,660 38,615 39,380 16.6% 5,610 Contra Costa
County 579,075 589,810 617,185 633,830 655,135 665,875 15.0% 86,800 Represents an estimate from the ABAG 2010-2040 Regional Growth Forecast.

Sources: ABAG Plan Bay Area Projections 2040.

Table 2-6 shows employment growth in Brentwood from 2010 to 2019 by industry. Based on the 2019 ACS data, 63.7 percent of Brentwood’s population age 16 and over was employed. Employment in the City increased by 35.3 percent from 2010 to 2019. The Education Services, Health Care, and Social Assistance industry represents the largest percentage of the City’s employment in both 2010 and 2019.

Between 2010 and 2019 most occupations in the City experienced an increase in employment – the Education Services, Health Care, and Social Assistance industry and the Transportation and Warehousing, and Utilities industry experienced the greatest changes.

Brentwood 2023-2031 Housing Element
Section 2: Community Profile 2-6
Table 2-6: Employment by Industry (2019)
Employment Industry
2010 2019 Percent
Change
2010-2019
Amount
Employed
Percent
Employed
Amount
Employed
Percent
Employed
Agriculture, Forestry, Fishing
and Hunting, and Mining 198 0.10% 184 0.6% -7.1%
Construction 1,748 9.00% 2626 9.3% 50.2%
Manufacturing 1,549 8.00% 2160 7.6% 39.4%
Wholesale Trade 629 3.20% 607 2.1% -3.5%
Retail Trade 2,472 12.80% 3017 10.6% 22.0%
Transportation and
Warehousing, and Utilities 872 4.50% 1462 5.2% 67.7%
Information 568 2.90% 702 2.5% 23.6%
Finance and Insurance, and Real
Estate and Rental Leasing 1,585 8.20% 1873 6.6% 18.2%
Professional, Scientific,
Management, and
Administrative Services
2,114 10.90% 3453 12.2% 63.3%
Education Services, Health Care,
and Social Assistance 4,075 21.00% 6920 24.4% 69.8%
Arts, Entertainment, Recreation,
Accommodation, and Food
Services
1,471 7.60% 2409 8.5% 63.8%
Other Services (Except Public
Administration) 1,036 5.30% 1331 4.7% 28.5%
Public Administration 1,068 5.50% 1615 5.7% 51.2%
Total 20,958 100% 28,359 100% 35.3%
Source: American Community Survey, Table DP03, 5-Year Estimates, 2010 and 2019.

In addition to reporting and analyzing employment sector trends, analyzing the unemployment rate is essential to understanding current and projected housing affordability needs. Economists identify a 3.5 to

4.5 percent unemployment rate as natural, as it reflects the real voluntary economic forces within a city.2 Table 2-7 shows the City has an unemployment rate of 4.3 percent, which is greater than the County’s

3.4 percent. Based on this data, approximately 2,039 persons aged 16 years and over were without work in 2019 and may therefore benefit from affordable housing options.

Table 2-7: Unemployment Rate, 2018
Jurisdiction Unemployment Rate
Antioch 5.4%
Brentwood 4.3%
Oakley 2.6%
Pittsburg 5.5%
Contra Costa County 3.4%
*Population 16 years and over
Source: American Community Survey, Table DP03, 5-Year Estimates, 2019.

For those employed, income level can further identify housing types that may be needed. According to the ABAG Regional Housing Needs Assessment (RHNA) Methodology, housing needs by income are broken down into four income levels based on the Area Median Income (AMI):
 Very Low-Income (50 percent or less of the AMI)
2 Natural Rate of Unemployment, Its Components, and Recent Trends, Kimberly Amadeo, ed. Eric Estevez, August 30, 2020.

Brentwood 2023-2031 Housing Element
Section 2: Community Profile 2-7
 Low-Income (50 to 80 percent of the AMI)
 Moderate-Income (80 to 120 percent of the AMI)
 Above Moderate-Income (120 percent or more of the AMI) According to 2018 ACS data, Brentwood’s median income is $108,994. As shown in Table 2-8, more than half of the occupations in Contra Costa County have an average income that is either low or very low. If this trend is applied to Brentwood, it should be anticipated that housing stock in the City would need to be affordable to accommodate lower-income levels.

Table 2-8: Median Salary by Occupation in Oakland-Hayward-Berkeley MD (Alameda and Contra Costa Counties)
Occupation Salary
Management $137,618
Computer and Mathematical $115,395
Legal $108,348
Healthcare Practitioners and Technical $106,907
Architecture and Engineering $101,273
Life, Physical and Social Sciences $94,563
Business and Financial Operations $83,777
Construction and Extraction $71,055
Installation, Maintenance and Repair $59,483
Education, Training and Library $57,683
Community and Social Service $57,108
Arts, Design, Entertainment, Sports and Media $56,923
Protective Services $51,757
Office and Administration Support $49,465
Production $43,804
Building, Grounds Cleaning, and Maintenance $41,931
Transportation and Material Moving $39,702
Sales $37,731
Farming, Fishing and Forestry $35,142
Personal Care and Service $32,841
Healthcare Support $32,020
Food Preparation and Serving Related $30,985
Source: California Employment Development Division, Occupational Wage data, 2018-2028.

Brentwood 2023-2031 Housing Element
Section 2: Community Profile 2-8
C. Household Characteristics
Households include all individuals that occupy a single housing unit in a shared state whether they are single occupants, families, or unrelated people sharing a housing unit. Household trends provide useful information that can be used to predict future housing needs. Household characteristics are also important in analyzing and understanding growth and determining the housing needs of a community.

Income and affordability are best measured at the household level, as well as the special needs of certain groups, such as large families, single-parent households, or lower-income households.

1. Household Type
The City has 19,906 total households, according to ACS data. This represents approximately five percent of the total Contra Costa County households. As shown in Table 2-9, Brentwood has more married-couple households than the County and the second most among the surrounding jurisdictions. Married-couple households tend to seek occupancy in single-family homes with multiple bedrooms. In contrast, 8.7 percent are non-family households – these include persons living alone or with roommates. Senior households living alone (individuals over 65 years) represent 10.2 percent, as shown in Figure 2-3 below.

Seniors generally tend to occupy apartments or seek out more affordable housing options.

Table 2-9: Household Characteristics (2019)
Jurisdiction
MarriedCouple
Family HH
% of
Total HH
Female HH,
No Spouse
Present
% of
Total HH
NonFamily HH % of
Total HH
Total
Households
Antioch 16,716 49.1% 9,869 29.0% 4,550 13.4% 34,028
Brentwood 12,967 65.1% 4,140 20.8% 1,726 8.7% 19,906
Oakley 7,835 66.5% 1,967 16.7% 1,273 10.8% 11,778
Pittsburg 10,100 47.3% 6,177 28.9% 3,779 17.7% 21,357
Contra Costa
County 217,370 55.1% 99,944 25.3% 44,613 11.3% 394,769
Source: American Community Survey, Table DP02, 5-Year Estimates, 2019.

HH = Households
Figure 2-3: Household Characteristics
Source: American Community Survey, Table DP02, 5-Year Estimates, 2019.

Married-Couple
Family HH
Female-Headed
Household, No
Spouse Present
Male-Headed
Household, No
Spouse Present
Non-Family
Household
Householder 65
Years or Older
Living Alone
Brentwood 65.1% 20.8% 9.20% 8.7% 10.2%
0%
10%
20%
30%
40%
50%
60%
70%

Brentwood 2023-2031 Housing Element
Section 2: Community Profile 2-9
Table 2-10 summarizes household changes from 2010 through 2019. During this time, the City gained approximately 5,101 new households, and now has a household size of about 3.10 average persons (Table 2-11). From 2010 to 2019, female-headed households with no spouse present experienced the greatest increase. Non-family households were the only household type to experience a decrease of 46.8 percent.

Table 2-10: Changes in Household Types
Household Type 2010 Percent 2015 Percent 2019 Percent
Percent
Change
2010-2019
Married-Couple Family
Households 11,563 78.1% 11,681 65.9% 12,967 65.1% 12.1% Female-Headed Households,
No Spouse Present 1,364 9.2% 2,087 11.8% 4,140 20.8% 203.5% Male-Headed Households
with No Spouse Present 702 4.7% 928 5.2% 1,835 9.2% 161.4% Non-Family Households 3,242 21.9% 3,029 17.1% 1,726 8.7% -46.8% Householders 65 Years and
Older Living Alone 1,132 7.6% 1,266 7.1% 2,030 10.2% 79.3% Total Households 14,805 17,725 19,906 34.5%
Source: American Community Survey, 5-Year Estimates, 2010, 2015, 2019.

2. Household Size
Household size represents the most basic unit of demand for housing, as it identifies the type and size of housing needed in a community. It can provide information on population growth and household character, as well as be both a result and indicator of housing affordability and other economic conditions.

Household size is important in understanding housing need by type of housing. For example, data reflecting household size in a community can help identify issues of overcrowding, which is a result of inadequate space for all household members and is considered a housing burden.

Table 2-11 below identifies household size for the City, nearby jurisdictions, and Contra Costa County. At approximately 3.10 persons per household, Brentwood has the smallest household size in the area. This shows a trend in Brentwood to have smaller families or generally smaller occupancies for housing units.

Table 2-11: Average Household Size by Jurisdiction
Jurisdiction Average Persons per Household
Antioch 3.25
Brentwood 3.10
Oakley 3.50
Pittsburg 3.33
Contra Costa County 2.87
Source: American Community Survey, Table B25010, 5-Year Estimates, 2019.

3. Household Income
Household income is an important indicator of housing needs in a community, as it is directly connected to the ability to afford housing. As household income increases, it is more likely that the household can afford market-rate housing, larger units, and/or pursue ownership opportunities; however, as household income decreases, households tend to pay a disproportionate amount of their income for housing. This may influence increased incidences of overcrowding and substandard living conditions.

Brentwood 2023-2031 Housing Element
Section 2: Community Profile 2-10
The California State Department of Housing and Community Development (HCD) has identified the following income categories based on the HUD Area Median Income (HAMI) of Contra Costa County:
 Extremely Low-Income (up to 30 percent of the HAMI)
 Very Low-Income (31 and 50 percent of the HAMI)
 Low-Income (51 percent and 80 percent of the HAMI)
 Moderate-Income (81 percent and 120 percent of the HAMI)  Above Moderate-Income (120 percent or more of the HAMI) Combined, the extremely low-, very low-, and low-income groups are referred to as lower-income.3 The Comprehensive Housing Affordability Strategy (CHAS) estimates the number of households by income based on 2018 ACS data. Table 2-12 shows a majority (68 percent) of residents in the City have a Moderate or Above income. A total of 32 percent of households in Brentwood are estimated to be of lower-income – with 10.2 percent estimated in the Extremely Low-Income category.

Table 2-12: Households by Income Category in Brentwood
Income Category (Percent of County MFI) Households Percent 2019 AMI* Extremely Low (30% MFI or less) 1,985 10.2% $34,850
Very Low (30% to 50% MFI) 2,090 10.7% $58,100
Low (50% to 80% MFI) 2,175 11.1% $89,600
Moderate or Above (Over 80% MFI) 13,290 68.0% $125,300
Total 19,545 100% $104,400 Median AMI
*For an average family of four.

Source: Department of Housing and Urban Development (HUD) Comprehensive Housing Affordability Strategy (CHAS), 2014-2018; HCD State Income Limits for 2018.

Higher household incomes allow for greater flexibility and opportunity of housing choice. Households with lower median-incomes are more susceptible to housing cost burdens and may have fewer choices available, meaning a large, low-income household may face challenges finding adequately sized rental housing. As a result, cost burden, displacement, and overcrowding may occur. Figure 2-4 and Table 2-13 compare Brentwood’s median household income to that of nearby jurisdictions and the County. At $108,994, the City has the greatest household income for the area, this implies a better ability to facilitate housing units at a wider range of pricing and values.
3 Federal housing and community development programs typically assist households with incomes up to 80 percent of the AMI and use different terminology. For example, the Federal Community Development Block Grant (CDBG) program refers households with incomes between 51 and 80 percent AMI as moderate-income (compared to low-income based on State definition).

Brentwood 2023-2031 Housing Element
Section 2: Community Profile 2-11
Figure 2-4: Median Household Income by City (2019)
Source: American Community Survey, Table S1903, 5-Year Estimates, 2019.

Table 2-13: Median Household Income
Jurisdiction Median Income Percent Above/Below
Regional Median
Antioch $76,601 -30.2%
Brentwood $108,994 8.5%
Oakley $104,893 4.9%
Pittsburg $74,459 -33.9%
Contra Costa County $99,716 --
Source: American Community Survey, Table S190, 5-Year Estimates, 2019.

Figure 2-5 below illustrates the City’s household income broken down by income level. The data shows that 59 percent of Brentwood households earn over $100,000 per year. In comparison, 29 percent of households earn less than $75,000 per year, which is considered low-income in Contra Costa County.

Figure 2-5: Brentwood Income Breakdown by Category
Source: American Community Survey, Table DP03, 5-Year Estimates, 2019. $76,601
$108,994 $104,893
$74,459
$99,716
$0
$20,000
$40,000
$60,000
$80,000
$100,000
$120,000
Antioch Brentwood Oakley Pittsburg
Cities Costa Contra County
Less than $25,000
10%
$25,000 to
$34,999
5%
$35,000 to
$49,999
5%
$50,000 to
$74,999
9%
$75,000 tp
$99,999
12% $100,000 to
$149,999
24%
$150,000 or more
35%

Brentwood 2023-2031 Housing Element
Section 2: Community Profile 2-12
D. Housing Problems
The Comprehensive Housing Affordability Strategy (CHAS) developed by the Census Bureau for HUD provides detailed information on housing problems by income level for different types of households in the City. The most recent available CHAS data was published in September 2021 and is based on 2018 ACS data. Housing problems considered by CHAS included:

Housing Problems:
 Units with physical defects (lacking complete kitchen or bathroom);  Overcrowded conditions (more than one person per room); or  Cost burdens exceeding 30 percent of gross income (including utilities).

Severe Housing Problems:
 Units with physical defects (lacking complete kitchen or bathroom);  Overcrowded conditions (more than 1.5 persons per room); or  Cost burdens exceeding 50 percent of gross income (including utilities).

Table 2-14: Housing Assistance Needs of Lower-Income Households Housing Problem
Overview* Owner Percent of Owner HH
Percent of
Total HH Renter Percent of Renter HH
Percent of
Total HH Total Percent of Total HH
Household has at least
1 of 4 Housing Problems 5,290 36.0% 27.1% 2,825 58.2% 14.5% 8,115 41.5% Household has none of
4 Housing Problems OR
Cost Burden not
available, no other
problems
9,400 64.0% 48.1% 2,030 41.8% 10.4% 11,430 58.5%
Total 14,690 -- 75% 4,855 -- 25% 19,545 100%
Severe Housing
Problem Overview** Owner Percent of Owner HH
Percent of
Total HH Renter Percent of Renter HH
Percent of
Total HH Total Percent of Total HH
Household has at least
1 of 4 Severe Housing
Problems
1,990 13.5% 10.2% 1,685 34.7% 8.6% 3,675 18.8%
Household has none of
4 Housing Problems OR
Cost Burden not
available, no other
problems
12,700 86.5% 65.0% 3,170 65.3% 16.2% 15,870 81.2%
Total 14,690 -- 75% 4,855 -- 25% 19,545 100%
Notes:

HH = household
* The four housing problems are: incomplete kitchen facilities, incomplete plumbing facilities, more than 1 person per room, and cost burden greater than 30%.
** The four severe housing problems are: incomplete kitchen facilities, incomplete plumbing facilities, more than 1.5 persons per room, and cost burden greater than 50%.

Source: U.S. Department of Housing and Urban Development (HUD), Comprehensive Housing Affordability Strategy (CHAS) 2014-2018.

Brentwood 2023-2031 Housing Element
Section 2: Community Profile 2-13
The types of housing problems in Brentwood vary according to household income, type, and tenure, as shown in Table 2-14. In general, there are more owner-occupied households (75.2 percent) than renteroccupied households (24.8 percent). Of all households, 41.5 percent have at least one of the four housing problems. Overall, owner households (27.1 percent) experience a higher incidence of housing problems than renter households (14.5 percent).

Severe housing problems may also include incomplete kitchen or plumbing facilities but may also have more than 1.5 persons per room or a cost burden greater than 50 percent. There are significantly less households that experience severe housing problems, but 18.8 percent of all households in Brentwood do experience at least one of these severe problems. More owners (10.2 percent) experience a severe housing problem than renter occupied households (8.6 percent).

1. Overcrowding
Overcrowding is generally defined as a housing unit occupied by more than one person per room in house (including living room and dining rooms, but excluding hallways, kitchen, and bathrooms). An overcrowded household results from either a lack of affordable housing (which forces more than one household to live together) and/or a lack of available housing units of adequate size. Overcrowding can indicate that a community does not have an adequate supply of affordable housing, especially for large families.

Overcrowded and severely overcrowded households can lead to neighborhood deterioration due to the intensive use of individual housing units leading to excessive wear and tear, and the potential cumulative overburdening of community infrastructure and service capacity. Furthermore, overcrowding in neighborhoods can lead to an overall decline in social cohesion and environmental quality. Such decline can spread geographically and impact the quality of life and the economic value of property and the vitality of commerce within a city. The combination of lower incomes and high housing costs result in many households living in overcrowded housing conditions.

Table 2-15 illustrates overcrowding in Brentwood and shows that it affects renters at a higher rate.

Overall, 2.3 percent, or 467 households, experience some form of overcrowding in Brentwood. The existence of overcrowded units can be mitigated by increased opportunities for housing of all types and appropriate sizes for different households.

Table 2-15: Overcrowding by Tenure, Brentwood
Tenure
Overcrowded Units
(1.0 to 1.5 persons/room)
Severely Overcrowded Units
(>1.51 persons/room)
Total Overcrowded
Occupied Units
Count Percent1 Count Percent1 Count Percent1
Owner Occupied 112 0.6% 80 0.4% 192 1.0%
Renter Occupied 153 0.8% 122 0.6% 275 1.4%
Total 265 1.3% 202 1.0% 467 2.3%

1. Percent of total occupied housing units.

Source: American Community Survey, Table B25014, 5-Year Estimates, 2019.

As seen in Table 2-16, owner-occupied housing units make up 41.1 percent of overcrowded units in the City. Renter-occupied units, in comparison, account for 58.9 percent of overcrowded units.

Homeownership is generally more accessible to higher-income households, while renting is more often sought by those who have insufficient income for home buying. Table 2-16 shows that Brentwood has the lowest percentage (2.3 percent) of the surrounding cities.

Brentwood 2023-2031 Housing Element
Section 2: Community Profile 2-14
Table 2-16: Overcrowded Housing Units by Tenure
Jurisdiction
Owner Occupied
Overcrowded Units
(>1.0 persons/room)
Renter Occupied
Overcrowded Units
(>1.0 persons/room)
Total Overcrowded Units
Count Percent1 Count Percent1 Count Percent2
Antioch 601 33.5% 1193 66.5% 1,794 5.3%
Brentwood 192 41.1% 275 58.9% 467 2.3%
Oakley 215 34.0% 417 66.0% 632 5.4%
Pittsburg 553 27.7% 1447 72.4% 2,000 9.4%
Contra Costa County 6,099 30.4% 13,944 69.6% 20,043 5.1%

1. Percent of total overcrowded units.

2. Percent of total occupied units.

Source: American Community Survey, 5-Year Estimates, 2019.

2. Overpayment (Cost Burden)
State and Federal standards indicate that a household paying more than 30 percent of its income for housing is overpaying. Overpayment for housing can cause an imbalance on the remainder of a household’s budget. Understanding and measuring overpayment for housing in a community is also an indicator of the dynamics of supply and demand.

Table 2-17 summarizes the City’s cost burden trends by household tenure. As displayed in the table, homeowners experience more cost burdens compared to renters. In Brentwood, 55.3 percent of renters experience cost burden over 30 percent and 28.2 percent experience cost burden over 50 percent. In comparison, 34.6 percent of homeowners experience cost burden over 30 percent and 12.1 percent for cost burden over 50 percent. Of homeowners who experience cost burden over 30 percent, those who earn a household income greater than the City’s mean annual household income experience the highest rates of cost burden (13.8 percent). The data shows that as income increases, renters are less likely to experience a cost burden. For homeowners, a cost burden is more common for those with moderate- to above moderate-income.

Brentwood 2023-2031 Housing Element
Section 2: Community Profile 2-15
Table 2-17: Summary of Housing Overpayment by Tenure
Income by Cost
Burden1
Homeowners Renters
Cost
Burden >
30%
Percent of
Owner HH
Cost
Burden >
50%
Percent of
Owner HH
Cost
Burden >
30%
Percent of
Renter HH
Cost
Burden >
50%
Percent of
Renter HH
Household Income
less-than or = 30% 690 4.7% 585 4.0% 955 19.7% 905 18.6% Household Income
>30% to less-than
or = 50% MFI3
1,015 6.9% 560 3.8% 700 14.4% 415 8.5%
Household Income
>50% to less-than
or = 80% MFI3
955 6.5% 415 2.8% 470 9.7% 50 1.0%
Household Income
>80% to less-than
or = 100% MFI3
395 2.7% 120 0.8% 235 4.8% 0 0.0%
Household Income
>100% MFI3 2,030 13.8% 95 0.6% 325 6.7% 0 0.0%
Total 5,085 34.6%2 1,775 12.1%2 2,685 55.3%2 1,370 28.2%2

1. Cost burden is the ratio of housing costs to household income. For renters, housing cost is gross rent (contract rent plus utilities). For owners, housing cost is "select monthly owner costs," which includes mortgage payment, utilities, association fees, insurance, and real estate taxes.

2. Percent of total households in Brentwood

3. MFI refers to the HUD Area Median Family Income – this is the median family income calculated by HUD for each jurisdiction, to determine Fair Market Rents (FMRs) and income limits for HUD programs. MFI will not necessarily be the same as other calculations of median incomes (such as a simple Census number), due to a series of adjustments that are made.

Source: Department of Housing and Urban Development (HUD) Comprehensive Housing Affordability Strategy (CHAS), 2014-2018.

Brentwood 2023-2031 Housing Element
Section 2: Community Profile 2-16
E. Special Needs Groups
Special needs populations include seniors, persons with disabilities, female-headed households, large households, farmworkers, persons experiencing homelessness, and students. Special needs groups may have lower-incomes because of their conditions. Special circumstances may be related to one’s employment and income, family characteristics, disability and household characteristics, or other factors.

Consequently, certain residents in Brentwood may experience higher incidences of housing overpayment (cost burden), overcrowding, or other housing problems. As Table 2-18 below shows, households with Seniors make up a large portion of Brentwood households and are the largest special needs group in the City. These categories may also overlap with one another, for example seniors may have disabilities and large households may be overcrowded as a result of falling below the poverty line (the federal poverty line in California for 2022 is $27,750 for a four-person household). The following sections provide a detailed discussion of the housing needs facing each particular group in the City.

Table 2-18: Special Needs Groups
Special Needs Groups # of People or
Households
Percent of Total
Households
Percent of Total
Population
Senior Headed Households 7,703 HH 38.7% --
Households with Seniors (65 years and over) 9,215 HH 46.3% -- Seniors Living Alone 3,557 HH 17.9% --
Persons with Disabilities 7,188 persons -- 11.6%
Persons with Developmental Disabilities1 23,423 persons -- -- Large Households (five or more persons per
household) 3,037 HH 15.3% --
Single-Parent Households 5,975 HH 30.0% --
Single-Parent, Female Headed Households with
Children (under 18 years) 4,140 HH 20.8% --
People Living in Poverty 3,641 persons -- 5.9%
Farmworkers2 1,310 persons -- 2.1%
Migrant Farmworkers 105 persons -- --
Seasonal Farmworkers 860 persons -- --
Permanent Farmworkers 450 persons -- --
Homeless 69 persons -- --
HH=Households

1. Total persons who received service from the East Bay Regional Center for FY 2019-2020.

2. Farmworker data is taken of the population 16 years and over. Data taken at the County level and provided by USDA Statistics Services.

Source: American Community Survey, 5-Year Estimates, 2019; Contra Costa County:

Annual Point in Time Count Report 2020.

1. Seniors
The senior population, generally defined as those over 65 years of age, may have several special circumstances that lead to difficulty in finding adequate and affordable housing: limited and fixed incomes, high health care costs, higher incidence of mobility and self-care limitations, transit dependency, and living alone. Specific housing needs of the senior population include affordable housing, supportive housing (such as intermediate care facilities), group homes, and other housing that includes a planned service component. The City has a slightly higher average percent of persons over the age of 65 than the surrounding cities, as shown in Table 2-19. Table 2-20 also illustrates the tenure of senior households in the City of Brentwood and shows the majority of senior households are owner-occupied.

Brentwood 2023-2031 Housing Element
Section 2: Community Profile 2-17
Table 2-19: Persons Age 65 and Over
Jurisdiction Population Count Percent of Population
Antioch 13,547 12.2%
Brentwood 9,279 15.0%
Oakley 3,837 9.3%
Pittsburg 7,834 11.0%
Contra Costa County 175,882 15.4%
Source: American Community Survey, Table S0101, 5-Year Estimates, 2019.

Table 2-20: Senior Households by Tenure
Tenure Senior Households Percent of Total
Senior Households
Owner Occupied 4,423 83.9%
Renter Occupied 851 16.1%
Total 5,274 100.00%
Source: American Community Survey, Table B25007, 5-Year Estimates, 2019.

Table 2-21 summarizes the income of senior households in the City. Of all senior households, 14 percent earn less than 30 percent of the Median Family Income (MFI), and 20.8 percent earn less than 50 percent of the MFI. In total, 51.7 percent of senior households are considered low-income and earn less than 80 percent of the MFI.

Table 2-21: Elderly Households by Income and Tenure
Income Category Owner Renter Total
Percent of
Total Elderly
Households
Extremely Low (<30% MFI) 470 280 750 14.0%
Very Low (30% to 50% MFI) 820 290 1,110 20.8%
Low (50% to 80% MFI) 840 69 909 16.9%
Moderate (80% to 100% MFI) 405 90 495 9.3%
Above Moderate (>100% MFI) 1,920 165 2,085 38.9%
Total 4,455 894 5,349 100.00%
Source: U.S. Department of Housing and Urban Development (HUD), Comprehensive Housing Affordability Strategy (CHAS) ACS tabulation, 2013-2017.

2. Persons with Physical and Developmental Disabilities Physical and developmental disabilities can hinder access to traditional housing units and may limit the ability to earn adequate income. Physical, mental, and/or developmental disabilities may deprive a person from earning income, restrict one’s mobility, or make self-care difficult. Persons with disabilities often have special housing needs related to limited earning capacity, a lack of accessible and affordable housing, and higher health costs associated with a disability. Some residents may also have disabilities that require living in a supportive or assisted-living setting.

Although no current comparisons of disability with income, household size, or race/ethnicity are available, it is reasonable to assume that a substantial portion of persons with disabilities would have annual incomes within Federal and State income limits, especially those households not in the labor force.

Furthermore, many lower-income persons with disabilities are likely to require housing assistance and services. Housing needs for disabled persons are further compounded by design issues and location factors, which can often be costly. For example, households with wheelchair-bound or semi-ambulatory

Brentwood 2023-2031 Housing Element
Section 2: Community Profile 2-18
individuals may require ramps, holding bars, special bathroom designs, wider doorways, lower cabinets, elevators, and other interior and exterior design features.

Housing opportunities for persons with disabilities can be addressed through the provision of affordable, barrier-free housing. Rehabilitation assistance can be targeted toward renters and homeowners with disabilities for unit modifications that can improve accessibility.

The ACS identifies six disability types: hearing disability, vision disability, cognitive disability, ambulatory disability, self-care disability and independent living disability. The Census and the ACS provide clarifying questions to determine persons with disabilities and differentiate disabilities within the population. The ACS defines a disability as a report of one of the six disabilities identified by the following questions:
 Hearing Disability: Is this person deaf or do they have serious difficulty hearing?  Visual Disability: Is this person blind or do they have serious difficulty seeing even when wearing glasses?
 Cognitive Difficulty: Because of a physical, mental, or emotional condition, does this person have serious difficulty concentrating, remembering, or making decisions?  Ambulatory Difficulty: Does this person have serious difficulty walking or climbing stairs?  Independent Living Difficulty: Because of a physical, mental, or emotional condition, does this person have difficulty doing errands alone such as visiting a doctor’s office or shopping? According to the 2019 ACS, approximately 11.6 percent of the Brentwood population has a disability (Table 2-22). Of those reporting a disability, the most common is ambulatory difficulty, while the most common for persons under the age of 18 is cognitive disability. For those ages 18 to 64, ambulatory and independent living difficulty are the most common. The senior population has the largest percent of persons experiencing a disability.

Table 2-22: Disability Status
Disability Type Under 18 18 to 64 65 and
Over Total2

Percent of
Population with a
Disability
Percent of
Total
Population1
Hearing Difficulty 49 780 1367 2196 30.6% 3.5%
Vision Difficulty 173 392 449 1014 14.1% 1.6%
Cognitive Difficulty 528 952 791 2271 31.6% 3.9%
Ambulatory Difficulty 46 1482 1929 3457 48.1% 5.9%
Self-care Difficulty 164 641 615 1420 19.8% 2.4%
Independent Living
Difficulty -- 1267 1139 2406 33.5% 5.3%
Total2 960 5514 6290 12,7642 -- 11.6%

1. Total non-institutionalized population.

2. This total may double count persons having one or more disabilities.

Source: American Community Survey, 5-Year Estimates, 2019.

State law requires that the Housing Element discuss the housing needs of persons with developmental disabilities. As defined by Federal law, “developmental disability” means a severe, chronic disability of an individual that:
 Is attributable to a mental or physical impairment or combination of mental and physical impairments;

Brentwood 2023-2031 Housing Element
Section 2: Community Profile 2-19
 Is manifested before the individual attains age 22;
 Is likely to continue indefinitely;
 Results in substantial functional limitations in three or more of the following areas of major life activity: a) self-care; b) receptive and expressive language; c) learning; d) mobility; e) selfdirection; f) capacity for independent living; or g) economic self- sufficiency; and  Reflects the individual’s need for a combination and sequence of special, interdisciplinary, or generic services, individualized supports, or other forms of assistance that are of lifelong or extended duration and are individually planned and coordinated.

According to the Regional Center of the East Bay Purchase of Services Expenditure and Demographic Data Report for 2019 to 2020, there is a total of 23,423 developmentally disabled individuals from the region who received services. Of the 23,423 individuals, those diagnosed with Autism (38.4 percent) made up the largest group. The rest were diagnosed with intellectual disability (33.5 percent), Category 5 (6.0 percent), Cerebral Palsy (4.3 percent), Epilepsy (1.3 percent), and 16.6 percent with some other disability. Of those who received services, 26.3 percent were White, 18.4 percent were Asian, 15.7 percent were Black or African American, 0.2 percent were American Indian or Alaska Native, 0.3 percent were Native Hawaiian or Other Pacific Islander, and 15.2 percent were some other race. At 23.6 percent, approximately one quarter of those who received services identified as Hispanic or Latino. The largest age group who received services were between the age of three to 21 years (44.3 percent), the rest were 22 years or older (40.5 percent) and under the age of two (15.2 percent). Approximately 79.4 percent of individuals who received services lived at home with a parent or guardian.

The California Department of Developmental Services (CDDS) provides estimates of persons with developmental disabilities in Brentwood, as shown in Table 2-23 below. As of January 2022, CDDS identified 373 juvenile persons and 285 adults of having developmental disability in the ZIP code 94513.

Table 2-23: Developmental Disability Status for ZIP Code 94513 Disability Type Number of Residents
Living Arrangement
Home of Parent/Guardian 584
Independent/Supported Living <11
Community Care Facility 57
Intermediate Care Facility 0
Foster/Family Home <11
Other <11
Age Range
0-17 Years Old 373
18+ Years Old 285
Source: CA DDS data by ZIP Code, January 2022
Many people with developmental disabilities can live and work independently within a conventional housing environment. Individuals with more severe developmental disabilities may require a group living environment where supervision is provided. The most severely affected individuals may require an institutional environment where medical attention and physical therapy are provided. The most common issue in supportive housing for persons with developmental disabilities is the transition from the person’s living situation as a child to an appropriate level of independence as an adult as developmental disabilities exist before adulthood.

Brentwood 2023-2031 Housing Element
Section 2: Community Profile 2-20
There are several housing types appropriate for people living with a development disability: rent subsidized homes, licensed and unlicensed single-family homes, inclusionary housing, Section 8 vouchers, special programs for home purchase, HUD housing, and SB 962 (veterans) homes. The design of housingaccessibility modifications, the proximity to services and transit, and the availability of group living opportunities represent some of the types of considerations that are important in serving the needs of this group. Incorporating ‘barrier-free’ design in all, new multi-family housing (as required by California and Federal Fair Housing laws) is especially important to provide the widest range of choices for residents with disabilities. Special consideration should also be given to the affordability of housing, as people with disabilities may be living on a fixed income.

3. Large Households
Large households are households of five or more individuals. Procuring resources for a large household requires a greater income. This may lead households to find smaller, more affordable housing units. Such units may not be large enough to adequately contain a large household and may lead to overcrowding.

Securing housing large enough to accommodate all members of a household is more challenging for renters, because multi-family rental units are typically physically smaller than single-family ownership units. While apartment complexes offering two and three bedrooms are common, apartments with four or more bedrooms are rare. It is more likely that large households will experience overcrowding in comparison to smaller households. Throughout the region, single-family homes with higher bedroom counts, whether rental or ownership units, are rarely affordable to lower-income households. Table 2-24 is a breakdown of large households by tenure for the City. The data identifies a contrast in household size between homeowners and renters living in large households.

Table 2-24: Large Households by Tenure
Household Size Owner Renter Total
Count Percent Count Percent Count Percent
5-Person Household 1204 39.6% 730 24.0% 1,934 9.7%
6-Person Household 613 20.2% 141 4.6% 754 3.8%
7-or-More Person Household 221 7.3% 128 4.2% 349 1.8%
Total 2,038 41.2%1 999 58.8%1 3,037 15.3%2

1. Percent of large households.

2. Percent of total households.

Source: American Community Survey, Table B25009, 5-Year Estimates, 2019.

4. Single-Parent Households
Single-parent households often require special consideration and assistance due to their greater need for affordable and accessible day care, health care, and other supportive services. Many female-headed households with children are susceptible to having lower incomes than similar two-parent households.

Single, female mothers may face social pressures that may limit their occupational choices and income earning potential, housing options, and access to supportive services.

Table 2-25 shows about double the percent of female single-parent, no spouse present households, in both the County and the City, compared to male single-parents. The same is true for households living in poverty.

Brentwood 2023-2031 Housing Element
Section 2: Community Profile 2-21
Table 2-25: Single-Parent Households
Jurisdictions
Single Parent-Male, No
Spouse Present
Single Parent-Female,
No Spouse Present
Total Single Parent
Households
Count Percent1 Count Percent1 Count Percent1
Brentwood 1,835 9.2% 4,140 20.8% 5,975 30.0%
Contra Costa County 54,423 13.8% 99,944 25.3% 154,367 39.1%

1. Percent of total households.

Source: American Community Survey, Table DP02 and S1702, 5-Year Estimates, 2019.

5. Farmworkers
Farmworkers are traditionally defined as persons whose primary incomes are earned through permanent or seasonal agricultural labor. Permanent farm laborers work in the fields, processing plants, or support activities on a generally year-round basis. When workload increases during harvest periods, the labor force is supplemented by seasonal workers, often supplied by a labor contractor. For some crops, farms may hire migrant workers, defined as those whose travel prevents them from returning to their primary residence every evening. Farmworkers have special housing needs because they earn lower incomes than many other occupations and move throughout the year from one harvest location to the next.

The United States Department of Agriculture, National Agriculture Statistics provides data on hired farm labor across the United States. The data is compiled at both a State and County level. Within Contra Costa County, there were a total of 1,310 hired farmworkers in 2017. A total of 450 are considered permanent, working 150 days or more, and a total of 860 farmworkers were considered seasonal, working only 150 days or less. Additionally, the County of Contra Costa reported 106 total migrant farmworkers.

In Contra Costa County, farmworkers earn one of the lowest estimated median salaries of $35,142 annually, according to the California Employment Development Department. The HUD Comprehensive Housing Affordability Strategy considers this a very low-income for the City as it represents 32.2 percent of the average median income for the City. Limited income may be exacerbated by farmworker’s tenuous and/or seasonal employment status.

6. Extremely Low-Income Household (ELI) and Poverty Status Extremely low-income (ELI) households are those that earn 30 percent or less of the median family income (MFI) for Contra Costa County. As shown in Table 2-12, the CHAS data indicates there are approximately 1,985 ELI households living in the City. Table 2-6 above identifies industries with salaries that could qualify as ELI, these include: Personal Care and Service, Healthcare Support, and Food Preparation and Serving Related.

Table 2-26: ELI Households by Tenure
Income Category (Percent of
County MFI) Owner
Percent
of Owner
HH
Renter
Percent
of Renter
HH
Total
Percent
of Total
HH
Extremely Low (30% MFI or
less) 820 41.3% 1,165 58.7% 1,985 10.2%
Source: Department of Housing and Urban Development (HUD) Comprehensive Housing Affordability Strategy (CHAS), 2014-2018; HCD State Income Limits for 2018.

Brentwood 2023-2031 Housing Element
Section 2: Community Profile 2-22
Table 2-26 shows that ELI households represent approximately 10.2 percent of all Brentwood households.

Of these households, 58.7 percent are renters and 41.3 percent are homeowners. ELI renter households represent about 5.6 percent of Brentwood renter households, and ELI owner households represent about 24 percent of Brentwood owner households.

Housing ELI households is generally challenging in Brentwood. Table 2-27 shows White, Non-Hispanic Households experience the highest rates of extremely low-incomes, representing 40.1 percent of the total ELI Population. Hispanic households experience the second highest rates of extremely low-incomes. Per HCD guidance, the City assumes 50 percent of its very low-income RHNA as extremely low-income units to calculate future ELI housing needs over the next eight years. Table 1-2 shows the breakdown of the RHNA by income categories. The total number of very low-income in Brentwood was 402. As such, the City has a need of 201 extremely low-income units.

Table 2-27: Household Income Distribution by Race
Racial/Ethnic Group 0%-30% of
AMI
31%-50% of
AMI
51%-80% of
AMI
81%-100% of
AMI
Greater than
100% of AMI
American Indian or Alaska
Native, Non-Hispanic 15 0 0 30 0
Asian / API, Non-Hispanic 54 180 250 155 855
Black or African American,
Non-Hispanic 290 335 10 25 440
White, Non-Hispanic 805 1,195 1,245 910 7,835
Other Race or Multiple Races,
Non-Hispanic 130 40 40 130 310
Hispanic or Latinx 715 510 750 335 1,210
Totals 2,009 2,260 2,295 1,585 10,650
Source: U.S. Department of Housing and Urban Development (HUD), Comprehensive Housing Affordability Strategy (CHAS) ACS tabulation, 2013-2017 release.

Table 2-28 illustrates the tendencies for extremely low-income households to experience housing problems and cost burdens, as defined in Section 2.D. Table 2-28 also includes data characterizing affordability and cost burden for ELI households. ELI renters in Brentwood experience disproportionate cost burdens compared to ELI owners. Approximately 19.8 percent of the ELI renters experience at least 1 of the 4 housing problem which includes either incomplete kitchen facilities, incomplete plumbing facilities, more than 1 person per room, and a cost burden greater than 50 percent. Of the renters, 18.6 percent experience a cost burden greater than 50 percent. Householders experience housing problems at a much lower rate compared to renters at 4.7 percent. Of the householders, 4 percent experience cost burden greater than 50 percent. Generally, as the income goes up for renters, the number of housing units with a housing problem goes down.

Table 2-28: Housing Needs of Extremely Low-Income Households Housing Problems
Renter Households Owner Households Total Households
Count
% of
Renter HH
Count
% of
Owner HH
Count
% of Total
HH
Household has at least 1 of 4
housing problem
960 19.8% 695 4.7% 1,655 8.5%
Cost burden <= 30% 955 19.7% 690 4.7% 1,645 8.4%
Cost Burden > 50% 905 18.6% 585 4.0% 1,490 7.6%
Source: Department of Housing and Urban Development (HUD) Comprehensive Housing Affordability Strategy (CHAS), 2014- 2018.

Brentwood 2023-2031 Housing Element
Section 2: Community Profile 2-23
According to 2019 ACS data, 5.9 percent of the Brentwood population lives in poverty. The U.S. Census Bureau’s definition of poverty is: “If a family's total income is less than the family's threshold, then that family and every individual in it is considered in poverty. The official poverty thresholds do not vary geographically, but they are updated for inflation using the Consumer Price Index (CPI-U). The official poverty definition uses money income before taxes and does not include capital gains or noncash benefits (such as public housing, Medicaid, and food stamps).” Poverty status cannot be determined for people in institutional group quarters (e.g., prisons or nursing homes), college dormitories, military barracks, living situations without conventional housing (and who are not in shelters), as well as unrelated individuals under age 15 (e.g., foster children).

Figure 2-6: Poverty Status by Race4
Source: U.S. Census Bureau, American Community Survey 5-Year Data (2015-2019), Table B17001(A-I).

Key Challenges and Resources to Address Extremely Low-Income Households Extremely Low-Income Households in Brentwood have exhibited the following unique challenges to housing:
 Need for increased affordable housing options
 Incidents of cost burden for housing
 Rental and Homebuyer Assistance
Extremely Low-Income household needs are focused on affordability of housing and access to subsidies and services that support lower monthly overall costs. To address these challenges, the City must consider a variety of solutions to address the issues above: these may include:
 Affordable housing options for Extremely Low-Income households 4 The Census Bureau uses a federally defined poverty threshold that remains constant throughout the country and does not correspond to Area Median Income.

For this table, the Census Bureau does not disaggregate racial groups by Hispanic/Latinx ethnicity. However, data for the white racial group is also reported for white householders who are not Hispanic/Latinx. Since residents who identify as white and Hispanic/Latinx may have very different experiences within the housing market and the economy from those who identify as white and non-Hispanic/Latinx, data for multiple white sub-groups are reported here.

The racial/ethnic groups reported in this table are not all mutually exclusive. Therefore, the data should not be summed as the sum exceeds the population for whom poverty status is determined for this jurisdiction. However, all groups labelled “Hispanic and Non-Hispanic” are mutually exclusive, and the sum of the data for these groups is equivalent to the population for whom poverty status is determined.

13.2%

11.3%

10.6%

9.5%

4.2%

3.7%

2.9%

0.0% 2.0% 4.0% 6.0% 8.0% 10.0% 12.0% 14.0%
Black or African American (Hispanic and Non-Hispanic)
American Indian or Alaska Native (Hispanic and Non-…
Other Race or Multiple Races (Hispanic and Non-Hispanic) Hispanic or Latinx
White (Hispanic and Non-Hispanic)
White, Non-Hispanic
Asian / API (Hispanic and Non-Hispanic)
Percent of Households in Racial / Ethnic Group

Brentwood 2023-2031 Housing Element
Section 2: Community Profile 2-24
 Preservation of subsidized housing units
 Inclusionary policies
 Housing with a service component
Resources to address the needs of Extremely Low-Income households include a variety of federal, state, and regional programs, such as HUD, LIHTC USDA, CalHFA, and other public and private funding sources.

The City has included Action H.3f in Section 4 to address Housing for Extremely Low-, Very Low-, and Lowincome residents. The City will assist developers accessing City, County CDBG and HOME Funds, Federal, and State housing development programs and fund to undertake development of housing projects for extremely low-, very low-, and low-income households. The City will continue to monitor the inventory of sites appropriate to accommodate extremely low-income households and work with appropriate organizations to ensure the needs of ELI residents are met.

7. Persons Experiencing Homelessness
Homelessness is an important issue within California. Factors contributing to the rise in homelessness include increased unemployment and underemployment, a lack of housing affordable to lower- and moderate-income persons (especially extremely low-income persons), reductions in public subsidies to the poor, a lack of assistance for those struggling with addiction, and the de-institutionalization of the mentally ill.

State law mandates that jurisdictions address the special needs of persons experiencing homelessness within their jurisdictional boundaries. The U.S. Department of Housing and Urban Development (HUD) definition of “Homelessness” was recently updated. The following lists the updated definition of homelessness as provided by HUD:
 People who are living in a place not meant for human habitation, in emergency shelter, in transitional housing, or are exiting an institution where they temporarily resided. The only significant change from existing practice is that people will be considered homeless if they are exiting an institution where they resided for up to 90 days (it was previously 30 days) and were in a shelter or a place not meant for human habitation immediately prior to entering that institution.  People who are losing their primary nighttime residence, which may include a motel or hotel or a doubled-up situation, within 14 days and lack resources or support networks to remain in housing.

HUD had previously allowed people who were being displaced within seven days to be considered homeless. The proposed regulation also describes specific documentation requirements for this category.
 Families with children or unaccompanied youth who are unstably housed and likely to continue in that state. This is a new category of homelessness, and it applies to families with children or unaccompanied youth who have not had a lease or ownership interest in a housing unit in the last 60 or more days, have had two or more moves in the last 60 days, and who are likely to continue to be unstably housed because of disability or multiple barriers to employment.  People who are fleeing or attempting to flee domestic violence, have no other residence, and lack the resources or support networks to obtain other permanent housing. This category is similar to the current practice regarding people who are fleeing domestic violence.

Brentwood 2023-2031 Housing Element
Section 2: Community Profile 2-25
 This definition does not include persons living in substandard or overcrowded housing units, persons being discharged from mental health facilities (unless the person was homeless when entering and is considered to be homeless at discharge), or persons who may be at risk of homelessness (for example, living temporarily with family or friends).

Table 2-29 shows the population of persons experiencing homelessness in the County, in the City, and in the surrounding jurisdictions as reported by the Contra Costa County Point-In-Time Count. Brentwood experienced an overall increase since 2019 but reports a lower figure in 2023 compared to 2021.

Brentwood had 1.6 percent of all persons experiencing homelessness in Contra Costa County in 2023.

Table 2-29: Homelessness in Brentwood and Surrounding Cities Jurisdiction 2019 2021 2023
Percent Change
2019-2023
Antioch 226 342 334 47.8%
Brentwood 14 69 37 164.3%
Oakley 13 43 9 -30.8%
Pittsburg 128 221 58 -54.7%
Contra Costa County 2,295 3,093 2,372 3.4%
Source: Contra Costa County Health Services: Annual Point-in-Time Count Report, 2019, 2021, 2023.

Table 2-30: Homelessness in Brentwood and Surrounding Cities Jurisdiction 2023 % of County
Antioch 334 14.1%
Brentwood 37 1.6%
Oakley 9 0.4%
Pittsburg 58 2.4%
Contra Costa County 2,372 100%
Source: Contra Costa County: Annual Point in Time Count Report, 2023.

8. Students
Students are typically considered lower-income and are, therefore, affected by a lack of affordable housing. They may seek shared housing situations to decrease expenses and can be assisted through roommate referral services offered on and off campus. Students living independently have varied needs and may live on fixed incomes. A report by the California Community College Chancellor’s Office found that 56 percent of students surveyed were food insecure, and nearly half were either experiencing housing insecurity (35 percent) or homelessness (14 percent).5 Student housing often only produces a temporary housing need based on the duration of the educational institution enrolled in. The only college located in Brentwood is a satellite campus for the Los Medanos College called the Brentwood Center. While there may not be many colleges or universities in Brentwood, students who grew up in the City and attend colleges or universities nearby or online may wish to continue living in Brentwood. According to 2019 ACS data, there are approximately 4,286 Brentwood residents enrolled in college or graduate school. College graduates provide a specialized pool of skilled labor that is vital to the economy. However, a lack of affordable housing may lead to their departure post-graduation.

5 California Community Colleges, Chancellor’s Office, Basic Needs Survey report, 2018.

Brentwood 2023-2031 Housing Element
Section 2: Community Profile 2-26
F. Housing Stock Characteristics
Brentwood’s housing stock includes all housing units located within its jurisdiction. Housing stock growth, type, age and condition, tenure, vacancy, and cost are all important factors in determining the community's housing needs. This section details the City’s housing stock characteristics to identify how well the needs of current and future residents are addressed.

1. Housing Growth
Table 2-31 shows growth trends for housing units in Brentwood and surrounding jurisdictions. The data shown reflects ACS estimates and is not based on true City reported figures. The number of housing units in the City has increased faster than neighboring jurisdictions between 2010 and 2019.

Table 2-31: Housing Unit Growth Trends
Jurisdiction 2010 2015 2019 Change
2010 to 2015
Change
2015 to 2019
Antioch 34,730 36,009 35,373 3.7% -1.8%
Brentwood 16,094 18,301 20,627 13.7% 12.7%
Oakley 10,991 11,607 12,097 5.6% 4.2%
Pittsburg 20,825 21,227 22,294 1.9% 5.0%
Contra Costa County 396,782 405,001 413,719 2.1% 2.2%
Notes: These unit figures are based on ACS estimates – not City-collected data. As such, percent change may show a decrease in units. This does not reflect a true loss in units but reflects survey estimates.

Source: American Community Survey, Table DP04, 5-Year Estimates, 2019.

2. Housing Types
Table 2-32 summarizes the available housing units in the City and Contra Costa County by housing type.

As of 2019, the City’s housing stock predominantly includes single-unit detached homes. Single-unit attached homes, which include townhomes and condominiums, make up only 2.5 percent of the housing stock. Multi-unit developments, such as apartments, make up 7.7 percent of the housing stock and 1.5 percent were mobile homes. In comparison to the rest of the County, the City has a higher percentage of single-unit detached homes and a lower percentage of all other types of homes.

Table 2-32: Total Housing Units by Type
Jurisdiction
Single-Unit
Detached
Single-Unit
Attached Multi-Unit
Mobile Homes,
Boats, and other
Types of Housing
Total
Units
Count % Count % Count % Count %
Brentwood 18,219 88.3% 516 2.5% 1592 7.7% 300 1.5% 20,627 Contra Costa
County 274,997 66.5% 33,686 8.1% 97,314 23.5% 7,264 1.8% 413,719 Source: American Community Survey, Table DP04, 5-Year Estimates, 2019.

3. Housing Availability and Tenure
Household size typically differs between renter and owner-occupied housing units. Owner-occupied units trend towards larger households compared to renter-occupied units. Homeowners typically have a greater income than renters and therefore have more expendable income to afford purchasing a home.

In addition, family households generally occupy larger housing units such as single-unit homes. The City

Brentwood 2023-2031 Housing Element
Section 2: Community Profile 2-27
housing stock includes 15,364 owner-occupied housing units and 4,542 renter-occupied housing units, as shown in Table 2-33. The large majority of occupied homes in Brentwood are single-unit detached structures. Multi-unit homes are largely renter-occupied compared to owner-occupied.

Table 2-33: Occupied Housing Units by Type and Tenure
Tenure Single-Unit
Detached
Single-Unit
Attached Multi-Unit Mobile Homes Total Occupied Units
Owner Occupied 96.8% 1.2% .4% 1.6% 15,364
Renter Occupied 63.9% 6.3% 28.6% 1.2% 4,542
Source: American Community Survey, Table B25032, 5-Year Estimates, 2019.

As Table 2-34 shows, the City trends towards smaller household size when compared to neighboring jurisdictions. The average household size for owner and renter households in Brentwood are similar (3.06 and 3.24, respectively).

Table 2-34: Average Household Size by Tenure
Jurisdiction Owner Occupied
Household Size
Renter Occupied
Household Size Average Household Size
Antioch 3.18 3.36 3.25
Brentwood 3.06 3.24 3.1
Oakley 3.4 3.8 3.5
Pittsburg 3.36 3.29 3.33
Contra Costa County 2.88 2.86 2.87
Source: American Community Survey, Table B25010, 5-Year Estimates, 2019.

Figure 2-7 shows the City has the second lowest vacancy rate of neighboring jurisdictions. Table 2-35 shows vacant housing units by type in the City. As shown, 42.9 percent of vacant units are up for rent, and 24 percent are up for sale. According to State law, a healthy vacancy rate should not be less than five percent. The City’s low vacancy rate may result in higher housing costs in response to the low market inventory.

Figure 2-7: Vacancy Rates by Jurisdiction
Source: American Community Survey, 5-Year Estimates, 2019. Antioch Brentwood Oakley Pittsburg Contra Costa County
Vacancy Rate 3.8% 3.5% 2.6% 4.2% 4.6%

0.0%

0.5%

1.0%

1.5%

2.0%

2.5%

3.0%

3.5%

4.0%

4.5%

5.0%

Brentwood 2023-2031 Housing Element
Section 2: Community Profile 2-28
Table 2-35: Vacant T Units by Type
Type of Housing Estimate Percentage
For rent 309 42.9%
Rented, not occupied 0 0.0%
For sale only 173 24.0%
Sold, not occupied 42 5.8%
For seasonal, recreational, or occasional use 63 8.7%
For migrant workers 0 0.0%
Other vacant 134 18.6%
Total 721 100%
Source: American Community Survey, Table B25004, 5-Year Estimates, 2019.

4. Housing Age and Conditions
Housing age may affect the structural integrity of a house and can be an indicator of overall housing quality within a community. Housing that is over 30 years old is deemed to be likely in need of some rehabilitation, such as a new roof, foundation, plumbing, etc. Many Federal and State programs also use the age of housing as a factor in determining housing rehabilitation needs. A large proportion of older housing stock would typically indicate that the City could benefit from housing rehabilitation assistance programs.

Rehabilitation needs based on unit age does not include historical districts, which are generally well preserved.

Figure 2-8 shows the City’s housing stock age based on ACS estimates and is not based on City reported figures. The data shows that the majority of the City’s housing stock was built after 2000. Only 16.1 percent of the City’s housing stock was built over 30 years ago. It can be assumed that a majority of Brentwood’s housing stock is in good condition, but some of the older units may require some rehabilitation. A windshield housing condition survey was conducted in February 2023 of older neighborhoods developed prior to 1990 in order to identify housing in need of rehabilitation. Based on the sampling it is estimated that there are approximately 17 units in need of replacement throughout Brentwood.

Figure 2-8: Housing Stock Age
Source: American Community Survey, 5-Year Estimates, 2019.

Built
1939 or
earlier
Built
1940 to
1949
Built
1950 to
1959
Built
1960 to
1969
Built
1970 to
1979
Built
1980 to
1989
Built
1990 to
1999
Built
2000 to
2009
Built
2010 to
2013
Built
2014 or
later
Housing Stock 0.9% 0.9% 2.9% 1.7% 4.8% 4.9% 22.2% 48.8% 5.6% 7.2%

0.0%

5.0%

10.0%

15.0%

20.0%

25.0%

30.0%

35.0%

40.0%

45.0%

50.0%

Brentwood 2023-2031 Housing Element
Section 2: Community Profile 2-29
Figure 2-9 below illustrates tenure by year the housing unit was built. This shows whether homeowners or renters occupy newer or older housing units. Given the higher percentage of renters in multi-family units, this may point towards the addition of new multi-family developments versus older, single-unit homes that are occupied by more homeowners.

Figure 2-9: Tenure by Year Housing Unit Built
Source: American Community Survey, Table B25036, 5-Year Estimates, 2019.

5. Housing Costs and Affordability
The median home value in Brentwood as of June 2022 is estimated to be $975,000, according to the Zillow Home Value Index (ZHVI). Figure 3-10 illustrates home value trends for the Bay Area, Contra Costa County, and Brentwood from December 2001 to June 2022. As shown, Brentwood’s home costs have remained lower but have gained proximity to the County’s values from 2011 to 2013 and again since 2016. Data is not available for 2021 and 2022 Bay Area ZHVI.

Figure 2-10: Zillow Home Value Index (2001-2020)
Source: Zillow, Zillow Home Value Index (ZHVI).

Built
1939 or
earlier
Built
1940 to
1949
Built
1950 to
1959
Built
1960 to
1969
Built
1970 to
1979
Built
1980 to
1989
Built
1990 to
1999
Built
2000 to
2009
Built
2010 to
2013
Built
2014 or
later
Owner 0.4% 0.3% 1.9% 1.1% 3.4% 3.4% 17.1% 38.7% 4.5% 6.4% Renter 0.6% 0.6% 1.1% 0.7% 1.3% 1.3% 4.9% 10.9% 0.7% 0.7%

0.0%

5.0%

10.0%

15.0%

20.0%

25.0%

30.0%

35.0%

40.0%
$100,000
$300,000
$500,000
$700,000
$900,000
$1,100,000
$1,300,000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 2016 2017 2018 2019 2020 2021 Bay Area Contra Costa County Brentwood

Brentwood 2023-2031 Housing Element
Section 2: Community Profile 2-30
Figure 2-11 shows the median contract rent for Brentwood, Contra Costa County, and the Bay Area from 2009 to 2019. As illustrated, the City of Brentwood experienced a much greater rental cost increase in 2010, but in 2018 rental costs in the Bay Area caught up. Contra Costa County rental costs remain almost $200 lower than the City’s.

Figure 2-11: Median Contract Rent (2009-2019)
Source: U.S. Census Bureau, American Community Survey 5-Year Data releases, starting with 2005-2009 through 2015-2019, B25058, B25056 (for unincorporated areas). County and regional counts are weighted averages of jurisdiction median using B25003 rental unit counts from the relevant year.

The affordability standard for housing in the United States is defined as paying 30 percent or less of annual income for housing. This does not account for transportation costs which are the second largest expense for households6. The HUD Location Affordability Index (LAI) provides standardized data on affordability throughout communities and includes both housing and transportation costs. As a place becomes less affordable, the index increases, and vice versa.

Figure 2-12 shows the LAI in the City is at its lowest towards the downtown region and progressively increases towards the eastern and southern extremities of the City. The figure shows that households around downtown Brentwood pay less for housing and transportation combined, and as households get further away from the downtown, they start accruing higher costs. 6 HUD Exchange – About the Location Affordability Index. $1,100
$1,200
$1,300
$1,400
$1,500
$1,600
$1,700
$1,800
$1,900
$2,000
2009 2010 2011 2012 2013 2014 2015 2016 2017 2018 2019 Dollars Brentwood Contra Costa County Bay Area

Brentwood 2023-2031 Housing Element
Section 2: Community Profile 2-31
Figure 2-12: HUD Location Affordability Index by Census Tract Source: California Department of Housing and Community Development – AFFH Data Viewer

Brentwood 2023-2031 Housing Element
Section 2: Community Profile 2-32
Housing affordability analysis includes comparing the cost of renting or owning a home in the City with the maximum affordable housing costs for households at different income levels. The analysis informs the affordability of different housing sizes and types and indicates the type of households most likely to experience overcrowding and overpayment.

HUD conducts annual household income surveys nationwide to determine a household’s eligibility for Federal housing assistance. Based on this survey and MFI data, HCD develops income limits which can be used to determine the maximum affordable price for households in the upper range of their respective income category. Households in the lower end of each category can afford less than those at the upper end. The maximum affordable home prices without overpayment for residents in Brentwood are shown in Table 2-36. This data is based on analysis conducted by the City for 2022 to 2023. In Table 2-37, the data shows the maximum affordable monthly rental amount that a Contra Cost County household can pay for each month without overpayment; City-specific data is not available for rental costs.

Very Low-Income Households
The very low-income limits are the basis for all other income limits. For a very low-income household that earns between 31 percent and 50 percent of the County MFI the maximum affordable home price for ownership is up to $136,000 for a zero-bedroom unit and up to $231,000 for a five-bedroom units in 2022.

Very low-income households cannot afford market-rate rental or ownership housing in Brentwood without a substantial cost burden.

Low-Income Households
For a low-income household that earns between 51 percent and 80 percent of the County’s MFI the maximum affordable home price for ownership is up to $222,000 for a zero-bedroom unit and up to $374,000 for a five-bedroom unit in 2022. Generally, market-rate rental would be affordable to 5-person households but remain generally unattainable to smaller household sizes. Low-income households would not be able to afford ownership housing.

Moderate-Income Households
Households of moderate-income earn between 81 percent and 120 percent of the County’s MFI. The maximum affordable home price for a moderate-income household is $472,000 for a zero-bedroom unit and $789,000 for a five-bedroom unit. Moderate-income households can generally find affordable market-rate rental units in the City. Ownership housing in Brentwood is generally not affordable to any household sizes that are not considered above moderate-income.

Brentwood 2023-2031 Housing Element
Section 2: Community Profile 2-33
Table 2-36: Affordable Housing Price for Owner-Occupied Households in Brentwood (2022-2023) Area Median Income Mortgage Utilities Tax and
Insurance (1)
Total Affordable
Monthly Cost
Affordable
Purchase Price
Very Low-Income (50% of AMFI)
0 Bedrooms $99,950 $661 $169 $420 $1,250 $136,000
1 Bedroom $114,250 $786 $182 $460 $1,428 $162,000
2 Bedrooms $128,500 $887 $225 $494 $1,606 $182,000
3 Bedrooms $142,800 $986 $270 $529 $1,785 $203,000
4 Bedrooms $154,200 $1,058 $318 $552 $1,928 $218,000
5 Bedrooms $165,650 $1,125 $364 $581 $2,070 $231,000
Low-Income (80% AMFI)
0 Bedrooms $99,950 $1,078 $169 $502 $1,749 $222,000
1 Bedroom $114,250 $1,264 $182 $553 $1,999 $260,000
2 Bedrooms $128,500 $1,424 $225 $600 $2,249 $293,000
3 Bedrooms $142,800 $1,583 $270 $646 $2,499 $326,000
4 Bedrooms $154,200 $1,702 $318 $679 $2,699 $350,000
5 Bedrooms $165,650 $1,818 $364 $717 $2,899 $374,000
Moderate Income (120% AMFI)
0 Bedrooms $99,950 $2,297 $169 $741 $3,207 $472,000
1 Bedroom $114,250 $2,656 $182 $828 $3,666 $546,000
2 Bedrooms $128,500 $2,991 $225 $908 $4,124 $615,000
3 Bedrooms $142,800 $3,323 $270 $989 $4,582 $684,000
4 Bedrooms $154,200 $3,581 $318 $1,049 $4,948 $737,000
5 Bedrooms $165,650 $3,838 $364 $1,114 $5,316 $789,000

1. Includes: Assessment District Taxes, HOA Dues, Property Taxes, and Property Insurance.

Source: City of Brentwood – July 2022-June 2023 Affordable Sales Price for Owner-Occupied Households at Very Low, Low and Moderate Income Levels Report

Brentwood 2023-2031 Housing Element
Section 2: Community Profile 2-34
Table 2-37: Affordable Monthly Housing Cost for Renters in Contra Costa County (2021) Annual Income Rent Utilities (1)
Total Affordable
Monthly Cost
Very Low-income (50% of AMFI)
1-Person $47,950 $1,045 $154 $1,199
2-Person $54,800 $1,204 $166 $1,370
3-Person $61,650 $1,334 $207 $1,541
4-Person $68,500 $1,464 $249 $1,713
5-Person $74,000 $1,554 $296 $1,850
Low-Income (80% AMFI)
1-Person $76,750 $1,765 $154 $1,919
2-Person $87,700 $2,027 $166 $2,193
3-Person $98,650 $2,259 $207 $2,466
4-Person $109,600 $2,491 $249 $2,740
5-Person $118,400 $2,664 $296 $2,960
Moderate Income (120% AMFI)
1-Person $105,500 $2,484 $154 $2,638
2-Person $120,550 $2,848 $166 $3,014
3-Person $135,650 $3,184 $207 $3,391
4-Person $150,700 $3,519 $249 $3,768
5-Person $162,750 $3,773 $296 $4,069

1. Utilities includes electric cooking, heating, water heating; basic electric; water; trash; air conditioning; refrigerator.

Source: 2021 Housing Authority of the County of Contra Costa Utility Allowance Schedule and California Department of Housing and Community Development, 2021 Income Limits and Kimley Horn and Associates Assumptions: 2021 HCD income limits; 30% gross household income as affordable housing cost. Utilities based on Housing Authority of the County of Contra Costa Utility Allowance.

Brentwood 2023-2031 Housing Element
Section 3: Housing Constraints, Resources, and Fair Housing 3-0 Housing Constraints, Resources, and Fair Housing
Section 3

Brentwood 2023-2031 Housing Element
Section 3: Housing Constraints, Resources, and Fair Housing 3-1 Section 3 Contents
A. Housing Constraints

1. Nongovernmental Constraints
Land Costs and Construction Costs
Availability of Financing
Economic Constraints

2. Governmental Constraints
Land Use Controls
Variety of Housing Types Permitted
Residential Development Standards
Planned Development Zones
Local Ordinances
Specific Plans
On-/Off-Site Improvements
Development Fees
Local Processing and Permit Procedures

3. Infrastructure Constraints
Dry Utilities
Water Supply
Fire and Emergency Services
Police Services

4. Environmental Constraints
Geological and Seismic Hazards
Flood Hazards
Fire Hazards
Toxic Hazards
Summary of Constraints
B. Financial Resources

1. Section 8 Housing Choice Vouchers

2. Community Development Block Grants
(CDBG)

3. HOME Investment Partnership Program

4. Local Early Action Planning (LEAP) Grant

5. SB 2 Grant

6. City of Brentwood Housing Trust Fund
C. Opportunities for Energy Conservation

1. Energy Use and Providers

2. Energy Conservation
D. Affirmatively Furthering Fair Housing (AFFH)

1. Assessment of Fair Housing Issues
Fair Housing Enforcement and Outreach
Fair Housing Laws
Integration and Segregation
Racially and Ethnically Concentrated Areas
Access to Opportunities
Disproportionate Needs
Resources for Special Needs Households
Senate Bill 330 (SB 330)

2. Assessment of Contributing Factors
Current Local Contributing Factors
AFFH Findings and Sites Summary
A. Housing Constraints
There are a number of potential factors that may affect the provision of adequate housing or access to opportunities for current and future residents in the City of Brentwood. These factors may include governmental and nongovernmental constraints, such as:
 Nongovernmental Constraints:
o Land costs
o Constructions costs
o Availability of financing
 Governmental Constraints:
o Land use controls
o Development standards
o Permitting processes and fees
o Local ordinances
 Infrastructure Constraints:
o Dry utilities
o Water supply
o Fire and emergency services
o Police Services
 Environmental Constraints:
o Geologic hazards
o Flood hazards
o Fire hazards
Combined, these factors may create barriers for current and future residents to access adequate and affordable housing options, especially for low- and moderate-income households.

Brentwood 2023-2031 Housing Element
Section 3: Housing Constraints, Resources, and Fair Housing 3-2

1. Nongovernmental Constraints
Nongovernmental constraints largely affect the cost of housing in Brentwood and can produce barriers to housing production and affordability. These constraints may include real wages, the availability and cost of land for residential development, the demand for housing, financing and lending, construction costs, and the availability of labor, which can make it expensive for developers to build any housing and especially affordable housing. The following highlights the primary market factors that affect the production of housing in the City of Brentwood.

Land Costs and Construction Costs
Construction costs vary widely according to the type of development, with multi-family housing generally less expensive to construct than single-family homes. However, there is wide variation within each construction type, depending on the size of the unit and the number and quality of amenities provided.

An indicator of construction costs is Building Valuation Data compiled by the International Code Council (ICC). The ICC updates the estimated cost of construction at six-month intervals and provides estimates for the average cost of labor and materials for typical Type VA wood-frame housing. Estimates are based on “good-quality” construction, providing for materials and fixtures well above the minimum required by state and local building codes. In August 2021, the IC estimated that the average per square-foot cost for good-quality housing was approximately $142.08 for multi-family housing, $157.66 for single-family homes, and $178.22 for residential care/assisted living facilities. Construction costs are also dependent upon materials and building height, as well as regulations set by the City’s adopted Building Code.

Although construction costs are a significant portion of the overall development cost, they are consistent throughout the region and, especially when considering land costs, are not considered a major constraint to housing production in Brentwood.

Land costs may also create a constraint to the development of affordable housing and represents a significant cost component in residential developments. Land costs may vary depending on whether the site is vacant or has an existing use that must be removed. Similarly, site constraints such as environmental issues (e.g., steep slopes, soil stability, seismic hazards, flooding) can be a factor in the cost of land. A March 2022 Zillow search for vacant lots sold between 2019 and 2022 returned approximately 50 lots ranging from 0.08 acres at $605,000 to 119 acres at $2,820,000. Based on the sale prices, the average lot size and cost per square foot was 8.65 acres and $46.04 per square foot. Table 3- 1 shows the acreage cost of vacant land in Brentwood compared to neighboring jurisdictions. In general, the cost of land in Brentwood does not create a constraint to the development of housing.

Availability of Financing
The availability of financing in a community depends on a number of factors, including the type of lending institutions active in a community, lending practices, algorithms, rates, and fees charged, laws and regulations governing financial institutions, and equal access to such loans. Additionally, availability of financing affects a person’s ability to purchase or improve a home. Under the Home Mortgage Disclosure Act (HMDA), lending institutions are required to disclose information on the disposition of loan applications and the income, gender, and race of loan applicants. The primary concern in a review of Table 3-1: Average Vacant Land Cost
Jurisdiction Lot Acreage Cost Per Square-Foot
Antioch 4.03 acres $68.87
Brentwood 8.65 acres $46.04
Oakley 14.75 acres $14.65
Pittsburg 0.47 acres $35.95
Source: Zillow.com (Accessed March 4, 2022).

Brentwood 2023-2031 Housing Element
Section 3: Housing Constraints, Resources, and Fair Housing 3-3 lending activity is to determine whether home financing is available to all residents of a community, regardless of income, sex, race, or ethnicity. The data presented in this section include the disposition of loan applications submitted to financial institutions for home purchase, home improvement, and refinancing in the San Jose-San Francisco-Oakland MSA/MD.

Table 3-2 below displays the disposition of loan applications for the San Jose-San Francisco-Oakland MSA/MD per the 2020 Home Mortgage Discloser Act report. According to the data, applications in the 100-119 percent of the MSA/MD median had the highest rates of loan approval. Within that income category, those who identify as White had the highest approval rates (74.5 percent), while those who identify as Native Hawaiian/Other Pacific Islander and Black or African American had the lowest rates (64.2 and 64.6 percent, respectively). This trend remains fairly similar in all income categories. According to the data, applicants who identify as White were on average more likely than other race/ethnicities to receive a loan approval. On average, applicants who identify as White have approval rates approximately 12 percent higher than the lowest approval rate of all Race or Ethnicity groups. Given the generally high rates of loan approvals, home financing is typically available and not considered to be a constraint to the provision and maintenance of housing in Brentwood.

Brentwood 2023-2031 Housing Element
Section 3: Housing Constraints, Resources, and Fair Housing 3-4 Table 3-2: Disposition of Loan Applications by Race/Ethnicity – San Jose-San Francisco-Oakland MSA/MD.

Applications by Race/Ethnicity Percent
Approved
Percent
Denied
Percent
Other(1)
Total (Count)
LESS THAN 50% OF MSA/MD MEDIAN
American Indian and Alaska Native 36.4% 36.4% 30.6% 121 Asian 45.5% 31.0% 25.3% 3320
Black or African American 44.9% 28.9% 28.9% 1260
Native Hawaiian or other Pacific Islander 44.9% 30.7% 24.4% 127 White 50.3% 25.3% 28.0% 7678
Hispanic or Latino 44.2% 30.7% 28.1% 2509
50-79% OF MSA/MD MEDIAN
American Indian and Alaska Native 53.3% 19.6% 31.5% 184 Asian 66.2% 14.7% 24.9% 7727
Black or African American 59.6% 17.9% 26.0% 2515
Native Hawaiian or other Pacific Islander 58.8% 18.4% 24.8% 294 White 68.2% 12.0% 24.6% 16372
Hispanic or Latino 62.8% 15.4% 26.3% 5994
80-99% OF MSA/MD MEDIAN
American Indian and Alaska Native 66.2% 21.6% 16.2% 74
Asian 69.8% 11.0% 22.4% 3236
Black or African American 63.6% 14.3% 24.8% 819
Native Hawaiian or other Pacific Islander 61.5% 15.6% 24.8% 109 White 71.3% 9.4% 21.5% 6573
Hispanic or Latino 66.7% 12.0% 23.9% 1933
100-119% OF MSA/MD MEDIAN
American Indian and Alaska Native 64.2% 17.3% 21.4% 173 Asian 72.2% 9.1% 21.6% 11974
Black or African American 64.6% 14.2% 23.8% 2258
Native Hawaiian or other Pacific Islander 70.0% 10.8% 21.2% 297 White 74.5% 7.7% 20.4% 18195
Hispanic or Latino 68.1% 11.7% 22.9% 4327
120% OR MORE OF MSA/MD MEDIAN
American Indian and Alaska Native 65.8% 11.5% 23.3% 330 Asian 71.4% 7.8% 23.5% 50498
Black or African American 63.9% 12.9% 26.8% 3508
Native Hawaiian or other Pacific Islander 66.0% 11.8% 24.6% 483 White 73.4% 7.3% 22.5% 50678
Hispanic or Latino 67.3% 10.2% 26.4% 5862
Notes: 1. “Other” includes: applications withdrawn, files closed for incompleteness, and purchased loans.

Source: Consumer Financial Protection Bureau, Disposition of loan applications, by Ethnicity/Race of applicant, 2020.

Brentwood 2023-2031 Housing Element
Section 3: Housing Constraints, Resources, and Fair Housing 3-5 Economic Constraints
Market forces on the economy and the trickle-down effects on the construction industry can act as a barrier to housing construction and especially to affordable housing construction. It is estimated that housing price growth will continue in the City and the region for the foreseeable future. Moving into 2020, the economy was growing, California was seeing a 1.6 percent growth in jobs from 2019 and experiencing all-time lows for unemployment rates. The COVID-19 pandemic had stalled much of the economy in early 2020; however, as Figure 3-1 shows, the Brentwood housing market has maintained overall growth.

Figure 3-2 shows a decline in number of homes sold in Brentwood which may indicate a lack of inventory which contributes to higher median sale prices.

Figure 3-1: Brentwood Housing Market Trends – Median Sale Price 2019-2022 Source: Redfin, Brentwood Housing Market Trends (Accessed March 4, 2022).

Figure 3-2: Brentwood Housing Market Trends – Number of Homes Sold 2019-2022 Source: Redfin, Brentwood Housing Market Trends (Accessed March 4, 2022).

Brentwood 2023-2031 Housing Element
Section 3: Housing Constraints, Resources, and Fair Housing 3-6 A January 2022 California Association of Realtors (CAR) report found that single-family homes on the market in Contra Costa County had a median cost of $829,000 and experienced a year-to-year change of

8.4 percent. Single-family homes on the market in the San Francisco Bay Area had the highest median cost in the State of California at $1,200,000. Single-family homes in Contra Costa County had a median cost of $765,580.

According to a CAR First-Time Buyer Housing Affordability Index report for the fourth quarter of 2021, the median home price for a single-family home in Contra Costa County was $739,500 with monthly payments of $3,490 (including taxes and insurance). This required a minimum qualifying income of $104,700. In comparison, the median cost for a single-family home in California was $677,850 with monthly payments of $3,200 and a minimum qualifying income of $96,000.

2. Governmental Constraints
In addition to market constraints, local policies and regulations also affect the price and affordability of housing and the provision of affordable housing. Policies and regulations may make it difficult to meet the demand for affordable housing and limit supply in the region. Regulations related to environmental protection, building codes, and other topics may have significant, often adverse, impacts on housing cost and affordability.

While the City of Brentwood has no control over State and Federal policies and regulations that affect housing, the City’s Housing Element can address local policies and regulations which create a constraint on the development of housing, and particularly affordable housing.

Land Use Controls
Jurisdictions in California are required by Law to prepare a comprehensive, long-term General Plan to guide future development. The Land Use Element of the General Plan establishes permitted land uses and development density throughout the City of Brentwood. These land uses provide a wide variety of housing types throughout the City, while also ensuring compatibility between neighboring uses. Table 3-3 lists the land uses that permit residential developments and their density ranges – this information is readily available on the City’s website, in compliance with State transparency requirements.

Brentwood 2023-2031 Housing Element
Section 3: Housing Constraints, Resources, and Fair Housing 3-7 The City’s Zoning Code establishes the following residential zone districts:
 Ranchette Estate (RE) - The purpose of the Ranchette Estate zone is to provide semirural residential areas to serve as a buffer or transition between higher density urban residential development and productive agricultural uses or adjacent urban communities. The RE zone provides areas where single-family residences and facilities for limited numbers of livestock and small farming operations may be located. The RE zone permits a maximum of 1 single-family dwelling per parcel.
 Single-Family Residential Estate (R-1-E) - The purpose of the Single-Family Residential Estate zone is to provide for large single-family residential parcels in an identifiable, suburban residential neighborhood. The R-1-E zone provides areas where single-family residences and common facilities for large livestock may be located if planned and provided for within the design of the subdivision and approved by the City. The R-1-E zone permits single-family dwelling units not exceeding a density of two dwelling units per gross acre.  Single-Family Residential (R-1) - The purpose of the Single-Family Residential zone is to provide areas for three-and-one-half dwelling units per gross acre and areas of different lot sizes through the use of the R-1-6, R-1-8, R-1-10 and R-1-12 subzones and the specific regulations for each subzone as specified in this chapter.
 Moderate Density Multifamily Residential (R-2) - The purpose of the Moderate Density Multifamily Residential zone is to encourage the development of more affordable and innovative housing primarily for duplexes, triplexes, townhouses and single-family attached or detached homes on smaller lots. The R2 zone permits duplex, triplex, apartments and other small multifamily structures; townhouses and single-family attached homes; all not exceeding a density of nine dwellings per gross acre.
 High Density Multifamily Residential (R-3) - The purpose of the High Density Multifamily Residential zone is to provide appropriate areas for apartments or condominiums in close proximity to the central business district. The R-3 zone permits duplex, triplex, townhouses, apartments and other multifamily structures not exceeding a density of sixteen dwelling units per gross acre.

Table 3-3: Residential Land Uses and Density Ranges
General Plan Land Uses Density Range Mid-Range*
Ranchette Estate (RE) < 1 unit/acre N/A
Residential Very Low Density (R-VLD) 1.1 – 3 units/acre 2 units/acre Residential Low Density (R-LD) 1.1 – 5 units/acre 3 units/acre Residential Medium Density (R-MD) 5.1 – 11 units/acre 8 units/acre Residential High Density (R-HD) 11.1 – 20 units/acre 15.5 units/acre Residential Very High Density (R-VHD) 20.1 – 30 units/acre N/A *Densities above the mid-range can be achieved at the discretion of the City Council through the exercise of transferable agricultural credits or if a significant amount of amenities are incorporated into a project, extensive off-site public improvements are installed, or other significant improvements of community-wide benefit are provided.

Residential development proposals that provide at least 20% of its units affordable to lower income households, as defined by State law and the City's Housing Element, are exempt from the mid-range requirement and may develop at the high point of the density range, provided that an agreement is recorded with the City insuring affordability "overtime". In addition, senior, disabled, and multi-family housing projects which set aside 10-25% of the units for lower income households (as defined by the City's Housing Element) are permitted to develop up to 25% above the high point of the designated density range in accordance with the City's density bonus ordinance.

Action H.1t is included in the Housing Plan to remove discretion or constraints for projects requesting densities above the mid-point for all residential land use categories.

Source: City of Brentwood General Plan, Land Use Element.

Brentwood 2023-2031 Housing Element
Section 3: Housing Constraints, Resources, and Fair Housing 3-8 In addition to the identified primary residential use zones, the City allows mixed-use residential development in other districts in order to increase development near transit corridors and essential resources. The following districts permit mixed-use residential uses:
 Commercial Office Residential (COR) - The Commercial Office Residential zone is a mixed-use zone allowing administrative and professional offices in conjunction with residential uses. This mix of uses may be separate buildings on one site or separate areas in a building (such as ground floor professional/administrative offices with apartments above). The primary use of the site shall be devoted to office usage and residential densities may be within any of the residential density ranges of the Land Use Element.
 Commercial Residential (CR) - The Commercial Residential zone is a mixed-use zone allowing commercial as the primary use and residential as a permitted, optional secondary use. This mix of uses may be separate buildings on one site or separate areas in a building (such as appropriate ground floor shops and offices with apartments above). Densities may be within any of the residential density ranges of the Land Use Element.
 Brentwood Boulevard (BB) – The purpose and intent of the Brentwood Boulevard zone is to transform the auto-oriented former State Route 4 corridor into a more traditional boulevard with distinctive, unique, front-facing buildings as reflected in the Brentwood Boulevard specific plan (BBSP). The BBSP also promotes comfortable walkways and generous landscaping to provide an active, inviting, and attractive location for residents, workers, and visitors. Brentwood Boulevard within the boundaries of the BB zone is a distinguished portion of the city that extends between the city limits at Delta Road on the north and the downtown at Second Street on the south. The BBSP provides for a cohesive arrangement of uses, building types, frontage treatments, and street designs that function as integral parts of a single urban structure. Taken together, the expectation is that the structure over time will result in an area comprised of an attractive and desirable streetscape environment along which well-designed buildings are located behind generous amounts of continuous landscaping and open space. The result is a prominent setting for new development and a framework for new neighborhood and workplace districts along one of the city’s most visible corridors.
 Priority Area One (PA-1) – The Priority Area One zone is a mixed-use zone and one of the City’s primary future employment centers, offering individuals and businesses access and opportunities to create high-quality jobs across a diverse array of industries. The PA-1 zone will assist the City towards achieving its goal of a healthy jobs-to-housing balance, reducing commute times for residents, and establishing new opportunities for economic growth and employment within the city.

Variety of Housing Types Permitted
California Housing Element Law mandates jurisdictions must make sites available through zoning and development standards to promote the development of a variety of housing types for all socioeconomic levels of the populations. Housing types include single-family homes, multi-family housing, accessory dwelling units, factory-built homes, mobile-homes employee and agricultural work housing, transitional and supportive housing, single-room occupancy (SROs), and housing for persons with disabilities. Table 3- 4 shows the various housing types permitted throughout the City of Brentwood in zoning districts which permit housing or care facility uses. The City of Brentwood is in compliance with all transparency requirements and all zoning information, development standards, and fees are available on the City’s website and at the Planning Department Counter.

Brentwood 2023-2031 Housing Element
Section 3: Housing Constraints, Resources, and Fair Housing 3-9 Table 3-4: Permitted Residential Uses by Zoning District Residential Uses RE R-1-E R-1 R-2 R-3 COR CR BB PA-1 A-10 A-20 AP Single-Family P P P P P C C SP1 SP2 P P P
Manufactured Homes P P P P P C C SP SP P P P
Accessory Dwelling Unit P P P P P C C SP SP P P P
Duplex, Triplex, Apartments - - - P P C C SP SP - - -
Small Multifamily Structures - - - P P C C SP SP - - -
Multifamily Structures - - - C P C C SP SP - - -
Senior Housing C C SP SP
Secondary Housing Units C C C P P C C SP SP C C C
Mobile Home Parks C C C C C C C SP SP - - -
Subdivisions3 - C C P P C C SP SP - - -
Small Residential Care Facilities4 P P P P P C C SP SP P P P Large Residential Care Facilities5 C C C C C C C SP SP C C C Rooming and Boarding - - - P P C C SP SP - - -
Emergency Shelters6- - - - - - - SP SP - - -
Transitional Housing P P P P P C C SP SP - - -
Supportive Housing P P P P P C C SP SP - - -
Single Room Occupancy - - - - - C C SP SP - - -
Farmworker Housing - - - - - - - - - - - -
Low Barrier Housing - - - - - - - - - - - -
P – Permitted
(-) – Not Permitted
C – Conditionally Permitted
SP – Specific Plan
Notes:

1. Detached single-family units are prohibited within 150 feet of the Brentwood Boulevard right-of-way

2. Only allowed in High Density Residential area

3. Subdivisions having a reduced lot size, patio houses, row houses, apartments and similar housing developments provided as follows: 1) The entire parcel or a group of parcels are master planned, 2) any increases in density are offset by lessor densities or greater lot sizes within the development or through the provision of permanent open space so that the overall density is within the range of 1.1 to six dwelling units per gross acre.

4. Includes any small family home—adults, social rehabilitation center—small, small family day home—adults or family day care—small

5. Includes any large family home—adults, group home—children or adults, social rehabilitation center—large, day care center—adults or children.

6. Emergency Shelters are permitted in subarea C of PD-38.

Source: City of Brentwood Municipal Code

Brentwood 2023-2031 Housing Element
Section 3: Housing Constraints, Resources, and Fair Housing 3-10 Single-Family Dwelling
A single-family dwelling is defined as a detached building designed for and/or used exclusively for residence purposes by one family. An attached single-family dwelling is defined as a building designed for and/or used exclusively for residence purposes by one family and joined structurally along a common wall and property line to another like dwelling unit. Single-family dwellings are permitted as a primary use in RE, R-1-E, R-1, R-2, R-3, A-10, A-20, and AP zones. Detached single-family dwellings are prohibited within 150 feet of the Brentwood Boulevard right-of-way but attached single-family dwellings are allowed.

Single-family dwellings are allowed with a CUP in the COR and CR zones.

Multiple-Family Dwelling
A multiple-family dwelling is defined as a building or portion thereof designed for and/or used exclusively for residence purposes by two or more families living independently of one another to include the terms duplex, triplex, and apartment. Small multi-family dwellings such as Duplex, Triplex, and Apartments are permitted as a primary use in R-2, R-3, BB, and PA-1 zones. Small multi-family dwellings such as Duplex, Triplex, and Apartments are allowed with a CUP in the COR and CR zones. Multi-family structures are permitted as a primary use in R-3, BB, and PA-1 zones. Multi-family structures are allowed with a CUP in R-2, COR, and CR zones.

Accessory Dwelling Unit (ADU)
An accessory dwelling unit is defined as an attached or detached residential dwelling unit that provides complete independent living facilities for one or more persons and is located on a parcel with a proposed or existing primary dwelling. It shall include permanent provisions for living, sleeping, eating, cooking, and sanitation on the same parcel as the single-family or multifamily dwelling is or will be situated. An accessory dwelling unit also includes the following:

1. An efficiency unit, as defined in Section 17958.1 of the California Health and Safety Code; and

2. A manufactured home, as defined in Section 18007 of the California Health and Safety Code.

Accessory Dwelling Units are permitted as a primary use in in RE, R-1-E, R-1, R-2, R-3, PA-1 A-10, A-20, and AP zones. Accessory Dwelling Units are allowed with a CUP in the COR and CR zones. A program is included in Section 4: Housing Plan to review and, as necessary, amend the ADU ordinance to comply with State law.

Manufactured Home, Mobile Home, Modular Home
Manufactured homes, mobile homes or modular homes are defined as a single-family housing units, which are commonly referred to as mobile homes, manufactured homes or modular homes, and which are certified under the National Mobile Home Construction and Safety Standards Act of 1974, and which are to be placed on a foundation system, pursuant to Section 18551 of the Health and Safety Code or constructed in accordance with the appropriate Uniform Building Code, Plumbing Code, Electrical Code, etc., that has been adopted and is in effect within the City of Brentwood. Manufactured Homes, Mobile Homes, and Modular Homes are permitted as a primary use in RE, R-1-E, R-1, R-2, R-3, A-10, A-20, and AP zones. Manufactured Homes, Mobile Homes, and Modular Homes are allowed with a CUP in the COR and CR zones.

Mobile Home Park
A group home is defined as any area or tract of land where two or more mobile home lots are rented or leased or held out for rent or lease to accommodate mobile homes used for human habitation. The rental paid for any such mobile home shall be deemed to include rental for the lot it occupies. Mobile Home Parks are allowed with a CUP in RE, R-1-E, R-1, R-2, R-3, COR, and CR zones.

Brentwood 2023-2031 Housing Element
Section 3: Housing Constraints, Resources, and Fair Housing 3-11 Residential Care Facility
A small residential care facility is defined as any small family home used as a social rehabilitation center or adult or family day care. A large residential care facility is defined as any large family home used as an adult or child group home, social rehabilitation center, and adult or child day care center. Small Residential Care Facilities are permitted as a primary use in RE, R-1-E, R-1, R-2, R-3, BB, and AP A-10, A-20, and PA-1 zones. Small Residential Care Facilities are allowed with a CUP in the COR and CR zones. Large Residential Care Facilities are allowed with a CUP in RE, R-1-E, R-1, R-2, R-3, COR, CR, BB, PA-1, A-10, A-20, and AP zones. Action H.4o is included in the Housing Plan to revise these current permitting requirements for large residential care facilities to remove potential constraints.

Supportive Housing
Supportive Housing is defined as housing with no limit on length of stay, that is occupied by the target population, and that is linked to on-site or off-site services that assist the supportive housing resident in retaining the housing, improving his or her health status, and maximizing his or her ability to live and, when possible, work in the community. Supportive housing is considered a residential use and is subject only to the restrictions and standards that apply to other residential dwellings of the same type (e.g., single-family residence(s) or multifamily development) in the same zone. Supportive Housing is permitted as a primary use in RE, R-1-E, R-1, R-2, R-3, and PA-1 zones. Supportive Housing is allowed with a CUP in the COR and CR zones.

Transitional Housing
Transitional Housing is defined as buildings configured as rental housing developments but operated under program requirements that call for the termination of assistance and recirculation of the assisted unit to another eligible program recipient at some predetermined future point in time, which shall be no less than six months. Transitional housing is considered a residential use and is subject only to the restrictions and standards that apply to other residential dwellings of the same type (e.g., single-family residence(s) or multifamily development) in the same zone. Transitional Housing is permitted as a primary use in RE, R-1-E, R-1, R-2, R-3, and PA-1 zones. Transitional Housing is allowed with a CUP in the COR and CR zones.

Emergency Shelter
An emergency shelter is defined as housing with minimal supportive services for homeless persons that is limited to occupancy of six months or less by a homeless person. No individual or household may be denied emergency shelter because of an inability to pay.

In 2015, the City adopted a chapter in the Zoning Code addressing emergency shelters. An amendment to the Planned Development 38 Zone (PD-38) now allows emergency shelters as a permitted use within Subarea C of the zone. There are three parcels within Subarea C, covering approximately 17 acres. The parcels sizes are 0.47, 4.53, and 12.0 acres respectively. Of the three parcels, two are currently vacant and cumulatively total five acres. All Planned Development 38 zoning districts and Subareas are reflected in Figure 3-3. Per AB 2339 requirements, the City must show existing capacity for the current Brentwood homeless population. The 2023 Point-in-Time count reports 37 persons experiencing homelessness in Brentwood (a decrease of approximately 46 percent from 2021). With a requirement of at least 200 square feet of land per person, the City is able to accommodate the 7,400 square-foot need with the available 17 acres noted above – 5 acres of which are currently vacant. Program H.4k is included in the Housing Plan to amend the Municipal Code in compliance with AB 139 and AB 2339.

The City currently has one privately run women and children’s shelter with ten bedrooms, and it is currently in the review pipeline to add an additional three independent living units on-site to transition out.

Brentwood 2023-2031 Housing Element
Section 3: Housing Constraints, Resources, and Fair Housing 3-12 The City’s Zoning Code states that an emergency shelter must meet the standards set forth in Chapter

17.770 “Emergency Shelters” and must be approved ministerially and without discretionary review or a public hearing when proposed within a permitted zone. All new construction must comply with the commercial and industrial land use regulations for the underlying district in which the emergency shelter will be located. Construction of a new structure or exterior modification of an existing structure for an emergency shelter must also be subject to a ministerial design review process. The City’s Zoning Code requires each emergency shelter have a minimum of two off-street parking spaces plus one additional offstreet parking space for each ten beds, or fraction thereof.

Figure 3-4 shows the location of hazardous waste generators and hazardous waste percentile for the region surrounding the PD-38 zoning district. According to CalEnviroScreen 4.0, this indicator is calculated by considering the number of permitted Treatment, Storage and Disposal Facilities (TSDFs), generators of hazardous waste or chrome plating facilities, the weight of each generator or site, and the distance to the census tract. The figure shows the hazardous waste generators located near the PD-38 zoning district. As of May 2022, these generators include Walgreens Pharmacy (which disposed of hazardous waste into company trash bins between 2013 and 2020 that were going to municipal landfills not authorized to accept hazardous waste. The items included over-the-counter and prescription medication, electronic devices, batteries, aerosol products, and cleaning agents), Target (which had improper storage, transportation and disposal of bleach, paint, pesticides, batteries, lightbulbs, and other hazardous materials in the past), and Banfield Pet Hospital.

Figure 3-5 shows the location of cleanup sites and cleanup site percentile for the region surrounding the PD-38 zoning district. According to CalEnviroScreen 4.0, this indicator is calculated by considering the number of cleanup sites including Superfund sites on the National Priorities List (NPL), the weight of each site, and the distance to the census tract. The figure shows one cleanup site located in Subarea C of the PD-38 zoning district. As of May 2022, the potential contaminants of concern are Benzene, Bromodichloromethane, and Chloroform in the soil and soil vapor. The site was an orchard from 1939 to the 1970s. The Sun Recycling Center was formerly located on the western portion of the site but has since been demolished.

Brentwood 2023-2031 Housing Element
Section 3: Housing Constraints, Resources, and Fair Housing 3-13 Figure 3-3: Brentwood Zoning Map – Planned Development 38 Zoning District (PD-38) Source: City of Brentwood Zoning Map

Brentwood 2023-2031 Housing Element
Section 3: Housing Constraints, Resources, and Fair Housing 3-14 Figure 3-4: CalEnviroScreen 4.0 – Hazardous Waste
Source: CalEnviroScreen 4.0
Figure 3-5: CalEnviroScreen 4.0 – Cleanup Sites
Source: CalEnviroScreen 4.0

Brentwood 2023-2031 Housing Element
Section 3: Housing Constraints, Resources, and Fair Housing 3-15 Additionally, the PD-38 district is located near existing commercial and retail resources, as well as existing public transportation routes. Figure 3-6 shows the Tri Delta Transit routes located near the PD-38 zoning district and the transit routes and stops running through the area. As the figure shows, the PD-38 zoning district and potential emergency shelter occupants are located within a short distance to public transportation with destinations throughout the City and the Bay Area region.

Brentwood is served primarily by the Tri Delta Transit (Eastern Contra Costa Transit Authority). Tri-Delta Transit provides local public transportation. Besides Brentwood, the buses stop in Antioch, Oakley, Bay Point, Pittsburg, Martinez, and Concord. The transit authority operates local and express routes on weekdays, and local routes on weekends/holidays. Major transfer points for majority of Tri Delta Transit’s routes include:
 Brentwood Park & Ride in Brentwood
 Antioch eBART Station in Antioch
 Pittsburg Center BART Station in Pittsburg
 Pittsburg/Bay Point BART Station in Pittsburg
 Los Medanos College in Pittsburg
Tri Delta Transit routes allow Brentwood residents access to the Bay Area region via BART. Tri Delta Transit operates 20 bus lines at different times. On weekdays, 16 bus lines operate throughout the cities of Pittsburg, Antioch, Oakley, Brentwood, and far-west of Martinez, California. On weekends, only 5 bus lines operate throughout cities of Pittsburg, Antioch, Oakley, and Brentwood only. Weekend bus-lines tend to be longer to cover segments of many weekday-bus lines.

Future transportation proposals would facilitate increased accessibility to the rest of the region. An eBART expansion has been considered in the City and would help connect Brentwood to the greater BART system.

The potential eBART station locations have been discussed with the City focusing on a newly designated location with PA-1.

Brentwood 2023-2031 Housing Element
Section 3: Housing Constraints, Resources, and Fair Housing 3-16 Figure 3-6: Transit Routes – Tri Delta Transit System Map Source: 511 Tri Delta Transit – System Map

Brentwood 2023-2031 Housing Element
Section 3: Housing Constraints, Resources, and Fair Housing 3-17 Farmworker 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. A program is included in Section 4: Housing Plan to ensure the City’s development standards allow farmworker housing by-right, without a CUP, in single-family zones for six or fewer persons, as well as employee housing consisting of no more than 12 units or 36 beds in the same manner as other agricultural uses in the same zone.

Low Barrier Navigation Centers
AB 101 states that “Legislature finds and declares that low barrier navigation center developments are essential tools for alleviating the homelessness crisis in this state and are a matter of statewide concern.” Low barrier navigation centers are defined as a Housing First, low-barrier, service-enriched shelter focused on moving people into permanent housing that provides temporary living facilities while case managers connect individuals experiencing homelessness to income, public benefits, health services, shelter, and housing. Low barrier navigation centers are required as a use by-right in areas zoned for mixed uses and nonresidential zones permitting multifamily uses if it meets specified requirements. The Brentwood Zoning Code does not address low barrier navigation centers by definition. A program is included in Section 4: Housing Plan to adopt and implement procedures and regulations to process low-barrier navigation centers, including establishing a ministerial approval process.

Residential Development Standards
The City’s Zoning Code establishes regulations and development standards for each residential district to provide a range of housing types. All information regarding the City’s zoning and development standards are available to the public on the Brentwood City website pursuant to Government Code §65940.1 (a)(1)(B).

These standards and regulations are intended to create, preserve, and enhance residential neighborhood sites for a range of development types and lifestyles. The residential zoning guidelines and development standards are intended to:
 Provide appropriately located areas for a variety of residential neighborhoods to meet the housing needs of the Brentwood community;
 Provide for a range of housing types and housing alternatives for all economic segments of the community;
 Encourage the provision of attractive and stimulating surroundings that will make Brentwood’s residential areas enjoyable places to live; and
 Protect residential areas from the intrusion of incompatible uses or activities which may impair the livability of a neighborhood.

The City established development standards to regulate development throughout the City through its Zoning Code. The development standards include minimum requirements for lot size and lot widths and maximum construction standards for height, lot coverage, and density. Table 3-5 below provides the standards applicable to each zoning district in Brentwood that permits residential development.

Brentwood 2023-2031 Housing Element
Section 3: Housing Constraints, Resources, and Fair Housing 3-18 Table 3-5: Brentwood Development Standards - Dimensions Zone
Min. Dimensions
(Sq. Ft.) Min. Yard Setbacks (Feet) Construction Standards Lot Size 1
Lot
Width1
Front Side 2 Rear
Max.

Height
(Feet)
Max. Lot
Coverage
(Percent)
Min.

Density
RE 43,560/ac 140 20 20 40 35 -- 1 du/ac
R-1-E 14,500 100 20 153 30 35 -- 2 du/ac
R-1 -- -- -- -- -- -- -- 3.5 du/ac
R-1-6 6,000 60 20 153 20 35 -- 3.5 du/ac
R-1-8 8,000 70 20 203 20 35 -- 3.5 du/ac
R-1-10 10,000 80 20 253 20 35 -- 3.5 du/ac
R-1-12 12,000 90 20 303 20 35 -- 3.5 du/ac
R-2 -- -- -- -- -- -- -- 2 du/ac
Apartment 6,000 50 15 153 20 30 -- 2 du/ac
Single-Family 3,700 37.5 20 123 20 30 -- 2 du/ac
Apartments
and attached
single-family
dwellings
6,000 50 15 153 20 30 40% 2 du/ac
R-3 6,000 70 10 153 20 36 40% 4 du/ac
COR 7,500 50 10 20 20 35 49% 4
CR 43,560/ac5 -- 10 10 10 30 49% 4
BB6 2,000 -- 10 0 10 40 80% 5 du/ac
PA-17 1,600 25 10 5 20 35 80% 10 du/ac
PEC8-- -- -- -- -- -- 49% --
A-10 10 acres 300 50 25 50 35 -- 1
du/parcel
A-20 20 acres 500 50 25 50 35 -- 1
du/parcel
AP 20 acres 500 50 25 50 35 -- 1
du/parcel

1. Standard

2. Interior side yard

3. Sum of both sides

4. Within any of the residential density ranges of the general plan land use element provided the entire parcel or a group of parcels are master planned

5. A master planned project may be subdivided into parcels having a minimum lot area of ten thousand square feet

6. Based on High Density Residential Development Standards in the Brentwood Boulevard Specific Plan

7. Based on High Density Residential Development Standards in the Priority Area 1 Specific Plan

8. According to adopted Specific Plan
Source: City of Brentwood Zoning Code

Brentwood 2023-2031 Housing Element
Section 3: Housing Constraints, Resources, and Fair Housing 3-19 Yard Requirements
The Brentwood Zoning Code defines a yard as an open area between a wall or other facility and the nearest lot line and measured perpendicular from the line, on a horizontal plane, to the wall of the facility; including the front yard, side yard and rear yard, or space between structures. The yard requirements as established in Table 3-5 above are not considered a constraint to the development of housing and are similar to that of the region.

Lot Coverage and FAR
The Brentwood Zoning Code defines lot coverage as the percentage of total site area covered by the main building and all accessory buildings, open or enclosed. Lot coverage is regulated in order to avoid nuisances from inappropriate and excessive massing or density in a particular zoning district. Floor area is defined as the entire floor area of a building. The floor area includes not only the ground floor area but also any additional stories or basement of the building. All horizontal dimensions shall be taken from the exterior faces of walls, including enclosed porches. The City does not set Floor Area Ratios (FAR) for standalone residential structures. This may however apply in certain planned and also mixed-use developments. FAR is the ratio of floor area to the total lot area and is used to limit the maximum floor area on a particular site. A 0.50 FAR for a 10,000 square foot lot would allow a 5,000 square foot building.

The FAR requirements limit the usable floor area to limit the bulk of a building in comparison to the land, other buildings, and public facilities in the area.

The lot coverage limits as established in Table 3-5 above are not considered a constraint to the development of housing and are similar to that of the region.

Maximum Building Heights
The building height refers to the vertical distance above the finish grade and is measured to the highest point of roof. The maximum building height in the residential zoning districts of Brentwood range from 30 feet to 36 feet and 30 feet to 45 feet in mixed-use projects. Setting limits to the height of buildings avoids bulking and potential nuisances on neighboring properties – relating to privacy and/or sunlight and shade.

This requirement also ensures a compatibility and similar aesthetic amongst uses. Residential developments in the R-2 and R-3 zones are able to meet the maximum density limit while complying with the height limits and the remaining development standards shown in Table 3-5. Specifically, a proposed 3-story multi-family development on a one-acre lot in the R3 zone can meet the setback and lot coverage requirements and be able to build approximately 16 units each measuring 1,000 square feet; as the maximum density is 16 dwelling units per acre, the maximum building height limits is shown not to impede the development of multi-family developments.

Parking Standards
Sufficient off-street parking must be provided to avoid street overcrowding. This is maintained through the establishment on parking requirements, which fluctuate depending on the land use/housing type and the number of bedrooms. Table 3-6 provides the parking requirements specific to the City of Brentwood.

Parking standards in Brentwood are similar, and less in certain instances, to that of the neighboring communities. Therefore, parking standards are not considered a constraint to development of residential projects.

Brentwood 2023-2031 Housing Element
Section 3: Housing Constraints, Resources, and Fair Housing 3-20 Table 3-6: Required Parking Spaces for Residential Uses Residential Uses Minimum Number of Spaces Required per Unit Single-Family Dwelling 2 spaces in garage
Accessory Dwelling Units 1 space per ADU with exceptions found in Zoning Code Article lll Chapter

17.100.005 Section 11.B
Multiple-Family Dwellings
Two- and ThreeFamily Dwellings 2 assigned spaces for each dwelling unit, all of which shall be covered
Four- and More
Family Dwellings
Parking shall be provided for each dwelling unit in
an apartment complex at a ratio of 1 assigned
space which shall be covered plus 1 common space
which may be uncovered
Condominium or Similar SingleFamily Residence Projects Two assigned spaces which shall be enclosed within a garage, and two common
Senior Housing (congregate care,
senior apartments, subsidized
housing, residential care)
Subject to conditional use permit approval
Emergency Shelters Minimum of two off-street parking spaces plus one additional off-street parking space for each ten beds, or fraction thereof
Other Parking Requirements
Mobile home
park
2 assigned spaces on each mobile home lot, 1 of
which shall be covered, plus 1 of which may be
covered, plus one common space for each 2
mobile home lots which may be uncovered
Boardinghouse
1 space for each sleeping unit plus the required
spaces for ancillary eating and drinking places,
places of assembly or retail trade
The City’s parking requirements fluctuate depending on land use and intensity. The minimum parking requirements in the R-3 zoning district for a 20-unit project on one acre is 20 covered parking spaces and 20 common space parking spaces which may be uncovered. Assuming a standard 9-foot by 18-foot parking space (162 square-feet per space), parking requirements total about 6,420 square-feet. Using the estimated cost of $46.04 per square-foot (based on the market analysis done above) parking for a 1-acre development in the R-3 zone can cost about $298,339.

City of Brentwood parking standards requires 20 parking spaces to be covered; construction costs can be higher for covered parking, parking structures, and/or below ground parking. The required parking standards are consistent or lower than neighboring jurisdictions but the cost of land in the City is more expensive than some surrounding jurisdictions. The cost of developing parking based on the City’s requirements for multi-family housing can be considered a constraint to the development of housing.

However, developers may receive concessions or incentives in the form of parking reduction for the development of housing affordable to low- and very low-income households as provided in the State Density Bonus Law section, as well as for development projects that are subject to the Affordable Housing Program.

The City has received feedback from HCD noting the current parking requirements for studios and onebedroom units may create a constraint for multifamily development projects. As such, Action H.1r in the Housing Plan establishes an objective for the City to adopt a Zoning Code update to decrease parking requirements to 1.5 spaces per one-bedroom unit and 0.5 spaces per studio.

Development Example
A theoretical parcel zoned R-3 measuring 6,000 square feet (75 feet wide and 80 feet deep) is permitted a maximum density of four units per 6,000-square-feet. With yard setbacks, the 6,000 square-foot parcel

Brentwood 2023-2031 Housing Element
Section 3: Housing Constraints, Resources, and Fair Housing 3-21 is left with a possible 2,250-square-foot building footprint. The maximum lot coverage is 40 percent (2,400 square feet), which leaves enough room. Assuming the maximum height of 36 feet creates a three-story structure, a total of 6,750 square feet are possible.

Parking standards for four permitted units would total 8 spaces, or 1,368 square feet (assuming each space measures nine feet by 19 feet). This would leave a total of 5,382 square feet for five 1,000-squarefoot units, or more smaller units. As such, the development standards do not constrain developments from reaching the maximum density limit.

Planned Development Zones
The Planned Development Zones (PD) are intended to encourage a mixture of uses and more flexibility and variation from that of established zones (unusual building intensity or design characteristics or variations in density, including density between the midrange and upper end of land use designated by the general plan which would not normally be permitted in a single use zone). The PD zones are used to implement specific plans by providing regulations for all or part of the area encompassed by each adopted specific plan – Planned Developments are optional and are not pre-zoned, nor are standards preestablished by the City. A PD Zone can be established on the following properties:
 Any property in the City at such time an application for rezoning for a PD zone is made and to any property for which PD zoning is approved; and
 To all or part of any area in the City for which a specific plan has been approved.

Any and all compatible uses are permitted within the zoning regulations adopted for the specific PD zone; provided, however, no use shall be authorized which does not conform to the community development plan of the City of Brentwood and to any applicable specific plan. The development regulations shall be specified within the regulations adopted for the specific PD zone. Deviation from those regulations shall be permitted only through a zoning amendment or the grant of a variance. There are currently 70 PD zones in the City.

All development standards, allowable densities, zoning, and any other relevant requirements are established during the adoption of the specific PD zone and are established with the intent of maximizing density in an effort to reduce cost and ensure feasibility. Rezoning for a PD zone requires the following findings:
 That the proposed development will clearly result in a more desirable use of land, and a better physical environment than would be possible under any single or combination of zones;  That the PD zone proposed is on property which has a suitable relationship to one or more thoroughfares; and that such thoroughfares are adequate to carry any traffic generated by the development;
 That the plan for the proposed development presents a unified and organized arrangement of buildings and service facilities which are appropriate in relation to adjacent or nearby properties and that adequate landscaping and/or screening is included if necessary to insure compatibility;  That the natural and scenic qualities of the site are protected, with adequate available public and private open spaces designated on the development plan;  That the development of the subject property, in the manner proposed by the applicant, will not be detrimental to the public welfare, will be in the best interests of the city and will be in keeping with the general intent and spirit of the zoning ordinance and with the city’s community development plan, including all relevant elements thereof, and with any applicable specific plan adopted by the city.

Brentwood 2023-2031 Housing Element
Section 3: Housing Constraints, Resources, and Fair Housing 3-22 Appendix B: Table B-8 includes candidate sites in the following PD zones:
 PD-21 (pipeline project)
 PD-35 (pipeline project)
 PD-38 (pipeline project)
 PD-42 (pipeline project)
 PD-49 (vacant residential)
 PD-64 (pipeline project)
Additionally, the specific development standards for these five PD zones are provided in the table below.

No development standards are included for PD zone 42 (G) as it requires an amendment to the planned development guidelines prior to and/or in conjunction with submittal of a development plan. Of the candidate sites identified in Appendix B, three are vacant residential sites located in PD-49; other sites located in the remaining five PD zones are projects in the pipeline.

Consistent with “smart growth” planning principles, the purpose of the PD-49 zone is to permit and regulate mixed-use development of approximately sixty-four gross acres located south of Balfour Road, west of existing Concord Avenue/future Highway 4 Bypass, and to allow for the phased development of a mix of medical campus, office, retail, public and quasi-public and residential uses, variations in density and building intensities, innovative design characteristics, that would not normally be permitted in a single-use zone, and retention of greater flexibility to adjust square footage allocated to each permitted use. The precise square footage for each use would be determined at the time of approval of the development plans as described below. The land covered by this PD-49 zone is designated by the Brentwood General Plan as a special planning area (SPA) Q, to be developed consistent with this PD-49 zone. Uses permitted by-right in Subarea B include medium to very high density multifamily residential not exceeding an average density of twenty-five units per acre. Mixed residential and nonresidential uses within the same structure are permitted with the approval of a conditional use permit.

Table 3-7: Development Standards of Candidate Site PD Zones Standards PD-21 (A2) PD-35 (I) PD-38 (D) PD-49 (B) PD-64 (F) Minimum lot size 4,000 SF 5,800/3,600 SF 3,000 SF 1 acre - Minimum lot width - 60 feet 40 feet - -
Minimum lot depth - 80 feet 70 feet - -
Minimum lot frontage - 40 feet - - 18 feet
Minimum front yard - - 40 feet -

1. To door of a frontentry garage
20 feet 20 feet - - 20 feet

2. To wall of a side-entry
garage
10 feet 15 feet - - -

3. To wall of a habitable
room
20 feet 15 feet - - 10 feet
Minimum side yard
adjoining a street 15 feet 10 feet 4 feet - 10 feet
Minimum side yard at
interior lot line - 5 feet 4 feet 10 feet -

1. To the wall of a garage 5 feet - - - 0/5 feet

2. To wall of a habitable
room
5 feet - - - 0/5 feet

3. Aggregate, both side
yards 10 feet - - - 5 feet

4. Aggregate, both side
yards, non-garage 10 feet - - - 5 feet
Minimum rear yard 15-20 feet 20 feet 4 feet - 5 feet
Maximum building height 35 feet 32 feet/ 35 feet/ 40 feet/ 35 feet

Brentwood 2023-2031 Housing Element
Section 3: Housing Constraints, Resources, and Fair Housing 3-23 2 stories 2 stories 3 stories
Maximum lot coverage N/A 45% one-story
40% two-story 50% - 65%
Minimum off-street
parking 2 - - - 4
Source: Brentwood Municipal Code
Given the number of pipeline projects (totaling 500 units) located in the PD zones, as well as the development standards and required findings listed above, the City does not identify any constraints from the PD zones. Sites identified as part of PD zone 49 are considered feasible and prime for redevelopment.

As such, development standards and rezoning findings are not considered a constraint to development.

Housing for Persons with Disabilities
Both the Federal Fair Housing Amendment Act (FHAA) and the California Fair Employment and Housing Act direct require governments to make reasonable accommodations (that is, modifications or exceptions) in their zoning laws and other land use regulations to afford disabled persons an equal opportunity to housing. State law also requires cities to analyze potential and actual constraints to the development, maintenance, and improvement of housing for persons with disabilities.

The Housing Element Update must also include programs that remove constraints or provide reasonable accommodations for housing designed for persons with disabilities. The analysis of constraints must touch upon each of three general categories: 1) zoning/land use; 2) permit and processing procedures; and 3) building codes and other factors, including design, location, and discrimination, which could limit the availability of housing for disabled persons.

Reasonable Accommodations
Reasonable accommodation in the land use and zoning context means providing individuals with disabilities or developers of housing for people with disabilities, flexibility in the application of land use and zoning and building regulations, policies, practices, and procedures, or even waiving certain requirements, when it is necessary to eliminate barriers to housing opportunities. For example, it may be reasonable to accommodate requests from persons with disabilities to waive a setback requirement or other standard of the Zoning Code to ensure that homes are accessible for the mobility impaired. Whether a particular modification is reasonable depends on the circumstances.

The Brentwood Zoning Code allows a request for reasonable accommodation to be made by any person with a disability, their representative or any entity, when the application of a zoning law, building regulation, or other land use regulation, policy, or practice acts as a barrier to fair housing opportunities.

The Brentwood Zoning Code defines an individual with a disability as any individual who has a physical or mental impairment that limits or substantially limits one or more major life activities, anyone who is regarded as having such impairment or anyone who has a record of such impairment.

No applications for reasonable accommodations were received by the City during the 5th Planning Cycle.

APPLICATION REQUIREMENTS
Requests for reasonable accommodation shall be submitted on an application form provided by the Community Development Director, or in the form of a letter, to the director and shall contain the following information:
 The applicant’s name, address, and telephone number;
 Address of the property for which the request is being made;

Brentwood 2023-2031 Housing Element
Section 3: Housing Constraints, Resources, and Fair Housing 3-24  The current actual use of the property;
 The basis for the claim that the individual is considered disabled under the Acts;  The municipal code provision, zoning ordinance provision, or other regulation or policy from which reasonable accommodation is being requested; and
 Why the reasonable accommodation is necessary to make the specific property accessible to the individual.

If the project for which the request for reasonable accommodation is being made also requires some other discretionary approval, then the applicant shall file the information together for concurrent review with the application for discretionary approval.

REVIEW PROCEDURE
The Community Development Director, or designee, shall make a written determination within thirty calendar days and either grant, grant with modifications, or deny a request for reasonable accommodation. The written determination on whether to grant or deny the request for reasonable accommodation shall be also made by the authority responsible for reviewing the discretionary land use application in compliance with the applicable review procedure for the discretionary review. If necessary, to reach a determination on the request for reasonable accommodation, the reviewing authority may request further information from the applicant consistent with the Acts, specifying in detail the information that is required. In the event that a request for additional information is made, the thirty-day period to issue a decision is stayed until the applicant responds to the request.

The director may decide to allow the Planning Commission to determine whether to approve, conditionally approve, or deny an application for a minor reasonable accommodation if the Director finds that the reasonable accommodation involves significant controversy or extraordinary circumstances.

FINDINGS AND DECISION
The written decision to grant or deny a request for reasonable accommodation will be consistent with the Acts and shall be based on consideration of the following factors:
 Whether the housing, which is the subject of the request, will be used by an individual with a disability protected under the Acts.
 Whether the request for reasonable accommodation is necessary to make specific housing available to an individual with a disability under the Acts.  Whether the requested for reasonable accommodation would impose an undue financial or administrative burden on the city.
 Whether the requested reasonable accommodation would require a fundamental alteration in the nature of a city program or law, including, but not limited to, land use and zoning.  Potential impact on surrounding uses.
 Physical attributes of the property and structures
 Alternative reasonable accommodations which may provide an equivalent level of benefit.

In granting a request for reasonable accommodation, the reviewing authority may impose any conditions of approval deemed reasonable and necessary to ensure that the reasonable accommodation would comply with the findings required above. The City Council initiated a Zoning Code update on January 24, 2023, through which the City will, among other things, remove subjective requirements to reasonable accommodations findings. See Action H.4m in the Housing Plan.

APPEAL OF DETERMINATION

Brentwood 2023-2031 Housing Element
Section 3: Housing Constraints, Resources, and Fair Housing 3-25 An applicant or any party with interest may appeal any determination of the Community Development Director to the Planning Commission if appropriate notice is given to the Community Development Department office within ten calendar days of the Director’s decision. The City shall charge a fee for costs involved in the appeal. The Planning Commission shall hear and determine any appeal within thirty days of such notice.

An applicant or any party with interest may appeal any determination of the Planning Commission or other reviewer to the City Council if appropriate notice is given to the Community Development Department office within ten calendar days of the Planning Commission’s decision. The City shall charge a fee for costs involved in the appeal. The City Council shall hear and determine any appeal within thirty days of such notice. The decision of the City Council shall be deemed final.

Definition of Family
Under the right of privacy, the California Constitution prohibits a restrictive definition of “Family” which limits the number of unrelated persons and differentiates between related and unrelated individuals living together. The City’s Zoning Code defines “Family” as “the functional equivalent of a traditional family, whose members are an interactive group of persons jointly occupying a single dwelling 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.” Action H.4n has been added to the Housing Plan to address potential constraints posed by the definition of “Family.”
Local Ordinances
An ordinance is a law passed by a municipal government. Local ordinances are enacted to maintain or improve public safety, health, and general welfare. Locally adopted ordinances such as inclusionary ordinances or short-term rental ordinances may directly impact the cost and supply of residential development. Impacts may create governmental constraints to the development of housing and may hinder the City from meeting its share of the regional housing need and the need for housing for persons with disabilities, supportive housing, transitional housing, and emergency shelters.

Affordable Housing Program
Inclusionary housing ordinances are local zoning ordinances which either mandate or encourage housing developers to include a specified percentage of units affordable to lower and moderate-income households. Inclusionary Housing Ordinances bring affordable housing to market and increases types of housing available to different income levels.

The City of Brentwood enforces an Affordable Housing Program which acts as the City’s inclusionary housing ordinance. The purpose of the Affordable Housing Program is to:
 Enhance the public welfare and assure that further housing development contributes to the attainment of the City’s housing goals as described in the Housing Element of the General Plan, by creating, preserving, maintaining, and protecting housing affordable for households of very low-, low- and moderate-income;
 Assure that the remaining developable land in the City’s planning area is utilized in a manner consistent with the City’s housing policies and needs;

Brentwood 2023-2031 Housing Element
Section 3: Housing Constraints, Resources, and Fair Housing 3-26  Increase the number of affordable housing units in Brentwood in recognition of the insufficient number of existing affordable housing units in relation to the community’s current and future needs; and
 Assure that new affordable housing units that are constructed are distributed throughout the City as part of mixed-income developments in order to obtain the benefits that flow from economically diverse communities, increase access to opportunity, and affirmatively further fair housing.

The Affordable Housing Program applies to all new residential developments of five or more lots or dwelling units designed and intended for residential occupancy. Developers of residential developments of five or more lots or dwelling units designed and intended for residential occupancy shall construct or make possible the construction of a minimum of 13 percent of the total number of dwelling units within the residential development as affordable units.

The City fully implements the State Density Bonus law in conjunction with the Affordable Housing Ordinance by providing developers with the option to combine double count units towards both requirements if they are subject to the Affordable Housing Ordinance and seek to receive a Density Bonus.

Additionally, the City implements Density Bonuses through the same application as required by a project – there are no additionally required steps and no required discretionary review just for the Density Bonus.

Five to Nine Unit Developments
Developers of residential developments consisting of five to nine dwelling units may either construct one low-income affordable unit, pay a fee equal to fifty percent of the low-income in-lieu fee, or provide an “alternative equivalent.” However, if all or any portion of a residential development of five to nine dwelling units is later re-subdivided into ten or more parcels or dwelling units, the City’s affordable housing requirement may not be satisfied by payment of an in-lieu fee. Alternative Equivalents include:
 Payment of In-Lieu Fees;
o $3,000 per moderate-income unit not built
o $361,000 per low-income unit not built
o $484,000 per very low-income unit not built
 Dedication of Vacant Developable Land;
 Off-Site Construction of For-Sale or For-Rent Affordable Units or Conversion of Market-Rate ForSale or For-Rent Units to Affordable Units;  Dedication of Affordable Units to the City of Brentwood; or  Other Means of Fulfilling Affordable Housing Requirements subject to City Manager or designee approval.

In addition, for residential developments with very low- to medium-density zoning designations as defined by the General Plan, the affordable unit may be smaller in size than other models in the residential development. The minimum permissible affordable unit size is one thousand six hundred square feet on a three thousand square foot parcel. As a means to provide massing and lot proportions consistent with the residential development, a duet unit will satisfy the City’s affordable housing requirement. For example, a duet unit can be located on a corner with each duet unit being one thousand six hundred square feet on two separate three thousand square foot parcels.

To facilitate the development of required affordable units, the City may grant development standards reductions.

The City has not processed any recent housing applications for developments between five and nine units.

Brentwood 2023-2031 Housing Element
Section 3: Housing Constraints, Resources, and Fair Housing 3-27 Ten or More Unit Developments
In residential development consisting of ten or more dwelling units, any decimal fraction less than 0.50 dwelling units shall be disregarded and any decimal fraction equal to or greater than 0.50 dwelling units shall be construed as one dwelling unit. Table 3-8 below show the allocation of affordable units required by the Affordable Housing Program.

Table 3-8: Allocation of Affordable Units to Income Levels Income Level Percentage Required
Ownership and Rental Development
Very Low-Income Households 3%
Low-Income Households 4%
Moderate-Income Households 6%
Source: City of Brentwood Zoning Code
The development community cites local ordinances such as inclusionary housing ordinances as constraints to development. There is evidence that the development of affordable units may increase overall development costs and cut developer’s profit margins. Increased costs may be passed on to market-rate owners and renters. In order to eliminate or reduce constraints in the development of housing in Brentwood, the City offers concessions and construction incentives. The city may offer incentives or financial assistance to encourage compliance with requirements of the Affordable Housing Program. Such incentives may include, but shall not be limited to, any of the following items, applied alone or in any combination upon the City Council’s finding that a developer has proven that the incentive is necessary to the financial feasibility of the residential development:
 Development Processing Fee Deferral;
 Development Impact Fee Deferral;
 Density Bonus;
 Flexible Design Standards - including, but not limited to, the following:
o Reduced lot sizes;
o Reduced setback requirements;
o Reduced open space requirements;
o Construction of duets, duplexes, triplexes or fourplexes on corner lots within single-family areas;
o Reduced landscaping requirements;
o Reduced parking requirements;
o Height restriction waivers.
 Fast Track Processing;
 Direct Financial Assistance; or
 Additional Concessions and Incentives the City Council may consider, on a case-by-case basis, at its sole discretion.

Alternative Equivalents include:
 Dedication of Vacant Developable Land;
 Off-Site Construction of For-Sale or For-Rent Affordable Units or Conversion of Market-Rate ForSale or For-Rent Units to Affordable Units;  Dedication of Affordable Units to the City of Brentwood; or  Other Means of Fulfilling Affordable Housing Requirements subject to City Manager or designee approval.

Brentwood 2023-2031 Housing Element
Section 3: Housing Constraints, Resources, and Fair Housing 3-28 The off-site construction or conversion of off-site market rate units to affordable units has been the most popular option amongst developers, including the Parkside Villas project currently under construction and included as a Pipeline project. This has proven effective in the ultimate construction of affordable units.

Due to concessions and construction incentives offered to developers, it has been determined that the Affordable Housing Program does not pose a constraint to the development or cost of housing in Brentwood. The concessions and construction incentives offered to developers in Brentwood often result in increased profit margins and project feasibility for developers.

Growth Management
Growth management is the use of a wide range of techniques to determine the amount, type, and rate of development desired by the community and to channel that growth into designated areas. A growth management system is commonly organized into a set of goals, objectives, policies, and performance standards that guide the physical development of a community.

Growth management systems promote a variety of environmental, social, and economic goals, including balancing the service costs and revenues associated with development; protecting environmental and aesthetic qualities; encouraging the efficient use of land, water, and energy resources; preserving community identity; and protecting the economic base of the community.

The City of Brentwood has adopted the Growth Management Element that is part of the General Plan.

The Growth Management Element was adopted to ensure orderly and fiscally sustainable growth, while maintaining high levels of public services and infrastructure, and because Contra Costa County voters approved a 0.5% sales tax increase in November 1988, commonly known as “Measure C,” that includes both Transportation Improvement and Growth Management Programs (GMP). The overall goals of the Measure C program are:
 To relieve congestion created by past development through road and transit improvements funded by the proceeds of the sales tax increase; and
 To prevent future development decisions from resulting in the deterioration of public services and unacceptable traffic performance standards.

To be eligible for its share of revenue generated under Measure C, the City of Brentwood must commit itself, as a matter of public policy, to carrying out the following objectives:
 Manage congestion by adopting and applying traffic service standards for streets, roads, and Regional Routes; and
 Adopt policies for fire protection, police, parks, water, flood control, and sanitary sewer service level standards that will be met as the city grows.

In November 2004, voters in Contra Costa County extended the Measure C sales tax until 2034 through the passage of Measure J. While this new measure retained many of the components of the Measure C GMP, some changes were made, most notably the requirement for the adoption of an Urban Limit Line (ULL) for each jurisdiction. On January 8, 2008, the City Council adopted the Contra Costa County Measure L Voter-Approved Urban Limit Line (Resolution No. 2008-3) as the City of Brentwood’s Urban Limit Line, which was approved by the majority of Brentwood voters in November 2006.

Short-Term Rental Ordinance
Short-term rentals are commonly defined as an accessory use of a primary residence for the purposes of providing temporary lodging for compensation for up to 30 days or less. The purpose of Short-Term Rental Ordinances is to establish regulations, standards, and a permitting process governing the renting or

Brentwood 2023-2031 Housing Element
Section 3: Housing Constraints, Resources, and Fair Housing 3-29 leasing of privately owned, visitor-serving dwelling units on a short-term basis. Short-Term Rental Ordinances are often established to safeguard residents by ensuring that short-term rental activities do not threaten the character of neighborhoods and that such short-term rental activities do not become a nuisance, or threaten the public health, safety, or welfare of neighboring properties. The City of Brentwood does not have a Short-Term Rental Ordinance.

Density Bonus Ordinance
In accordance with California State Government Code Section 65915, a housing development may increase the number of units above the maximum permitted and/or receive reductions in development standards in exchange for reserving units for very low-, low-income, and/or moderate-income households or for seniors. These units must be restricted to their level of affordable for at least 30 years through a deed-restricted affordable housing covenant. All Density Bonus information is available to the public and can be found in the City of Brentwood Zoning Code Chapter 17.720 Density Bonus Program. According to the City’s Zoning Code, qualifying housing developments which satisfy at least one of the following categories or land dedication provisions listed below will be granted a density bonus:
 At least 10 percent of the total units of a housing development for lower income households;  At least 5 percent of the total units of a housing development for very low or extremely lowincome households;  At least 10 percent of the total dwelling units in a common interest development, as defined in Civil Code Section 1351, are for households of moderate income, provided that all units are offered to the public for purchase;
 A senior citizen project or a mobile home park that limits residency based on age requirements for housing older persons in compliance with Civil Code Section 51.2, 51.3, 798.76, or 799.5. (Senior citizen projects shall be restricted to occupancy by senior citizens in perpetuity.);  When an applicant for a residential development agrees to donate land to the city for very lowincome households;  When a development is the conversion of an existing apartment complex to a condominium complex and the applicant agrees to make at least thirty-three percent of the total units of the development affordable to moderate income households for thirty years, or fifteen percent of the total units of the proposed development affordable to lower income households for thirty years, and agrees to pay for the administrative costs incurred by the city to process the application and to monitor the continued affordability and habitability of the affordable housing units; or  When an applicant proposes to construct a development that conforms to the requirements of Section 17.720.003 and includes a childcare facility located on the premises, or as part of, or adjacent to, the development.

In addition to density bonuses, the City of Brentwood Zoning Code Chapter 17.720 allows for the incentives and concessions listed below to projects which meet the qualifying number of lower/very low- /moderate-income units:
 One incentive or concession for a project that includes: at least ten percent of the total units affordable to low-income households, at least five percent of the total units affordable to very low-income households, or at least ten percent of the total units affordable to households of moderate income in a common interest development; or
 Two incentives or concessions for a project that includes: at least twenty percent of the total units affordable to low-income households, at least ten percent of the total units affordable to very low-income households, at least five percent of the total units affordable to extremely lowPage 193 of 894 Brentwood 2023-2031 Housing Element
Section 3: Housing Constraints, Resources, and Fair Housing 3-30 income households, or at least twenty percent of the total units affordable to households of moderate income in a common interest development; or
 A total of three incentives or concessions for a project that includes: at least thirty percent of the total units affordable to low-income households, at least fifteen percent of the total units affordable to very low-income households, or at least thirty percent of the total units affordable to households of moderate income in a common interest development.  One additional incentive for a project that is affordable to low-income households and provides any of the following: at least twenty-five percent of the units as three- or four-bedroom units, at least twenty-five percent of the units accommodate disabled persons and are set-aside for occupancy by disabled persons, or at least ten percent of the units are affordable to extremely low-income households.

Types of incentives and concessions include any of the following:
 A reduction in the site development standards that results in identifiable, financially sufficient, and actual cost reductions. The reduction may include, but is not limited to:
o Reduced minimum lot size;
o Reduced minimum lot width;
o Reduced minimum setback;
o Increased maximum building height;
o Reduced onsite open-space requirement;
o Increased maximum lot coverage;
o Increased floor area ratio; or
o Reduced parking requirement.
 A reduction in architectural design requirements that exceeds the minimum building standards approved by the California Building Standards Commission in compliance with Health and Safety Code Section 18901 et seq., that would otherwise be required, that results in identifiable, financially sufficient, and actual cost reductions;
 Approval of mixed-use development in conjunction with the proposed development if nonresidential uses will reduce the development cost of the residential portion of the proposed development, and if the nonresidential uses are compatible with the proposed development and with existing or planned development in the area.
 Expedited Project Processing. The project will receive expedited project processing, which will include:
o Mandatory Pre-Development Review Meeting. An applicant requesting expedited project processing must participate in a mandatory pre-development review meeting prior to submittal of the project application and must pay all applicable pre-development meeting fees.
o The review period(s) to determine completeness of the project application will be reduced from thirty calendar days to twenty-five calendar days. o Upon completion of project processing, including completion of the environmental document, if necessary, at the applicant’s request the city will schedule the project for a public hearing, if required, and for project consideration by the decision-making body.  Other regulatory incentives or concessions proposed by the applicant or the city that result in identifiable, financially sufficient, and actual cost reductions.  A direct financial contribution, waiver of fees, or reduction of fees, when financially feasible, at the sole discretion of the city council. Nothing in this chapter shall be construed to require the provision of direct financial incentives for the development, including the provision of publicly owned land by the city or other waiver of fees or dedication requirements. (Ord. 943 § 6, 2015)

Brentwood 2023-2031 Housing Element
Section 3: Housing Constraints, Resources, and Fair Housing 3-31 In accordance with the City of Brentwood Zoning Code Chapter 17.720 Density Bonus Program, the following density bonus calculations in Table 3-9 through 3-12 will be applied to housing developments that meet the above criteria:

Table 3-9: Very Low-Income Density Bonus Calculations
Percentage Very Low-Income Units Percentage Density Bonus 5 20
6 22.5
7 25
8 27.5
9 30
10 32.5
11 35
Source: City of Brentwood Zoning Code
Table 3-10: Low-Income Density Bonus Calculations
Percentage Low-Income Units Percentage Density Bonus
10 20
11 21.5
12 23
13 24.5
14 26
15 27.5
17 30.5
18 32
19 33.5
20 35
Source: City of Brentwood Zoning Code
Table 3-11: Moderate-Income Density Bonus Calculations
Percentage Moderate-Income Units Percentage Density Bonus 10 5
11 6
12 7
13 8
14 9
15 10
16 11
17 12
18 13
19 14
20 15
21 16
22 17
23 18
24 19
25 20
26 21
27 22
28 23
29 24
30 25

Brentwood 2023-2031 Housing Element
Section 3: Housing Constraints, Resources, and Fair Housing 3-32 Table 3-11: Moderate-Income Density Bonus Calculations
Percentage Moderate-Income Units Percentage Density Bonus 31 26
32 27
33 28
34 29
35 30
36 31
37 32
38 33
39 34
40 35
Source: City of Brentwood Zoning Code
Table 3-12: Extremely Low and Very Low-Income Density Bonus Calculations—Land Donation
Percentage Moderate-Income Units Percentage Density Bonus 10 15
11 16
12 17
13 18
14 19
15 20
16 21
17 22
18 23
19 24
20 25
21 26
22 27
23 28
24 29
25 30
26 31
27 32
28 33
29 34
30 35
Source: City of Brentwood Zoning Code
The Government Code states that when an applicant for a tentative subdivision map, parcel map, or other residential development approval donates land to a city, county, or city and county in accordance with these subdivisions, the applicant shall be entitled to a 15 percent increased above the otherwise maximum allowable residential density for the entire development, as shown in Table 3-12. This increase may be added to the density bonuses listed above but may not exceed 35 percent.

Until 2021, under Government Code Section 65915, known as the Density Bonus Law, the maximum bonus was 35 percent. California State Law AB 2345 states that all jurisdictions in California are required to process projects proposing up to 50 percent additional density as long as those projects provide the additional Below Market Rate units (BMR) in the “base” portion of the project, unless the locality already

Brentwood 2023-2031 Housing Element
Section 3: Housing Constraints, Resources, and Fair Housing 3-33 allows a bonus above 35 percent. The bill also lowered the BMR thresholds for concessions and incentives for projects with low-income BMRs. As of 2021, Government Code Section 65915 authorizes an applicant to receive two incentives or concessions for projects that include at least 17 percent of the total units for lower income households, at least 10 percent of the total units for very low-income households, or at least 20 percent for persons or families of moderate income in a common interest development. It also allows an applicant to receive three incentives or concessions for projects that include at least 24 percent of the total units for lower income households, at least 15 percent of the total units for very low-income households, or at least 30 percent for persons or families of moderate income in a common interest development.

The City’s Density Bonus program currently allows a maximum of 35 percent density increase; however, AB 2345 requires an allowance of up to 50 percent density bonus when the base BMR is proposed. A program is included in Section 4: Housing Plan to update the City’s Zoning Code in compliance with state legislation.

Specific Plans
The purpose of a Specific Plan is to implement the goals and objectives of a City’s General Plan in a more focused and detailed manner that is area and project specific. The Specific Plan promotes consistent and an enhanced aesthetic levels throughout the project community. Specific Plans contain their own development standards and requirements that may be more restrictive than those defined for the City as a whole. The City of Brentwood has three adopted Specific Plans throughout the City, and the following sections provide brief descriptions of the adopted Specific Plans which affect the development of housing.

Brentwood Boulevard Specific Plan
The Brentwood Boulevard Specific Plan (BBSP) was adopted on March 27, 2012, and was most recently amended on October 27, 2015. The purpose of the Specific Plan is to provide long-term policy guidance needed to revitalize and improve a significant portion of Brentwood Boulevard and to recognize the opportunities for change as the corridor transitions from a rural State route to a local mixed-use arterial roadway. The BBSP provides guidance needed to revitalize and improve a 310-acre area in the City.

Historically, Brentwood Boulevard has served as the primary route through the City of Brentwood for residents, workers, and visitors. The corridor includes a major gateway into the City of Brentwood along the shared boundary with the City of Oakley at Delta Road on the north, and a connection to the historic Downtown at Second Street on the south. The vision for the BBSP is to transform the existing autooriented corridor into a more traditional boulevard with distinctive, unique, front-facing buildings. The BBSP also promotes comfortable walkways and generous landscaping to provide an active, inviting, and attractive location for residents, workers, and visitors. The Specific Plan allows for single-family dwellings, multi-family dwellings, small residential care facilities, accessory facilities and buildings, animal keeping, and some home occupations.

The minimum required lot size is 4,000 square feet for detached single-family dwellings in the Medium Density Residential (MDR) area and the maximum lot coverage is 50 percent. The minimum required lot size is 3,000 square feet for attached single-family dwellings in the Medium Density Residential (MDR) area and the maximum lot coverage is 60 percent. The minimum required lot size is 2,000 square feet for multi-family dwellings in the Medium Density Residential (MDR) area and the maximum lot coverage is 70 percent.

The minimum required lot size is 2,000 square feet in the High Density Residential (HDR) area and the maximum lot coverage is 80 percent. The maximum number of attached dwelling units within an individual building shall not exceed 12. The Commercial/Office/Industrial/Residential (COIR) district within the BBSP permits all uses allowed in the HDR areas.

Brentwood 2023-2031 Housing Element
Section 3: Housing Constraints, Resources, and Fair Housing 3-34 Downtown Specific Plan
The Downtown Specific Plan (DSP) was adopted on November 16, 2005 and was most recently amended on September 26, 2017. The purpose of the Specific Plan is to coordinate public and private investment in the City’s Downtown District to fulfill the community’s intention for the downtown to remain the heart of the Brentwood community as the City goes through a period of explosive growth and change. The DSP contains both a strategy to manage growth and a regulatory policy to guide and govern future development within the DSP area.

The DSP area consists of approximately 205 acres within the City’s historic center, which begins near the intersection of Oak Street and the Union Pacific Railway. All districts, except for the Brentwood Civic Center Brentwood District, allow residential uses. A variety of residential uses are allowed within different districts including upper-floor mixed used residential, live-work residential, stacked units, and both attached and detached single-family dwellings.

Priority Area One Specific Plan
The Priority Area One Specific Plan (PA-1 SP) was originally adopted on November 13, 2018. In October 2022, the City adopted additional changes to PA-1 incorporating updated development standards, land uses, infrastructure and public services, and circulation, as well as an economic development and implementation plan which had the support and involvement of the property owners who are also large landowners and developers within the community. The purpose of the Specific Plan is to enable the development of Priority Area One as a vibrant, compact, transit-oriented development – focused on a future multi-modal transit station, e.g., Tri Delta Transit/eBART station - and as an employment center within the City. The City of Brentwood envisions the PA-1 SP area emerging as one of the City’s primary future employment centers, offering individuals and businesses access and opportunities to create highquality jobs across a diverse array of industries. The establishment of the employment center will assist the City towards achieving its goal of a healthy jobs-to-housing balance, reducing commute times for residents, and establishing new opportunities for economic growth and employment within the City.

The PA-1 SP area is approximately 431 acres and located in the northwestern corner of the City.

Approximately 63 acres of the PA-1 SP area consists of public right-of-way and the Mokelumne Coast to Crest Trail corridor. The remaining area, approximately 368 acres, is privately-owned. Three districts within the PA-1 SP area allow residential uses. The Transit Village district allows upper floor multi-family dwellings, and the density range is 25 to 40 dwellings units per acre. The Multiple-Family Very-High Density Residential district is primarily intended to accommodate multiple story condominium and apartment buildings at a density from 15 to 35 dwelling units per acre. The High Density Residential district accommodates a wide variety of housing types including duplexes, triplexes, townhouses, condominium and apartment buildings, and small-lot detached single-family houses. The density ranges from 10 to 20 dwelling units per acre.

The City has approved the extension of Sand Creek Road from its existing terminus, just west of SR 4, to the intersection of Sand Creek Road and Heidorn Ranch Road in Antioch. This project will facilitate the development of PA-1 and is anticipated to break ground in July 2023 with completion in February 2024. A total of $8,694,359 will come from City Roadway Development Impact Fees. East Contra Costa Regional Fee and Financing Authority (“ECCRFFA”) has also authorized funding in the amount of $4,105,641.

The City has also approved over $11 million of Capital Improvement Project funding to provide the PA-1 SP area with infrastructure. The infrastructure project is already funded and is currently in the design phase. This will facilitate development of the area as the parcels will be infrastructure ready. This project will construct infrastructure improvements within PA-1. The improvements include Jeffery Way roadway extension from Amber Lane to Empire Avenue, the extension of wet utilities (water, sewer, and nonPage 198 of 894 Brentwood 2023-2031 Housing Element
Section 3: Housing Constraints, Resources, and Fair Housing 3-35 potable water) on Empire Avenue under State Route 4 to Heidorn Ranch Road, widening Lone Tree Plaza Drive between Heidorn Ranch Road and Canada Valley Road, and all associated improvements and land acquisition.

On-/Off-Site Improvements
Site improvements in the City consist of those typically associated with development for on-site improvements (street frontage improvements, curbs, gutters, sewer/water, and sidewalks), and off-site improvements caused by project impacts (drainage, parks, traffic, schools, and sewer/water). Because residential development cannot take place without the addition of adequate infrastructure, site improvement requirements are considered a regular component of development of housing within the City and may also influence the sale or rental price of housing. The majority of cost associated with on and off-site improvements is undertaken by the City and recovered in the City’s development and impact fees.

For single-family residential development on vacant land, examples of typical on-site improvements might include stormwater detention facilities (required by the Clean Water Act), roads, sidewalks, perimeter walls, fire hydrants, emergency access drives, and recreational trails. Multifamily developments may also include common open space and recreation areas, as well as lockable storage areas.

Typical off-site improvements for both single-family and multi-family developments might include: new curbs, gutters, and sidewalks, recreational trail facilities, road improvements and traffic control needed to serve the development, street trees, and landscaping. Utilities may need to be updated or installed to serve the development, including water mains, sewer mains, stormwater pollution prevention measures, and undergrounding of electric utilities.

Infill residential projects may be required to install any of the improvements listed above, depending on site-specific circumstances and neighborhood needs.

The City of Brentwood has standard improvements required for subdivisions that can be found in the City’s Municipal Code. General improvements include the following:
 The thoroughfare and/or collector adjoining the proposed development shall be improved as required by the public works director. If it is determined that there are deficiencies in the thoroughfare or collector system that is not adjoining the proposed development but will be affected by the proposed development creating a health or safety problem, then the development shall also be responsible for the full or portion of the improvement of such deficiency;  The subdivider shall dedicate or make an irrevocable offer of dedication of all parcels of land within the subdivision that are needed for streets, alleys, including access rights and abutters’ rights, drainage, local transit facilities, bike paths, public utility easements, and other public easements as required;
 The subdivider shall install or agree to install all on and off-site public and private street improvements, bike paths, local transit facilities, drainage facilities, utilities and fences as required.

Specific design standards for streets can be found in Chapter 12.04 Street Widths in the City of Brentwood Municipal Code. The following lists the typical design of street sections throughout the City:
 Thoroughfares: 80-126 feet
 Collectors: 60 feet

Brentwood 2023-2031 Housing Element
Section 3: Housing Constraints, Resources, and Fair Housing 3-36 On and off-site improvements in the City of Brentwood are consistent with requirements of other cities in the region. On and off-site improvements do influence the cost of development, but the improvement requirements do not present a constraint to the development of housing in Brentwood.

Building Codes and Code Compliance
The City has adopted the 2019 California Building Code, including the ancillary information within the tables, attachments, addendums, and footnotes. This would include the California Administrative Code, Building Code, Residential Code, Electrical Code, Mechanical Code, Plumbing Code, Energy Code, Historical Building Code, Fire Code, Existing Building Code, Green Building Standards Code, and California Referenced Standards Code. The adoption California Building Code therefore ensures a consistent development standard that would be promoted throughout the State. The Code’s intent is to safeguard the public health, safety, and general welfare through structural strength, means of egress facilities, stability, sanitation, adequate light and ventilation, energy conservation, and safety to life and property from fire and other hazards attributed to the built environment and to provide safety to firefighters and emergency responders during emergency operations. The newest edition of the California Building Standards Code is the 2019 edition with an effective date of January 1, 2020. The City of Brentwood is required by State law to enforce the new code.

The City does not have any local amendments to the Building Code but has made one amendment to the 2019 California Plumbing Code. The City has amended the 2019 California Plumbing Code to add to Section 1208.6. The addition is provided below:
 High levels of acid (pH) found in many locations throughout the city from natural soils and imported soils have proven to have a highly corrosive effect on metallic piping laid underground.

The city prohibits the use of metallic gas piping underground without the approval of the city’s chief building official and a soils analysis showing a level of pH that will not corrode metallic piping.

The City of Brentwood’s Community Enrichment team responds to citizen concerns and proactively identifies violations on private property while achieving a very high rate of voluntary compliance through education. The basis of Community Enrichment rests with property owners and tenants to act as good neighbors. Property owners have rights that protect them; however, the term "property rights" also implies that property owners have certain responsibilities. No property within the City may be used or maintained in a manner, which downgrades the value, use, enjoyment, or safety of one’s own or surrounding property. The Community Enrichment Program activities protect the health and safety of the community. Staff work with residents to take an active role in improving and maintaining the quality of life of their neighborhoods, as well as maintaining property values. Staff receive concerns regarding structures in need of rehabilitation or for construction without a permit, and typically investigate 50-60 such cases per month, with an overall caseload of 5000-6000 cases per year. The Community Enrichment Program works with property owners to correct compliance issues which may require entitlements and building permits. A code compliance case is deemed to be resolved after the property has been inspected by Community Enrichment staff, as well as Building Inspection staff when building permits are required, to ensure all violations have been corrected.

Development Fees
Residential developers are subject to a variety of permitting, development, and impact fees in order to access services and facilities as allowed by State law. The additional cost to develop, maintain, and improve housing due to development fees result in increased housing unit cost, and therefore is generally considered a constraint to housing development. However, fees are necessary to provide planning and public services in Brentwood. All information regarding the City’s development fees is available to the public on the City of Brentwood website as pursuant to Government Code §65940.1 (a)(1)(B).

Brentwood 2023-2031 Housing Element
Section 3: Housing Constraints, Resources, and Fair Housing 3-37 The location of projects and housing type result in varying degrees of development fees. The presumed total cost of development is also contingent on the project meeting City policies and regulations and the circumstances involved in a particular development project application. The majority of the City planning fees operate on a deposit account basis where time and materials are charged against the established account as the project is processed. Table 3-13 provides the planning fees and Table 3-14 provides the development impact fees.

Table 3-13: Planning Processing Fees
Application Type Fee
Annexations $5,800 Deposit
Appeals $411
Development Agreement $4,200 Deposit
CEQA
Catagorical Exemption $225
Negative Declaration $3,500
Mitigated Declaration $4,900 Deposit
Mitigated Negative Declaration Deposit for Consultant cost + 25% Environmental Impact Report Deposit for Consultant cost + 25% Residential Condominium Conversion $2,200 Deposit
Design Review Residential 1-4 DU’s $500 / per unit up to $2,000 Deposit Residential 5+ DU’s $6,600 Deposit
General Plan Amendment $5,800 Deposit
Lot Line Adjustment (per parcel) $918
Tentative Maps Tentative Subdivision Map Review $3,810 + $10 per lot Tentative Parcel Map Review $2,210 + $10 per lot
Variance
Variance $1,700 Deposit
Administrative Variance $1,063
Sign Variance $900 Deposit
Zone Change $4,900 Deposit
Source: City of Brentwood Universal Application (July 1, 2021) Table 3-14: Development Impact Fees
Fee Type Fee
Single-Family* Multi-Family*
City of Brentwood
Administration $870.52 $510.90
Community Facilities $858.02 $503.57
Park and Trail $13,063.38 $9,655.14
Roadway $14,552.06 $9,022.28
Wastewater $7,882.37 $5,825.86
Water $16,274.07 $6,675.54
City Water fee if in CCWD LV Service Area $15,691.54 $6,436.59 Solid Waste $638.42 $374.01
Storm Water Plan Check & Inspection

2.5% of construction cost of first $250,000, 2.25% of construction cost from $250,000 - $1,000,000, 2% of construction cost over $1,000,000, additional deposit of 0.5% of construction cost if costs exceed fees collected
Flood Control Fee and Storm-Drain Fees As set forth in Contra Costa County Ordinance at time of Final Map approval
Other City of Brentwood Fees
Agricultural Mitigation Fees $8,531.00 per acre of prime farmland developed Habitat Conservation Plan Fees To be determined according to project area and land cover type Affordable Housing Fees To be determined based on agreement with City Council

Brentwood 2023-2031 Housing Element
Section 3: Housing Constraints, Resources, and Fair Housing 3-38 Table 3-14: Development Impact Fees
Fee Type Fee
Single-Family* Multi-Family*
CCWD Area Overlap (if applicable) To be determined according to the meter size serving the use Brentwood Union School District Fees
Residential $2.86 per sf
Senior Housing $0.462 per sf
Liberty Union School District Fees
Residential $2.07 per sf
Residential Additions $1.44 per sf
Senior Housing $0.23 per sf
East Contra Costa Regional Fee and Financing Authority
ECCRFFA (Bypass Authority Impact Fee) $22,479 $13,799
ECCRFFA Admin (City Administrative Fee) $224.79 $137.99 Fire District
Fire Impact Fees $1,317.97 $935.33
*Per Unit
Source: City of Brentwood 2022 Development Fee Program, Liberty Union School District Developer Fees 2022, Brentwood Union School District Developer Fees 2020.

The development fees associated with each project is dependent on the housing type, density, intensity of use, and location. In addition to these direct fees, the total cost of development is contingent on the project meeting the City’s policies and standards, as well as the project applicant submitting necessary documents and plans in a timely manner.

Estimated total development and impact fees for a typical single-unit residential project, assuming it is not part of a subdivision and is consistent with existing city policies and regulations can range from $67,354 to $83,046. Estimated total development and impact fees for a typical multi-unit residential project with ten units, assuming it is consistent with existing City policies and regulations range from $294,813 to $301,249.

Both estimates are illustrative in nature and actual costs are contingent upon unique circumstances of individual development project applications. Considering the cost of land in Brentwood, and the International Code Council (ICC) estimates for cost of labor and materials, the combined costs of permits and fees range from approximately 10.7 percent to 13.2 percent of the direct cost of development for a single-unit residential project and 5.1 percent to 5.2 percent for a multi-unit residential project. Direct costs do not include, landscaping, connection fees, on/off-site improvements, shell construction or amenities, therefore the percentage of development and impact fees charged by the City may be smaller if all direct and indirect costs are included.

Local Processing and Permit Procedures
The development community commonly cites the permit processing time as a contributor to the high cost of housing. Depending on the magnitude and complexity of the development proposal, the time that elapses from application submittal to project approval may vary considerably. Factors that can affect the length of development review of a proposed project include the completeness of the development application and the responsiveness of developers to staff comments and requests for information.

Approval times are substantially lengthened for projects that are not exempt from the California Environmental Quality Act (CEQA), require rezoning or general plan amendments, or encounter community opposition. Applicants for all permits or reviews are recommended to request a preapplication meeting with the respective department to: confirm City requirements as they apply to the proposed project; review the City’s review process, possible project alternatives or revisions; and identify

Brentwood 2023-2031 Housing Element
Section 3: Housing Constraints, Resources, and Fair Housing 3-39 information and materials the City will require with the application, and any necessary technical studies and information relating to the environmental review of the project.

All permit applications are first reviewed by City staff for completeness, and discretionary applications must then receive a recommendation through a staff report prior to a review by the appropriate authority.

Various applications may also require public noticing and a public hearing.

The typical timeline for permit review processing and approval for single-family and multi-family developments is 6 months to a year. Single- and multi-family developments are subject to the following submittal requirements:

1. Submittal of application including the following information:
a. A legal description of the property;
b. A location map showing the project site and the general vicinity of the site; c. A completed environmental information form as prescribed by the City; d. Site plans, elevation plans, floor plans and other maps and data as may be necessary to describe the existing conditions on and surrounding the property and the proposed plans for the future development of the property. The planning commission shall by resolution, maintain a listing of the minimum documentation necessary for submittal in support of each type of application; and
e. Such other information specified in this title for the particular entitlement requested.

2. Payment of fees for permit plan check.

3. Plan check completed by all applicable departments and agencies. Timeline and number of reviews can vary.

4. Permit issued once all comments are satisfied.

Varying project scopes may require different review processes that have different requirements and processing times. Common review types are provided below.

Design and Site Development Review
The purpose and intent of the design and site development review process is to assure that projects foster a good design character through consideration of aesthetic and functional relationships to surrounding development, and in order to further enhance the City’s appearance, and the livability and usefulness of properties. Design and site development review is a process that enables the City to ensure the quality and compatibility of the proposed development with surrounding properties. This procedure applies to all principally permitted use.

The design and site review criteria considered by the Architectural Review Committee1, Community Development Director, and on appeal the City Council include:
 The proposed development shall create a well-composed urban design, harmoniously related to other facilities in the immediate area and to the total setting as seen from key vantage points in the community;
 Elements of design which have significant relationship to the exterior appearance of structures and facilities shall be given special consideration; these elements include but are not limited to height, arrangement on the site, texture, lighting, material, color, signs, landscaping, size, bulk and scale, and appurtenances;
1 Review by the Architectural Review Committee (currently the Planning Commission) does not require public noticing or a public hearing.

Brentwood 2023-2031 Housing Element
Section 3: Housing Constraints, Resources, and Fair Housing 3-40  The proposed development shall be of a quality and character appropriate to, and serving to protect the value of, private and public investments in the immediate area;  Where the proposed development is located in an area for which a specific plan, planned development, neighborhood plan or precise plan has been adopted by the city council, the design of the development shall conform in all significant respects with such plans;  The proposed development shall conform with all requirements for landscaping, screening, parking, usable open space and off-street loading as set forth in this title;  The site development criteria set forth in Section 17.820.008;  “The City of Brentwood Design Guidelines” Draft, dated February 1, 2001, and any other applicable specific design criteria or standards set out in this title or other city ordinance;  All applicable regulations of the zoning ordinance and other city ordinances, policies or resolutions. (Ord. 663 § 1, 2001; Ord. 408, 1987)
In addition, the following criteria is applied in considering all applications for design and site development review approval:
 The siting and internal arrangement of all structures and other facilities on the site, including the land uses, internal circulation, off-street parking and loading facilities, lighting, signing and access to and from public rights-of-way, shall be conducive to an orderly, attractive, efficient and harmonious development.
 The proposed development shall not have adverse environmental effects on adjacent developments, existing or potential, by reason of conflicts in land use, topography or traffic. (Ord. 408, 1987)
Program H.1s is included in the Housing Plan to remove subjectivity in the approval criteria, to promote approval certainty, and adopt objective standards.

Conditional Use Permit
The City recognizes that certain types of land uses require individual review by the Planning Commission to determine whether the type of use proposed, or the location of that use, is compatible with, or can be made compatible with surrounding land uses. The purpose and intent of the Conditional Use Permit review is to allow for the accommodation of uses with special operating characteristics, site or design requirements or potential adverse effects on surrounding properties, by means of review and, where necessary, the imposition of special conditions of approval. The Planning Commission is authorized to approve or deny applications for conditional use permit, and to impose conditions upon such approval.

Conditional Use Permits are the most common type of permits, and are issued for land uses that maybe approved under the zoning ordinance, but only upon meeting specific conditions. Common conditions of approval include limited hours of operation, road improvements, soundproofing, additional landscaping, and additional parking. The permit is granted on the land, not to the property owner, and will remain valid even if the property changes owners. A conditional use permit may also be revoked for noncompliance or other reasons cited in the permit, subject to notice and a hearing.

A Conditional Use Permit is required for developments that exceed the permitted density in a zone, such as a multifamily structure in the R-2 zone (small multifamily structures are permitted in this zone) and residential uses in the commercial zones (unless a proposed projects meets the requirements of AB 2011, as detailed in Appendix B). Due to updates in State law, a number of residential uses listed in Table 3-4 that currently require the approval of a Conditional Use Permit will receive Zoning Code updates to remove this permitting requirement, this includes, but is not limited to, transitional and supportive housing, large residential care facilities, and farmworker housing. It should be noted that no multifamily

Brentwood 2023-2031 Housing Element
Section 3: Housing Constraints, Resources, and Fair Housing 3-41 developments in the High Density Multifamily Residential (R-3) zone require approval of a Conditional Use Permit. Additionally, none of the sites identified in the candidate sites inventory listed in Appendix B require the approval of a Conditional Use Permit.

For a Conditional Use Permit to be granted, the City requires conformance with the following set of criteria:
 The location, size, design and operating characteristics of the proposed development must be compatible with and must not adversely affect the livability of appropriate development of abutting properties and the surrounding neighborhood. Consideration shall be given, but shall not be limited to:
o Harmony in scale, bulk, coverage and density;
o The availability of public facilities and utilities;
o The harmful effect, if any, upon desirable neighborhood character or the planned specialization of retail, commercial or community service areas; o Generation of traffic and the capacity of surrounding streets; o Any other relevant impact of the development;
o The criteria set forth in Chapter 17.820 for design and site development review if applicable.
 The location, design, landscaping and screening, and overall site planning of the proposed development will provide an attractive, useful and convenient living, working, shopping or community-service area.

Program H.1s is included in the Housing Plan to remove subjectivity in the approval criteria, promote approval certainty, and adopt objective standards.

Variance
A variance is review is a procedure through which a property owner may seek a relaxation or waiver of the zoning regulations where there are extraordinary circumstances associated with a parcel of land such that the land or facilities cannot be used to the extent intended by the zoning. It shall be the purpose of this procedure to allow justice, while preserving to the greatest possible extent the purposes of the zoning regulations. Because of special circumstances unique to a specific property, strict application of the zoning regulations deprives such property of privileges enjoyed by other property in the vicinity and under identical zoning. Any variance granted shall not constitute a special privilege. 5 th Cycle Development
In the 5th Planning Cycle, only one residential project was denied. In 2021, an applicant submitted an application for a General Plan amendment, a rezone, a Development Agreement, a vesting tentative subdivision map, and two design reviews for 252 single-family residential parcels, an 11.35-acre school site, two park parcels, four bio-retention areas for stormwater treatments, 258 apartment units on one multi-family parcel, acreage for regional commercial, open space, as well as related improvements.

Resolution No. 2021-36 denies the application as it failed to meet the following required findings:
 General Plan Amendment
o The amendment is deemed to be in the public interest. o The amendment is consistent and/ or compatible with the rest of the General Plan.  Rezone
o The proposed action is consistent with the community development plan and other applicable city plans and is not inappropriate or otherwise contrary to the public interest.  Development Agreement

Brentwood 2023-2031 Housing Element
Section 3: Housing Constraints, Resources, and Fair Housing 3-42 o The development agreement is consistent with the objectives, policies, general land uses and programs specified in the community development plan and applicable specific plans. o The development agreement will not be detrimental to the health, safety and general welfare of persons residing in the immediate area nor be detrimental or injurious to property or persons in the general neighborhood or to the general welfare of the residents of the city as a whole.
o The development agreement will not adversely affect the orderly development of property or the preservation of property values.
 Vesting Tentative Subdivision Map
o That the proposed map is consistent with the community development plan and any applicable specific plans.
o That the design or improvement of the proposed subdivision is consistent with the community development plan and any applicable specific plans. o That the site is not physically suitable for the type of development. o That the site is not physically suitable for the proposed density of development.  Design Review – Single-Family
o The proposed development shall be of a quality and character appropriate to, and serving to protect the value of, private and public investments in the immediate area. o The siting and internal arrangement of all structures and other facilities on the site, including the land uses, internal circulation, off-street parking and loading facilities, lighting, signing and access to and from public rights-of-way, shall be conducive to an orderly, attractive, efficient and harmonious development. o The proposed development shall not have adverse environmental effects on adjacent developments, existing or potential, by reason of conflicts in land use, topography or traffic.
o All applicable regulations of the zoning ordinance and other city ordinances, policies or resolutions.

Senate Bill 35
California Senate Bill 35 (SB 35), codified at Government Code Section 65913.41, was signed on September 29, 2017 and became effective January 1, 2018. SB 35 will automatically sunset on January 1, 2026 (Section 65913.4(m)). The intent of SB 35 is to expedite and facilitate construction of affordable housing. SB 35 applies to cities and counties that have not made sufficient progress toward meeting their affordable housing goals for above moderate- and lower-income levels as mandated by the State. In an effort to meet the affordable housing goals, SB 35 requires cities and counties to streamline the review and approval of certain qualifying affordable housing projects through a ministerial process.

When a jurisdictions has made insufficient progress toward their Lower or Above Moderate income RHNA and/or have not submitted the latest Housing Element Annual Progress Report it is subject to the streamlined ministerial approval process (SB 35 (Chapter 366, Statutes of 2017) streamlining) for proposed developments with at least 50 percent affordability. Annual Progress Reports are due to HCD by April 1 of each year reporting on the prior calendar year’s activities. All projects, which propose at least 50 percent affordable units within Brentwood are eligible for ministerial approval under SB 35 as determined by the SB 35 Statewide Determination Summary. To be eligible for SB 35 approval, sites must meet a long list of criteria, including:
 A multifamily housing development (at least two residential units) in an urbanized area;  Located where 75% of the perimeter of the site is developed;

Brentwood 2023-2031 Housing Element
Section 3: Housing Constraints, Resources, and Fair Housing 3-43  Zoned or designated by the general plan for residential or mixed use residential;  In a location where the locality’s share of regional housing needs have not been satisfied by building permits previously issued;
 One that includes affordable housing in accordance with SB 35 requirements;  Consistent with the local government’s objective zoning and design review standards; and  Willing to pay construction workers the state-determined “prevailing wage.” A project does not qualify for SB 35 streamline processing if:
 A coastal zone, conservation lands, or habitat for protected species;  Prime farmland or farmland of statewide importance;
 Wetlands or lands under conservation easement;
 A very high fire hazard severity zone;
 Hazardous waste site;
 Earthquake fault zone;
 Flood plain or floodway;
 A site with existing multi-family housing that has been occupied by tenants in the last ten years or is subject to rent control; or
 A site with existing affordable housing.2
A program is included in Section 4: Housing Plan to establish SB 35 procedures and implement the State requirements as necessary if the City has not made sufficient progress towards its RHNA at any point throughout the planning period.

3. Infrastructure Constraints
Another factor that could constrain new residential construction is the requirement and cost to provide adequate infrastructure (major and local streets; water and sewer lines; and street lighting) needed to serve new residential development. In most cases, where new infrastructure is required, it is funded by the developer and then dedicated to the City, which is then responsible for its maintenance. Because the cost of these facilities is generally borne by developers, it increases the cost of new construction, with much of that increased cost often “passed on” in as part of home rental or sales rates.

Dry Utilities
Dry utilities include electric, telephone, TV, internet, and gas service in a community. The various utility providers are responsible for providing these necessary resources to new housing units.

Electrical
Pacific Gas and Electric Company (PG&E) provides electricity and electric services in the City of Brentwood.

Electrical infrastructure in the project area is located aboveground on utility poles as well as belowground.

Pacific Gas and Electric Company continues to provide energy to customers through a series of methods 2 JD Supra Knowledge Center, “How California’s SB 35 Can Be Used to Streamline Real Estate Development Projects”, Accessed September 30, 2021.

Brentwood 2023-2031 Housing Element
Section 3: Housing Constraints, Resources, and Fair Housing 3-44 including oil and natural gas, renewable energy resources and alternative diverse supplies. The power mix delivered to customers includes the following greenhouse gas-free technologies:
 Non-emitting nuclear generation (43 percent)
 Large hydroelectric facilities (10 percent)
 Eligible renewable resources, such as wind, geothermal, biomass, solar and small hydro (31 percent)
 Natural gas (16 percent)
Pacific Gas and Electric Company is responsible for providing service to all existing and future development in Brentwood.

Natural Gas
Pacific Gas and Electric Company (PG&E) also provides natural gas services in the City of Brentwood.

Natural gas pipelines are located belowground. As a public utility, PG&E is under the jurisdiction of the California Public Utilities Commission (CPUC) which regulates natural gas rates and natural gas services, including in state transportation over the utilities’ transmission and distribution pipelines system, storage, procurement, metering, and billing. Pacific Gas and Electric Company is responsible for providing service to residential, industrial, and commercial customers in Brentwood.

Water Supply
The City of Brentwood Water Operations Division serves a population of approximately 65,118 within a service area of approximately 14.8 square miles as of 2020. The Division is responsible for providing a safe and reliable source of water to Brentwood households, including 2,701 million gallons per year (MGY) to single-family residential and 116 MGY to multi-family residential.

Brentwood Water Source
The City of Brentwood receives its water supply from several sources, both surface water from the Delta and groundwater from existing wells located in the East Contra Costa Subbasin. The City pumps groundwater from an alluvial basin underlying the City. The City has nine permitted groundwater wells within its service area, five of which are active wells. The total design capacity of the wells is approximately

6.62 million gallons per day (MGD). The firm design capacity of the wells, where firm capacity is the capacity of all the wells minus the capacity of the largest well, is approximately 5.18 MGD.

The City has purchased a permanent capacity share of 6 MGD at the Randall-Bold Water Treatment Plant (RBWTP) and may use additional capacity on an as-need basis. The City anticipates using the entire 6 MGD but does not project to use additional capacity in future years. Currently, the City utilizes at least 1.7 MGD based on existing customer connections in overlap with Contra Costa Water District’s (CCWD) service area.

Contra Costa Water District has operated the RBWTP since 1992. The RBWTP has a design capacity to treat up to 50 MGD. The RBWTP is jointly owned by Diablo Water District and CCWD.

Water Maintenance and Repair
The City’s water distribution system includes about 300 miles of water mains. The City of Brentwood Water Operations Division is responsible for the maintenance and operation of the City's water mains and valves that are located underground.

Water Production
The City of Brentwood Water Operations Division operates, maintains, and disinfects the City of Brentwood’s water supply. City of Brentwood Water Treatment Plant receives it water from Local

Brentwood 2023-2031 Housing Element
Section 3: Housing Constraints, Resources, and Fair Housing 3-45 Groundwater Basins (East Contra Costa Subbasin), Local Surface Water (San Joaquin River Delta - Old River, Middle River, and Rock Slough) and imported surface water (State Water Project water RBWTP).

Water Quality
The City of Brentwood Water Operations Division is responsible for providing residents with a reliable, safe, clean, potable and domestic water supply. The City of Brentwood Water Operations Division is required to test the quality of the water it serves in order to guard the health of our customers and the general public. Federal, state and local agencies all have a role to play in setting water quality standards.

Water quality samples results are compiled in a monthly report and forwarded to the State Water Resources Control Board, Division of Drinking Water.

Water System Services
The City of Brentwood Water Operations Division assists customers with any questions regarding water quality, water pressure, consumption usage, any concern with water meters, leak detection, utilities inspections and underground utility locating. The City’s Water Systems Services webpage provides tips and information for proper water systems care for property owners as well as additional resources.

Water Demand
In 2020, the City’s total water demand was approximately 4,015 MGY of potable and non-potable water.

The City’s single family and multifamily residential combined are projected to use 2,817 MGY in the year 2020, increasing approximately 7 percent by 2040. These amounts will likely change depending on State mandates in response to current drought conditions.

Wastewater
The City of Brentwood Wastewater Division provides sanitary sewer service for the City of Brentwood.

The City of Brentwood maintains the sewer main lines and service laterals to the property line.

The main goals of the City of Brentwood Wastewater Division are as follows:
 Minimize the number and impact of sanitary sewer overflows;  Maintain existing infrastructure and plan for future Capital Improvement Plan projects;  Continue to provide capacity evaluation for the collection system and plan for future growth;  Develop a plan to increase the number of staff as needed to meet the obligations of the Sewer System Management Plan; and
 Operate in a safe and efficient manner.

Fire and Emergency Services
The City of Brentwood’s fire services are provided by Contra Costa County Fire Protection District (“CCCFPD”). Effective July 1, 2022, the East Contra Costa Fire Protection District (ECCFPD), who historically has provided fire services to the City of Brentwood, annexed with the CCCFPD. ECCFPD historically served the cities of Brentwood and Oakley and the townships of Discovery Bay, Bethel Island, Knightsen, Byron, Marsh Creek and Morgan Territory. CCCFPD is an independent special district and provides fire protection services in and around 1111 cities and unincorporated communities in the County including Brentwood.

The District is a full-service agency providing fire suppression, fire prevention, emergency medical, rescue, and ambulance transport. The District’s service area spans over 555 square miles of rural, suburban and urban development. The CCCFPD has 31 fire stations dispersed throughout the district. Within the City of Brentwood, the department has one fire station, Fire Station 52. The station provides 24-hour protection and response to the City of Brentwood’s residents, businesses, and visitors. The department’s primary goals are identified as follows:

Brentwood 2023-2031 Housing Element
Section 3: Housing Constraints, Resources, and Fair Housing 3-46  Ensure financial stability and sustainability;
 Reduce response times for emergency services throughout the District;  Maintain a high-performing workforce;
 Modernize stations, apparatus, and equipment; and
 Develop a community risk reduction program.

Then in 2021, while still with ECCFPD, ECCFPD received 8,481 calls for service, an 11 percent increase from 2020. Fire Station 52 had 4,059 “roll outs” in 2021, a 13 percent increase from 2020. Roll outs are how many times an engine company gets called for service. For example, a structure fire is counted as one call for the district, however all three engine companies need to respond, thus creating three roll outs for service for the incident. The ECCFPD’s average response time was 8:42 in 2021. Response times are anticipated to improve with the annexation with CCCFPD. CCCFPD is an all risk department, which responds to all types of fires, medical emergencies, technical rescues, hazardous material incidents, and enforces the Fire Prevention Code.

Emergency Medical Services (EMS)
The CCCFPD is responsible for keeping up with emergency medical mandates, equipment, and program development for both advanced and basic life support education and training. Every firefighter in the district has some level of EMS training which requires recertification and continued education.

Community Emergency Response Team
The Community Emergency Response Team (CERT) Program educates people about disaster preparedness for hazards that may impact their area and trains them in basic disaster response skills, such as fire safety, light search and rescue, team organization, and disaster medical operations. Using the training learned in the classroom and during exercises, CERT members can assist others in their neighborhood or workplace following an event when professional responders are not immediately available to help. CERT members also are encouraged to support emergency response agencies by taking a more active role in emergency preparedness projects in their community. The Brentwood Police Department offers CERT training for those community members interested in this type of community service.

Police Services
The Brentwood Police Department (BPD) acts as the City’s enforcement agency to provide general law enforcement. Established in 1948, the Brentwood Police Department services an area of approximately 14 square miles. The City is divided up into 4 separate, geographical beats. The BPD currently has 71 sworn police officer positions and another 36 civilian support staff positions. In addition to permanent staff, the BPD have approximately 20 volunteers who are citizens of the community and assist with our day to day operations. The BPD has one station located in the southern part of the City. The BPD is led by Chief of Police, Tom Hansen. The BPD has two divisions, the Field Operations Division and the Support Services Division.

Field Operations Division
The Field Operations Division is responsible for front line law enforcement services in the City of Brentwood. The Field Operations Division command staff consist of a Captain who oversees the Field Operations Division, two Field Lieutenants who are the day and evening Watch Commanders, six Field teams that are responsible for calls for service, the Traffic Safety Unit, the School Resource Officers assigned to the schools, two K-9 Units, the Field Training Officer Program, Community Service Officers deployed in the field as support staff and S.W.A.T.

Brentwood 2023-2031 Housing Element
Section 3: Housing Constraints, Resources, and Fair Housing 3-47 Personnel assigned to the Field Operations Division are tasked with carrying out the Brentwood Police Department’s mission of protecting and enhancing the quality of life in the community through uncompromised dedication, professionalism, integrity and innovative police services.

In this effort, and in alignment with the Brentwood Police Department’s Strategic Plan, the Field Operations Division works to keep the City of Brentwood and the people in the community safe from harm, and to maintain their quality of life. The Field Operation Division’s priorities are to reduce crime, improve traffic safety, and build community partnerships.

Support Services Division
The Support Services Division is commanded by a Captain and has two Bureaus, Administration and Investigations, each directed by a Lieutenant. The Administration Bureau responsibility includes records, emergency services, recruiting and hiring, training, special projects, special event coordination, financial accounting, and crime prevention services. The Investigations Bureau includes major crimes and special operations investigation units, city planning liaison, the property unit, and the Chaplain’s program.

The Support Services Division provides support and assistance to the Patrol Bureau in order to ensure that officers in the field can provide the highest quality service to residents. Detectives provide expertise to patrol and follow-up on major cases such as domestic violence, homicides, robberies, and other crimes of violence. Detectives also initiate their own investigations especially in the areas of narcotics, vice, child abuse, and sex crimes. Records personnel staff the front counter and provide document processing for the entire department. Records staff are usually the people who answer the phone when a citizen calls into the police department. The property unit maintains found property, property held for safekeeping and as evidence. The training sergeant is responsible for recruiting and facilitating the hiring of all department personnel providing the best people for the BPD.

4. Environmental Constraints
The City of Brentwood may be susceptible to several environmental constraints to the development of housing. While the City’s land, hillsides, and waterways are assets to the community, these features can present risks due to flood, geologic, and seismic hazards. In addition, human-caused risks, such as hazardous materials, can pose risks to community health and safety. Effective planning to prepare for and mitigate the adverse effects of these risks can help ensure that Brentwood maintains a high level of safety for its residents. The City of Brentwood, plans and engages mitigation techniques through the City’s Public Safety Element.

Geological and Seismic Hazards
Geologic and seismic hazards in Brentwood include those related to earthquakes, steep slopes and landslides, erosion, and soil subsidence. Earthquakes pose the greatest potential for far-reaching loss of life or property. Brentwood is located within a 50-mile radius of five active faults. According to the USGS Interactive Fault Map, the nearest active faults zones include the Greenville Fault and the Concord Fault zones. The Greenville Fault has the estimated potential to produce a magnitude 6.8 to 7.0 earthquake.

Residential development within a seismically active zone could expose Brentwood residents to adverse effects.

A lesser geologic hazard relates to soil stability in the City. Hillsides located mostly on the periphery of the City can be subject to landslides and portions of the City have expansive soil types. Expansive clay soils, which can shrink and swell, are common within the City of Brentwood. In addition, areas found in the City may be subject to liquefaction during a seismic event if groundwater is present near the surface.

Brentwood 2023-2031 Housing Element
Section 3: Housing Constraints, Resources, and Fair Housing 3-48 To ensure structural stability, seismic and geologic hazards are addressed through the environmental and development review and permitting process.

Flood Hazards
Potential flooding in Brentwood is attributable to natural flooding (excess rain and watercourse). Flooding becomes particularly hazardous when development encroaches onto floodplains, modifying the landscape and altering natural patterns of conveying excess water during floods. Brentwood's geographic location in proximity to several significant bodies of water contribute to the flood risk within the City. The greatest flood hazard is present mainly along four existing creeks, Marsh Creek, Deer Creek, Dry Creek, and Sand Creek, that are included as flood hazard areas on existing Federal Emergency Management Agency (FEMA) maps.
100-Year Floods
One-hundred-year floods are those that have a 1/100 or one percent chance of occurring in any given year. The 100-year flood is a regulatory standard used by Federal agencies and most states to administer floodplain management programs and is also used by the National Flood Insurance Program (NFIP) as the basis for flood insurance requirements nationwide. Flood insurance rates are based on FEMA designations of flood zones. Standard practice is to avoid or restrict construction within 100-year flood zones, or to engage in flood-proofing techniques such as elevating building pads or constructing walls, dams, and levees. Portions of the City of Brentwood are located within a 100-year flood plain, primarily in the parts of the City along Marsh and Sand Creek. Figure 3-7 shows the 100-year and 500-year flood zones in the City of Brentwood. One (1) percent Annual Chance Flood Hazard zones are 100-year flood zones and 0.2 percent Annual Chance Flood Hazard zones are 500-year flood zones.

Brentwood 2023-2031 Housing Element
Section 3: Housing Constraints, Resources, and Fair Housing 3-49 Figure 3-7: Flood Hazard Zones in Brentwood
Source: FEMA National Flood Hazard Zone Viewer

Brentwood 2023-2031 Housing Element
Section 3: Housing Constraints, Resources, and Fair Housing 3-50 Fire Hazards
The City of Brentwood is prone to fire hazards and the City plans and engages mitigation techniques through the City’s Public Safety Element. The City is at risk of wildland and urban fires.

Wildland Fires
A wildland fire is an uncontrolled fire spreading through vegetative fuels that may expose or consume structures. The wildland fire threat is high in the area surrounding Brentwood because of the region's weather, topography, and native vegetation. Mild and wet winters result in an annual growth of grasses and plants that dry out during the hot summer months and provide fuel for wildfires in the autumn. The areas with the highest threat are generally the undeveloped, mountainous, and hilly sections south and west of the City. There are no Fire Hazard Severity Zones within the City of Brentwood. Figure 3-8 below shows the Wildland Fire Hazard Severity Zones in the area surrounding City of Brentwood.

Urban Fires
Structural and automobile fires are the most common types of urban fires, and they can be caused by a variety of human, mechanical, and natural factors. Urban fires can spread to other structures or areas, particularly if not extinguished promptly. Proactive efforts, such as fire sprinkler systems, fire alarms, fire resistant roofing and construction methods, can help reduce the frequency and severity of urban fires. In newer structures, these safety requirements help confine structural fires to the building or property of origin. In the older areas of Brentwood, where building materials may not be fire rated and structures are not fitted with fire sprinklers, the probability of structural fires spreading to adjacent buildings is much higher. Structural fires are of particular concern in high-density areas, where the potential for fire to spread from one building to the next is greater.

Brentwood 2023-2031 Housing Element
Section 3: Housing Constraints, Resources, and Fair Housing 3-51 Figure 3-8: Fire Hazard Severity Zones in Brentwood
Source: FEMA National Flood Hazard Zone Viewer

Brentwood 2023-2031 Housing Element
Section 3: Housing Constraints, Resources, and Fair Housing 3-52 Toxic Hazards
The western portions of the City occasionally experience oil and gas well and pipeline related hazards. As residential development encroaches into oil fields, potential health and safety risks increase. Risks include blowouts when drilling new wells, spills or blowouts when servicing or reworking existing wells, and soil and groundwater contamination. Areas of the City that are adjacent to oil and gas wells and pipelines would be subject to further environmental review to determine which mitigation measures are required to reduce or eliminate hazards.

Summary of Constraints
Although the City of Brentwood has identified environmental issues above, they do not impact the City’s ability to accommodate the number of units required to meet the RHNA obligation.

The City has reviewed all sites for the above environmental concerns and considerations as well as development regulation and land use restrictions. Additionally, each site has been reviewed for access to infrastructure, water, utilities, and additional development constraints. Where the analysis showed increased barriers to development related to environmental concerned, infrastructure concerns or existing conditions and development concerns (such as fire hazards, hazardous surrounding uses, restrictive development standards, etc.) the sites were removed. The result is a list and analysis of sites which are most ripe for development or redevelopment for housing, a complete analysis of the sites is provided in Appendix B.

The City has never denied a residential development project due to environmental constraints. The environmental concerns noted above would not impede housing development in the future.

B. Financial Resources
Providing an adequate supply of decent and affordable housing requires funding from various sources, the City has access to the following funding sources.

1. Section 8 Housing Choice Vouchers
The Section 8 Housing Choice Voucher program is a Federal government program to assist very lowincome families, the elderly, and the disabled with rent subsidy payments in privately owned rental housing units. Section 8 participants are able to choose any housing that meets the requirements of the program and are not limited to units located within subsidized housing projects. They typically pay 30 to 40 percent of their income for rent and utilities. The Contra Costa County Housing Authority administers and managed the Section 8 Housing Choice vouchers within the City of Brentwood. The City shares information about Section 8 Housing Choice vouchers and other resources available on the City website and at the public counter.

2. Community Development Block Grants (CDBG)
The Community Development Block Grant (CDBG) program provides annual grants on a formula basis to cities to develop viable urban communities by providing a suitable living environment and by expanding economic opportunities, principally for low- and moderate-income persons (up to 80 percent AMI).

CDBG funds can be used for a wide array of activities, including:
 Housing rehabilitation;
 Lead-based paint screening and abatement;

Brentwood 2023-2031 Housing Element
Section 3: Housing Constraints, Resources, and Fair Housing 3-53  Acquisition of buildings and land;
 Construction or rehabilitation of public facilities and infrastructure, and  Public services for low-income households and those with special needs.

Each year, the City of Brentwood receives Community Development Block Grant (CDBG) funds from the U.S. Department of Housing and Urban Development. The City Administration is responsible for administering these funds. These funds must be used to develop viable communities by promoting integrated approaches that provide items such as decent housing, a suitable living environment, and expand economic opportunities for low- and moderate-income persons.

The City of Brentwood does not administer its own CDBG programs and instead participates in the Contra Costa County CDBG program. To obtain funding, applicant projects or programs must meet eligibility requirements and demonstrate that they benefit very low- and low-income persons within the City. The funds are distributed on a competitive basis.

3. HOME Investment Partnership Program
The HOME program provides federal funds for the development and rehabilitation of affordable rental and ownership housing for households with incomes not exceeding 80 percent of area median income.

The program gives local governments the flexibility to fund a wide range of affordable housing activities through housing partnerships with private industry and non-profit organizations. HOME funds can be used for activities that promote affordable rental housing and homeownership by low-income households. The City of Brentwood does not currently receive HOME funds directly but the City participates in the Contra Costa County-administered HOME Consortium, which administers HOME funds to projects in participating jurisdictions.

4. Local Early Action Planning (LEAP) Grant
The City of Brentwood applied for and received a total of $300,000 from the California Department of Housing and Community Development (HCD). LEAP Grants provide funding opportunities for jurisdictions to update their planning documents and implement process improvements that will facilitate or accelerate housing productions to meet the 6th Cycle Regional Housing Needs Assessment (RHNA).

5. SB 2 Grant
To supplement the cost of the City’s effort to update the streamlining process of affordable housing, the City has been awarded an SB 2 Planning Grant Program grant from HCD. The SB 2 program includes improvements to expedite local planning processes. In 2020, the City received $310,000 from the SB 2 Grant.

6. City of Brentwood Housing Trust Fund
The City of Brentwood’s Affordable Housing Program established the Brentwood Housing Trust Fund that can be used to purchase, construct or repair single-family or multifamily rental unit inside the city limits.

Brentwood 2023-2031 Housing Element
Section 3: Housing Constraints, Resources, and Fair Housing 3-54 C. Opportunities for Energy Conservation

1. Energy Use and Providers
Pacific Gas and Electric Company (PG&E) provides electricity and natural gas service for the City. Natural gas is a “fossil fuel” and is a non-renewable resource. The natural gas transmission pipelines within the City are owned and operated by PG&E. Pacific Gas and Electric Company has the capacity and resources to deliver gas except in certain situations that are noted in state law. As development occurs, PG&E will continue to extend its service to accommodate development and supply the necessary gas lines. Electricity is provided on an as-needed basis to customers within existing structures in the City. Every year SCE expands and improves existing facilities according to demand.

Pacific Gas and Electric Company offers programs to promote the efficient energy use and assist lowerincome customers. Pacific Gas and Electric Company participates in the Low-Income Home Energy Assistance Program and Energy Savings Assistance Program to help homeowners and renters conserve energy and control costs. Eligible customers receive no-cost weatherization, including attic insulation, energy efficient refrigerators, energy-efficient furnaces, weather stripping, caulking, low-flow showerheads, water heater blankets, and door and building envelope repairs which reduce air infiltration.

2. Energy Conservation
The primary uses of energy in urban areas are for transportation lighting, water heating, and space heating and cooling. The high cost of energy demands that efforts be taken to reduce or minimize the overall level of urban energy consumption. Energy conservation is important in preserving non-renewable fuels to ensure that these resources are available for use by future generations. There are also a number of benefits associated with energy conservation including improved air quality and lower energy costs.

Energy conservation strategies can help reduce consumptions of energy which would reduce monthly costs to homeowners and renters. Examples of energy conservation strategies include weatherization such as installation of more efficient appliances, and solar energy systems. Buildings can also be designed to incorporate energy conservation strategies such as cooling materials and building orientation. The City encourages energy conservation strategies and has seen an increase in solar energy system installations.

D. Affirmatively Furthering Fair Housing (AFFH)
Beginning January 1, 2019, AB 686 established new requirements for all California jurisdictions to ensure that local laws, programs, and activities affirmatively further fair housing. All Housing Elements due on or after January 1, 2021 must contain an Assessment of Fair Housing (AFH) consistent with the core elements of the analysis required by the federal Affirmatively Further Fair Housing Final Rule of July 16, 2015.

Fair housing is a condition in which individuals of similar income levels in the same housing market have like ranges of choice available to them regardless of race, color, ancestry, national origin, age, religion, sex, disability, marital status, familial status, source of income, sexual orientation, or any other arbitrary factor. Under State law, affirmatively furthering fair housing means “taking meaningful actions, in addition to combatting discrimination, that overcome patterns of segregation and foster inclusive communities free from barriers that restrict access to opportunity based on protected characteristics”. These characteristics can include, but are not limited to race, religion, sex, marital status, ancestry, national origin, color, familiar status, or disability.

Brentwood 2023-2031 Housing Element
Section 3: Housing Constraints, Resources, and Fair Housing 3-55 The Analysis of Impediments (AI) to Fair Housing Choice, prepared by Contra Costa County for 2020 to 2025, examines housing conditions, economics, policies, and practices in order to ensure that housing choices and opportunities for all residents are available in an environment free from discrimination. The AI assembles fair housing information, identifies any existing impediments that limit housing choice, and proposes actions to mitigate those impediments.

1. Assessment of Fair Housing Issues
Fair Housing Enforcement and Outreach
Fair housing enforcement and outreach capacity refers to the ability of a locality and fair housing entities to disseminate information related to fair housing laws and rights and provide outreach and education to community members. Enforcement and outreach capacity also includes the ability to address compliance with fair housing laws, such as investigating complaints, obtaining remedies, and engaging in fair housing testing. The Fair Employment and Housing Act and the Unruh Civil Rights Act are the primary California fair housing laws. California state law extends anti-discrimination protections in housing to several classes that are not covered by the federal Fair Housing Act (FHA) of 1968, including prohibiting discrimination on the basis of sexual orientation.

In Contra Costa County, local housing, social services, and legal service organizations include the Fair Housing Advocates of Northern California (FHANC), Eden Council for Hope and Opportunity (ECHO) Fair Housing, Bay Area Legal Aid, and Pacific Community Services.

Table 3-15: Fair Housing Advocacy Organizations, Contra Costa County Organization Focus Areas
Fair Housing Advocates of Northern
California (FHANC)
Non-profit agency that provides fair housing information and literature in a number of different languages, primarily serves Marin, Sonoma, and Solano County but also has resources to residents outside of the above geographic areas.

Eden Council for Hope and Opportunity
(ECHO) Fair Housing
Housing counseling agency that provides education and charitable assistance to the general public in matters related to obtaining and maintaining housing.

Bay Area Legal Aid
Largest civil legal aid provider serving seven Bay Area counties. Has a focus area in housing preservation and homelessness task force to provide legal services and advocacy for those in need.

Pacific Community Services
Private non-profit housing agency that serves East Contra Costa County (Bay Point, Antioch, and Pittsburg) and provides fair housing counseling as well as education and outreach
In Brentwood, the City has an Affordable Housing Division that provides various programs and resources to those who qualify under the programs’ income guidelines. These programs include down payment assistance, first-time homebuyer programs, a list of preferred lenders, and rental housing programs. ECHO Fair Housing also provides housing/rental assistance to the City’s residents.

While these organizations provide valuable assistance, the capacity and funding that they have is generally insufficient.

Fair Housing Enforcement
California’s Department of Fair Employment and Housing (DFEH) has statutory mandates to protect the people of California from discrimination pursuant to the California Fair Employment and Housing Act (FEHA), Ralph Civil Rights Act, and Unruh Civil Rights Act (with regards to housing). The FEHA prohibits discrimination and harassment on the basis of race, color, religion, sex (including pregnancy, childbirth,

Brentwood 2023-2031 Housing Element
Section 3: Housing Constraints, Resources, and Fair Housing 3-56 or related medical conditions), gender, gender identity, gender expression, sexual orientation, marital status, military or veteran status, national origin, ancestry, familial status, source of income, disability, and genetic information, or because another person perceives the tenant or applicant to have one or more of these characteristics.

The Unruh Civil Rights Act (Civ. Code, §51) prohibits business establishments in California from discriminating in the provision of services, accommodations, advantages, facilities and privileges to clients, patrons and customers because of their sex, race, color, religion, ancestry, national origin, disability, medical condition, genetic information, marital status, sexual orientation, citizenship, primary language, or immigration status. The Ralph Civil Rights Act (Civ. Code, § 51.7) guarantees the right of all persons within California to be free from any violence, or intimidation by threat of violence, committed against their persons or property because of political affiliation, or on account of sex, race, color, religion, ancestry, national origin, disability, medical condition, genetic information, marital status, sexual orientation, citizenship, primary language, immigration status, or position in a labor dispute, or because another person perceives them to have one or more of these characteristics.

REGIONAL TRENDS
Based on DFEH Annual Reports, Table 3-16 shows the number of housing complaints filed by Contra Costa County to DFEH between 2015–2020. A slight increase in the number of complaints precedes the downward trend from 2016–2020. Note that fair housing cases alleging a violation of FEHA can also involve an alleged Unruh violation as the same unlawful activity can violate both laws. DFEH creates companion cases that are investigated separately from the housing investigation.

Table 3-16 Number of DFEH Housing Complaints in Contra Costa County (2015-2020) Year Housing Unruh Civil Rights Act
2015 30 5
2016 32 2
2017 26 2
2018 22 2
2019 22 2
2020 20 1
Total 152 14
Source: CA Department of Fair Employment and Housing
The Department of Housing and Urban Development’s Office of Fair Housing and Equal Opportunity (HUD FHEO) enforces fair housing by investigating complaints of housing discrimination. Table 3-17 shows the number of FHEO Filed Cases by Protected Class in Contra Costa County between 2015 and 2020. Cases for 2020 were significantly lower because data was not collected after June 30, 2020. A total of 148 cases were filed between 2015 and June 30, 2020, with disability being the top allegation of basis of discrimination followed by familial status, race, national origin, and sex. These findings are consistent with national trends stated in FHEO’s FY 2020 State of Fair Housing Annual Report to Congress where disability was also the top allegation of basis of discrimination.

Brentwood 2023-2031 Housing Element
Section 3: Housing Constraints, Resources, and Fair Housing 3-57 Table 3-17: Number of FHEO Filed Cases by Protected Class in Contra Costa County (2015–2020) Year Number of
Filed Cases Disability Race National Origin Sex Familial Status 2015 28 17 4 2 2 4
2016 30 14 8 7 5 6
2017 20 12 3 5 1 5
2018 31 20 6 3 4 9
2019 32 27 4 4 4 1
2020 7 4 1 0 2 1
Total 148 94 26 21 18 26
Percentage of Total Filed
Cases
*Note that cases may be filed
on more than one basis.

63.5% 17.5% 14.2% 12.2% 17.6%
Source: Data.Gov - Department of Housing and Urban Development Office of Fair Housing and Equal Opportunity (FHEO) Filed Cases, https://catalog.data.gov/dataset/fheo-filed-cases Table 3-17 indicates that the highest number of fair housing complaints in Contra Costa County are due to discrimination against those with disabilities, followed by income source, race, and national origin.

Note, however, that no further breakdown of the number of DFEH complaints or FHEO cases are provided on a city level. A summary of ECHO’s Fair Housing Complaint Log for Contra Costa County on fair housing issues, actions taken, services provided, and outcomes can be found in Table 3-18 and Table 3-19.

Table 3-18: ECHO’s Fair Housing Issue Outcomes (2020-2021) Protected Class
Testers Sent
for
Investigation
Referred to
Attorney
Conciliation
with Landlord
Client
Provided with
Counseling
Client
Provided with
Brief Service
Total
Race 21 0 0 2 0 23
Marital Status 0 0 0 1 0 1
Sex 0 0 0 0 0 0
Religion 0 0 0 0 0 0
Familial Status 0 0 0 3 0 3
Sexual Orientation 0 0 0 0 0 0
Sexual Harassment 0 0 0 1 0 1
Income 15 0 1 7 1 24
Disability 7 1 14 33 5 60
National Origin 13 0 0 1 0 14
Other 0 0 1 11 5 17
Total 56 94 26 21 18 143

1. Testers sent for investigation; 3. Referred to attorney; 5. Conciliation with landlord; 6. Client provided with counseling; 7.

Client provided with brief service; Source: ECHO Fair Housing (2020 - 2021)

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Section 3: Housing Constraints, Resources, and Fair Housing 3-58 Table 3-19: ECHO’s Fair Housing Issues Outcomes Continued (2020-2021) Protected Class
Counseling
Provided Education
to Landlord
Insufficient
Evidence
Preparing
Site Visit
Referred To

DFEH/HUD
Successful
Mediation Total
Landlord Tenant
Race 0 0 2 20 0 1 0 23
National Origin 0 0 1 13 0 0 0 14
Marital Status 0 0 0 1 0 0 0 1
Sex 0 0 0 0 0 0 0 0
Disability 2 25 2 12 0 4 15 60
Religion 0 0 0 0 0 0 0 0
Sexual
Orientation 0 0 0 0 0 0 0 0
Familial Status 0 3 0 0 0 0 0 3
Income Source 3 3 0 16 1 0 1 24
Sexual
Harassment 0 8 2 2 1 4 0 17
Other 0 0 0 0 0 1 0 1
Total 5 39 7 64 2 10 16 143
Services that were not provided include (2.) Case tested by phone; (4.) Case referred to HUD and (8.) Case accepted for full representation. The most common action(s) taken/services provided are providing clients with counseling, followed by sending testers for investigation, and conciliation with landlords. Regardless of actions taken or services provided, almost 45% of cases are found to have insufficient evidence. Only about 12% of all cases resulted in successful mediation.

Source: ECHO Fair Housing (2020 - 2021)

LOCAL TRENDS
In Brentwood, only three general fair housing inquiries were made to ECHO between 2016-2021. One client was provided with counseling on an inquiry on income source. Testers were sent for investigation in two inquiries that were racial in nature, but insufficient evidence was found.

Fair Housing Testing
Fair housing testing is a randomized audit of property owners’ compliance with local, state, and federal fair housing laws. Initiated by the Department of Justice’s Civil Rights Division in 1991, fair housing testing involves the use of an individual or individuals who pose as prospective renters for the purpose of determining whether a landlord is complying with local, state, and federal fair housing laws.

REGIONAL TRENDS
ECHO conducts fair housing investigations in Contra Costa County (except Pittsburg). The 2020 Contra Costa County AI did not report any findings on fair housing testing on the county level nor at the local level for the City of Brentwood, however, it does bring to attention that private discrimination is a problem in Contra Costa County that continues to perpetuate segregation.

Fair Housing Education and Outreach

REGIONAL TRENDS
Fair housing outreach and education is imperative to ensure that those experiencing discrimination know when and how to seek help. Find below a more detailed description of fair housing services provided by local housing, social services, and legal service organizations.

Brentwood 2023-2031 Housing Element
Section 3: Housing Constraints, Resources, and Fair Housing 3-59 Fair Housing Advocates of Northern California (FHANC)
FHANC is a non-profit agency with a mission to actively support and promote fair housing through education and advocacy. Fair housing services provided to residents outside of Marin, Sonoma, or Solano County include foreclosure prevention services and information, information on fair housing law for the housing industry, and other fair housing literature. The majority of the fair housing literature is provided in Spanish and English, with some provided in Vietnamese and Tagalog.

Eden Council for Hope and Opportunity (ECHO) Fair Housing ECHO Fair Housing is a HUD-approved housing counseling agency that aims to promote equal access in housing, provide support services to aid in the prevention of homelessness, and promote permanent housing conditions. The organization provides education and charitable assistance to the general public in matters related to obtaining and maintaining housing in addition to rental assistance, housing assistance, tenant/landlord counseling, homeseeking, homesharing, and mortgage and home purchase counseling. In Contra Costa County, ECHO Fair Housing provides fair housing services, first-time home buyer counseling and education, and tenant/landlord services (rent review and eviction harassment programs are available only in Concord). Although ECHO serves most of Contra Costa County, only one fair housing counselor serves the County. Fair housing services encompasses:
 Counseling, investigation, mediation, enforcement, and education.  First-time home buyer counseling provides one-on-one counseling with a Housing Counselor on the homebuying process. The Housing Counselor will review all documentation, examine and identify barriers to homeownership, create an action plan, and prepare potential homebuyers for the responsibility of being homeowners. The Housing Counselor will also review the credit reports, determine what steps need to be taken to clean up adverse credit, provide counseling on money-saving methods, and assist in developing a budget.  First-time home buyer education provides classroom training regarding credit information, home ownership incentives, home buying opportunities, predatory lending, home ownership responsibilities, government-assisted programs, as well as conventional financing. The class also provides education on how to apply for HUD-insured mortgages, purchase procedures, and alternatives for financing the purchase. Education also includes information on fair housing and fair lending and how to recognize discrimination and predatory lending procedures, and locating accessible housing if needed.
 ECHO’s Tenant/Landlord Services provides information to tenants and landlords on rental housing issues such as evictions, rent increases, repairs and habitability, harassment, illegal entry, and other rights and responsibilities regarding the tenant/landlord relationship. Trained mediators assist in resolving housing disputes through conciliation and mediation  In cities that adopt ordinances to allow Rent Reviews (City of Concord only in Contra Costa County), tenants can request a rent review from ECHO Housing by phone or email. This allows tenants who experience rent increases exceeding 10% in a 12-month period to seek non-binding conciliation and mediation services.

Though the Contra Costa County Consortium Analysis of Impediments (AI) to Fair Housing states that the organization provides information in Spanish, the ECHO website is predominantly in English with options to translate the homepage into various languages. Navigating the entire site may be difficult for the limited-English proficient (LEP) population.

Bay Area Legal Aid (BayLegal)
BayLegal is the largest civil legal aid provider serving seven Bay Area counties (Alameda, Contra Costa, Marin, Napa, San Francisco, San Mateo, and Santa Clara). With respect to affordable housing, BayLegal

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Section 3: Housing Constraints, Resources, and Fair Housing 3-60 has a focus area in housing preservation (landlord-tenant matters, subsidized and public housing issues, unlawful evictions, foreclosures, habitability, and enforcement of fair housing laws) as well as a homelessness task force that provides legal services and advocacy for systems change to maintain housing, help people exit homelessness, and protect unhoused persons’ civil rights. The organization provides translations for their online resources to over 50 languages and uses volunteer interpreters/translators to help provide language access. Its legal advice line provides counsel and advice in different languages. Specific to Contra Costa County, tenant housing resources are provided in English and Spanish.

The Housing Preservation practice is designed to protect families from illegal evictions, substandard housing conditions, and wrongful denials and terminations of housing subsidies. The practice also works to preserve and expand affordable housing and protect families from foreclosure rescue scams. BayLegal helps low-income tenants obtain or remain in safe affordable housing by providing legal assistance in housing-law related areas such as public, subsidized (including Section 8 and other HUD subsidized projects) and private housing, fair housing and housing discrimination, housing conditions, rent control, eviction defense, lock-outs and utility shut-offs, residential hotels, and training advocates and community organizations.

BayLegal also provides free civil legal services to low-income individuals and families to prevent homelessness and increase housing stability as well as assist unhoused youth/adults address legal barriers that prevent them from exiting homelessness. This is done through a mix of direct legal services, coalition building and partnerships, policy advocacy, and litigation to advocate for systems change that will help people maintain housing, exit homelessness, and protect unhoused persons’ civil rights. The Homelessness Task Force (HTF) was developed in response to complex barriers and inequities contributing to homelessness and strives to build capacity and develop best practices across the seven aforementioned counties to enhance BayLegal’s coordinated, multi-systems response to homelessness.

Pacific Community Services, Inc. (PCSI)
PCSI is a private non-profit housing agency that serves East Contra Costa County (Bay Point, Antioch, and Pittsburg) and provides fair housing counseling in English and Spanish. Housing Counseling Services provided include:
 Foreclosure Prevention: Consists of a personal interview and the development of a case management plan for families to keep their homes and protect any equity that may have built up.

Relief measures sought include: loan modification or reduced payments, reinstatement and assistance under ‘Keep Your Home’ program, forbearance agreements, deed-in-lieu of foreclosure, refinancing or recasting the mortgage, or sale of the property  Homeownership Counseling: Prepares first-time buyers for a successful home purchase by helping them in budgeting, understanding the home purchase process, and understanding the fees that lenders may charge to better prepare new buyers when acquiring their first home.  Rental Counseling; Tenant and Landlord Rights: PCSI provides information and assistance in dealing with eviction and unlawful detainer actions, deposit returns, habitability issues, getting repairs done, mediation of tenant/landlord disputes, assisting tenant organizations, legal referrals to Bay Area Legal Aid & Bar Association resources, pre-rental counseling and budgeting  Fair Housing Services: Include counseling regarding fair housing rights, referral services and education and outreach. PCSI offers training for landlords and owners involving issues of compliance with federal and state fair housing regulations.

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Section 3: Housing Constraints, Resources, and Fair Housing 3-61  Fair Housing Education and Outreach: Offers informative workshops for social service organizations and persons of protected categories. These workshops are designed to inform individuals how to recognize and report housing discrimination.

Though PCSI’s list of available services is comprehensive, their website lacks contact information, resources, and accessibility.

LOCAL TRENDS
The City of Brentwood provides Affordable Housing Programs such as down payment assistance, first time homebuyer programs, affordable rental housing, and a list of preferred lenders for home mortgages. The city also directs its residents to external housing resources (e.g., BayLegal, HUD, etc.) to assist in preserving homeownership, provide housing counseling, and provide legal assistance.

Fair Housing Laws
The following lists State and local fair housing laws and specifies how the City complies:
 Government Code section 65008: This statute forbids discrimination against affordable housing developments, developers, or potential residents by local agencies when carrying out their planning and zoning powers.
o The City has identified candidate sites to address RHNA equitably throughout the City and in proximity to public transportation, community resources, services, and employment.

The sites selected are assessed in conjunction with the AFFH requirements throughout this section and summarized in the “AFFH Findings and Sites Summary.” Overall, the City seeks to promote a variety of housing types at all affordability levels throughout Brentwood in a manner that does not discriminate.
 Government Code section 8899.50: “Affirmatively furthering fair housing” 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.
o The City implements programs and actions in compliance with State law that affirmatively further fair housing. As detailed in Section 4 Policies H.1-1 through H.1-4, the City administers programs to promote equal housing access and affordable resources.  Government Code section 11135: No person in the State of California shall, on the basis of race, national origin, ethnic group identification, religion, age, sex, sexual orientation, color, genetic information, or disability, be unlawfully denied full and equal access to the benefits of, or be unlawfully subjected to discrimination under, any program or activity that is conducted, operated, or administered by the state or by any state agency, is funded directly by the state, or receives any financial assistance from the state.
o Potential State funding is associated with the following programs: H.1d, H.1g, H.2d, H.2e, H.2f, H.3f, H.4a, H.4e, H.4f, The City continues to encourage programs that promote full and equal access to all programs and activities. The City’s official website and public counter provides access to all programs and activities happening in the City.  Density Bonus Law: Density bonuses allow developers of market-rate housing to build higherdensity housing in exchange for having a certain portion of their units offered at affordable prices. o Assembly Bill 2345, Chapter 197 Statutes 2020 requires a density bonus of up to 50 percent when a qualifying percentage of Below Market Rate (BMR) units are proposed.

Section 4 Action H.2i: Density Bonus Ordinance works to update the Density Bonus Ordinance in compliance with State law requirements.

Brentwood 2023-2031 Housing Element
Section 3: Housing Constraints, Resources, and Fair Housing 3-62  Housing Accountability Act: This Act establishes limitations to a local government’s ability to 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.
o The City implements programs such as fee incentives, funding, and review of zoning procedures to facilitate and encourage housing development.  Housing Element Law: California’s Housing Element Law acknowledges that, in order for the private market to adequately address the housing needs and demand of Californians, local governments must adopt plans and regulatory systems that provide opportunities for (and do not unduly constrain) housing development.
o The City’s Housing Element identifies and includes an analysis of existing and projected housing needs and a statement of goals, policies, quantified objectives, financial resources, and scheduled programs.
 Housing Plan Programs: The Housing Element of the General Plan identifies the City’s housing conditions and needs, establishes goals, objectives, policies, and programs to meet the housing needs.
o Section 4: Housing Plan details the City’s goals, policies, programs, and objectives. The City addresses the need for additional housing opportunities, removing constraints to affordable housing, improving the existing housing stock, and providing equal opportunities for current and future residents of Brentwood.

Integration and Segregation
Race/Ethnicity
Segregation is defined as the separation or isolation of a race/ethnic group, national origin group, individuals with disabilities, or other social group by enforced or voluntary residence in a restricted area, by barriers to social connection or dealings between persons or groups, by separate educational facilities, or by other discriminatory means.

To measure segregation in a given jurisdiction, the US Department of Housing and Urban Development (HUD) provides racial or ethnic dissimilarity trends. Dissimilarity indices are used to measure the evenness with which two groups (frequently defined on racial or ethnic characteristics) are distributed across the geographic units, such as block groups within a community. The index ranges from 0 to 100, with 0 meaning no segregation and 100 indicating complete segregation between the two groups. The index score can be understood as the percentage of one of the two groups that would need to move to produce an even distribution of racial/ethnic groups within the specified area. For example, if an index score is above 60, 60% of people in the specified area would need to move to eliminate segregation. The following shows how HUD views various levels of the index:
 <40: Low Segregation
 40-54: Moderate Segregation
 >55: High Segregation

REGIONAL TRENDS
Contra Costa County is a large, diverse jurisdiction in which people of color comprise a majority of the population. As of the 2010 Census, 47.75% of residents were non-Hispanic Whites, 8.92% of residents were non-Hispanic Blacks, 24.36% were Hispanics, 14.61% were non-Hispanic Asians or Pacific Islanders,

0.28% were non-Hispanic Native Americans, 3.77% were non-Hispanic multiracial individuals, and 0.30%

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Section 3: Housing Constraints, Resources, and Fair Housing 3-63 identified as some other race. Refer to Figure 3-9 for the distribution and proportion of non-white residents at the block group level3.

In Contra Costa County, all minority (non-White) residents combined are considered moderately segregated from White residents, with an index score of 41.86 at the Census tract level and 44.93 at the block group level (Table 3-20). Segregation between non-white and white residents has remained relatively steady since 1990. However, since 1990 segregation has increased from low to moderate levels for Hispanic residents, the largest increase amongst all racial/ethnic groups. This trend is commonly seen throughout the State and is likely attributed to an increase of Hispanic residents during the migration boom of the mid-to-late 1990s. A 2% increase in segregation also occurred for Asian or Pacific Islander residents. Block group level data reveals that segregation is more prominent amongst Asian or Pacific Islander residents than what is measured at the tract level (index score of 40.55 at the block group level versus 35.67 at the tract level). For Black residents, segregation has decreased by 13% since 1990. The proportion of Black residents has remained relatively steady during this same time period, indicating segregation has been diminishing for the Black population.

Figure 3-9: Racial Demographics in Contra Costa County
3 Block groups (BGs) are the next level above census blocks in the geographic hierarchy (census blocks are the smallest geographic area for which the Bureau of the Census collects and tabulates decennial census data). A BG is a combination of census blocks that is a subdivision of a census tract or block numbering area (BNA). A county or its statistically equivalent entity contains either census tracts or BNAs; it cannot contain both. The BG is the smallest geographic entity for which the decennial census tabulates and publishes sample data.

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Section 3: Housing Constraints, Resources, and Fair Housing 3-64 Table 3-20: Racial/Ethnic Dissimilarity Trends (1990–2020) in Contra Costa County Dissimilarity Index 1990 Trend 2000 Trend 2010 Trend Current (2010 Census Block Group)4
Non-White/White 41.19 41.95 41.86 44.93
Black/White 67.52 62.54 58.42 61.80
Hispanic/White 36.70 45.24 48.07 49.49
Asian or Pacific Islander/White 34.89 32.73 35.67 40.55 Source: HUD’s Affirmatively Furthering Fair Housing Tool (AFFH-T), Table 3 – Racial/Ethnic Dissimilarity Trends, Data version:

AFFHT006, released July 10th, 2020.

A key aspect of fair housing choice is equal access to credit for the purchase or improvement of a home, particularly considering the continued impacts of the lending/credit crisis. In the past, credit market distortions and other activities such as “redlining” were prevalent and prevented some groups from having equal access to credit. The Community Reinvestment Act (CRA) in 1977 and the subsequent Home Mortgage Disclosure Act (HMDA) were designed to improve access to credit for all members of the community and hold the lender industry responsible for community lending. Under HMDA, lenders are required to disclose information on the disposition of home loan applications and on the race or national origin, gender, and annual income of loan applicants.

However, lending discrimination continues to be a contributing factor to disproportionate housing needs, as class groups who struggle to obtain access to loans are more likely to experience housing problems such as cost burdens, overcrowding, and substandard housing, and to be renters rather than homeowners. When banks and other financial institutions deny loan applications from people of color, they are less likely to achieve home ownership and instead must turn to the rental market. As Contra Costa’s rental housing market grows increasingly unaffordable, Black or African American population and Hispanic or Latino population are disproportionately impacted. Table 3-21 below shows that home loan applications by Black or African American and Hispanic or Latino individuals are denied at higher rates than those of White or Asian individuals. Because Black or African American and Hispanic or Latino individuals in the region are denied loans at far higher rights than White or Asian individuals, their families are far more likely to have less access to quality education, healthcare, and employment.

When minorities are unable to obtain loans, they are far more likely to be relegated to certain areas of the community. While de jure segregation (discriminatory separation of groups of people by governmentenacted law) is currently illegal, the drastic difference in loans denied between White individuals and minorities perpetuates de facto segregation, which is segregation that is not created by the law, but which forms a pattern as a result of various outside factors, including former laws. 4 Note: The table presents Decennial Census values for 1990, 2000, 2010, all calculated by HUD using census tracts as the area of measurement. The “current” figure is calculated using block groups from the 2010 Decennial Census, because block groups can measure segregation at a finer grain than census tracts due to their smaller geographies.

See https://www.hud.gov/program_offices/fair_housing_equal_opp/affh for more information.

Brentwood 2023-2031 Housing Element
Section 3: Housing Constraints, Resources, and Fair Housing 3-65 Table 3-21: Home Loan Application Denial Rates by Race/Ethnicity in Contra Costa County Race/Ethnicity

FHA, FSA/RHA,
and VA Home–
Purchase Loans
Conventional
HomePurchase
Loans
Refinance
Loans
Home
Improvement
Loans MultiFamily Homes
Multi-family
Homes
White, Non-Hispanic 9.2% 8.0% 16.6% 19.5% 9.5%
Black or African American,
Non-Hispanic 14.8% 13.5% 27.1% 34.6% 29.4%
Asian, Non-Hispanic 13.1% 9.8% 15.2% 19.3% 12.3%
Hispanic or Latino 11.3% 12.0% 22.3% 31.0% 28.6%
Source: Contra Costa County AI (2020)

LOCAL TRENDS
According to the 2015-2019 American Community Survey, the majority (55.50%) of residents in the City of Brentwood were non-Hispanic Whites. 25.12% of residents were Hispanic or Latino, 8.18% were nonHispanic Asians, 5.75% were non-Hispanic multiracial, and 5.10% were non-Hispanic Black or African American. Non-Hispanic Native Hawaiian and Other Pacific Islanders, American Indians and Alaskan Natives, and non-Hispanic other races were the minority of the city, making up only 0.22%, 0.08% and

0.05% of the population respectively. Refer to Table 3-22 for a comparison of racial composition in Contra Costa County and in the City of Brentwood.

The scores below correlate with the percentage of people within that racial or ethnic group that would need to move into a predominately White census tract to achieve a more integrated community. For instance, in Brentwood, 25.12 percent of the Hispanic or Latino population would need to move into predominately white census tract areas to achieve “perfect” integration. Whereas in Contra Costa County,

24.36 percent of the Hispanic or Latino population would need to move into predominately white census tract areas to achieve “perfect” integration.

Overall, there are higher rates of segregation across Brentwood compared to Contra Costa County. The Department of Housing and Community Development (HCD) considers dissimilarity index scores above 30, but below 60 as moderate segregation. Scores above 60 are high segregation. According to Table 3- 22, the City of Brentwood has no racial or ethnic populations with a dissimilarity index above 30 (with the exception of the White, non-Hispanic population), meaning all groups experience minor segregation from the White population. Similarly, all populations in the County have a score below 30 (with the exception of the White, non-Hispanic population).

Table 3-22: Racial Composition for Contra Costa County and Brentwood Race Contra Costa County City of Brentwood
White, non-Hispanic 47.75% 55.50%
Black or African-American, non-Hispanic 8.92% 5.10%
American Indian and Alaska Native, non-Hispanic 0.28% 0.08% Asian, non-Hispanic 14.61%* 8.18%
Native Hawaiian and Other Pacific Islander, non-Hispanic N/A 0.22% Some other race, non-Hispanic 0.30% 0.05%
Two or more races, non-Hispanic 3.77% 5.75%
Hispanic or Latino 24.36% 25.12%
*Asian and Pacific Islander combined

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Section 3: Housing Constraints, Resources, and Fair Housing 3-66 Section 2 Community Profile: Table 2-4 shows an analysis in the changes in Racial Ethnic Composition from 2010 to 2019 in Brentwood. The Brentwood population that identifies as American Indian/Alaska Native increased by 400 percent from 2010 to 2019. The population that identifies as Asian had the second largest increase (41.9 percent) followed by the population that identifies as Black (39.3 percent). The Hispanic or Latino (of any race) population decreased by 15.2 percent, and the White (Non-Hispanic) population decreased by 5.4 percent. While segregation may be a result of ethnic enclaves or persons of similar cultures living in a community, there is often increased likelihood segregated populations will have access to fewer essential resources.

Dissimilarity Indices for the City of Brentwood are not provided by the HUD Affirmatively Furthering Fair Housing Tool (AFFH-T) because the city does not directly receive HUD funds through the Community Development Block Grant (CDBG), HOME Investment Partnerships Program (HOME), or Emergency Solutions Grants (ESG) program. According to the Contra Costa County AI though, there is increasing segregation of Black and Hispanic residents in Brentwood.

The AFFH Data Viewer does, however, provide visuals on racial demographics for the City of Brentwood on the block group level. Refer to Figure 3-10. Brentwood has a relatively homogenous distribution and proportion of non-white residents. The majority of the city has block groups where 21-40% of the population are non-white. The central western portion of the city has block groups with less than 20% of non-white residents. The northeastern portion of the city has the highest percentage of non-white residents (61-80%).

Figure 3-10: Racial Demographics in Brentwood

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Section 3: Housing Constraints, Resources, and Fair Housing 3-67

HATE CRIMES
Hate crimes are violent acts against people, property, or organizations because of the group to which they belong or identify with. The Federal Fair Housing Act makes it illegal to threaten, harass, intimidate, or act violently toward a person who has exercised their right to free housing choice. Table 3-23 below identifies the reported hate crimes in the City of Brentwood between 2014 and 2020. A total of 11 hate crimes were reported over 7 years. Hate crimes in Brentwood were due to race, ethnicity, and/or ancestry, religion, and gender identity. The most prevalent hate crime was Anti-Black or African American crimes.

Table 3-23: City of Brentwood, Reported Hate Crimes by Bias Motivation (2015-2019) Year
Race/
Ethnicity/
Ancestry
Religion Sexual
Orientation Disability Gender Gender Identity Total
2014 2 0 0 0 0 0 2
2015 0 0 0 0 0 0 0
2016 0 0 0 0 0 0 0
2017 1 0 0 0 0 1 2
2018 3 0 0 0 0 0 3
2019 0 4 0 0 0 0 4
2020 0 0 0 0 0 0 0
Total 6 4 0 0 0 1 11
Source: Federal Bureau of Investigation, Uniform Crime Reporting. Hate Crime Statistics Report, 2014, 2015, 2016, 2017, 2018, and 2019.

Persons with Disabilities
In 1988, Congress added protections against housing discrimination for persons with disabilities through the FHA, which protects against intentional discrimination and unjustified policies and practices with disproportionate effects. The FHA also includes the following unique provisions to persons with disabilities: (1) prohibits the denial of requests for reasonable accommodations for persons with disabilities if necessary, to afford an individual equal opportunity to use and enjoy a dwelling; and (2) prohibits the denial of reasonable modification requests. With regards to fair housing, persons with disabilities have special housing needs because of the lack of accessible and affordable housing, and the higher health costs associated with their disability. In addition, many may be on fixed incomes that further limit their housing options.

REGIONAL TRENDS
According to the 2015-2019 American Community Survey (ACS) 5-year estimates, 118,603 residents (10.9% of Contra Costa County’s population) reported having one of six disability types listed in the ACS (hearing, vision, cognitive, ambulatory, self-care, and independent living). The percentage of residents detailed by disability are listed in Table 3-24 below. Note that an individual may report more than one disability.

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Section 3: Housing Constraints, Resources, and Fair Housing 3-68 Table 3-24: Percentage of Populations by Disability Types in Contra Costa County and Brentwood Disability Type Contra Costa County City of Brentwood
Hearing 2.9% 2.70%
Vision 1.8% 1.06%
Cognitive 4.4% 2.99%
Ambulatory 5.9% 5.38%
Self-Care Difficulty 2.4% 1.99%
Independent Living Difficulty 5.2% 5.10%
Percentage of Total Population with Disability5 10.9% 9.24% Source: 2019 ACS 5-year Estimates
In both Contra Costa County and the City of Brentwood, the percentage of individuals with disabilities also increases with age, with the highest percentage of individuals with disabilities being those 65 years and older. Refer to Table 3-25 for the distribution of percentages by age.

Table 3-25: Percentage of Population with Disabilities by Age in Contra Costa County and Brentwood Age Contra Costa County Age City of Brentwood
Under 5 years 0.8%
Under 18 2.71%
5 - 17 years 4.9%
18 - 34 years 6.2%
18 - 64 years 6.57%
35 - 64 years 9.7%
65 - 74 years 21.5%
65 years and over 34.33%
75 years and over 51.2%
Source: 2019 ACS 5-year Estimates
In terms of geographic dispersal, there is a relatively homogenous dispersal of persons with disabilities, especially in Central Contra Costa County, where most census tracts have less than 10% of individuals with disabilities. Towards Eastern Contra Costa County, the Western boundary, and parts of Southern Contra Costa County, however, the percentage of population with disabilities increases to 10–20%. Comparing Figure 3-11 and Figure 3-12, note that areas with a high percentage of populations with disabilities correspond with areas with high housing choice voucher (HCV) concentration (24% of people who utilize HCVs in Contra Costa County have a disability). Though use of HCVs do not represent a proxy for actual accessible units, participating landlords remain subject to the FHA to provide reasonable accommodations and allow tenants to make reasonable modifications at their own expense. Areas with a high percentage of populations with disabilities also correspond to areas with high percentages of low-moderate income communities. The above demographic information indicates socioeconomic trends of populations of persons with disabilities.
5 These disabilities are counted separately and are not mutually exclusive, as an individual may report more than one disability. These counts should not be summed.

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Section 3: Housing Constraints, Resources, and Fair Housing 3-69 Figure 3-11: Distribution of Population with a Disability in Contra Costa County

LOCAL TRENDS
Though the City of Brentwood has a slightly lower percentage of population with disabilities, the city’s overall disability statistics are consistent with Contra Costa County’s. The greatest percentage of disabilities in Brentwood consist of ambulatory disabilities, followed by independent living, cognitive, hearing, self-care, and vision difficulties. Overall, 9.24% of residents in Brentwood have a disability of any kind.

Referring to Figure 3-12, Brentwood has an overall low-to-moderate distribution of population with disabilities in the city. The northern central part of the city has less than 10% of population with a disability; the rest of the city has 10% – 20% of population with a disability.

Table 3-26: Percentage of Populations by Disability Types in Contra Costa County and Brentwood Disability Type Contra Costa County City of Brentwood
Hearing 2.9% 2.70%
Vision 1.8% 1.06%
Cognitive 4.4% 2.99%
Ambulatory 5.9% 5.38%
Self-Care Difficulty 2.4% 1.99%
Independent Living Difficulty 5.2% 5.10%
Percentage of Total Population with Disability* 10.9% 9.24% Source: 2019 ACS 5-year Estimates
*These disabilities are counted separately and are not mutually exclusive, as an individual may report more than one disability. These counts should not be summed.

Brentwood 2023-2031 Housing Element
Section 3: Housing Constraints, Resources, and Fair Housing 3-70 Figure 3-12: Distribution of Population with a Disability in Brentwood

Familial Status
Under the FHA, housing providers (e.g., landlords, property managers, real estate agents, or property owners) may not discriminate because of familial status. Familial status refers to the presence of at least one child under 18 years old, pregnant persons, or any person in the process of securing legal custody of a minor child (including adoptive or foster parents). Examples of familial status discrimination include refusing to rent to families with children, evicting families once a child joins the family (through birth, adoption, or custody), enforcing overly restrictive rules regarding children’s use of common areas, requiring families with children to live on specific floors, buildings, or areas, charging additional rent, security deposit, or fees because a household has children, advertising a preference for households without children, and lying about unit availability.

Families with children often have special housing needs due to lower per capita income, the need for affordable childcare, the need for affordable housing, or the need for larger units with three or more bedrooms. Single parent households are also protected by fair housing law. Of particular consideration are female-headed households, who may experience greater housing affordability challenges due to typically lower household incomes compared to two-parent households. Often, sex and familial status intersect to compound the discrimination faced by single mothers.

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Section 3: Housing Constraints, Resources, and Fair Housing 3-71

REGIONAL TRENDS
Figure 3-13 indicates that most children living in Contra Costa County live in married-couple households, especially in central parts of the county where the percentage of children in such households exceed 80%.

Census tracts adjacent to these areas also have relatively high percentages of children living in marriedcouple households (60%–80%). Census tracts with the lowest percentage of children in married-couple households (less than 20%) are located between Pittsburg and Antioch.

Figure 3-13: Distribution of Children in Married-Couple Households in Contra Costa County Figure 3-14 depicts the concentration of households headed by single mothers in the County by Census Tract. Areas of concentration include Richmond, San Pablo, Rodeo, Bay Point, Pittsburg, Antioch, and to the west of Concord. Those communities are also areas of high minority populations. By contrast, central County, in general, and the portions of central County to the south of the City of Concord have relatively low concentrations of children living in female-headed households (less than 20%). These tend to be more heavily White or White and Asian and Pacific Islander communities.

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Section 3: Housing Constraints, Resources, and Fair Housing 3-72 Figure 3-14: Distribution of Children in Female-Headed Households in Contra Costa County

LOCAL TRENDS
Referring to Figure 3-15, all census tracts in Brentwood have at least 61%–80% of children in marriedcouple households. The southern and east-most areas have over 80% of children in married-couple households. In terms of the percentage of children in female-headed households, however, all census tracts in the city have less than 20% of such households. Tracts with lower percentage of children in female-headed households have higher percentages of children in married-couple households and vice versa.

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Section 3: Housing Constraints, Resources, and Fair Housing 3-73 Figure 3-15: Percent of Children in Married-Couple Households by Tract in Brentwood Figure 3-16: Percent of Children in Female-Headed Households by Tract in Brentwood

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Section 3: Housing Constraints, Resources, and Fair Housing 3-74 Income Level
Each year, HUD receives custom tabulations of American Community Survey (ACS) data from the U.S.

Census Bureau. Known as the "CHAS" data (Comprehensive Housing Affordability Strategy), it demonstrates the number of households in need of housing assistance by estimating the number of households that have certain housing problems and have income low enough to qualify for HUD’s programs (primarily 30%, 50%, and 80% of median income). HUD defines a Low to Moderate Income (LMI) area as a census tract or block group where over 51% of the population is LMI (based on HUD income definition of up to 80% of the Area Median Income).

REGIONAL TRENDS
Figure 3-17 shows the LMI areas in Contra Costa County by block group. Most of central Contra Costa County has less than 25% of LMI populations. Block groups with high concentrations of LMI (between 75– 100% of the population) can be found clustered around Antioch, Pittsburg, Richmond, and San Pablo.

There are also small pockets with high percentages of LMI population around Concord. Other areas of the county have a moderate percentage of LMI population (25%–75%).

Figure 3-17: Population with Low to Moderate Income Levels in Contra Costa County

Brentwood 2023-2031 Housing Element
Section 3: Housing Constraints, Resources, and Fair Housing 3-75 Table 3-27 lists Contra Costa County households by income category and tenure. Based on the above definition, 38.71% of Contra Costa County households are considered LMI as they earn less than 80% of the HUD Area Median Family Income (HAMFI). Almost 60% of all renters are considered LMI compared to only 27.5% of owner households.

Table 3-27: Households by Income Category and Tenure in Contra Costa County Income Distribution Overview Owner Renter Total
Household Income < 30% HAMFI 7.53% 26.95% 14.40%
Household Income >30% to < 50% HAMFI 8.85% 17.09% 11.76% Household Income >50% to < 80% HAMFI 11.12% 15.16% 12.55% Household Income >80% to < 100% HAMFI 8.98% 9.92% 9.31% Household Income >100% HAMFI 63.52% 30.89% 51.98%
Total Population 248,670 135,980 384,645
Source: HUD Office of Policy Development and Research (PD&R) CHAS Data; 2011–2015 ACS

LOCAL TRENDS
Figure 3-18 below shows the percent of population with low to moderate income levels by block group in the City of Brentwood. The block groups located in the most central portion of the city have the highest percentage of LMI populations (75% –100%). Radiating from the center, block groups in the east have 50%–75% of LMI populations, 25%–50% towards the west, and less than 25% in the outermost portions towards the south and west. A section of block groups in central Brentwood have less than 25% of LMI population as well. Block groups with less than 25% of LMI correlate with block groups with median household income greater than $125,000 and over 80% of overpayment by renters.

Table 3-28 provides a list of households by income category and tenure in the City of Brentwood.

Generally speaking, there are disparities between the incomes of homeowners and renters, a pattern observed on both the regional and local level. In Brentwood, only 28.89% of owner households are considered LMI (earns less than 80% of HAMFI) compared to almost 60% of renter households. The reverse is true for those of high income households (more than 100% of HAMFI), where almost 65% of owner households are high income and only about 34% of renter households are high income.

Brentwood 2023-2031 Housing Element
Section 3: Housing Constraints, Resources, and Fair Housing 3-76 Figure 3-18: Population with Low to Moderate Income Levels in Brentwood Table 3-28: Households by Income Category and Tenure in Brentwood Income Distribution Overview Owner Renter Total
Household Income < 30% HAMFI 5.37% 22.15% 9.73%
Household Income >30% to < 50% HAMFI 9.72% 21.17% 12.70% Household Income >50% to < 80% HAMFI 13.80% 14.12% 13.88% Household Income >80% to < 100% HAMFI 7.70% 8.80% 7.98% Household Income >100% HAMFI 63.41% 33.77% 55.71%
Total Population 13,120 4,605 17,725
Figure 3-19a shows the median household income by tract in Brentwood. The data shows that Brentwood has a small range of median income levels. There is a large number of tracts in Brentwood whose median income for households is less than $100,000. The remaining two tracts located on the eastern side of the City were under $80,000. There are no tracts in the City with a majority of residents earning a median household income less than $60,000. Figure 3-19b shows that there were more census blocks greater than $125,000 in 2019 than 2014. This may indicate that census blocks are becoming more diverse based on household income.

Brentwood 2023-2031 Housing Element
Section 3: Housing Constraints, Resources, and Fair Housing 3-77 Figure 3-19a: Median Income for Households, 2014
Figure 3-19b: Median Income for Households, 2019

Brentwood 2023-2031 Housing Element
Section 3: Housing Constraints, Resources, and Fair Housing 3-78 Table 3-29 below shows the Households by Income compared by geography. The City of Brentwood had a higher median household income than the County and State in 2019. The majority of the City’s households are considered higher earning; approximately 55.7 percent of households in Brentwood earn more than the State median-income. Additionally, over 17.7 percent of households in Brentwood earn $200,000 or more annually. Just about 22.5 percent of City residents earn less than $50,000 annually, compared to 24.6 percent and 34.4 percent for the County and State, respectively.

Although Brentwood experiences higher median incomes, it is still important to provide improved access to resources and opportunities for all households. The community has been strategically planned to place affordable units near resources and opportunities for all residents. Lower-income households will benefit from increased access to resources and opportunities.

Table 3-29: Households by Income, Compared by Geography, 2019 Households Income City of
Brentwood
Contra Costa
County California
Less than $10,000 2.4% 3.4% 4.8%
$10,000-$14,999 1.9% 2.8% 4.1%
$15,000-$24,999 5.0% 4.9% 7.5%
$25,000-$34,999 4.6% 5.4% 7.5%
$35,000-$49,999 8.6% 8.1% 10.5%
$50,000-$74,999 10.2% 13.0% 15.5%
$75,000-$99,999 11.7% 12.6% 12.4%
$100,000-$149,999 22.6% 18.9% 16.6%
$150,000-$199,999 15.4% 11.5% 8.9%
$200,000 or More 17.7% 19.4% 12.2%
Median Household Income $108,994.00 $99,716.00 $75,235.00 Source: American Community Survey, 5-Year Estimates, 2020.

HOUSING CHOICE VOUCHERS (HCV)
Housing Choice Vouchers (HCV) are a form of HUD rental subsidy issued to low-income households that promise to pay a certain amount of the household’s rent. Prices, or payment standards, are set based on the rent in the metropolitan area, and voucher households must pay any difference between the rent and the voucher amount. Participants of the HCV program are free to choose any rental housing that meets program requirements
An analysis of the trends in HCV concentration can be useful in examining the success of the program in improving the living conditions and quality of life of its holders. One of the objectives of the HCV program is to encourage participants to avoid high-poverty neighborhoods and encourage the recruitment of landlords with rental properties in low-poverty neighborhoods. HCV programs are managed by Public Housing Agencies (PHAs), and the program’s assessment structure (Section Eight Management Assessment Program) includes an “expanding housing opportunities” indicator that shows whether the PHA has adopted and implemented a written policy to encourage participation by owners of units located outside areas of poverty or minority concentration.

A study prepared by HUD’s Office of Policy Development and Research found a positive association between the HCV share of occupied housing and neighborhood poverty concentration, and a negative association between rent and neighborhood poverty. This means that HCV use was concentrated in areas

Brentwood 2023-2031 Housing Element
Section 3: Housing Constraints, Resources, and Fair Housing 3-79 of high poverty where rents tend to be lower. In areas where these patterns occur, the program has not succeeded in moving holders out of areas of poverty.

Location Affordability
The Location Affordability Index was developed by HUD in collaboration with DOT under the federal Partnership for Sustainable Communities. One objective of the Partnership is to increase public access to data on housing, transportation, and land use. Before this Index, there was no standardized national data source on household transportation expenses, which limited the ability of homebuyers and renters to fully account for the cost of living in a particular city or neighborhood.

The prevailing standard of affordability in the United States is paying 30% or less of your family’s income on housing, but this fails to account for transportation costs. Transportation costs have grown significantly as a proportion of household income since this standard was established. According to the Bureau of Labor Statistics, in the 1930's American households spent just 8% of their income on transportation. Since then, as a substantial proportion of the U.S. population has migrated from center cities to surrounding suburbs and exurbs and come to rely more heavily (or exclusively) on cars, that percentage has steadily increased, peaking at 19.1% in 2003. As of 2013, households spent on average about 17% of their annual income on transportation, second only to housing costs in terms of budget impact. And for many workingclass and rural households, transportation costs actually exceed housing costs.

REGIONAL TRENDS
According to the Contra Costa County AI, the Housing Authority of Contra Costa County (HACCC) administers approximately 7,000 units of affordable housing under the HCV program (and Shelter Care Plus program). Northwest Contra Costa County is served by the Richmond Housing Authority (RHA) that administers approximately 1,851 HCVs. North-central Contra Costa County is served by the Housing Authority of the City of Pittsburg (HACP), which manages 1,118 tenant-based HCVs.

The HCV program serves as a mechanism for bringing otherwise unaffordable housing within reach of lowincome populations. With reference to Figure 3-20, the program appears to be most prominent in western Contra Costa County, in heavily Black and Hispanic areas, and in the northeast of the County, in predominantly Black, Hispanic, and Asian areas. Central Contra Costa County largely has no data on the percentage of renter units with HCVs. The correlation between low rents and a high concentration of HCV holders holds true for the areas around San Pablo, Richmond, Martinez, Pittsburg, and Antioch.

Figure 3-21 shows the Location Affordability Index in Contra Costa County. In Contra Costa County, the majority of the county has a median gross rent of $2,000–$2,500. Central Contra Costa County (areas between Danville and Walnut Creek) have the highest rents around $3,000 or more. The most affordable tracts in the county are along the perimeter of the County in cities like Richmond, San Pablo, Pittsburg and Martinez.