Brentwood City Council
February 13, 2024

Brentwood 2023-2031 Housing Element
Section 3: Housing Constraints, Resources, and Fair Housing 3-80 Figure 3-20: Distribution of Percentage of Renter Units with HCVs in Contra Costa County

Figure 3-21: Location Affordability Index in Contra Costa County

Brentwood 2023-2031 Housing Element
Section 3: Housing Constraints, Resources, and Fair Housing 3-81

LOCAL TRENDS
The Contra Costa County Housing Authority administers and manages the Housing Voucher Program (Section 8) in most of Contra Costa County, including Brentwood.

Figure 3-22 provides the percentage of renter units with Housing Choice Vouchers (HCV) in Brentwood.

Census tracts located in northwestern Brentwood, west of State Route 4, have the highest percentage of renter units with HCVs (> 15% - 30%). Northeastern tracts have >5% - 15% of renter units with HCVs.

Southwest tracts have > 0% - 5%. The southwest portion of the city has no data, which may indicate that no HCVs are used in the area. The areas with no data correspond to areas where rent is above $3,000 and median income higher than $87,000.

Figure 3-22: Distribution of Percentage of Renter Units with Housing Choice Vouchers in Brentwood

Figure 3-23 shows the Location Affordability Index in the City of Brentwood. At greater than $3,000, median gross rent is highest in the southern portion of Brentwood. The western and eastern tracts of the city have median gross rent of less than $2,000. The central portion of the city running from north to south has a median gross rent of less than $2,500.

When compared to Figure 3-47, census tracts with the highest percentage of renter units with HCVs correlate with census tracts that have over 80% of renters that experience cost burden (defined as households paying 30% or more of their gross income on housing expenses).

Brentwood 2023-2031 Housing Element
Section 3: Housing Constraints, Resources, and Fair Housing 3-82 Figure 3-23: Housing Affordability Index in Brentwood
Potential Effects on Integration and Segregation Trends, Access to Opportunity, and Displacement
This analysis evaluates the potential effects candidate housing sites and their affordability could have on current patterns of residential segregation based on race and ethnicity and/or income once housing is built within the City. Previous analyses have established that there are varying levels of racial and ethnic segregation in Brentwood but there is no significant segregation. Communities in the northeastern portion of the City are typically characterized by non-white predominance with a trend of lower Hispanic populations closer to the City limits. By placing more affordable housing in predominantly non-white communities, housing issues such as overcrowding, overpayment, and lack of housing options can be alleviated where they are felt most. The redistribution of lower-income household opportunities into places where non-white predominance is not as strong could mean the alteration of settlement trends for non-white and low income households. As a result, Brentwood communities could become further integrated in regard to race/ethnicity and income.

A total of 10 sites at lower income levels are located in the western parts of the City. The data shows that the proposed candidate sites to meet the RHNA allocation are dispersed throughout the community with an emphasis on locating units where there is a high level of access to important public services and transit.

While sites at lower incomes are isolated to one area of the City, the distribution of potential units does not disproportionately impact areas with larger concentrations of special needs or vulnerable populations.

The data shows that the proposed candidate sites to meet the very low- and low-income RHNA allocation are predominantly concentrated in areas with suitable vacant land in the northwest portion of the City.

This is due to the area having the highest opportunity and resource ratings, as well as the highest transit connectivity. It is important to place low and moderate-income units in areas with highest opportunity and resource ratings to increase mobility for those households.

Brentwood 2023-2031 Housing Element
Section 3: Housing Constraints, Resources, and Fair Housing 3-83 It should be noted that the location of low and very low-income sites located in the northwest portion of the City are designated to be mixed income, which would provide housing opportunities for both lower income households and moderate to above-moderate income households. Thus, the location of low and very low-income sites disbursed throughout the City does not segregate low-income housing from market rate or moderate-income housing. Having lower-income units dispersed throughout the City helps create more mixed-income communities and brings resources and services closer to special needs and vulnerable populations. This further improves conditions in these areas and does not exacerbate any conditions.

Racially and Ethnically Concentrated Areas
Racially and Ethnically Concentrated Areas of Poverty (R/ECAP) Racially and Ethnically Concentrated Areas of Poverty (R/ECAPs) are geographic areas with significant concentrations of poverty and minority populations. HUD developed a census-tract based definition of R/ECAP that relies on a racial and ethnic concentration threshold and a poverty test. The threshold states that an area with a non-White population of 50% or more would be identified as a R/ECAP; the poverty test defines areas of extreme poverty as areas where 40% or more of the population live below the federal poverty line or where the poverty rate is three times the average poverty rate for the metropolitan area (whichever is lower). Thus, an area that meets either the racial or ethnic concentration and the poverty test would be classified as a R/ECAP. Identifying R/ECAPS facilitates an understanding of entrenched patterns of segregation and poverty due to the effects of historically racist and discriminatory laws.

REGIONAL TRENDS
In Contra Costa County, the only area that meets the official definition of a R/ECAP is Monument Corridor in Concord (highlighted with red stripes in Figure 3-24 below).

Figure 3-24: R/ECAPs in Contra Costa County

Brentwood 2023-2031 Housing Element
Section 3: Housing Constraints, Resources, and Fair Housing 3-84 Expanded R/ECAPs in Contra Costa County
According to the 2020 Contra Costa County AI, however, the HUD definition that utilizes the federal poverty rate is not suitable for analysis in the San Francisco Bay Area due to the high cost of living. The HUD definition would severely underestimate whether an individual is living in poverty. The Contra Costa County AI proposes an alternate definition of a R/ECAP that includes majority-minority census tracts that have poverty rates of 25% or more. Under this definition, twelve other census tracts would qualify as R/ECAPs in the areas of Antioch (1), Bay Point (1), Concord (3), Pittsburg (2), North Richmond (1), Richmond (3) and San Pablo (1). Refer to Figure 3-25 for the locations of R/ECAPS based on the expanded definition. Note that the Contra Costa County AI does not provide a legend for the map.

According to the 2012–2016 American Community Survey, 69,326 people lived in these expanded R/ECAPs, representing 6.3% of the County’s population. Hispanic and Black populations make up a disproportionately large percentage of residents who reside in R/ECAPs compared to the population of the County or Region as a whole. In Contra Costa County, approximately 53% of individuals living in R/ECAPs are Hispanic, nearly 18% are Black, 19.57% are Mexican American, 4.65% are Salvadoran American, and 1.49% are Guatemalan Americans. Families with children under 18 still in the household comprise almost 60% of the population in Contra Costa County’s R/ECAPs. To those already living in poverty, the higher rate of dependent children in their households would translate to a greater strain on their resources.

Figure 3-25: Expanded R/ECAPs in Contra Costa County

Brentwood 2023-2031 Housing Element
Section 3: Housing Constraints, Resources, and Fair Housing 3-85

LOCAL TRENDS
The City of Brentwood has no (R/ECAPs) as defined by HUD.

Figure 3-26: R/ECAPs in Brentwood
Racially Concentrated Areas of Affluence (RCAAs)
Racially Concentrated Areas of Affluence (RCAAs) are defined by the HUD as communities with a large proportion of affluent and non-Hispanic White residents. According to a policy paper published by the HUD, non-Hispanic Whites are the most racially segregated group in the United States. In the same way neighborhood disadvantage is associated with concentrated poverty and high concentrations of people of color, distinct advantages are associated with residence in affluent, White communities. RCAAs are currently not available for mapping on the AFFH Data Viewer. As such, an alternate definition of RCAA from the University of Minnesota Humphrey School of Public Affairs is used in this analysis. RCAAs are defined as census tracts where (1) 80% or more of the population is white, and (2) the median household income is $125,000 or greater (slightly more than double the national median household income in 2016).

Data used in the analysis of RCAA is from the 2015-2019 American Community Survey and measured at the census tract level. HCD has created an RCAA metric to reflect California’s relative diversity and regional conditions, and to aid local jurisdictions in their analysis of racially concentrated areas of poverty and affluence pursuant to AB 686 and AB 1304. HCD's RCAA metric is created by first calculating a Location Quotient (LQ) for each California census tract using data from the 2015-2019 ACS. This LQ represents the percentage of total white population (White Alone, Not Hispanic or Latino) for each census tract compared to the average percentage of total white population for all census tracts in a given Council of Governments (COG) region. For example, a census tract with a LQ of 1.5 has a percentage of total white population that is 1.5 times higher than the average percentage of total white population in the given COG region. To determine the RCAAs, census tracts with an LQ of more than 1.25 and a median income 1.5 times higher than the COG Area Median Income (AMI), or 1.5 times the State AMI, whichever is lower, are assigned a

Brentwood 2023-2031 Housing Element
Section 3: Housing Constraints, Resources, and Fair Housing 3-86 numeric score of 1. A score of 1 indicates that a census tract is an RCAA. Census tracts that did not meet this criterion are assigned a score of 0.

The nationwide RCAA analysis identifies the following:
 RCAA tracts have more than twice the median household income of the average tract in their metro area.
 Poverty rates in RCAAs are significantly lower and are, on average about 20 percent of a typical tract.
 RCAAs tracts are more income homogenous than R/ECAPs.  The average RCAA is about 57 percent affluent, whereas the average R/ECAP had a poverty rate of 48 percent.

The typical RCAA tract has a rate of affluence 3.2 times that of a typical tract, whereas R/ECAPs on average had a poverty rate 3.2 times that of a typical tract. Overall, RCAAs may represent a public policy issue to the extent that they have been created and maintained through exclusionary and discriminatory land use and development practices.

REGIONAL TRENDS
By cross-referencing Figure 3-9 and Figure 3-27, a string of RCAAs that run from Danville to Lafayette and tapers off towards Walnut Creek emerges. This aligns with the cities’ racial demographic and median income (summarized in Table 3-30 below). Although not all census tracts/block groups meet the criteria to qualify as RCAAs, there is a tendency for census block groups with higher white populations to have higher median incomes throughout the county.

Figure 3-27: Median Household Income in Contra Costa County

Brentwood 2023-2031 Housing Element
Section 3: Housing Constraints, Resources, and Fair Housing 3-87 Table 3-30: White Population and Median Household Income of RCAAs in Contra Costa County City White Population Median Household Income (2019)
Danville 80.53% $160,808
Lafayette 81.23% $178,889
Walnut Creek 74.05% $105,948
Source: DataUSA.io (2019)
As shown in Figure 3-28, there are RCAAs in the County and in jurisdictions surrounding Brentwood. The majority of the jurisdictions west and south of Brentwood shows signs of RCAA such as Livermore, Pleasanton, Dublin, San Ramon, Walnut Creek, and Lafayette.

Figure 3-28: Racially Concentrated Areas of Affluence (RCAA), Brentwood

LOCAL TRENDS
Figure 3-29 shows the median household income by block group in the City of Brentwood. Central Brentwood has the highest median income (> $125,000). Median household income for block groups decreases as block groups radiate out from the center. The lowest median income in the city is less than $55,000 near the southeast border. By cross-referencing Figure 3-8 and Figure 3-29, the block group with the highest percentage of White population also has the lowest median income in the city. Areas with high median income do not overlap with areas where there are high percentages of White residents, thus not qualifying these areas as RCAAs.

Income above $87,000 is considered above HCD’s 2020 Median Income for California. A small block group located in southern Brentwood has a median household income of between $30,000–$55,000, lower than the HCD Median Income for California. This tract correlates with tracts where over 80% of renters experience cost burden in Figure 3-49.

Brentwood 2023-2031 Housing Element
Section 3: Housing Constraints, Resources, and Fair Housing 3-88 Figure 3-29: Median Household Income in Brentwood
Figure 3-30 shows census tracts that meet the RCAA criterion. As illustrated, there are census tracts on the northern and southern side of the City that would be classified as an RCAA under HCD’s criterion. The areas classified as an RCAA are areas with higher median Household Income as shown in Figure 3-29.

These areas are parts of the City where it is the least affordable for residents to live. Pursuant to AB 686, the City will affirmatively further fair housing by taking meaningful actions that foster inclusive communities free from barriers, which restrict access to opportunities based on protected classes, as defined by State law. The City has added programs to Section 4: Housing Plan, Policy Action H.4a to address RCAAs present in the City.

Brentwood 2023-2031 Housing Element
Section 3: Housing Constraints, Resources, and Fair Housing 3-89 Figure 3-30: Racially Concentrated Areas of Affluence (RCAA), Brentwood Access to Opportunities
Access to opportunity is a concept to approximate the link between place-based characteristics (e.g., education, employment, safety, and the environment) and critical life outcomes (e.g., health, wealth, and life expectancy). Ensuring access to opportunity means both improving the quality of life for residents of low-income communities, as well as supporting residents’ mobility and access to ‘high resource’ neighborhoods.

TCAC Opportunity Maps
TCAC Maps are opportunity maps created by the California Fair Housing Task Force (a convening of the Department of Housing and Community Development (HCD) and the California Tax Credit Allocation Committee (TCAC)) to provide research and evidence-based policy recommendations to further HCD’s fair housing goals of (1) avoiding further segregation and concentration of poverty and (2) encouraging access to opportunity through land use policy and affordable housing, program design, and implementation.

These opportunity maps identify census tracts with highest to lowest resources, segregation, and poverty, which in turn inform the TCAC to more equitably distribute funding for affordable housing in areas with the highest opportunity through the Low-Income Housing Tax Credit (LIHTC) Program.

TCAC Opportunity Maps display areas by highest to lowest resources by assigning scores (0–1) for each “domain” by census tracts – higher scores indicate higher “access” to the domain or higher “outcomes.” Refer to Table 3-31 for a list of domains and indicators. The scores are a combination of the three domains and rank census tracts by the level of resources (low, moderate, high, highest, and high poverty and segregation). The opportunity maps also identify areas with poverty and racial segregation through the following criteria:
 Poverty: Tracts with at least 30 percent of population under the federal poverty line;  Racial Segregation: Tracts with location quotient higher than 1.25 for Blacks, Hispanics, Asians, or all people of color in comparison to the County

Brentwood 2023-2031 Housing Element
Section 3: Housing Constraints, Resources, and Fair Housing 3-90 Table 3-31: Domains and List of Indicators for Opportunity Maps Domain Indicator
Economic
Poverty
Adult Education
Employment
Job Proximity
Median Home Value
Environmental CalEnviroScreen 3.0 Pollution Indicators and Values Education
Math Proficiency
Reading Proficiency
High School Graduation Rates
Student Poverty Rates
Source: California Fair Housing Task Force, Methodology for the 2021 TCAC/HCD Opportunity Maps, December 2020 High resource areas have high index scores for a variety of opportunity indicators such as high employment rates, low poverty rates, proximity to jobs, high educational proficiency, and limited exposure to environmental health hazards. High resource tracts are areas that offer low-income residents the best chance of a high quality of life, whether through economic advancement, high educational attainment, or clean environmental health. Moderate resource areas have access to many of the same resources as the high resource areas but may have fewer job opportunities, lower performing schools, lower median home values, or other factors that lower their indexes across the various economic, educational, and environmental indicators. Low resource areas are characterized as having fewer opportunities for employment and education, or a lower index for other economic, environmental, and educational indicators. These areas have greater quality of life needs and should be prioritized for future investment to improve opportunities for current and future residents.

Information from opportunity mapping can help highlight the need for housing element policies and programs that would help to remediate conditions in low resource areas or areas of high segregation and poverty, and to encourage better access for low and moderate income and black, indigenous, and people of color (BIPOC) households to housing in high resource areas.

REGIONAL TRENDS
Figure 3-31 provides a visual representation of TCAC Opportunity Areas in Contra Costa County based on a composite score, where each tract is categorized based on percentile rankings of the level of resources within the region. The only census tract in Contra Costa County considered an area of high segregation and poverty is located in Martinez. Concentrations of low resource areas are located in the northwestern and eastern parts of the county (Richmond to Hercules and Concord to Oakley); census tracts with the highest resources are located in central and southern parts of the county (San Ramon, Danville, Moraga, and Lafayette).

Brentwood 2023-2031 Housing Element
Section 3: Housing Constraints, Resources, and Fair Housing 3-91 Figure 3-31: Composite Score of TCAC Opportunity Areas in Contra Costa County

LOCAL TRENDS
The City of Brentwood is composed of mostly moderate resource areas, with a small sliver on the east considered low resource (Figure 3-32). When compared to Figure 3-54, the eastern tracts correspond to those areas defined as sensitive communities, where sensitive communities are communities vulnerable to displacement due to rising property values.

Brentwood 2023-2031 Housing Element
Section 3: Housing Constraints, Resources, and Fair Housing 3-92 Figure 3-32: TCAC Composite Scores in Brentwood
Opportunity Indices
This section presents the HUD-developed index scores based on nationally available data sources to assess residents’ access to key opportunity assets in comparison to the County. Table 3-32 provides index scores or values (the values range from 0 to 100) for the following opportunity indicator indices:
 School Proficiency Index: The school proficiency index uses school-level data on the performance of 4th grade students on state exams to describe which neighborhoods have high-performing elementary schools nearby and which are near lower performing elementary schools. The higher the index value, the higher the school system quality is in a neighborhood.  Labor Market Engagement Index: The labor market engagement index provides a summary description of the relative intensity of labor market engagement and human capital in a neighborhood. This is based upon the level of employment, labor force participation, and educational attainment in a census tract. The higher the index value, the higher the labor force participation and human capital in a neighborhood.
 Transit Trips Index: This index is based on estimates of transit trips taken by a family that meets the following description: a 3-person single-parent family with income at 50% of the median income for renters for the region (i.e. the Core-Based Statistical Area (CBSA). The higher the transit trips index value, the more likely residents in that neighborhood utilize public transit.  Low Transportation Cost Index: This index is based on estimates of transportation costs for a family that meets the following description: a 3-person single-parent family with income at 50 percent of the median income for renters for the region/CBSA. The higher the index value, the lower the cost of transportation in that neighborhood.
 Jobs Proximity Index: The jobs proximity index quantifies the accessibility of a given residential neighborhood as a function of its distance to all job locations within a region/CBSA, with larger

Brentwood 2023-2031 Housing Element
Section 3: Housing Constraints, Resources, and Fair Housing 3-93 employment centers weighted more heavily. The higher the index value, the better the access to employment opportunities for residents in a neighborhood.  Environmental Health Index: The environmental health index summarizes potential exposure to harmful toxins at a neighborhood level. The higher the index value, the less exposure to toxins harmful to human health. Therefore, the higher the index value, the better the environmental quality of a neighborhood, where a neighborhood is a census block-group.

Table 3-32: Opportunity Indices in Contra Costa County
Index School
Proficiency
Transit
Trip
Low
Transportation Cost
Labor
Market
Jobs
Proximity
Environmental
Health
Total Population
White, Non-Hispanic 69.32 79.83 71.72 68.76 49.30 54.75 Black, Non-Hispanic 34.34 81.81 75.62 42.52 48.12 43.68 Asian or Pacific Islander,
Non-Hispanic 59.43 80.81 72.22 66.87 45.27 52.22
Native American, NonHispanic 49.99 80.47 73.09 51.19 49.04 47.92 Hispanic 39.38 82.31 75.57 42.30 45.11 43.85
Population Below Federal Poverty Line
White, Non-Hispanic 55.60 81.05 74.17 55.46 50.67 49.39 Black, Non-Hispanic 25.84 84.03 78.23 32.63 48.69 39.84 Asian or Pacific Islander,
Non-Hispanic 46.48 84.04 77.75 52.15 50.02 41.52
Native American, NonHispanic 19.92 82.61 75.06 34.52 48.41 46.48 Hispanic 30.50 84.69 78.06 32.01 44.57 38.66
Note: American Community Survey Data are based on a sample and are subject to sampling variability.

Source: AFFHT Data Table 12; Data Sources: Decennial Census; ACS; Great Schools; Common Core of Data; SABINS; LAI; LEHD; NATA

Brentwood 2023-2031 Housing Element
Section 3: Housing Constraints, Resources, and Fair Housing 3-94 Education
Housing and school policies are mutually reinforcing, which is why it is important to analyze access to educational opportunities when assessing fair housing. At the most general level, school districts with the greatest amount of affordable housing tend to attract larger numbers of LMI families (largely composed of minorities). As test scores are a reflection of student demographics, where Black/Hispanic/Latino students routinely score lower than their White peers, less diverse schools with higher test scores tend to attract higher income families to the school district. This is a fair housing issue because as higher income families move to the area, the overall cost of housing rises and an exclusionary feedback loop is created, leading to increased racial and economic segregation across districts as well as decreased access to highperforming schools for non-White students.

REGIONAL TRENDS
According to the Contra Costa County AI, academic outcomes for low-income students are depressed by the presence of high proportions of low-income classmates; similarly situated low-income students perform at higher levels in schools with lower proportions of low income students. The research on racial segregation is consistent with the research on poverty concentration—positive levels of school integration led to improved educational outcomes for all students. Thus, it is important wherever possible to reduce school-based poverty concentration and to give low-income families access to schools with lower levels of poverty and greater racial diversity. The 2021 TCAC Opportunity Areas Education Composite Score for a census tract is based on math and reading proficiency, high school graduation rates, and student poverty rate indicators. The score is broken up by quartiles, with the highest quartile indicating more positive education outcomes and the lowest quartile signifying fewer positive outcomes.

Figure 3-33: TCAC Opportunity Areas’ Education Score in Contra Costa County

Brentwood 2023-2031 Housing Element
Section 3: Housing Constraints, Resources, and Fair Housing 3-95 There are 19 public school districts in Contra Costa County, in addition to 124 private schools and 19 charter schools. Figure 3-33 shows that the northwestern and eastern parts of the county have the lowest education domain scores (less than 0.25) per census tracts, especially around Richmond and San Pablo, Pittsburg, Antioch, east of Clayton, and Concord and its northern unincorporated areas. Census tracts with the highest education domain scores (greater than 0.75) are located in central and southern parts of the county (bounded by San Ramon on the south; Orinda and Moraga on the west; Lafayette, Walnut Creek, Clayton, and Brentwood on the north). Overlaying Figure 3-27 and Figure 3-34 reveals that areas with lower education scores correspond with areas with lower income households (largely composed of minorities) and vice versa. Table 3-32 also indicates that index values for school proficiency are higher for White residents, indicating a greater access to high quality schools regardless of poverty status.

LOCAL TRENDS
The City of Brentwood is served by the Brentwood Union Elementary School District (BUESD) for elementary and middle schools and Liberty Union High School District (LUHSD) for high schools. The majority of the city has an Educational Score of 0.50–0.75. Southern tracts of the city have the highest percentile scores of above 0.75, which would indicate a more positive education outcome. Public schools in Brentwood Union Elementary School District (BUESD) have an average math proficiency score of 50% and a reading proficiency score of 59%. Public schools in Liberty Union High School District (LUHSD) have an average math proficiency score of 36% and reading proficiency score of 69%, higher than Contra Costa County’s, where the public school average for math proficiency is 19% and 21% for reading proficiency. In terms of minority enrollment, 59% of the student body is Hispanic in BUESD and 58% of the student body is Hispanic in LUHSD; 71% of the student body is Hispanic in the county. Figure 3-34 shows that census tracts in the southern region of the City generally have more positive education outcomes.

Figure 3-34: TCAC Opportunity Areas’ Education Score in Brentwood

Brentwood 2023-2031 Housing Element
Section 3: Housing Constraints, Resources, and Fair Housing 3-96 Transportation
Access to public transit is of paramount importance to households affected by low incomes and rising housing prices, especially because lower income households are often transit dependent. Public transit should strive to link lower income persons, who are often transit dependent, to major employers where job opportunities exist. Access to employment via public transportation can reduce welfare usage and increase housing mobility, which enables residents to locate housing outside of traditionally low-income neighborhoods.

Transportation opportunities are depicted by two indices: (1) the transit trips index and (2) the low transportation cost index. The transit trips index measures how often low-income families in a neighborhood use public transportation. The index ranges from 0 to 100, with higher values indicating a higher likelihood that residents in a neighborhood utilize public transit. The low transportation cost index measures cost of transportation and proximity to public transportation by neighborhood. It too varies from 0 to 100, and higher scores point to lower transportation costs in that neighborhood.

REGIONAL TRENDS
Neither indices, regardless of poverty level, varies noticeably across racial/ethnic categories. All races and ethnicities score highly on both indices with values close in magnitude. If these indices are accurate depictions of transportation accessibility, it is possible to conclude that all racial and ethnic classes have high and relatively equal access to transportation at both the jurisdiction and regional levels. If anything, both indices appear to take slightly higher values for non-Hispanic Blacks and Hispanics, suggesting better access to transit and lower costs for these protected groups.

Contra Costa County is served by rail, bus, and ferry transit but the quality of service varies across the county. Much of Contra Costa County is connected to other parts of the East Bay as well as to San Francisco and San Mateo County by Bay Area Rapid Transit (BART) rail service. The Richmond-Warm Springs/South Fremont and Richmond-Daly City/Millbrae Lines serve El Cerrito and Richmond during peak hours while the Antioch-SFO Line extends east from Oakland to serve Orinda, Lafayette, Walnut Creek, Contra Costa Center/Pleasant Hill, Concord, and the Pittsburg/Bay Point station. An eastward extension, also known as eBART, began service on May 26, 2018. The extension provides service beyond the Pittsburg/Bay Point station to the new Pittsburg Center and Antioch stations. The Capitol Corridor route provides rail service between San Jose and Sacramento and serves commuters in Martinez and Richmond.

In contrast to rail transportation, bus service is much more fragmented in the County and regionally.

Several different bus systems including Tri-Delta Transit, AC Transit, County Connection, and WestCat provide local service in different sections of the County. The lack of an integrated network can make it harder for transit riders to understand how to make a trip that spans multiple operators and adds costs during a daily commute.

Within Contra Costa County, transit is generally not as robust in east County despite growing demand for public transportation among residents. The lack of adequate public transportation makes it more difficult for lower-income people in particular to access jobs. Average transit commutes in Pittsburg and Antioch exceed 70 minutes. In Brentwood, average transit commute times exceed 100 minutes.

Transit agencies that service Contra Costa County include County Connection, Tri Delta Transit, WestCAT, AC Transit, and BART. The County Connection Bus (CCCTA) is the largest bus transit system in the county that provides fixed-route and paratransit bus service for communities in Central Contra Costa. Other nonContra Costa agencies that provide express service to the county include:
 San Francisco Bay Ferry (Richmond to SF Ferry Building);

Brentwood 2023-2031 Housing Element
Section 3: Housing Constraints, Resources, and Fair Housing 3-97  Golden Gate Transit (Line 40);
 WHEELS Livermore Amador Valley Transit Authority (Route 70x);  SolTrans (Route 80/82 and the Yellow Line);
 Capitol Corridor (Richmond/Martinez to cities between Auburn and San Jose);  Fairfield & Suisun Transit (Intercity express routes);  Altamont Corridor Express (commute-hour trains from Pleasanton);  Napa Vine Transit (Route 29)
Figure 3-35: Public Transit Routes in Contra Costa County

Brentwood 2023-2031 Housing Element
Section 3: Housing Constraints, Resources, and Fair Housing 3-98

LOCAL TRENDS
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, local routes on weekends/holidays, and shuttle service to San Francisco 49ers home games.

Major transfer points for majority of Tri Delta Transit’s routes include:
 Brentwood Park & Ride in Brentwood
 Antioch BART Station in Antioch
 Pittsburg Center BART Station in
Pittsburg
 Pittsburg/Bay Point BART Station in
Pittsburg
 Los Medanos College in Pittsburg
Tri Delta Transit operates 21 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. Figure 3-36 shows Tri Delta Transit’s Weekday System Map, with Brentwood shown in the inset map.

Brentwood 2023-2031 Housing Element
Section 3: Housing Constraints, Resources, and Fair Housing 3-99 Figure 3-36: Public Transit Routes in Brentwood

Brentwood 2023-2031 Housing Element
Section 3: Housing Constraints, Resources, and Fair Housing 3-100 According to AllTransit, an online source of transit connectivity, access, and frequency data, 81.3% of jobs in Brentwood are located within half a mile of transit. However, only 3.26% of commuters use transit.

AllTransit states that 0% of the population live near high-frequency transit, which may contribute to the low percentage of commuters who use public transit.

Figure 3-37 is a map that illustrates transit scores from a range of 1< to >9, where higher scores indicate higher connectivity, access to jobs, and frequency of service. About 60% of the population live in areas with scores of 2–4; about 18% of the population live in areas with scores of 5–6; about 12% of the population live in areas with scores of 4–5. Areas with lower transit scores correlate with a high percentage of LMI populations.

Overall, AllTransit scores Brentwood 3.7/10 for its transit performance, which means that the city has a low combination of trips per week and low number of jobs accessible enabling few people to take transit to work. AllTransit further scores Brentwood 2/100 on its transit connectivity index based on the number of bus routes and train stations within walking distance for households in a given Block Group scaled by the frequency of service.

Figure 3-37: Transit Metric Map in Brentwood
Economic Development
Employment opportunities are depicted by two indices: (1) the labor market engagement index and (2) the jobs proximity index. The labor market engagement index provides a summary description of the relative intensity of labor market engagement and human capital in a neighborhood, taking into account the unemployment rate, labor-force participation rate, and percent with a bachelor’s degree or higher.

The index ranges from 0 to 100, with higher values indicating higher labor force participation and human capital. The jobs proximity index quantifies the accessibility of a neighborhood to jobs in the region by measuring the physical distances between jobs and places of residence. It too varies from 0 to 100, and higher scores point to better accessibility to employment opportunities.

Brentwood 2023-2031 Housing Element
Section 3: Housing Constraints, Resources, and Fair Housing 3-101

REGIONAL TRENDS
In Contra Costa County, non-Hispanic Whites and non-Hispanic Asians/Pacific Islanders are at the top of the labor market engagement index with scores of 66.76 and 66.87 respectively. Non-Hispanic Blacks and Hispanics score the lowest in the county with scores around 32. (Refer to Table 3-31 for a full list of indices). Figure 3-38 shows the spatial variability of job proximity in Contra Costa County. Tracts extending north from Lafayette to Martinez and its surrounding unincorporated areas have the highest index values followed by its directly adjacent areas. Cities like Pittsburg, Antioch, Brentwood, Oakley, and Hercules have the lowest index scores (less than 20). Hispanic residents have the least access to employment opportunities with an index score of 45.11, whereas White residents have the highest index score of 49.30.

Contra Cost County has wide-variety of economic scores ranging from less than 0.25–greater than .75 (Figure 3-39). The County shows disparities in economic scores between the eastern and western regions, with the eastern region scoring lower than the western region.

At the end of 2021, Contra Costa County had an unemployment rate of 4.2%-22,900 residents were without a job. Antioch, Pittsburg, and Richmond were amongst the cities with the highest unemployment rates, 6.6%, 5.6%, and 5.2% respectively. These cities were closely followed by Brentwood, Oakley, and San Pablo. The unemployment rates in cities within Contra Costa County correspond with low opportunity index scores.

Figure 3-38: Residential Proximity to Job Locations in Contra Costa County

Brentwood 2023-2031 Housing Element
Section 3: Housing Constraints, Resources, and Fair Housing 3-102 Figure 3-39: TCAC Opportunity Areas’ Economic Score in Contra Costa County

LOCAL TRENDS
The TCAC/HCD Opportunity Area Maps include economic data, as shown in Figure 3-41. This data represents opportunity levels based on the following factors:
 Poverty – Percent of population with an income above 200 percent of the federal poverty line.  Adult Education – Percent of adults aged 20-64 who are employed in the civilian labor force in the armed forces.
 Job Proximity – Number of jobs filled by workers with less than a Bachelor of Arts degree within a given radius (determined by the typical commute distance of low-wage workers in each region) or each census tract population-weighted centroid.
 Median Home Value – Value of owner-occupied units.

The City of Brentwood had an unemployment rate of 4.9% at the end of 2021. Figure 3-40 shows the job proximity index by block group for the City of Brentwood. The majority of Brentwood has a Jobs Proximity Index of less than 20, meaning furthest proximity from jobs and longest commute times. Residents in northwest and northeast Brentwood are slightly closer in proximity with their jobs (indices of 20–40).

Based on the ACS 2015-2019 5-year estimates, 18.64% of Brentwood residents have a commute time of 60 to 89 minutes. 15.25% of residents have a commute time of 45–59 minutes, and 13.62% of residents have a commute time of 90 or more minutes. According to the Contra Costa County AI, the average transit commute times in Brentwood exceed 100 minutes.

Overall, Brentwood has low-to-moderate economic scores ranging from less than 0.25–0.50 (Figure 3-41).

Most of Brentwood have scores of 0.25–0.50. The most western and eastern parts of the city are in the lowest quartile of less than 0.25.

Brentwood 2023-2031 Housing Element
Section 3: Housing Constraints, Resources, and Fair Housing 3-103 Figure 3-40: Job Proximity Index in Brentwood

Figure 3-41: TCAC Opportunity Areas’ Economic Score in Brentwood

Brentwood 2023-2031 Housing Element
Section 3: Housing Constraints, Resources, and Fair Housing 3-104 Environment
The Environmental Health Index summarizes potential exposure to harmful toxins at a neighborhood level. Index values range from 0 to 100 and the higher the index value, the less exposure to toxins harmful to human health. Therefore, the higher the value, the better the environmental quality of a neighborhood, where a neighborhood is a census block-group. There are modest differences across racial and ethnic groups in neighborhood access to environmental quality. All racial/ethnic groups in the Consortium obtained moderate scores ranging from low 40s to mid–50s. Non-Hispanic Blacks and Hispanics have the lowest scores amongst all residents in Contra Costa County with scores of 43; whereas non-Hispanic Whites and Asians/Pacific Islanders have the highest scores (over 50) amongst all residents in Contra Costa County (Refer to Table 3-32).

CalEnviroScreen was developed by the California Environmental Protection Agency (CalEPA) to evaluate pollution sources in a community while accounting for a community’s vulnerability to the adverse effects of pollution. Measures of pollution burden and population characteristics are combined into a single composite score that is mapped and analyzed. Higher values on the index indicate higher cumulative environmental impacts on individuals arising from these burdens and population factors.

The California Office of Environmental Health Hazard Assessment (OEHHA) compiles these scores to help identify California communities disproportionately burdened by multiple sources of pollution. In addition to environmental factors (pollutant exposure, groundwater threats, toxic sites, and hazardous materials exposure) and sensitive receptors (seniors, children, persons with asthma, and low birth weight infants), CalEnviroScreen also considers socioeconomic factors such as educational attainment, linguistic isolation, poverty, and unemployment.

Figure 3-42: TCAC Opportunity Areas’ Environmental Score in Contra Costa County

Brentwood 2023-2031 Housing Element
Section 3: Housing Constraints, Resources, and Fair Housing 3-105

REGIONAL TRENDS
Figure 3-42 above displays the Environmental Score for Contra Costa County based on CalEnviroScreen

3.0 Pollution Indicators and Values that identifies communities in California disproportionately burdened by multiple sources of pollution and face vulnerability due to socioeconomic factors. The highest scoring 25% of census tracts were designated as disadvantaged communities. In Contra Costa County, disadvantaged communities include census tracts in North Richmond, Richmond, Pittsburg, San Pablo, Antioch, Rodeo, and Oakley.

Figure 3-43 shows updated scores for CalEnviroScreen 4.0 released by the California Office of Environmental Health Hazard Assessment. Generally speaking, adverse environmental impacts are concentrated around the northern border of the county (Bay Point to Pittsburg) and the western border of the county (Richmond to Pinole). Areas around Concord to Antioch have moderate scores and the rest of the county has relatively low scores. From central Contra Costa County, an almost radial gradient effect can be seen from green to red (least to most pollution).

Figure 3-43: CalEnviroScreen 4.0 Results in Contra Costa County

LOCAL TRENDS
Environmental Scores for the City of Brentwood, shown in Figure 3-44, are considerably lower than the rest of the county. The eastern parts of the city have a score of less than 0.25, indicating a less positive environmental outcome. The western parts of the city have a higher score of 0.25–0.50. Updated CalEnviroScreen Scores in Figure 3-45 show a “necklace” of census tracts around north central Brentwood with scores between 50%–74%. The rest of the city has a score of 25%–49%. Table 3-33a and 3-33b compare two census tracts with the highest and lowest pollution burdens in the City.

Brentwood 2023-2031 Housing Element
Section 3: Housing Constraints, Resources, and Fair Housing 3-106 Table 3-33a: CalEnviroScreen 4.0 for Census Tract 32.04 (Highest Pollution Burden) Pollutant Percentile* Health Risk/Burden Percentile*
Over Percentiles Environmental Effects
CalEnviroScreen 4.0 68 Cleanup Sites 0
Pollution Burden 51 Groundwater Threats 56
Population Characteristics 73 Hazardous Waste 64
Exposure Impaired Waters 77
Ozone 40 Solid Waste 0
Particulate Matter 2.5 31 Socioeconomic Factors
Diesel Particulate Matter 57 Education 59
Toxic Releases 31 Linguistic Isolation 62
Traffic 51 Poverty 55
Pesticides 64 Unemployment 82
Drinking Water 58 Housing Burden 61
Lead from Housing 24 - -
Sensitive Populations - -
Asthma 67 - -
Low Birth Weight 64 - -
Cardiovascular Disease 70 - -
*Percentile derived using a weighted scoring system to determine average pollution burden/socioeconomic scores relative to other census tracts.

Source: CalEnviroScreen 4.0. Accessed July 19, 2023.

Table 3-33b: CalEnviroScreen 4.0 for Census Tract 32.02 (Lowest Pollution Burden) Pollutant Percentile* Health Risk/Burden Percentile*
Over Percentiles Environmental Effects
CalEnviroScreen 4.0 37 Cleanup Sites 47
Pollution Burden 36 Groundwater Threats 55
Population Characteristics 38 Hazardous Waste 45
Exposure Impaired Waters 77
Ozone 38 Solid Waste 0
Particulate Matter 2.5 30 Socioeconomic Factors
Diesel Particulate Matter 44 Education 39
Toxic Releases 31 Linguistic Isolation 5
Traffic 49 Poverty 20
Pesticides 8 Unemployment 97
Drinking Water 58 Housing Burden 16
Lead from Housing 12 - -
Sensitive Populations - -
Asthma 67 - -
Low Birth Weight 7 - -
Cardiovascular Disease 70 - -
*Percentile derived using a weighted scoring system to determine average pollution burden/socioeconomic scores relative to other census tracts.

Source: CalEnviroScreen 4.0. Accessed July 19, 2023.

Brentwood 2023-2031 Housing Element
Section 3: Housing Constraints, Resources, and Fair Housing 3-107 Figure 3-44: TCAC Opportunity Areas’ Environmental Score in Brentwood

Figure 3-45: CalEnviroScreen 4.0 Results in Brentwood

Brentwood 2023-2031 Housing Element
Section 3: Housing Constraints, Resources, and Fair Housing 3-108 Health and Recreation
The Healthy Places Index (HPI) is a new tool that allows local officials to diagnose and change community conditions that affect health outcomes and the wellbeing of residents. The HPI tool was developed by the Public Health Alliance of Southern California to assist in comparing community conditions across the state and combined 25 community characteristics such as housing, education, economic, and social factors into a single indexed HPI Percentile Score, where lower percentiles indicate lower conditions.

REGIONAL TRENDS
Figure 3-46 shows the HPI percentile score distributions for Contra Costa County. The majority of the County falls in the highest quarter, indicating healthier conditions. These areas have a lower percentage of minority populations and higher median incomes. The reverse is true for cities with the lowest percentile ranking, which indicates less healthy conditions, are Pittsburg, San Pablo, and Richmond. These areas have higher percentages of minority populations and lower median incomes.

Figure 3-46: Healthy Places Index in Contra Costa County

LOCAL TRENDS
Over 50% of census tracts in Brentwood are within the highest quartile (75–100) in the Healthy Places Index (Figure 3-47). Northwest and northeast Brentwood have slightly lower percentile rankings (50–75); these tracts correspond with tracts that have lower median gross rent (less than $2,000) and tracts that have high percentages of overpayment by renters.

Brentwood 2023-2031 Housing Element
Section 3: Housing Constraints, Resources, and Fair Housing 3-109 Figure 3-47: Healthy Places Index in Brentwood

Disproportionate Needs
Disproportionate housing needs generally refers to a condition in which there are significant disparities in the proportion of members of a protected class experiencing a category of housing need when compared to the proportion of members of any other relevant groups, or the total population experiencing that category of housing need in the applicable geographic area. The Comprehensive Housing Affordability Strategy (CHAS) developed by the Census for HUD provides detailed information on housing needs by income level for different types of households in Contra Costa County. Housing problems considered by CHAS include:
 Housing cost burden, including utilities, exceeding 30% of gross income;  Severe housing cost burden, including utilities, exceeding 50% of gross income;  Overcrowded conditions (housing units with more than one person per room); and  Units with physical defects (lacking complete kitchen or bathroom).

Severe housing problems are defined as households with at least 1 of 4 housing problems: overcrowding, high housing costs, lack of kitchen facilities, or lack of plumbing facilities.

According to the Contra Costa County AI, a total of 164,994 households (43.90%) in the county experience any one of the above housing problems; 85,009 households (22.62%) experience severe housing problems. Based on relative percentage, Hispanic households experience the highest rate of housing problems regardless of severity, followed by Black households and ‘Other’ races. Table 3-33c lists the demographics of households with housing problems in the County.

Hispanic and Black residents face particularly severe housing problems. These housing burdens are greatest in portions of Hercules (along with other cities like Richmond, North Richmond, San Pablo, Concord, Martinez, Pittsburg, Antioch, and Oakley).

Brentwood 2023-2031 Housing Element
Section 3: Housing Constraints, Resources, and Fair Housing 3-110 Table 3-33c: Demographics of Households with Housing Problems in Contra Costa County Demographic Total Number of
Households
Households with Housing
Problems
Households with Severe
Housing Problems
White 213,302 80,864 37.91% 38,039 17.83%
Black 34,275 19,316 56.36% 10,465 30.53%
Asian/Pacific Islander 51,353 21,640 42.14% 10,447 20.34% Native American 1,211 482 39.80% 203 16.76%
Other 10,355 5,090 49.15% 2,782 26.87%
Hispanic 65,201 37,541 57.58% 23,002 35.28%
Total 375,853 164,994 43.90% 85,009 22.62%
Source: Contra Costa County AI (2020)
There are significant disparities between the rates of housing problems that larger families (households of five or more people) experience and the rates of housing problems that families of five or fewer people experience. Larger families tend to experience housing problems more than smaller families. Non-family households in Contra Costa experience housing problems at a higher rate than smaller family households, but at a lower rate than larger family households. Table 3-34 lists the number of households with housing problems according to household type.

Table 3-34: Number of Households with Housing Problems by Household Type in Contra Costa County Household Type No. of Households with Housing Problems
Family Households (< 5 people) 85,176
Family Households (> 5 people) 26,035
Non-family Households 53,733
Source: Contra Costa County AI (2020)
Cost Burden
Housing cost burden, or overpayment, is defined as households paying 30% or more of their gross income on housing expenses, including rent or mortgage payments and utilities. Renters are more likely to overpay for housing costs than homeowners. Housing cost burden is considered a housing need because households that overpay for housing costs may have difficulty affording other necessary expenses, such as childcare, transportation, and medical costs.

REGIONAL TRENDS
As presented in Table 3-35, almost 35.58% of all households experience cost burdens. Renters experience cost burdens at higher rates than owners (48.28% compared to 28.95%).

Table 3-35: Households that Experience Cost Burden by Tenure in Contra Costa County Total Number of Households
Cost burden Percentage of Households that
Experience Cost Burden >30% to < 50% > 50%
Owners Only 257,530 44,535 30,010 28.95%
Renters Only 134,750 32,015 33,040 48.28%
All Households 392,275 76,550 63,050 35.59%
Source: https://www.huduser.gov/portal/datasets/cp.html

Brentwood 2023-2031 Housing Element
Section 3: Housing Constraints, Resources, and Fair Housing 3-111 Figure 3-48 shows concentrations of cost burdened renter households in and around San Pablo, Pittsburg, Antioch, west Brentwood and Oakley, East San Ramon, and northern parts of Concord towards unincorporated areas. In these tracts, over 80% of renters experience cost burdens. The majority of east Contra Costa County has 60–80% of renter households that experience cost burdens; west Contra Costa County has 20–40% of renter households that experience cost burdens. Census tracts with a low percentage of cost-burdened households are located between San Ramon and Martinez on a north-south axis. In these tracts, less than 20% of renter households experience cost burdens.

Figure 3-48: Distribution of Percentage of Overpayment by Renters in Contra Costa County

Brentwood 2023-2031 Housing Element
Section 3: Housing Constraints, Resources, and Fair Housing 3-112

LOCAL TRENDS
In Brentwood, almost 40% of all households experience cost burden. Similar to Contra Costa County, renters experience higher rates of cost burdens than owners (55.30% to 34.62%) at a higher rate than the county. Refer to Table 3-36 below for households that experience cost burden by tenure.

Table 3-36: Households that Experience Cost Burden by Tenure in Brentwood Total Number of Households
Cost burden Percentage of Households that
Experience Cost Burden >30% to < 50% > 50%
Owners Only 14,690 3,310 1,775 34.62%
Renters Only 4,855 1,315 1,370 55.30%
All Households 19,545 4,625 3,145 39.75%
Source: https://www.huduser.gov/portal/datasets/cp.html, 2014–2018 Figure 3-49 shows high concentrations of cost burdened renter households in western and central parts of Brentwood (over 80%). The rest of the city have 60%–80% of cost burdened renter households. By overlaying Figure 3-49 and 3-21, areas where renters experience cost burdens correspond with areas that have high percentages of renters who are in the HCV program. Cost-burdened households have lower median gross rents, lower scores on the healthy places index, and low economic scores compared to other areas of the city. The tract that experiences high percentages of cost burden corresponds to the only tract in the city with populations whose incomes are below the poverty level, as shown in Figure 3-50.

Figure 3-49: Distribution of Percentage of Overpayment by Renters in Brentwood

Brentwood 2023-2031 Housing Element
Section 3: Housing Constraints, Resources, and Fair Housing 3-113 Figure 3-50: Population in Poverty in Brentwood

Brentwood 2023-2031 Housing Element
Section 3: Housing Constraints, Resources, and Fair Housing 3-114 Overcrowded Households
Overcrowding is defined as housing units with more than one person per room (including dining and living rooms but excluding bathrooms and kitchen).

REGIONAL TRENDS
Figure 3-51 below indicates that Contra Costa County in general has low levels of overcrowded households. Tracts in San Pablo, Richmond, and Pittsburg with higher percentages of non-White population show higher concentrations of overcrowded households compared to the rest of the county.

Monument Corridor, the only official R/ECAP in Contra Costa County, a predominantly Hispanic community in Concord, also exhibits more overcrowding than other parts of the County.

Figure 3-51: Distribution of Percentage of Overcrowded Households in Contra Costa County

LOCAL TRENDS
The City of Brentwood has a homogenous distribution of concentrations of overcrowded households as illustrated in Figure 3-52 below. All tracts in the city have less than 8.2% of overcrowded households. This could potentially be due to HCV use within the city, which could help maintain low levels of overcrowding even in areas where there is overpayment by renters. Furthermore, according to the ACS 2020 5-year estimates, the City of Brentwood has a high percentage (about 86%) of large housing units with 5 rooms and more. Only 0.40% of all housing units have 1 room, 0.80% have 2 rooms, 3.73% have 3 rooms, and

8.31% have 4 rooms. Large housing units could be another factor in the low percentage of overcrowding.

The median number of rooms per housing unit is 6.8.

Brentwood 2023-2031 Housing Element
Section 3: Housing Constraints, Resources, and Fair Housing 3-115 Figure 3-52: Distribution of Percentage of Overcrowded Households in Brentwood

Substandard Conditions
Incomplete plumbing or kitchen facilities can be used to measure substandard housing conditions.

REGIONAL TRENDS
According to 2015–2019 ACS estimates, shown in Table 3-37, 0.86% of households in Contra Costa County lack complete kitchen facilities and 0.39% of households lack complete plumbing facilities. Renter households are more likely to lack complete facilities compared to owner households.

Table 3-37: Substandard Housing Conditions by Tenure in Contra Costa County Owner Renter All Households
Lacking complete kitchen facilities 0.19% 0.67% 0.86%
Lacking complete plumbing facilities 0.19% 0.20% 0.39%
Source: American Community Survey, 2015-2019 (5-Year Estimates)

Table 3-38 below shows the substandard housing within Contra Costa County and the State of California from 2010 to 2019. The County has seen a drop in occupied housing units without complete plumbing and kitchen facilities from 2010 and 2019. In 2019, the County had a lower percent of occupied housing units without complete kitchen facilities compared to the State (0.9 percent and 1.1 percent, respectively).

Furthermore, the County and the State had about the same percentage of occupied housing units without complete plumbing facilities by 2019.

Brentwood 2023-2031 Housing Element
Section 3: Housing Constraints, Resources, and Fair Housing 3-116 Table 3-38: Substandard Housing Over Time by Geography
Factors
Contra Costa County State of California
2010 2019 2010 2019
Total Occupied Housing
Units 368,087 394,769 12,392,852 13,044,266
Without Complete
Plumbing Facilities 0.6% 0.4% 0.5% 0.4%
Without Complete
Kitchen Facilities 1.5% 0.9% 1.1% 1.1%
Source: American Community Survey, 5-Year Estimates, 2010, 2019.

Table 3-39 below displays the County’s housing stock by year built. Older housing may generally require more upkeep and regular maintenance and can cause a cost burden on both renters and homeowners.

Units over 30 years of age are considered older and more at-risk of requiring upgrades. Approximately

56.6 percent of the County’s housing stock was built prior to 1980. About half of housing units within the County that are over 30 years of age and should be considered for major rehabilitation.

Table 3-39: Age of Contra Costa County Housing Stock
Year Built Number of Occupied
Housing Units Percent
2014 or later 5,896 1.4%
2010 to 2013 7,275 1.8%
2000 to 2009 48,920 11.8%
1990 to 1999 51,483 12.4%
1980 to 1989 65,888 15.9%
1970 to 1979 78,180 18.9%
1960 to 1969 58,469 14.1%
1950 to 1959 52,903 12.8%
1940 to 1949 26,824 6.5%
1939 or earlier 17,881 4.3%
Source: American Community Survey, 5-Year Estimates, 2019.

LOCAL TRENDS
According to 2015–2019 ACS estimates, shown in Table 3-40, substandard housing conditions in Brentwood follow similar patterns in Contra Costa County, where higher percentages of renter households have substandard housing conditions compared to owner households. Brentwood has a higher percentage of households lacking complete kitchen facilities than the County.

Table 3-40: Substandard Housing Conditions by Tenure in Brentwood Owner Renter All Households
Lacking complete kitchen facilities 0.41% 0.67% 0.86%
Lacking complete plumbing facilities 0% 0.17% 0.17%
Source: American Community Survey, 2015-2019 (5-Year Estimates) Table 3-41 below shows the substandard housing within Brentwood and the State of California from 2010 to 2019. The City has seen a drop in occupied housing units without complete plumbing and kitchen facilities from 2010 and 2019. In 2019, the City had 0.5 percent of occupied housing units without complete kitchen facilities compared to 0.4 percent for the State. As shown in Figures 3-52a and b, the

Brentwood 2023-2031 Housing Element
Section 3: Housing Constraints, Resources, and Fair Housing 3-117 City has a few census tracks which report greater percentages of households lacking complete facilities.

The data in Table 3-41 shows that over time substandard housing conditions have decreased in the City.

The substandard units illustrated in the maps are located in areas of recent development interest; as such, substandard units may continue to decrease over time as new residential developments move forward and as the City’s Code Enforcement works with property owners.

Table 3-41: Substandard Housing Over Time by Geography
Factors
Brentwood State of California
2010 2019 2010 2019
Total Occupied Housing
Units 14,805 19,906 12,392,852 13,044,266
Without Complete
Plumbing Facilities 0.8% 0.5% 0.5% 0.4%
Without Complete
Kitchen Facilities 1.1% 0.9% 1.1% 1.1%
Source: American Community Survey, 5-Year Estimates, 2010, 2019.

Figure 3-52a: Percent Lacking Complete Plumbing in Brentwood

Brentwood 2023-2031 Housing Element
Section 3: Housing Constraints, Resources, and Fair Housing 3-118 Figure 3-52b: Percent Lacking a Complete Kitchen in Brentwood Table 3-42 below displays the City’s housing stock by year built. Approximately 11.2 percent of the City’s housing stock was built prior to 1980. The majority of the City’s housing stock was built after 1980, which indicates newer housing units.

Table 3-42: Age of Brentwood Housing Stock
Year Built Number of Occupied
Housing Units Percent
2014 or later 1,482 7.2%
2010 to 2013 1,158 5.6%
2000 to 2009 10,069 48.8%
1990 to 1999 4,578 22.2%
1980 to 1989 1,005 4.9%
1970 to 1979 999 4.8%
1960 to 1969 357 1.7%
1950 to 1959 605 2.9%
1940 to 1949 183 0.9%
1939 or earlier 191 0.9%
Source: American Community Survey, 5-Year Estimates, 2019.

The current distribution of the age of homes in Brentwood also indicates that a minority of homes in the City were built prior to the 1990 Americans with Disabilities Act (ADA), which may result in a lack of accessible homes for those residents experiencing a disability. The City’s older housing stock also reflects

Brentwood 2023-2031 Housing Element
Section 3: Housing Constraints, Resources, and Fair Housing 3-119 a need to rehabilitate housing to meet minimum livability and quality requirements, which may be a barrier to homeowners and residents in Brentwood who have a lower income or a fixed income.

Displacement Risk
Displacement occurs when housing costs or neighboring conditions force current residents out and rents become so high that lower-income people are excluded from moving in. UC Berkeley’s Urban Displacement Project (UDP) states that a census tract is a sensitive community if the proportion of very low income residents was above 20% in 2017 and the census tracts meets two of the following criteria:
(1) Share of renters above 40% in 2017; (2) Share of Non-White population above 50% in 2017; (3) Share of very low-income households (50% AMI or below) that are also severely rent burdened households above the county median in 2017; or (4) Nearby areas have been experiencing displacement pressures.

The potential for economic displacement risk can result from a variety of factors, including large-scale development activity, neighborhood reinvestment, infrastructure investments, and changes in local and regional employment opportunities. Economic displacement can be an inadvertent result of public and private investment, where individuals and families may not be able to keep pace with increased property values and market rental rates.

REGIONAL TRENDS
Using the methodology above, sensitive communities were identified in areas between El Cerrito and Pinole; Pittsburg, Antioch and Clayton; East Brentwood; and unincorporated land in Bay Point. Small pockets of Sensitive Communities are also found in central Contra Costa County from Lafayette towards Concord. Refer to Figure 3-53.

Figure 3-53: Contra Costa County Sensitive Communities - Urban Displacement Project

Brentwood 2023-2031 Housing Element
Section 3: Housing Constraints, Resources, and Fair Housing 3-120

LOCAL TRENDS
In 2015, the UDP conducted research on gentrification and displacement in the Bay Area, which concluded that nearly 48% of Bay Area neighborhoods are experiencing displacement. However, in Brentwood, only the easternmost census tract (6013303103) was identified as having sensitive communities (see Figure 3- 54). This area corresponds to block groups with higher percentages of non-white populations.

Figure 3-54: Brentwood Sensitive Communities - Urban Displacement Project

Table 3-43 analyzes the easternmost census tract in the City, which is the most vulnerable to displacement. About 53.1 percent of this block group is comprised of non-white populations.

Brentwood 2023-2031 Housing Element
Section 3: Housing Constraints, Resources, and Fair Housing 3-121 Table 3-43: Areas Vulnerable of Displacement (2019)
Data 6013303103
Demographics
Population 12,652
Households 3,907
Renter Occupied 31.70%
Median Income $93,697
Low-Income Households 43.8%
Speak English Less Than Very Well 9.5%
Race/Ethnicity:

Latino-White
White 47.0%
Black 6.60%
Asian 7.90%
LatinX 33.50%
Other 5.10%
Housing
Median Rent $1,575
Rent Gap Tract rent is $428.40 lower than nearby rents.

Hot Market No
Displacement Type: At-Risk of Displacement
Note: The Census greatly underestimates rent and home values.

Source: California Department of Housing and Community Development – AFFH Data Viewer In addition to displacement and gentrification data, the UC Berkeley Urban Displacement Project also analyzes the occurrence of anti-displacement policies, as defined below:
 Just Cause Eviction Ordinance. Just cause eviction statutes are laws that allow tenants to be evicted only for specific reasons. These “just causes” can include a failure to pay rent or violation of the lease terms.
 Rent Stabilization or Rent Control. Rent Control ordinances protect tenants from excessive rent increases, while allowing landlords a reasonable return on their investments. Such ordinances limit rent increase to certain percentages, but State law allows landlords to raise rents to the market rate once the unit becomes vacant.
 Rent Review Board and/or Mediation. Rent review boards mediate between tenants and landlords on issues related to rent increases and encourage them to come into voluntary agreement. As mediators, the board normally does not make binding decisions.  Mobile Home Rent Control. Mobile home rent control places specific rent increase restrictions on the land rented by mobile homeowners, or the mobile homes themselves.  SRO (Single-Room Occupancy) Preservation. Single room occupancies, also called residential hotels, house one or two people in individual rooms. Tenants typically share bathrooms and/or kitchens. These are often considered a form of permanent residence affordable for low-income individuals. SRO Preservation Ordinances help to preserve or create new SRO units.  Condominium Conversion Regulations. In addition to state laws regulating the conversion of multi-family rental property into condominiums, many cities have enacted condominium conversion ordinances. These impose procedural restrictions and/or substantive restrictions on the ability to convert apartment units into condominiums to protect the supply of rental housing.  Foreclosure Assistance. Many cities and counties have local programs that assist homeowners when they are at risk of foreclosure. These programs may be funded with federal grants.

Brentwood 2023-2031 Housing Element
Section 3: Housing Constraints, Resources, and Fair Housing 3-122  Jobs-Housing Linkage Fee or Affordable Housing Impact/Linkage Fee. Affordable housing impact/linkage fees are charges on developers of new market-rate, residential developments.

They are based on the square footage or number of units in the developments and are used to develop or preserve affordable housing.
 Commercial Linkage Fee/Program. Commercial linkage fees are charged to developers per square foot of new commercial development. Revenues are used to develop or preserve affordable housing.
 Housing Trust Fund. A housing trust fund is a designated source of public funds—generated through various means—that is dedicated to creating affordable housing.  Inclusionary Zoning/Housing (Below Market Rate Housing). Inclusionary housing policies require market-rate developers of rental or for-sale housing to rent or sell a certain percentage of units at affordable prices. Some policies include a provision for developers to pay “in-lieu fees” in place of building the housing; this revenue is used to develop affordable units elsewhere.  Density Bonus Ordinance. Density bonuses allow developers of market-rate housing to build higher-density housing, in exchange for having a certain portion of their units offered at affordable prices.
 Community Land Trusts. Community land trusts are nonprofit, community-based organizations (supported by the city or county) whose mission is to provide affordable housing in perpetuity by owning land and leasing it to those who live in houses built on that land.  First Source Hiring Ordinances. First Source hiring ordinances ensure that residents are given priority for new jobs created by municipal financing and development programs.

Table 3-44 identifies which of these polices the City has adopted.

Table 3-44: Anti-Displacement Policies
Anti-Displacement Measures Brentwood Policy Measure
Just Cause Eviction Ordinance No
Rent Stabilization or Rent Control No
Rent Review Board and/or Mediation No
Mobile Home Rent Control No
SRO Preservation No
Condominium Conversion Regulations Yes
Foreclosure Assistance Yes
Jobs-Housing Linkage Fee No
Commercial Linkage Fee No
Housing Trust Fund Yes
Inclusionary Zoning Yes
Density Bonus Ordinance Yes
Community Land Trusts No
First Source Hiring No
Source: Urban Displacement Project, University of California Berkeley (2021), and the City of Brentwood.

Brentwood 2023-2031 Housing Element
Section 3: Housing Constraints, Resources, and Fair Housing 3-123 At-Risk Assisted Affordable Housing
Jurisdictions are required by State Housing Element Law to analyze government-assisted housing that is eligible to convert from lower income to market rate housing over the next 10 years. State law identifies housing assistance as a rental subsidy, mortgage subsidy or mortgage insurance to an assisted housing development. Government assisted housing may convert to market rate housing for several reasons, including expiring subsidies, mortgage repayments, or expiration of affordability restrictions. Affordable covenants help to ensure that certain housing units remain affordable for an extended period of time.

Covenants help balance the housing market in a community and provide lasting affordable options to low and very low-income households.

Table 3-45 below provides a list of 96 housing units with affordability covenants, of which 9 housing units are at-risk of converting to market-rate between 2023 and 2033. Consistent with the requirements to analyze the impacts of the potential conversion of these units to market-rate units, this section provides an analysis of preservation of assisted housing units at-risk of conversion.

Table 3-45: City of Brentwood Assisted Housing Covenants (2023-2033) APN Address Income Earliest Possible
Date of Conversion Assisted Units
010-650-010 621 Cashew Court Moderate 2036 1
010-650-033 671 Armstrong Way Very Low 2034 1
010-660-009 517 Edgefield Street Very Low 2035 1
010-670-042 522 Coconut Place Moderate 2035 1
010-770-018 300 Datenut Street Moderate 2032 1
010-650-025 644 Macadamia Court Moderate 2044 1
010-670-033 519 Coconut Place Moderate 2033 1
010-660-049 504 Edgefield Street Moderate 2032 1
010-670-007 172 Continente Ave Moderate 2033 1
010-770-040 623 Armstrong Way Moderate 2033 1
010-660-064 532 Coconut Street Moderate 2032 1
010-660-053 533 Coconut Street Moderate 2032 1
010-660-003 204 Continente Ave Moderate 2032 1
010-770-031 588 Flowering Plum Place Moderate 2043 1
010-770-005 541 Cashew Place Moderate 2045 1
010-650-019 651 Macadamia Court Moderate 2032 1
012-350-004 81 Rossano Street Very Low 2053 1
013-380-105 828 Shasta Daisy Drive Very Low 2049 1
013-400-013 124 Kingfisher Street Low 2063 1
013-400-016 118 Kingfisher Street Very Low 2050 1
013-400-023 95 Pelican Street Very Low 2050 1
013-400-052 83 Roadrunner Street Very Low 2056 1
013-400-053 81 Ibis Street Very Low 2050 1
013-400-058 71 Roadrunner Street Moderate 2062 1
013-400-064 111 Spruce Street Low 2050 1
013-410-028 935 Oxford Lane Moderate 2052 1
013-410-033 919 Oxford Lane Moderate 2050 1
016-300-004 281 Washington Drive Moderate 2050 1
016-300-016 251 Washington Drive Moderate 2050 1
016-300-017 247 Washington Drive Moderate 2050 1
016-300-110 352 Jefferson Drive Moderate 2050 1
016-300-119 293 Washington Drive Moderate 2064 1
016-300-217 1333 Harrison Lane Moderate 2059 1

Brentwood 2023-2031 Housing Element
Section 3: Housing Constraints, Resources, and Fair Housing 3-124 Table 3-45: City of Brentwood Assisted Housing Covenants (2023-2033) APN Address Income Earliest Possible
Date of Conversion Assisted Units
016-300-254 364 Jefferson Drive Moderate 2065 1
018-470-004 1351 Tiffany Drive Low 2050 1
018-520-030 1183 Tropicana Lane Low 2057 1
018-520-070 2523 Albertine Lane Low 2050 1
018-520-071 1133 Europena Drive Low 2050 1
018-520-072 1272 Picadilly Lane Low 2051 1
018-560-020 1085 Granville Lane Very Low 2051 1
018-560-021 1237 Sheldon Drive Low 2051 1
018-560-042 1135 Breton Drive Low 2051 1
018-560-043 1097 Granville Lane Low 2051 1
019-760-059 1500 Rampart Way Very Low 2050 1
019-760-060 1999 Helena Way Low 2050 1
019-840-090 1862 White Sands Street Low 2051 1
019-850-007 2394 Tamalpais Avenue Low 2051 1
019-840-029 2461 Mojave Drive Very Low 2055 1
019-840-020 2442 Mojave Drive Low 2055 1
019-850-089 2414 Tamalpais Court Low 2055 1
019-850-081 2348 Blue Ridge Avenue Low 2055 1
019-850-077 2345 Blue Ridge Avenue Low 2055 1
019-850-053 2263 Black Stone Drive Low 2056 1
019-850-072 2331 Blue Ridge Avenue Low 2056 1
019-850-065 2317 Blue Ridge Avenue Low 2056 1
019-850-018 2322 Blue Ridge Avenue Low 2056 1
019-850-035 2284 Black Stone Drive Very Low 2066 1
016-480-048 1652 Bedford Court Low 2057 1
016-480-049 1650 Bedford Court Very Low 2057 1
016-490-012-8 473 Milford Court Low 2058 1
018-620-048 2600 Brookshire Street Low 2059 1
018-610-079 1063 Steeple Boulevard Very Low 2059 1
016-520-025-4 1355 Bellerose Court Low 2059 1
017-640-041 816 Queen Palm Lane Low 2060 1
016-460-053 614 Bristol Court Low 2061 1
016-460-054 616 Bristol Court Low 2061 1
016-490-028 470 Stratford Court Low 2062 1
016-510-0066 708 Jennifer Street Very Low 2063 1
016-510-0074 710 Jennifer Street Very Low 2063 1
016-570-062 204 Sespe Creek Avenue Low 2065 1
016-570-031 133 Scott Creek Way Very Low 2065 1
016-580-073-1 175 Brush Creek Drive Low 2066 1
016-580-038-4 162 Canary Creek Drive Low 2066 1
016-590-068 208 Brush Creek Drive Low 2066 1
Total Units 75
TOTAL AT-RISK UNITS 6

Brentwood 2023-2031 Housing Element
Section 3: Housing Constraints, Resources, and Fair Housing 3-125 Table 3-43b: City of Brentwood CHPC Units
Property Address Financing Placed in
Service
Term/Expiration
Year
Assisted
Units
Arbor Ridge
Apartments
2400 Shady Willow
Lane LIHTC 2005 55 years, 2060 36
Villa Amador
Apartments 2101 Sand Creek Road LIHTC, MHP, CalHFA Permanent Loan 2008 55 years, 2063 94 Marsh Creek
Apartments 7251 Brentwood Blvd LIHTC 1997 55 years, 2052 126 The Grove at Sunset
Court 55 Havenwood Ave LIHTC 2013 55 years, 2068 53
Sycamore Place 1100 Sycamore Court PRAC/202 HUD
Financing Program 1997 40 years, 2037 40
Sycamore Place
Senior Housing 161 Sycamore Avenue PRAC/202 HUG Financing Program 2005 55 years, 2060 39 Brentwood Garden
Apartments 180 Sycamore Avenue LIHTC 1998 55 years, 2053 80 Brentwood Park
Apartments 160 Sycamore Avenue LIHTC 1997 55 years, 2052 79 Brentwood Senior
Commons 750 Larkspur Lane LIHTC 2006 55 years, 2061 79
Green Valley
Apartments 8510 Brentwood Blvd LIHTC, RHCP 1992 60 years, 2052 28 Total Units 654
TOTAL AT-RISK UNITS 0
Source: California Housing Partnership - Affordable Housing Map and Benefits Calculator

COST OF PRESERVING AT-RISK UNITS
While there are many options to preserve at-risk units including providing financial incentives to property owners to extend lower-income use restrictions, purchasing affordable housing units by a non-profit or public agency, or providing local subsidies to offset the difference between the affordable and market rate units, the strategy considered below is to provide local rental subsidy to residents. The rent subsidy would provide financial assistance to residents if their affordable units converted to market-rate units. To determine the subsidy needed, fair market rents were compared to market-rate rents. Table 3-46 below outlines an estimated monthly subsidy that would be required to preserve these at-risk units.

Table 3-46: Estimated Monthly Subsidy to Preserve At-Risk Units Unit Size
Monthly Rents Number of
Units
At-Risk*
Difference Monthly
Subsidy
Annual
Fair Market Subsidy 1 Average
Market Rate2
Efficiency $1,538 N/A 0 - - -
1-Bedroom $1,854 N/A 0 - - -
2-Bedroom $2,274 $3,150 0 $876 $0 $0
3-Bedroom $3,006 $3,000 0 ($6) $0 $0
4-Bedroom $3,578 $3,597 6 $19 $114 $1,368
Total $1.368
*This is based upon the assumption that the single-family units at-risk of converting to market rate all contain 4 bedrooms.

Source:

1. HUD FY 2022 Fair Market Rent Documentation System – Oakland-Fremont, CA HUD Metro FMR Area.

2. Kimley-Horn and Associates Analysis – based on 39 single-family units listed for rent on August 3, 2022.

Brentwood 2023-2031 Housing Element
Section 3: Housing Constraints, Resources, and Fair Housing 3-126

COST OF REPLACING AT-RISK UNITS
The City can also consider the cost of replacing the units with new construction. Construction cost estimates include all hard and soft costs associated with construction in addition to per unit land costs.

The analysis assumes the replacement units are apartments with concrete block with steel frame buildings and parking provided on-site. Square footage estimates are based on estimated size of units to be replaced and assume housing units are developed on multi-family zoned properties. Land costs have been determined on a per unit basis. Table 3-47 below estimates that $2,396,591 would be required to replace the at-risk units.

Table 3-47: Replacement Cost of At-Risk Units
Unit Size Cost per
Square Foot1
Average
Square Foot
per Unit2
Replacement
Cost per Unit
Number of
Units At-Risk*
Total
Replacement
Cost
Efficiency $160.35 N/A - - -
1-Bedroom $160.35 N/A - - -
2-Bedroom $160.35 1,582 $253,673.70 0 $0.00
3-Bedroom $160.35 1,854 $297,288.90 0 $0.00
4-Bedroom $160.35 2,491 $399,431.85 74 $2,396,591.10
Total $2,396,591.10
* This is based upon the assumption that the single-family units at-risk of converting to market rate all contain 4 bedrooms.

Source:

1. International Code Council – February 2022. Square Foot Construction Cost for a VA Structure.

2. Kimley-Horn and Associates Analysis – based on 39 single-family units listed for rent on August 3, 2022.

A variety of programs exist to help cities acquire, replace, or subsidize at-risk affordable housing units.

The following summarizes financial resources available:
 Community Development Block Grant (CDBG) – CDBG funds are awarded to cities on a formula basis for housing activities. The primary objective of the CDBG program is the development of viable communities through the provision of decent housing, a suitable living environment and economic opportunity for principally low- and moderate-income persons. Eligible activities include administration, fair housing, energy conservation and renewable energy sources, assistance for economic development, public facilities and improvements and public services.  HOME Investment Partnership – Local jurisdiction can receive funds by formula from the Department of Housing and Urban Development (HUD) to increase the supply of decent, safe, sanitary, and affordable housing to lower income households. Eligible activities include housing acquisition, rehabilitation, and development, homebuyer assistance, and rental assistance.  Section 8 Rental Assistance Program – The Section 8 Rental Assistance Program provides rental assistance payments to owners of private, market rate units on behalf of very low-income tenants, senior citizens, disabled and/or handicapped persons, and other individuals for securing affordable housing.
 Section 202/811 Program – Non-profit and consumer cooperatives can receive no-interest capital advances from HUD under the Section 202 program for the construction of very low-income rental housing with the availability of supportive services for seniors and persons with disabilities. These funds can be used in conjunction with Section 811, which can be used to develop group homes, independent living facilities and immediate care facilities. The capital advance funding can also provide project rental assistance for the properties developed using the funds. Eligible activities include acquisition, rehabilitation, new construction, and rental assistance.  California Housing Finance Agency (CalHFA) Multifamily Programs – CalHFA’s Multifamily Programs provide permanent financing for the acquisition, rehabilitation, and preservation of

Brentwood 2023-2031 Housing Element
Section 3: Housing Constraints, Resources, and Fair Housing 3-127 new construction of rental housing that includes affordable rents for low- and moderate-income families and individuals. One of the programs is the Preservation Loan program which provides acquisition/rehabilitation and permanent loan financing designed to preserve or increase the affordability status of existing multifamily housing projects.  Low-Income Housing Tax Credit (LIHTC) – This program provides tax credits to individuals and corporations that invest in low-income rental housing. Tax credits are sold to those with high tax liability and proceeds are used to create housing. Eligible activities include new construction, rehabilitation, and acquisition of properties.
 California Community Reinvestment Corporation (CCRC) – The California Community Reinvestment Corporation is a multifamily affordable housing lender whose mission is to increase the availability of affordable housing for low-income families, seniors, and residents with special needs by facilitating private capital flow from its investors for debt and equity to developers of affordable housing. Eligible activities include new construction, rehabilitation, and acquisition of properties.

The following organizations may potentially assist in preserving units at-risk of converting to market rate.  ACLC, Inc
 East Bay NHS
 Affordable Housing Associates
 Eskaton Properties Inc.
 Rural California Housing Corp
 East Bay Asian Local Development
Corporation
 Pacific Community Services, Inc.
 Rubicon Programs, Inc. Community
Housing Development Corp.
 Satellite Housing Inc.
 Northern California Land Trust, Inc.
 Alameda County Allied Housing
Program
 ROEM Development Corporation
 Neighborhood Housing Services of the
East Bay
 L + M Fund Management LLC
Resources for Special Needs Households
The analysis of disproportionate housing needs within Brentwood evaluated existing housing need, needs of the future housing population, and units within the community at-risk of converting to market-rate. A variety of factors affect housing needs for different households. Most commonly, disability, household income and households’ characteristics shape the type and size of housing units needed, as well as accessibility based on existing units in a City. Table 3-32 through 3-37 displayed data for demographic characteristics of Brentwood. Additional detailed analysis of the community demographics is outlined in Section 2: Community Profile of this Housing Element.

Section 3.B: Financial Resources provides information on financial resources available to meet the housing needs of special needs households. A variety of programs exist to help cities meet the needs of their communities. The following financial resources are available in the City and are summarized above:
 Community Development Block Grant (CDBG)
 HOME Investment Partnership
 Section 8 Rental Assistance Program
 Section 202/811 Program
 California Housing Finance Agency (CalHFA) Multifamily Programs  Low-Income Housing Tax Credit (LIHTC)
 California Community Reinvestment Corporation (CCRC)

Brentwood 2023-2031 Housing Element
Section 3: Housing Constraints, Resources, and Fair Housing 3-128 The following is a partial list of organizations that may potentially assist with local housing, social services, and legal services:
 Fair Housing Advocates of Northern California (FHANC);  Eden Council for Hope and Opportunity (ECHO) Fair Housing;  Bay Area Legal Aid;
 Pacific Community Services.

Persons with Disabilities
According to the 2015-2019 American Community Survey (ACS) 5-year estimates, 118,603 residents (10.9 percent 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 3-26 above (9.24 percent in Brentwood). Note that an individual may report more than one disability. The greatest percentage of disabilities in Brentwood consist of ambulatory disabilities, followed by independent living, cognitive, hearing, self-care, and vision difficulties. The California Department of Developmental Services (CDDS) provides estimates of persons with developmental disabilities in Brentwood, as shown in Section 2 Community Profile: Table 2-23. As of January 2022, CDDS identified 373 juvenile persons and 285 adults of having developmental disability in the ZIP code 94513.

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.

There are several housing types appropriate for people living with a developmental 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
Referring to Figure 3-12, Brentwood has an overall low-to-moderate distribution of population with disabilities. The northern central part of the city has less than 10 percent of population with a disability; the rest of the city has 10 to 20 percent of population with a disability. In terms of geographic dispersal, there is a relatively homogenous dispersal of persons with disabilities. Ease of reasonable accommodation procedures and opportunity for accessible housing can provide increased housing security for the population with disabilities.

A number of proposed housing sites are located within the areas that have 10 to 20 percent of population with a disability. While the percentages are relatively low and similar to neighboring communities, the location of the potential future housing sites in these census tracts may provide opportunities for affordable housing in conjunction with or near services.

Brentwood 2023-2031 Housing Element
Section 3: Housing Constraints, Resources, and Fair Housing 3-129 Patterns and Trends for Disproportionate Housing Needs Based On Disability Analysis of persons with disabilities indicates there are no significant concentrations within the City. As shown in Figure 3-12, there are census tract with 10 percent to 20 percent incidents of disability status.

There is no indication that land use or access to opportunity affect concentrations of persons with disabilities. The City believes ADA requirements and other development standards will not restrict or concentrate persons with disabilities in the community. Federal/State law and City programs support fair housing opportunity and seek to reduce and/or eliminate potential impacts. The City has committed to the following programs to assist persons with disabilities:
 Action H.4i: Housing for Persons with Developmental Disabilities  Action H.4e: Housing Opportunities for Special Needs Groups  Action H.4g: Reasonable Accommodation
 Action H.4a: Affirmatively Further Fair Housing
 Action H.1k: Condominium Conversion
 Action H.4c: Disseminate Fair Housing Information
 Action H.2d: Affordable Housing Assistance
Persons Experiencing Homelessness
Table 2-28 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 2018 but reports a lower figure in 2021 compared to 2020.

Brentwood had 2.2 percent of all persons experiencing homelessness in Contra Costa County in 2021.

People experiencing homelessness in Brentwood are those who do not have a fixed, regular, and adequate overnight residence, or whose overnight residence is a shelter, street, vehicle, or enclosure or structure unfit for habitation. Factors contributing to increases of homelessness may include the following:
 Lack available resources to support stable housing access  Spikes in rent increase and lack of tenant protections  Housing discrimination
 Evictions
 Lack of housing affordable to low- and moderate-income persons  Increases in the number of persons whose incomes fall below the poverty level  Reductions in public subsidies to the poor
 The deinstitutionalization of the mentally ill
Residents experiencing homelessness in Brentwood have exhibited the following unique challenges to housing:
 Need for increased affordable housing options
 Need for smaller housing unit options such as SRO’s
 Rental assistance
 Higher likelihood for transitional and supportive housing  Lack of access to emergency shelters
Homelessness is a serious issue in the City of Brentwood. As such, the City has also committed to the following programs:

Brentwood 2023-2031 Housing Element
Section 3: Housing Constraints, Resources, and Fair Housing 3-130  Action H.4f: Coordination with Agencies Serving the Homeless  Action H.4e: Housing Opportunities for Special Needs Groups  Action H.4j: Single-Room Occupancy (SRO) Units
 Action H.4h: Low-Barrier Navigation Center
 Action H.4b: Cooperative Association with Non-Profits  Action H.3f: Housing for Extremely Low-, Very Low-, and Low-Income Residents  Action H.4a: Affirmatively Further Fair Housing
 Action H.2d: Affordable Housing Assistance
Patterns and Trends for Disproportionate Housing Needs Based On Homeless Status Analysis of homeless persons historically, has indicated that homeless persons in the City are located close to where services are offered. While by nature homeless in transient, there is typically higher incidents of homeless persons located in areas the provide services or fulfill the day to day needs of the population.

The City has evaluated the location of homeless persons in sheltered versus unsheltered living conditions.

It was found that most known homeless persons in the community are currently living in unsheltered conditions. Current land use patterns and the built environment have no known influence on the location and extent of homelessness in the community. As persons experiencing homelessness are in need of low cost, emergency, or transitional housing shelter with access to services, a suite of housing Programs have been included in the Housing Element to support the specific needs of the community. These programs address local trends by supporting service-based housing to the most vulnerable populations in the City.

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 (15 percent), 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.

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 as shown in Table 2-21. In total, 51.7 percent of senior households are considered low-income and earn less than 80 percent of the MFI. Seniors may also face various disabilities. Smaller, more affordable housing units allow for a greater accommodation of senior lifestyles.

Seniors in Brentwood generally have exhibited the following unique challenges to housing:
 Having limited and fixed incomes
 Disproportionately higher healthcare costs, adding monthly living costs  Require customized housing features due to mobility and selfcare limitations  Transit dependency
 Limited in-home support, due to living alone

Brentwood 2023-2031 Housing Element
Section 3: Housing Constraints, Resources, and Fair Housing 3-131 More than half of seniors within the city have median incomes that are less than the City’s median income.

In order to ensure fair housing for seniors, the following strategies have been included in Section 4:
 Action H.4e: Housing Opportunities for Special Needs Groups  Action H.4b: Cooperative Association with Non-Profits  Action H.3f: Housing for Extremely Low-, Very Low-, and Low-Income Residents  Action H.4g: Reasonable Accommodation
 Action H.4a: Affirmatively Further Fair Housing
 Action H.1k: Condominium Conversion
 Action H.4c: Disseminate Fair Housing Information
 Action H.1d: Monitor At-Risk Projects
 Action H.2d: Affordable Housing Assistance
Farmworkers
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. These employees and their households may reside in severely overcrowded dwellings, in packing buildings, or in storage sheds. Future housing in Brentwood may need to consider the needs of farm workers employed in and near the City.

Farmworker households have exhibited the following unique challenges to housing:
 Affordable housing options
 Higher incidents of cost burden for housing
 Rental and for sale housing options
Similar to other special needs groups, farmworkers needs are focused on affordability of housing and access to services that support lower monthly overall costs. To address these challenges the City must consider a variety of solution to address the above issues, such as affordable housing options for farmworkers and leveraging grants and funding opportunities.

While farmworkers do not make up a large group of residents within the City, the City has included Action H.1l: Farmworker and Employee Housing to amend the City’s Municipal Code to comply with the provisions for farmworker housing set forth in the Employee Housing Act. In addition, the following programs are included to promote the development of affordable housing units throughout the City that may be available to Farmworkers:
 Action H.4e: Housing Opportunities for Special Needs Groups  Action H.4b: Cooperative Association with Non-Profits  Action H.3f: Housing for Extremely Low-, Very Low-, and Low-Income Residents  Action H.4a: Affirmatively Further Fair Housing

Brentwood 2023-2031 Housing Element
Section 3: Housing Constraints, Resources, and Fair Housing 3-132  Action H.2d: Affordable Housing Assistance
Large Households
The HCD defines large households as households of five or more individuals. Procuring resources for a large household requires a greater portion of income. This may lead households to find smaller, more affordable housing units, which may not be large enough to accommodate a large household and may lead to overcrowding. It may be more challenging for renters to secure larger housing units as multi- family rental units are typically smaller than single-family ownership units. Many apartment complexes do not typically have 4- or 5-bedroom units. As bedroom count increases, the affordability of a housing unit typically decreases.

Table 2-24 shows that 15.3 percent of all households have five or more persons with five person households being the most common. According to the same table, renters represent a large portion of large households in the City. The provision of affordable housing may alleviate potential overcrowding burdens experienced by these households. While households over the size of four people typically make more money than the City’s median income, it shows that households with over four people typically allocate less money per person than households with four or fewer people.

According to the ACS 2020 5-year estimates, the City of Brentwood has a high percentage (about 86 percent) of large housing units with 5 rooms and more. Only 0.40 percent of all housing units have one room, 0.80 percent have two rooms, 3.73 percent have three rooms, and 8.31 percent have four rooms.

Large housing units could be the reason the City has a low percentage of overcrowding. The median number of rooms per housing unit is 6.8.

In general, large person households have exhibited the following unique challenges to housing:
 Lack of affordable housing with sufficient bedroom counts  Options for larger bedroom counts in rental units
 Higher monthly cost burden
 Affordable options for large family households
 Childcare needs for working families
The City has committed to the following programs in order to ensure fair housing for large households:
 Action H.4e: Housing Opportunities for Special Needs Groups  Action H.3f: Housing for Extremely Low-, Very Low-, and Low-Income Residents  Action H.4a: Affirmatively Further Fair Housing
 Action H.2d: Affordable Housing Assistance
Extremely Low-Income Households
Extremely low-income (ELI) households are those that earn 30 percent or less of the median family income (MFI) for Contra Costa County. CHAS data indicates there are approximately 2,009 ELI households living in the City. Table 2-6 identifies industries with salaries that could qualify as ELI, these include: Personal Care and Service, Healthcare Support, and Food Preparation and Serving Related.

ELI households represent approximately 10.1 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.

Brentwood 2023-2031 Housing Element
Section 3: Housing Constraints, Resources, and Fair Housing 3-133 Housing ELI households is generally challenging in Brentwood. Table 2-26 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.

A majority of extremely low-income households face a variety of housing problems. Additionally, some extremely low-income households could face other issues such as having special needs or disabilities that could exacerbate housing problems.

Extremely Low-Income Households in Brentwood have exhibited the following unique challenges to housing:
 Need for increased affordable housing options
 Markedly higher incidents of cost burden for housing
 Need for smaller housing unit options such as SRO’s
 Rental assistance
 Higher incidents of homelessness
Figure 3-18 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 to 100 percent). Radiating from the center, block groups in the east have 50 to 75 percent of LMI populations, 25 to 50 percent towards the west, and less than 25 percent in the outermost portions towards the south and west. A section of block groups in central Brentwood have less than 25 percent of LMI population as well. Block groups with less than 25 percent of LMI correlate with block groups with median household income greater than $125,000 and over 80 percent 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 28.9 percent of owner households are considered LMI (earns less than 80 percent of HAMFI) compared to almost 60 percent of renter households. The reverse is true for those of high-income households (more than 100 percent of HAMFI), where almost 65 percent of owner households are high income and only about 34 percent of renter households are high income.

Although Brentwood experiences higher median incomes, it is still important to provide improved access to resources and opportunities for all households. The City has committed to the following programs in order to ensure fair housing for families experiencing financial hardships and to address unique needs of extremely-low income households in the City:
 Action H.4e: Housing Opportunities for Special Needs Groups  Action H.4b: Cooperative Association with Non-Profits  Action H.3f: Housing for Extremely Low-, Very Low-, and Low-Income Residents  Action H.4j: Single-Room Occupancy (SRO) Units
 Action H.2d: Affordable Housing Assistance
 Action H.4a: Affirmatively Further Fair Housing
 Action H.1k: Condominium Conversion
 Action H.1b: Accessory Dwelling Units
 Action H.4c: Disseminate Fair Housing Information

Brentwood 2023-2031 Housing Element
Section 3: Housing Constraints, Resources, and Fair Housing 3-134  Action H.1d: Monitor At-Risk Projects
 Action H.2a: Compliance with Affordable Housing Ordinance  Action H.3c: Development Incentives
 Action H.2b: Additional Development Incentives for Affordable Housing  Action H.2l: Development Fees
Senate Bill 330 (SB 330)
Effective January 1, 2020, Senate Bill 330 (SB 330) aims to increase residential unit development, protect existing housing inventory, and expedite permit processing. Under this legislation, municipal and county agencies are restricted in ordinances and polices that can be applied to residential development. The revised definition of “Housing Development” now contains residential projects of two or more units, mixed-use projects (with two-thirds of the floor area designated for residential use), transitional, supportive, and emergency housing projects. SB 330 sets a temporary 5-year prohibition of residential density reduction associated with a “housing development project”, from January 1, 2020, to January 1, 2025. For example, during this temporary prohibition, a residential triplex cannot be demolished and replaced with a duplex as this would be a net loss of one unit.

The City has identified sites as part of its candidate sites analysis that have existing residential uses. A replacement program is included in Section 4: Housing Plan.

2. Assessment of Contributing Factors
The Contra Costa AI identifies the following regional goals for mitigating impediments to fair housing within jurisdictions in Contra Costa County:
 Increase available financial resources for affordable housing in order to better fund efforts to foster stable residential integration and increased access to opportunity;  Provide for the production of additional affordable housing through market incentives and improvements;
 Increase residential racial and ethnic integration by increasing the supply of affordable housing for families in high opportunity areas;
 Increase the supply of permanent supportive housing for people with disabilities and services for people with disabilities;
 Reduce housing discrimination and discriminatory barriers to residential mobility;  Address barriers to mobility for families and individuals in publicly-supported housing, including Housing Choice Voucher participants;
 Reduce the displacement of low-income communities of color by enhancing protections for vulnerable tenants and homeowners and preserving affordable housing in areas that are gentrifying or at risk of gentrification;
 Increase access to opportunity through targeted public investments and efforts to increase economic mobility within Racially or Ethnically Concentrated Areas of Poverty (R/ECAPs);  Increase and stabilize access to proficient schools;
 Increase coordination of housing and environmental health planning to support access to healthy homes and neighborhood; and
 Improve inter-jurisdictional coordination.

Brentwood 2023-2031 Housing Element
Section 3: Housing Constraints, Resources, and Fair Housing 3-135 Current Local Contributing Factors
As a part of the Housing Element, the City considers protected class (such as race, ethnicity, income, etc.) and opportunity indicators as key factors in fair housing. Federal, state, and local data provide regional context, background information and supportive data which helps the City to understand fair housing issues and to identify key fair housing factors for Brentwood. The section below uses available data to identify key trends and local contributing factors for fair housing. Key findings identified through this analysis are stated below:
 All but four census tracts earn an annual income higher than the State Median Income, many of which earn more than $125,000.
 Census tracts earning equal or less than the State Median Income experienced lower access to resources.
 Census tracts earning equal or less than the State Median Income experienced higher environmental burdens.
 Census tracts earning equal or less than the State Median Income experienced a higher concentration of overpayment from both owners and renters.  Native Hawaiian/Other Pacific Islander and Black or African American had the lowest loan approval rates in the City.
 The racial and ethnic groups with the highest levels of segregation is the Black or African American, non-Hispanic population and Hispanic or Latino population.  The whole City experiences poor job proximity and transportation connectivity.

There are a number of elements that may contribute to fair housing issues throughout the community.

The following provides potential contributing factors affecting fair housing in Brentwood:
 Displacement of Residents Due to Economic Pressures – Displacement of residents due to economic pressures may be a contributing factor to fair housing in Brentwood. Contra Costa County has been facing a major affordable housing crisis for years due to factors including insufficient housing production, especially in predominantly non-Hispanic White high-opportunity areas, and a strong regional economy. The rising housing costs during the COVID-19 exacerbated current conditions.
 Availability of Affordable Housing – Section 2 of this Housing Element provides data on household and economic characteristics. The City has an unemployment rate of 4.3 percent and 32 percent of the employed population earn a lower income (below 80 percent of the Median Family Income for the region). In addition to allowing for the development of additional affordable housing units for current lower income residents, the City should provide additional resources and outreach to organizations and residents regarding aid available for those in need.  Environmental Justice Discrepancy – Excessive exposure to harmful environmental pollutants often exacerbate and are exacerbated by socioeconomic issues such as lack of access to resources, healthy food, or housing. Lack of affordable housing in areas where resources are higher, exposure to harmful pollutants is lower and opportunities are more plentiful would mitigate this effect on the residents.
 Access to Housing Opportunities for Special Needs Populations – Affordability, design, and discrimination limit the supply of housing for special needs populations. For persons with disabilities, amendments to the Fair Housing Act, as well as State law, require ground-floor units of new multi-family construction with more than four units to be accessible; however, units built prior to 1989 are not required to be accessible to today’s standards. Just over a quarter of the City’s housing stock was built prior to 1989. Additionally, persons with disabilities, lower income households, single parents, and seniors may have limited incomes which make market-rate

Brentwood 2023-2031 Housing Element
Section 3: Housing Constraints, Resources, and Fair Housing 3-136 housing inaccessible and they may require housing within close proximity to childcare or community services. A greater variety of housing types which cater to the needs of special housing needs populations in areas of opportunity and near services and resources may address this issue.  Racially Concentrated Areas of Affluence – The City has two census tracts that are designated as RCAAs (32.02 and 40.01). RCAAs may represent a public policy issue to the extent that they have been created and maintained through exclusionary and discriminatory land use and development practices.

AFFH Findings and Sites Summary
As noted before, the City has identified candidate sites to accommodate future housing growth based on existing access to community resources, services, and public transportation, while also considering the availability of land, developer interest, and general likelihood the sites would develop residential uses over the next eight years. Figure 3-55 shows the three “regions” of the City where candidate sites have been identified in relation to the location of resources and services.

Brentwood 2023-2031 Housing Element
Section 3: Housing Constraints, Resources, and Fair Housing 3-137 Figure 3-55: Sites Inventory Quadrants
Area 1
Area 2
Area 3

Brentwood 2023-2031 Housing Element
Section 3: Housing Constraints, Resources, and Fair Housing 3-138 AREA 1
The TCAC Opportunity Maps identified Area One as an area with moderate resources that is rapidly changing. Area One has all the PA-1 Specific Plan sites. There are several restaurants and retail uses that are currently located along Lone Tree Way to the north and Sand Creek Road to the South. Shopping plazas such as the Slatten Ranch Shopping Center, Empire Shopping Center, and Lone Tree Plaza are all located in Area One. These plazas have big box retail stores such as Kohl’s, Best Buy, Home Depot and JCPenney that are near each other. The Labor Market engagement index score for this area was scored between 40 to 60. Residents in Area One are slightly closer in proximity with their jobs compared to other parts of the City. Trader Joe’s is also located within PA-1 area and Sprouts Farmers Market and Raley’s are located to the south. Area One’s close proximity to healthy food access places rates this area as one of the healthier conditions in the City (TCAC Opportunity Maps).

There are two pharmacies as well as a number of medical offices located in close proximity in Area One.

Two elementary schools, Pioneer Elementary and Loma Vista Elementary, are also located in this area.

Area One has access to four bus lines – Routes 384, 380, 385, and 395. The routes are currently located along Sand Creek Road, Shady Willow Lane, Canada Valley Road, and Lone Tree Way. The area is also bisected by John Marsh Heritage Highway (State Route 4) which connects the City to the rest of the County and the San Francisco Bay area. Hence, Area One has moderate connectivity, access to jobs, and frequency of services as identified in the AllTransit Map. As future developments are built throughout the years, residents in Area One will have access to the various resources and opportunities.

AFFH Findings for Area One:
 Along the City’s western border reports a non-white population of approximately 21 to 40 percent. However, this data may be impacted by neighboring communities as the portion within Brentwood includes just a few housing units.
 Most of the City reports the same percentage of population with a disability (10 to 20 percent), including Area One.
 Average percentages of low- to moderate-income households; income in the area has increased between 2014 and 2019.
 The affordability index reports a median gross rent ranging from $2,000 to $2,500.  TCAC moderate resource scores
 Moderate/low transit scores
 Moderate CalEnviroScreen pollution burden
 High Healthy Places Index score
 40 to 80 percent overpayment by renters
 One neighborhood with 2 to 5 percent households lacking complete plumbing, and another neighborhood to the south with 5 to 10 percent
 One neighborhood with 2 to 5 percent households lacking a complete kitchen In summary, Area One is experiencing a growth in development interest through the PA-1 Specific Plan and additional pipeline projects, in combination with increasing median incomes and average rental rates in comparison to the rest of the City. Access to transit in the area has been low, but with the development of PA-1 access may increase. In general, this area is appropriate for the development of housing at all income levels; as the area with the most lower income units, future households will have access to resources, won’t be overly impacted by pollution burdens, and future developments will create opportunities for existing lower income households to have affordable rents and units with complete facilities.

Brentwood 2023-2031 Housing Element
Section 3: Housing Constraints, Resources, and Fair Housing 3-139 As shown in Table 3-48, all of the low-income units are from the PA-1 sites. Area one has the most lowincome, moderate-income, and above moderate-income units compared to the other two areas. As shown in the AFFH data viewer, Area One has the highest percentage of renter units with HCVs (>15%- 30%). Furthermore, majority of the households have a median income greater than $125,000. As a result, Area One can accommodate a greater variety of housing for different income categories. In general, the area is well supported with resources and will continue to be as PA-1 Specific Plan units are developed in this area.

Table 3-48: Area One RHNA
Site
Number Map Category Low- Income ModerateIncome
Above ModerateIncome Total
1 PA-1 Specific Plan 42 18 60 120
2 PA-1 Specific Plan 41 18 59 118
3 PA-1 Specific Plan 43 18 61 122
4 PA-1 Specific Plan 43 18 61.25 122
5 PA-1 Specific Plan 36 15 51 102
6 PA-1 Specific Plan 34 15 48.5 98
7 PA-1 Specific Plan 60 26 86.5 173
8 PA-1 Specific Plan 61 26 88 175
9 PA-1 Specific Plan 70 30 100 200
10 PA-1 Specific Plan 34 15 49 98
11 PA-1 Specific Plan 0 30 169 199
16 Pipeline 0 0 37 37
17 Pipeline 0 0 288 288
18 Pipeline 0 0 160 160
TOTAL 464 229 1,318 2,011
AREA 2
Area Two consists of the northeastern portions of the City. Majority of the land uses in this area are residential and agricultural conservation. The TCAC Opportunity map has identified this area to have moderate to low resources. Brentwood Boulevard runs through Area two. There is renewed interest in redevelopment within this area of town with a new shopping center located on the southeast corner of Brentwood Boulevard and Sand Creek Road that include Chipotle, Panda Express, Starbucks, and Grocery Outlet, as well as Denny’s and Wendy’s still under construction. Directly across the street on the northeast corner is also a new gas station and 7-eleven. There are also dining options along Brentwood Boulevard which include Brentwood Cafe, Chicago’s Pizza, Starbucks, and McDonald’s. The Town Centre Plaza is also located within close distance to Brentwood Boulevard which has a CVS Pharmacy and a Safeway. There are also a few grocery stores located throughout the area, which include Eatwell Nutrition, Grocery Outlet, and Syriana International Food. Schools in this area includes Mary Casey Black Elementary School, Bristow Middle School, Edna Middle School, Independence High School, La Paloma High School, and Liberty High School. Other services such as the United States Postal Service and the Brentwood Police Department are located near the southern portions of Area Two.

The AllTransit Map identified Area Two with a higher connectivity, access to jobs, and frequency of service.

Tri Delta’s transit services serves Area Two with various bus routes. Along Brentwood Boulevard, routes 300X, 383, 384, and 391 connect the area to the rest of the City. Lone Tree Way bisects this area and connects to State Route 4, which connects the City to the County and to the San Francisco Bay Area.

Brentwood 2023-2031 Housing Element
Section 3: Housing Constraints, Resources, and Fair Housing 3-140 AFFH Findings for Area Two:
 An RCAA exists partly within Area Two to the west of the train tracks and north of Central Boulevard.
 Highest percentage of non-white population.
 Most of the City reports the same percentage of population with a disability (10 to 20 percent), but Area Two reports a lower percentage at less than 10 percent.  The affordability index reports a median gross rent ranging from $2,000 to $2,500.  Area Two includes a large portion of land that reports 50 to 75 percent low- and moderate-income population and a smaller are that reports 75 to 100 percent low- and moderate-income population. Of the three areas, this is the only with low- and moderate-income population over 50 percent.
 Increase in median income between 2014 and 2019, except for the area surrounding the Woodgate Mobile Home Park.
 While mostly categorized at Moderate Resource, Area Two is the only portion of the City which contains Low Resource neighborhoods.
 High transit scores
 Low to high CalEnviroScreen pollution burden
 High Healthy Places Index score
 40 to 80 percent overpayment by renters
 One neighborhood with 10 to 20 percent population below poverty level  One neighborhood with 2 to 5 percent households lacking complete plumbing  Sensitive community vulnerable to displacement due to rising property values east of Brentwood Boulevard
In summary, Area Two has the highest percentages of lower income households, non-white population, and low resource neighborhoods. The median income has mostly increased in the area, aside from the Woodgate Mobile Home Park, but the population remains sensitive to displacement.

Access to transit has the highest score in this area, though this is the only area in the City with high pollution burden. The City has identified the lowest amount of lower income units in this area so as not to overburden existing, sensitive populations. However, the City continues to work on improving resources – the 2023/24 to 2027/208 Capital Improvement Program identifies the following completed improvements and future priorities:
 Completed Improvements:
o Sunset Park Playground replacements to meet ADA accessibility guidelines and Consumer Product Safety Commission Guidelines.
 Future Priorities:
o Brentwood Boulevard widening which includes two bike lanes, curb and gutter, medians, sidewalk on the east side, as well as streetlights and landscaping on each side of the roadway. The project is intended to improve safety and traffic flow and facilitate development.
o Downtown Alley Rehabilitation from Midway to Park Way to update and replace aging infrastructure. These upgrades will allow the City to accommodate additional development in the Downtown area. For example, these types of improvements can enhance access and reduce infrastructure need for future developments. o Homecoming Park Playground play equipment replacements. o Lone Tree Way roadway improvements to support a new K-8 school anticipated to open in July 2024.

Brentwood 2023-2031 Housing Element
Section 3: Housing Constraints, Resources, and Fair Housing 3-141 Table 3-49 below shows the breakdown of RHNA by income category. Of the three sites, this area has the least amount of low-income sites and sites overall. All of the candidate sites located in Area Two are classified under a pipeline project. There are a few moderate-income and low-income units. As shown in the AFFH Data Viewer, majority of this area has a median income for households greater than $125,000.

Hence, the sites identified in Area Two have less diversity for lower-income households. Hence, majority of the housing dedicated to Area Two were designated to the above moderate-income group. Three sites were in the northern portions of Area Two where majority of the resources are concentrated. The fourth site was in the southern portion of Area Two where there are multiple parks and in close proximity to various grocery stores. Given the RCAA located within the area, the City will promote affordable ADU development as a method of promoting diversity and housing mobility in areas of opportunity.

Table 3-49: Area Two RHNA
Site Number Map Category Low- Income Moderate- Income Above ModerateIncome Total 20 Pipeline 2 0 75 77
21 Pipeline 0 0 166 166
22 Pipeline 0 0 14 14
23 Pipeline 1 5 45 51
TOTAL 3 5 300 308
AREA 3
Area Three is located in the City’s Southwestern area. The area offers close access to a number of medical and dental offices, an urgent care center, as well as a Walgreens Pharmacy. The R Paul Krey Elementary School and Oak Meadow Park are located just south of the candidate sites, and a Contra Costa County Fire Protection District station is just north of Balfour Road. Just north of the area along Balfour Road are a few dinning and options, gas stations, and a bank.

Public transit is available to the north along Balfour Road. Route 385 connects the sites to the rest of the City. Similarly to the PA-1 area, the three vacant residential parcels are also located along State Route 4 for convenient access to other parts of the region and to the San Francisco Bay Area.

Residential development in Area 3 consists largely of 55 and over communities. The majority of development in the area began in the early 1990’s with the development of the Summerset 55 and older community consisting of over 2,000 single family homes. This was followed by the construction of the Trilogy 55 and over community in 2006 made up of approximately 1,100 single family homes, and more recently the Barcelona 55 and over community of 72 homes in 2018 and Kindred and Balfour 55 and over community in 2020 with 86 single family homes.

AFFH Findings for Area Three:
 One RCAA south of Balfour Road and West of Highway 4.  Lowest percentage of non-white population in the City.  25 to 50 percent population earning a low- to moderate-income; median income in the area mostly increased, except for the area east of Highway 4 which experienced a decrease.  The affordability index reports a median gross rent ranging from $2,500 to $3,000.  Most of the City reports the same percentage of population with a disability (10 to 20 percent), including Area Three.
 TCAC moderate resource scores
 Low and non-existent transit scores
 Low CalEnviroScreen pollution burden

Brentwood 2023-2031 Housing Element
Section 3: Housing Constraints, Resources, and Fair Housing 3-142  High Healthy Places Index score
 40 to 60 percent overpayment by renters
 One neighborhood with 2 to 5 percent households lacking a complete kitchen In summary, Area Three has the lowest percent of lower income households and non-white population; the affordability index reports the highest gross rent range in the City. These factors add up to an RCAA; overpayment by renters is the lowest in this area as well given the higher incomes. As the area has developed through low density subdivisions planned around driving, access to public transportation has the lowest rating – where service is available. In order to improve diversity and create opportunities for lower income households, the City has identified three sites with the capacity to accommodate higher density developments. The City will continue to work with developers in facilitating affordable housing development and with the transit agency to extend services for new developments.

Overall, this area offers less services and resources than the PA-1 Specific Plan area as it is predominantly single-family neighborhoods; however, it provides for a greater variety of housing options at varying costs.

As shown in Table 3-50, the table shows the breakdown of RHNA in Area Three. Of the five sites identified, three of them are categorized under Vacant Residential Sites. Candidate sites 8 through 10 are identified as currently vacant residential parcels and located south of Balfour Road and west of State Route 4. Area Three will also have 68 and 448 moderate-income units. These additional affordable units will assist in promoting diversity to address the existing RCAA. In addition, the City will promote affordable ADU development.

Table 3-50: Area Three RHNA
Site
Number Map Category LowIncome
ModerateIncome
Above
ModerateIncome Total
12 Vacant Residential Sites 29 13 42 84
13 Vacant Residential Sites 60 26 84 170
14 Vacant Residential Sites 67 29 96 192
15 Pipeline 0 0 140 140
19 Pipeline 0 0 86 86
TOTAL 156 68 448 672

Brentwood 2023-2031 Housing Element
Section 4: Housing Plan 4-0
ca
Housing Plan
Section 4

Brentwood 2023-2031 Housing Element
Section 4: Housing Plan 4-1
Section 4: Housing Plan
The Housing Plan described in this Chapter includes the City’s goals, policies, and objectives for the 2023- 2031 planning period. The Housing Plan addresses the need to plan for additional housing opportunities, remove constraints to affordable housing, improve the existing housing stock, and provide equal opportunities for all current and future residents of Brentwood.

These goals, policies, and programs were developed based on:
 Review of the City’s 5th Planning Cycle Housing Element;  Input and feedback from the community, stakeholders, and decision makers;  New State law requirements; and
 Analysis provided in the Community Profile and the Constraints, Resources, and Fair Housing Chapters of this 2023-2031 Housing Element.

Section 4 Contents
A. Goals, Policies, and Actions
H.1 - Housing Goal
Housing Policies
Implementing Actions
H.2 - Affordability Goal
Housing Policies
Implementing Actions
H.3 - Equitable Distribution of Affordable Housing Goal Housing Policies
Implementing Actions
H.4 - Housing Opportunities Goal
Housing Policies
Implementing Actions
B. Summary of Quantified Objectives

Brentwood 2023-2031 Housing Element
Section 4: Housing Plan 4-2
A. Goals, Policies, and Actions
H.1 - Housing Goal
Facilitate a diversity of housing opportunities to enhance the City’s living environment and to satisfy the shelter needs of all Brentwood residents.

Housing Policies
 Policy H.1-1: Encourage adequate residential sites with densities distributed throughout the City for the production of new for-sale and rental residential units, emergency shelters, and transitional and supportive housing sites for existing and future residents.  Policy H.1-2: Endeavor to ensure the supply of safe, decent, and sound housing for all residents.  Policy H.1-3: Provide incentives for water and energy conservation measures in new housing and substantial housing rehabilitation projects.
 Policy H.1-4: Encourage multi-family rental units for Brentwood’s population that include an adequate variety of choices of product types, price, unit sizes, amenities, and location of housing in the community and maintain an adequate supply of rental housing available to very-low-, lowand moderate-income persons. Minimize displacement of tenants, particularly seniors, disabled, and low- and moderate-income residents in rental apartments and encourage ownership of lower-cost residential units by prior renters through the regulation of condominium conversions.

Implementing Actions
Action H.1a: Biennial Evaluation
Conduct a biennial evaluation of the City's inventory of available sites, including very high-density residential sites, and take appropriate action to ensure an ongoing supply of available sites at appropriate densities to meet projected housing needs. This biennial evaluation shall include an assessment of the effect of the City’s midrange density land use policy to ensure that it does not become a barrier or impact the cost to the development of additional housing opportunities and hinder the efficient use of the City’s available vacant residential land supply. The biennial evaluation will also include an evaluation of factors such as built densities, development standards such as parking requirements, processing time, and impacts on approval and development costs. If the evaluation identifies constraints, the City will take action within one year to mitigate its impacts on development. In addition, should the Residential Growth Management Program be reinstated, the City shall evaluate the program for consistency with SB 330 requirements and include an evaluation of any impacts or constraints on the development of housing.

Objectives:
 Maintain adequate residential sites.
 Biennial evaluation of available sites, the City’s midrange density land use policy, and factors such as built densities, processing time, and impacts on approval and development costs. Adopt amendments within one year if constraints are identified.

Timing: Biennial review and evaluation; amendments to occur within one year, if constraints are identified
Responsible Agency: Community Development Department, Planning Commission, City Council Funding Source: General Fund

Brentwood 2023-2031 Housing Element
Section 4: Housing Plan 4-3
Action H.1b: Accessory Dwelling Units
The City is projecting 14 ADUs per year throughout the planning period – this is based on development trends since 2019 and does not exceed the total average. The City shall support and accommodate the development of Accessory Dwelling Units (ADUs) and Junior Accessory Dwelling Units (JADUs) during the 2023-2031 planning period to meet projection figures detailed in Appendix B of this Housing Element.

Objectives:
 Amend the ADU ordinance to comply with State law.
 Implement a permit-ready ADU program (pre-approved ADU plans that do not require additional review).
 Post a user-friendly FAQ on the City’s website to assist the public and advertise ADU resources across online social media platforms.
 Create an expedited plan check review process.
 Research potential State and Regional funding sources for affordable ADUs and make information publicly available.

Timing: Amend the ADU ordinance by January 2025; Implement remaining objectives by January 2026; review ADU development annually; make program changes, if necessary, within six months Responsible Agency: Community Development Department
Funding Source: General Fund
Action H.1c: ADU and JADU Monitoring
The City shall monitor the development of ADU and JADU applications, location, affordability, and other relevant features to ensure adequate ADU development is occurring to meet the City’s 2023-2031 development goals. The City shall evaluate the need to adjust policies and actions if the pace of applications and development is less than anticipated in Appendix B. Should changes need to be made due to a gap in the numbers of ADUs projected and the number of ADUs permitted, the City shall make changes proportional to the gap identified. For example, if actual production and affordability of ADUs is far from anticipated trends, then density or fee incentives for projects incorporating ADUs or something similar would be an appropriate action. If actual production and affordability is near anticipated trends, then measures like outreach and marketing might be more appropriate.

Objectives:
 Create and implement an ADU and JADU monitoring program.  Annually review development trends and make changes proportional to potential gaps as needed – by the midpoint of the planning period, if actual production and affordability of ADUs is not keeping pace with assumed trends in the inventory, the City shall establish a process to provide additional incentives which may include, but are not limited to, density increases, fee incentives, or other strategies for projects incorporating ADUs, or other similar actions. If actual production and affordability is near anticipated trends, then measures like outreach and marketing might be more appropriate.

Timing: Create a monitoring program by January 2025; annually review development trends and by the midpoint of the planning period; make program changes, if necessary, within six months Responsible Agency: Community Development Department
Funding Source: General Fund

Brentwood 2023-2031 Housing Element
Section 4: Housing Plan 4-4
Action H.1d: Monitor At-Risk Projects
Where assisted housing projects are “at risk” of reverting or converting to market rate pricing, develop strategies including potential expenditure of City housing funds to preserve their ongoing affordability.

The City shall identify and implement opportunities to preserve ongoing affordability – such as, but not limited to, financial resources and technical assistance – so that existing affordable units are not at risk of converting to market rate after their restricted affordability term expires. If affordable units will be lost, opportunities to convert existing market-rate units to affordable units shall be investigated by determining whether provision of rehab improvement assistance or purchase of affordability covenants is warranted.

Objectives:
 Monitor units at-risk of converting to market-rate and outreach to property owners to identify resources and programs available to maintain affordability.  Identify and pursue funding opportunities to assist in the preservation of at-risk, affordable units.  Investigate opportunities to convert existing market-rate units to affordable units through rehabilitation improvement assistance.
 Comply with noticing requirements.
 Provide tenant education and assistance through a variety of methods including, but not limited to, informational materials online and in-person at City Hall, annual workshops or informational webinars, and/or partnerships with local organizations and agencies that provide assistance to renters and low-income households.
 Coordinate with qualified entities in identifying solutions to maintaining affordability for units atrisk of converting to market rate.

Timing: Monitor units through the planning period; outreach to property owners by January 2025; investigate opportunities for units at risk of converting to market rate annually; annually identify and pursue funding opportunities; comply with noticing requirements within 3 years, 12 months, and 6 months of the affordability expiration dates; begin coordinating with qualified entities by January 2025 Responsible Agency: Community Development Department
Funding Source: State Funds, County CDBG and HOME Funds, City Housing Fund, and other potential funding sources
Action H.1e: Community Education Regarding the Availability of Rehabilitation Programs Collaborate with the Contra Costa County HOME Consortium and CDBG Urban County to offer educational materials and events for lower-income households, owners, and managers of rental properties, nonEnglish-speaking households, and other special needs groups about available rehabilitation programs and available affordable housing opportunities. Conduct targeted multi-lingual outreach using neighborhood and community organizations, the City and County websites, and various print, broadcast, and online media.

Objectives:
 Collaborate with relevant agencies and organizations to discuss and review available resources.

Agencies and organizations the City currently collaborate and partners with include, but is not limited to, Contra Costa County HOME Consortium, CDBG Urban County, Village Drive Resource Center, ECHO Housing, Inc.
 Continue to host an annual City Council meeting with a CDBG representative to discuss rehabilitation funds for older housing units and programs to assist property owners.  Proactively outreach to households and provide educational opportunities on available programs for special housing needs populations.

Brentwood 2023-2031 Housing Element
Section 4: Housing Plan 4-5
 Maintain informational materials online.
 Seek to assist in rehabilitating 30 housing units through community education and outreach efforts.

Timing: Annually collaborate with agencies and organizations, review informational materials, and conduct outreach; annually review rehabilitated units and resources available Responsible Agency: Community Development Department; Contra Costa County CDBG/HOME Consortium
Funding Source: County CDBG and HOME funds
Action H.1f: Housing Condition Survey
Maintain a current housing condition survey of a representative sample of all housing units within the City. This survey should include the number of units in need of rehabilitation or replacement.

Objectives:
 Conduct a housing condition survey annually and advertise through the utilities bill, newsletters, newspaper, social media, and on the City’s website.
 Update the housing condition survey and annually monitor the number of units in need of rehabilitation. Update the survey every five years.
 Provide information online on resources available to units in need of rehabilitation.  Identify new programs or actions needed to address units in need of rehabilitation depending on the data collected by the survey. This may include allocating additional funding towards assisting homeowners with upgrades, conducting informational workshops on available resources, sending out mailers to households in need of rehabilitation with resources, or other similar actions.

Timing: Update the survey by January 2025; update the survey every following five years; annually conduct the survey and provide information online on resources available Responsible Agency: Community Development Department
Funding Source: General Fund
Action H.1g: Residential Design Guidelines
Continue implementation of the City’s approved Residential Design Guidelines and encourage a variety of housing types to continue to provide safe, sound, and attractive for units all residents. The intent of these guidelines is to express the housing design features the City would like to encourage in order to improve certainty and to minimize the processing time for design review applications. The City will also review the Residential Design Guidelines for subjective language and adopt modifications to promote objectivity – as of January 24, 2023, the City Council has approved to create objective standards for all residential uses by the end of 2023.

Objectives:
 Implement the Residential Design Guidelines.
 Annually meet with housing developers to provide them with information on the Residential Design Guidelines and receive input and feedback. If constraints are identified as part of the feedback received, the City will adopt amendments within 6 months.

Brentwood 2023-2031 Housing Element
Section 4: Housing Plan 4-6
Timing: Annually meet with developers, and adopt amendments within 6 months if feedback is received identifying constraints; amend the Residential Design Guidelines by January 2024; implement the guidelines throughout the 2023-2031 planning period
Responsible Agency: Community Development Department
Funding Source: General Fund, SB 2 Planning and Development Grant Action H.1h: Code Enforcement
Continue to provide both proactive and reactive code enforcement to encourage adherence to and address land use regulations and State and local laws, health and safety concerns, property maintenance, and nuisance conditions.

Objectives:
 Maintain code compliance.
 Assist homeowners in addressing code enforcement violations through technical assistance. The Code Enforcement Division currently mails informational materials to all new homeowners quarterly, and they also attend community events to provide educational materials and speak at HOAs.
 Seek and pursue funding opportunities to provide resources for homeowners.

Timing: Annually review the number and type of code enforcement cases, assist homeowners through technical assistance, and pursue funding opportunities
Responsible Agency: Community Development Department
Funding Source: General Fund
Action H.1i: Water Conservation Program
Continue implementation of the City's Water Conservation Program. The program promotes the use of water conservation devices in existing structures, including use of low-flow toilets and shower heads, and water-conserving landscaping.

Objectives:
 Implement the Water Conservation Program.

Timing: Review effectiveness annually; changes, if necessary, to be made within one year Responsible Agency: Public Works Department
Funding Source: CDBG, Water Enterprise
Action H.1j: Energy Efficient Design
Continue to implement the California Green Building Standards Code (CalGreen), encouraging new development and substantial rehabilitation projects to achieve a greater reduction in efficiency and conservation where feasible. Continue to encourage new development projects to meet LEED standards and apply for LEED certification.

Objectives:
 Implement the California Green Building Standards Code.  Provide information on LEED certification online and outreach to housing developers with informational materials.

Brentwood 2023-2031 Housing Element
Section 4: Housing Plan 4-7
Timing: Review the California Green Building Standards Code for updates every three years; annually outreach to developers with information and maintain updated information online Responsible Agency: Community Development Department
Funding Source: General Fund
Action H.1k: Condominium Conversion
Continue implementation of the City’s adopted condominium conversion ordinance to regulate conversions of multi-family units and to mitigate tenant displacement and minimize displacement of seniors, disabled, and low- and moderate-income residents. Continue monitoring of condominium conversions to insure that a proposed conversion would not result in a disproportionate balance of available rental housing with a variety of choices in tenure, price, unit sizes, amenities, and location in the community. The City did not see any condominium conversions during the 5th cycle.

Objectives:
 Monitor condominium conversions.

Timing: Annually review condominium conversions and adopt ordinance amendments, if necessary Responsible Agency: Community Development Department
Funding Source: General Fund
Action H.1l: Farmworker and Employee Housing
California Health and Safety Code Sections 17021.5 and 17021.6 requires agricultural employee housing for six or fewer persons to be permitted by-right, without a Conditional Use Permit or other discretionary permit that is not likewise required of a family dwelling of the same type in the same zone, in single-family residential zoning districts, and in agricultural zones with no more than 12 units or spaces designed for use by a single family or household or 36 beds in a group quarters. The City shall amend the Zoning Code to comply with these State requirements. The Zoning Code shall also be amended to permit employee housing consisting of no more than 12 units or 36 beds in the same manner as other agricultural uses in the same zone.

Objectives:
 Amend the Zoning Code to comply with State requirements regarding farmworker and employee housing.

Timing: Amend the Zoning Code by January 2025
Responsible Agency: Community Development Department
Funding Source: General Fund
Action H.1m: Senate Bill 35 Streamlining
The City shall establish written procedures to comply with California Government Code Section 65913.4 and publish those procedures for the public, as appropriate, to comply with the requirements of Senate Bill 35 (SB 35), Chapter 366 Statutes 2017. These requirements apply at any point in time when the City does not meet the State mandated requirements, based upon the SB 35 Statewide Determination Summary Report for Housing Element progress and reporting on Regional Housing Needs Assessment (RHNA). The City shall process development projects with at least 50 percent affordable units through a streamlined permit process set forth in State law. All projects covered by SB 35 are still subject to the objective development standards of the Brentwood Municipal Code, including the Building and Fire Codes.

However, qualifying projects cannot be subject to discretionary review or public hearings; and in many

Brentwood 2023-2031 Housing Element
Section 4: Housing Plan 4-8
cases, the City cannot require parking. Reduced parking requirements would be established consistent with the requirements of SB 35 for qualified streamlining projects.

Objectives:
 Establish SB 35 procedures and provide information online.  Develop and implement the program.

Timing: By January 2025
Responsible Agency: Community Development Department
Funding Source: General Fund
Action H.1n: Residential Incentives
The Sites Inventory (Appendix B) identifies sites that allow mixed use development. To encourage residential development on these sites and maximize the development potential identified in the Sites Inventory, the City will promote existing residential incentives and identify potential new incentives as appropriate, including but not limited to, priority processing, granting fee waivers, granting concessions, providing technical assistance, providing funding support, and/or other similar incentives.

Objectives:
 Promote existing incentives and identify potential new incentives for the development of residential uses on sites identified in the Sites Inventory that allow both residential and nonresidential uses.  Establish and implement a residential incentives program to encourage residential development on mixed use sites. Annually promote the program to the development community.

Timing: Annually review and promote residential development incentives; establish and implement a residential incentives program by January 2025 promote the program to the development community annually
Responsible Agency: Community Development Department
Funding Source: General Fund
Action H.1o: Safety Element Update
Senate Bill 1035 (SB 1035), Chapter 733 Statutes 2018 requires that the City revise the Safety Element to identify flood hazards and address the risk of fire hazards in certain lands upon each revision of the Housing Element. The City Council shall adopt amendments to the Safety Element in accordance with the requirements of SB 1035. Objectives:
 Adopt an updated Safety Element, which identifies and addresses flood and fire hazards.

Timing: By January 2025
Responsible Agency: Community Development Department, City Council Funding Source: General Fund
Action H.1p: Replacement Housing
The City may have existing non-vacant sites included within the sites inventory that may contain vacant or demolished residential units that were occupied by lower-income households or households subject to affordability requirements within the last five years. The City will adopt a formal replacement housing program to ensure any units currently occupied by lower-income households, or households subject to affordability requirements within the last five years, that are lost for housing units are replaced in compliance with Government Code Section 66300.

Brentwood 2023-2031 Housing Element
Section 4: Housing Plan 4-9
Objectives:
 Adopt a replacement housing program for units lost that are currently occupied by lower-income households or households subject to affordability requirements of Government Code Section 66300 within the last five years.

Timeframe: Adopt program by January 2025
Responsible Agency: Community Development Department, City Council Funding Source: General Fund
Action H.1q: No Net Loss
Consistent with SB 166 (No Net Loss), the City will monitor housing sites to ensure adequate sites to accommodate the remaining unmet RHNA by each income category are maintained at all times. Reporting is anticipated to coincide with preparation of the Annual Progress Reports. The City will track each site in its inventory and report annually to the City Council on the adequacy of available sites compared to the progress made towards meeting the RHNA.

If residential development is not sufficiently progressing towards building permits or if the City is not meeting the pro-rated share of the RHNA at all income levels by midway through the planning period, the City will evaluate its sites inventory and capacity to maintain adequate sites throughout the planning period and, if necessary, identify strategies to streamline and/or assist projects through entitlement (including, but not limited to, technical assistance, expedited review, and/or support of funding applications), adopt amendments to the ADU development regulations, or implement other strategies, such as General Plan and zoning changes to allow for greater residential densities.

Objectives:
 Monitor housing sites to ensure adequate sites to accommodate the remaining unmet RHNA by each income category.

Timeframe: Annually track status of identified sites and report to City Council (by April 1 of each year) Responsible Agency: Planning Division
Funding Source: General Fund
Action H.1r: Parking Standards for Studios and 1-Bedroom Units The City shall amend its parking standards for multi-family by requiring 1.5 parking spaces per 1-bedroom units and 1 parking space per 0-bedroom units.

The City will also continue to provide parking reductions as needed and for projects that comply with the City’s Affordable Housing Ordinance.

Objectives:
 Adopt Zoning Code updates for multi-family unit parking requirements by requiring 1.5 parking spaces per 1-bedroom units and 0.5 spaces per 0-bedroom units.

Timeframe: Adopt the Zoning Code updates by January 2025 Responsible Agency: Planning Division
Funding Source: General Fund
Action H.1s: CUP and Design and Site Development Review Findings As part of the Zoning Code Update, the City shall amend approval findings for CUP and Design and Site Development Review applications to replace subjective language with objective standards.

Brentwood 2023-2031 Housing Element
Section 4: Housing Plan 4-10
Objectives:
 Adopt Zoning Code updates removing subjectivity in application findings for CUPs and Design and Site Development Reviews.

Timeframe: Adopt the Zoning Code updates by January 2025 Responsible Agency: Planning Division
Funding Source: General Fund
Action H.1t: Mid-Point Policy
The City shall remove its mid-point policy to remove any added discretion or constraints, such as requiring the exercise of transferable agricultural credits, significant added amenities, extensive off-site public improvements, or other significant improvements for projects requesting densities above the mid-point for all residential land use categories.

Objectives:
 Adopt Zoning Code/General Plan updates removing discretion or constraints, such as requiring the exercise of transferable agricultural credits, significant added amenities, extensive off-site public improvements, or other significant improvements for projects requesting densities above the mid-point for all residential land use categories.

Timeframe: Adopt the Zoning Code/General Plan updates by January 2025 Responsible Agency: Planning Division
Funding Source: General Fund

Brentwood 2023-2031 Housing Element
Section 4: Housing Plan 4-11
H.2 - Affordability Goal
Encourage housing that is affordable to all socio-economic segments of Brentwood’s population.

Housing Policies
 Policy H.2-1: Encourage housing affordable and appropriate for a variety of Brentwood households at all economic levels throughout the City.
 Policy H.2-2: Support the use of available local, County, State, and Federal housing assistance programs.
 Policy H.2-3: Assist and cooperate with non-profit, private, and public entities to maximize opportunities to develop and preserve affordable housing.  Policy H.2-4: Review and modify, when necessary, all standards and application processes to ensure that none act to constrain the production of affordable units.

Implementing Actions
Action H.2a: Compliance with Affordable Housing Ordinance All new residential projects shall provide affordable housing units in accordance with the City’s adopted Affordable Housing Ordinance Chapter 17.725. The City will continue to review and monitor the ongoing effectiveness of the City’s affordable housing ordinance to ensure developers provide a certain percentage of new homes to qualifying households at an affordable cost for the longest feasible time. The ordinance shall also continue to include a list of automatically available development incentives to encourage the construction of the inclusionary units, as well as provide the details for available alternatives to satisfy inclusionary housing obligations.

In 2022, the City approved an amendment to the Ordinance requiring multi-family developments to construct the required affordable units, instead of paying in-lieu fees, if the project proposes nine or more units. The City will continue to enforce this new requirement.

Objectives:
 Annually monitor development of affordable housing units and adjust ordinance as needed.  Provide information on the Affordable Housing Ordinance online and annually outreach to housing developers to provide information on the Ordinance.

Timing: Annually monitor affordable housing production and provide information to housing developers
Responsible Agency: Community Development Department
Funding Source: City Housing Fund
Action H.2b: Additional Development Incentives for Affordable Housing Use voluntary incentives to encourage the production of affordable housing, particularly housing affordable to extremely low-, very low-, and low-income groups, and provide incentives for the production of affordable housing where appropriate. Examples of such additional incentives include, but are not limited to, the following:

Brentwood 2023-2031 Housing Element
Section 4: Housing Plan 4-12
 Fast track processing. By expediting the development review process, carrying costs for lands being developed with affordable housing can be minimized.  Fee Deferrals. Continue the provision of financial assistance for projects ensuring the long-term affordability of housing for very low- and low-income households through the use of additional fee deferrals of development processing and development impact fees until issuance of final inspection or 12 months from the date of deferral, whichever occurs first, or other similar incentives, so as to ensure the project’s economic feasibility.  Flexible Development Standards. Modification of the City’s standards or approval of design modifications that increase the flexibility of the construction of affordable units for the necessary financial or other feasibility of the affordable housing development. Such modifications may include reduced lot sizes, home sizes, setback requirements, interior amenities, open space, and landscaping requirements.
 Direct Financial Assistance. Establish procedures, by January 2025, for the provision of direct financial assistance, if available, in the form of a loan or grant from the City housing funds for development of ownership and/or rental units affordable to lower income households in accordance with the City’s affordable housing ordinance. Seek and pursue funding opportunities to enable the provision of financial assistance for the development of affordable units.  Additional Concessions and Incentives. On a case-by-case basis, implement the provision of additional concessions or incentives consistent with State law and Brentwood’s Housing Element for affordable units that exceed the requirements of the City’s affordable housing ordinance.

Objectives:
 Provide incentives to affordable housing projects to encourage development of units.

Timing: Annually review incentives and effectiveness of the program; if necessary, changes to be made within one year; Establish direct financial assistance procedures by January 2025 and pursue funding annually
Responsible Agency: Community Development Department
Funding Source: City Housing Fund, and other potential funding sources Action H.2c: First-Time Homebuyer Assistance Program
The City shall continue providing first-time homebuyer assistance services, either directly or through the Contra Costa Urban County and/or HOME Consortium, to lower income Brentwood residents to facilitate homeownership. This may include educational materials, referral information to existing programs, and/or down payment assistance depending upon available City financial resources.

Objectives:
 Provide informational materials on the First-Time Homebuyer Assistance Program online and outreach to the community.
 Annually host an in-person First-Time Homebuyer workshop with approved lenders, community groups, credit counseling, and other relevant groups/organizations to provide assistance to potential homebuyers.
 Assist 20 households in accessing First-Time Homebuyer assistance during the planning period.

Timing: Annually review households assisted and outreach conducted; annually host workshops Responsible Agency: Community Development Department
Funding Source: City Housing Fund/County CDBG and HOME Funds

Brentwood 2023-2031 Housing Element
Section 4: Housing Plan 4-13
Action H.2d: Affordable Housing Assistance
Review the variety of potential financial assistance programs from both the public and private sectors to provide more affordable housing units. All available local, State, Federal, and private affordable housing programs for new housing and for the conservation and/or rehabilitation of existing housing will be identified for pursuit. City housing funds and other potential funding sources shall be leveraged to the greatest extent possible to create and preserve housing affordable to Brentwood’s workforce by encouraging developers to layer available public housing funds.

Objectives:
 Annually identify, pursue, and make affordable housing development funds available for affordable housing projects.
 At the time an application is submitted for affordable housing, the City shall review available funding sources and programs to determine if there are funds available for the project to claim.  Provide technical assistance for developers to access financial assistance and funding sources.  Coordinate with other public agencies to access resources and pursue funding opportunities.  Utilize the Senior Analyst that manages affordable programs to be the point-of-contact for developers seeking information and assistance, as well as to identify and pursue funding opportunities.
 Through these resources and assistance, aim to facilitate the development of 50 extremely low-, 50 very low-, and 50 low-income units during the planning period.

Timing: Annual coordination with public agencies; review programs on a case-by-case basis; review affordable units annually; annually identify and pursue funding opportunities Responsible Agency: Community Development Department
Funding Source: Private resources, County CDBG and HOME Funds, Federal and State funds, City Housing Fund, and other potential funding sources
Action H.2e: Partnership Program
When non-profit, private, and other public entities indicate interest in the development of affordable housing, the City will initiate a first meeting and subsequent follow-up contact to examine opportunities for cooperative efforts to expand the City’s supply of affordable housing. In addition to coordinating with interested entities, the City will proactively conduct outreach efforts to market available incentives and opportunities. Outreach may include, but is not limited to, email blasts, meetings, and phone calls with developers; website notices; social media posts; and other similar actions.

Objectives:
 Meet with developers and outside agencies when interest is expressed and follow up annually.  Outreach to local and regional nonprofits and other entities engaged in building affordable housing to identify partnership opportunities.
 Host builder and developer roundtable meetings to identify opportunities and market available incentives and resources.
 Proactively market candidate sites and incentives to the development community to build relationships and interest.

Brentwood 2023-2031 Housing Element
Section 4: Housing Plan 4-14
Timing: Meet with developers and agencies on a case-by-case basis based on interest and annually follow-up; annually conduct proactive outreach to nonprofits and other entities to identify partnership opportunities; annually host a building and developer roundtable meeting; annually proactively market candidate sites and incentives to the developer community Responsible Agency: Community Development Department
Funding Source: Private resources, County HOME and CDBG Funds, Federal and State funds, City Housing Fund, and other potential funding sources
Action H.2f: Support Housing Sponsors
Support non-profit and for-profit corporations in their efforts to make housing more affordable to lowerand moderate-income households. These efforts include, but are not limited to, written support letters for grant applications, identifying available sites for housing development (see related efforts in Program H.2e), City involvement in the development of such sites, and City financial support and contact of housing sponsors on an annual basis. This also includes collaborating with non-profit organizations or affordable housing developers in developing City-owned parcels with affordable housing units.

Objectives:
 Contact interested housing sponsors on an annual basis.  Establish and implement a housing sponsors program aimed at supporting the development of affordable units though the following actions such as, but not limited to, support of grant applications, identifying available sites for housing development, City involvement in the development of such sites, and City financial support and contact of housing sponsors.  Aim to facilitate the development of 50 affordable units from local partnerships and the housing sponsors program.

Timing: Annually outreach and review affordable housing units; biennially review efforts and make changes, if necessary; Establish the housing sponsors program by January 2024 Responsible Agency: Community Development Department
Funding Source: Private resources, HOME Funds, CDBG Funds, Federal and State Funds, City Housing Fund, and other potential funding sources
Action H.2g: Streamline Application Process
Continue efforts to streamline and improve the development review process, as well as eliminate any unnecessary delays and restrictions in the processing of development applications.

Objectives:
 Biennially review development review processes and meet with developers to identify potential constraint to the development of housing. If constraints are identified as part of the feedback received, the City will adopt amendments within 6 months.

Timing: Biennially meet with developers and review processes, and adopt amendments within 6 months if feedback is received identifying constraints
Responsible Agency: Community Development Department
Funding Source: General Fund

Brentwood 2023-2031 Housing Element
Section 4: Housing Plan 4-15
Action H.2h: Land Acquisition
The City shall identify opportunities to acquire appropriately located and residentially zoned land for the purpose of partnering with profit and non-profit developers to construct new affordable housing.

Objectives:
 Identify potential residential land for affordable housing, to the extent that financial and staff resources are available to proceed with purchase of land.  Pursue funding opportunities for the acquisition of land for the purpose of partnering with organizations and developers to develop affordable housing.

Timing: Annually; 2023-2031
Responsible Agency: Community Development Department, City Council Funding Source: City Housing Fund and other potential funding sources Action H.2i: Density Bonus Ordinance
Assembly Bill 2345 (AB 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. Among other things, Government Code Section 65915 also 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 development in which the units are for sale;
 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 development in which the units are for sale; and
 Four incentives or concessions for projects that meet additional State law requirements The City shall update its Density Bonus Ordinance to comply with State law requirements.

Objectives:
 Update the Density Bonus Ordinance in compliance with State law requirements. As of February 2023, the City Council has authorized Staff to move forward with a focused update of the Zoning Ordinance, including the Density Bonus Ordinance, and is anticipated to be completed by mid2024.

Timing: By December 2024; review annually and update as necessary; 2023-2031 Responsible Agency: Community Development Department
Funding Source: General Fund
Action H.2j: Priority Building Inspections for Affordable Housing Projects The City will give priority to low- and very low-income housing projects for building inspections carried out during various stages of the construction process.

Objectives:
 Provide priority building inspections to housing projects with lower-income units.

Timing: On a case-by-case basis; 2023-2031
Responsible Agency: Community Development Department
Funding Source: General Fund

Brentwood 2023-2031 Housing Element
Section 4: Housing Plan 4-16
Action H.2k: Support Flexibility for Certain Residential Development Standards The City has adopted development standards for all residential zoning designations and, as of February 2023, has begun the process of drafting objective development standards. However, applicants may elect to propose their own development standards through the rezoning and planned development amendment processes. The City shall provide the guidance and direction to foster context sensitive development that enhances the community while providing greater flexibility to encourage future development.

Objectives:
 Provide information online on programs available for projects proposing affordable housing units and collaborate with developers on potential opportunities for flexible development standards on certain vacant lots.
 Adopt objective development standards and conduct community and developer outreach as part of the process. This outreach may include, but is not limited to, workshop, meetings, informational handouts, e-blasts, newsletters, and phone calls.

Timing: Annually review affordable housing unit development; collaborate with developers on a caseby-case basis; Adopt objective development standards by January 2024 Responsible Agency: Community Development Department
Funding Source: General Fund
Action H.2l: Development Fees
The City shall monitor required development fees including in-lieu fees, development impact fees, and processing fees, with the aim of reducing constraints on the development of affordable residential projects, including, but not limited to, senior housing, housing for farmworkers, emergency/transitional housing, housing for persons with disabilities (including developmental), single room occupancies, and accessory dwelling units. To respond to changing local market conditions during the planning period, the City shall revise required development fees, if it is deemed appropriate.

Where fees are established and administered by regional agencies, such as the Regional Transportation Development Impact Fee, the City shall request the administering agency to review and reduce fees if the City has determined that the agency’s fee is constraining residential development, particularly development of affordable housing and/or housing for special needs groups.

Objectives:
 Address potential constraints to affordable housing as it relates to development fees.  Conduct a Community Development comprehensive fee update.

Timing: Annually monitor and review development fees; if changes are deemed necessary, amend fee schedules or collaborate with external agencies to amend fee schedules within one year; Conduct a Community Development comprehensive fee update for Fiscal Year 2024-2026 Responsible Agency: Community Development Department
Funding Source: General Fund

Brentwood 2023-2031 Housing Element
Section 4: Housing Plan 4-17
Action H.2m: Water and Sewer Priority
Following adoption of the Housing Element, the City shall provide the water and sewer providers with a copy of the Housing Element. The copy of the Housing Element will be accompanied by a letter identifying the City’s 2023-2031 RHNA allocation for lower- income units and will refer the water and sewer providers to the requirements of State law set forth at Government Code Section 65589.7 regarding the granting of a priority for provision of water and sewer services to proposed developments that include housing units affordable to lower-income households.

Objectives:
 Comply with requirements of State law associated with provision of Housing Element to water and sewer providers.

Timing: Upon adoption of the 2023-2031 Housing Element, and immediately following the adoption of subsequent amendments to the Housing Element
Responsible Agency: Community Development Department
Funding Source: General Fund
Action H.2n: Affordability Monitoring
Continue to require affordable housing projects that receive City assistance to enter into an affordable housing agreement with the City that includes provisions to ensure initial and continuing affordability – this is required per Ordinance. For rental projects, the affordable housing agreement shall include provisions requiring annual monitoring to ensure that the affordable units are assisting income-eligible households. For for-sale projects, the affordable housing agreement shall include sale and resale provisions that ensure the execution and recordation of deed restrictions to ensure continued affordability for the term of the affordable housing agreement.

Objectives:
 Monitor affordable housing projects that receive City assistance.  Per City Ordinance, continue to require affordable housing projects that receive City assistance to enter into an affordable housing agreement with the City that includes provisions to ensure initial and continuing affordability.

Timing: Monitor existing and proposed affordable housing projects on a project-by-project basis; 2023- 2031
Responsible Agency: Community Development Department
Funding Source: General Fund
Action H.2o: By-Right Development of 5th and 4th Cycle Sites Pursuant to Government Code section 65583.2(c), adopt amendments to the Zoning Code to allow byright development for projects proposing 20 percent or more of the total units as affordable to lower income households if the site is non-vacant and previously identified with the same zoning in the 5th Cycle Housing Element or if the site is vacant and previously identified with the same zoning in the 5th and 4th Cycle Housing Elements.

Objectives:
 Allow by-right development for qualifying sites pursuant to Government Code section 65583.2(c).

Timeframe: Adopt amendments by January 2025
Responsible Agency: Community Development Department
Funding Source: General Fund

Brentwood 2023-2031 Housing Element
Section 4: Housing Plan 4-18
Action H.2o: Monitor Effects of Regional Fees
Like other jurisdictions in the county, Brentwood is subject to regional transportation impact fees levied by Contra Costa County. The City shall monitor the effects of these fees on housing costs and production and continue to work with the East Contra Costa County Regional Fee and Financing Authority (ECCCRFFA), a Joint Powers Authority (JPA) that levies the fee and operates through the TRANSPLAN Committee, to ensure that the fees are equitable and appropriately applied and adjusted. The City shall also support, and work with the ECCCRFFA to pursue, a fee reduction or exemption for high-density housing near transit, and affordable housing developments, as feasible.

Objectives:
 Continue to appoint one City Council Member and one Planning Commissioner to represent the City of Brentwood on the ECCCRFFA.
 Continue to participate in regular meetings of the JPA, and work with the other members of the ECCRFFA to pursue and support reductions to the regional fee for higher-density residential uses near major transit stops and affordable housing developments.

Timeframe: Periodically and throughout the planning period, as fees are reevaluated Responsible Agency: City Council and Planning Commission Funding Source: General Fund

Brentwood 2023-2031 Housing Element
Section 4: Housing Plan 4-19
H.3 - Equitable Distribution of Affordable Housing Goal Encourage an equitable distribution of housing for all economic groups throughout the community.

Housing Policies
 Policy H.3-1: Facilitate the integration of new lower income households into the fabric of the community, avoiding, where feasible, identifying housing developments or portions of a development as being restricted to very low-, low-, or moderate-income households.  Policy H.3-2: Facilitate infill and new residential projects within all areas of the City as a means of making each neighborhood more attractive for all types of housing units thereby encouraging future private economic investment in the community.
 Policy H.3-3: Maintain an inventory of lands that equitably distributes, through General Plan land use designations and zoning, low-, medium-, high-, and very high-density residential development throughout the community.

Implementing Actions
Action H.3a: Affordable Housing Design and Distribution All affordable units within a mixed-income subdivision shall be harmonious and comparable to the market-rate units in exterior design, quality of materials and architectural elements, and overall construction quality. Affordable units may have different interior amenities and/or slightly different dimensions than market rate units in a residential development. Affordable units in a mixed-income development shall be dispersed throughout the residential development so as to prevent the concentration of affordable units.

Objectives:
 Monitor affordable housing design and distribution requirements and make information on requirements available to developers and the community online.  Adopt revisions to mixed-use design requirements following the adoption of the objective development standards.

Timing: Monitor requirements as projects are proposed; provide informational materials online by January 2025; review and update, if necessary, on a biennial basis; Adopt revisions following the adoption of the objective development standards
Responsible Agency: Community Development Department
Funding Source: General Fund
Action H.3b: Community Education
Continue to educate the community about annual incomes for typical occupations and the equivalent “buying power” of these incomes in today’s housing market. As part of this program, ensure that the community is aware of the income ranges of very low-, low-, and moderate-incomes, and of the typical occupations that fall into these categories.

Objectives:
 Maintain informational materials online.

Brentwood 2023-2031 Housing Element
Section 4: Housing Plan 4-20
 Annually host events/workshops to inform the community of affordable housing programs and provide informational sessions on the housing market, density examples, and community need.  Annually create and advertise informational materials related to housing such as, but not limited to, the housing market, resources available to the community, development projects, what different densities look like, FAQ on affordable units, and the inclusionary ordinance.

Timing: Update materials by January 2025; review and update, if necessary, on a biennial basis; host community events annually; Create and advertise informational materials annually Responsible Agency: Community Development Department
Funding Source: General Fund, City Housing Fund
Action H.3c: Development Incentives
Maintain the existing package of incentives to facilitate development of housing intended for extremely low-, very low-, low-, and moderate-income households in a manner which does not distinguish such “affordable” housing from “market rate” housing in the same area. Provide package to housing developers and interested parties at meetings and on the City’s website.

Objectives:
 Provide a package to relevant entities and online summarizing available incentives for the development of units affordable to lower- and moderate-income households.  Biennial review of the incentive package with the development community to receive feedback on the efficacy of the incentives. Within one year of receiving feedback, identify if changes to the package are necessary to further incentivize affordable development.

Timing: Update materials by January 2024; review and update, if necessary, on a biennial basis Responsible Agency: Community Development Department, Planning Commission, City Council Funding Source: General Fund
Action H.3d: Marketing Materials
Prepare marketing materials to be provided to the building industry, outlining opportunities for the development of housing projects. The City shall provide materials to housing developers and interested parties at meetings and on the City’s website.

Objectives:
 Provide marketing materials to affordable housing developers and include an inventory of sites and information regarding housing needs (also see similar actions in Action H.2e and H.2f).

Timing: Update materials by January 2024; review and update on a biennial basis Responsible Agency: Community Development Department
Funding Source: General Fund, City Housing Fund, and other potential funding sources Action H.3e: Meet with Potential Developers
As infill sites become available on the open market, the City shall actively seek out potential developers as a means of generating interest on their part to undertake residential projects.

Objectives:
 Outreach to developers with potential residential development opportunities.

Brentwood 2023-2031 Housing Element
Section 4: Housing Plan 4-21
Timing: Annually outreach to developers; annual review of developer interest and outreach methods Responsible Agency: Community Development Department
Funding Source: General Fund, City Housing Fund, and other potential funding sources Action H.3f: Housing for Extremely Low-, Very Low-, and Low-Income Residents Assist developers in accessing City, County CDBG and HOME Funds, Federal, and State housing development programs and funds to undertake development of housing projects for extremely low-, very low-, and low-income households.

Objectives:
 Meet with housing developers to discuss available programs and funding sources to develop lower-income housing units.
 Provide technical assistance to affordable housing developers in the form of one-on-one meetings to review applications and potential projects with affordable housing staff, share financing and funding resources, connect potential applications to other agencies or organizations with additional resources and assistance.
 Provide written support letters for funding applications from affordable housing developers.

Timing: Annually meet with developers; annually provide technical assistance and support funding applications
Responsible Agency: Community Development Department
Funding Source: CDBG, HOME, City Housing Fund, Federal and State funds, and other potential funding sources
Action H.3g: Improve Participation in Existing Local Housing Assistance Provide access to available housing assistance programs for Brentwood residents through improved marketing and outreach efforts including providing information at annual forums, scheduling appointments with County housing program specialists in Brentwood, providing multilingual brochures, and posting housing program information on the City’s website.

Objectives:
 Conduct multilingual outreach to the community with available housing assistance programs.

Timing: Annually conduct multilingual outreach; Annually review effectiveness of the program to determine if adjustments need to be made regarding outreach methods; if changes are deemed necessary, implement within six months
Responsible Agency: Community Development Department
Funding Source: City Housing Fund and other potential funding sources

Brentwood 2023-2031 Housing Element
Section 4: Housing Plan 4-22
H.4 - Housing Opportunities Goal
Promote equal housing opportunities for all residents of Brentwood.

Housing Policies
 Policy H.4-1: Encourage and support the enforcement of laws and regulations prohibiting discrimination in lending practices and in the sale or rental of housing.  Policy H.4-2: Facilitate the provision of housing opportunities for those residents of the City who have special housing needs including farmworkers, the elderly, disabled, developmentally disabled, large families, and the homeless.

Implementing Actions
Action H.4a: Affirmatively Further Fair Housing
Pursuant to Assembly Bill 686 (AB 686), Chapter 958 Statutes 2018, the City shall affirmatively further fair housing by taking meaningful actions that foster inclusive communities free from barriers that restrict access to opportunities based on protected characteristics, as defined by State law. The City shall collaborate with the community, stakeholders, and appropriate organizations and agencies to address potential constraints to fair housing. This may include, but is not limited to:
 Analyzing and identifying barriers to entry into homeownership or rental opportunities;  Reviewing restrictions that may prevent disadvantaged groups from locating in Brentwood;  Fostering a more inclusive community for all disadvantaged groups.

In addition, the City has identified factors contributing to fair housing issues in Section 3.E.2. These factors include: displacement of residents due to economic pressures, availability of affordable housing, and environmental justice discrepancy. The City will take the following actions to address each contributing factor.

Action H.4a – Contributing Factors and Actions
Contributing
Factor Meaningful Action Geographic Target1
Priority and
Timeline
Housing Mobility
Availability of
Affordable
Housing
Conduct landlord outreach to expand the
location of participating voucher
properties.

Metric: Identify 5 additional properties
throughout the planning period to
participate in the voucher program.

Area 1 and 3 Low
Annually conduct
outreach. MidCycle review of
progress; if
changes are
deemed necessary,
implement within
one year.

Annually host an educational workshop on
voucher programs and source of income
discrimination.

Metric: Aim to engage a minimum of 15
individuals (renters and landlords) per
workshop.

City-wide Low
Annually

Brentwood 2023-2031 Housing Element
Section 4: Housing Plan 4-23
Action H.4a – Contributing Factors and Actions
Contributing
Factor Meaningful Action Geographic Target1
Priority and
Timeline
Work with and incentivize developers to
develop four or more units in a building
when possible and identify opportunities
for more units or lot consolidations.

Incentives may include, but are not limited
to, technical assistance, development
standards flexibility, and/or reduced fees.

Metric: Work with developers to maximize
potential units per site, including building
affordable units. (Note: per the 2022
Inclusionary Ordinance update, projects
over nine units cannot pay in-lieu fees and
must build the affordable units).

Area 1 and 3 Low
Annually
coordinate with
housing developers
and provide
assistance on a
case-by-case basis.

Facilitate collaboration between local
governments and community land trusts
through annual meetings as a mechanism
to develop affordable housing in higheropportunity areas, as well as work with local agencies and departments in
improving TCAC opportunity ratings in
areas of need.

Metric: Facilitate the development of 100
affordable units within relatively higheropportunity areas.

City-Wide, with
a focus on
improving
opportunity
scores in Area 2
Moderate
Maintain and
update candidate
sites list and
annually provide
opportunities to
relevant agencies
and organizations.

Offer collaboration
and assistance.

Housing Choices and Affordability in Areas of Opportunity Environmental
Justice
Discrepancy
Review and implement changes in the
zoning code and standards, permit
streamlining, fees, incentives and other
approaches to increase housing choices
and affordability (e.g., duplex, triplex,
multifamily, ADU, transitional and
supportive housing, group homes) in higher
opportunity areas, as well as improve
opportunity ratings in areas of need.

Metric: Facilitate the development of 100
affordable units within relatively higheropportunity areas.

Area 1 and Area
3, relatively
higher income
areas including
RCAA
neighborhoods.

High
By January 2025
establish an
incentive plan and
begin
implementation in
2026. Conduct a
Mid-Cycle review;
if changes are
deemed necessary,
implement within
one year.

See Action H.1q:

No Net Loss for
additional actions.

Availability of
Affordable
Housing
Continue to implement inclusionary zoning
regulations and promote the creation of
affordable units over the payment of in-lieu
fees.

City-wide High
On a project-byproject basis

Brentwood 2023-2031 Housing Element
Section 4: Housing Plan 4-24
Action H.4a – Contributing Factors and Actions
Contributing
Factor Meaningful Action Geographic Target1
Priority and
Timeline
Metric: Aim for 75 percent of projects
subject to inclusionary requirements
building affordable units instead of using
alternative methods of meeting the
requirements, such as in-lieu fees.

Assist with the construction of affordable
housing for special housing needs
population, including, but not limited to,
providing technical assistance, streamlined
review, reduced development fees.

Metric: Aim to facilitate the construction of
100 units for special needs populations
City-wide, with
a focus on areas
in close
proximity to
community
resources
Moderate
Throughout the
planning period
Racially
Concentrated
Areas of
Affluence
Affirmative marketing to promote equal
access to government-assisted housing and
to promote housing opportunities
throughout that City and within RCAAs.

This may include, but is not limited to,
noticing of affordable units/projects
through direct mail targeted outreach to
lower income census tracts; publishing
advertising materials in multiple languages,
informing service agencies, and outreach to
community organizations and places of
worship.

Metric: Conduct affirmative marketing for
each new housing development which
includes affordable units.

City-wide, with
a focus on
RCAAs/ Area 3
Moderate
On a project-byproject basis
Facilitate the development of 112 ADUs
through Action H.1b. and promote ADU
development in areas of opportunity and
RCAAs.

Metric: Facilitate the construction of 112
ADUs with 66 affordable to lower income
households and 34 affordable to moderate
income households.

City-wide, with
a focus on
RCAAs/ Area 3
Moderate
Throughout the
planning period.

See Action H.1c for
monitoring and
planning mid pint
review timeframes.

Review future policies and programs for
potentially restrictive practices that would
limit diversity in RCAAs.

Metric: As long-range plans are updated, or
as policies and programs are proposed,
review language for potentially restrictive
practices that would limit diversity with
RCAAs.

RCAAs/ Area 3 Low
As long-range plans
are updated, or as
new policies and
programs are
proposed
Establish specific incentives for the
development of affordable units the RCAAs
RCAAs/ Area 3 Moderate

Brentwood 2023-2031 Housing Element
Section 4: Housing Plan 4-25
Action H.4a – Contributing Factors and Actions
Contributing
Factor Meaningful Action Geographic Target1
Priority and
Timeline
and high opportunity areas, including, but
not limited to, permit streamlining and
reduced fees. For example, the City has
identified 3 candidate sites in this area for a
total of 156 LI units. Incentives could be
specific to these sites or other sites that
allow high-density housing and may
include, but are not limited to, reduced
fees, technical assistance, and support to
funding applications.

Metric: Aim to facilitate the construction of
75 affordable units within RCAAs.

Throughout the
planning period
Community Conservation and Revitalization
Environmental
Justice
Discrepancy
Research and establish targeted
investments in areas of most need focused
on improving community assets such as
schools, recreational facilities and
programs, social service programs, parks,
streets, active transportation and
infrastructure.

Metric: Complete at least 4 targeted
investments, totaling approximately $30
million, aimed at improving TCAC
Opportunity scores for census tract 31.03
(Area 2).

Area 2 High
Begin
implementation by
January 2026.

Create a plan for
targeted
investments by
January 2025.

Develop a proactive code enforcement
program that targets areas of concentrated
rehabilitation needs, results in repairs and
mitigates potential cost, displacement and
relocation impacts on residents. Identify
target areas through annual windshield
surveys and neighborhood visits. Program
will be paired with additional information
on funding and resources to the City and/or
County’s housing home repair or rehab
programs.

Metric: Identify areas of need and establish
targeted investments and programs to
address rehabilitation need.

City-wide –
specific target
areas will be
identified
annually and
may be subject
to change based
on the review
with a focus on
Area 2
High
Develop by January
2026. Implement
annually and
throughout the
planning period.

Complete the first phase of Brentwood
Boulevard widening to improve safety,
traffic flow, and facilitate development.

Brentwood
Boulevard
High
By June 2026
Complete the Downtown Alley
Rehabilitation from Midway to Park Way to
accommodate additional development in
Downtown Alley
from Midway to
Park Way
High
By January 2025

Brentwood 2023-2031 Housing Element
Section 4: Housing Plan 4-26
Action H.4a – Contributing Factors and Actions
Contributing
Factor Meaningful Action Geographic Target1
Priority and
Timeline
the Downtown, enhance access, and
reduce infrastructure need for future
developments.

Complete the Homecoming Park
Playground play equipment replacements.

Homecoming
Park
High
By January 2025
Complete the Lone Tree Way roadway
improvements to support a new K-8 school
anticipated to open in July 2024.

Lone Tree Way
roadway
High
By January 2025
Housing for
Special Needs
Populations
Create and promote informational
materials on housing accessibility,
rehabilitation, and maintenance resources.

Metric: Aim to assist 10 households with
accessibility, rehabilitation, and
maintenance needs.

City-wide, with
a focus on Areas
1 and 2
Moderate
Develop materials
by January 2025
and advertise
annually
throughout the
planning period
Annually host a workshop with relevant
community organizations and groups to
discuss the needs of persons with
disabilities and identify whether additional
resources and development concessions
are needed. If necessary changes are
identified, adopt amendments within 6
months.

Metric: Aim to a engage a minimum of 15
individuals and organizations per
workshop.

City-wide Moderate
Throughout the
planning period
Extend search times for particular groups
with housing choice vouchers, such as
larger families with children, persons with
disabilities, or seniors.

Metric: Extend search times for special
needs populations
City-wide High
By January 2026
Protection from Displacement
Displacement
from
Economic
Pressures
Maintain multi-lingual informational
materials on tenant legal counseling and
resources and provide materials annually to
local organizations that serve non-English
speakers.

Metric: Aim to protect a minimum of 10
households from displacement through
tenant resources throughout the planning
cycle.

City-wide with a
focus on Area 2
High
Create materials by
August 2024;
update as
necessary.

Distribute
materials annually.

Create and promote informational
materials on the location of participating
City-wide Low
Publish materials
by January 2026

Brentwood 2023-2031 Housing Element
Section 4: Housing Plan 4-27
Action H.4a – Contributing Factors and Actions
Contributing
Factor Meaningful Action Geographic Target1
Priority and
Timeline
voucher properties and availability of
voucher programs/financial assistance.

Metric: Publish materials and update as
necessary
and update as
necessary

1. See Figure 3-55, in Section 3 of this Housing Element, for an outline of the geographic areas.

Timing: 2023-2031; annually review each actions individual timeline and make changes as necessary Responsible Agency: Community Development Department
Funding Source: Private Resources, Federal and State funds, CDBG, HOME, City Housing Fund, and other potential funding sources
Action H.4b: Cooperative Association with Non-Profits
Continue to refer cases and questions to Bay Area Legal Aid, Housing Rights Inc., Shelter, Inc., and Pacific Community Services for assistance.

Objectives:
 Maintain information online on non-profits that provide fair housing assistance and services and, on a need basis, refer cases and questions to said non-profits.

Timing: On a case-by-case basis; review information available online annually Responsible Agency: Community Development Department
Funding Source: City Housing Fund
Action H.4c: Disseminate Fair Housing Information
The City shall disseminate fair housing information widely in the community in multiple languages. This effort shall include providing information to local apartment managers and realtors involved in residential rental real estate transactions, providing information at the Brentwood public library, at City Hall, at the Brentwood Community Center and Senior Center, at the Police Department, and at social service offices in Brentwood, on a space-available basis, serving special needs groups including lower-income households.

Objectives:
 Disseminate fair housing information annually throughout the community and annually meet with local organizations and agencies to provide information on available resources.

Timing: Review annually; meet with organizations and agencies annually Responsible Agency: Community Development Department
Funding Source: City Housing Fund
Action H.4d: Foreclosure Prevention and Loan Modification Information The City shall continue to provide foreclosure prevention and loan modification information on its website, sponsor workshops for the community, and refer owners to non-profit counseling and service providers for legal, credit, foreclosure, and loan modification counseling.

Objectives:
 Maintain information online on resource for foreclosure prevention and loan modification.

Brentwood 2023-2031 Housing Element
Section 4: Housing Plan 4-28
Timing: Review annually; annually collaborate with local organizations and agencies on available resources
Responsible Agency: Community Development Department
Funding Source: City Housing Fund
Action H.4e: Housing Opportunities for Special Needs Groups Encourage housing opportunities to meet the special housing needs of farmworkers, elderly, disabled, developmentally disabled, large families, female-headed households, and persons experiencing homelessness. Encourage affordable housing developers to provide units for special needs persons or households, when feasible and appropriate.

Objectives:
 Facilitate the construction of 50 special needs units (farmworker, affordable senior, disabled, developmentally disabled, large households, female-headed household, homeless) during the planning period.
 Annually coordinate with housing developers to discuss potential constraints and resources for developing housing for special needs groups.

Timing: 2023-2031; annually coordinate with housing developers and review progress in providing housing for special needs groups
Responsible Agency: Community Development Department
Funding Source: Private Resources, Federal and State funds, CDBG, HOME, City Housing Fund, and other potential funding sources
Action H.4f: Coordination with Agencies Serving the Homeless The City shall cooperate with public and private agencies to develop housing (including transitional housing), family counseling, and employment programs for the homeless. The City shall participate in regional efforts to combat homelessness, including coordination with the Contra Costa Interjurisdictional Council on Homelessness and participation in the Contra Costa Homeless Continuum of Care.

Objectives:
 Participate in local and regional efforts to address the needs of persons experiencing homelessness.
 As available, provide funding assistance and support funding applications for efforts addressing homelessness.
 Seek and pursue funding opportunities to address homelessness in the City and participate in regional efforts.

Timing: Annually coordinate with public and private agencies; review funding and available assistance annually; annually pursue funding opportunities
Responsible Agency: Community Development Department and Contra Costa County Funding Source: Homeless Agencies, Federal and State funds Action H.4g: Reasonable Accommodation
Pursuant to Government Code Section 65583, the City is obligated to analyze and demonstrate local efforts to remove potential and actual governmental constraints to the maintenance, improvement, or development of housing for all income levels and for persons with disabilities. The Fair Housing Act, as amended in 1988, requires that cities and counties provide reasonable accommodation with regard to rules, policies, practices, and procedures where such accommodation may be necessary to afford

Brentwood 2023-2031 Housing Element
Section 4: Housing Plan 4-29
individuals with disabilities equal housing opportunities. Reasonable accommodation provides a basis for residents with disabilities to request flexibility in the application of land use and zoning regulations or, in some instances, even a waiver of certain regulations or requirements to ensure equal access to housing opportunities. The City is required to consider requests for accommodations related to housing for people with disabilities and provide the accommodation when it is determined to be appropriate under the factors set forth in Brentwood Municipal Code Chapter 17.760.

In compliance with Government Code Section 65583, the City shall continue to provide reasonable accommodations for persons with disabilities pursuant to Brentwood Municipal Code Chapter 17.760.

Objectives:
 Maintain updated information on reasonable accommodations on the City’s website.  Biennially review and update applicable procedures and/or requirements to remove potential constraints.
 Provide information on housing resources available to persons with disabilities to the Regional Center and other local groups or organizations serving the needs of persons with disabilities.

Timing: Review biennially, and if determined necessary, amend the Zoning Code within six months; annually provide information on housing resources to the Regional Center and other local organizations and groups serving the needs of persons with disabilities.

Responsible Agency: Community Development Department
Funding Source: General Fund
Action H.4h: Low-Barrier Navigation Center
Assembly Bill 101 (AB 101), Chapter 159 Statutes 2019 requires 'by right' approval of low-barrier navigation centers in areas zoned for mixed uses and nonresidential zones permitting multifamily uses that meet specified requirements. The City shall adopt regulations and procedures for this type of use and establish a ministerial approval process for low-barrier navigation centers. In the interim, any submitted application for this use type shall be processed in accordance with State law.

The City shall also monitor the effectiveness and appropriateness of these regulations and procedures.

Should any amendments be warranted pursuant to State law, the City shall amend the Municipal Code.

Objectives:
 Adopt and implement procedures and regulations to process low-barrier navigation centers.

Procedures shall include establishing a ministerial approval process pursuant to State law.

Timing: Adopt and implement by January 2025; review annually Responsible Agency: Community Development Department
Funding Source: General Fund
Action H.4i: Housing for Persons with Developmental Disabilities The City shall encourage construction and rehabilitation of housing with supportive services targeted for persons with developmental disabilities, including collaborating with developers of supportive housing to identify opportunities, resources, and potential constraints. The City shall establish regulatory incentives, such as expedited permit processing and fee deferrals, to projects targeted for persons with developmental disabilities. The City shall seek State and Federal funding and support funding applications for housing construction and rehabilitation targeted for persons with developmental disabilities, as staff resources allow. The City shall maintain information online on housing and services available for persons with developmental disabilities.

Brentwood 2023-2031 Housing Element
Section 4: Housing Plan 4-30
Objectives:
 Collaborate with housing developers and local organizations to identify the needs of local persons with developmental disabilities.
 Seek State and Federal funding and support funding applications.  Establish regulatory incentives for projects proposing housing for persons with developmental disabilities.

Timeframe: Implement by January 2027; annually meet with developers and organizations and seek funding opportunities; review annually
Responsible Agency: Community Development Department
Funding Source: General Fund
Action H.4j: Single-Room Occupancy (SRO) Units
Single-Room Occupancy (SROs) Units may provide a valuable source of affordable housing for individuals and may serve as an entry point into the housing market for persons who previously experienced homelessness. The City’s Municipal Code conditionally permits SROs in the COR and CR zoning district.

Objectives:
 Define Single-Room Occupancy Units in the Municipal Code.  Collaborate with local organizations and agencies to discuss the needs of persons who previously experienced homelessness.
 Support and, when possible, fund local and regional efforts to address the housing needs of persons in Brentwood who previously experienced homelessness.

Timing: Add a definition of SRO in the Municipal Code by January 2026; collaborate with organizations annually; annually review funding resources; make changes as necessary throughout the planning period
Responsible Agency: Community Development Department
Funding Source: General Fund
Action H.4k: Emergency Shelters
Pursuant to the provisions of SB 2, AB 139, and AB 2339 the City will continue to facilitate the establishment of emergency shelters to assist those experiencing homelessness. The City will update the Municipal Code to comply with AB 139 parking requirements and AB 2339.

Objectives:
 Amend the Municipal Code parking requirements for emergency shelters in compliance with AB 139.
 Amend the Municipal Code to allow emergency shelters by-right in at least one zone that allows residential and revise the definition of emergency shelters pursuant to AB 2339 (2023).

Timing: Adopt amendment by January 2025
Responsible Agency: Community Development Department
Funding Source: General Fund

Brentwood 2023-2031 Housing Element
Section 4: Housing Plan 4-31
Action H.4l: By-Right Permanent Supportive Housing (AB 2162) Pursuant to Government Code section 65651, supportive housing shall be a use by-right in zones where multifamily and mixed uses are permitted, including non-residential zones permitting multifamily uses.

Objectives:
 Amend the Municipal Code to permit by-right permanent supportive housing in compliance with Government Code section 65651.

Timing: Adopt amendment by January 2025
Responsible Agency: Community Development Department
Funding Source: General Fund
Action H.4m: Reasonable Accommodations
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.

An individual with a disability is defined 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.

As part of the ongoing Zoning Code update, the City will amend reasonable accommodations to remove subjective requirements to application findings and constraints.

Objectives:
 Adopt Zoning Code updates removing subjectivity and constraints in application finding requirements.

Timing: Adopt the Zoning Code updates by January 2025
Responsible Agency: Community Development Department
Funding Source: General Fund
Action H.4n: Definition of Family
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.”
As part of the ongoing Zoning Code update, the City will amend its definition of “Family” to remove the requirement that all household members be under a single lease to be considered a family.

Objectives:
 Adopt Zoning Code updates removing constraints posed by the City’s definition of “Family” to comply with State law requirements.

Brentwood 2023-2031 Housing Element
Section 4: Housing Plan 4-32
Timing: Adopt the Zoning Code updates by January 2025
Responsible Agency: Community Development Department
Funding Source: General Fund
Action H.4o: Residential Care Facilities
Large residential care facilities occupy a large family home and provide adult or child group home, social rehabilitation center, or adult or child day care center. Approval of a CUP is currently required for large residential care facilities, potentially creating a constraint to the development of this housing type. The City will revise the Zoning Code to remove the CUP requirement and establish a processes and requirements for large residential care facilities to allow these uses in the same way as other residential uses in the same zone.

Objectives:
 Adopt Zoning Code updates to allow residential care facilities in all zones allowing residential uses in the same was as other residential uses in the same zone.

Timing: Adopt the Zoning Code updates by January 2025
Responsible Agency: Community Development Department
Funding Source: General Fund
B. Summary of Quantified Objectives
Table 4-1 summarizes the City’s quantified objectives for the 2023-2031 planning period by income group.

Table 4-1: 6th Planning Cycle Quantified Objectives
Objectives
Units by Income Level
Extremely TOTAL UNITS
Low
Very
Low Low Moderate Above Moderate
RHNA 402 232 247 641 1,522
Home Repair/ Rehabilitation 30 30
Special Needs Units 50 50
First-Time Homebuyer 15 5 0 20
Affordable Housing
Assistance 50 50 50 0 0 150
Conservation of At-Risk
Affordable Housing Units 6 0 0 6

REVIEW OF PAST PERFORMANCE
Appendix A

Brentwood 2023-2031 Housing Element
Appendix A: Review of Past Performance A-1
Appendix A: Review of Past Performance
The following is a review of the City of Brentwood’s housing project and program performance in the 2015- 2023 Planning Period. It is an evaluation of the 5th Cycle’s Policy Program and considers all current and existing programs and projects, as well as the most current effectiveness and appropriateness for the 2023- 2031 6th Cycle.

Appendix A Contents
A. Program Evaluation for Households with Special Needs

1. Seniors

2. Persons with Disabilities

3. Large Households

4. Farmworkers

5. Single-Parent Households

6. Persons Experiencing Homelessness

7. Extremely Low-Income Households
B. 5th Planning Cycle Program Accomplishments
A. Program Evaluation for Households with Special Needs As part of analyzing prior programs, this Appendix A must provide an outline of the effectiveness of goals, policies, and programs in the housing needs of Brentwood’s special needs populations. The following section identifies 5th Cycle accomplishments by special needs groups.

1. Seniors
Section 2: Community Profile shows that 15 percent (9,279 residents) of Brentwood residents are over the age of 65. Senior housing is permitted in the form of community care facilities, which are permitted with six or fewer persons in the agricultural, residential, and commercial zoning districts, as well as conditionally permitted with seven or more persons in residential and commercial zoning districts. Supportive housing may be used for senior care and is permitted with six or fewer persons in the agricultural and residential zoning districts, as well as conditionally permitted with seven or more persons in the residential and commercial zoning districts. In addition, Chapter 17.720 of the Brentwood Municipal Code provides for density bonuses and other incentives for the development of Senior Housing.

The Housing Choice Voucher Program extends rental subsidies to low-income households, including families, seniors, and the disabled. The Housing Authority of the County of Contra Costa (HACCC) provided Housing Choice Vouchers to over 9,000 households in Contra Costa County. In Brentwood, the Housing Choice Vouchers paid Brentwood landlords approximately $1,600 per month towards rent assistance in 2021.

The City continues to implement and monitor actions related to access to housing for seniors. The City continues to regulate conversions of multi-family units, minimize displacement of seniors, and monitor required development fees to reduce constraints on the development of affordable residential projects,

Brentwood 2023-2031 Housing Element
Appendix A: Review of Past Performance A-2
including senior housing. While no housing projects took advantage of condominium to multi-family unit conversion applications during the 5th Cycle, the City provides information online on the City’s website and promotes the incentives in conversations with developers.

In addition, the City of Brentwood provides further information regarding senior housing and programs on its website. Senior housing listed on the City’s website include subsidized senior housing projects such as the Sycamore Place I and II Apartments and apartment complexes and mixed family projects that include subsidized senior units such as Brentwood Senior Commons, Los Nogales Apartments, Towne Center Commons, and Villa Amador. There are a variety of programs and community resources for Brentwood seniors. Café Costa provides nutritious lunches to Brentwood seniors ages 60 and up. Contra Costa County Food Bank Brown Bag Program also distributes free supplemental food twice per month for low-income seniors ages 55 years or older.

2. Persons with Disabilities
Persons with disabilities may require varying accessibility improvements and may also have limited ability to earn adequate income. According to 2019 ACS data, about 11.6 percent of Brentwood residents have at least on disability. Of that percentage, 48.1 percent have ambulatory difficulty. The following most common disabilities in Brentwood are ambulatory and independent living difficulties.

The City partners with County-wide groups, such as the Contra Costa County Developmental Disabilities Council, Network of Care, and Department of Public Social Services, to provide various supportive services including information regarding federal and state programming and linkage, and referrals to regional disability resources. Additionally, the City continues to encourage the development of housing types accessible for people living with a disability, such as rent subsidized homes, licensed and unlicensed singlefamily homes, inclusionary housing, Section 8 vouchers, special programs of home purchase, HUD housing, and SB 962 (veteran) homes.

3. Large Households
Large Households consist of five or more residents and may have a harder time finding adequately sized units to avoid overcrowding. Section 2 of this Housing Element shows that approximately 15.3 percent of Brentwood households have five or more members. This percentage consists of 9.7 percent 5-person households, 3.8 percent 6-person households, and 1.8 percent 7-or-more person households.

Larger, lower income families may qualify for Housing Choice Vouchers. As noted above, HACCC provided Housing Choice Vouchers to Brentwood households. The Housing Choice vouchers paid Brentwood landlords approximately $1,600 per month towards rent assistance in 2021. The City continues to encourage affordable housing development for large households through CDBG and HOME funds, partnerships with developers and entities, and providing homebuyer assistance.

4. Farmworkers
Farmworkers include persons seasonally or permanently employed in the agricultural industry and generally earn lower incomes than many other workers. According to 2019 ACS data, there are 184 Brentwood residents employed in the agriculture, forestry, fishing, hunting, and mining sector. The California Employment Development Division reports the median salary for those employed in the farming, fishing, and

Brentwood 2023-2031 Housing Element
Appendix A: Review of Past Performance A-3
forestry occupation in the Oakland-Hayward-Berkeley Metropolitan Division, which is inclusive of Alameda and Contra Costa Counties, as $35,142 in the 2018-2028 period. 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.

Given new provisions in the California Health and Safety Code Sections 17021.5 and 17021.6, a program has been included in the Housing Plan to permit, by-right, farmworker and employee housing in single-family zone districts for six or fewer persons and in agricultural zoning districts for up to 12 units or 36 beds.

5. 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. Single parents make up 30 percent of Brentwood households, with 20.8 percent being single mothers and 9.2 percent being single fathers.

The City offers a variety of community resources for children and single parents in the community. The Brentwood Union School District (BUSD) serves over 9,000 students from preschool through adult education courses. The BUSD includes eight elementary schools and three middle schools.

6. Persons Experiencing Homelessness
Homelessness has become an increasingly important issue in the region and throughout the State of California. There are a number of factors that may contribute to a person experiencing homelessness; Section 2: Community Profile provides a detailed definition of “homelessness” and an analysis of the City and County’s unhoused population.

The City partners with the Contra Costa Health Services Department for the County of Contra Costa Continuum of Care (CoC) program. The Contra Costa CoC provides homeless assistance, coordination, and programs. The CoC has a network of more than 50 private and public sector organizations and homeless service providers designed to promote community-wide planning and the strategic use of resources to address homelessness in the County.

Additionally, the City of Brentwood partners with Shepherd's Gate – which has locations in both Brentwood and Livermore – and offers a total of 95 beds between the two locations for persons experiencing homelessness. Other regional homeless shelters that serve the people of Contra Costa County include Bay Area Rescue Mission - Men's Shelter, Bay Area Rescue Mission - Women and Family Shelter, and SHELTER, Inc. of Contra Costa.

7. Extremely Low-Income Households
Extremely low-income households are those that earn 30 percent or less of the household median family income (HMFI) for Contra Costa County. Extremely low-income households may require rental assistance and other community service assistance. According to CHAS data, there are approximately 1,985 extremely low-income households in Brentwood, including both renters and homeowners.

Brentwood 2023-2031 Housing Element
Appendix A: Review of Past Performance A-4
Throughout the 5th Cycle, the City coordinated with a number of developers to develop affordable housing units, including units affordable to extremely low-income households. The City also continues to encourage the development of housing types accessible for extremely low-income households, such as rent subsidized homes, licensed and unlicensed single-family homes, inclusionary housing, Section 8 vouchers, special programs of home purchase, HUD housing, and SB 962 (veteran) homes.

B. 5th Planning Cycle Program Accomplishments
Table A-1 provides detailed, program-specific accomplishments for 2015-2023. The City of Brentwood has demonstrated significant effort in working towards accomplishing many of the objectives established in the 5 th Planning Cycle Housing Element. The City’s successful programs have been identified as ongoing for the 6 th Planning Cycle. Various programs have been modified in the 6th Cycle Housing Plan to account for new requirements and changes in State Law.

Brentwood 2023-2031 Housing Element
Appendix A: Review of Past Performance A-5
Table A-1: 5th Planning Cycle Program Accomplishments
Policy Actions Program Accomplishments Status for Sixth Cycle Goal H 1
HOUSING: Provide a diversity of housing opportunities to enhance the City's living environment and to satisfy the shelter needs of all Brentwood residents.

Action H 1a:

Biennial Evaluation: Conduct an bi-annual evaluation of the City's inventory of available sites, including very high density residential sites, and take appropriate action to ensure an ongoing supply of available sites at appropriate densities to meet projected housing needs. This bi-annual evaluation shall include an assessment of the effect of the City’s midrange density land use policy to ensure that it does not become a barrier or impact the cost to the development of additional housing opportunities and hinder the efficient use of the City’s available vacant residential land supply. The bi-annual evaluation will at a minimum evaluate factors such as built densities, processing time, and impacts on approval and development costs. If the evaluation identifies the mid-range policy as a constraint, the City will take action within one year to mitigate its impacts on development. In addition, should the Residential Growth Management Program be reinstated, the City shall include an evaluation of any impacts or constraints on the development of housing.

Objectives: The objective is to maintain adequate residential sites.

The City has had relatively few land use changes since
the adoption of its Housing Element. All land use
changes are evaluated at the time of processing to
ensure that adequate residential acreage remains
available for all income levels to meet the City’s RHNA.

Ongoing.

The City will continue to monitor
and evaluate land use policies
throughout the 6th planning cycle
for potential constraints to housing
development.

Action H 1b:

Second Unit/Accessory Units: Continue to encourage the use of second units in single-family residential areas in meeting the City's low- and moderate-income housing objectives. The second unit should neither adversely affect nor alter the character of the surrounding single-family neighborhood.

Objectives: On-going implementation anticipated to result in 25 new second units during the planning period.

The City has been successful in updating its Accessory
Dwelling Unit ordinance in order to be in conformance
with State regulations. From 2018-2020, the City was
successful in encouraging accessory dwelling units.
2018: added 22 units
2019: added 22 units
2020: added 20 units
It is anticipated that additional accessory dwelling
units will be added throughout the planning period.

Modify.

The program is modified for the 6th
cycle to include additional
objectives in order to continue
facilitating the development of
ADUs as a strategy to meet the
City’s RHNA.

Brentwood 2023-2031 Housing Element
Appendix A: Review of Past Performance A-6
Table A-1: 5th Planning Cycle Program Accomplishments
Policy Actions Program Accomplishments Status for Sixth Cycle Action H 1c:

Emergency Shelters and Transitional and Supportive Housing Sites:

As required by Government Code Section 65583, the City shall amend the Zoning Ordinance to allow for the development of at least one year-round emergency shelter to fulfill the City’s need as a permitted use without a conditional use permit within the PD 38 zoning district. Development standards shall encourage and facilitate the development of or conversion to emergency shelters.

Additionally, the City shall facilitate the approval of transitional and supportive housing sites within the community by amending the zoning ordinance to add a definition for Transitional and Supportive Housing as defined in Section 50675.2(h) of the Health and Safety Code and allow such housing within all zones that allow residential uses subject to the same requirements as residential development within those zones.

Objectives: Objective is to accommodate emergency shelters, transitional housing, and supportive housing.

The City added a chapter to its Zoning Ordinance
addressing emergency shelters. This chapter is an
amendment to the Planned Development 38 Zone text
to allow emergency shelters as a permitted use within
Subarea C. This chapter also is an amendment to the
definitions chapter to address transitional and
supportive housing within all residential zoning
designations.

Completed.

The City successfully amended its
Zoning Ordinance to accommodate
emergency shelters, transitional
housing, and supportive housing.

Action H 1d:

Monitor At-Risk Projects: One year prior to each Housing Element update, determine the status of financial incentives for assisted housing projects to determine whether income restrictions on such projects are “at risk” of being lifted, thereby terminating the “affordability” of the project. Where assisted housing projects are “at risk,” develop strategies including potential expenditure of City housing funds to preserve their ongoing affordability. The City shall consider opportunities to preserve ongoing affordability by providing financial resources and technical assistance so that existing affordable units are not at risk of converting to market rate after their restricted affordability term expires. If affordable units will be lost, opportunities to convert existing market rate units to affordable units shall be investigated by providing rehabilitation improvement assistance to owner-occupied single units and to The City continues to consider opportunities to
preserve ongoing affordability by providing financial
resources and technical assistance so that existing
affordable units are not at risk of converting to market rate after their restricted affordability term expires.

Ongoing.

The City will continue to monitor atrisk units and work with property owners to maintain affordability
throughout the 6th planning cycle.

Brentwood 2023-2031 Housing Element
Appendix A: Review of Past Performance A-7
Table A-1: 5th Planning Cycle Program Accomplishments
Policy Actions Program Accomplishments Status for Sixth Cycle owners of apartment complexes or by purchasing affordability covenants.

Objectives: The objective is to identify any at-risk units (there are currently none) one year prior to the next Housing Element Update.

Action H 1e:

Community Education Regarding the Availability of Rehabilitation Programs: Encourage the Contra Costa County HOME Consortium and CDBG Urban County to educate lower-income households, owners, and managers of rental properties, non-English-speaking households, and other special needs groups about available rehabilitation programs and available affordable housing opportunities by using neighborhood and community organizations, the City and County websites, and various print, broadcast and online media.

Objectives: Objective is rehabilitation of 30 units.

The City continues to encourage the education of
lower-income households, owners, and managers of
rental properties, non-English-speaking households,
and other special needs groups about available
rehabilitation programs and available affordable
housing opportunities by using neighborhood and
community organizations, the City and County
website, and various print, broadcast, and online
media.

Ongoing.

The City will continue to outreach
to the community and seek to assist
30 units throughout the 6th
planning cycle.

Action H 1f:

Housing Condition Survey: Maintain a current housing condition survey of a representative sample of all housing units within the City. This survey should include the number of units in need of rehabilitation or replacement.

Objectives: Objective is to maintain a current survey.

The City continues to maintain a current housing
condition survey of a representative sample of all
housing units within the City.

Ongoing.

The City will continue to maintain a
survey of housing units throughout
the community throughout the 6th
planning cycle to identify needs and
units in need of rehabilitation.

Action H 1g:

Residential Design Guidelines: Continue implementation of the City’s approved Residential Design Guidelines and encourage a variety of housing types to continue to provide safe, sound, and attractive housing for all residents. The intent of these guidelines is to express the housing design features the City would like to encourage in order to improve certainty and to minimize the processing time for design review applications.

Objectives: Objective is continued implementation of the Residential Design Guidelines.

The City continues to implement the adopted
Residential Design Guidelines by evaluating all new
residential projects for compliance with the
Guidelines.

Ongoing.

The City will continue to implement
the adopted Residential Design
Guidelines throughout the 6th
planning cycle.

Brentwood 2023-2031 Housing Element
Appendix A: Review of Past Performance A-8
Table A-1: 5th Planning Cycle Program Accomplishments
Policy Actions Program Accomplishments Status for Sixth Cycle Action H 1h:

Code Enforcement: Provide both proactive and reactive code enforcement to ensure adherence to and address land use regulations and State and local laws, health and safety concerns, property maintenance, and nuisance conditions.

Objectives: Objective is to maintain code compliance.

The City continues to be proactive and reactive with
code enforcement to ensure adherence to and
address land use regulations and State and local laws,
health and safety concerns, property maintenance,
and nuisance conditions.

Ongoing.

The City will continue to be
proactive and reactive with code
enforcement throughout the 6th
planning cycle.

Action H 1i:

Water Conservation Program: Continue implementation of the City's Water Conservation Program. The program promotes the use of water conservation devices in existing structures, including use of low-flow toilets and shower heads, and water-conserving landscaping.

The City adopted an ordinance in compliance with
State law to reduce overall water consumption by 35
percent and has achieved this goal by 2015. The City
continues conservation efforts by promoting the use
of water conservation devices in existing structures.

Ongoing.

The City will continue to implement
the Water Conservation Program
throughout the 6th planning cycle.

Action H 1j:

Landscaping Water Efficiency: Implement the City’s adopted model water efficiency landscape ordinance in accordance with Assembly Bill 1881, the Water Conservation in Landscaping Act, to conserve water and reduce consumption by 20% by the year 2020.

Objectives: Objective is to achieve a 20% consumption reduction by 2020.

By 2016, the City updated its Water Efficient
Landscape Ordinance to be in compliance with State
law. In 2018, the City has adopted a model water
efficiency landscape ordinance in accordance with
Assembly Bill 1881, and Water Conservation in
Landscaping Act. The City aimed to conserve water
and reduce consumption by 20 percent by the year
2020.

Ongoing.

The City will continue to implement
the City’s adopted model water
efficiency landscape ordinance
throughout the 6th planning cycle.

Action H 1k:

Energy Efficient Design: Continue to implement the California Green Building Standards Code (CalGreen), encouraging new development and substantial rehabilitation projects to achieve a greater reduction in efficiency and conservation where feasible. Continue to encourage new development projects to meet LEED standards and apply for LEED certification.

Objectives: Objective is continued compliance with CalGreen.

The City continues to implement the California Green
Building Standards Code (CalGreen) and encourages
new development and substantial rehabilitation
projects to achieve a greater reduction in efficiency
and conservation where feasible. The City also
continues to encourage new development projects to
meet LEED standards and to apply for LEED
certification.

Ongoing.

The City will continue to implement
the California Green Building
Standards Code (CalGreen)
throughout the 6th planning cycle.

Action H 1l:

Condominium Conversion: Continue implementation of the City’s adopted condominium conversion ordinance to regulate
The City continues to implement the adopted
condominium conversion ordinance to regulate
conversions of multi-family units and to mitigate
Ongoing.

The City will continue to implement
the adopted condominium

Brentwood 2023-2031 Housing Element
Appendix A: Review of Past Performance A-9
Table A-1: 5th Planning Cycle Program Accomplishments
Policy Actions Program Accomplishments Status for Sixth Cycle conversions of multi-family units and to mitigate tenant displacement and minimize displacement of seniors, disabled, and low- and moderate-income residents. Continue monitoring of condominium conversions to insure that a proposed conversion would not result in a disproportionate balance of available rental housing with a variety of choices in tenure, price, unit sizes, amenities, and location in the community.

Objectives: Objective is to ensure that there is not a significant adverse impact associated with condominium conversions. tenant displacement and minimize displacement of
seniors, disabled, and low- and moderate-income
residents. The City continues to monitor condominium
conversions. In 2018, 2019, and 2020, the City has not
received any applications for condominium
conversions.
conversion ordinance and monitor
condominium conversions
throughout the 6th planning cycle.

Action H 1m:

Farmworker Housing: Revise the definition of “agriculture” in the Zoning Code to identify that employee housing, as identified by Health and Safety Code Section 17021.6, is considered an agricultural use and is subject to the same permitting requirements and standards as any other agricultural use in the same zone.

Objectives: Objective is to accommodate farmworker housing By 2018, the City has revised its definition of
“agriculture” in the zoning code and continues to
identify that employee housing is considered an
agricultural use and is subject to the same permitting
requirements and standards as any other agricultural
use in the same zone.

Modify.

The City successfully amended the
Zoning Code to accommodate
farmworker housing. The program
is modified for the 6th planning
cycle to include updates to State
law related to farmworker and
employee housing.

Action H 1n:

Family: Revise the definition of “family” in the Zoning Code to remove the phrase “related by blood, marriage, cooptation or adoption.”.

Objectives: Objective is to ensure fair housing.

The City continues to ensure fair housing. By 2015, the City has revised its definition of “family” in the zoning code to remove the phrase “related by blood,
marriage, cooptation, or adoption.”
Completed.

The City successfully revised its
definition of “family” during the 5th
planning cycle.

Action H 1o:

Affordable Housing Requirement: Revise the density bonus language at Section 17.725.006 of the Zoning Code to identify the density bonus allowed for the City’s affordable housing requirement is not the same as the density bonus allowed under State law. The revision is to change the title of the paragraph to “Density Incentive” and to refer to the potential increase in density associated with the affordable housing requirement as a “density incentive” rather than a “density bonus” so that it is not confused with the density bonus provisions of State law, as established by Zoning Code Chapter 17.720.

The City continues to encourage affordable housing.

By 2015, the City revised the density bonus language
to identify the density bonus allowed for the City’s
affordable housing requirement is not the same as the
density bonus allowed under State Law.

Completed.

The City amended its Zoning Code
to clarify language relating to
density bonuses during the 5th
planning cycle.

Brentwood 2023-2031 Housing Element
Appendix A: Review of Past Performance A-10
Table A-1: 5th Planning Cycle Program Accomplishments
Policy Actions Program Accomplishments Status for Sixth Cycle Objectives: Objective is to encourage affordable housing.

GOAL H 2
AFFORDABILITY: Provide housing that is affordable to all socio-economic segments of Brentwood's population.

Action H 2a:

Compliance with Affordable Housing Ordinance: All new residential projects, with the exception of multi-family apartment units, shall provide affordable housing units in accordance with the City’s adopted affordable housing ordinance. The City will continue to review and monitor the ongoing effectiveness of the City’s affordable housing ordinance to ensure developers provide a certain percentage of new homes to qualifying households at an affordable cost for the longest feasible time. The ordinance shall also continue to include a list of automatically available development incentives to encourage the construction of the inclusionary units as well as provide the details for available alternatives to satisfy inclusionary housing obligations.

Objectives: Annually track development of affordable housing units and adjust ordinance as needed.

The City continues to track development of affordable
housing and adjust the ordinance as needed.
2015, 2016
The City successfully negotiated for the inclusion of
five housing units integrated into new subdivisions,
which construction was completed in 2015. The City
collected $863,729.96 for in-lieu fees.
2017
The City successfully negotiated for the inclusion of 11 deed restricted units integrated into new subdivisions.

Construction of these units were completed in 2017.
2018, 2019
The City continues to investigate options for amending
the affordable housing ordinance in order to create
more affordable units.
2020
The City was successful in amending its affordable
housing ordinance by increasing the percentage from
2 percent to 10 percent in order to create more
affordable housing units.

Ongoing.

The City will continue to track
affordable housing development
throughout the 6th planning cycle.

Action H 2b:

Additional Development Incentives for Affordable Housing: Use voluntary incentives to encourage the production of affordable housing, particularly housing affordable to extremely low, very low, The City continues to provide incentives to affordable
housing projects and to encourage development of
units.

Ongoing.

The City will continue to encourage
and provide incentives for the
development of affordable housing

Brentwood 2023-2031 Housing Element
Appendix A: Review of Past Performance A-11
Table A-1: 5th Planning Cycle Program Accomplishments
Policy Actions Program Accomplishments Status for Sixth Cycle and low income groups, and provide incentives for the production of affordable housing where appropriate. Examples of such additional incentives include, but are not limited to the following:
 Density. Allow density to exceed allowable mid-range
density.
 Fast track processing. By expediting the development
review process, carrying costs for lands being developed with affordable housing can be minimized.
 Fee Deferrals. Consider the provision of financial assistance for projects ensuring the long term affordability of housing for very low and low income households through the use
of additional fee deferrals of development processing and development impact fees until issuance of final inspection or 12 months from the date of deferral, whichever occurs first, or other similar incentives, so as to ensure the project’s economic feasibility.
 Flexible Development Standards. Consider modification of City’s standards or approval of design modification that increase the flexibility of the construction of affordable units may be considered for the necessary financial or
other feasibility of the affordable housing development.

Such modifications may include reduced lot sizes, home
sizes, setback requirements, interior amenities, open
space, and landscaping requirements.
 Flexible Zoning. Consider modification of development standards to allow the ability to construct duplexes and triplexes on corner lots within single-family areas. City zoning and subdivision requirements can be modified to
permit the construction of duplexes and triplexes on
corner lots within single-family areas. By accomplishing this, affordable housing can be integrated into singlefamily neighborhoods. development throughout the 6th
planning cycle.

Brentwood 2023-2031 Housing Element
Appendix A: Review of Past Performance A-12
Table A-1: 5th Planning Cycle Program Accomplishments
Policy Actions Program Accomplishments Status for Sixth Cycle  Direct Financial Assistance. Consider authorization of provision of direct financial assistance, if available, in the form of a loan or grant from the City housing funds for development of ownership and/or rental units affordable to lower income households in accordance with the City’s affordable housing ordinance.
 Additional Concessions and Incentives. Consider, on a case-by-case basis, the provision of additional concessions or incentives consistent with State law and Brentwood’s Housing Element for affordable units that exceed the
requirements of the City’s affordable housing ordinance.

Objectives: Objective is to provide incentives to affordable housing projects and to encourage development of units (see Action H 2d for numeric objectives).

Action H 2c:

First-Time Homebuyer Assistance Program: The City shall continue providing first-time homebuyer assistance services, either directly or through the Contra Costa Urban County and/or HOME
Consortium, to lower income Brentwood residents to facilitate homeownership. This may include educational materials, referral information to existing programs, and/or down payment assistance depending upon available City financial resources.

Objectives: Assist 20 households during the planning period.

The City continues to provide first-time homebuyer
assistance services to lower income Brentwood
residents to facilitate homeownership.

In 2017, the City was successful in providing two down
payment assistance loans for a total of $30,000.

In 2018, the City was successful in refinancing one
down payment assistance loan.

In 2019, the City was successful in refinancing one
down payment assistance loan.

In 2020, the City was successful granting down
payment assistance loans for three new loans for lowincome homeowners for a total of $38,000.

Ongoing.

The City successfully provided firsttime homebuyer assistance services throughout the 5th planning cycle.

The City will continue to do so
throughout the 6th planning cycle.

Brentwood 2023-2031 Housing Element
Appendix A: Review of Past Performance A-13
Table A-1: 5th Planning Cycle Program Accomplishments
Policy Actions Program Accomplishments Status for Sixth Cycle Action H 2d:

Affordable Housing Assistance: Explore the variety of potential financial assistance programs from both the public and private sectors to provide more affordable housing units. All available local, State, Federal, and private affordable housing programs for new housing and for the conservation and/or rehabilitation of existing housing will be pursued. City housing funds and other potential funding sources shall be leveraged to the greatest extent possible to create and preserve housing affordable to Brentwood’s workforce by encouraging developers to layer available public housing funds
Objectives: Objective (in conjunction with other actions) is to provide 20 extremely low, 50 very low, and 50 low income units during the planning period.

The City continues to explore a variety of potential
financial assistance programs from both public and
private sectors to provide more affordable units.

Ongoing.

The City will continue to explore
funding options for affordable
housing developments and seek to
facilitate 120 total lower income
units throughout the 6th planning
cycle.

Action H 2e:

Partnership Program: When non-profit, private, and other public entities indicate interest in the development of affordable housing, the City will initiate a first meeting and subsequent follow-up contact to examine opportunities for cooperative efforts to expand the City’s supply of affordable housing.

Objectives: Meet with developers and outside agencies when interest is expressed and follow up annually.

The City continues to respond to requests or interest
in partnership for the development of affordable
housing.

Ongoing.

The City will continue to work with
developers and organizations to
create partnerships with the goal of
facilitating the creation of
affordable housing units
throughout the 6th planning cycle.

Action H 2f:

Support Housing Sponsors: Support non-profit and for-profit corporations in their efforts to make housing more affordable to lower and moderate-income households. This effort will include ongoing support of grant applications, identifying available sites for housing development, City involvement in the development of such sites, and consideration of City financial support and contact of housing sponsors on an annual basis.

Objectives: Objective is to provide affordable housing units, in conjunction with other actions (see Action H 2d for numeric objectives).

The City continues to support non-profit and for-profit corporations in their efforts to make housing more
affordable to lower and moderate-income households.

The City continues to contact interested housing
sponsors on an annual basis.

Ongoing.

The City will continue to support
non-profit and for-profit entities in
efforts to develop affordable
housing units throughout the 6th
planning cycle.

Brentwood 2023-2031 Housing Element
Appendix A: Review of Past Performance A-14
Table A-1: 5th Planning Cycle Program Accomplishments
Policy Actions Program Accomplishments Status for Sixth Cycle Action H 2g:

Streamline Application Process: Continue efforts to streamline and improve the development review process, as well as eliminate any unnecessary delays and restrictions in the processing of development applications.

Objectives: Biennially review the development review process.

The City continues to review the development review
process for improvements. In 2018, the City has
completed an update for all development applications,
which clearly outlines submittal materials required
and expected processing times, in order to expedite
processing and minimize incomplete applications.

Ongoing.

The City will continue its efforts to
streamline and improve the
development review process and
remove any potential constraints
throughout the 6th planning cycle.

Action H 2h1:

Land Acquisition: The City shall consider opportunities to acquire appropriately located and residentially-zoned land for the purpose of partnering with profit and non-profit developers to construct new affordable housing.

Objectives: Consider potential residential land for affordable housing, to the extent that financial and staff resources are available to proceed with purchase of land.

The City continues to consider opportunities to
acquire land to partner with developers for the
creation of affordable housing units.

Ongoing.

The City will continue to consider
opportunities to acquire land to
partner with developers for the
creation of affordable housing units
throughout the 6th planning cycle.

Action H 2h2:

Density Bonus: Revise density bonus ordinance concurrent with adoption of housing element update.

In 2019, the City adopted a zoning ordinance
amendment to the municipal code to update the
density bonus ordinance to comply with State law.

Modify.

The program is modified to account
for new State laws.

Action H 2i:

Priority Building Inspections for Affordable Housing Projects: The City will give priority to low and very low income housing projects for building inspections carried out during various stages of the construction process.

The City continues to give priority to low and very lowincome housing projects for building inspections carried out during various stages of the construction
process.

Ongoing.

The City will continue to give
priority building inspections for
affordable housing projects
throughout the 6th planning cycle.

Action H 2j:

Improve Certainty of Residential Development Standards: The City has adopted development standards for all residential zoning designations. However, in order to maintain flexibility for the developer in providing affordable units, applicants may elect to create their own development standards through the rezoning and planned development amendment processes. The development standards for vacant residential land shall provide the guidance and direction to foster context sensitive development that enhances the The City continues to improve residential
development standards and to maintain flexibility for
developers in providing affordable units.
2015, 2016
The City was successful in the completed construction
of five low-income units with deed restrictions. The
City allowed the rezoning of the three properties in
which these units are located to accommodate project
Ongoing.

The City successfully continued to
review and revise its residential
development standards and
flexibility for affordable units
throughout the 5th planning cycle.

The City will continue to do so
throughout the 6th planning cycle.

Brentwood 2023-2031 Housing Element
Appendix A: Review of Past Performance A-15
Table A-1: 5th Planning Cycle Program Accomplishments
Policy Actions Program Accomplishments Status for Sixth Cycle community and provides greater certainty to encourage future development.
specific development standards to facilitate
construction.
2017
The City was successful in the completed construction
of 11 units with deed restrictions. The City allowed the rezoning of the three properties in which these units
are located to accommodate project specific
development standards to facilitate construction.
2018, 2019
The City adopted development standards for all
residential zoning designations.
2020
The City initiated an update to its entire zoning
ordinance to include residential development
standards for improved certainty for developers.

Action H 2k:

Development Fees: The City will continue to monitor required development fees including in-lieu fees, development impact fees, and processing fees, with the aim of reducing constraints on the development of affordable residential projects, including, but not limited to, senior housing, housing for farmworkers,
emergency/transitional housing, housing for persons with disabilities (including developmental), single room occupancies, and second units. To respond to changing local market conditions during the planning period, the City shall revise required development fees, if it is deemed appropriate.

Where fees are established and administered by regional agencies, such as the Regional Transportation Development Impact Fee, the City will request the administering agency to review and reduce fees if the City has determined that the agency’s fee is constraining The City continues to biennially review and monitor
required development fees with the aim of reducing
constraints on the development of affordable housing
projects.

Ongoing.

The City will continue to review its
development fees to avoid create
potential constraints to the
development of affordable housing
units throughout the 6th planning
cycle.

Brentwood 2023-2031 Housing Element
Appendix A: Review of Past Performance A-16
Table A-1: 5th Planning Cycle Program Accomplishments
Policy Actions Program Accomplishments Status for Sixth Cycle the residential development, particularly development of affordable housing and/or housing for special needs groups.

Objectives: Objective is to address potential constraints to affordable housing.

Action H 2l:

Water and Sewer Priority: Following adoption of the Housing Element, the City will provide the water and sewer providers with a copy of the Housing Element. The copy of the Housing Element will be accompanied by a letter identifying the City’s 2014-2022 RHNA allocation for lower income units and will refer the water and sewer providers to the requirements of State law set forth at Government Code Section 65589.7 regarding the granting of a priority for provision of water and sewer services to proposed developments that include housing units affordable to lower income households.

Objectives: Objective is comply with requirements of State law associated with provision of Housing Element to water and sewer providers
The City has provided the water and sewer providers
with a copy of the Housing Element and a letter
identifying the City’s 2014-2022 RHNA allocation for
lower income units to grant priority for provision of
water and sewer services to proposed developments
that include housing units affordable to lower-income
households.

Ongoing.

The City will provide the adopted
6 th planning cycle Housing Element
to water and sewer providers.

Action H 2m:

Affordability Monitoring: Require affordable housing projects that receive City assistance to enter into an affordable housing agreement with the City that includes provisions to ensure initial and continuing affordability. For rental projects, the affordable housing agreement shall include provisions requiring annual monitoring to ensure that the affordable units are assisting incomeeligible households. For for-sale projects, the affordable housing agreement shall include sale and resale provisions that ensure the execution and recordation of deed restrictions to ensure continued affordability for the term of the affordable housing agreement.

The City continues to require affordable housing
projects that receive City assistance to enter an
affordable housing agreement with the City.

Ongoing.

Throughout the 6th planning cycle,
the City will continue to require
affordable housing projects that
receive City assistance to enter an
affordable housing agreement with
the City.

GOAL H 3
EQUITABLE DISTRIBUTION OF AFFORDABLE HOUSING: Achieve and maintain an equitable distribution of housing for all economic groups throughout the community Action H 3a: The City continues to monitor development with affordable units to ensure that they blend in with the
Ongoing.

Brentwood 2023-2031 Housing Element
Appendix A: Review of Past Performance A-17
Table A-1: 5th Planning Cycle Program Accomplishments
Policy Actions Program Accomplishments Status for Sixth Cycle Affordable Housing Design and Distribution: All affordable units within a mixed-income subdivision shall be harmonious and comparable to the market-rate units in exterior design, quality of materials and architectural elements, and overall construction quality. Affordable units may have different interior amenities and/or slightly different dimension than market rate units in a residential development. Affordable units in a mixed-income development shall be dispersed throughout the residential development so as to prevent the concentration of affordable units. market rate units and are dispersed throughout the
project.

The City will continue to monitor
affordable housing development
throughout the 6th planning cycle.

Action H 3b:

Community Education: Continue to educate the community about annual incomes for typical occupations and the equivalent “buying power” of these incomes in today’s housing market. As part of this program, ensure that the community is aware of the income ranges of very low, low, and moderate incomes, and of the typical occupations that fall into these categories.

The City continues to hold workshops/seminars to
inform the public regarding affordable housing
programs. The City also continues to work with
preferred lenders to provide information regarding the
City’s first time homebuyers program and its
affordable housing program.

Ongoing.

The City will continue to inform and
engage the community on
affordable housing programs and
assistance available throughout the
6 th planning cycle.

Action H 3c:

Development Incentives: Maintain a package of incentives to facilitate development of housing intended for extremely low, very low, low, and moderate income households in a manner which does not distinguish such “affordable” housing from “market rate” housing in the same area (see Actions H 2b through H 2i). Provide package to housing developers and interested parties at meetings and on the City’s website.

Objectives: Review and update the package, as necessary, on a biennial basis.

The City continues to review and update, as necessary,
on a biennial basis, a package of incentives to facilitate the development of housing intended for extremely
low-, very low-, low-, and moderate-income
households. The City continues to provide this package
to housing developers and interested parties at
meetings and on the City’s website.

Ongoing.

The City will continue to provide
information on available incentives
to housing developer throughout
the 6th planning cycle.

Action H 3d:

Marketing Materials: Prepare marketing materials to be provided to the building industry, outlining opportunities for the development of housing projects. Provide materials to housing developers and interested parties at meetings and on the City’s website.

Objectives: In conjunction with Action H 3c, update materials provided to affordable housing developers to include an inventory The City continues to prepare and provide marketing
materials, as necessary, on a biennial basis, to housing developers and interested parties at meetings and the
City’s website.

Ongoing.

The City will continue to provide
updated materials to housing
developers on the sites inventory
and community housing needs
throughout the 6th planning cycle.

Brentwood 2023-2031 Housing Element
Appendix A: Review of Past Performance A-18
Table A-1: 5th Planning Cycle Program Accomplishments
Policy Actions Program Accomplishments Status for Sixth Cycle of sites and information regarding housing needs by 2016. Review and update the package, as necessary, on a biennial basis.

Action H 3e:

Meet with Potential Developers: As infill sites become available on the open market, actively seek out potential developers as a means of generating interest on their part to undertake residential projects. Additional outreach efforts to developers shall occur on an annual basis.

The City continues to seek out potential developers as
a means of generating interest to undertake
residential projects.

Ongoing.

The City will continue to outreach
to developers with potential
residential development
opportunities throughout the 6th
planning cycle.

Action H 3f:

Housing for Extremely Low, Very Low and Low Income Residents:

Use and encourage developers to use City, County CDBG and HOME Funds, Federal, and State housing development programs and funds to undertake development of housing projects for extremely low, very low and low income households
Objectives: Objective is to provide affordable housing units, in conjunction with other actions (see Action H 2d for numeric objectives).

The City continues to provide affordable housing units
by using and encouraging developers to use City,
County CDBG and HOME Funds, Federal, and State
housing development programs and funds to
undertake development of housing projects for
extremely low-, very low-, and low-income
households.

Ongoing.

The City will continue to outreach
to and provide information to
developers on available programs
and funding sources.

Action H 3g:

Improve Participation in Existing Local Housing Assistance Programs: Provide access to available housing assistance programs for Brentwood residents through improved marketing and outreach efforts including providing information at annual forums, scheduling appointments with County housing program specialists in Brentwood, providing multilingual brochures, and posting housing program information on the City’s website.

The City continues to provide access to available
housing assistance programs for Brentwood residents.

By 2018, the City has included information on its
website regarding housing assistance programs.

Ongoing.

The City will continue to outreach
to the community with available
housing assistance programs
throughout the 6th planning cycle.

GOAL H 4
HOUSING OPPORTUNITIES: Provide equal housing opportunities for all residents of Brentwood.

Action H 4a:

Cooperative Association with Non-Profits: Continue to refer cases and questions to Bay Area Legal Aid, Housing Rights Inc., Shelter, Inc., and Pacific Community Services for assistance.

The City continues to refer members of the
community to various shelters and other non-profits
for assistance.

Ongoing.

The City will continue to coordinate
with non-profits to provide fair
housing assistance and provide
information online.

Brentwood 2023-2031 Housing Element
Appendix A: Review of Past Performance A-19
Table A-1: 5th Planning Cycle Program Accomplishments
Policy Actions Program Accomplishments Status for Sixth Cycle Action H 4b:

Disseminate Fair Housing Information: The City shall disseminate fair housing information widely in the community in multiple languages. This effort shall include providing information to local apartment managers and realtors involved in residential rental real estate transactions, providing information at the Brentwood public library, at City Hall, at the Brentwood Community Center and Senior Center, at the Police Department, and at social service offices in Brentwood, on a space- available basis, serving special needs groups including lower income households.

The City continues to distribute fair housing
information periodically throughout the year to
various entities and locations throughout the City as
new information is acquired.

Ongoing.

The City successfully provided fair
housing information throughout the
5 th planning cycle and will continue
to do so, including meeting with
local agencies and organizations,
throughout the 6th planning cycle.

Action H 4c:

Foreclosure Prevention and Loan Modification Information: The City shall continue to provide foreclosure prevention and loan modification information on its website, sponsor workshops for the community, and refer owners to non-profit counseling and service providers for legal, credit, foreclosure, and loan modification counseling.

The City continues to provide foreclosure prevention
and loan modification on its website, sponsor
workshops for the community, and refer owners to
non-profit counseling and service providers.

Ongoing.

The City maintained information
online regarding foreclosure
prevention and loan modification
and will continue to do so
throughout the 6th planning cycle.

Action H 4d:

Housing Opportunities for Special Needs Groups: Provide housing opportunities to meet the special housing needs of farmworkers, elderly, disabled, developmentally disabled, large families, and the homeless. Encourage affordable housing developers assisted through Actions H 2c, H 2e, H 2g, and H 3f to provide units for special needs persons or households, when feasible and
appropriate. Annually review the progress in providing housing for the special needs groups.

Objectives: Objective is to provide 50 special needs units (farmworker, affordable senior, disabled, developmentally disabled, large households, single female head o household, homeless) during the planning period.

The City continues to provide housing opportunities to
meet special housing needs and to encourage
affordable housing developers to provide units for
special needs persons or households. The City
continues to review the progress in providing housing
for the special needs groups on an annual basis.

Ongoing.

The City has successfully continued
to provide opportunities for special
needs groups throughout the 5th
planning cycle. Throughout the 6th
planning cycle the City will
coordinate with housing developers
and continuously review resources
and constraints.

Action H 4e:

Coordination with Agencies Serving the Homeless: The City shall cooperate with public and private agencies to develop housing The City continues to be in contact with the County
and other organizations regarding its homeless
population and programs available.

Ongoing.

The City has successfully
coordinated with local and regional

Brentwood 2023-2031 Housing Element
Appendix A: Review of Past Performance A-20
Table A-1: 5th Planning Cycle Program Accomplishments
Policy Actions Program Accomplishments Status for Sixth Cycle (including transitional housing), family counseling, and employment programs for the homeless. The City shall participate in regional efforts to combat homelessness, including coordination with the Contra Costa Interjurisdictional Council on Homelessness and participation in the Contra Costa Homeless Continuum of Care. agencies and will continue to do so
through the 6th planning cycle to
continue addressing the needs of
persons experiencing
homelessness.

Action H 4f:

Reasonable Accommodation: Amend the Zoning Ordinance within one year to include a written reasonable accommodation policy for persons with disabilities seeking fair access to housing in the application of the City’s land use, zoning laws, development policies and procedures pursuant to the Federal Fair Housing Amendments Act of 1988.

By 2015, the City successfully adopted an ordinance
for reasonable accommodation for persons with
disabilities seeking fair access to housing in the
application of the City’s land use, zoning laws,
development policies, and procedures pursuant to the
Federal Fair Housing Amendments Act of 1988.

Modify.

The City successfully completed this
program during the 5th planning
cycle. The program is modified for
the 6th cycle to include annual
reviews for potential constraints to
persons with disabilities.

Brentwood 2023-2031 Housing Element
Appendix B: Candidate Sites Analysis B-0
Candidate Sites Analysis
Appendix B

Brentwood 2023-2031 Housing Element
Appendix B: Candidate Sites Analysis B-1
Appendix B: Candidate Sites Analysis
The Housing Element is required to identify sites by income category to meet the City’s Regional Housing Needs Allocation (RHNA). The sites identified within the 2023-2031 Housing Element represent the City’s ability to accommodate housing at the designated income levels during the 2023-2031 planning period.

This Appendix provides detailed information on the sites identified to meet the City’s RHNA, including:
 Assessor Parcel Number (APN)
 Address
 Size (Acres)
 Zoning
 General Plan Land Use
 Ownership
 Existing On-site Uses
 Density
 Potential Development Capacity
(Dwelling Units)
Appendix B Contents
A. RHNA Strategies

1. Adequacy of Sites to Accommodate RHNA
Availability of Water, Sewer, and Dry Utilities

2. Accessory Dwelling Units and Junior

3. Projects in the Pipeline
B. Very Low- and Low-Income Sites Inventory

1. Strategy for Accommodating Very Low- and
Low-Income RHNA
Existing Zoning and Land Use
Priority Area One Specific Plan
Projects in the Pipeline

2. Calculation of Unit Capacity
Site-by-Site Calculation
Realistic Capacity
Affordability Assumptions

3. Adequacy of Sites to Accommodate Very
Low- and Low-Income Housing
Vacant Parcels
Non-Vacant Sites
Replacement Analysis
Identification of Small or Large Parcels
C. Moderate- and Above Moderate-Income Sites
Inventory

1. Strategy for Accommodating Moderate and
Above Moderate-Income Allocation
Existing Zoning and Land Use
Priority Area One Specific Plan
Projects in the Pipeline

2. Calculation of Unit Capacity
Selection of Sites
Affordability Assumptions
Assembly Bill 725
D. Affirmatively Furthering Fair Housing

1. PA-1 Specific Plan Area

2. Vacant Residential Land
E. Summary of RHNA Status and Sites Inventory
F. Sites Identified to Accommodate RHNA and Maps

Brentwood 2023-2031 Housing Element
Appendix B: Candidate Sites Analysis B-2
A. RHNA Strategies
Table B-1 shows the City’s 2023-2031 RHNA by income category and how the RHNA will be accommodated. The analysis demonstrates the City has the capacity to meet the RHNA through a variety of methods, including:
 Projects in the development pipeline;
 Future development of accessory dwelling units (ADUs);  Capacity on existing, residentially-zoned sites; and
Table B-1: Summary of Sites Inventory

Extremely Low-
/Very LowIncome
LowIncome ModerateIncome
Above
ModerateIncome Total
RHNA (2023-2031) 402 232 247 641 1,552
Projects in the Pipeline and Estimated ADUs
Projects in the Pipeline 3 5 1,011 1,019
Projected ADU Production 66 34 12 112
Existing Zoning Capacity
Vacant Residential Land 156 68 222 446
PA-1 Specific Plan 464 229 833 1,526
Sites Inventory Total
Total Units 689 336 2,078 3,103
RHNA Buffer 9% 36% 224% 100%

1. Adequacy of Sites to Accommodate RHNA
Availability of Water, Sewer, and Dry Utilities
The City has existing or planned water, sewer, and dry utilities that have been designed and located to accommodate potential residential development identified for the 2023-2031 Housing Element.

The City’s Wastewater Division provides sanitary sewer service. The City operates one wastewater treatment plant, which has a current capacity of five million gallons per day (MGD). The City is currently in the process of expanding the treatment capacity to 6.4 MGD which should be sufficient for the buildout of the City per the City’s General Plan – including the 2023-2031 RHNA. The City provides water treatment and distribution and wastewater collection, treatment, and disposal services for its residents and businesses. The City’s untreated water sources include groundwater extracted from the San Joaquin Basin, and surface water from the San Joaquin River Delta through purchase of surplus irrigation water from the East Contra Costa Irrigation District (ECCID). The City’s Wastewater Treatment Plant receives wastewater from approximately 19,000 residential connections and 500 commercial business connections. The City’s Wastewater Treatment Plant produces tertiary filtered and disinfected water suitable for non-potable reuse.

Under the City’s Public Works Department, the Water Operations Division is the water provider for residents in Brentwood. The City’s water supply consists of both surface water from the Sacramento-San Joaquin River Delta and groundwater from existing wells located in the East Contra Costa Subbasin within the larger San Joaquin Valley Groundwater Basin. The City’s water distribution system consists of three pressure zones, one potable water treatment plant, five active groundwater wells, six water reservoirs, seven water booster pump stations, and 347 miles of water mains within city-limits. The City’s water

Brentwood 2023-2031 Housing Element
Appendix B: Candidate Sites Analysis B-3
system serves more than 20,000 connections. The City obtains approximately 5 MGD from City wells, 6 MGD from Contra Costa Water District’s Randall Bold Water Treatment Plant, and 15 MGD from the Brentwood Water Treatment Plant. The City is currently in the process of planning for the expansion of the Brentwood Water Treatment Plant to 30 MGD. According to the 2020 Brentwood Urban Water Management Plan, the City has always met system water demand and expects no reductions from normal year supply. While the City is taking steps to accommodate future buildout over the next 30 to 40 years, existing infrastructure can currently accommodate the entire RHNA.

Electric power within the City is supplied by Pacific Gas and Electric (PG&E). Most electric power is brought to electric substations in the region via transmission lines connected to the statewide grid system. Electric power capacity is looked at on a subregional (rather than citywide) basis. Local electrical capacity is a function of transmission network capacity to bring this power to the subregion, capacity of the local substations to lower the voltages (or step down the power) to deliverable suitable voltage, and the ability of the local distribution network to deliver adequate power to customers.

Natural gas is supplied directly to residential and commercial customers by PG&E. Natural gas is pumped from underground reservoirs into large transmission pipelines, which transport the gas to local distribution pipelines. Some local distribution systems lead to underground storage. These natural gas storage areas are utilized during seasonal peaks.

The General Plan Conservation and Open Space Element establishes policy programs which promote energy conservation and efficiency in new and existing buildings throughout the City.

Each site in the Sites Inventory has been evaluated to ensure there is adequate access to utility services and connections, including water, sewer, and dry utilities. Each site is situated with a direct connection to a public street that has appropriate water and sewer mains and other infrastructure services.

2. Accessory Dwelling Units and Junior Accessory Dwelling Units In addition to primary dwelling units, there is capacity for the development of Accessory Dwelling Units (ADUs) and Junior ADUs on existing and future single-family properties. It is anticipated an additional 112 ADUs can be accommodated throughout the community during the 2023-2031 planning period. This is equivalent to 14 ADUs per year throughout the planning period – this is based on development trends since 2019 and does not exceed the total average.

The State Department of Housing and Community Development (HCD) has supported a strategy for estimating future development of ADUs in the City based on the average number of ADUs from past performance (2019 to 2022).

Table B-2 displays the City’s past performance in permitting ADUs from 2019 through 2022. The data shows that in total, the City received an increase in ADU development interest but the figures have fluctuated year-by-year. Although there was a slight decline in 2022 with only 12 units permitted, there were a total 17 permits under review as of January 1st 2023. Using the “Safe Harbor” approach to ADU projection, the City has estimated a total of 14 ADUs per year during the Planning Cycle based on the average production between 2019 and 2022. The estimates are consistent with the City’s most recent ADU trends, including permits currently under review, and are reflective of the changes in State law and the City’s ability to streamline review and approval of applications.

Brentwood 2023-2031 Housing Element
Appendix B: Candidate Sites Analysis B-4
Table B-2: Accessory Dwelling Units Past Performance and Future Projections Year ADU Permitted and Projected
2019 9
2020 20
2021 16
2022 12
Annual Projection (2023-2030) 14 per year*
2023 14
2024 14
2025 14
2026 14
2027 14
2028 14
2029 14
2030 14
Projection Period Total 112
*Estimate based on the average of ADUs permitted between 2019 and 2021.

Additionally, to facilitate the development of ADUs available for lower-income households, Program H.1b is included in the Housing Plan. For the purposes of Sites Inventory, the City assumes a percentage of ADUs will be affordable based on the Using ADUs to Satisfy RHNA Technical Memo, produced by the Association of Bay Area Governments (ABAG). ABAG’s analysis consisted of the following steps to finalize proportions:
 Calculated maximum rent limits for RHNA income categories for one-person and two person households by county;
 Surveyed rents for ADUs in the ABAG region;
 Used survey data to determine proportion of ADUs within each income category; and  Created assumption of how many persons will occupy each ADU.

Using ABAG’s analysis, Table B-3 shows estimated ADU projections for Brentwood by income category.

Table B-3: Accessory Dwelling Unit Projections by Income Category Income Category Percentage Units
Low- and Very Low-Income 60% 66
Moderate-Income 30% 34
Above Moderate-Income 10% 12
Total 112 units

Brentwood 2023-2031 Housing Element
Appendix B: Candidate Sites Analysis B-5

3. Projects in the Pipeline
HCD guidance defines pipeline projects as residential projects that are approved, permitted, or receive a certificate of occupancy after the beginning of the RHNA period, and states that they may be credited toward meeting the RHNA based on the affordability and unit count of the development. Table B-4 shows eight projects in the pipeline totaling 968 units, including two low-income units and 966 above moderateincome units.

Also shown in Table B-4, the average time between a project receiving entitlements and submitting an application for Building Permits is just under 60 days. This is a quick turnaround time, which illustrates the markets interest in getting projects approved and built as quickly as possible. As such, it is not considered a constraint to development.

Table B-4: Projects in the Pipeline1
Project Name
Project
Status
(April 2022)
Map
ID
Planning
Approval
Submittal
for
Building
Permits
Projected Units
Very LowIncome LowIncome Moderate -
Income
Above
ModerateIncome Total
Cowell Ranch
Marsh Creek Road Approved 11 8/28/18 N/A 0 0 0 140 140
Parkside Villas
(formerly Seasons at
Parkside)
1925 Apricot Way
Under
Construction 12 2/1/22 3/22/22 0 0 0 37 37
Amber Lane
Apartments
South of Amber Ln.
and west of Shady
Willow Ln.

Under
Construction 13 1/14/20 1/28/20 0 0 0 288 288
Bennett Estates
3405 O’Hara Avenue
Under
Construction 18 6/1/21 8/5/21 0 0 0 14 14
Chandler
2800 Empire Ave.

Under
Construction 14 12/4/18 4/1/20 0 0 0 160 160
Kindred & Balfour
131 Summerset Dr.

Under
Construction 15 6/2/21 6/15/21 0 0 0 86 86
Orchard Trails
South of Continent
Ave. and west of
Walnut Blvd.

Under
Construction 16 11/10/20 12/1/20 0 2 0 75 77
Silvergate Apartments
South of Sand Creek
Rd. and east of O’Hara
Ave.

Under
Construction 17 12/5/17 6/4/18 0 0 0 166 166
Orchard Grove
Adams Lane and
Gracie Lane
Approved 18 9/13/22 11/10/22 0 1 5 45 51
Total Projected Units 0 3 5 1,011 1,019
1 Project unit projections are planning-level assumptions and are subject to change. Table is based upon available data at the time the draft document was prepared.

Brentwood 2023-2031 Housing Element
Appendix B: Candidate Sites Analysis B-6
B. Very Low- and Low-Income Sites Inventory
This section contains a description and listing of the sites identified to meet the City’s very low- and lowincome allocation.

1. Strategy for Accommodating Very Low- and Low-Income RHNA Existing Zoning and Land Use
HCD has identified 30 dwelling units per acre as the default density, or feasible density to accommodate very low- and low-income housing applicable to Brentwood. The City has three land use designations that can accommodate residential development at this density, including the Residential – Very High Density (R-VHD) and two designations within the PA-1 Specific Plan– Transit Village (TV) and Multi-Family Very High Density Residential (MFVHDR). Parcels within these land use designations were analyzed for compliance with Assembly Bill 1397 (AB 1397) requirements and analyzed for vacancies or opportunity for redevelopment.

Existing vacant, residentially zoned parcels can accommodate 156 very low- and low-income units.

Utilizing the City’s existing residentially zoned land, Specific Plans, ADU assumptions, and projects in the pipeline, the City can accommodate 109 percent of the very low- and low-income allocation.

Priority Area One Specific Plan
The Priority Area One Specific Plan (PA-1) was recently updated in October 2022 and establishes development standards and design guidelines to create a mixed-use center that provides a wide array of opportunities for working, living, agriculture, and outdoor recreation in a pedestrian-friendly and aesthetically pleasing setting that attracts both local and regional residents. Three land use designations are projected to accommodate residential development on the site:
 Transit Village. The Transit Village designation is zoned to allow a minimum residential density of 25 dwelling units per acre with a maximum of 40 dwelling units per acre. Based on the existing general plan, density is projected at the midpoint of 32.5 dwelling units to the acre with a residential capacity of 75 percent.
 Multi-Family Very High Density. The Very High Density designation is zoned to allow a minimum residential density of 15 dwelling units per acre with a maximum of 35 dwelling units per acre.

Based on the existing general plan, density is projected at the midpoint of 25 dwelling units to the acre.
 High Density. The High Density designation is zoned to allow a minimum residential density of 10 dwelling units per acre with a maximum of 20 dwelling units per acre. Based on the existing general plan, density is projected at the midpoint of 15 dwelling units to the acre. No very lowand low-income affordable units anticipated in PA-1 are projected to develop within this designation (although this land use designation may provide moderate income units).

Based on the City’s affordability assumption of 35 percent it is expected that 464 affordable units will develop on identified parcels within the three land use designations. Total residential development included in the inventory, across approximately 67 acres in the three land use designations identified in the Specific Plan, is projected to be 1,526 units.