Brentwood 2023-2031 Housing Element
Appendix B: Candidate Sites Analysis B-7
Projects in the Pipeline
As shown in Table B-4, there are nine projects currently in the pipeline to realize a total of 1,019 units, including three deed-restricted low-income units and five deed-restricted moderate-income units. The table includes the status of these projects as of February 2023. The Orchard Trails project, which includes the two low-income units, is currently under construction, and the recently approved Orchard Grove project, which includes one deed-restricted low-income units and five deed-restricted moderate-income units. No further affordability information is available as of February 2023.
2. Calculation of Unit Capacity
Site-by-Site Calculation
The City has identified unit capacity on sites considering existing development and the feasibility of adding housing, development standards for the respective zone, and the feasible buildable acreage of the site.
Then unit capacity was calculated by multiplying the net acreage of the site (considering existing environmental issues and existing structures) by the assumed density. A sample site calculation for a site is shown below in Table B-5.
Table B-5: Sample Sites Calculation
Site Descriptor Data
Unique ID 2
APN 019032011
Zone PA-1 (MFVHDR)
Assumed Density 25 dwelling units/acre
Existing Use Vacant/seasonal agriculture
Existing Structures None
Buildable Acreage 4.75 acres
Total Net Units 118 units
Low/Very Low-Income Affordability Assumptions 35%
Low/Very Low-Income Unit Yield 41 units
Moderate-Income Affordability Assumptions 15%
Moderate-Income Unit Yield 18 units
Above Moderate-Income Unit Yield 59 units
Realistic Capacity
Development calculations for identified sites assume a mid-point density range so as to provide a conservative estimate.
For residential-only parcels, the mid-point density calculation roughly equates to 80 percent of the maximum density permitted. For example, candidate site #12 has a gross acreage of 3.39 and a permitted density between 20.1 and 30 units per acre; a mid-point density of 25 units per acre is assumed (80 percent of the maximum would be 24 units per acre), which results in 84 net units including 29 affordable to lower income (35 percent), 13 affordable to moderate income (15 percent), and 42 affordable to above moderate income (50 percent).
For mixed-use parcels, an additional 75 percent reduction is added to the mid-point density calculation to provide a further conservative estimate and avoid a potential no-net-loss situation should non-residential uses be developed (analysis in the following “Mixed-Use Capacity” section provides development trends showing residential development is largely favored over non-residential). For example, candidate site #4 has a buildable acreage of 5 and a permitted density between 25 and 40 units per acre; a mid-point density of 32.5 units per acre is assumed and a 75 percent reduction is added which results in 122 net units
Brentwood 2023-2031 Housing Element
Appendix B: Candidate Sites Analysis B-8
including 43 affordable to lower income (35 percent), 18 affordable to moderate income (15 percent), and 61 affordable to above moderate income (50 percent).
It should be noted that the City does not generally receive development applications at densities below the range allowed in residential zoning districts. Table B-6 shows that density yield in recent projects either meets or exceeds the maximum density permitted.
The majority of the development in Brentwood in recent years has been low-density single-family development. There have only been two higher density projects in the last ten years, which are included in the Pipeline projects and listed below as Silvergate and Amber Lane. Each of the projects have yielded 100 percent of the development capacity within their zone.
Silvergate – Pipeline Project 17
The site is designated by the General Plan as BBSP (Brentwood Boulevard Specific Plan). The BBSP contains several different use categories, also known as district zones. The subject property is part of the COIR (Commercial/Office/Industrial/Residential) zone, which allows high density residential, with a density range from 11 to 20 dwelling units per acre, while commercial, office, and light industrial development is also allowed. The proposed development is an apartment complex consisting of 166 units on 8.3 acres, for a density of 20 units per acre achieving a yield of 100 percent of the maximum allowed by the underlying zoning. No commercial, office, or light industrial development was proposed as part of the project.
Amber Lane – Pipeline Project 13
The site is designated by the General Plan Land Use Map as Priority Area – 1 (PA-1). The project site is located within the PA-1 Specific Plan area’s High Density Residential (HDR) zone with an allowable density range from 10 to 20 dwelling units per acre. The proposed development is an apartment complex consisting of 288 units on 14.4 acres, for a density of 20 units per acre achieving a yield of 100 percent of the maximum allowed by the underlying zoning. Orchard Grove – Pipeline Project 18
The site is designated by the General Plan Land Use Map as R-VLD (Residential-Very Low Density). The project site is located within the R-1-E (Single Family Residential) zone with an allowable density range from 1.1 to 3 dwelling units per acre. The proposed development is a detached single-family development consisting of 51 single-family homes, for a density of 3.03 units per acre. The application included one deed-restricted low-income unit and five deed-restricted moderate-income units to qualify as a Density Bonus project to achieve a yield of 101 percent of the maximum allowed by the underlying zoning.
To supplement regional data, the neighboring city of Antioch has approved several multi-family projects in recent years, including two with yields over 100 percent (Table B-6). The AMCAL project is a 100 percent affordable project. A senior density bonus request was approved to achieve of yield of 106 percent of the maximum allowed by the underlying zoning.
Overall, recent project yields ranged from 80 percent to 106 percent of the allowed density, with an average yield of 94 percent. In Brentwood alone, the 100 percent capacity assumption is deemed reasonable given these trends.
Brentwood 2023-2031 Housing Element
Appendix B: Candidate Sites Analysis B-9
Table B-6: Regional Residential Development Yields
Project Acres Zoning
Allowed
Density
(DU/AC)
Units
Built
Density
(DU/AC)
Yield Status
Brentwood
Silvergate 8.3 COIR 11-20 166 20 100% Under
Construction
Amber Lane 12.4 PA-1
(HDR) 11-20 288 20 100% Under Construction
Orchard Grove 16.8 R-1-E 1.1-3 51 3.03 101% Entitled 2022 Antioch
AMCAL 14.9 R-25 25 394 26.5 106% Under
Construction
Wildflower Station
(Multi-Family) 7 P-D As Built 98 14 N/A Completed 2020
Wildflower Station
(Single-Family) 4.5 P-D As Built 22 4.9 N/A Completed 2020 Almond Knolls 2.9 R-20 20 58 20 100% Completed 2020
Deer Valley Estates 37.6 P-D 3.6 121 3.22 89% Entitled 2021 The Ranch 253.5 P-D As Built 1,177 4.6 Entitled 2020
Quail Cove 5.6 P-D 6 30 5.4 90% Completed 2021
Oakley Knolls 5.6 P-D 6 28 5 83% Under
Construction
Creekside Vineyard
at Sand Creek 59 P-D 4.6 220 3.7 80% Entitled 2021
Average Yield 94%
Average Yield Excluding P-D Zones 101%
Source: City of Antioch and Urban Planning Partners, 2022.
MIXED-USE CAPACITY
Five sites have been identified as part of the PA-1 Specific Plan which allow for both residential and commercial uses. The PA-1 (TV) zone requires ground-floor commercial on all multi-family residential projects. Density for standalone residential projects in the TV zone is 25 to 40 dwelling units per acre; for mixed-use projects, the residential/commercial mix ratio is a required first floor full commercial and a minimum 10 percent of the total project for commercial. As detailed in the section above, the assumed density for these sites includes a mid-point calculation (32.5 units per acre) plus an added reduction of 75 percent for the required commercial components. A total of 592 units are possible on these five sites, including 207 affordable to lower income households.
Projects listed in Table B-7 include one project zoned mixed-use currently under construction with a 100 percent unit yield – resulting in 166 units (Silvergate). Two additional projects with mixed-use zoning have submitted Preliminary Review applications and propose a total 690 units. Preliminary Review Application #1 proposes horizontal mixed-use with commercial on the first 150 feet along Brentwood Boulevard with a unit yield of 73 percent, or 93 percent net. Preliminary Review Application #2 proposes a mixed-use development with ground floor retail and 162 units 100 percent affordable to lower income households with a unit yield of 125 percent. In general, a 75 percent development capacity for mixed-use sites is considered feasible based on the City’s recent development history and large residential development interest. To further ensure the development of these five sites, Action H.1n is included in the Housing Plan
Brentwood 2023-2031 Housing Element
Appendix B: Candidate Sites Analysis B-10
to establish and implement a residential incentives program encouraging residential development on mixed use sites.
The PA-1 (TV) zone allows for 100 percent commercial uses. As listed above, Silvergate is the only comparable project in a mixed-use zone and it includes residential uses. The City has not received any development applications for commercial-only projects on sites that also allow residential uses.
Residential development continues to be the top interest within Brentwood. The City has now received three SB 330 Preliminary Applications on other similarly zoned mixed-use sites that allow for 100% commercial development yet have proposed 100 percent residential development. Furthermore, AB 2011 now paves the way for residential development in commercial zones and has already begun gaining interest from the development community, as detailed below.
AB 2011
In 2022, Governor Newsom signed into law the Affordable Housing and High Road Jobs Act (AB 2011), and the Bill went into effect on July 1, 2023. The bill makes affordable housing a by-right use on commercially zoned lands and mixed-income housing by-right along commercial corridors, as long as the projects meet specified affordability, labor, and environmental criteria.
As of August 2023, the City has already received one AB 2011 application on a commercial site proposing 33 units per density with 20 percent affordable units. This is the first application in Contra Costa County.
As part of the proposed project, the applicant is also seeking a density bonus for development concessions and waivers. This highlights the development potential and interest for residential development on parcels zoned commercial.
Affordability Assumptions
All sites identified with the appropriate zoning are assumed to develop with 35 percent of units affordable to very low- and low-income households. The goals of the 2023-2031 Housing Element include creating more opportunities for affordable housing and to work with the affordable housing development community to bring additional very low- and low-income housing opportunities to Brentwood.
While the City has had limited affordable housing development in past years, there has been a recent increase in proposed projects with affordable components, as well as City actions to increase access to housing for all segments of the population.
In 2020, the Affordable Housing Ordinance was modified to include affordability requirements for rental units and increase the affordability requirement from 2 percent to 10 percent. In 2022 the Ordinance was modified to increase the affordability requirement from 10 percent to 13 percent. Due to these updates, the City is currently processing seven projects that include the newly required ten to thirteen percent affordable unit requirements based on when the projects are deemed complete. As Table B-4 also shows, the Orchard Trails project is currently under construction and includes two deed-restricted units affordable to low-income households and the Orchard Grove project recently approved includes one deed-restricted low-income unit and five deed-restricted moderate-income units While past performance is limited, the City has made efforts to promote the development of housing affordable to Brentwood’s current and future residents. Through this Appendix, the City has identified sufficient land to accommodate the 2023-2031 RHNA for all income levels. The Section 4: Housing Plan also includes a number of programs that will assist in the development of affordable units throughout the 6 th Planning Cycle.
Brentwood 2023-2031 Housing Element
Appendix B: Candidate Sites Analysis B-11
3. Adequacy of Sites to Accommodate Very Low- and Low-Income Housing Vacant Sites
As part of the candidate sites inventory, the City has identified 4 sites which include very low- and lowincome units. The units on these sites represent 21.3 percent of the RHNA for very low- and low-income units. To identify this percent, the City used the following calculation:
(Lower income RHNA – lower income pipeline units – lower income ADU projections – lower income units on non-vacant sites)/lower income RHNA = lower income units on vacant sites (634 – 3 – 66 – 430) = 135/634 = 21.3 percent
It should be noted that 4 additional sites are vacant of structures and have improvement values of $0 but cannot be considered vacant due to their seasonal agricultural uses. Despite this classification, the property owners are working with developers to construct residential projects. The sites are not zoned for agriculture; however, the seasonal use allows the property owners to benefit from their land until they move forward with development. Were these sites considered vacant, the City would be able to claim
66.6 percent of its lower income units on vacant sites. More information on these properties is included in the following “Non-Vacant Sites” section.
Non-Vacant Sites
The City has identified five non-vacant sites to accommodate a portion of the lower income allocation.
These are sites over about 23 total acres, seasonally agricultural, and have five older residential units in total. The sites are entirely consolidated within PA-1, which is being developed as part of a master-planned development. In 2022, the City adopted amendments to PA-1, which had the support and involvement of the property owners who are also large landowners and developers within the community.
Historically, the City has fully developed on previously agricultural land. Brentwood and the surrounding area once represented a major agricultural center and the largest shipping point for grains between New Orleans and San Francisco. In the early 1900s Brentwood was a thriving township with much agricultural land for cattle, grains, fruits, and vineyards. By 1930, the area was producing thousands of acres of apricots, peaches, and cherries. At the onset of the Great Depression many farmers in midwestern states headed for California where they could find employment harvesting crops. Many of these families planted their roots in Brentwood and made the area their permanent home. In 1948, the City of Brentwood was incorporated. Initial development patterns throughout the City began east of the San Pablo Tulare railroad tracks and around the Train Station and Downtown Brentwood where City hall and the majority of the store were located. Growth later began to spread west with the rerouting of Highway 4 relocating traditional traffic patterns from Brentwood Boulevard to the Highway. What was once an entirely agricultural area, Brentwood has become a residential community.
Throughout the 5th Cycle, the City has approved seven applications for residential developments on previously agricultural land, and three additional Preliminary Review applications have been received. The seven projects include a total of 918 units.
The City has received two letters of support from the property owners of Candidate Sites 7, 8, and 9 – they are included in Appendix C. The letters state that Site 9 is currently in contract with a developer for the development of 8 of the 36 acre property for high density residential and the property owner of Sites 7 and 8 have signed a letter of intent with Alliance Residential Properties to sell a portion of their land for residential development.
Brentwood 2023-2031 Housing Element
Appendix B: Candidate Sites Analysis B-12
In sum, the five non-vacant sites identified do not present a significant constraint to the development of future housing.
Table B-7: Residentially Redeveloped Agricultural Land
Project Use Acres Zoning
Allowed
Density
(DU/AC)
Units Built/Proposed
Density Yield Status
1925 Apricot Way –
Parkside Villas
(Pipeline Project 16)
Agricultural
Land 10.76 PD-35 1.1-5 36 3.35 67% Under Construction
Orchard Grove –
(Pipeline Project 23)
Agricultural
Land 16.82 R-1-E 1.1 - 3 51 3.03 101% Approved
Amber Lane
Apartments (Pipeline
Project 17)
Agricultural
Land 14.4 PA-1 (HDR) 10-20 288 20 100% Under Construction Silvergate
Apartments (Pipeline
Project 21)
Agricultural
Land 8.3
BBSP
(COIR
Mixed
Use)
11-20 166 20 100% Under
Construction
Cowell Ranch
(Pipeline Project 15)
Agricultural
Land 29.19 PD-65 5 140 4.8 96% Approved
Orchard Trails
(Pipeline Project 20)
Agricultural
Land 25.57 PD-47 1.1-5 77 3 60% Under Construction
Chandler (Pipeline
Project 18)
SFR w/
Agricultural
Land
20 PD-38 5.1-11 160 8 72% Under
Construction
Preliminary Review 1
(Horizontal mixed
use with Commercial
first 150’ along
Brentwood Blvd)
SFR w/
Agricultural
Land
36.03 (28.27
net)
BBSP
(COIR
Mixed
Use)
11-20 528 14.54 (18.6
net)
73%
(93%
net)
Preliminary
Review
Preliminary Review 2
(Mixed-Use Project
with ground floor
retail and 100%
affordable units)
Multitenant
retail
building
6.5 BBSP
(COIR
Mixed
Use)
11-20 162 25 125% Preliminary
Review
Preliminary Review 3
(Only 8-acres are
currently allocated
as MFVHDR)
Agricultural
Land 12.8 PA-1 (MFVHDR) 15-35 219 17 49% Preliminary Review Replacement Analysis
The Sites Inventory includes five sites with existing residential units. All are within PA-1 and each contains a single rural housing unit. As such, Program H.1p is included in the Housing Plan to ensure demolished residential units occupied by lower-income households, or households subject to affordability requirements within the last five years, are replaced in compliance with Government Code Section 65915.
Identification of Small or Large Parcels
AB 1397 identifies parcels measuring between half an acre and ten acres to be appropriate for the development of affordable housing units. Parcels that are less than half an acre (“smaller”) or above 10 acres (“larger”) are not deemed adequate to accommodate lower income housing needs unless past performance shows a tendency for affordable housing projects to develop on smaller or larger sites.
Brentwood 2023-2031 Housing Element
Appendix B: Candidate Sites Analysis B-13
The City has not identified any small or large parcels to accommodate lower income units. Candidate Site #11, as part of the PA-1 Specific Plan, has a total of 13.3 acres of land identified for development capacity but no lower income housing units have been identified on this parcel. All parcels in the PA-1 Specific Plan will be parcelized prior to residential development; the Specific Plan has an adopted land use map which includes designating the acreage for each type of use and subdistrict. More details on the Specific Plan are available in Section 3 of this Housing Element.
However, the City has recently received Preliminary Review Applications for a 12-acre high-density residential development within PA-1, as well as a 28-acre high-density residential development elsewhere in the City. Recent trends have also shown that with the approval in Brentwood of the Amber Lane pipeline project, which is situated on a 14.4 acre parcel, and the recently approved 15 acre 100 percent affordable development in Antioch, there is a high level of developer interest in larger sites.
C. Moderate- and Above Moderate-Income Sites Inventory
This section contains a description and listing of the sites identified to meet Brentwood’s moderate- and above moderate-income allocation.
1. Strategy for Accommodating Moderate and Above Moderate-Income Allocation
Utilizing pipeline projects, projected ADU development, Specific Plans, and existing residential zoning, the City can fully accommodate Brentwood’s 247 unit moderate-income and 641 unit above moderateincome allocation.
Existing Zoning and Land Use
Existing vacant, residentially zoned parcels can accommodate 68 moderate- and 222 above moderateincome units. Utilizing the City’s existing vacant, residentially zoned land, Specific Plans, ADU assumptions, and projects in the pipeline, the City can accommodate 136 percent of the moderate-income allocation and 324 percent of the above moderate-income allocation.
Priority Area One Specific Plan
As stated above, the PA-1 Specific Plan has three residential land use designations that can accommodate the entirety of the moderate- and above moderate-income RHNA. PA-1 can accommodate a total of 1,526 units – 229 of which are affordable to moderate-income households and 833 affordable to above moderate-income households.
Projects in the Pipeline
As shown in Table B-4, the City has nine projects in the pipeline to develop five moderate-income units and 1,011 above-moderate income units. Of these projects, two have received Planning approval and seven are currently under construction.
2. Calculation of Unit Capacity
Selection of Sites
The Sites Inventory contains a selection of sites that are most likely to be developed for moderate- and above moderate-income housing. For the purpose of identifying sites with the potential to be developed within the planning period, this analysis considered existing zoned parcels that permit residential as a primary use.
Brentwood 2023-2031 Housing Element
Appendix B: Candidate Sites Analysis B-14
For the purposes of this analysis, projected ADU assumptions were calculated separately as outlined within Section 2 above. ADUs represent additional potential units to meet the City’s RHNA.
Affordability Assumptions
All sites identified with the appropriate zoning are assumed to develop with 15 percent of units affordable to moderate-income households. The goal of the 2023-2031 Housing Element is to create more opportunities for affordable housing and to work with the affordable housing development community to bring additional moderate-income housing opportunities to Brentwood.
Assembly Bill 725
Assembly Bill 725 (AB 725) requires jurisdiction to identify at least 25 percent of their moderate- and above moderate-income RHNA on sites with zoning that allows at least four units of housing (and no more than 100 units for moderate-income).
The above moderate-income RHNA is fully accommodated for through projects in the pipeline. In additional, all candidate sites identified in Table B-8 permit multi-family residential developments with density ranges starting at ten dwelling units per acre and going up to 40 dwelling units per acre – in compliance with AB 725 requirements.
D. Affirmatively Furthering Fair Housing
As detailed in this Appendix, sites were selected based on availability of land, existing development plans, as well as propensity for development throughout the planning period. As it relates to affirmatively furthering fair housing, access to resources, services, and public transportation were considered for the location of lower-income units. Lower-income units are proposed though the PA-1 Specific Plan and Vacant Land, as illustrated in Figure B-1.
1. PA-1 Specific Plan Area
The PA-1 Specific Plan area will offer a variety of commercial and retail uses as it develops, as well as a many employment opportunities. A number of restaurants and retail uses are currently located along Lone Tree Way to the north and Sand Creek Road to the south. Trader Joe’s and Target Grocery stores are located north of the PA-1 area and Sprouts Farmers Market and Raley’s are located to the south.
For medical services, two pharmacies are located north of Lone Tree Way and a number of medical offices are within close proximity of the PA-1 area. Two elementary schools are also located in close proximity (Pioneer Elementary and Loma Vista Elementary). Bristow Middle School is located nearby, as are Independence High School and Liberty High School.
The PA-1 area 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.
In general, the area is well supported with resources and will continue to be as the PA-1 Specific Plan is developed.
Brentwood 2023-2031 Housing Element
Appendix B: Candidate Sites Analysis B-15
2. Vacant Residential Land
Candidate sites 12 through 14 are identified as currently vacant residential parcels and located south of Balfour Road and west of State Route 4. Just north of the area along Balfour Road are a few dinning and options, gas stations, and a bank.
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 sites, and the East Contra Costa Fire Protection District station is just north of Balfour Road.
Public transit is available to the north along Balfour Road. Route 385 connect 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.
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.
E. Summary of RHNA Status and Sites Inventory
The City has reviewed all sites for environmental concerns and considerations as well as development and land use restrictions. Additionally, each site has been reviewed for existing use; access to infrastructure, water, utilities; and additional development constraints. Where the analysis showed increased barriers to development related to environmental concerns, infrastructure concerns or existing conditions and development concerns (such as slope and grading, hazardous surrounding uses, restrictive development standards) the sites were removed. The result is a list and analysis of sites that are most ripe for development or redevelopment for housing.
F. Sites Identified to Accommodate RHNA and Maps
Figure B-1 below maps all sites identified to accommodate the City’s 2023-2031 RHNA. Table B-8 is the Sites Inventory sorted by Unique ID.
Brentwood 2023-2031 Housing Element
Appendix B: Candidate Sites Analysis B-16
Figure B-1: Sites Inventory Map
Brentwood 2023-2031 Housing Element
Appendix B: Candidate Sites Analysis B-17
Table B-8: Brentwood 6th Cycle Sites Inventory
ID APN Street Address Existing
Units Vacancy Gross Acreage
Buildable
Acreage
5 th
Cycle
Site
4 th
Cycle
Site
ZONING GPLU Assumed
Density
Net Potential
Units
Net Units by Income
Category Assumed Income
Category
Category
Existing Use and Additional
Information
Low Mod. Above
Mod.
Specific Plan Sites
1 019032010 2251 SHADY
WILLOW LN 1 No 4.80 4.80 No No PA-1 (MFVHDR) PA-1 25 120 42 18 60 Low and Very Low PA-1 This site is identified as part of
the PA-1 Specific Plan. It
contains an existing residential
unit and some land for
seasonal agricultural use.
Property owners have been
involved and in support of
redevelopment through PA-1.
2 019032011 2201 SHADY
WILLOW LN 0 No 4.75 4.75 No No PA-1 (MFVHDR) PA-1 25 118 41 18 59 Low and Very Low PA-1 This site is identified as part of
the PA-1 Specific Plan. It is
vacant with seasonal
agricultural use. The
improvement value for this site
is $0. Property owners have
been involved and in support
of redevelopment through PA1.
3 019032029 2301 SHADY
WILLOW LN 1 No 4.88 4.88 No No PA-1 (MFVHDR) PA-1 25 122 43 18 61 Low and Very Low PA-1 This site is identified as part of
the PA-1 Specific Plan. It
contains an existing residential
unit, storage for cars and parts,
and some land for seasonal
agricultural use. Property
owners have been involved and
in support of redevelopment
through PA-1.
4 019020059 5225 HEIDORN
RANCH RD 1 No 5.41 5.41 No No PA-1 (TV) PA-1 32.5 (x 75%) 122 43 18 61 Low and Very Low PA-1 This site is identified as part of
the PA-1 Specific Plan. It
contains an existing residential
unit and land for seasonal
agricultural use. Property
owners have been involved and
in support of redevelopment
through PA-1.
5 019020076 5305 HEIDORN
RANCH RD 1 No 4.20 4.20 No No PA-1 (TV) PA-1 32.5 (x 75%) 102 36 15 51 Low and Very Low PA-1 This site is identified as part of
the PA-1 Specific Plan. It
contains an existing residential
unit, an equine pasture, and
land for seasonal agricultural
use. Property owners have
been involved and in support
of redevelopment through PA1.
6 019020083 5315 HEIDORN
RANCH RD 1 No 4.00 4.00 No No PA-1 (TV) PA-1 32.5 (x 75%) 98 34 15 48.5 Low and Very Low PA-1 This site is identified as part of
the PA-1 Specific Plan. It
contains an existing residential
Brentwood 2023-2031 Housing Element
Appendix B: Candidate Sites Analysis B-18
Table B-8: Brentwood 6th Cycle Sites Inventory
ID APN Street Address Existing
Units Vacancy Gross Acreage
Buildable
Acreage
5 th
Cycle
Site
4 th
Cycle
Site
ZONING GPLU Assumed
Density
Net Potential
Units
Net Units by Income
Category Assumed Income
Category
Category
Existing Use and Additional
Information
Low Mod. Above
Mod.
Specific Plan Sites
unit and vacant land. Property
owners have been involved and
in support of redevelopment
through PA-1.
7 019081024
HEIDORN
RANCH RD 0 No 48.9 7.1 No No PA-1 (TV) PA-1 32.5 (x 75%) 173 60 26 86.5 Low and Very Low PA-1 This site is identified as part of
the PA-1 Specific Plan. It is
vacant with seasonal
agricultural use. The
improvement value for this site
is $0. Property owners have
been involved and in support
of redevelopment through PA1 – letter of support for
residential development on
this site is included in Appendix
C.
8 019081024
HEIDORN
RANCH RD 0 No 48.9 7 No No PA-1 (MFVHDR) PA-1 25 175 61 26 88 Low and Very Low PA-1 This site is identified as part of
the PA-1 Specific Plan. It is
vacant with seasonal
agricultural use. The
improvement value for this site
is $0. Property owners have
been involved and in support
of redevelopment through PA1 – letter of support for
residential development on
this site is included in Appendix
C.
9 019081021 HEIDORN
RANCH RD 0 No 35.7 8 No No PA-1 (MFVHDR) PA-1 25 200 70 30 100 Low and Very Low PA-1 This site is identified as part of
the PA-1 Specific Plan. It is
vacant with seasonal
agricultural use. The
improvement value for this site
is $0. Property owners have
been involved and in support
of redevelopment through PA1 – letter of support for
residential development on
this site is included in Appendix
C.
10 019020055 HEIDORN
RANCH RD 0 Yes 4 4 No No PA-1 (TV) PA-1 32.5 (x 75%) 98 34 15 49 Low and Very Low PA-1 This site is identified as part of
the PA-1 Specific Plan. It is
entirely vacant. Property
owners have been involved and
in support of redevelopment
through PA-1.
Brentwood 2023-2031 Housing Element
Appendix B: Candidate Sites Analysis B-19
Table B-8: Brentwood 6th Cycle Sites Inventory
ID APN Street Address Existing
Units Vacancy Gross Acreage
Buildable
Acreage
5 th
Cycle
Site
4 th
Cycle
Site
ZONING GPLU Assumed
Density
Net Potential
Units
Net Units by Income
Category Assumed Income
Category
Category
Existing Use and Additional
Information
Low Mod. Above
Mod.
Specific Plan Sites
11 019092046 2483 OLD SAND
CREEK RD 1 No 32.6 13.3 No No PA-1 (HDR) PA-1 15 199 0 30 169 Moderate PA-1 This site is identified as part of
the PA-1 Specific Plan. It
contains an existing residential
unit, barn, and land for
seasonal agricultural use.
Property owners have been
involved and in support of
redevelopment through PA-1.
Vacant Residential Sites
12 010840010 JOHN MUIR
PKWY 0 Yes 3.39 - Yes Yes PD (R-VHD) R-VHD 25 84 29 13 42 Low and Very Low Vacant
Land
Entirely vacant site
13 010840011 JOHN MUIR
PKWY 0 Yes 6.81 - Yes Yes PD (R-VHD) R-VHD 25 170 60 26 84 Low and Very Low Vacant
Land
Entirely vacant site
14 010840012 JOHN MUIR
PKWY 0 Yes 7.70 - Yes Yes PD (R-VHD) R-VHD 25 192 67 29 96 Low and Very Low Vacant
Land
Entirely vacant site
Pipeline Projects
15 007380002 Marsh Creek
Road 0 Yes 28 - No No PD-64 PD 5 140 0 0 140 Above Moderate Pipeline Seasonally agricultural land
identified as part of the Cowell
Ranch pipeline project which
has received Planning approval.
16 019092032 1925 Apricot
Way 0 Yes 10.76 - Yes Yes PD-35 R-LD 3 37 0 0 37 Above Moderate Pipeline Vacant site identified as part of
the Parkside Villas pipeline
project which has received
Planning approval.
17 019031006
South of Amber
Lane and west
of Shady
Willow Lane
0 Yes 14.43 - No No PA-1 (HDR) PA-1 20 288 0 0 288 Above Moderate Pipeline Previously vacant site currently
under construction as part of
the Amber Lan Apartments
pipeline project.
18 018740116 2800 Empire
Avenue 0 Yes 0 - No No PD-38 PD - 160 0 0 160 Above Moderate Pipeline Previously vacant site currently
under construction as part of
the Chandler pipeline project.
19 010440152 131 Summerset
Drive 0 Yes 0 - No No PD-21 PD - 86 86 Above Moderate Pipeline Previously vacant site currently
under construction as part of
the Kindred & Balfour pipeline
project.
20 016300138
South of
Continente
Avenue and
west of Walnut
Boulevard
0 Yes 0.83 - No No PD-42 PD - 77 2 75 Low and Very Low Pipeline Seasonally agricultural land
currently under construction as
part of the Orchard Trails
pipeline project.
21 016120025
South of Sand
Creek Road and
east of O'Hara
Avenue
0 Yes 8.31 - Yes No BBSP BBSP 20 166 0 0 166 Above Moderate Pipeline Previously vacant site currently
under construction as part of
the Silvergate Apartments
pipeline project.
22 018090012 3405 O'Hara
Avenue 0 Yes 5.0 - Yes Yes R-1-10 R-LD - 14 0 0 14 Above Moderate Pipeline Previously vacant site currently
under construction as part of
Brentwood 2023-2031 Housing Element
Appendix B: Candidate Sites Analysis B-20
Table B-8: Brentwood 6th Cycle Sites Inventory
ID APN Street Address Existing
Units Vacancy Gross Acreage
Buildable
Acreage
5 th
Cycle
Site
4 th
Cycle
Site
ZONING GPLU Assumed
Density
Net Potential
Units
Net Units by Income
Category Assumed Income
Category
Category
Existing Use and Additional
Information
Low Mod. Above
Mod.
Specific Plan Sites
the Bennett Estates pipeline
project.
23 016040005
East of Adams
and north of
Gracie Lane
0 Yes 16.82 - Yes Yes R-1-E R-VLD - 51 1 5 45 Low and Very Low Pipeline As part of the Orchard Grove
pipeline project.
Brentwood 2023-2031 Housing Element
Appendix C: Summary of Community Engagement C-1
Summary of Community Engagement
Appendix C
Brentwood 2023-2031 Housing Element
Appendix C: Summary of Community Engagement C-2
Appendix C: Summary of Community Engagement
Section 65583 of the Government Code states, “local government shall make diligent effort to achieve public participation of all economic segments of the community in the development of the housing element, and the program shall describe this effort.” Meaningful community participation is also required in connection with the City’s Assessment of Fair Housing (AF). As such, a summary of community participation is included within this Appendix.
Appendix C Contents
A. Summary of Community Engagement
C.1 Joint City Council and Planning Commission Workshop C.2 Online Community Survey
C.3 Joint City Council and Planning Commission Workshop C.4 City Council Meeting
C.5 City Council and Community Meeting
C.6 Planning Commission Meeting
C.7 City Council Meeting
C.8 Flyers/Outreach Materials
C.9 Public Review Draft
A. Outreach Efforts
As part of the 2023-2031 Housing Element Update process, the City conducted a variety of outreach and engagement efforts beginning in Spring 2022. A summary of community engagement and outreach for the 2023-2031 Housing Element is outlined below:
• Housing Element Update Webpage: A webpage was created to provide background information and guide the public to outreach events and resources throughout the course of the update process and is translatable in multiple languages. The website provides information about the update process, key features of the housing element, recorded meetings, a project timeline, resources, and contact information. The website also provided a link to the community survey as well as a contact form for interested persons to sign up for the email list and provide comments to the Housing Element Update team.
The website is available at: https://brentwoodhousingelement.com/. • Joint Planning Commission and City Council Workshop: On April 14, 2022, Staff presented to Planning Commission, City Council, and members of the public during a joint workshop. The presentation provided introductory information on the Housing Element Update process, details on the City’s RHNA allocation, and key milestones. The agenda item was organized to solicit input and recommendations from Planning Commission, City Council, and members of the public. Live Spanish translation was provided during the workshopand both the English and Spanish, including all presentation materials being presented in both English and Spanish during the meeting.
Recordings of the meeting in both English and Spanish are available on the Housing Element
Brentwood 2023-2031 Housing Element
Appendix C: Summary of Community Engagement C-3
local markets in both English and Spanish in order to encourage public involvement. In addition, social media posts were published in both English and Spanish multiple times prior to the hearing. Online Community Survey: From April 2022 to June 2022, the City released an online community survey to solicit feedback and input on housing conditions in the City for the purpose of developing policy programs. The survey was made available in English and Spanish; it was linked on the Housing Element Update webpage and advertised to the community through the water bill in both English and Spanish, City Newsletter, posted flyers in neighborhood serving businesses in both English and Spanish, email blasts, and social media posts with paid targeted advertising to special needs populations and the local Spanish speaking community. Advertisements were also posted on social media by local organizations who serve the City’s special needs population such as the Village Community Resource Center as well as emails to all parents within the Brentwood Unified School District in both English and Spanish.
Joint Planning Commission and City Council Workshop: On June 1, 2022, Staff presented to Planning Commission, City Council, and members of the public during a joint workshop. The presentation provided a summary of RHNA and the proposed sites strategy, as well as changes in Housing Element Law. The agenda was organized to solicit input from Planning Commission, City Council, and members of the public. Live Spanish translation was provided during the workshop and both the English and Spanish recordings of the meeting are available on the Housing Element Update webpage.
City Council Workshop: On July 21, 2022, Staff presented the City Council with updated RHNA sites strategy options. The presentation detailed three different strategies and the implications of each. The agenda was organized to solicit feedback from the Council and receive a recommendation on which strategy to move forward with. Live Spanish translation was provided during the workshop and both the English and Spanish recordings of the meeting are available on the Housing Element Update webpage.
City Council and Community Meeting: On August 30, 2022, Staff informed the City Council of the available Public Review Draft Housing Element and presented details on how the candidate sites inventory had been revised to incorporate feedback received. The meeting also provided meeting attendants with details on where to find the Draft and how to provide feedback through the public review period. Live Spanish translation was provided during the meeting and both the English and Spanish recordings of the meeting are available on the Housing Element Update webpage. Planning Commission Meeting: On September 20, 2022, Staff presented the Planning Commission with an information update on the Housing Element update and the available Public Review Draft. The goal of the meeting was to solicit feedback from the Planning Commission. City Council Meeting: On September 27, 2022, Staff presented the City Council with a final version of the Draft 6th Cycle Housing Element and summary of comments received on the Public Review Draft. The intent of the meeting was to gather final feedback on the sites inventory and to receive approval from the City Council to submit the Draft Housing Element to HCD for review. HCD Revisions Draft: Following revisions to the Draft 6th Cycle Housing Element addressing comments made by HCD, the City made the Draft available to the public for a 7-day public review.
This included outreach to stakeholders and interested parties to notify them of the available draft.
Brentwood 2023-2031 Housing Element
Appendix C: Summary of Community Engagement C-4
Planning Commission Hearing: On February 28, 2023, the Planning Commission held a special meeting to consider a recommendation to the City Council on an amendment to the General Plan to update the Housing Element for the 2023-2031 (6th Cycle). City Council Hearing: On March 14, 2023, the City Council adopted an amendment to the General Plan to update the Housing Element for the 2023-2031 (6th Cycle). Multilingual Outreach: Multilingual outreach was identified by the Brentwood City Council as a top need at the very beginning of the outreach process. As such, the City made public meetings and workshops available in Spanish, and all public outreach materials were also made available in Spanish. In addition, public hearing notices and agendas for all meetings were also posted in both English and Spanish as well as posted on all City social media outlets. Direct Outreach to the Community: The City has conducted direct outreach to various community groups, developers, stakeholders, and interested community members throughout the Housing Element update process. This has included advertising for public meetings and workshops, surveys, and draft releases. The intent of the outreach was to solicit the participation and feedback from all community members. The following lists the organizations and companies that were contacted throughout the process in advance of every community meeting and public hearing, in addition to 207 individual community members:
o BRIDGE Housing
o Christian Church Homes of
Northern California (CCHNC)
o Ecumenical Association For
Housing (EAH)
o Eden Housing
o First Community Housing (FCH)
o Hijas Del Campo
o Mercy Housing of California
o MidPen Housing Corporation
(MidPen)
o Resources for Community
Development
o Satellite Affordable Housing
Associates
o Sunflower Hill
o Meta Housing
o Village Community Resource
Center
o Blackhawk Properties
o Bradford Communities
o Building Industry Association
Bay Area
o Carlson Barbee and Gibson
o Century Communities
o D. R. Horton
o Denova Homes
o Discovery Builders
o Integral Communities
o Isakson and Associates
o K. Hovnanian Homes
o KB Homes
o Lyon Homes
o Martin Land Company
o Meritage Homes
o Mission Peak Company
o Nuvera Homes
o Pulte Homes
o Richland Communities
o Shea Homes
o Signature Homes
o Strauss Design
o The Grupe Company
o The True Life Companies
o Tri Pointe Homes
o Van Daele Homes
o Westgate Ventures
o Wood Rodgers
Brentwood 2023-2031 Housing Element
Appendix C: Summary of Community Engagement C-5
This Appendix contains all public comments regarding the Housing Element received by the City at scheduled public meetings. As required by Government Code Section 65585(b)(2), all written comments regarding the Housing Element made by the public have previously been provided to each member of the City Council.
Brentwood 2023-2031 Housing Element
Appendix C: Summary of Community Engagement C-6
C.1 Joint City Council and Planning Commission Workshop This section contains all materials created for the April 14, 2022, joint Planning Commission and City Council workshop. Participants had the opportunity to make public comments verbally or in written form through the Zoom chat. A recording of the workshop is available in both English and Spanish on the Housing Element Update webpage: https://brentwoodhousingelement.com/.
2023-2031 Housing Element Update
Joint Planning Commission and City Council Meeting
The City of Brentwood is currently updating its 2023-2031 Housing Element.
The State-required Housing Element plans for the City’s housing needs at all income levels and establishes policies and programs that comply with State laws. All cities across the State are required to update their Housing Elements every 8 years to account for changes in community needs and new laws. Please join us virtually to learn about the update process, State requirements, and what opportunities the community has to provide input and give feedback.
When: Thursday April 14, 2022 at 6:00PM
Where: Zoom - https://brentwoodca-gov.zoom.us/j/76013970037 Please also help us better understand your housing needs and provide initial feedback on housing conditions in Brentwood by completing this survey:
https://forms.office.com/r/KYZjmQDjA5
For more information about the Housing Element Update please visit:
www.brentwoodhousingelement.com
Actualización del Elemento de Vivienda 2023-2031
Reunión conjunta de la Comisión de Planificación y el
Consejo de la Ciudad
En estos momentos, la Ciudad de Brentwood está actualizando su Elemento de Vivienda 2023-2031. El Elemento de Vivienda requerido por el Estado planifica las necesidades de vivienda de la Ciudad en todos los niveles de ingresos y establece políticas y programas que cumplen con las leyes estatales.
Todas las ciudades del Estado están obligadas a actualizar su Elemento de Vivienda cada 8 años para tomar en cuenta los cambios en las necesidades de la comunidad y las nuevas leyes. Acompáñenos en forma virtual para aprender sobre el proceso de actualización, los requisitos del Estado, y las oportunidades que tiene la comunidad para aportar información y ofrecer opiniones.
Cuándo: Jueves, 14 de abril de 2022 a las 6:00 p.m.
Dónde: Zoom - https://brentwoodca-gov.zoom.us/j/76013970037 Le pedimos también que nos ayude a entender mejor sus necesidades de vivienda y brinde información inicial sobre las condiciones de vivienda en Brentwood, contestando esta encuesta:
https://forms.office.com/r/KYZjmQDjA5
Para obtener más información sobre la actualización del Elemento de Vivienda, conéctese a: www.brentwoodhousingelement.com
APRIL 14, 2022
CITY COUNCIL/PLANNING COMMISSION WORKSHOP AGENDA
*IMPORTANT NOTICE ABOUT PUBLIC COMMENTS AND MEETING PARTICIPATION* UPDATED, MARCH 17, 2022
Consistent with Contra Costa County Health orders, and in accordance with California Government Code Section 54953(e) concerning teleconference meetings, this joint City Council/Planning Commission meeting will be held exclusively via teleconference, using the Zoom video conferencing system. At this time, public participation will be available exclusively via telephone or teleconference, using the Zoom video conferencing system.
How to View and Participate
The public is invited to participate in the City Council/Planning Commission meeting and offer comments of up to 3 minutes (or as may otherwise be determined by the Council/Commission) using any of the following methods:
1. Zoom: www.brentwoodca.gov/vcc or Zoom Webinar ID: 760 1397 0037 As the City Council Chamber will not be open to the public, individuals may view and participate in the meeting with this link. During the meeting, each period for public comment will be announced, and participants may use the “Raise Hand” feature on Zoom to request to speak. The meeting host will call on you, by name, and microphone when it is your turn to speak. In order to ensure the orderly administration of the meeting using this method, providing your name is encouraged, but is not required. (If you need instructions on how to use this feature, please contact the City Clerk by noon of the meeting date at [email protected] or 925.516.5182.)
The public may view the meeting via one-way video feed by selecting the video option at the City Council Agendas’ link on the City webpage at www.brentwoodca.gov
2. Telephone
If you wish to comment during the meeting via telephone, you may “raise your hand” virtually on most devices by pressing *3, and you will be called upon when it is your time to speak. After speaking, please press *3 again to remove the “raise your hand” feature. If that feature does not work on your device, please email [email protected] in advance of the meeting where possible. The request must contain in the subject line “Request to Speak – Agenda Item #” and should include name and full phone number that will be used to call in. In order to ensure the orderly administration of the meeting using this method, providing your name is encouraged, but is not required.
3. E-mail
Public comments can also be submitted via e-mail to [email protected]. Any public comments received up until 3:00 p.m. of the meeting date will be:
§ distributed to the Council/Commission via email before the meeting, § posted online for public inspection at https://www.brentwoodca.gov/councilmeetingonline, and
§ later summarized in the meeting minutes.
Public comments received after 3:00 p.m. of the meeting date, but prior to the start of the meeting, will be emailed to the City Council/Planning Commission, posted online within one day following the meeting, and will be summarized in the meeting minutes. The City cannot guarantee that its network, website, and/or the Zoom system will be uninterrupted. In the event of an interruption to the broadcasting of the meeting using the telephone or internet-based
APRIL 14, 2022
CITY COUNCIL/PLANNING COMMISSION WORKSHOP AGENDA
options listed above, the City Council/Planning Commission will take no further action on items on the agenda until public access to the meeting via either option is restored. To ensure that the City Council/Planning Commission receives your comments prior to taking action, you are strongly encouraged to submit them in advance of the meeting by 12:00 p.m.
As e-mails containing public meeting comments are part of the official record, note that personal contact information may be published if it is included with your e-mail.
The Closed Captioning provided via Zoom is auto generated it is not the official record and is provided as a convenience
Pursuant to Section 54956 of the California Government Code, a special joint meeting for a workshop of the
City Council and the Planning Commission
is hereby called for:
6:00 p.m. on Thursday, April 14, 2022
Immediately following the staff presentation,
public comment will be taken.
WORKSHOP
1. Call to Order/Roll Call: A Workshop of the City Council and Planning Commission
2. Introduction of the 2023-2031 Housing Element Update and 6th Cycle Regional Housing Needs Allocation, and community engagement opportunities. (Alexis Morris/Jennifer Hagen)
3. Adjournment
Any disclosable public records related to an agenda item for the open session of this meeting distributed to all or a majority of the City Council/Planning Commission less than 72 hours before this meeting will also made available for review on the City’s website at www.brentwoodca.gov/councilmeetingonline.
NOTICE
In compliance with the Americans with Disabilities Act, if you are a person with a disability and you need disability-related modifications or accommodations to participate in this meeting, please contact the City Clerk's Office at (925) 516-5440 or fax (925) 516-5441. Notification 48 hours prior to the meeting will enable the City to make reasonable arrangements to ensure accessibility to this meeting. {28 CFR
35.102-35, 104 ADA Title II}
POSTING STATEMENT
On April 6, 2022, a true and correct copy of this agenda was posted on the City Hall Bulletin Board, outside City Hall, 150 City Park Way, Brentwood, CA 94513 and at our website www.brentwoodca.gov A complete packet of information is available for public review at City Hall or on our website at www.brentwoodca.gov
JOINT WORKSHOP AGENDA ITEM NO. 2
Meeting Date: April 14, 2022
Subject Title: Introduction of the 2023-2031 Housing Element Update and 6th Cycle Regional Housing Needs Allocation process, including review of the draft Community Engagement Plan and report on the status of the current (5th Cycle) Housing Element, as well as overview of recent changes to Housing Element law
Prepared By: Jennifer Hagen, Senior Planner
Submitted By: Alexis Morris, Community Development Director Erik Nolthenius, Planning Manager
PURPOSE AND RECOMMENDATION
This introductory workshop serves as an official launch for the Housing Element Update and includes an introduction to Kimley-Horn, who will be assisting staff with this effort. The workshop will provide for public comments, staff presentation, and the City Council and Planning Commission discussion on an overview of the Housing Element Update process, including an update on the 6th Cycle Regional Housing Needs Allocation (RHNA) process, a report on status of the current (5th Cycle) Housing Element, and changes to Housing Element law since the last update.
PREVIOUS ACTION
The City Council authorized execution of an agreement for consulting services with Kimley-Horn to assist with the 2023-2031 (6th RHNA Cycle) Housing Element Update on October 12, 2021.
BACKGROUND
What is a Housing Element?
The Housing Element is one of seven mandated elements of the City’s General Plan and is a comprehensive statement by the community of its current and future housing needs and proposed actions to facilitate the provision of housing to meet those needs at all income levels.
Rising housing costs are not just a statewide or regional issue, but directly impact Brentwood residents and those faced with rising housing prices and increased incidence of homelessness.
Periodic updating of the Housing Element is required by State law; and thus, the Element reflects the State’s housing goal of "attaining decent housing and a suitable living environment for every California family," as well as incorporating the unique concerns of the community. The current Housing Element, which was adopted by the City Council and certified by the State in 2015, covers the planning period from 2015 to 2022 (the 5th Cycle). The next Housing Element Update (the 6th Cycle) must be adopted by January 2023, to address the period from 2023- 2031.
State law establishes a series of very specific requirements as to the scope, content, and process by which a Housing Element is updated and adopted, including review and approval
2 (known as certification) by the California Department of Housing and Community Development (HCD).
Unlike the majority of the other required General Plan elements, the Housing Element must include very specific information to pass legal muster. In accordance with State law, Brentwood’s Housing Element must look at housing trends, zoning and market constraints, and evaluate various approaches to meeting housing needs across income levels. The inventory of available sites, or “Sites Inventory,” will be a key component of a Housing Element in which the City must identify land zoned for housing to meet the RHNA. Local governments must involve the public from all economic segments of the community in developing the Housing Element; a robust public outreach plan is discussed in this memo and is anticipated to be a key component of the project.
What Are the Components of a Housing Element?
State law defines the required content of the Housing Element, with key components including:
1. Housing Needs Assessment: Examine demographic, employment and housing trends and conditions that affect the housing needs of the community.
2. Evaluation of Past Performance: Review the prior Housing Element to measure progress in implementing policies and programs.
3. Affirmatively Furthering Fair Housing (AFFH): Review to ensure that City regulations, programs and activities affirmatively further fair housing, and create meaningful actions, in addition to combating discrimination, that overcome patterns of segregation and foster inclusive communities free from barriers that restrict access to opportunity based on protected characteristics.
4. Housing Sites Inventory: Identify locations of available sites for housing development or redevelopment to ensure that there is adequate capacity to address the RHNA.
5. Community Outreach and Engagement: Implement a robust community outreach and engagement program, with a particular focus on outreach to traditionally underrepresented groups.
6. Constraints Analysis: Analyze and recommend remedies for existing and potential governmental and nongovernmental barriers to the maintenance, improvement, and development of housing for all income levels. The analysis must specifically determine whether local regulatory standards impose an actual constraint on housing development and show local efforts to remove constraints that may hinder the City from meetings its housing needs.
7. Policies and Programs: Establish policies and programs to fulfill the identified housing needs.
During the Housing Element Update, the City Council, Planning Commission, and the public will have the ability to provide input on each key project milestone.
The timely development and implementation of a Housing Element Update is essential to avoid the serious ramifications that come from failing to do so. Among these consequences could be the inability of the City to qualify for certain state or federal funding programs for transportation, infrastructure, and housing; shortened deadlines for completing any necessary rezones associated with Housing Element Law compliance; and findings that the City is not in substantial compliance with the Housing Element Law pending any required rezoning.
Annual Progress Report and Progress Towards RHNA
Each year, the City is required to provide an Annual Progress Report (APR) to the State, which reports housing unit production compared to RHNA targets, as well as describes the status of the various policies and programs included in the Housing Element. The report was presented
3 to the City Council at its March 22nd meeting. Table 1 summarizes the RHNA and the overall production of housing for the current cycle. In the current (5th) cycle, 74 affordable (very low-, low- and moderate-income) units have been produced thus far, which is about 15 percent of the total affordable allocation of 481 units.
Table 1: Current Cycle (2015-2023) RHNA Progress
Income Level RHNA
Allocation 2015 2016 2017 2018 2019 2020 2021 Total
Units
Total
Remaining
Very Low
DR
234
- - 2 - - - 2
4 230
NDR - - - - - - -
Low DR
124
5 3 - - - - -
11 113
NDR - - - - 3 - -
Moderate
DR
123 - - - - - - - 59 64
NDR - - 1 22 - 20 16
AboveModerate 279 449 540 503 323 321 268 724 3,128 -
Total RHNA 760
Total Units 454 543 506 345 324 288 742 3,202 407
DR = Deed Restricted
NDR = Not Deed Restricted
Key Changes in Housing Element Law
In recent years, the State has adopted significant new housing-related legislation, which will influence and shape the upcoming Housing Element Update. These include but are not limited to:
· Housing Crisis Act (SB 330) - Makes changes to land use and zoning law to encourage housing production, by limiting the scope of local review of housing projects to objective standards only for qualifying projects; limiting the ability of cities to change the general plan land use designation, specific plan land use designation, or zoning to a less intensive use or reduce the intensity of land use within an existing general plan land use designation, specific plan land use designation, or zoning district below that which was in effect on January 1, 2018; limiting the number of public hearings for projects; and shortening review timeframes.
· Streamlined Ministerial Approval Process (SB 35) - Requires a streamlined ministerial approval process for development in cities that have not yet made sufficient progress towards their allocation of their RHNA. Eligible developments must include a specified level of affordability, be on an infill site, comply with existing residential and mixed-use general plan or zoning provisions, and comply with other requirements. · Adequate Housing Element Sites (AB 1397) - Strengthens local governments’ obligation to identify a supply of adequate sites available to meet their share of regional housing needs at all income levels.
· Accessory Dwelling Units (Multiple bills) – In recent years, the State has facilitated the development of accessory dwelling units (ADUs) by adopting and updating laws limiting local regulation of this housing type. These may be counted toward a local agency’s RHNA through the processes established by HCD. · No Net Loss (SB 166) - Requires jurisdictions to maintain adequate sites to always accommodate its remaining regional housing needs allocation throughout the housing element planning period, rather than only at adoption.
4 · Affirmatively Furthering Fair Housing - AFFH (AB 686) - Requires Housing Elements to demonstrate the local jurisdiction is affirmatively furthering fair housing. Specifically, AFFH requires taking meaningful actions that, taken together:
o Address significant disparities in housing needs and in access to opportunity o Replace segregated living patterns with truly integrated and balanced living patterns
o Transform racially and ethnically concentrated areas of poverty into areas of opportunity, and
o Foster and maintain compliance with civil rights and fair housing laws. · Housing Element Enforcement (AB 72) - Allows HCD to review any action or lack of action by a jurisdiction that is allegedly inconsistent with its housing element. HCD can revoke housing element compliance and notify the Attorney General.
The new legislation has reinforced local governments’ obligation to identify a supply of adequate sites available to meet their RHNA share at all income levels. Further, under the rubric of No Net Loss, it requires jurisdictions to maintain adequate sites to continuously accommodate their remaining RHNA throughout the Housing Element planning period, instead of only at adoption.
Therefore, a site that is zoned for a certain number of units must provide that number of units at the allocated affordability level; if a development project is approved for a fewer number of units the remaining number of units must be allocated to a different site, resulting in “no net loss” of units.
In addition, the State laws require additional analysis of AFFH and fair housing and segregation, placing a greater obligation on the City to demonstrate that the City is affirmatively furthering fair housing. This will require a large amount of staff and consultant time and effort to demonstrate that our outreach efforts are going beyond simply giving the public an opportunity to provide input and will be proactive and broadly conducted through a variety of methods to assure access and participation. In a growing effort by the state to increase accountability and enforcement of these new state laws and to better address the housing needs of Californians, as part of the 2021-2022 state budget, HCD increased its accountability efforts and formed the Housing Accountability Unit (HAU). The HAU will be in charge of holding jurisdictions accountable for their housing element commitments, as well as with other state housing laws.
Violations of these state laws may lead to consequences including revocation of housing element certification and/or referral to the California Office of the Attorney General. 6th Cycle RHNA Process and Status
As part of the Housing Element update, HCD requires each jurisdiction in the state to demonstrate capacity to meet their local “fair share” of the assigned Regional Housing Needs Determination (RHND), including total housing units across a series of affordability categories.
The RHNA is then determined and assigned through a process led by HCD and regional Councils of Governments (for the Bay Area, this is ABAG/MTC). The City of Brentwood has been allocated a total of 1,522 units for the upcoming cycle.
Table 2 summarizes the current RHNA in comparison to 5th Cycle allocations. As the estimate shows, the projection would more than double the number of units assigned in the current cycle.
Compared to the 5th Cycle, Very-Low and Low-income allocations together increase by 276 units, and the Above-Moderate income category by 362 units.
5 Table 2: 6th Cycle RHNA and Comparison to 5th Cycle
5th Cycle RHNA
(2015-2022)
6th Cycle RHNA
(2023-2031)
Category Units Units Comparison
to Cycle 5
Very Low 234 402 +168
Low 124 232 +108
Moderate 123 247 +124
Above-Moderate 279 641 +362
TOTAL 760 1,522 +762
DISCUSSION
Housing Element Process and Schedule
The Housing Element Update began in November 2021, and will be drafted throughout 2022 and early 2023. It will reflect a robust process with significant engagement with the public, key stakeholders, the City Council and the Planning Commission throughout, to ensure a community-wide conversation about housing policy, future housing sites, and strategies and actions to meet the City’s assigned RHNA. Staff and the consultant have been diligently working on the extensive outreach efforts that are ready to be launched to seek initial input on the Housing Element Update, including this initial community meeting/joint workshop with the City Council and Planning Commission, communication with key stakeholders (such as housing developers and community services providers), and an online community survey.
A simplified schedule with key dates is shown in Table 3 below. Initial steps in the process began in November 2021. As the project proceeds through the summer, there will be an extensive review of existing housing conditions, policies, and programs for inclusion in the Housing Element. Critical to the process will be the sites inventory, whereby sites to accommodate the City’s RHNA allocation will be analyzed. Following completion of the sites analysis, the public review draft of the Housing Element will be created, and taken through a review process that incorporates a required review by HCD, as well as input from the City Council and Planning Commission.
Table 3: Project Schedule
Task Month
Introductory Kick-Off Meeting with City Council and
Planning Commission
April 2022
Community Survey April 2022
Prepare Technical Studies, Housing Needs,
Constraints and Resources Baseline Review
February – May 2022
Stakeholder and Focused Community Outreach May-June 2022 Community Workshop - Land Use Strategies and
Housing Policies
May-June 2022
Start of Public Review Draft 30-Day Review Period* June - July 2022 Start of HCD 90-Day Review Period August - September 2022 Public Hearings to adopt Housing Element December 2022 - January 2023 * New this cycle, if any comments are received during the Public Review Period, the City must take at least 10 business days to consider and incorporate public comments.
6 Housing Element Public Engagement Plan
Staff and Kimley-Horn have prepared a Community Engagement Plan that outlines several outreach activities over the duration of the Project. Currently, the Engagement Plan describes the majority of the outreach activities as virtual events given the COVID-19 restrictions that were in place at the onset of the Housing Element Update process. Although the majority of the activities are currently described as virtual, staff is in discussion with Kimley-Horn regarding how future activities may transition to in-person. Since the current contract with Kimley-Horn did not include in-person appearances, and since their staff is based in different regions throughout the State, staff is evaluating whether an additional contract amendment may be required to accommodate in-person meetings. Community outreach efforts have now begun and will continue through the adoption of the Housing Element Update in 2023. The public will have many opportunities to obtain information and provide input in a variety of ways, including:
• Project website;
• Community workshops;
• Informational handouts;
• Housing Element Public Review Draft;
• City Council and Planning Commission Joint Sessions; and • Final Public Hearings with Planning Commission and City Council.
The Engagement Plan identifies dedicated community meetings, held in a workshop format, to provide information and seek broad community input in the process. The outreach activities have been designed to engage a wide representation of the Brentwood community. The Engagement Plan includes efforts to target the engagement of community members who have not traditionally participated in community outreach events and may be harder to reach.
Creative methods to engage senior citizens, those for whom English is not their first language, persons with limited access to technology, those living in disadvantaged areas, and other underrepresented groups in Brentwood will be included in the Engagement Plan.
Outreach and Communication Tools
The Housing Element Update website will serve as the primary medium through which community members access information and project documents and learn about the Housing Element Update. The website will be user-friendly and updated regularly to include content that will reflect public engagement opportunities as they are scheduled and material available for public review. The website has been created with a project-specific URL to identify with the project: BrentwoodHousingElement.com
The website will allow a convenient access point for interested parties to sign up to be notified about future meetings and upcoming events and will include pages dedicated to public engagement, project documents, and “Frequently Asked Questions.” In addition, the website will provide opportunities for interactive involvement through an on-line survey and other tools.
These will occur alongside more traditional methods of outreach such as press releases, print media, and other publicity.
The project website and most outreach materials for the community meetings will also be provided in English and Spanish, with opportunities for Spanish-speaking engagement during each meeting through interpretation services for all virtual meetings and/or in-person meetings.
If the City Council determines that other language translation is appropriate, this can be accommodated. Although translation services were not fully scoped as part of the Housing Element Update contract with Kimley-Horn, funding for initial translation services have been identified. Funding for the remainder of the translation services planned for is currently being
7 evaluated. All Project materials, recordings, and summaries will be provided on the Project website for community accessibility as well.
To aid in soliciting participation from disadvantaged communities, the City is in the process of identifying interested parties and stakeholders to be regularly engaged, as well as to aid in soliciting participation from their organizations and members. City staff will then continue to communicate and engage with participating community members and stakeholders throughout the update process including notification of all public meetings and hearings.
FISCAL IMPACT
There is no financial impact anticipated as a result of this initial discussion. The cost of the update was included as part of the adopted 2021/22 – 2025/26 Capital Improvement Program which included the Housing Element Update (CIP Project No. 337-37258) with subsequent amendment to the 2021/22 Operating Budget approved by the City Council on October 12, 2021.
Attachment A - “What is a Housing Element?” (English and Spanish versions), based on ABAG Regional Technical Assistance
State law does not require that
jurisdictions build or finance new housing,
but they must plan for it.
Every city in California receives a target
number of homes to plan for. This is
called the Regional Housing Needs
Allocation or RHNA.
The state of California determines the
number of new homes the Bay Area
needs to plan for – and how affordable
those homes need to be – in order to
meet the housing needs of people at all
income levels.
The Association of Bay Area
Governments convened diverse
stakeholders in a Housing Methodology
Committee to distribute the region’s
housing allocation to each jurisdiction in
the Bay Area.
Housing elements must be updated every
eight years and must be certified by the
California Department of Housing and
Community Development.
A Housing Element is a local plan, adopted
by a city, town or county that includes the
goals, policies and programs that direct
decision-making around housing.
All jurisdictions in the Bay Area must
update their Housing Element for the 2023-
2031 planning period. Local jurisdictions
look at housing trends, zoning and market
constraints, and evaluate various
approaches to meeting housing needs
across income levels.
The Inventory of Available Sites, or “Sites
Inventory,” is a key component of a
Housing Element where jurisdictions
identify if they have enough land zoned for
housing to meet the future need.
Local governments must involve the public
from all economic segments of the
community in developing the Housing
Element.
What is a
Housing Element?
A Housing Element is how local jurisdictions plan to meet the housing needs of everyone in the community. At its core a Housing Element is an opportunity to have a community conversation about how to address local housing challenges and find solutions. The Housing Element is one important part of a city or county’s General Plan, which serves as the blueprint for how a city or county will grow and address changing needs for development. Every eight years, every city, town and county must update their Housing Element and have it certified by the California Department of Housing and Community Development.
Source: ABAG Regional Technical Assistance
The Housing Element typically includes:
1. Housing Needs Assessment: Examine demographic, employment and housing trends and conditions that affect the housing needs of the community.
2. Evaluation of Past Performance: Review the prior Housing Element to measure progress in implementing policies and programs.
3. Housing Sites Inventory: Identify locations of available sites for housing development or redevelopment to ensure that there is adequate capacity to address the Regional Housing Needs Allocation.
4. Community Outreach and Engagement: Implement a robust community outreach and engagement program, with a particular focus on outreach to traditionally underrepresented groups.
5. Constraints Analysis: Analyze and recommend remedies for existing and potential governmental and nongovernmental barriers to housing development.
6. Policies and Programs: Establish policies and programs to fulfill the identified housing needs.
What Happens if a Jurisdiction Does Not Adopt a Housing Element? If a city does not comply with State law, it can be sued. In addition to facing significant fines, a court may limit local land use decision-making authority until the jurisdiction brings its Housing Element into compliance. Additionally, local governments may lose the right to deny certain projects. These and other consequences are established in state law; Housing Elements are subject to regulatory oversight by the California Department of Housing and Community Development. ABAG does not play a direct role in regulating local Housing Elements.
What are the
Components of a
Housing Element?
Source: ABAG Regional Technical Assistance
La ley estatal no obliga a las jurisdicciones a
construir o a financiar nuevas viviendas, sin
embargo, deben planificarlas.
Cada ciudad en California recibe un número
objetivo de hogares que debe planificar. A
esto se le llama Asignación Regional de
Vivienda Necesaria (RHNA, por sus siglas en
inglés).
El estado de California determina el número
de hogares que el Área de la Bahía necesita
planificar, y qué tan accesibles en precio
esos hogares necesitan ser, para poder
cumplir con las necesidades de vivienda de
las personas a todo nivel de ingreso.
La Asociación de Gobiernos del Área de la
Bahía convocó a una variedad de partes
interesadas en un Comité de Metodología de
Viviendas para distribuir la asignación de
viviendas de la región a cada jurisdicción en el
Área de la Bahía.
Los elementos de vivienda deben
actualizarse cada ocho años y deben ser
certificados por el Departamento de Vivienda
y Desarrollo Comunitario de California.
Un Elemento de Vivienda es un plan local,
aprobado por una ciudad, pueblo o condado,
que incluye las metas, las políticas y los
programas que dirigen la toma de decisiones
en temas de vivienda.
Todas las jurisdicciones en el Área de la Bahía
deben actualizar su Elemento de Vivienda
para el período de planificación 2023-2031.
Las jurisdicciones locales analizan tendencias
de vivienda, la zonificación y limitaciones del
mercado, y evalúan diversos enfoques para
satisfacer las necesidades de vivienda para
personas de todos los niveles de ingresos.
El Inventario de sitios disponibles (Inventory of
Available Sites), o "Inventario de Sitios", es un
componente clave de un Elemento de
Vivienda en el que las jurisdicciones
identifican si tienen suficientes terrenos
zonificados para viviendas para satisfacer la
necesidad futura.
Los gobiernos locales deben invitar la
participación del público de todos los
segmentos económicos de la comunidad
durante el desarrollo del Elemento de
Vivienda.
¿Qué es un Elemento
de Vivienda (Housing
Element)?
Un Elemento de Vivienda es la manera en que las jurisdicciones locales planean cómo satisfacer las necesidades de vivienda de todos los miembros de la comunidad.
Fundamentalmente, un Elemento de Vivienda es una oportunidad para tener una conversación con la comunidad sobre cómo abordar los retos locales de vivienda y encontrar soluciones. El Elemento de Vivienda es una parte importante del Plan General de una ciudad o condado, que sirve como proyecto de cómo una ciudad o condado crecerá y abordará las necesidades cambiantes de desarrollo. Cada ocho años, cada ciudad, pueblo y condado debe actualizar su Elemento de Vivienda y obtener la certificación del Departamento de Vivienda y Desarrollo Comunitario de California.
Source: ABAG Regional Technical Assistance
El Elemento de Vivienda suele incluir:
1. Evaluación de las necesidades de vivienda: Examinación de las tendencias y condiciones demográficas, de empleo y de vivienda que afectan las necesidades de vivienda en la comunidad.
2. Evaluación de desempeño anterior: Analizar el Elemento de Vivienda anterior para medir el progreso de implementación de políticas y programas.
3. Inventario de los sitios de vivienda: Identificar la ubicación de los sitios disponibles para el desarrollo o la renovación de viviendas para garantizar que haya una capacidad adecuada para abordar la Asignación Regional de Vivienda Necesaria.
4. Divulgación y participación comunitaria: Implementar un programa sólido de divulgación de información y participación comunitaria, con un enfoque particular en la participación de los grupos tradicionalmente subrepresentados.
5. Análisis de las limitaciones: Analizar y recomendar soluciones para las barreras gubernamentales y no gubernamentales existentes y potenciales en el desarrollo de viviendas.
6. Políticas y programas: Establecer políticas y programas para satisfacer las necesidades de vivienda identificadas.
¿Qué sucede si una jurisdicción no adopta un Elemento de Vivienda? Si una ciudad no cumple con la ley estatal, se le puede demandar. Además de hacerse acreedor de multas significativas, la ciudad podría ver limitada por un tribunal su autoridad en la toma de decisiones sobre el uso del suelo local, hasta que la jurisdicción cumpla con su Elemento de Vivienda. Asimismo, los gobiernos locales pueden perder el derecho a rechazar determinados proyectos. Estas y otras consecuencias están establecidas en la legislación estatal; los Elementos de Vivienda están sujetos a la supervisión normativa del Departamento de Vivienda y Desarrollo Comunitario de California. La ABAG no tiene un rol directo en la regulación de los Elementos de Vivienda locales.
¿Cuáles son los
componentes de un
Elemento de Vivienda?
Source: ABAG Regional Technical Assistance
Brentwood 2023-2031 Housing Element
Appendix C: Summary of Community Engagement C-7
C.2 Online Community Survey
This section contains the online community survey results and the outreach materials related to it. The survey was open from April to June 2022.
2023-2031 Housing Element Update
Community Survey
The City of Brentwood is currently updating its 2023-2031 Housing Element which establishes policies and programs to address housing needs at all income levels throughout the community.
For more information about the Housing Element Update please visit:
www.brentwoodhousingelement.com
Make your voices heard! Take the
Housing Element Community Survey
Be the first to fill out our Housing Element
Update Community Survey. The feedback
provided in the survey will help inform and plan
for the future of housing in Brentwood and is
intended to assist in creating policies and
programs that appropriately address the housing
needs of current and future Brentwood residents.
Actualización del Elemento de Vivienda 2023-2031
Encuesta de la comunidad
La Ciudad de Brentwood está preparando actualmente el Elemento de Vivienda de 2023-2031, el cual establece políticas y programas para abordar las necesidades de vivienda en todos los niveles de ingresos en toda la comunidad.
Para obtener más información sobre la actualización del Elemento de Vivienda, conéctese a:
www.brentwoodhousingelement.com
Sea el primero en completar nuestra Encuesta
comunitaria de actualización de Elementos de
Vivienda. La retroalimentación proporcionada en
la encuesta ayudará a informar y planificar el
futuro de la vivienda en Brentwood y está
destinada a recopilar comentarios e identificar
tendencias sobre las preferencias de vivienda, las
necesidades y las futuras oportunidades de
vivienda en la ciudad.
¡Haz que tus voces sean escuchadas! Responda la
Encuesta Comunitaria del Elemento de Vivienda
City of Brentwood
2023-2031 Housing Element Update
CommunitySurvey Report
On April 1, 2022, the City of Brentwood launched an online community survey to gather input and feedback regarding potential policy programs and housing needs within the community. The survey was available through June 10, 2022, on the Housing Element Update website. In total, the survey gathered 514 responses; below is a summary of the responses.
Housing Types
1. What housing types do you think are missing in Brentwood? (Select as man as applicable) When asked what housing types are missing in Brentwood, respondents believed that affordable housing, single-family housing, and accessory dwelling units (ADUs) were missing most. Respondents believe that affordable housing is the housing type that is missing most in Brentwood. The responses indicate that the community may be favorable to increased affordable housing options in the City. Respondents also believed that more single-family housing would benefit the City and its residents. This responses indicates that ADUs may be an important housing type to increase affordable housing options in Brentwood.
Respondents were given an “Other” option where they could provide comments and feedback that were not listed above. A summary of those comments is provided below:
• A majority of respondents who selected “Other” mentioned that there was enough housing in Brentwood and they did not want more housing to be built in the City. Most respondents did not provide reasons why they did not want any new housing in the City. A few respondents cited traffic and essential infrastructure limitations as the reason why new housing should be limited or stopped. Others believed that the City is overbuilt or overpopulated and did not need new housing. Two respondents believed that a growth moratorium would be beneficial to the City. • Some respondents provided comments suggesting that Brentwood needs more townhouses, condos, and condos for sale. The respondents indicated that although there are condos in the City, many are for low-income residents or for rent. Others believe that the existing condos may not be in safe locations. Question #1 had “Apartment/Condos” as an option, and it was the sixth 0 50 100 150 200 250 300 350
Accessory Dwelling Units (ADUs)
Affordable Housing
Apartments/Condos
Housing for Persons with Disabilities
Mixed-Income Housing
Multi-Generational Housing
Senior Housing
Single-Family Housing
Supportive or Transitional Housing
City of Brentwood
2023-2031 Housing Element Update
highest grossing option. The respondent feedback may indicate a need for townhomes and condos.
• Some respondents believed that Brentwood needs more “high-end” and exclusive communities with higher-income homes. Other respondents believed that there is a need for more singlefamily homes with bigger lots and ranches. • The rest of the respondents believe that the City has a sufficient mix of all housing types that meets the needs of Brentwood residents. Some suggested that because the City has a sufficient mix of housing types, there should be an emphasis on providing more restaurants, amenities, entertainment attractions, and activitiesfor residents instead of building more homes. There is a sentiment that there has been too many gas stations constructed in the Brentwood and there should be a greater variety of land uses.
See Attachment 1 for detailed responses.
2. Of the housing types listed above, please rank which you would like prioritized in future development. (First choice being the most important and last choice being the least important) Single-Family Housing
Affordable Housing
Housing for Persons with Disabilities
Accessory Dwelling Units (ADUs)
Senior Housing
Apartments/Condos
Multi-Generational Housing
Mixed-Income Housing
Supportive or Transitional Housing
3. What type of housing would you like to see more of – for sale or for rent? 7%
62%
31%
For Rent
For Sale
Both
City of Brentwood
2023-2031 Housing Element Update
Housing Programs
4. Community Assistance - This section will help us in developing policy programs to help households access information and/or funding assistance. Please rate the following based on importance to the community. (1 being the least important and 5 being the most important) Homebuyers assistance
Housing rental assistance
Property maintenance
Housing information
5. Fair Housing - This section will help us in developing programs to assist special needs groups in accessing housing that meets their particular needs and is affordable to all income levels. Please rate the following based on importance to the community. (1 being the least important and 5 being the most important)
Promote fair housing
Senior Housing Programs
Persons with disabilities
Supportive Housing
City of Brentwood
2023-2031 Housing Element Update
6. Which of the following special needs groups listed below do you believe are most in need of housing and/or related services in Brentwood? (Select as many as applicable)
7. Please describe your vision for the future of housing in Brentwood.
Respondents were asked to describe their vision for the future of housing in Brentwood. A summary of the responses is provided below.
Many respondents shared a common interest in the development of all housing types at all income levels for both sale and rent. Many respondents believe that there is a need for more dense, affordable housing throughout the City. Some respondents shared their frustration with not being able to afford rent or a mortgage in Brentwood even with an above median salary. Others highlighted the fact that first time homebuyers and young professionals cannot find homes for sale at reasonable prices. The most common needs were for affordable housing and “workforce” housing in order to house low income, young, or seniors. A lack of affordable and mid-level housing has forced many to be overburdened with housing costs. Some respondents placed emphasis on equitable distribution of housing types in Brentwood. Many believe that it is important to develop a variety of housing types at various income levels and disburse them around the City so as not to concentrate housing types or income levels in specific areas.
Many respondents believe that it is important to develop dense, mixed-use housing in the downtown area because it creates a welcoming, walkable area for those living nearby. Overall, most respondents in favor of higher density housing also believed that condos, townhouses, and apartments were the best housing type for Brentwood. Respondents believe that higher density development will reduce housing costs which they believe is required. Some respondents support denser housing types but believe that it is important to limit dense, mixed-use housing to the downtown area to prevent negatively affecting the neighborhood character.
Many others are opposed to any housing development. Most cited congestion, overcrowding, housing costs, crime, and a loss of neighborhood character as reasons why any new housing development should be stopped or limited. A common theme was the idea that Brentwood is not equipped with adequate infrastructure, services, and resources to accommodate a larger population. Many fear that a larger population will increase congestion, pollution, and crime. Some current residents are open to some 0 50 100 150 200 250 300
Seniors (65+ years)
Large households (5 or more members)
Persons with disabilities
Persons experiencing homelessness
Female-headed households
Farmworkers
Students
Veterans
Other
City of Brentwood
2023-2031 Housing Element Update
housing types over others. Some oppose all housing development because they believe that the City is built out enough and any new development will negatively affect the neighborhood character.
A common theme amongst some respondents is the emphasis on preserving the existing farmland and agriculture culture in Brentwood. Some respondents voiced their concern of a loss of farmland. Many stated that they moved to Brentwood to live in a rural, agricultural, neighborhood but they now feel like that is lost. Many respondents believe that housing developments are the reason for the loss of farmland and agricultural character. Some respondents support responsible, thought-out housing developments that do not encroach on open space or farmland. A majority of those in support of farmland preservation do not oppose housing so long as it does not reduce or jeopardize existing farmland.
Many respondents support the development of higher-income single family homes that can support families with higher incomes. Some believe that Brentwood has placed too much emphasis on low-income and high-density housing and not enough on high-income housing. Some respondents desire bigger homes with more open space and privacy. Some respondents believe that low-income housing reduces the desirability of Brentwood and do not support more of it.
Some respondents shared a desire to have more amenities such as parks, open space, and attractive commercial centers in Brentwood. Many believe that there are enough gas stations, car washes, and convenience stores and not enough attractive, quality stores and commercial centers. Some believe that Brentwood does not offer enough amenities and entertainment. One respondent believes that Brentwood can become a place people want to visit if the City attracts commercial center development.
A similar sentiment is that if Brentwood’s population increases, there is a need for more quality stores to serve the population.
See Attachment 2 for detailed responses.
8. Do you live or work in Brentwood? 9. Are you a renter of homeowner? 65%
3%
31%
0% 1%
I live in Brentwood
I work in Brentwood
Both
I own property in Brentwood that I rent to others
Neither
11%
87%
1% 1%
Renter Homeowner Neither Other
City of Brentwood
2023-2031 Housing Element Update
10. What is your age?
8%
34%
32%
26%
Less than 18 years
18-34 years
35-49 years
50-64 years
65 years or older
City of Brentwood
2023-2031 Housing Element Update
Attachment 1: Mission Housing Types Written Comments
Table 1 – Missing Housing Types
Brentwood is already full of all types of houses.
Create a growth moratorium cap
Don't need more housing
Executive Housing Upper income
Gated multi-million dollar homes
Have too many already.
High end custom or semi-custom single family homes
homes with side yards and back yards!!!
I don’t think we need anymore houses
I think w have enough housing. We are exceeding out road loads as it is. Balfour, O’Hara, Brentwood blvd not design for this much traffic. Please stop building If you want good feedback, you should include a definition of these terms.
Just condos
Just condos for purchase not low income
Meet employed Brentwood residents needs.
N/A. No new houses
New housing with larger lots
NO MORE HOUSES !!!
No more housing
No more housing is required. The housing is outpacing the infrastructure.
No more housing. We don’t have the water or electricity No opinion
no type of housing is missing
None
None - city is becoming overcrowded
None - need construction permit limits
None - STOP BUILDING
None - Too many people here already
None of the above
None of the above
None of the above, feel there is sufficient mix of all housing types None of these, stop trying to lower the value of my home None unless mandated by law.
None!!
None, no more houses needed
None, Brentwood is overpopulated
None, start building more restaurants and things to do. All you do is build houses and gas stations None, we have enough already built and planned
None, we have too much housing as is, with such few EMS resources and traffic logistics.
City of Brentwood
2023-2031 Housing Element Update
Table 1 – Missing Housing Types
None, we need to stop building
None. There shouldn’t be more added
None. Too many houses
None-too much housing
not missing any
Nothing. We have enough
Overbuilt already
Ranches
single family homes on large lots
Stop Building
There are enough houses in Brentwood
There too many houses in Brentwood.
Too many houses already
Too many houses already.
unable to locate nice condos or townhouses in a good land safe location to purchase!!!!! We do not need more housing. We need more businesses, restaurants, and amenities. That does not include gas stations or car washes.
We have enough houses. Preserve agriculture.
We have enough housing. Let go for zero growth to preserve our beauty and agricultural heritage We seem to have all of them covered.
City of Brentwood
2023-2031 Housing Element Update
Attachment 2: Vision for the Future Written Comments
Table 2 – Vision for the Future
I want Brentwood to prioritize taking care of the property we have now including lots and open spaces. I agree with the planning that brought our community to where it is. I don’t want more building. **this form with numbering 5 being most important is confusing usually 1 is most important.
Green, functional, one story homes, simple but attractive.
Homes that are not built so close together with larger green space between. So many streets in the developments of Brentwood are full of
driveways with no on street parking or adequate placement for trash bins. Solar systems should be on every house which includes car charging units Brentwood should create programs that provide grants for homeowners to add solar to existing homes. Also builders should be required to have solar systems and car charging units on all new homes. New home roof lines should be designed large enough to allow for best placement of solar panels that provide adequate and efficient electrical supply. Rainwater catchment systems should be included with every new build. This water could supply sprinkler systems for gardens and landscaping. 25% of new homes should be priced for low to moderate income home buyers. Sound proofing for all new housing.
Build Live Work mixed use housing that would bring small businesses of all types including trades, tech, artists.
Every person living in Brentwood or from Brentwood and trying to live there is considered a citizen of Brentwood no matter what their immigration status. The city will provide them affordable housing even if it must be a campground set up for long term stays.
Good mix of housing, including housing that is accessible for retail and other essential service industry workers, geographically dispersed equitably throughout the city, especially close to retail centers and schools
More attention to productive members of the community, especially veterans and seniors.
Bringing more young families to area to help Brentwood thrive. Bringing more AFFORDABlE housing for seniors on a fixed income with quality living arrangements that satisfy the needs of seniors. What is currently available DOES NOT meet the needs of aging, independent seniors! Affordable housing for types of income
Family community center for all ages -let’s all age in Brentwood! More affordable renting. We’ll be moving in September and our rent will go up by $400-$800…and all we need is a 4 bed house with a bed/bath downstairs for my mom.
Balanced and vibrant
Variety of homes!
Housing type and size constructed according to well developed plan that considers traffic volume and services availability.
Provide resources for homeless, have multiple dwelling developments in appropriate areas, and encourage ADUs to assist with the housing shortage in the area.
Currently I believe Brentwood is on correct path
No homelessness
The Innovation Center's East District should contain "mixed-use" with 3-4 floors of housing above ground floor commercial space. We need to diversify the housing types in the city so households will have a choice and not have to settle for purchasing traditional single family homes. There are
City of Brentwood
2023-2031 Housing Element Update
Table 2 – Vision for the Future
millennials (under the age of 40) and empty nesters who do not wish to own nor tend to yards, etc. who would be more inclined to rent in a densely mixed-use community. affordable
It currently appears Brentwood is addressing a wide variety of housing markets (lots of apartments, high-end homes, etc). It would be nice to see more ADUs in the mix.
All levels of housing. There needs to be a way to build housing that persons with one income can live in Brentwood! My daughter is a first year teacher and cannot afford any apartment currently in Brentwood
Slow steady growth
Don't punish people by raising the assessed value of their home just because they make improvements/repairs/additions or remodel to accommodate changing family needs (ie. a family member becomes disabled, or just because an adult child needs to live at home due to lack of affordable housing). A tax break for doing this would be even better, but at the bare minimum, don't make it cost prohibitive and difficult. Thanks for asking! I love Brentwood. I love the connection to the farms and the land, and to family. Farm to table.
Farmers Market. Supporting local. Sustainable. I'm not interested in seeing big city. Dense housing.
Section 8. Crime. Grunge. Drugs. Trash. Uncaring people. Creating environments that alienate people.
I love the mix of old homes downtown with the new. Character. A place to relax and call home, and a place to also work hard and nurture great children and food for the nation and the world. Did you know that Brentwood corn is a specialty dish in London? I have rented and owned all my life. Renters can be a mixed bag when they don't "own" property.
What I prefer to see: Renters/owners/seniors in ADUs, small-footprint homes, duplexes, and even shared housing, where the inhabitants actually have an "investment" in their abode and surroundings, and can feel less alienated without paying a fortune for housing. When people don't have a stake in their home, they tend not to care about their home and what's around them. I also would like to see more ADU and AirBNB activity for seniors, students, for people who just can't afford or don't have the time to upkeep a massive home, and for tourism too, of course. When you live "small" and "simple", you tend to have more time and more funds to enjoy and participate in your community. I think a mix of "small" with "big" could help address the gaps and debates in the "fair housing" divide. Also, it's very hot here, and at times very windy. We need more trees to cool and protect the city and surrounding areas, and to clean the air.
Balanced with supporting infrastructure (roads, traffics control, transportation, schools) While continuing with the "agricultural town" feeling I was welcomed to in the "80's", I, along with my children would love to experience the "American Dream" of home ownership- as first time homeowners in the town we grew up in "Brentwood!" I feel there are many families in our situation (low-income)with the same dream. Families who love their town show it in their communities. We appreciate each other, learn through our differences and strengthen each other through our commonalities. That is the Brentwood I know and love. I hope future generations will be able to experience the same blessing I hope for.
Thank you
One in which we respect our ULL but also develop affordable housing as mandated by RHNA. Why are we still approving market-rate housing?
Affordable housing for single moms. More programs for the low income.
Housing to accommodate retirement, multi generation, or young families Affordable housing with many different options to choose from (apartments, houses, etc)
City of Brentwood
2023-2031 Housing Element Update
Table 2 – Vision for the Future
Housing for the less fortunate
Affordable housing for low income families. Especially rental homes for workers struggling to pay rent.
I don't want a Brentwood where a builder can buy the house next to mine, tear it down, and replace it with a 4 plex with little thought about parking and the increased number of cars driving in the neighborhood. California Government has caused much of the problems that resulted in a lack of affordable housing. We need reasonable regulations to address zoning and housing. Currently Government is the biggest enemy of affordable housing with requirements that only increase the cost of housing with little thought about the big picture and the final cost to the builders, and ultimately the buyer. We can't just keep throwing money to homeless housing when many of the homeless want to live without rules and thus don't want to live in a homeless hotel or shelter. Let's address the reason behind homelessness and not a feel good approach that doesn't address the root of the problem.
Beautiful, peaceful neighborhood, great school, a lot parks and walking trails.
I heard that we are looking at a maximum population of 80,000. That seems like a good number to me. I do not want to be a Walnut Creek nor do I want to be an O A city that facilitates development other than mini-mansions. A city where my kids can afford to buy or rent here.
Neighbors who respect their neighbors,, would be wonderful... no matter what type of dwelling they live in.
more affordable.
We have a large community of teachers and high schools in Brentwood. I'm grateful for the opportunity to teach and live in Brentwood however have only been able to rent. I would like to see more affordable housing especially for teachers with either a down payment assistance incentive or the teacher next door program. Teachers have been teaching here for so long and they're starting to move out of state and with teacher shortages it has been a challenge to keep teachers here. I've been in the district since 1996 and there are so many teachers who have been teaching in Brentwood from generation to generation. Especially homes in our farming community.
Limit future housing developments and add high class commercial development. We also need more parks and open spaces. We already have too much traffic, not enough services (emergency), and not enough water to support more residents.
In the future to provide more affordable housing, apartment style housing that I could live in on my own as a young adult, and to solve the regions housing crisis, and two create relatively dense and walkable neighborhoods creating a more diverse and well rounded city. I would like to see most of the rest of the empty land in our city filled with mid to high density mixed use development.
A growing community with accessible, affordable housing for several generations of interconnected families. A place where single family home ownership is within reach of new and established residents in California.
I think making it affordable for families instead of just investors would be best for Brentwood.
Accesible para la comunidad
Young people transitioning from their childhood homes need a place to live if they want to stay in Brentwood. There are few choices. More affordable housing for this demographic is needed.
Brentwood also has no place for homeless to sleep. It needs to be addressed or it will be addressed informally, which is not going to be the best way of helping our homeless population.
City of Brentwood
2023-2031 Housing Element Update
Table 2 – Vision for the Future
Affordable housing for all who want to live here, who are born and raised her and would like to remain here but can’t because either to expensive or not enough good / high paying jobs! Lower density, do not want a repeat of mistakes made in Pittsburg and then Antioch Affordable housing so people at all income levels can live in Brentwood. Higher density allowed to achieve this vision.
Affordable homes for the middle class that make $100k to $130k and save money and pay taxes but still can’t afford a home here in Brentwood
Cap construction at 75,000 homes, condos. There is a real need for improved external maintenance of yards, common areas (Garin Parkway from Balfour to 2nd street). Many yards are poorly maintained creating a blight in Brentwood
Walnut Creek with broad open plazas and a vibrant downtown with stores and restaurants Consistent growth while maintaining that small town feel.
I envision Brentwood being a safe happy community that is affordable for younger people to achieve the "American Dream".
Housing and infrastructure need to expand at the same time. Vasco is a significant artery for many commuters that live in Brentwood but must commute to higher-paying jobs. Rising commute times make it harder to stay in Brentwood. Pay for higher housing closer to work or commute 2 hours and miss out on time with your family and community.
Availability
More affordable housing.
Affordable housing market and less competitive
More mixed housing projects to promote diversity, equity and inclusion. Include affordable housing, senior housing, multigenerational housing, as well as housing for people with disabilities together for a better mix.
Affordable places to live. More business, like better restaurants, recreation.
I would like mixed use, mixed income neighborhoods that are designed to be walkable and not rely on driving so much, and which encourage community and connection rather than isolation and disconnection. I would like more accessible and affordable housing for people who work in Brentwood and young people who grew up here who can't afford to live here. Smaller entry level first time buyer homes for young families and more affordable rental housing. affordable housing programs for all
I see Brentwood maintaining the slow growth of housing, maintaining most of its agricultural spaces alive
Brentwood ha crecido mucho en los últimos años y pues ya se mira como una ciudad porque hay cada día mas casas y por lo consiguiente económicamente ha incrementado cada día más y eso significa que también contará con muchas fuentes de empleo
Affordable housing for every type of income and retirees!!! I see Brentwood as a city leading in housing homeless people in the smartest and sustainable way possible. A city where inequality is low.
That there will be equal housing for all
Affordable housing options
More Below market rate homes
I would like to see much mote mixed use housing in areas like downtown and the Streets of Brentwood
City of Brentwood
2023-2031 Housing Element Update
Table 2 – Vision for the Future
My vision includes the various types of housing identified above integrated in such a way that agriculture is viable
General note I don't know the definition of several categories mentioned above such as "fair housing " . I believe the terms have meaning to special interest growth at may be at odds to society at large.
Poder aceder a ellas ya que la gente que está comprado es de otros lados y los que vivimos a quw I por años no podemos debidos a Los Altos precios
Affordable housing rent and sale
The lack of affordable housing in the San Francisco Bay Area is one of the defining social issues of our time and place. According to recent US Census data, nearly one quarter of households in our Brentwood community pays more than half of their monthly income toward housing – far above a sustainable level. These individuals and families teeter at the precipice of homelessness, where one missed paycheck or unexpected expense could plunge them into instability that would affect every aspect of their lives and reverberate throughout the community.
A mixed-income model places priority on housing and serving low-income persons while integrating members of other socioeconomic groups. By bringing these populations together, housing is stabilized for middle and low-income persons. Vision: An inclusive mixed-income community that features low-income supportive housing, low-income senior housing, middle-income rental units, first time home buyer housing, and student housing complementing existing large single-family homes.
No more building without emergency services to support. No one is homeless! No more huge box-like apartments. Make apartments pleasant to look at and less like institutional buildings
We protect the available affordable housing and look for opportunities to add more that can be well maintained in areas that are properly zoned.
Well balanced to the community that SERVES US. "Work Here, Live Here". Equal opportunity for all regardless of status
More affordable housing available maybe multi family homes. Less unaffordable large single family homes. I am glad to see more apartments units are being built this year.
Housing availability to enable homeless to be taken off of the streets, or at least removed because Brentwood has housing available for them. Affordable senior living is a huge deal as well.
My fear is my adult kids will not be able to afford to live here, even with being highly educated and having good jobs. Brentwood is just too expensive, especially for single people. I'd like to see there be at least affordable rental homes/apartments/condos for this upcoming generation and future generations.
In placing high density housing consider placing it by services needed for that community such as groceries and transportation.
Juicy cultural and racial. Affordable or sub sized housing More family single story homes
Affordable housing!
Affordable housing especially condominiums and townhomes instead of continuing to build large homes on small lots.
As a single woman over age 65, I would like to see more affordable housing for purchase. It seems that most homes in this city are two-story dwellings. I would like to see a better selection of single story homes. We seem to be returning to a multi-generational lifestyle as we care for parents, or
City of Brentwood
2023-2031 Housing Element Update
Table 2 – Vision for the Future
perhaps as adult children need to move back in with families. Floorplans to accommodate this lifestyle would probably be popular.
Equal housing for low and moderate income households
Safe and affordable
Please preserve the farms for the next generation.
affordable, well-planned, planting of many trees
Provide housing of all types only if the streets and service sector can sustain them. For example, if you plan to build housing of any type in north east part of town, then Lone Tree needs to expand from Fairview to Brentwood Blvd. and not in piecemeal fashion.
We need lots of housing. Let’s use every inch of open space to get people into homes they can afford.
Using infill to create a dense urban area with large greenspace and convenient public transit for intown and out-of-town access
A BEAUITIFUL WORLD
affordable homes where a family income of over 100k a year can still afford to buy a home in Brentwood.
In order to maintain a livable community, it is important to provide services for seniors who may have disabilities, as Bentwood has a history which is founded on the young people who could afford to buy where they grew up in past generations and who now wish to remain comfortably as they age and disabilities arise for them. Brentwood also needs to make room for those with disabilities who prefer the agriculture and history that Brentwood offers in a Family-centered community. Affordable housing for first-time buyers sustains the latter two visions for the next century.
More affordable housing for seniors. The opportunity to buy lot mobile house is on.
I think you should build more affordable housing. I think you should build up and it should be mixed housing, with some subsidized and some affordable. People with disabilities need special help. I suppose they would be happy in multi-story buildings with elevators. Parks and transportation also super important to be in the mix.
More schools for the ever growing community and families that will be our future Less new building that is expanding on agricultural land without first improving expansion of new business and road improvements.
AFFORDABLE housing especially for
Seniors and disabled
Bedroom community with viable resources and amenities supporting the city.
Better services for farmworkers with more protections for the farmworker vs the farmer.
More affordable housing. Continued maintenance of parks. Maintain balance of housing and open space.
Get away from McMansions and provide units that are reasonable in size - nothing over 2000 sq feet.
Better than this bedroom community drowning in oversized, cookie cutter houses that nobody but implants can afford
We need more low income housing
I envision Brentwood’s housing providing affordable housing for families and singles. affordable with a fair mix of open space, farms, single family, apts and condos. special emphasis on services for 65 + and veterans.
Future housing in Brentwood should be fair and affordable for residents already living here, along with those looking to move to this area.
City of Brentwood
2023-2031 Housing Element Update
Table 2 – Vision for the Future
No overcrowding. Condos which provide affordable home ownership Less housing Until emergency services can be caught up to national standards. No more new housing until the fire department and emergency services can respond inner efficient manner. smart, well rounded growth.
Improved infrastructure to support that growth.
Mostly single family homes, with increased condo and apartment opportunities Smaller homes, walk-able.
There has been more than enough single family homes built in town over the last 20 years. I have yet to see any single family home projects not allowed even on irreplaceable farmland; it seems like every single open space is being built on. We need infill building of apts for low income & younger people.
Please, do not forget our teachers! Currently a teacher on a single income canNOT afford to buy a house in Brentwood. People move to Brentwood also because of our great schools and incredible teachers. It is a shame that with the current state of things teachers might be pushed to live outside of the great city of Brentwood.
KEEP OUR FARMLANDS, ORCHARDS, AND AGRICULTURE STRONG. THIS GIVES BRENTWOOD IT'S VALUE!
A home where I can continue to raise my kids. At this rate it’s too expensive for young families we need more affordable housing to make Brentwood more diverse Not putting too many homes in one area and building more schools More smaller homes like condos or townhomes.
I have teenager, and I want them to be able to afford to buy a house or condo in the future.
Please only build the absolute minimum number of houses required to fulfill state demands, until such time as the state returns control of housing decisions to the city.
My Vision of Brentwood with regards to housing is hopeful but only if we’re able to get people into city council and on boards and commissions to get the right kind of developers and builders in our city to build enough housing to satisfy the demand
Higher concentration of multi family housing downtown to bring greater vitality and viability to the area
I’d like Brentwood to continue to be a place where teachers and firefighters and single income families can find housing and live where they work. I’d like my kids to be able to come back here after college and be able to get an apartment. This isn’t happening anymore.
A nice mix of houses and condos for all income levels.
High tech city with access to BART
Brentwood needs to maintain its charm and a small town feel - a town that is safe and family friendly where our children should be able to ride bikes and walk home without adult supervision when they are old enough. Home prices should not be impacted by bringing in mixed house. For these $1M+ homes we pay quite a bit of taxes to have that environment.
More mixed use types, condos, SFH. Basically any housing Please keep low income housing out of Brentwood. We moved away from the Bay Area because of the crime that came with it in our neighborhoods and schools. Thank you Less building overall. More focus on town cleanliness and emergency response time.
Brentwood is a safe bedroom community with senor citizens and large families. Brentwood has an excellent police department, offers plenty of parks to the residents, provides an excellent vision for the future, and needs to remain in this condition going forward. The City needs to be smart in how it
City of Brentwood
2023-2031 Housing Element Update
Table 2 – Vision for the Future
deploys these state mandates where it will be a win win for the current residents and allow the City to meet these requirements without the residents seeing any difference from today's lifestyle.
Continue to be a beautiful small town that is family oriented.
Don’t build more than our streets can handle. Don’t put low income housing near upper class neighborhoods
A vibrant multi culture/racial city
There is nothing wrong with building more houses, condos, etc but we already know how congested Vasco and H-4 even during pandemic. I hope that Brentwood, Antioch, Oakley, and Disco Bay would pay attention to the already very congested traffic in these two major roads before even talking about more houses.
Keep Brentwood a small town environment
Save farms. Build better roads. Less development.
Infrastructure that meets new housing. Eg street improvement, highway access.
Executive style homes and Ranches
Brentwood needs to be the next Pleasanton and Livermore and not Antioch. Brentwood should focus on smart high end growth. We need luxury homes like Ruby Hill in Pleasanton. Brentwood should be known for beautiful organic farms, farm to table restaurants, and high end homes. Many people are moving from Silicon Valley here to raise a family and want a nice home with lots of space. We don’t need more apartments, low income housing, gas stations, car washes, or liquor stores to bring down Brentwood. The seniors that live here and spend there money want to live in a nice area that they feel safe in. Let’s not cater to the people that don’t put money back into Brentwood all they do is increase crime and cause property values to fall.
Stop growing. U are ruining the city ot was.
Brentwood should focus on home ownership for upper middle class families with careers.
I would like to see a focus on larger lot sizes and emphasis on higher end housing.
Housing areas where they look like well maintained parks. affordable housing for people with incomes below $75,000 per year -so that means rent or mortgages below $2000 per month.
I'm concerned about too much density in the City. I would like to see more housing for those with disabilities and that need support. I think developers will put as much housing on a lot that possible (that is their business motivation), but Brentwood can be choosy now with what type of housing is available. The City will need to continue to have viable open space for our residents.
More townhomes for 1st time homebuyers. Housing for persons with disabilities. Maintaining current zoning
I'm not in agreement with any policies or legislation that would dictate to homeowners to rent rooms to people of low, or no income against their will.
Mixed Cost housing in same subdivision, don't build the "projects" will all subsidized Housing in the same area.
As Brentwood will inevitably expand my vision will be to keep our community to the same standards.
Considering developments location and the impact on schools, parks and traffic. Mainstreets are becoming very difficult to go through during high volume times (weekends, after work). Stores are becoming more crowded. If more affordable housing becomes more accessible-it needs to have standards that reflect Brentwood. Clean landscaping and upkeep and a park.
Lots of variety.
City of Brentwood
2023-2031 Housing Element Update
Table 2 – Vision for the Future
do not become Antioch
Vibrant small businesses, especially healthy and diverse restaurants. Please no more fast food. We have more than enough of those.
Stop making it a bedroom community. Please look into more smarter housing no more sprawl…seems the developers give Brentwood money and the city replies “Yes to all your demands!” We have enough housing so far. We need services to support the community that’s here I would like the see a slow in development in Brentwood. Also, I would like to see primarily single family homes. What drew me to Brentwood in the first place was the open spaces and minimal apartment/condo complexes. I would like to see more large lot homes such as ranchettes.
Brentwood needs to promote housing that continues to showcase the charm and character it has been known for, that of a bedroom community surrounded by farm to table markets, and suburbia.
Too many apartments, and low income housing will bring transients, and more crime.
I would just encourage that affordable housing be spread out through the city not just built on one side of the city.
I love the open space here a d would hate to see it all consumed by housing. Brentwood is special because it is not inundated with folks from neighboring cities.
Slow growth. some apartments. Special needs is great. Support for ne'er-do-wells is bad. Do not want turn into Antioch.
Many homes in Brentwood are already orientated to the over 50 people . I think a community like Rossmore is needed for the people of advancing age and health problems. There are many people are in that age group and more are coming. They need a city that can accommodate them. They need a quiet area where they can have their declining years of their life in safe environment. Many of the surrounding areas can accommodate the younger se.t
In the future there will be so many houses and so much traffic people will move on to more affordable housing and a small town (like this used to be).
I think we have to many houses already. No more building. We don’t have the Infrastructure or land left to build anymore.
I believe that we should curtail building in Brentwood in terms of housing. I think it would be more beneficial to provide more open space, Improve bike and walking access to all parts of Brentwood.
Create/develop a youth recreation Center, along the lines of a girls and boys club or YMCA type facility.
Keeping of open space. Love the farms and open fields.
Single parents being able to afford housing on a single income without having to go through low income housing. More jobs and less single family home developments. More fire departments and middle/high schools to accommodate the growth of students from all these homes.
Match the housing to the employed and non-employed (including retired) residents. With a proper match and amount of housing, commuting could and should be minimized.
I would love to see more affordable housing options. Providing this will bring much needed diversity and new ideas to the city.
A selection of duplexes or 4-plexes that allow ownership at a lower cost.
We are doing better than the adjacent cities around, we should keep managing what we done.
Specially the crime issue.
Brentwood need a nice shopping mall, instead more houses. Shopping Mall which will bring different people, different business into Brentwood , Brentwood will become a destination for people to visit.
City of Brentwood
2023-2031 Housing Element Update
Table 2 – Vision for the Future
I would like to keep Brentwood environmentally pleasant, unsaturated with less homes and people, and provides a feeling of breathe-ability. I would like to see more greenery (grass and trees), uncongested streets in and out of the community, a place of safety and security.
Realtors who don’t steer the mid to low income families who want live in safe neighborhoods and not be judge solely because you don’t have 3 times amount of income to cover an income check there are a lot of prejudice and racist’s realtors and home owners and have experienced this first hand for many months because of the pandemic made it tailored to realtors to only approve those who have pre qualified for housing in the area.
continue with a healthy farm community for years to come Mix of nicely maintained housing for people who take pride in where they live.
Stop the growth of expensive housing. Even senior housing is expensive in Brentwood. Our roads and schools are not equipped for this influx. We also don’t have careers out here.
We need to stick to the plan. Look at what land we have left and decide if the way they are zoned makes sense.
A good mix of something for everyone.
Affordable and attractable business policy
for companies to move and provide employment opportunities for the residents.
Keeping what farm land that we can and also build homes that are affordable to the working families that work in our area
Back to base for each unit/house have job in town
Safe and attractive neighborhoods complimented by well maintained parks, trails and open space The use of property as it was zoned.
Infrastructure balance, there must be enough supermarkets, shops, water, to support all of the homes being built.
Spread out, well planned communities that focus on families. A town that is not filled with low income apartments, where families feel safe and value the town I would prefer more affordable housing in the form of Condos vs. Apartments.
I envision growth in the area of homeownership opportunities for low-income families, such as myself, whose hearts belong to Brentwood, without changing the landscape and small town vibe we've always appreciated.
Thank you
We need to adhere to the plan that has been set. Do no rezone locations.
Build the technology park to attract businesses
Controlled growth
Housing that families can afford and keeping neighborhoods clean and safe. Neighborhood watch and housing that doesn’t exceed the capacity of our schools. No over development.
Nice
Preserve our farm town. Don't push our farmers out just to build homes. We are a beautiful small farm town, the soil here is fruitful. Build homes on bigger lots. Stop trying to overcrowd. Homes are on top of each other now.
Retain the current look and feel of the community, and only increase the density as mandated by state law.
Controlled housing that considers and plans for limited services such as water, parking, fire, police and schools. Brentwood should not over build new homes where/when services are already over
City of Brentwood
2023-2031 Housing Element Update
Table 2 – Vision for the Future
used. Services should be increased as housing is built and be ready as new homes come on the market.
Housing prices stabilize. Not as many "cookie cutter" houses.
Less apartments. Less crime. Less affordable housing. Fewer homeless encampments and no additional transitional housing programs. Zero tolerance for drug dealers and gangs moving into the city. If more housing needs to be added, gated 55+ communities are the best choice. Assisted living facilities are needed. Remaining open spaces should be preserved as parks or green areas.
More single story homes since we need them as we age. We don’t want them only in age restricted communities. Too many apartments now being built Stop that. Some sort of central shopping. Maybe a two story enclosed mall. Too hot and cold here for an open one. More police and fire personnel.
More grocery store options. Like Whole Foods Stop building out all the open space. no to low cost housing in Brentwood, it will lower the market value of houses here in Brentwood Slow it down. It won’t be sustainable.
Maintain that small town feel.
Home value growth
Family oriented housing mostly made up of multi-generational and single family with the bare minimal multi-family (apartments) and low income properties to meet State requirements.
Keep Brentwood as rural as possible
We moved here to get away from over populated towns and traffic. In the 4years we have been here the town has already started to lose its rural charm.
No section 8
I would like to see more affordable housing options, but I am not in favor of more building. I would like to see the agricultural área preserved.
No more condos/apartments, no low income housing, or new housing. We are streets and our schools are congested enough.
Comfortable family homes with space for plants
Less than 70,000 population would be best
Our city is already bursting at the seams. We don’t have the emergency services or support systems in place to build any more residential housing whether it’s apartments, single family homes, etc. We need more police to deal with all the riff raff making it’s way into Brentwood. This city is losing its charm. A moratorium is what we need on all future home building. This state has gotten so lost!!! More parks, sports complexes, open space. Schools, roads, and infrastructure need to increase in order to keep up with the increase of housing.
Ingress and egress surrounding the schools are a mess and should be addressed. 30 minutes to drop off/ pick up at a school within the city is unacceptable and is based on poor planning and lack of city government action.
An increase in affordable housing and low income complexes drive down home value and make the commute into and out of the city less tolerable.
Increase the police budget so retail theft, homelessness, and blight can be addressed properly.
The vision is a clean, safe, crime free city, where families that can afford to live here have a place they can relate to and want to be productive, contributing members of the community.
City of Brentwood
2023-2031 Housing Element Update
Table 2 – Vision for the Future
No water, no electricity, no more housing, until those issues are solved.
Continue the feeling of a small community with rural farming areas close by. Maintain law and order by minimizing densely populated areas.
I would prefer that if Brentwood grows it does so to the East. Additionally, I hope that jobs come with the growth as not to further increase traffic on Hwy 4 and Vasco Rd.
We’d like Brentwood to continue to be an environment that is safe for our children and elderly and the whole community. That our surroundings are kept clean and neat and safe, with homeowners willing to do their share in the work of keeping Brentwood a city that we are all proud to call Home. 3x's the land for every house built - meaning you keep Brentwood green Small town feel.
Brentwood doesn't need more housing. Brentwood needs more long term jobs.
No more housing!!!!! No big box stores!!! Follow through with the Brentwood Blvd plan get rid of all that crappy homes and stores and revamp it all we should look like Danville or Alamo not Concord! Prioritize the farms highlight all the farms all the time. No more football player owned farms he left us anyway! Force knightsen to clean up or take them over.
Brentwood is beautiful the way she is. No more homes, apartments, senior facilities. No more developers in Brentwood. We see what they do when you don't succumb to their wants (Deer Ridge) I would like the city to consider building of new homes/apartments done. We are stretching our resources too thin. Water resources and emergency services.
Stop building high density housing and creating new issues: increasing the use of resources such as water (apparently there isn’t enough for those who already live here and pay to be here, many 20+ years), emergency services, roads, and empty malls/buildings. It appears the city needs people who better understand business.
I moved my family to Brentwood from the South Bay because of its charm, young family oriented, open spaces, suburban and rural. We wanted to get away from the crowd and chaos of a metropolitan city. I would so much would like to keep Brentwood this way. Opening Brentwood to affordable housing will definitely change the environment, and will bring in more crime to our city.
Let’s keep Brentwood as is.
would like to see better maint of existing housing and support of same Less trac houses. Larger yards on new build single family I hope for Brentwood to remain a small and safe community for families.
I would like to see no more houses. And definitely no apartments.
Less growth and more investments in infrastructure. Better commuter experience on Vasco, more public transit, more schools. Cannot blindly build dwellings without FIRST addressing infrastructure needs. To do so is lunacy.
No more is necessary. Leave the community as is. The road infrastructure can barely manage the Brentwood infrastructure as is.
Leave it as it is now
I think we need to create more workplaces locally before building more homes.
Slow it down....infrastructure is not maintained to add any more high density housing! Halted. Too much development and losing community feel and atmosphere.
Not enough water in the entire state, let alone Brentwood, no new building should be initiated.
Brentwood's current housing situation is fine, it would be good to encourage builders to allow for more room between properties so people can adequately store garbage cans/basketball hoops or
City of Brentwood
2023-2031 Housing Element Update
Table 2 – Vision for the Future
even recreational vehicles to minimize the need for additional storage facilities around town. Also, the impact on the roadways leading in and out of Brentwood need to be addressed before additional housing. Those of us who have commuted for years on Vasco have seen our commute increase by over an our each way. Please work with government agencies to open up Vasco and the congestion before increasing housing. There are not enough high compensation jobs in Brentwood/Oakley/Antioch to afford the increasing home prices so we are forced to commute.
Less people and apartments
A balance of businesses vs homes vs traffic impact studies that support continuation of building density and what infrastructure the city plans to relieve congestion ~ growth is inevitable and so is balance.
I believe the city is becoming overcrowded...it is too condensed; with more people/housing units, you will need additional services and roads.
Model the issuance of housing permits similar to Livermore For Brentwood to get their infrastructure up to par and to stop big developers from ruining our once small town. I left the big city for the small town Brentwood was back in 2003.
No more building of any housing. Cap the population at current levels. Even better, reduce the population so the character of the area is preserved.
Everyone who is able to afford a house in Brentwood should be able to get one.
We create addition problem when we try to artificially impose our will on the market.
Maintain Brentwood small town feel
Please stop building car washes and gas stations. You have put so many gas stations into the city of Brentwood and probably don't even understand what underground storage tanks do to the surrounding area. You have congested this area with nothing but crappy little stores that can't stay open you have ruined the small town feel of Brentwood. Stop it. I moved back here to feel at home and you guys have ruined the city stop building bull crap. Stop lowering the value of my home with affordable housing, And filling every nook and cranny with apartments when we can't even travel to the grocery store without waiting in line for 45 minutes because the connectivity in the city is not good. You have ruined Brentwood please fix it
Smart housing, which includes but is not limited to:
Future proof infrastructure
Future proof roads
Strategic ares of growth
Stop building!! Ruining Brentwood.
No more housing. Keep our small town feel. Keep our quality neighborhoods. No more houses, impacting our schools and making more traffic!
Less people because its already overcrowded
To many people and everywhere crowded and nothing for people to do.
Stop building houses. Put a program in place that owners of rental properties need to maintain their landscaping or risk being fined. Build more schools to support the growth that is already happening and planned. Do not allow SB9 to infect our housing communities and drive our property values down.
We enjoy living in Brentwood, because, for the last several years, it has been a peaceful “small town” - good for raising a family. However, in recent years, crime has gone up, EMS services are inadequate, and traffic is increasing. Our city needs more commercial and retail growth and no more new housing
City of Brentwood
2023-2031 Housing Element Update
Table 2 – Vision for the Future
(especially high density housing). Keep Brentwood great by keeping it a family-friendly city with a “small town” feel.
My vision is that the homelessness is going to get out of control it seems that its not being deal with.
Less apartments, more family homes. Brentwood is not meant to house this many people with infrastructure that can’t support it.
The future of Brentwood is not looking great for families. You're showing pictures of fields and trees and all you want to do is develop and ruin this community. we have adequate housing and need more business/commercial property Certainly not to build the monstrosity on Lone Tree and O’Hara. Planners need to be mindful of the entire space to be occupied and the surrounding area. For example, we have an over abundance of gas stations and car washes for our fair city. It’s almost as if the people who approved one after the other had zero knowledge that what they were approving was already present. Case in point, there are 3-4 gas stations and/or car washes within a few blocks of each other on the very same road (located on Brentwood Blvd between Sand Creek and Lone Tree).
Have a larger minimum lot size. Keep the urban boundary. Improve roadways to alleviate congestion.
Less affordable for criminals and illegals
A sanctuary for low income seniors with lots of family's with master community development integration, parks, trees as always
Restricted and well thought out planning, the city is getting very congested and quality of life is being impaired.
make street lights, roads and highways more smooth and safe Limited housing development. Brentwood is getting crowded and has traffic congestion. Keep land and farm open for agriculture. Need more green and open space areas.
I would like to see Brentwood capped at 80K-90K population. The infrastructure can't withstand much more without creating more local jobs. Traffic is becoming unbearable as it is now. Housing needs to stick to the general plan with a mix of single family, low income, senior, and disability housing. We need more areas for kids to get involved (community centers or sports programs offered by the city.
More high-level income housing. Limiting low income housing and apartment. Encouraging new businesses, restaurants.
Continue with similar to current Master Plan. Keep high density housing projects on outskirts or near high density urbanized areas (away from single family residences). Keep single family projects to 2 or story units maximum and high density to 3 story buildings. Do not urbanize residential areas.
Minimize affordable housing projects to prevent violent crime migrating from neighboring cities.
My vision would be that Brentwood provides safe and clean neighborhoods. Homes where families can have a good education for their children. Seniors and veterans have affordable housing in a community that is supportive.
Community where residents themselves take pride in their city and ensures it is clean, well taken care of not liter filled and in state of disgrace, but could rubies to welcome families year after year to take part and experience our farms and community.
No more traffic. Less building, more open space. Quit using more and more water, before we all have to ration.
Respecting current zoning to keep neighborhoods in tact. Peoples life savings have been spent in the types of neighborhoods in which they want to live either for raising their families or living in retirement.
City of Brentwood
2023-2031 Housing Element Update
Table 2 – Vision for the Future
Enough low income houses for family and seniors
Protect important farmland east and south of Brentwood. Build between Brentwood and Antioch / Oakley borders to the west where land isn't being actively cultivated.
No new development until infrastructure is in place. Public transportation, schools and fire services.
No more gas stations, 7-11 type stores or Grocery outlets need to be built. We need good restaurants, which are few and far between.
Plenty of green space and healthy food sources within east access of neighborhoods We need units that a single senior can afford with marginal retirement No more developments.
More mid-priced single family homes. Limit the amount of section eight allowed in the city ! More oversight for properties that are not being maintained (ie: overgrown vegetation, too many vehicles on the street, degraded concrete & weathered structures) ! Possible tiny home communities
My family has lived in Brentwood since the 30s. I've seen many changes, We Should 1st. develop better infrastructure of our city to accommodate more housing of any kind. Without more Schools, Fire and Emergency Services the CITY is putting their tax paying Citizens that they already have at RISK!
Renew the senior housing proposal at Balfour and Deer Valley. It was great I would like to see single family homes,not a congested Brentwood.
Keeping a small family oriented town.
Safe, recreational and affordable City with farmland and parks.
A family oriented community with a quality standard of living. Large police officer pool, upscale restaurants, etc,
Keeping low income housing to a minimum.
Small, safe community with an emphasis on parks and recreation Keep it nice. No more traffic, No more housing, A cap on property taxes for retired seniors.
Please enforce ordinances that prohibit parking boats RVs inoperable vehicles large work trucks and trailers in driveways and on streets!
A crime less community where we can raise families safely, and where dwellers care and keep their properties kept up
Stop building period, until some roads in and out are planned Not to look like Emeryville or Berkeley. Have room to park cars in driveways. Houses spread out and not up.
Affordable housing for seniors (65+). Duplexes and condos for purchase.
Affordable single story condos for seniors
I think best for me if Brentwood city they will allow to build a shopping mall like in Concord Provide affordable housing to the senior community
Increase the number of senior housing options
Quality, well- maintained and safe neighborhoods featuring green belts and parks Protected farmlands adjoining smaller developments. Brentwood is growing too fast Less low income apartments- more single family homes.
Housing for seniors
City of Brentwood
2023-2031 Housing Element Update
Table 2 – Vision for the Future
A Lot Less!!!! Brentwood is not longer the close nit family friendly community. Too many people over running the City. Bring big jobs, not more houses!!!!
I would like to see a slow growth in Brentwood. I do not want any more traffic and crowding here.
There is not enough water for new homes and all the families they will bring. Our water needs to go to our farms. I do not want to lose the small town atmosphere and relative safety in our community. single family homes with NO low income or any other government assistance A community of single family homes for sale, not to rent. More enforcement requiring owners to abide by Brentwood 's housing codes, rules and regulations (e g. Cars parked on the driveway, not the grass or in front of neighbor's homes, no work vehicles of a certain size parked on or near the homes, require all home owners to take care of their landscapes) If the City of Brentwood regularly maintains the medians, streets and parks; the homeowners should be required to as well. Move all apartments and low income housing units to areas outside the city boundaries.
No re-zoning. No further congestion / overcrowding. In most cases, we are already there. Way too much stagnant traffic around schools- especially elementary schools throughout the day. Prevent school overcrowding. Brentwood has grown way too fast. Enforcement is seriously lacking. It seriously diminishes benefits of time and money spent.
Keep the agricultural uniqueness of Brentwood, NO STACK AND PACK CRAP. We do not want Brentwood to turn into Dublin. Single family homes with yards for children and pets (that is why people drive hours for commute) to have the opportunity for a small town life. PLEASE DON'T DESTROY IT. With little to no employment in Brentwood, keep it small with the hometown feel. Please consider the HWY 4 road noise in any future development and please stop catering to the builders to develop the land from farm to profit.
Single family neighborhoods that are not affected by crime and homeless vagrants upscale housing and shopping similar to Walnut Creek or Pleasant Hill.
I would like Brentwood to maintain its small town atmosphere but develop into a destination city for its farms and vineyards and shopping
Small home town feel where neighbors know and talk to each other.
More quality homes owned by good members of society
Local control with no state or federal interference.
Restrain the building of new houses as much as possible to maintain the quality of life in our city A safe place for families, with good schools . A place where homeowners are responsible and respect their neighbors and their community.
More single family dwellings on larger lots.
Do not over built the area
I would love to see more housing built in Brentwood with improvements to the roads (wider/better) Larger homes with larger lots & well manicured neighborhoods. Maintain the cleanliness of the City.
Brentwood is currently an escape from the tightly packed housing issues of the inner Bay Area, and is also extraordinarily safe. Please oppose urbanization of this lovely city. Maintain open spaces as much as possible, continue to use funding for public works and beautification measures. There's a reason why even this survey maker chose to make the background pictures of Brentwood as flowering trees and the Deer Ridge/Shadow Lakes neighborhoods.
Dwell with Nature's Harmony
Keep the building of new homes limited…Don’t want this city to turn into a low income area…keep it family oriented with slow steady we’ll thought our growth that is good for the hard working families of this community.
City of Brentwood
2023-2031 Housing Element Update
Table 2 – Vision for the Future
More affordable single family homes
Family oriented safe quiet place
Majority single family housing that caters to families and provides a safe environment for kids to walk city and play in parks.
No high-density or transitional / transient apartments
Less building period. Enough already. Keep some open space as we are already crowded.
I would like to see more upscale housing with upscale shopping centers. Brentwood is a great city with amazing housing as it is, but would love to see this city as people is Southern California see their Brentwood.
Stop allowing developers to have tiny lots with houses built right to the edge of lot lines. Stop building low income/affordable homes. Lets try to be a Danville of east county, NOT like Antioch.
Stop the growth of apartments/condominium complexes and put controls on renters/landlords that require the upkeep of their properties.
Smart growth. Not these ramrod developer friendly builds Bigger lot sizes for housing that will be approved. No more houses, concentrate on bringing businesses to the area.
Clean safe city free of the homeless California scorge
No more apartments and no more low cost housing.
Safe place to raise a family
That we don’t add too much condensed housing, especially in established neighborhoods. They weren’t planned for that.
We need more entry level homes such as condos and townhomes rather than all of these apartments.
There are way too many apartments on shady willow.
We also need to attract higher income levels with larger lots. We need a mix of people in Brentwood, we shouldn’t only be attracting low income, we should attract a variety of income level citizens.
The future is bleak. Governmental intervention has ruined Brentwood. It is probably too late. Stop.
Repent. Fire all managers and consultants now. Restore common sense and an open market and society will self-regulate.
Do not rezone single-family areas into cramped and overcrowded apartment/condo areas. People move to Brentwood to get AWAY from the super densely populated inner Bay Area. Don't let Brentwood turn into San Jose.
Do not over build the area!
to stay safe and secure
No high-density developments.
Currently, 0 lot high volume housing projects without upgrades to infrastructure is diminishing the value of current homes. We need more commerce not homes housing shouldn’t adversely affect roadways that still need upgrades, ie; Lone Tree to O’hara. please fix this roadway.
Parkways need to be considered before any more new developments are built. The traffic is terrible.
It takes a long time just to travel from one side of town to the other because of all the cars.
Good neighborhood, lower crime, no homeless view, no panhandlers, create middle and upper income jobs, not in any particular order
Continue the path of developing a community that is safe, excellent educational opportunities and supportive of the Arts.
City of Brentwood
2023-2031 Housing Element Update
Table 2 – Vision for the Future
Brentwood is a beautiful growing community for working families. We love the beautiful parks and downtown. I love that the trails are clean and safe. I would hope to see Brentwood continue down the path of being a family-oriented town geared toward working families. We do not need affordable living, homeless shelters, apartments which will inevitably bring in crime and blight from Antioch and Pittsburgh.
Don’t change R-1-10. No rezoning. Keep Brentwood as is. WORK ON DEVELOPING COMMERCE AND BRINGING IN GOOD PAYING JOBS. If special interest groups or government agencies or new regulations are forcing Brentwood to change then put a moratorium on Housing and work on developing good paying jobs and resume housing later. JOBS HERE FIXES EVERYTHING!!! I’d like to see the general plan followed, it is only fair to the people who bought housing for their specific zone. I worked hard and saved money, planned and bought my house. It is not fair to after the fact change the zoning of it for the surrounding neighborhoods. I’d like to see the general plan followed.
Less apartments, more single family homes. Clean, safe, well maintained neighborhoods. No homeless.
I would like to see mix-use housing with transit access nearby the Bart Extension, and bus pick-up areas.
I would like to see housing projects mixed into large areas of open space, so our neighborhoods have trees, parks, and more open space. Lots that are small, and are stacked upon one another look very much like a Daily City or a large city plan. I know we can much better! Slow down before we become another Antioch
No more new homes until water is worked out
Single family homes, construction no taller than2 stories Suburban living
Family friendly, safe
Big lots for families, space in schools, no traffic
Brentwood has always been a family community. There are so many different dynamics of families these days you need a variety of housing options.
No more building. No more new housing. Stop. Enjoy the Brentwood hills and small town.
I would hope to see Brentwood remain a family community with most homes owned by families and less homes owned and rented out by developers and investors. less hotels/low income housing.
Family homes with strong community bonds.
Slow down the building! The city is expanding far too quickly and we are not equipped to deal with it on so many aspects - traffic is heavier, roads are wearing out, less parking, not enough grocery stores/restaurants. Seems the city is too focused on housing and not how to SUPPORT that housing.
Less housing and more upscale commercial and business opportunities. Plus more activities of things to do in the area. Wineries, high end restaurants, indoor and outdoor sports recreational centers, bring back golf courses, concert venues, fun centers such as Top Golf, batting cages, etc.
Stop building homes and start bringing in more businesses, i.e. jobs, jobs, jobs. Stop building grassfilled parks (we don't need anymore parks) and build sports complex (large indoor facility that can host basketball, volleyball, soccer, etc.)., if run properly, this can be a large source of revenue.
No more apartments and no more high density low income housing.
A clean safe community to raise my children
City of Brentwood
2023-2031 Housing Element Update
Table 2 – Vision for the Future
Please keep Brentwood a city where people who work hard, raise families, and contribute to their society live. Please remove section 8. With the expansion of BART into Antioch, the park and ride near Dainty Ave, and the recession, the homeless and criminal population who come from the Bay Area have infilitrated our great city and many like minded individuals who’s income pays for the city’s taxes are likely to leave if this issue continues. Many folks here have been here all our lives and enjoy the small city Brentwood is.
Low density housing north of sand creek, med/high density should only be in areas where infrastructure can accommodate (new development in southern Brentwood, etc). Lone tree is already too congested.
The future of housing in Brentwood should focus on affordability while maintaining it's family oriented charm.
Brentwood need more housing tracks like Trilogy
I like Brentwood with single family home
Single house dwellings
Quit building transcient apartments. Brentwood was always a family oriented community and is now being destroyed by the leftist ideology.
I would like to see housing development slow down in Brentwood. We are out building our resources and it shows.
To not be ruined with low income housing or to have multiple family dwellings in the middle of single family home neighborhoods
Attention to maintaining beautiful neighborhoods and walkways. It’s disappointing to shop around in the brand new developments and they are crammed in with a loss of the priority of also having beautiful spaces within a neighborhood.
Leave it alone. Affordable housing brings crime and lower property value. Plus, I shouldn’t have to pay for me to live in Brentwood and then for another family. Government should stay out of it.
Don’t bring in a flood of low income tax payer funded housing. That brings nothing but crime and lower home values for the people that work hard to live here. stop building so much housing especially low income, just bring rift raft. we need better stores and security
Single family housing. No apartments or condos. Larger parks for children to play. Keeping the small town vibe.
Single family homes only and no multi family homes but only after traffic concerns are resolved to accommodate more homes, especially local highways and freeways. safe, family oriented housing environment
I would like to see more affordable single family homes.
Family neighborhoods, available apartments/condos for rent, low-income or homelessness housing available but NOT located next to higher income housing, Keep Brentwood a upper-middle class community; do not allow it to become another Antioch or Pittsburg. Focus on keeping the community safe and focus housing on upper-middle class and seniors.
We do NOT need more "affordable" housing and rentals occupied by homeless and criminals! Maintain a clean neighborhood, family life activities and respectful community Limited apartments. So disappointed with Brentwood building apartments near Pioneer Elementary without vote of residence!
Shame on you for devaluing our homes and communities.
City of Brentwood
2023-2031 Housing Element Update
Table 2 – Vision for the Future
Stop with Government handouts. Let families take care of their own. We have enough housing. No more apartments, condos, section 8 or high density housing, just brings in more of those who DO NOT own or care about Brentwood or others. Get a job, go to school, work to buy a home. Do not tax others and give to those who do not earn it. Help our Veterans who volunteered to serve not illegals or those who choose not to serve in armed forces. Brentwood was a nicer place to live 40 years ago.
More housing just brings more problems. More government brings more people who do not work.
People come to Brentwood and bring their city ways and Democrat values with them and destroy what was once beautiful and more open and free. I will move if Brentwood keeps building and it will so I will move. Say NO to State housing requirements or eliminate or change them. Do not take the Money. Do what Brentwood residents want NOT what Sacramento or Washington DC wants. But I see what is going on in Brentwood and it will not stop. Brentwood has become Democrat cesspool just like Antioch,Pittsburg, Oakland, SF, etc. More crime, more homeless, more drugs, more ungodly, more Government control and that is what Democrats LOVE, control because they know better than the people. Brentwood used to be Republican 40+ years ago. Less government, more freedoms and more farms. People knew each other. Brighter Future of Brentwood is gone so housing does not matter. Look at San Francisco that is Brentwoods future. Yes I will move and take my values and money to a place that offers more peace and freedom than the cesspool that Brentwood will become if it doesnt reverse course and stop building anything but single family homes. Want higher density housing move to another city and take your values there. But when government gets involved it costs more to do little when compared to private industry. Government does not have to make a profit but forces private people to and then takes what they have and calls it good. I work for government and try to make changes but too many people high up are corrupt and greedy or truly beleive they are doing good but are blind or sinful in there ways. God Help us. Thank you for listening. Know it will probably not make a difference but I still have hope and it's NOT in Brentwood! High end housing to balance out what is forced upon us by state regulations.
Limit housing, too much housing and crime now with not enough utilities and infrastructure to support it.
No Rezone
Building new houses needs to slow down. Where is all the water going to come from for all those new houses when the state is telling homeowners to stop using water Stop Building without First developing Freeway and Road infrastructures to support the expansion of future building. Traffic congestion is very high due to poor road infrastructure to support the expansion of people. Stop the traffic issues caused by housing development. Stop using up all the open land. Hence why we settled in Brentwood.
It is growing too fast. Too many new housing tracks that are not affordable.
Safe housing that can accommodate the varied needs of all the community including the homeless.
Safe and happy Brentwood
Housing, living, recreational areas all equal and accessible to all citizens Brentwood is already overcrowded. Water is becoming scarce. Roads are overcrowded. We don’t need more houses.
Do not turn Brentwood into Antioch or Pittsburg ie, low income housing, increased crime and homelessness.
Current status for family housing
Structured short term housing for homeless
City of Brentwood
2023-2031 Housing Element Update
Table 2 – Vision for the Future
No more development. People sell/rent out their own houses, not management companies.
Brentwood’s small town, farm feel is what draws people here and the city’s plans of development has completely uprooted our culture through destroying our land, water, and resources. Just for more money. Very sad.
I would like to see a stricter imposition on curbing housing expansion. Our schools are busting at the seams, our fire and emergency services are overworked, and our streets are becoming more and more congested. We are destroying the fabric of our community. We need to plan for more grocery stores, restaurants, and small businesses. Every open square inch of dirt does not need to be filled with some sort of housing just because we can.
Brentwood is an agricultural town. That’s what makes it special. Once you build on every acre of open space, our agricultural heritage will be gone forever. Preserve that which makes Brentwood special and beautiful.
Much like the current California Costal Commission, I would like to see near zero future home development of any type if an effort to retain the rural and agricultural nature of this valley. Look at how beautiful our coastline has remained, from Santa Barbara to the far north coast.
To stop over building. This once quaint town was never meant to be this size with the infrastructure currently in place Its dangerous to drive on most roads and certainly over highway 4 and Vasco. Take a deep breath and let other cities build out while we figure out how to fix our roadway and supporting elements. And for Gods Sake, leave the farms and open hills as is, please! Only housing that is supported fully by infrastructure, e.g., no over-crowding of schools, sufficient fire and police protection, no increase in traffic (our commute traffic situation is already not conducive to a healthy lifestyle). Well thought-out neighborhoods that put the top priority as the residents' wellbeing (both existing and future residents). Perhaps mixing neighborhoods with all ranges of income levels would be the best plan to ensure the highest quality of life for all.
A place where you can own property and enjoy peace from persons in your personal business.
No low income housing! Vey few apartments. We do not want to become the next Anitoch or Oakland.
A community with housing for all groups and all incomes.
High or higher density house if should have close highway 4 access so that our main roads are not jammed up. It’s sensible to build near the highway. Do not approve high density housing on the east side of town. Also, infrastructure such as schools, police, fire and roads must be supported as the city population grows. Parking should be considered with all housing development because households own multiple cars.
I feel that currently Brentwood has sufficient housing. The City is also maxed out on gas stations, fast food restaurants and 7/11, Quick Stop type stores. Brentwood should try to enhance the City with High Tech employment work complexes to provide living wage employment opportunities and reduce the need to commute as the City of Livermore has done.
At this point in Brentwood's development we need to focus on balancing housing and jobs. NO MORE residential building until infrastructure and jobs catch up.
Housing developments with enough green space at all income levels to enable human thriving.
No more @#%% homes.... Let's be like southern CA and run out of water...
No low income housing close to nice neighborhoods please Less retirement communities, more family based housing.
Affordable options for our children as they become working adults. Housing programs/ options for our homeless.
City of Brentwood
2023-2031 Housing Element Update
Table 2 – Vision for the Future
We need more fire and police before we expand housing.
Limited housing, I don’t want Brentwoood to have overgrowth and be like all those other cities in the East Bay. The beauty of this city is that it has open spaces. Stop developing! same as now. more golf courses
Growing with thoughts toward the future. Traffic and balance should be held in mind, thinking about our agricultural history and treating it with the respect it deserves.
LIMIT MORE HOUSING AS MUCH AS POSSIBLE , TOO MUCH TRAFFIC, CRIME ETC A good balance of jobs-related developments and single family housing.
Brentwood 2023-2031 Housing Element
Appendix C: Summary of Community Engagement C-8
C.3 Joint City Council and Planning Commission Workshop This section contains all materials created for the June 1, 2022, joint Planning Commission and City Council workshop. Participants had the opportunity to make public comments verbally or in written form through the Zoom chat. A recording of the workshop is available in both English and Spanish on the Housing Element Update webpage: https://brentwoodhousingelement.com/.
2023-2031 Housing Element Update
Joint Planning Commission and City Council Meeting
The City of Brentwood is currently updating its 2023-2031 Housing Element.
As part of the update, the City must identify strategies to accommodate the Regional Housing Needs Allocation (RHNA) of 1,522 housing units over the next eight years. In addition, a number of new State laws have been adopted since the last update to the City’s Housing Element in 2015 which will need to be addressed and included in the policy plan.
Please join us to learn about the City’s proposed strategies to accommodate RHNA and the new policies that will be added to the Housing Element to maintain compliance with State laws and requirements.
When: Wednesday June 1, 2022 at 6:00PM
Where: Zoom - https://brentwoodca-gov.zoom.us/j/76013970037 For more information about the Housing Element Update please visit:
www.brentwoodhousingelement.com
Actualización del Elemento de Vivienda 2023-2031
Reunión conjunta de la Comisión de Planificación y el
Consejo de la Ciudad
En estos momentos, la Ciudad de Brentwood está actualizando su Elemento de Vivienda 2023-2031. Como parte de la actualización, la Ciudad debe identificar estrategias para dar cabida a la asignación de necesidades regionales de vivienda (RHNA) de 1,522 unidades de vivienda en los próximos ocho años. Además, se han adoptado varias leyes estatales nuevas desde la última actualización del Elemento de Vivienda de la Ciudad en 2015, las cuales se tendrán que incluir y tomar en cuenta en el plan de políticas.
Cuándo: Miércoles, 1 de junio de 2022 a las 6:00 p.m.
Dónde: Zoom - https://brentwoodca-gov.zoom.us/j/76013970037 Para obtener más información sobre la actualización
del Elemento de Vivienda, conéctese a:
www.brentwoodhousingelement.com
Acompáñenos para conocer las estrategias propuestas de la Ciudad para dar cabida a la asignación RHNA y las nuevas políticas que se agregarán al Elemento de Vivienda para mantener el cumplimiento de las leyes y requisitos estatales.
JOINT WORKSHOP AGENDA ITEM NO. 2
Meeting Date: June 1, 2022
Subject Title: Update and discussion of the 6th Cycle Housing Element Update, Regional Housing Needs Allocation (RHNA) sites strategies, and implications of new State legislation on the City’s policies and programs.
Prepared By: Ines Galmiche, Kimley Horn
Jennifer Hagen, Senior Planner
Submitted By: Alexis Morris, Community Development Director Erik Nolthenius, Planning Manager
PURPOSE AND RECOMMENDATION
This workshop includes an update and summary of RHNA and the sites strategies being used to identify sites to accommodate the City’s “fair share,” as well as a brief summary of key changes in Housing Element Law and possible implications as to City programs. The workshop will include a staff presentation, as well as public comments and City Council/Planning Commission discussion. No direction or action is being requested as part of this workshop.
PREVIOUS ACTION
The City Council authorized execution of an agreement for consulting services with Kimley-Horn to assist with preparation of the 2023-2031 (6th RHNA Cycle) Housing Element Update on October 12, 2021.
On April 14, 2022, staff presented an introduction to the Housing Element Update at a joint City Council/Planning Commission workshop.
BACKGROUND
The Housing Element is part of the City’s General Plan and is a comprehensive statement by the community of its current and future housing needs, including proposed actions to f acilitate the provision of housing to meet those needs at all income levels. State law requires periodic updating of the Housing Element; and thus, the element reflects the State’s housing goal of "attaining decent housing and a suitable living environment for every California family," as well as incorporating the unique concerns of the community. The current Housing Element, which was adopted by the City Council and certified by the State in 2015, covers the planning period from 2015 to 2022 (5th Cycle). The next Housing Element Update (the 6th Cycle) must be adopted by January 2023, to address the 2023-2031 planning period.
DISCUSSION
6th Cycle RHNA Process and Status
As part of the update, HCD requires each jurisdiction in the State to demonstrate capacity to meet their local “fair share” of the assigned Regional Housing Needs Allocation (RHNA), including total housing units across a series of affordability categories. The RHNA is then determined and assigned through a process led by HCD and regional Councils of Governments
(for the Bay Area, this is ABAG/MTC). The City of Brentwood has been allocated 1,522 units at various income levels for the upcoming cycle.
As a key component of the updated Housing Element, the City must document, through a detailed, parcel-specific inventory, that there are sufficient sites available at the time of adoption of the element to accommodate the entirety of its RHNA. The adequacy of the sites inventory will be evaluated by the State Department of Housing and Community Development (HCD).
Although HCD will review the entire inventory, it pays particular attention to sites identified to accommodate the City’s lower-income RHNA, based on criteria intended to show the various sites’ realistic capacity to develop residential uses during the eight-year planning period of the Housing Element.
It is important to note that identifying sites to accommodate the RHNA is a planning requirement; it is not a mandate or quota for the City to construct housing units. While the City must report annually on production of housing relative to its RHNA numbers, there are no direct penalties at this time for failing to meet the allocation. That being said, there are more indirect consequences. For example, recent State law has implemented streamlining requirements and reduced local discretion over approval of housing projects, some of which is specifically targeted at jurisdictions whose housing production has fallen short of the RHNA.
Table 1 summarizes the 6th Cycle RHNA for the City of Brentwood. The RHNA is distributed among the following income categories, each of which represent relative affordability to households as a proportion of the Countywide Area Median Income (AMI).
Table 1: RHNA Allocation Breakdown
Income Category Percentage of Area
Median Income
Brentwood RHNA
Extremely Low Income (ELI)* <30% 402 Very Low Income (VLI)* 31-50% Low Income (LI) 51-80% 232
Moderate Income (MI) 81-120% 247
Above-Moderate Income (AMI) >120% 641
Total 1,522 Units
* The RHNA does not split out Extremely-Low and Very-Low Income Units; however, jurisdictions are required to account for both categories in the Housing Element’s Quantified Needs Assessment, typically assuming an even split between units in each income category.
Analysis of Existing/Baseline Zoning Capacity
In order to provide a comprehensive analysis of the City’s existing zoning capacity, staff has identified the following components to address the City’s 6th Cycle RHNA, discussed in f urther detail below.
• Existing Residential Zoning - This includes parcels zoned for residential uses with capacity to add new housing units within the City’s single-family and multi-family residential zoning districts.1
• Capacity in existing Specific Plans - This includes parcels within the PA-1 Specific Plan, Brentwood Boulevard Specific Plan, and Downtown Specific Plan that allow for residential uses with capacity to add new housing units. 1 Although all vacant or underutilized residential parcels may be included within the inventory, the focus will be on sites that can accommodate the largest number of below market rate housing at the highest densities. Therefore, not all residentially zoned sites will be listed.
• Pipeline Projects - The “pipeline” of residential projects already entitled or expected to be entitled in the coming one- to two-year period, including projects under construction but which would not have building permits finaled by June 30, 2022. 2 This includes new projects to be approved under the City’s revised Affordable Housing Ordinance. • ADU Production - Other anticipated housing production, including ADU’s. HCD has issued a determination to allow local jurisdictions to “count” ADU production as a component of the sites inventory, based on a formula that considers the average annual number of ADU permits issued in the city over the last three years, multiplied over the Housing Element’s eight-year planning period.3
Together, existing residentially-zoned properties, pipeline projects, and ADUs constitute a baseline of zoned capacity that can accommodate the City’s RHNA. The difference between this number, and the RHNA in each category, represents the “buffer” in each category. Table 2 below summarizes the results of staff’s initial evaluation of existing residential development capacity and the difference between that number and the RHNA.
While changes may still be made before finalizing the baseline number of units and overall capacity, the initial analysis indicates that the City’s existing land use and zoning regulations allow adequate housing development to meet the full RHNA and that the City may thus not need to rezone any parcels. This initial analysis will be confirmed as staff finalizes the sites inventory.
If rezoning is determined to be needed, it is likely to be a small number of parcels.
Table 2: Summary of Preliminary Analysis of RHNA and Sites Strategies Summary of Preliminary Analysis of RHNA and Sites Strategies Very LowIncome
LowIncomeModerateIncome
Above
ModerateIncomeTotal
2023-2031 RHNA
Allocation 402 232 247 641 1,552
RHNA Strategies Under Existing Zoning
Projects Currently in
the Pipeline 17 39 1,481 1,537
PA-1 (Innovation
Center) 498 1,024 429 1,951
Vacant Residential
Land 134 44 835 1,013
Projected ADU
Production 80 41 14 135
Total Unit Potential 729 1,148 2,759 4,636
Buffer 15% 365% 330% 199%
2 The Housing Element 6th RHNA Cycle reporting period technically begins on July 1, 2022, meaning that units for which building permits are finaled (i.e., approved for occupancy) on or after this date, can be included in the 2023-2031 inventory.
3 ABAG has prepared a preliminary ADU Affordability Report, currently under review by HCD, intended as a basis to allocate ADU production into the various RHNA affordability categories. If HCD accepts the report’s analysis, ADU’s would be permitted to be counted at the following income levels: 30% Very Low Income, 30% Low Income, 30% Moderate Income, 10% Above Moderate Income. The inventory assumes this allocation, but it may need to be adjusted based on HCD’s direction.
Policies and Program Considerations and Implications of New State Law As part of the Housing Element Update, staff will provide an evaluation and review of the existing policies and programs, which will provide the implementation status of the current Housing Element programs. The purpose of this is to evaluate which programs have been successful and should be continued, and which programs have been ineffective and should be eliminated or modified. The evaluation is required by state law and will also include a comprehensive review of existing policies and programs to determine if there are any gaps to be addressed, or programs that could be considered for inclusion in the Housing Element to better meet community housing goals and to verify that all new legislative requirements are being addressed and are integrated into the Housing Element update.
In recent years, the State has adopted a significant amount of new housing-related legislation, which will influence and shape the current Housing Element Update. These include but are not limited to the following:
• Housing Crisis Act (SB 330) - Makes changes to land use and zoning law to encourage housing production, by, among other things, limiting the scope of local review of qualifying housing projects to objective standards only, limiting the number of public hearings for projects, and shortening review timeframes. • Adequate Housing Element Sites (AB 1397) - Strengthens local governments’ obligation to identify a supply of adequate sites available to meet their share of regional housing needs at all income levels, and make those sites available early in the housing element planning period with access to public infrastructure.
• No-Net-Loss (SB 166) - Requires jurisdictions to maintain adequate sites to continuously accommodate its remaining regional housing needs allocation throughout the housing element planning period.
An initial analysis of the existing programs indicate that some modifications or additions to our current goals and policies will be required to reflect changes in State law and provide more specificity in terms of City actions. Modified or new program actions that will need to be addressed in the Housing Element will include the following:
• Facilitation of Accessory Dwelling Unit production and monitoring – New legislation (AB 68, AB 881, SB 13, AB 587, AB 670, AB 671) requires Cities to promote the development of ADUs and establish streamlined approval processes for ADU applications. As future ADU development is proposed as a strategy to accommodate RHNA, the City must establish specific actions to facilitate development over the next eight years.
• Farmworker and Employee Housing – California Health and Safety Code Sections 17021.5 and 17021.6 require agricultural employee housing to be permitted by-right, without a conditional use permit (CUP), in single-family zones for six or fewer persons and in agricultural zones with no more than 12 units or 36 beds. • Senate Bill 35 Streamlining Procedures - Streamlines multifamily housing project approvals, at the request of a developer, in a city that fails to issue building permits for its share of the regional housing need by income category. In an SB 35 City, approval of a qualifying housing development on qualifying site is a ministerial act, without CEQA review or public hearings.
• Safety Element Update and Environmental Justice Policies – SB 1035 requires that the City revise the Safety Element to identify flood hazards and address the risk of f ire hazards in certain lands upon each revision of the Housing Element. SB 1000 requires that the City incorporate environmental justice policies within the General Plan. • Density Bonus Ordinance Update – AB 2753 requires local governments to provide determinations to developers regarding the amount of density bonus for which a development is eligible, all reductions in parking requirements for which the applicant is eligible and whether the applicant has provided adequate information for the local government to make a determination regarding any requested incentives, concessions, waivers or reductions in required parking. AB 2372 authorizes cities or counties to grant a developer of an eligible housing development under the State Density Bonus Law a floor area ratio bonus in lieu of a bonus based on dwelling units per acre. Additionally, SB 1227 allows student housing projects where at least 20 percent of the units are affordable for lower income students to receive a 35 percent density bonus, as well as requires the development to provide priority to students experiencing homelessness. • Affirmatively Further Fair Housing – AB 686 requires a public agency to administer its programs and activities relating to housing and community development in a manner to affirmatively further fair housing and not take any action that is inconsistent with this obligation. Additionally, an assessment of fair housing practices must now be included in upcoming housing elements.
• Low-Barrier Navigation Center – AB 101 requires local governments to provide “by right,” CEQA-exempt approvals to certain qualifying navigation centers that move persons experiencing homelessness into permanent housing, as well as creates additional incentives for cities to comply with their mandates to plan for sufficient housing under Housing Element law.
NEXT STEPS
As noted, the creation of the sites inventory is an important initial step in the Housing Element process. Following this meeting, staff and the consultant team will continue to develop and refine the analysis of existing sites and solidify the existing capacity that can be used to address our RHNA.
Staff also notes that in addition to working on reviewing the sites inventory and goals and policies, staff and the consultant team are continuing to advance other components of the Housing Element. These include:
• Conclusion and summary of input from the initial on-line community survey. The survey will continue to be posted through Friday, June 10th and staff encourages everyone who wished to participate to please visit https://brentwood.info/housing_element_survey As of Friday May 27th, there have been 459 submissions of the Community Survey. • Completion of the Public Review Draft of the 2023-2031 Housing Element Update that will address all of the mandatory informational requirements and analyses supporting the Housing Element, including findings of the required housing needs assessment; analysis of constraints to housing; and evaluation of existing Housing Element policies and programs. This draft report is anticipated to be published and presented to the City Council and Planning Commission in July ahead of submission to California Department of Housing and Community Development (HCD).
CONCLUSION
Staff is recommending that the City Council and Planning Commission review, discuss, and receive public comments on the Housing Element Update RHNA sites strategies, and implications of new State legislation on the City’s policies and programs. No direction or action is being requested as part of this workshop.
Brentwood 2023-2031 Housing Element
Appendix C: Summary of Community Engagement C-9
C.4 City Council Meeting
This section contains all materials created for the July 21, 2022, City Council meeting. Participants had the opportunity to make public comments verbally or in written form through the Zoom chat. A recording of the meeting is available in both English and Spanish on the Housing Element Update webpage:
https://brentwoodhousingelement.com/.
JULY 21, 2022
SPECIAL CITY COUNCIL AGENDA
*IMPORTANT NOTICE ABOUT PUBLIC COMMENTS AND MEETING PARTICIPATION* UPDATED APRIL 21, 2022
Consistent with Contra Costa County Health orders, and in accordance with California Government Code Section 54953(e) concerning teleconference meetings, this City Council meeting will be held exclusively via teleconference, using the Zoom video conferencing system. At this time, public participation will be available exclusively via telephone or teleconference, using the Zoom video conferencing system.
How to View and Participate
The public is invited to participate in the City Council meeting and offer comments of up to 3 minutes (or as may otherwise be determined by the Council) using any of the following methods:
1. Zoom: www.brentwoodca.gov/vcc or Zoom Webinar ID: 760 1397 0037 Phone Numbers:
Dial (for higher quality, dial a number based on your current location):
US: +1 720 707 2699 or +1 253 215 8782 or +1 346 248 7799 or +1 646 558 8656 or +1 301 715 8592 or +1 312 626 6799 or 888 788 0099 (Toll Free) or 833 548 0276 (Toll Free) or 833 548 0282 (Toll Free) or 877 853 5247 (Toll Free)
As the City Council Chamber will not be open to the public, individuals may view and participate in the meeting with this link. During the meeting, each period for public comment will be announced, and participants may use the “Raise Hand” feature on Zoom to request to speak. The meeting host will call on you, by name, and enable your microphone when it is your turn to speak.
In order to ensure the orderly administration of the meeting using this method, providing your name is encouraged, but is not required. (If you need instructions on how to use this feature, please contact the City Clerk by noon of the meeting date at [email protected] or 925.516.5182.)
The public may view the meeting via one-way video feed by selecting the video option at the City Council Agendas’ link on the City webpage at www.brentwoodca.gov
2. Telephone
If you wish to comment during the meeting via telephone, you may “raise your hand” virtually on most devices by pressing *9, and you will be called upon when it is your time to speak. After speaking, please press *9 again to remove the “raise your hand” feature. If that feature does not work on your device, please email [email protected] in advance of the meeting where possible. The request must contain in the subject line “Request to Speak – Agenda Item #” and should include name and full phone number that will be used to call in. In order to ensure the orderly administration of the meeting using this method, providing your name is encouraged, but is not required.
3. E-mail
Public comments can also be submitted via e-mail to [email protected]. Any public comments received up until 3:00 p.m. of the meeting date will be:
§ distributed to the Council via email before the meeting, § posted online for public inspection at https://www.brentwoodca.gov/councilmeetingonline, and
§ later summarized in the meeting minutes.
Public comments received after 3:00 p.m. of the meeting date, but prior to the start of the meeting, will be emailed to the City Council, posted online within one day following the
JULY 21, 2022
SPECIAL CITY COUNCIL AGENDA
PAGE 2 OF 2
meeting, and will be summarized in the meeting minutes. The City cannot guarantee that its network, website, and/or the Zoom system will be uninterrupted. In the event of an interruption to the broadcasting of the meeting using the telephone or internet-based options listed above, the City Council will take no further action on items on the agenda until public access to the meeting via either option is restored. To ensure that the City Council receives your comments prior to taking action, you are strongly encouraged to submit them in advance of the meeting by 3:00 p.m.
As e-mails containing public meeting comments are part of the official record, note that personal contact information may be published if it is included with your e-mail.
The Closed Captioning provided via Zoom is auto generated. It is not the official record and is provided as a convenience.
Pursuant to Section 54956 of the California Government Code, a special meeting of the City Council is hereby called for JULY 21, 2022, at 6:00 p.m. or as soon thereafter as possible.
Following the staff presentation of the agenda item, and before direction is provided, public comment will be taken.
CALL TO ORDER/ROLL CALL: A special meeting of the City Council A. Housing Element Update - Introduction of and direction to staff regarding the analysis of existing residential zoning capacity within the City including review of a list of potential sites under consideration for inclusion in the Housing Element Sites Inventory for the 2023-2031 (6th Cycle) Housing Element Update, as well as an evaluation of site inventory and affordability assumption strategies to address the City’s Regional Housing Need Allocation (RHNA). (Alexis Morris/Jennifer Hagen)
ADJOURNMENT
POSTING STATEMENT
On July 7, 2022, a true and correct copy of this agenda was posted on the City Hall Bulletin Board, outside City Hall, 150 City Park Way, Brentwood, CA 94513 and at our website www.brentwoodca.gov A complete packet of information is available for public review at City Hall or on our website at www.brentwoodca.gov
MEMORANDUM
DATE: July 6, 2022
TO: Mayor and City Council
FROM: Jennifer Hagen, Senior Planner
Alexis Morris, Community Development Director
SUBJECT: July 21, 2022 Housing Element Workshop Executive Summary Workshop Objectives
At the July 21, 2022 Workshop, staff is requesting the City Council’s input and direction on the list of sites to be carried forward for analysis in the Housing Element Update. The workshop is intended to accomplish the following objectives:
1. Present the initial framework for the site inventory, including HCD accepted assumptions and principles that may be used to develop the inventory.
2. Introduce the analysis of existing residential zoning capacity within the city, including the preliminary site list from which the site inventory will be compiled, and evaluation of the number of units for which additional sites may be needed to address the City’s RHNA utilizing three different strategies that include varying affordability assumptions and ADU projection assumptions.
3. Receive direction from the City Council on which Site Inventory Strategy, as described in the Site Inventory and Affordability Assumption Strategies section of this report, to move forward with when preparing affordability projections and the Draft Housing Element Update.
Developing the Site Inventory
The attached staff report provides background information on the framework for the site inventory, including HCD accepted assumptions and principles as outlined in the HCD Site Inventory Guidebook, which is attached for reference.
To move forward in the planning process in drafting the Housing Element Update, it is imperative that the City Council provide direction on which strategies should be used in forming baseline site inventory and affordability assumptions. Important things to consider when selecting the baseline site inventory strategy are:
1. Planning for vs. constructing housing: The City is not required to build housing, but is required to plan for sufficient housing to meet its regional housing need. All of the strategies summarized below utilize the City’s existing General Plan designations and do not require any changes to the General Plan.
2. Importance of a buffer and “no net loss” requirements: Each time the City approves a project on a site listed in the housing element, it must compare the project with both the number of units shown in the housing element and the projected income level. If either the project has fewer units than shown in the housing element, or the units are developed at a different income level, the City must demonstrate that it still has enough properly zoned sites to meet the RHNA at all income levels. If there are not enough properly zoned sites in the inventory, the City must identify and make available additional sites within 180 days, which may require rezoning.
3. Penalties for not constructing all units assigned by the RHNA: If fewer units are built in the City than included in the City’s RHNA, at present the only consequence is that developers may submit applications under SB 35, which is described in further detail in the report.
4. Penalties for not having a Housing Element Approved by HCD: Cities with non-compliant Housing Elements may be referred by HCD to the Attorney General or may be sued by private parties. Certain state housing funds also require that the City have a housing element approved by HCD. If a court agrees that the housing element does not comply with state law, the court may restrict the City’s ability to approve certain projects or order the City to approve certain projects, and the City would likely be required to pay attorney’s fees to the successful plaintiffs.
The attached staff report includes a draft site inventory table and map for reference that shows existing vacant/underutilized residential parcels, their buildable acreage, zoning and land use designations, and allowable and mid-range densities.
There are also three potential strategies identified that would allow the City to move forward with the provided draft site inventory that would not require any rezoning of sites within the City at this time. Staff has provided analysis of each strategy that includes a description of the scenario’s affordability assumptions, the buffer each strategy would provide, the likelihood of HCD acceptance, the likelihood of requiring no net loss, and CEQA implications. The strategies provided are only a sample of the strategies and assumptions that could be utilized to address the City’s RHNA. There will be an opportunity at June 21st workshop to use in real time, a model to make affordability and site assumption adjustments as necessary. A summary of each of the three identified strategies are included on the following page.
Strategy 1 Strategy 2 Strategy 3
Description No Rezoning Required,
Reduced Affordability
with Increased ADU
Assumptions
No Rezoning Required,
HCD Approved
Methodology
No Rezoning Required,
HCD Approved
Methodology with
Conservative
Affordability
Assumptions
HCD-supported No Yes Yes
Affordability
Assumptions*
21% Low and Very
Low, and 6% Moderate
100% Low and Very
Low, and 100%
Moderate
30% Low and Very
Low, and 10%
Moderate
Affordable Unit
Potential
VL/L: 635 units
Mod: 264 units
AMod: 4,183 units
Total: 5,082 units
VL/L: 2,321 units
Mod: 851 units
AMod: 1,775 units
Total: 4,947 units
VL/L: 755 units
Mod: 347 units
AMod: 1,405 units
Total: 4,947 units
Buffer 0% Low/Very Low,
7% Moderate-, and
553% Above Moderate
266% Low/Very Low,
245% Moderate-, and
177% Above Moderate
19% Low/Very Low,
40% Moderate-, and
500% Above Moderate
No Not Loss
Implications
Highly likely to trigger
no net loss
Least likely to trigger no
net loss
More likely than
Strategy 2 to trigger no
net loss
*Affordability assumptions are based on the site inventory with the assumption that sites that allow 30 du/ac (default density) or more can accommodate capacity for lower-income units and sites that allow 15 to 25 du/ac can accommodate capacity for moderate-income units.
5th Cycle Housing Element Sites
Lastly, for reference purposes, staff has included the adopted 2015 5th Cycle Housing Element Sites Inventory, broken down between multi-family and single-family residential parcels. Staff has included columns that indicate their buildable acreage, zoning and land use designations, the stated capacity in the previous inventory, whether the sites were developed during the planning period, how many units were developed, whether the site is recommended to be carried over into the current cycle, and if not carried over, why. It should be noted that staff is not recommending to carry over any sites that do not yield a minimum of 10 units.
CITY COUNCIL WORKSHOP AGENDA ITEM A
Meeting Date: July 21, 2022
Subject Title: Housing Element Update - Introduction on the analysis of existing residential zoning capacity within the city including review of a list of potential sites under consideration for inclusion in the Housing Element Site Inventory for the 2023-2031 (6th Cycle) Housing Element Update, as well as an evaluation of Site Inventory and affordability assumption strategies needed to address the City’s Regional Housing Need Allocation (RHNA).
Prepared By: Jennifer Hagen, Senior Planner
Submitted By: Alexis Morris, Community Development Director Erik Nolthenius, Planning Manager
PURPOSE AND RECOMMENDATION
Work is proceeding on the 2023-2031 (6th Cycle) Housing Element Update, which among other components, will include an updated inventory of sites that can accommodate the City’s Regional Housing Need Allocation (RHNA). As a starting point for creating the Housing Element Updated Site Inventory, staff has identified a list of sites that under the existing General Plan and Zoning designations allow for residential development at various densities. Staff has provided a map (Attachment 4) and list identifying each site (Attachment 3), as well as a calculation of the estimated yield of units for each based on the mid-point density allowed in each Zoning District or General Plan designation.
Workshop Objectives
At tonight’s workshop, staff requests the City Council’s input and direction on the list of sites to be carried forward for analysis in the Housing Element Update. This workshop is intended to accomplish the following objectives:
1. Present the initial framework for the site inventory, including HCD accepted assumptions and principles that may be used to develop the inventory.
2. Introduce the analysis of existing residential zoning capacity within the city including the preliminary site list from which the site inventory will be compiled, and evaluation of the number of units for which additional sites may be needed to address the City’s RHNA utilizing three different strategies that include varying affordability assumptions and ADU projection assumptions.
3. Receive direction from the City Council on which Site Inventory Strategy, as described in the Site Inventory and Affordability Assumption Strategies section of this report, to move forward with when preparing affordability projections and the Draft Housing Element Update.
2 PREVIOUS ACTION
The City Council authorized execution of an agreement for consulting services with Kimley-Horn to assist with preparation of the 2023-2031 (6th RHNA Cycle) Housing Element Update on October 12, 2021.
On April 14, 2022, staff presented an introduction to the Housing Element Update at a joint City Council/Planning Commission workshop.
On June 1, 2022, staff presented an update on the Housing Element Update including Regional Housing Needs Allocation (RHNA) site strategies, and implications of new State legislation on the City’s policies and programs. The City Council directed staff to return with a draft site inventory when available for review.
BACKGROUND
The Housing Element is part of the City’s General Plan and is a comprehensive statement by the community of its current and future housing needs, including proposed actions to facilitate the provision of housing to meet those needs at all income levels. The current Housing Element, which was adopted by the City Council and certified by the State in 2015, covers the planning period from 2015 to 2022 (5th Cycle). The next Housing Element Update (the 6th Cycle) must be adopted by January 2023, to address the 2023-2031 planning period1 .
6th Cycle RHNA
As has been previously outlined to the City Council, the City has been assigned a 6th Cycle RHNA of 1,522 housing units at various levels of affordability. As a key component of the updated Housing Element, the City must document, through a detailed, parcel-specific inventory, that there are sufficient sites available today to accommodate the entirety of its RHNA. If the City does not have enough adequate sites identified and currently zoned to accommodate the assigned RHNA, additional sites will need to be identified and ultimately rezoned.
The adequacy of the site inventory will be evaluated by the State Department of Housing and Community Development (HCD). Although HCD will review the entire inventory, it pays particular attention to sites identified to accommodate the City’s lower-income RHNA, based on criteria intended to show the various sites’ realistic capacity to develop during the eight-year planning period of the Housing Element.
Ramifications of Failure to Meet RHNA
At present, there is no requirement that enough homes be constructed in a city or county to meet the community’s RHNA. If fewer units are built in the City than included in the City’s RHNA, at present the only consequence is that developers may submit applications under SB
35. SB 35 allows developers to submit housing developments meeting certain requirements, including specified percentages of affordable housing and payment of prevailing wages, if fewer units are being constructed in the city to meet its above moderate, very low, or low-income RHNA requirements. Projects eligible for SB 35 must be approved ministerially without CEQA review under strict timelines. In the current 5th cycle, most jurisdictions in California, including Brentwood, are subject to SB 35. Brentwood must streamline projects that apply for SB 35 approval, set aside at least 50% of units for lower-income residents, and meet all of the other requirements. To date, no such project has been submitted to the City.
HCD has also formed the Housing Accountability Unit (HAU) to investigate violations of housing laws and may refer violators to the Attorney General. HCD has emphasized that it expects cities
1 It should be noted that although January 31, 2023 is the statutory deadline to have the Housing Element adopted for our jurisdiction, there is a 120-day grace period that is allowed in order to gain compliance with HCD
3 to implement the programs included in their housing elements. To date, its emphasis has been on programs that propose changes in zoning.
FRAMEWORK CONSIDERATIONS FOR DEVELOPING THE SITES INVENTORY The following outlines some of the key assumptions and “building blocks” that provide the framework for developing the sites inventory that are both acceptable to HCD and were used to develop the analysis presented to the City Council on June 1st.
Zoning Capacity and Density Assumptions for Initial Inventory City staff and the consultant team have evaluated the City’s residential land inventory (i.e. sites zoned for residential use “today” with capacity to accommodate additional development) starting with a review of the adopted 2015 (5th Cycle) Housing Element Site Inventory which is included in Attachment 6a and 6b for reference. In addition to the existing capacity, staff and the consultant team also reviewed the “pipeline” of residential projects already entitled in the coming one- to two- year period and Accessory Dwelling Unit projections (ADU projections are described in greater detail further in the report). This comprehensive list of sites with associated map are included as Attachment 3 and 4, and together, constitute a baseline of properties that can potentially accommodate at least a portion of the City’s RHNA. A map of the City showing all properties that have general plan designations that allow for residential development has been included for reference as Attachment 2. It should be noted that the PA-1 Specific Plan, Brentwood Boulevard Specific Plan, and Downtown Specific Plan have multiple areas which allow for residential and mixed use development under the various designations, but only have one General Plan designation for the entire specific plan area; therefore, the General Plan map does not depict all of the residential sites allowed under the specific plans. “No Net Loss” Law and Housing Buffer
HCD recommends identifying sites with zoning capacity sufficient to provide between 15 and 30 percent more units than the identified lower income RHNA, often called the housing “buffer”2 .
This is to ensure that the City has enough properly zoned sites throughout the eight-year planning period. Under a provision of state law called the “no net loss” law, each time the City approves a project on a site listed in the housing element, it must compare the project with both the number of units shown in the housing element and the projected income level. If either the project has fewer units than shown in the housing element, or they are developed at a different income level, the City must demonstrate that it still has enough properly zoned sites to meet the RHNA at all income levels. For instance, if a site is identified as suitable for 100 lower income units, but a project is proposed with 100 units but only 10 lower income units, then the City must show that it still has enough properly zoned sites to accommodate its lower income RHNA. If there are not enough properly zoned sites in the inventory, the City must identify and make available additional sites within 180 days, which may require rezoning. A buffer is particularly important for sites shown as suitable for lower income housing.
General Plan Consistency
In addition to including a buffer, staff recommends maintaining consistency with the General Plan to estimate potential unit capacity for the sites, using an “average or mid-point” density for all sites. Alternatively, the City could require a minimum density on each site and use that to calculate realistic capacity3
. The mid-point assumption can be supported by the General Plan and past project approvals (development at or above the mid-point density).
Based on guidance provided by HCD for higher-density housing sites, the inventory needs to reflect a realistic capacity that takes account aspects like physical constraints, necessary on-site infrastructure and circulation, parking, and development standards like height and setback requirements. Using an average or mid-point density for high-density sites will help to align the
2 Page 22 of the HCD Sites Inventory Guidebook included as Attachment 1 3 Page 19 of HCD Sites Inventory Guidebook included as an Attachment 1
4 initial inventory with these realistic capacity assumptions going forward, and not be overly aggressive in the assumed capacity for particular sites.
Default Densities and Capacity Assumptions by Affordability Level The inventory process requires the City to identify the density ranges at which each site will be developed. As discussed previously, staff has recommended using an “average or mid-point” density for all sites, including low, medium and high-density ranges to not be overly aggressive.
With respect to the various income categories for which the inventory must show adequate capacity, State law provides for a “default density4
” which is a zoning density which can be
assumed to be suitable to yield the potential capacity for lower-income housing units. In Brentwood, the default density for units to be projected as lower-income units in the inventory is 30 dwelling units per acre (du/ac). There is no default density for moderate-income units, but districts allowing less than 30 du/ac, in the range of 15 to 25 du/ac, may be appropriate.
Although not explicitly stated by HCD, based on past performance and peer city assumptions, the City is making the informed assumption that sites zoned at less than 30 du/ac, in the range of 15 to 25 du/ac, have the potential to accommodate capacity for moderate-income units.
Per HCD guidelines (Attachment 1), the City may project all units in the inventory that allow 30 du/ac (default density) or more as affordable for lower-income. Any site designated to accommodate lower income housing must also be between 0.5 acres – 10 acres and be projected to accommodate at least 16 units. The City has three land use designations that can accommodate residential development at this default density that would qualify for lower-income development including the R-VHD and two designations within the Innovation Center Specific Plan (PA-1), (Transit Village/Mixed-Use and Multi-Family Very High Residential).
As discussed later in this report, depending on the assumptions made, the majority of the lowerincome RHNA could be addressed within PA-1 using HCD’s recommendations, as well as a significant proportion of above-moderate units on other existing higher density housing sites, without requiring any rezoning. It is a policy decision for the City Council as to how to best allocate affordability assumptions for sites at various densities in various locations.
ANALYSIS OF EXISTING ZONING CAPACITY
The following outlines the City’s RHNA, the components that make up the current sites inventory, and how the projected shortfall is calculated. 6th Cycle RHNA
Table 1 summarizes the 6th Cycle RHNA for the City of Brentwood. The RHNA is distributed among the following income categories, each of which represent relative affordability to households as a proportion of the Countywide Area Median Income (AMI).
4 Sometimes called “Mullin densities” after the author of AB 2348, Statutes of 2004, which originated these requirements.
5 Table 1: RHNA Allocation Breakdown
Income Category Percentage of Area
Median Income
Brentwood RHNA
Extremely Low Income (ELI)* <30%
402 Very Low Income (VLI)* 31-50%
Low Income (LI) 51-80% 232
Moderate Income (MI) 81-120% 247
Above-Moderate Income (AMI) >120% 641
Total 1,522 Units
Analysis of Existing/Baseline Zoning Capacity
In order to provide a comprehensive analysis of the City’s existing zoning capacity, staff has utilized the following components to address the City’s 6th Cycle RHNA, discussed in further detail below.
Existing Residential Zoning
This includes parcels zoned for residential uses with capacity to add new housing units within the City’s single-family and multi-family residential zoning districts. Although all vacant or underutilized parcels that currently maintain zoning or general plan designations that allow residential development may be included within the inventory, staff recommends that the focus be on sites that can accommodate the largest amount of below market rate housing at the highest densities. Therefore, not all residentially zoned sites will need to be listed on the final inventory. A map of all parcels with a general plan designation that allows for residential development (excluding PA-1 and Specific Plan areas as noted above) is included for reference.
Capacity in Existing Specific Plans
This includes vacant or underutilized parcels within the PA-1 Specific Plan5 that allow for residential development with capacity to add new housing units.
Pipeline Projects
Pipeline Projects are defined as residential projects already entitled, under review, or expected to be entitled during the eight year planning period, including projects under construction but which would not have building permits finaled by June 30, 2022.6 This includes new proposed projects to be approved under the City’s revised Affordable Housing Ordinance. Although HCD allows Pipeline Projects to include projects currently under review, staff has only included entitled projects that have received City approval.
ADU Production
HCD has issued a determination to allow local jurisdictions to “count” ADU production as a component of the sites inventory based on a formula that considers the average annual number of ADU permits issued in the City over the last three years, multiplied over the Housing Element’s eight-year planning period. In 2019 the City issued nine permits, in 2020 the City issued 20 permits, and in 2021 the City issued 16. In the first six months of 2022, the City has only issued 2 new ADU permits. Since the City has not been able to show that there is currently an upward trend in ADU production, the average from 2019, 2020, and 2021 would need to be
5 Estimated capacity within PA-1 is based on draft revisions that the Planning Commission recommended for City Council approval on June 21, 2022, which will be reviewed by the City Council in July 2022. 6 The Housing Element 6th RHNA Cycle reporting period technically begins on July 1, 2022, meaning that units for which building permits are finaled (i.e., approved for occupancy) on or after this date, can be included in the 2023-2031 inventory.
6 used for future projections. This would allow the City to project 15 ADU’s per year over the next eight years for a total of 135 new units. Kimley-Horn strongly recommends this approach to projection – more aggressive projection approaches attempted by other cities Kimley-Horn has worked with have not been approved by HCD.
As stated in the report previously presented to the City Council on June 1st, ABAG has prepared a preliminary ADU Affordability Report, currently under review by HCD, intended as a basis to allocate ADU production into the various RHNA affordability categories. If HCD accepts the report’s analysis, ADU’s would be permitted to be counted at the following income levels: 30% Very Low Income, 30% Low Income, 30% Moderate Income, and 10% Above Moderate Income.
Follow-up or verification of affordability levels would not be required if utilizing these accepted income levels. Utilizing these assumptions, the City would be able to count the following ADU production shown in Table 2.
Table 2: Summary of Projected ADU Production by Affordability Income Category ABAG Affordability
Assumptions
Projected ADU Production
Very Low Income (VLI) 30% 40
Low Income (LI) 30% 41
Moderate Income (MI) 30% 40
Above-Moderate Income (AMI) 10% 14
Total 135 Units
These assumptions can potentially be adjusted if the City Council wants to consider including strong policies and programs to encourage the development of ADUs. Discussion of how the numbers may be adjusted and what types of programs may be considered are discussed further in the Site Inventory and Affordability Assumption Strategies section of the report.
Together, existing residentially-zoned properties, pipeline projects, and ADUs constitute a baseline of zoned capacity that can accommodate the City’s RHNA. The difference between this number, and the RHNA in each category, represents the remaining need in each category.
Table 3 below summarizes the results of staff’s initial evaluation of pipeline projects and ADU production assumptions. The table also includes the total existing residential development capacity; however, the capacity has not been assigned affordability assumptions until further direction is provided as discussed in the Site Inventory and Affordability Assumption Strategies section of the report. Notably, the unit numbers presented in the following tables represent calculated capacity within the City’s existing General Plan and zoning designations, rather than a specific obligation to meet a portion of the City’s RHNA on specific sites.
7 Table 3: Summary of Preliminary Capacity Analysis of RHNA and SiteStrategies Very LowIncome
LowIncomeModerateIncome
Above
ModerateIncomeTotal Units
2023-2031 RHNA
Allocation 402 232 247 641 1,552
RHNA Strategies Under Existing Zoning
Projects Currently in
the Pipeline 2 0 966 968
Projected ADU
Production 80 41 14 135
Remaining Need 552 206 -- 449
PA-1 (Innovation
Center) -- -- -- 2,222
Vacant Residential
Land -- -- -- 1,622
Total Unit Potential 82 41 980 4,947
Buffer/Gap -87% -83.5% 153% 319%
IMPACTS OF THE AFFORDABLE HOUSING ORDINANCE
At the June 1, 2022 Joint Workshop, concerns were also raised questioning whether the City could include projected affordable units that may be gained from low density housing developments as part of the City’s updated Affordable Housing Ordinance. While it may seem counterintuitive, HCD does not permit affordable units required through the City’s Affordable Housing Ordinance to be counted as “projected” units in the Sites Inventory unless they are proposed or approved as part of a specific housing development. These units are; however, able to be counted toward the City’s RHNA once a project is approved by the City. According to HCD’s Housing Element Site Inventory Guidebook (2020) (Attachment 1):
The analysis of ‘appropriate zoning’ should not include residential buildout projections resulting from the implementation of a jurisdiction’s inclusionary program or potential increase in density due to a density bonus, because these tools are not a substitute for addressing whether the underlining (base) zoning densities are appropriate to accommodate the RHNA for lower income households.
There are currently approximatively 10 residential developments under review with a total of 633 units currently proposed. If all of these projects were approved as currently proposed, the City would gain an additional 15 low- and very-low income units and 39 moderate income units. As noted above, although these projects are currently under review and are eligible to be included as Pipeline Projects, staff has only included entitled projects that have received City approval as Pipeline Projects.
On June 21, 2022, the Planning Commission recommended changes to the City’s Affordable Housing Ordinance to require a 13% affordable housing obligation for ownership and rental projects (3% Very Low / 4% Low / 6% Moderate). They also recommended changes to limit the option to pay a fee in lieu of constructing the required units to residential developments of 5-9 units, and removing the in lieu payment option for single-family residential development of 10 or more units. The proposed changes are tentatively scheduled to be presented to the City Council on July 12, 2022 for review and adoption.
8 SITE INVENTORY AND AFFORDABILITY ASSUMPTION STRATEGIES On June 1, 2022, staff presented the City Council and Planning Commission with an update on the Housing Element Update process, a description of the sites strategies, and a preliminary analysis that showed that the City has enough sites to meet the City’s RHNA obligation without having to rezone any parcels. This is a highly unusual position for communities in the sixth housing element cycle. Because the RHNA for most communities has increased significantly compared with the fifth cycle, most need to rezone substantial areas at higher densities. For instance, the total sixth cycle RHNA for Marin County is five times as large as in the fifth cycle.
The City Council reviewed the preliminary site strategies including initial assumptions and directed staff to return with a more detailed report on the sites inventory including a comprehensive draft sites inventory of every parcel when available for review. At this meeting, specific concerns were also raised regarding staff’s initial recommendation to assume that sites meeting the minimum default density of 30 du/ac be assumed to include 30% low income units and 10% moderate income units. Based on this feedback, staff has provided a comprehensive list of sites under consideration to be included in the draft sites inventory (attached for reference) and has three strategies for the City Council’s review and consideration. All three strategies include the same baseline for pipeline projects and existing residential inventory parcels, however, each will provide different affordability assumptions, and one with different ADU projections.
The strategies provided are only a sample of the strategies and assumptions that could be utilized to address the City’s RHNA. There will be an opportunity at June 21st workshop to use in real time, a model to make affordability and site assumption adjustments as necessary. A summary of the three identified strategies are included in Attachment 5 and below in Table 4 followed by a detailed discussion of each.
Table 4: Strategy Summaries
Strategy 1 Strategy 2 Strategy 3
Description No Rezoning Required,
Reduced Affordability
with Increased ADU
Assumptions
No Rezoning Required,
HCD Approved
Methodology
No Rezoning Required,
HCD Approved
Methodology with
Conservative
Affordability
Assumptions
HCD-supported No Yes Yes
Affordability
Assumptions*
21% Low and Very
Low, and 6% Moderate
100% Low and Very
Low, and 100%
Moderate
30% Low and Very
Low, and 10%
Moderate
Affordable Unit
Potential
VL/L: 635 units
Mod: 264 units
AMod: 4,183 units
Total: 5,082 units
VL/L: 2,321 units
Mod: 851 units
AMod: 1,775 units
Total: 4,947 units
VL/L: 755 units
Mod: 347 units
AMod: 1,405 units
Total: 4,947 units
Buffer 0% Low/Very Low,
7% Moderate-, and
553% Above Moderate
266% Low/Very Low,
245% Moderate-, and
177% Above Moderate
19% Low/Very Low,
40% Moderate-, and
500% Above Moderate
No Not Loss
Implications
Highly likely to trigger
no net loss
Least likely to trigger no
net loss
More likely than
Strategy 2 to trigger no
net loss
*Affordability assumptions are based on the sites inventory with the assumption that sites that allow 30 du/ac (default density) or more can accommodate capacity for lower-income units and sites that allow 15 to 25 du/ac can accommodate capacity for moderate-income units.
9 Only strategies 2 and 3 of the aforementioned options currently create the capacity necessary to meet RHNA with a buffer consistent with HCD recommendations. Strategy 1 is presented to illustrate what the inventory may look like using affordability assumptions that are more conservative and more closely track the proposed Affordable Housing Ordinance (3%, 4%, 6%), and other strategies by which Brentwood can pursue meeting the RHNA obligation, although additional adjustments would be required. Strategy 1 is not recommended due to its reliance on ADU’s, a strategy HCD has repeatedly disapproved. Table 5 below summarizes the affordability assumptions under each strategy followed by a more detailed analysis of each strategy.
Table 5: Affordability and Default Densities by General Plan Designation Density Category Density Range Income Level Potentially Accommodated in Inventory
Above-Mod. Mod. Low
Strategy 1 Affordability Assumptions
Low - Medium Density < 15 du/ac 100%
High Density 15 – 25 du/ac 70% 6%
Very High Density > 30 du/ac 60% 6% 21%
Strategy 2 Affordability Assumptions
Low - Medium Density < 15 du/ac 100%
High Density 15 – 25 du/ac 0% 100%
Very High Density > 30 du/ac 0% 0% 100%
Strategy 3 Affordability Assumptions
Low - Medium Density < 15 du/ac 100%
High Density 15 – 25 du/ac 70% 30%
Very High Density > 30 du/ac 60% 10% 30%
Strategy 1: Reduced Affordability with Increased ADU Assumptions ADU Assumptions
As indicated in the report, HCD allows ADU projections based on previous production averages projected over the next 8-year cycle. In order to increase these assumptions, the City would be required to include additional incentives, documented in new programs that could facilitate the added production. Additional programs that could be included to incentivize additional ADU production could include the following:
• programs to waive ADU plan check and permit fees;
• pre-approved ADU plans to streamline the project application and review process and reduce upfront project costs;
• promotion of ADUs through handouts, simplified application forms; and • exploration of a program to provide ADU funding assistance to homeowners that provide affordability covenants.
In addition to these programs, the City would be required to document and clearly justify to HCD how and why the City believes that these programs would work as well as creating a monitoring program to track ADU and JADU creation and affordability levels throughout the planning period. The program would require the City to monitor the development of accessory units at all
10 income levels and track progress annually. If ADUs are not approved and permitted at the rate anticipated in the City’s increased projections, the City would need to adopt additional incentives within 2 years of the original incentives, and every two years subsequent, until ADU construction matches ADU projections.
Staff has reviewed the City’s current Municipal Code regulations, residential development trends, and overall characteristics of residential properties within the city and does not believe that with added programs and an increased effort to highly encourage and incentivize ADU production throughout the city that there is additional realistic capacity and believes that doubling the current projections to a total of 30 ADUs per year would be rejected by HCD.
Although strategies similar to this have been approved in limited capacity within California, in those cases analysis and growth trends were typically provided to show a growing trend in production right up to adoption of the Housing Element. Since Brentwood is unable to show any substantial growth in production in the past six months to a year, adequate justification is not likely in this case. If increased assumptions were to still be considered, possible revised ADU production and assumptions are shown below in Table 6.
Table 6: Summary of Projected ADU Production by Affordability Income Category ABAG
Affordability
Assumptions
Original ADU
Productions
Increased ADU
Productions
Very Low Income (VLI) 30% 40 80
Low Income (LI) 30% 41 82
Moderate Income (MI) 30% 40 80
Above-Moderate Income
(AMI)
10% 14 28
Total 135 Units 270 Units
High and Very High Density Affordability Assumptions
In addition to higher ADU projections, Strategy 1 includes assumptions of 27% affordable units (9% very low-, 12% low-, and 6% moderate-income units) on all sites meeting the minimum default density of 30 du/ac. This assumption would be above what is required as part of the City’s Affordable Housing Ordinance, but would provide more conservative estimates and be more closely aligned with the City’s RHNA requirements. However, in this scenario the City would be most likely to need to modify affordability assumptions, or upzone additional sites during the planning period because the remaining undeveloped sites would be projected to provide few affordable units.
Table 7 below summarizes the results of initial evaluation of existing residential development capacity utilizing Strategy 1 capacity assumptions. Strategy 1 would result in the following projected capacity which would include a zero percent buffer in the lower income category:
11 Table 7: Summary of Strategy 1 Capacity Analysis
Very
LowIncome
LowIncomeModerateIncome
Above
ModerateIncomeTotal
2023-2031 RHNA
Allocation 402 232 247 641 1,552
Strategy 1 Capacity Under Existing Zoning
Projects Currently in the
Pipeline 2 0 966 968
Projected ADU Production 162 81 27 270
Remaining Need 471 166 -- 314
PA-1 (Innovation Center) 377 133 1,712 2,222
Vacant Residential Land 94 50 1,478 1,622
Total Unit Potential 635 264 4,183 5,082
Units +/- and Buffer/Gap
% 1 unit, 0% 17 units, 7% 3,542 units,
553%
3,844 units,
227%
CEQA Implications under Strategy 1
If Strategy 1 is chosen, no rezoning would be required and although affordability assumptions would be modified, all density assumptions would continue to be based on existing General Plan designations and therefore the Housing Element Update may be exempt from CEQA, pursuant to Section 15061(b)(3) of the State CEQA Guidelines, similar to Strategy 1 and 2.
Strategy 2: No Rezoning Required, HCD Approved Methodology Strategy 2 utilizes the preliminary analysis of RHNA and site strategies as presented in the HCD Guidebook. Based on HCD guidelines, the City may make assumptions up to 100% lowerincome affordability for all sites allowing 30 du/ac or more, and 100% moderate-income affordability for all sites allowing between 15-25 du/ac. Although utilizing this approach would require additional analysis and justification of the sites designated for lower income housing, this is the typical assumption that most communities in California have used. Utilizing this method would also provide the City with the largest buffer in the very low- and low-income categories.
Table 8 below summarizes the results of initial evaluation of existing residential development capacity utilizing Strategy 2 capacity assumptions. Strategy 2 would result in the following projected capacity which would include a large buffer in each income category:
12 Table 8: Summary of Strategy 2 Capacity Analysis
Very LowIncome
LowIncomeModerateIncome
Above
ModerateIncomeTotal
2023-2031 RHNA
Allocation 402 232 247 641 1,552
Strategy 2 Capacity Under Existing Zoning
Projects Currently in
the Pipeline 2 0 966 968
Projected ADU
Production 80 41 14 135
Remaining Need 552 206 -- 449
PA-1 (Innovation
Center) 1,793 429 0 2,222
Vacant Residential
Land 446 381 795 1,622
Total Unit Potential 2,321 851 1,775 4,947
Units +/- and
Buffer/Gap % 1,687 units, 266% 604 units,
245%
1,134 units,
177%
3,844 units,
219%
Strategy 2 could also be proposed with fewer sites and a smaller buffer, although this would be more likely to trigger no net loss. If that occurred, however, the City would be able to make a finding that additional properly zoned sites are available in the City.
CEQA Implications under Strategy 2
If Strategy 2 is chosen, no rezoning would be required and all density assumptions would be based on existing General Plan designations; therefore, the Housing Element Update would be exempt from CEQA review, pursuant to Section 15061(b)(3) of the State CEQA Guidelines, which provides that a project is exempt from CEQA if the activity is covered by the common sense exemption that CEQA applies only to projects which have the potential for causing a significant effect on the environment. However, HCD may require that other programs be included that could require additional CEQA review.
Strategy 3: No Rezoning Required, HCD Approved Methodology with Conservative Affordability Assumptions
Strategy 3 utilizes the preliminary analysis of RHNA and sites strategies as presented in the initial sections of this report. As stated above, based on HCD guidelines the City may make assumptions up to 100% lower-income affordability for all sites allowing 30 du/ac or more, and 100% moderate-income affordability for all sites allowing up to 20 du/ac. However, a more conservative assumption would project 30% low-income affordability and 10% moderate-income affordability for very high-density sites and 30% moderate-income affordability for high-density sites. Since not all sites are likely to develop at even this level of affordability, the City would need to carefully monitor development to ensure that it retains adequate sites at all times for the lower and moderate income categories. Because each site would be projected to have fewer affordable units, the City would be more likely to need to modify assumptions or up zone additional sites later in the planning period. A 100% affordable housing development would greatly assist in meeting the City’s RHNA.
13 Table 9 below summarizes the results of initial evaluation of existing residential development capacity utilizing Strategy 3 capacity assumptions. Strategy 3 would result in the following projected capacity which would include a minimum 19% buffer in the lower income category:
Table 9: Summary of Strategy 3 Capacity Analysis
Very LowIncome
LowIncomeModerateIncome
Above
ModerateIncomeTotal
2023-2031 RHNA
Allocation 402 232 247 641 1,552
Strategy 3 Capacity Under Existing Zoning
Projects Currently in
the Pipeline 2 0 966 968
Projected ADU
Production 80 41 14 135
Remaining Need 552 206 -- 449
PA-1 (Innovation
Center) 539 223 1,460 2,222
Vacant Residential
Land 134 83 1,405 1,622
Total Unit Potential 755 347 3,845 4,947
Units +/- and
Buffer/Gap % 121 units, 19% 100 units,
40%
3,204 units,
500%
3,844 units,
219%
CEQA Implications under Strategy 3
If Strategy 3 is chosen, no rezoning would be required and all density assumptions would be based on existing General Plan designations; therefore, the Housing Element Update would be exempt from CEQA, pursuant to Section 15061(b)(3) of the State CEQA Guidelines, which provides that a project is exempt from CEQA if the activity is covered by the common sense exemption that CEQA applies only to projects which have the potential for causing a significant effect on the environment. However, HCD may require that other programs be included that could require additional CEQA review.
NEXT STEPS
As noted, the creation of the site inventory is an important initial step in the Housing Element Update process. Following this meeting, staff and the consultant team will continue to develop and refine the analysis of existing sites and solidify the existing capacity that can be used to address the City’s RHNA. Based on where staff and the consultant team currently are in the analysis, a revised schedule and timeline has been prepared for Strategies 1, 2, and 3. A summary of the revised schedule is included below.
14 It should be noted that although January 31, 2023 is the statutory deadline to have the Housing Element adopted for our jurisdiction, there is a 120-day “grace period” that is allowed in order to gain compliance with HCD. Under Strategies 1, 2, or 3, Brentwood would be utilizing this 120- day grace period to gain certification.
Staff also notes that in addition to working on reviewing the site inventory and goals and policies, staff and the consultant team are continuing to advance other components of the Housing Element. These include:
• Summary of input from the initial on-line community survey. The survey concluded on Friday, June 10th and included a total of 526 responses. A comprehensive summary of the survey results will be presented to the City Council when available. • Completion of the Public Review Draft of the 2023-2031 Housing Element Update that will address all of the mandatory informational requirements and analyses supporting the Housing Element, including findings of the required housing needs assessment; analysis of constraints to housing; and evaluation of existing Housing Element policies and programs. This draft report is anticipated to be published and presented to the City Council and Planning Commission in August ahead of submission to HCD.
CONCLUSION
To move forward in the planning process in drafting the Housing Element Update, it is imperative that the City Council provide direction on which strategies should be used in forming baseline site inventory and affordability assumptions. Staff is recommending that the City Council review, discuss, and receive public comments on the Housing Element Update RHNA sites strategies and provide direction to staff on which of the above site strategies to move forward with in order to complete the public review draft of the Housing Element.
Attachments
1. HCD Site Inventory Guidebook
2. Residential General Plan Map
3. Draft Site Inventory Excel Sheet
4. Draft Site Inventory Map
5. Strategy 1-3 Site Analysis Tables
6. 5th Cycle Housing Element Site Inventory Analysis
a. Multi-Family Sites
b. Single-Family Sites
Task Timeframe
City Council Workshop July 21, 2022
Publish Public Review Draft August 2022
Joint City Council and Planning Commission Meeting –
Public Review Draft
August 2022
Internally Review Community Input/Feedback and Make
Revisions
Early September 2022
First HCD Submittal Mid-September 2022
Response to HCD Comments and Revisions Mid-December 2022 2nd Submission of Draft Housing Element to HCD February 2023 Response to HCD Comments and Revisions April 2023
3rd Submission of Draft Housing Element to HCD if needed May 2023 HCD Letter of Substantial Compliance May 2023
Adoption Public Hearings May 2023
STATE OF CALIFORNIA - BUSINESS, CONSUMER SERVICES AND HOUSING AGENCY
DEPARTMENT OF HOUSING AND COMMUNITY DEVELOPMENT
DIVISION OF HOUSING POLICY DEVELOPMENT
2020 W. El Camino Avenue, Suite 500
Sacramento, CA 95833
(916) 263-2911 / FAX (916) 263-7453
www.hcd.ca.gov
June 10, 2020
MEMORANDUM FOR: Planning Directors and Interested Parties FROM: Megan Kirkeby, Acting Deputy Director
Division of Housing Policy Development
SUBJECT: Housing Element Site Inventory Guidebook
Government Code Section 65583.2
The housing element of the general plan must include an inventory of land suitable and available for residential development to meet the locality’s regional housing need by income level. The purpose of this Guidebook is to assist jurisdictions and interested parties with the development of the site inventory analysis for the 6th Housing Element Planning Cycle and identify changes to the law as a result of Chapter 375, Statutes of 2017 (AB 1397), Chapter 958, Statutes of 2018 (AB 686), Chapter 664, Statutes of 2019 (AB 1486), and Chapter 667, Statutes of 2019 (SB 6). The Guidebook should be used in conjunction with the site inventory form developed by the California Department of Housing and Community Development (HCD). These laws introduced changes to the following components of the site inventory:
• Design and development of the site inventory (SB 6, 2019) • Requirements in the site inventory table (AB 1397, 2017 AB 1486, 2019) • Capacity calculation (AB 1397, 2017)
• Infrastructure requirements (AB 1397, 2017)
• Suitability of nonvacant sites (AB 1397, 2017)
• Size of site requirements (AB 1397, 2017)
• Locational requirements of identified sites (AB 686, 2018) • Sites identified in previous housing elements (AB 1397, 2017) • Nonvacant site replacement unit requirements (AB 1397, 2017) • Rezone program requirements (AB 1397, 2017)
The workbook is divided into five components: (Part A) identification of sites; (Part B) sites to accommodate the lower income RHNA; (Part C) capacity analysis; (Part D) non-vacant sites; and (Part E) determination of adequate sites.
If you have any questions, or would like additional information or technical assistance, please contact the Division of Housing Policy Development at (916) 263-2911.
Attachment 1
Table of Contents
BACKGROUND AND PURPOSE ........................................................................................ 3 Housing Element Site Inventory Requirements ................................................................ 3 SITE INVENTORY GUIDEBOOK FRAMEWORK................................................................ 4 Guidebook Structure......................................................................................................... 4 PART A: IDENTIFICATION OF SITES................................................................................. 5 Step 1: Identification of Developable Sites ....................................................................... 5 Step 2: Inventory of Sites.................................................................................................. 7 Step 3: Infrastructure Availability ...................................................................................... 7 Step 4: Map of Sites ......................................................................................................... 8 Step 5: Determination of Consistency with Affirmatively Furthering Fair Housing ............ 8 Step 6: Sites by RHNA Income Category ......................................................................... 9 Step 7: Environmental Constraints ................................................................................. 10 PART B: SITES TO ACCOMMODATE LOW AND VERY LOW- INCOME RHNA ............. 11 Step 1: Sites Used in Previous Planning Periods Housing Elements ............................. 11 Step 2: Zoning Appropriate to Accommodate Low- and Very Low- Income RHNA ........ 13 Step 3: Size of Sites ....................................................................................................... 15 PART C: CAPACITY ANALYSIS........................................................................................ 19 Step1: Utilizing minimum densities to calculate realistic capacity of sites....................... 19 Step 2: Utilizing factors to calculate realistic capacity of sites ........................................ 19 PART D: NONVACANT SITES .......................................................................................... 24 Step 1: Description of the nonvacant site ....................................................................... 25 Step 2: Nonvacant site analysis methodology ................................................................ 25 Step 3: Reliance on nonvacant sites to accommodate more than 50 percent of the RHNA for lower income households .......................................................................................... 26 Step 4: Program and policy requiring replacement of existing affordable units .............. 28 PART E: DETERMINATION OF ADEQUATE SITES......................................................... 30 Step 1: Consider any alternative means of meeting the RHNA ...................................... 30 Step 2: Determine whether there is sufficient capacity to accommodate the RHNA for the jurisdiction by income. .................................................................................................... 32 Step 3: Adequate Sites Program .................................................................................... 33 ATTACHMENT 1: SUMMARY OF NEW LAWS REFERENCED IN THE GUIDEBOOK .... 39 ATTACHMENT 2: GOVERNMENT CODE SECTION 65583.2 .......................................... 40 Attachment 1
Site Inventory Guidebook Page 3 May 2020
BACKGROUND AND PURPOSE
Housing Element Site Inventory Requirements
Scarcity of land with adequately zoned capacity is a significant contributor to increased land prices and housing development costs. A lack of adequately zoned sites exacerbates the already significant deficit of housing affordable to lower income households. An effective housing element provides the necessary conditions for conserving, preserving and producing an adequate supply of housing affordable at a variety of income levels and provides a vehicle for establishing and updating housing and land-use strategies to reflect changing needs, resources, and conditions. Among other things, the housing element establishes a jurisdiction’s strategy to plan for and facilitate the development of housing over the five-to-eight year planning period by providing an inventory of land adequately zoned or planned to be zoned for housing and programs to implement the strategy.
The purpose of the housing element’s site inventory is to identify and analyze specific land (sites) that is available and suitable for residential development in order to determine the jurisdiction’s capacity to accommodate residential development and reconcile that capacity with the jurisdiction’s Regional Housing Need Allocation (RHNA). The available and suitable sites are referred to as “adequate sites” throughout this Guidebook. The site inventory enables the jurisdiction to determine whether there are sufficient adequate sites to accommodate the RHNA by income category. A site inventory and analysis will determine whether program actions must be adopted to “make sites available” with appropriate zoning, development standards, and infrastructure capacity to accommodate the new development need.
Sites are suitable for residential development if zoned appropriately and available for residential use during the planning period. If the inventory demonstrates that there are insufficient sites to accommodate the RHNA for each income category, the inventory must identify sites for rezoning to be included in a housing element program to identify and make available additional sites to accommodate those housing needs early within the planning period.
Other characteristics to consider when evaluating the appropriateness of sites include physical features (e.g., size and shape of the site, improvements currently on the site, slope instability or erosion, or environmental and pollution considerations), location (e.g., proximity to and access to infrastructure, transit, job centers, and public or community services), competitiveness for affordable housing funding (e.g., Low Income Housing Tax Credit scoring criteria), and likelihood or interest in development due to access to opportunities such as jobs and high performing schools1. When determining sites to include in the inventory to meet the lower income housing need, HCD recommends that a local government first identify development potential in high opportunity neighborhoods. This will assist the local government in meeting its requirements to affirmatively further fair housing and ensure developments are more competitive for development financing. 1 Please Note: Significant increases in the housing capacity of the residential land inventory of the housing element could also warrant planning for updating of other elements, including the land use, safety, circulation elements and inclusion of an environmental justice element or environmental justice policies. The housing element must include a program describing the means by which consistency will be achieved with other general plan elements and community goals (GC 65583(c)(8)).
Attachment 1
Site Inventory Guidebook Page 4 May 2020
SITE INVENTORY GUIDEBOOK FRAMEWORK
The following is a Guidebook designed to assist a jurisdiction through the site inventory analysis required by Housing Element Law. Use of the Guidebook is not required for a determination of compliance by HCD. The Guidebook is intended to facilitate the jurisdiction in determining if adequate sites are available by income category to accommodate the jurisdiction’s share of the RHNA or if rezoning or other program actions are needed. Areas of the law that are newly added since the beginning of the 5th housing element cycle are marked with the designation *NEW*.
Guidebook Structure
PART A: IDENTIFICATION OF SITES
General characteristics of suitable sites identified in the inventory, including zoning, infrastructure availability, and environmental constraints, among others.
PART B: SITES TO ACCOMMODATE LOW AND VERY LOW- INCOME RHNA Analysis to determine if sites are appropriate to accommodate the jurisdiction’s RHNA for low- and very low-income households.
PART C: CAPACITY ANALYSIS
Description of the methodology used to determine the number of units that can be reasonably developed on a site.
PART D: NONVACANT SITES
Analysis to determine if nonvacant sites are appropriate to accommodate the jurisdiction’s RHNA.
PART E: DETERMINATION OF ADEQUATE SITES
After consideration of the above analysis and any alternate methods to accommodate RHNA, the determination of whether sufficient sites exist to accommodate RHNA or if there is a shortfall requiring a program to rezone additional sites.
Attachment 1
Site Inventory Guidebook Page 5 May 2020
PART A: IDENTIFICATION OF SITES
Step 1: Identification of Developable Sites
Government Code section 65583.2(a)
Generally, a site is a parcel or a group of parcels that can accommodate a portion of the jurisdictions RHNA. A jurisdiction must identify, as part of an inventory, sites within its boundaries (i.e., city limits or a county’s unincorporated area)2 that could have the potential for new residential development within the eight- or five-year timeframe of the housing element planning period.
Types of sites include:
• Vacant sites zoned for residential use.
• Vacant sites zoned for nonresidential use that allow residential development. • Residentially zoned sites that are capable of being developed at a higher density (nonvacant sites, including underutilized sites).
• Sites owned or leased by a city, county, or city and county. • Sites zoned for nonresidential use that can be redeveloped for residential use and a program is included to rezone the site to permit residential use.
Pending, approved, or permitted development:
Projects that have been approved, permitted, or received a certificate of occupancy since the beginning of the RHNA projected period may be credited toward meeting the RHNA allocation based on the affordability and unit count of the development. For these projects, affordability is based on the actual or projected sale prices, rent levels, or other mechanisms establishing affordability in the planning period of the units within the project (See Part E). For projects yet to receive their certificate of occupancy or final permit, the element must demonstrate that the project is expected to be built within the planning period.
Definition of Planning Period: The “Planning period” is the time period between the due date for one housing element and the due date for the next housing element (Government Code section 65588(f)(1).) For example, the San Diego Association of Governments’ 6th Cycle Planning Period is April 15, 2021 to April 15, 2029.
Definition of Projection Period: “Projection period” is the time period for which the regional housing need is calculated (Government Code section 65588(f)(2).). For example, the San Diego Association of Governments’ 6th Cycle Projection Period is June 30, 2020 to April 15, 2029. End definitions
Please note, sites with development projects where completed entitlements have been issued are no longer available for prospective development and must be credited towards the RHNA based on the affordability and unit count of the development. “Completed entitlements” means a housing development or project which has received all the required land use approvals or entitlements necessary for the issuance of a building permit. This 2 In some cases, jurisdictions may want to include sites anticipated to be annexed in the planning period.
Annexation is considered a rezoning effort to accommodate a shortfall of sites. For more information on annexation please see Part E, Step 3.
Attachment 1
Site Inventory Guidebook Page 6 May 2020
means that there is no additional action required to be eligible to apply and obtain a building permit.
Jurisdictions may choose to credit sites with pending projects since the beginning of the RHNA projection period towards their RHNA based on affordability and unit count within the proposed project but must demonstrate the units can be built within the remaining planning period. Affordability must be based on the projected sales prices, rent levels, or other mechanisms establishing affordability in the planning period of the units within the project.
Census definition of a unit: A housing unit is a house, an apartment, a group of rooms, or a single room occupied or intended for occupancy as separate living quarters. Separate living quarters are those in which the occupants do not live and eat with other persons in the structure and which have direct access from the outside of the building or through a common hall. Living quarters of the following types are excluded from the housing unit definition: dormitories, bunkhouses, and barracks; quarters in predominantly transient hotels, motels, and the like, except those occupied by persons who consider the hotel their usual place of residence; quarters in institutions, general hospitals, and military installations, except those occupied by staff members or resident employees who have separate living arrangements.
Student/University Housing: Please be aware, college and university student housing may be considered noninstitutional group quarters and not a housing unit for purposes of meeting the RHNA. According to the census, college/university student housing includes residence halls and other buildings, including apartment-style student housing, designed primarily to house college and university students in group living arrangements either on or off campus. These facilities are owned, leased, or managed by a college, university, or seminary or can be owned, leased, or managed by a private company or agency.
Residents typically enter into “by the bed” leases (i.e., single-liability leases). Another distinguishing factor is that the unit is not available for rent to non-students. For further information on whether university housing meets the definition of a housing unit, please contact the Department of Finance at (916) 323-4086. End definitions Exempt entity-controlled sites (state excess sites, military, university, and tribal land) HCD recognizes that the development of new housing on exempt entity sites (land controlled by exempt federal, state, or tribal entities) can meet a portion of a jurisdiction’s RHNA. However, sites located on land controlled by exempt entities are analyzed differently because the jurisdiction may not have control over the planning, permitting, and decision-making processes of land owned by another public entity.
Sites controlled by exempt entities can be used to accommodate RHNA when documentation can be provided that demonstrates the likelihood that the planned housing will be developed within the current RHNA/housing element cycle. Adequate documentation can vary due to differences in the planning processes on land controlled by exempt federal, state, or tribal entities. The following are examples of documentation that demonstrates the likelihood of housing being developed on sites outside the control of a local government. In each of these examples, the units would have to meet the U.S.
Census Bureau (Census) definition of a housing unit:
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• Agreement with the entity controlling the land that grants the jurisdiction authority regarding approving, permitting, certifying occupancy, and/or reporting new units to the California Department of Finance.
• Documentation from the entity controlling the land that demonstrates planned housing has been approved to be built within the current RHNA cycle. • Data pertaining to the timing of project construction and unit affordability by household income category.
• If the site is listed on the Department of General Services Real Estate Excess State Property map located EO N-06-19 Affordable Housing Development webpage.
Step 2: Inventory of Sites
Government Code section 65583.2(b)
Provide a parcel specific inventory of sites that includes the following information for each site:
• *NEW* Assessor parcel number(s).
• Size of each parcel (in acres).
• General plan land use designation.
• Zoning designation.
• For nonvacant sites, a description of the existing use of each parcel (See Part D) • *NEW* Whether the site is publicly owned or leased.
• Number of dwelling units that the site can realistically accommodate (See Part C) • *NEW* Whether the parcel has available or planned and accessible infrastructure (Part A: Step 3).
• *NEW* The RHNA income category the parcel is anticipated to accommodate (See Part A: Step 5).
• *NEW* If the parcel was identified in a previous planning period site inventory (Part B: Step 1).
*NEW* Please note pursuant to Chapter 667, Statutes of 2019 (SB 6), the site inventory must be prepared using the standards, form, and definitions adopted by HCD. HCD has prepared a form and instructions for this purpose that includes space for the information above and commonly provided optional fields. Starting January 1, 2021, local governments will need to submit an electronic version of the site inventory to HCD on this form along with its adopted housing element.
*NEW* Pursuant to Chapter 664, Statutes of 2019 (AB 1486), at Government Code section 65583.2(b)(3), if a site included in the inventory is owned by the city or county, the housing element must include a description of whether there are any plans to sell the property during the planning period and how the jurisdiction will comply with the Surplus Land Act Article 8 (commencing with Section 54220) of Chapter 5 of Part 1 of Division 2 of Title 5.
Step 3: Infrastructure Availability
Government Code section 65583.2(b)(5)(B)
Determine if parcels included in the inventory, including any parcels identified for rezoning, have sufficient water, sewer, and dry utilities available and accessible to support housing development or whether they are included in an existing general plan program or other mandatory program or plan, including a program or plan of a public or private entity to secure sufficient water, sewer, and dry utilities supply to support housing development on the site in time to make housing development realistic during the planning period. Dry utilities include, at minimum, a reliable energy source that supports full functionality of the Attachment 1
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home and could also include access to natural gas, telephone and/or cellular service, cable or satellite television systems, and internet or Wi-Fi service.
If Yes: Provide an analysis in the housing element describing existing or planned water, sewer, and other dry utilities supply, including the availability and access to parcels on the site inventory, distribution facilities, general plan programs or other mandatory program or plan (including a program or plan of a public or private entity to secure water or sewer service) to support housing development on the site. The housing element must include sufficient detail to determine whether the service levels of water delivery/treatment systems and sewer treatment facilities are sufficient and have the capacity to accommodate development on all identified sites in order to accommodate the RHNA. For example, the water supply should be a reliable supply that meets federal and state drinking water standards.
Please note sites identified as available for housing for above moderate-income households can still be in areas not served by public sewer systems.
If No: Include a program in the housing element that ensures access and availability to infrastructure to accommodate development within the planning period. If this is not possible, the site is not suitable for inclusion in the site inventory or in a program of action identifying a site for rezoning.
Step 4: Map of Sites
Government Code section 65583.2(b)(7)
Provide a map that shows the location of the sites included in the inventory. While the map may be on a larger scale, such as the land use map of the general plan, the more detailed the map, the easier it will be to demonstrate the sites meet new requirements pursuant to Chapter 958, Statutes of 2018 (AB 686) as stated below.
Step 5: Determination of Consistency with Affirmatively Furthering Fair Housing Government Code section 65583.2(a)
*NEW* Pursuant to AB 686, for housing elements due on or after January 1, 2021, sites must be identified throughout the community in a manner that affirmatively furthers fair housing opportunities (Government Code Section 65583(c)(10)).
Affirmatively Furthering Fair Housing means “taking meaningful actions, in addition to combating discrimination, that overcome patterns of segregation and fosters inclusive communities free from barriers that restrict access to opportunity based on protected characteristics. Specifically, affirmatively furthering fair housing means taking meaningful actions that, taken together, address significant disparities in housing needs and in access to opportunity, replacing segregated living patterns with truly integrated and balanced living patterns, transforming racially and ethnically concentrated areas of poverty into areas of opportunity, and fostering and maintaining compliance with civil rights and fair housing laws. The duty to affirmatively further fair housing extends to all of a public agency’s3 3 Public Agencies include the state, including every state office, officer, department, division, bureau, board, and commission, including the California State University, a city, including a charter city, county, including a charter county, city and county, and a redevelopment successor agency, a public housing authority created pursuant to the Housing Authorities Law, a public housing agency, and any other political subdivision of the state that is a grantee or subgrantee receiving funds provided by the United States Department of Housing and Urban Development (Government Code section 8899.5(a)(2).
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activities and programs relating to housing and community development.” (Government Code section 8899.50(a)(1)).
For purposes of the housing element site inventory, this means that sites identified to accommodate the lower-income need are not concentrated in low-resourced areas (lack of access to high performing schools, proximity to jobs, location disproportionately exposed to pollution or other health impacts) or areas of segregation and concentrations of poverty.
Instead, sites identified to accommodate the lower income RHNA must be distributed throughout the community in a manner that affirmatively furthers fair housing. One resource the jurisdiction could use when completing this analysis is the California Tax Credit Allocation/California Department of Housing and Community Development Opportunity Maps, which can be accessed at https://www.treasurer.ca.gov/ctcac/opportunity.asp.
Particularly, the jurisdiction should consider the barriers and opportunities identified in its assessment of fair housing pursuant to Government Code section 65583(c)(10). HCD plans to release a technical assistance memo to assist jurisdictions in addressing AB 686 requirements in their housing element in the Summer of 2020.
Jurisdictions should also consider integrating this analysis with the requirements of Government Code 65302(h), as added by SB 1000 (Statutes of 2016), which requires the preparation and adoption of an Environmental Justice element or equivalent environmental justice-related policies, objectives, and goals throughout other elements of their general plan, to address the needs of disadvantaged communities. More information on Environmental Justice elements can be found on the Governor’s Office of Planning and Research Website.
Step 6: Sites by RHNA Income Category
Government Code section 65583.2(c)
*NEW* Identify which RHNA income category that each site in the inventory is anticipated to accommodate. On the site inventory, specify whether the site or a portion of the site is adequate to accommodate lower income housing, moderate-income housing, or above moderate-income housing. Sites can accommodate units for more than one income category. However, the inventory should indicate the number of units of each income category, and together the total of units attributed to each income category may not exceed total units attributed to the site, so that no unit is designated for more than one income category. This requirement is particularly important because the No Net Loss Law (Government Code section 65863) requires adequate sites be maintained throughout the planning period to accommodate the remaining RHNA by income category. For more information, please consult the HCD’s memo on No Net Loss Law.
HCD Best Practices for selecting sites to accommodate the lower income RHNA:
When determining which sites are best suited to accommodate the RHNA for lower income households, the jurisdiction should consider factors such as:
• Proximity to transit.
• Access to high performing schools and jobs.
• Access to amenities, such as parks and services.
• Access to health care facilities and grocery stores.
• Locational scoring criteria for Low-income Housing Tax Credit (TCAC) Program funding. • Proximity to available infrastructure and utilities.
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• Sites that do not require environmental mitigation.
• Presence of development streamlining processes, environmental exemptions, and other development incentives.
Step 7: Environmental Constraints
Government Code section 65583.2(b)(4)
Provide in the analysis a general description of any known environmental or other features (e.g., presence of floodplains, protected wetlands, oak tree preserves, very high fire hazard severity zones) that have the potential to impact the development viability of the identified sites. The housing element need only describe those environmental constraints where documentation of such conditions is available to the local government. This analysis must demonstrate that the existence of these features will not preclude development of the sites identified in the planning period at the projected residential densities/capacities. This information need not be identified on a site-specific basis. However, local governments will find it beneficial to describe site specific environmental conditions when demonstrating site suitability and realistic buildout capacity of each site, as these types of impediments to building must be considered when determining how many residential units can be developed on the site.
NEXT STEP:
• If the site is selected to accommodate its low or very-low income RHNA, move to Part B: Sites to Accommodate Low and Very-Low Income RHNA.
• If the site accommodates moderate or above-moderate RHNA, move to Part C:
Capacity Analysis.
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PART B: SITES TO ACCOMMODATE LOW AND VERY LOW- INCOME RHNA Step 1: *NEW* Sites Used in Previous Planning Periods Housing Elements Government Code section 65583.2(c)
Determine if the site identified to accommodate the low- and very low-income RHNA pursuant to Part A, Step 6 was used in the previous planning period4. Generally, previously identified sites refer to parcels that were identified in a previous housing element’s site inventory to accommodate any portion of any income category of the jurisdiction’s RHNA, as follows:
For a nonvacant site: Included in a prior planning period’s housing element (e.g., 5th cycle housing element)
For a vacant site (see definition of vacant site on page 21): Included in two or more consecutive planning periods (e.g., 5th cycle and 4th cycle housing element) If Yes: move to Step 1A
If No: move to Step 2
Unusual Circumstances
Sites rezoned or identified for rezoning to accommodate a RHNA shortfall Previously identified sites can also include sites that were subject to a previous housing element’s rezone program but that were ultimately not rezoned. For example: a previous housing element’s rezone program to address a shortfall of sites for lower income households committed to rezone four acres to R-4 zoning, and identified five candidate sites for rezoning, A through E, and each site was two acres in size. If the program was completed in the prior planning period and four acres were rezoned, only those sites rezoned are considered “previously identified.” However, if none or fewer than four acres were rezoned, all the non-rezoned sites identified as candidate sites would be considered as “previously identified.”
Sites rezoned to a higher density as part of a general plan update (not needed to accommodate a shortfall)
Due to updates in the prior planning period to the general plan or other planning activities, such as the creation of a specific plan, some sites previously identified in the housing element may have been rezoned allowing a higher density, and therefore increasing the potential housing capacity of the site. Because the zoning characteristics of this site have changed, it can be considered a new site for the purposes of the housing element inventory. This is only the case if it was not utilized to accommodate a shortfall of sites to accommodate the RHNA. End unusual circumstances
4 Sites in unincorporated areas in a nonmetropolitan county without a micropolitan area are exempt from this step. This includes the unincorporated parts of Alpine, Amador, Calaveras, Colusa, Glenn, Mariposa, Modoc, Mono, Plumas, Sierra, Siskiyou, Trinity.
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Step 1A:
Indicate in the housing element site inventory that this parcel was used in a prior housing element planning period.
Step 1B:
Include a program in the housing element requiring rezoning within three years of the beginning of the planning period to allow residential use by right at specified densities (see Step 2) for housing developments in which at least 20 percent of the units are affordable to lower income households. This program can be an overlay on these specific sites. Please be aware that the intent of this requirement is to further incentivize the development of housing on sites that have been available over one or more planning periods. The application of the requirement should not be used to further constrain the development of housing. As such, housing developments that do not contain the requisite 20 percent would still be allowed to be developed according to the underlying (base) zoning but would not be eligible for “by right” processing. However, the jurisdiction would have to make findings on the approval of that project pursuant to No Net Loss Law (Government Code section 65863) and proceed to identify an alternative site or sites pursuant to that law. Sites where zoning already permits residential “use by right” as set forth in Government Code section 65583.2 (i) at the beginning of the planning period would be considered to meet this requirement.
Definition of Use By Right (Government Code section 65583.2 (i)) By right means the jurisdiction shall not require:
• A conditional use permit.
• A planned unit development permit.
• Other discretionary, local-government review or approval that would constitute a “project” as defined in Section 21100 of the Public Resources Code (California Environmental Quality Act “CEQA”).
However, if the project requires a subdivision, it is subject to all laws, including CEQA.
This does not preclude a jurisdiction from imposing objective design review standards.
However, the review and approval process must remain non discretionary and the design review must not constitute a “project” as defined in Section 21100 of the Public Resources Code. For example, a hearing officer (e.g., zoning administrator) or other hearing body (e.g., planning commission) can review the design merits of a project and call for a project proponent to make design-related modifications, but cannot exercise judgment to reject, deny, or modify the “residential use” itself. (See McCorkle Eastside Neighborhood Group v.
City of St. Helena (2019) 31 Cal.App.5th 80.)
For reference, CEQA applies when a governmental agency can exercise judgment in deciding whether and how to carry out or approve a project. This makes the project “discretionary” (CEQA Guidelines, §15357.) Where the law requires a governmental agency to act on a project using fixed standards and the agency does not have authority to use its own judgment, the project is called “ministerial,” and CEQA does not apply. (CEQA Guidelines, §§ 15268(a), 15369.) End definition of by right.
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Sample Program:
Provide Adequate Sites for Lower Income Households on Nonvacant and Vacant Sites Previously Identified
The City of X will rezone to allow developments by right pursuant to Government Code section 65583.2(i) when 20 percent or more of the units are affordable to lower income households on sites identified in Table A to accommodate the lower income RHNA that was previously identified in past housing elements. Specifically, the City will rezone the nonvacant sites identified on Table A previously identified in the 5th cycle housing element, and the vacant sites identified on Table A as previously identified for both the 5th and 4th cycle housing elements.
Objective: Create opportunity for at least X units of rental housing for lower income households
Responsible Agency: Community Development Department
Timeline: Sites rezoned by (a specific date, no more than three years from the beginning of the planning period)
Funding Source(s): General fund
Step 2: Zoning Appropriate to Accommodate Low- and Very Low- Income RHNA Government Code section 65583.2(c)(3)
Determine if the zoning on the site is appropriate to accommodate low- and very lowincome (termed together as “lower”) housing.
The statute allows jurisdictions to use higher density as a proxy for lower income affordability, as long as certain statutory requirements are met. Parcels must be zoned to allow sufficient density to accommodate the economies of scale needed to produce affordable housing. To make this determination, the statute allows the jurisdiction to either demonstrate that the zoning allows a specific density set forth in the statute (default density)5 or to provide an analysis demonstrating the appropriateness of the zoned densities of the site identified to accommodate the lower RHNA.
Step 2A: Does the parcel’s zoning allow for “at least” the following densities? • For an incorporated city within a nonmetropolitan county and for a nonmetropolitan county that has a micropolitan area: sites allowing at least 15 units per acre. • For an unincorporated area in a nonmetropolitan county not included in the first bullet:
sites allowing at least 10 units per acre.
• For a suburban jurisdiction: sites allowing at least 20 units per acre. • For a jurisdiction in a metropolitan county: sites allowing at least 30 units per acre. “At least” means the density range allowed on the parcel by the zone has to include the default density. For example, if a jurisdiction has a default density of 30 units per acre and the zone allows for range of 24 – 35 units per acre, the zoning is considered appropriate to accommodate the RHNA for lower income households. This is different than the program standard outlined in Part E which requires a minimum of a specific density in the allowed 5 Sometimes called “Mullin densities” after the author of AB 2348, Statutes of 2004, which originated these requirements.
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density range in the zone. To determine the default density for jurisdictions, please refer to HCD Memorandum: Default Density Standard Option (2010 Census Update).
If Yes: Move to Step 3
If No: Move to Step 2B
Step 2B: Can the analysis demonstrate the appropriateness of the zoning to accommodate housing?
Provide an analysis demonstrating how the allowed densities facilitate the development of housing to accommodate the lower income RHNA. The analysis shall include, but is not limited to, factors such as market demand, financial feasibility, and information based on development project experience within a zone or zones, or at densities that accommodate housing for lower income households.
Information gathered from local developers on densities ideal for housing development in the community and examples of recent residential projects that provide housing for lower income households is helpful in establishing the appropriateness of the zone. Other information could include land costs, market demand for various types of affordable housing, and the gap between typical market rents and subsidized rents. It is recognized that housing affordable to lower income households requires significant subsidies and financial assistance. However, for this analysis, identifying examples of subsidized housing projects alone is not sufficient to demonstrate the adequacy of a zone and/or density to accommodate the housing affordable to lower income households. In particular, identification of older project(s) or one-off projects that cannot be easily duplicated is not sufficient to demonstrate a development trend.
The analysis of “appropriate zoning” should not include residential buildout projections resulting from the implementation of a jurisdiction’s inclusionary program or potential increase in density due to a density bonus, because these tools are not a substitute for addressing whether the underlining (base) zoning densities are appropriate to accommodate the RHNA for lower income households. Additionally, inclusionary housing ordinances applied to rental housing must include options for the developer to meet the inclusionary requirements other than exclusively requiring building affordable units on site.
While an inclusionary requirement may be a development criterion, it is not a substitute for zoning. The availability of density bonuses is also not a substitute for an analysis, since they are not a development requirement, but are development options over the existing density, and generally require waivers or concessions in development standards to achieve densities and financial feasibility.
If Yes: Move to Step 3
If No: Site is not appropriate to accommodate lower income. Reclassify pursuant to Part A, Step 5.
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Housing Overlays
Affordable housing or zoning overlays are a zoning tool that allows jurisdictions to modify existing zoning to allow for or require certain types of residential development, or development at certain densities, on a parcel without modifying the standards of the underlying zoning district. Usually, they have specific requirements and conditions (e.g., a percentage of the development must be deed-restricted as affordable to lower income households for a specific number of years) that must be met in order for a developer to take advantage of the overlay. These are often combined with incentives to encourage developers to utilize the overlay. Jurisdictions use overlays to help promote a specific type of development, and to increase densities without having to go through a rezoning procedure on the actual parcel and can be more useful when issues such as density and affordable housing become contentious. To ensure the overlay is considered zoning and not just a development incentive, the overlay must demonstrate the following:
• There is no additional discretionary action needed above what is required in the base zone (i.e., a conditional use permit or other review) for a developer to take advantage of overlay.
• Development standards are consistent with those needed to allow for the density allowed under the overlay. Development standards for use exclusively in the overlay may be needed in order to ensure maximum allowable densities can be achieved. • The developer can access State Density Bonus Law in addition to using the densities allowed in the overlay. For example, if the underlying zoning allows a maximum density of 15 units per acre, but the overlay allows a maximum density of 25 units per acre, and if the developer is using the overlay and wants to use State Density Bonus Law, the density bonus is calculated assuming the base density is 25 units per acre.
If the overlay has conditions such as an affordability requirement, incentives should be sufficient and available to make development feasible and more profitable than the underlying zoning.
For an affordable housing overlay, the element should describe affordability threshold requirements to utilize the overlay (i.e., percentage of units and levels of affordability which must be met to develop at the increased densities). Please note, the jurisdiction should talk with for-profit and nonprofit developers to determine an appropriate mix of incomes that make development feasible in their community. For example, a 100 percent affordability requirement may act as a constraint to using the overlay depending on the level of subsidy required per unit and the availability of funding to support the level of affordability or available incentives. End Housing Overlay
Step 3: Size of Sites
Government Code section 65583.2(c)(2)(A), (B), and (C)
*NEW* Is the size of the site appropriate to accommodate housing for lower income households?
To achieve financial feasibility, many assisted housing developments using state or federal resources are between 50 to 150 units. Parcels that are too small may not support the number of units necessary to be competitive and to access scarce funding resources.
Parcels that are large may require very large projects, which may lead to an over concentration of affordable housing in one location, or may add cost to a project by Attachment 1
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requiring a developer to purchase more land than is needed, or render a project ineligible for funding. If the size of the site is smaller than one half acre or larger than 10 acres, the following analysis is required.
If the parcel is more than 0.5 acres or less than 10 acres, is the size of the site automatically considered appropriate to accommodate lower income RHNA? Not necessarily. If the size of the parcel in combination with the allowable density and accompanying development standards cannot support a housing development affordable to lower income households, further analysis and programs may be needed to demonstrate the suitability of that site to accommodate the portion of the RHNA for lower income households. End Question and Answer
Is the size of the parcel under 0.5 acres?
If Yes: Move to Step 3A
Is the size of the parcel over 10 acres?
If Yes: Move to Step 3B
If No to Both: Move to Part C: Capacity Analysis
Step 3A: Sites smaller than 0.5 acres
A parcel smaller than one half acre is considered inadequate to accommodate housing affordable to lower income households, unless the housing element demonstrates development of housing affordable to lower income households on these sites is realistic or feasible. While it may be possible to build housing on a small parcel, the nature and conditions (i.e., development standards) necessary to construct the units often render the provision of affordable housing infeasible. The housing element must consider and address the impact of constraints associated with small lot development on the ability of a developer to produce housing affordable to lower income households. To demonstrate the feasibility of development on this type of site, the analysis must include at least one of the following:
• An analysis demonstrating that sites of equivalent size were successfully developed during the prior planning period with an equivalent number of lower income housing units as projected for the site.
• Evidence that the site is adequate to accommodate lower income housing. Evidence could include developer interest, potential for lot consolidation, densities that allow sufficient capacity for a typical affordable housing project, and other information that can demonstrate to HCD the feasibility of the site for development. For parcels anticipated to be consolidated, the housing element must include analysis describing the jurisdiction’s role or track record in facilitating small lot consolidation, policies or incentives offered or proposed to encourage and facilitate lot consolidation, conditions rendering parcels suitable and ready for consolidation such as common ownership, and recent trends of lot consolidation. The housing element should include programs promoting, incentivizing, and supporting lot consolidations and/or small lot development. • A site may be presumed to be realistic for development to accommodate lower income housing need if, at the time of the adoption of the housing element, a development affordable to lower income households has been proposed and approved for development on the site.
Attachment 1