Brentwood City Council
February 13, 2024

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

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

Definition of a Large Site
For purposes of this requirement, “site” means that portion of the parcel designated to accommodate lower income housing needs. For example, a parcel greater than 10 acres in size could have to be split zoned, have an overlay zone with identified boundaries, or be identified in a specific plan that provides for subdivision of the parcel. If the specified boundaries of the site identified to accommodate the RHNA for lower income is less than 10 acres in size, then the large site analysis would not be required. However, the analysis must describe how the development will work on the site, including opportunities and timing for specific-plan development, further subdivision, or other methods to facilitate the development of housing affordable to lower income households on the identified site within the planning period. End definition
To demonstrate the feasibility of development on this type of site, the analysis must include at least one of the following:
• 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 may include developer interest, proposed specific-plan development, potential for subdivision, the jurisdiction’s role or track record in facilitating lot splits, or other information that can demonstrate to HCD the feasibility of the site for development. The housing element should include programs promoting, incentivizing, and supporting lot splits and/or large lot development.
• 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

Site Inventory Guidebook Page 18 May 2020
Specific Plans, Master Plan, and other Subdivisions
To utilize residential capacity in Specific Plan areas, areas under a Master Plan, or a similar multi-phased development plan, the housing element must identify specific sites by parcel number and demonstrate that the sites are available and suitable for development within the planning period. The analysis should include the following information:
• Identify the date of approval of the plans and expiration date. • Identify approved or pending projects within these plans that are anticipated in the planning period, including anticipated affordability based on the actual or projected sale prices, rent levels, or other mechanisms establishing affordability in the planning period of the units within the project.
• Describe necessary approvals or steps for entitlements for new development (e.g., design review, site plan review, etc.).
• Describe any development agreements, and conditions or requirements such as phasing or timing requirements, that impact development in the planning period. End information on planned development.

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

NEXT STEP:
• Move to Part C: Capacity Analysis
Attachment 1

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

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

Step 2: Utilizing factors to calculate realistic capacity of sites Government Code section 65583.2(c)(2)
The housing element must describe the methodology used to determine the number of units calculated based on the following factors:
• Land use controls and site improvements requirements, • *NEW* The realistic development capacity for the site, • *NEW* Typical densities of existing or approved residential developments at a similar affordability level in that jurisdiction,
• *NEW* The current or planned availability and accessibility of sufficient water, sewer, and dry utilities.

Attachment 1

Site Inventory Guidebook Page 20 May 2020
Applicable land-use controls and site improvement requirements The analysis must consider the imposition of any development standards that impact the residential development capacity of the sites identified in the inventory. When establishing realistic unit capacity calculations, the jurisdiction must consider the cumulative impact of standards such as maximum lot coverage, height, open space, parking, on-site improvements such as sidewalks or easements, and floor area ratios. The analysis should consider any development standards or the cumulative effect of development standards that would limit the achievable density on a site. For example, if a mixed-use zone requires commercial on the ground floor and has a height limit of three stories along with lot coverage and other development standards, the density that can actually be achieved on that site might be less than the maximum allowable density.

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

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

Form Based Codes
To estimate capacity for sites in jurisdictions that have adopted form-based codes, the element should describe the relationship between general plan land-use designation and the form-based code and density assumptions used to determine capacity. Specifically, describe where residential development is allowed, how density requirements found within the general plan are incorporated, how the zoning designations under the form-based code relate to the land-use designations of the general plan, identify potential densities, and consider development standards such as bulk, height, and build-to requirements, buildings types, and use requirements. The element could include examples of recently built projects and densities to support the analysis. End Form Base Codes Realistic development capacity for nonresidential, nonvacant, or overlay zoned sites The capacity calculation must be adjusted to reflect the realistic potential for residential development capacity on the sites in the inventory. Specifically, when the site has the potential to be developed with nonresidential uses, requires redevelopment, or has an overlay zone allowing the underlying zoning to be utilized for residential units, these capacity limits must be reflected in the housing element. Factors used to make this adjustment may include the following:
• Performance standards mandating a specified portion of residential development in mixed use or nonresidential zones (e.g., residential allowed only above first floor commercial).
• The likelihood for residential development such as incentives for residential use, market demand, efforts to attract and assist developers, or allowance of 100 percent residential development.
• Local or regional residential development trends in the same nonresidential zoning districts.
• Local or regional track records, past production trends, or net unit increases/yields for redeveloping sites or site intensification. This estimate may be based on the rate at which similar parcels were developed during the previous planning period, with Attachment 1

Site Inventory Guidebook Page 21 May 2020
adjustments as appropriate to reflect new market conditions or changes in the regulatory environment. If no information about the rate of development of similar parcels is available, report the proportion of parcels in the previous housing element’s site inventory that were developed during the previous planning period. For example, if past production trends indicate that two out of three similar sites were developed for residential use, and one out of three similar sites was developed for commercial use, an initial estimate of the proportion of new development which is expected to be residential would be two-thirds, i.e., 0.67.
• Local or regional track records, trends, or build out yields for redeveloping sites or site intensification.

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

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

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

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

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

Attachment 1

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

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

To ensure that sufficient capacity exists in the housing element to accommodate the RHNA throughout the planning period, it is recommended the jurisdiction create a buffer in the housing element inventory of at least 15 to 30 percent more capacity than required, especially for capacity to accommodate the lower income RHNA. Jurisdictions can also create a buffer by projecting site capacity at less than the maximum density to allow for some reductions in density at a project level. End no net loss law explanation.

Attachment 1

Site Inventory Guidebook Page 23 May 2020
NEXT STEP:
• If the parcel is nonvacant, including underutilized sites (see definition of vacant site on page 22), move to Part D: Nonvacant Sites Analysis
• If not, move to Part E: Determination of Adequate Sites Attachment 1

Site Inventory Guidebook Page 24 May 2020
PART D: NONVACANT SITES
Local governments with limited vacant land resources or with infill and reuse goals may rely on the potential for new residential development on nonvacant sites, including underutilized sites, to accommodate their RHNA. Examples include:
• Sites with obsolete uses that have the potential for redevelopment, such as a vacant restaurant.
• Nonvacant publicly owned surplus or excess land; portions of blighted areas with abandoned or vacant buildings.
• Existing high opportunity developed areas with mixed-used potential. • Nonvacant substandard or irregular lots that could be consolidated. • Any other suitable underutilized land.

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

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

Examples of Vacant Sites:
• No improvement on the site (other than being a finished lot). • No existing uses, including parking lots.
• Underutilized sites are not vacant sites.
• Sites with blighted improvements are not vacant sites. • Sites with abandoned or unoccupied uses are not vacant sites. End definition If the inventory identifies nonvacant sites to address a portion of the RHNA, the housing element must describe the realistic development potential of each site within the planning period. Specifically, the analysis must consider the extent that the nonvacant site’s existing use impedes additional residential development, the jurisdiction's past experience converting existing uses to higher density residential development, market trends and conditions, and regulatory or other incentives or standards that encourage additional housing development on the nonvacant sites.

Attachment 1

Site Inventory Guidebook Page 25 May 2020
Step 1: Description of the nonvacant site
Government Code Section 65583.2(b)
As stated in Part A, the site inventory must describe the specific existing use on the site, such as a surplus school site, auto shop, restaurant, single family residence, nursery, etc.

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

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

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

Existing Uses:

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

Development Trends:

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

Market Conditions:

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

Attachment 1

Site Inventory Guidebook Page 26 May 2020
Availability of Regulatory and/or other Incentives:

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

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

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

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

Adjustment Factor Number of units
Proposed Lower Income Project 50
Accessory Dwelling Unit Capacity (affordable to lower) 15 Capacity on Vacant Sites 100
Total Capacity (not related to non-vacant sites) 165
RHNA on Nonvacant sites 500 - 165 = 335
Percentage of Lower Income RHNA accommodated
on Nonvacant sites
335/500 = 77%
If Yes: Move to Step 3A
If No: Move to Step 4
Attachment 1

Site Inventory Guidebook Page 27 May 2020
Step 3A:

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

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

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

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

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

Attachment 1

Site Inventory Guidebook Page 28 May 2020
However, the same finding for multiple sites in a specific area may not be appropriate if their characteristics widely vary. For example, nonvacant sites with differing existing uses and lacking in common ownership, whether contiguous or located in the same general area, may not rely on a generalized analysis. While the sites may be located in an area with common economic issues, individual owners may not wish to sell their property or redevelop their site with residential uses. In addition, each site’s existing use, e.g., grocery store, retail shop, parking lot, and offices, may have lease agreements of different lengths of time or the owner may not wish to relocate or redevelop the site with a more intensive residential use. In this type of situation, use of the same findings for the multiple sites would not be appropriate.

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

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

Attachment 1

Site Inventory Guidebook Page 29 May 2020

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

Timeframes: The replacement requirement will be implemented immediately and applied as applications on identified sites are received and processed, and local policy shall be adopted by <DATE>. End of Sample Program
NEXT STEP:
• Move to Part E: Determination of Adequate Sites
Attachment 1

Site Inventory Guidebook Page 30 May 2020
PART E: DETERMINATION OF ADEQUATE SITES
The last step in this process is a determination of whether the housing element demonstrates sufficient land suitable and available for residential development to meet the locality’s housing need for each designated income level or if further program actions are required to accommodate a shortfall.

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

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

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

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

Attachment 1

Site Inventory Guidebook Page 31 May 2020
Impact of New Accessory Dwelling Unit Laws
Since 2017, the Legislature has passed a series of new laws that significantly increase the potential for development of new ADUs and JADUs by removing development barriers, allowing ADUs through ministerial permits, and requiring jurisdictions to include programs in their housing element that incentivize their development. As a result, using trend analysis when estimating the potential for development may not accurately reflect the increased potential for these units. To account for this increased potential, HCD recommends the following options when performing this analysis:
• Use the trends in ADU construction since January 2018 to estimate new production.

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

Potential affordability of these units must still be calculated per the analysis outlined on the previous page. In addition to the above options, the element should also include a monitoring program that a) tracks ADU and JADU creation and affordability levels, and b) commits to a review at the planning cycle mid-point to evaluate if production estimates are being achieved. Depending on the finding of that review, amendments to the housing element may be necessary, including rezoning pursuant to Government Code 65583.2 (h)and (i). End ADU explanation
• Alternative Adequate sites: Under limited circumstances, a local government may credit up to 25 percent of their adequate sites requirement per income category through existing units that will be:
- substantially rehabilitated
- in a multifamily rental or ownership housing complex of three or more units that are converted from non affordable to affordable rental
- preserved at levels affordable to low- or very low-income households, where the local government has provided those units with committed assistance For more information on this option, please refer to HCD’s Building Blocks Webpage • Manufactured housing, manufactured housing park hook-ups, floating homes/live aboard berths: In certain circumstances a jurisdiction can utilize the potential for new manufactured housing either in a manufactured housing park or on large properties in rural areas, or new floating home/liveaboard berths with sewer and water hook ups. In cases of a manufactured home park or in floating home/liveaboard berth marinas, the jurisdiction may count new spaces with infrastructure hook-ups intended for permanent residential occupancy and reported to the Department of Finance. Potential for manufactured homes in rural areas should be analyzed using the same factors as those Attachment 1

Site Inventory Guidebook Page 32 May 2020
for potential ADUs, including establishing the market rate affordability of the units and crediting them to the appropriate RHNA category. In addition, the analysis should indicate if appropriate water and sewer infrastructure is available to support the development.
• Former military housing: Sites that contain permanent housing units located on a military base undergoing closure or conversion as a result of action pursuant to the Defense Authorization Amendments and Base Closure and Realignment Act (Public Law 100-526), the Defense Base Closure and Realignment Act of 1990 (Public Law 101-510), or any subsequent act requiring the closure or conversion of a military base may be identified as an adequate site if the housing element demonstrates that the housing units will be available for occupancy by households within the planning period of the housing element. No sites containing housing units scheduled or planned for demolition or conversion to nonresidential uses shall qualify as an adequate site. • In consultation with HCD, other alternatives may be considered, such as motel conversions, adaptive reuse of existing buildings, or legalization of units not previously reported to the Department of Finance.

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

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

Adjustment Factor Very Low Low Moderate Above
Moderate
RHNA 300 200 165 465
Entitled, Permitted, or Constructed
Project Projects
50 50 0 200
Accessory Dwelling Unit Potential 10 15 15 10
Adequate Sites Alternative
Preservation
20 16
Multifamily Residential
R-3 (Vacant)
75 50
Mixed Use MU (Nonvacant) 75 50 50
Multifamily Residential (Vacant) R-2 75
Single-Family (Vacant) R-1 200
Spring Valley Specific Plan 150 250
Total 230 181 290 660
Shortfall/Surplus -70 -19 +125 +195
While the jurisdiction has sufficient sites to accommodate its RHNA for moderate- and above moderate-income units, it has a shortfall of 89 units to accommodate its lower income need. The jurisdiction would be required to include a program in the housing element to accommodate that shortfall.

Attachment 1

Site Inventory Guidebook Page 33 May 2020
If Yes: Congratulations, the site inventory analysis is complete If No: Move to Step 3
Step 3: Adequate Sites Program
Government Code section 65583(f) and Government Code section 65583.2(h) Where the inventory of sites does not identify adequate sites to accommodate the RHNA for lower income households, a program must be included to identify sites that can be developed for housing within the planning period. The housing element should include an inventory of potential sites for rezoning. Those sites must meet the adequate sites requirements in terms of the suitability and availability outlined above.

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

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

A locality’s ability to accommodate needed housing during the planning period requires designating appropriate zoning as early as possible. Generally, however, a rezoning should occur no later than three years and 120 days from the beginning of the planning period. A one-year extension to the deadline to complete required rezoning may be allowed if a local government has completed rezoning at sufficient densities to accommodate at least 75 percent of the units for very-low and low-income households. Also, the jurisdiction must determine after a public meeting that substantial evidence supports findings and adoption of a resolution that the rezone deadline was not met due to one of the following reasons:
• Action or inaction beyond the control of the local government of any other state, federal, or local agency.
• Infrastructure deficiencies due to fiscal or regulatory constraints.

Attachment 1

Site Inventory Guidebook Page 34 May 2020
• The local government must undertake a major revision to its general plan in order to accommodate the housing-related policies of a sustainable communities strategy or an alternative planning strategy adopted pursuant to Section 65080.

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

Consequences for Failing to Complete Rezoning Deadline:

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

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

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

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

Attachment 1

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

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

Attachment 1

Site Inventory Guidebook Page 36 May 2020
Rezoned due to an unaccommodated need from previous planning period9:

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

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

Attachment 1

Site Inventory Guidebook Page 37 May 2020
Sample Rezone Program:

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

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

Attachment 1

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

Common Program Questions and Answers for Shortfall Zoning:

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

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

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

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

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

End Questions and Answers
Attachment 1

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

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

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

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

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

Violations of the Surplus Land Act can be referred to the Attorney General. Finally, it adds a requirement in Housing Element Law for the jurisdiction to identify which of the sites included in the inventory are surplus property.

Attachment 1

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

Attachment 1

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

Attachment 1

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

The analysis shall include, but is not limited to, factors such as market demand, financial feasibility, or information based on development project experience within a zone or zones that provide housing for lower income households.
(B) The following densities shall be deemed appropriate to accommodate housing for lower income households:
(i) For an incorporated city within a nonmetropolitan county and for a nonmetropolitan county that has a micropolitan area: sites allowing at least 15 units per acre. (ii) For an unincorporated area in a nonmetropolitan county not included in clause (i): sites allowing at least 10 units per acre.
(iii) For a suburban jurisdiction: sites allowing at least 20 units per acre. (iv) For a jurisdiction in a metropolitan county: sites allowing at least 30 units per acre. (d) For purposes of this section, a metropolitan county, nonmetropolitan county, and nonmetropolitan county with a micropolitan area shall be as determined by the United States Census Bureau. A nonmetropolitan county with a micropolitan area includes the following counties: Del Norte, Humboldt, Lake, Mendocino, Nevada, Tehama, and Tuolumne and other counties as may be determined by the United States Census Bureau to be nonmetropolitan counties with micropolitan areas in the future. (e) (1) Except as provided in paragraph (2), a jurisdiction shall be considered suburban if the jurisdiction does not meet the requirements of clauses (i) and (ii) of subparagraph (B) of paragraph (3) of subdivision (c) and is located in a Metropolitan Statistical Area (MSA) of less than 2,000,000 in population, unless that jurisdiction’s population is greater than 100,000, in which case it shall be considered metropolitan. A county, not including the City and County of San Francisco, shall be considered suburban unless the county is in an MSA of 2,000,000 or greater in population in which case the county shall be considered metropolitan.
(2) (A) (i) Notwithstanding paragraph (1), if a county that is in the San Francisco-OaklandFremont California MSA has a population of less than 400,000, that county shall be considered suburban. If this county includes an incorporated city that has a population of less than 100,000, this city shall also be considered suburban. This paragraph shall apply to a housing element revision cycle, as described in subparagraph (A) of paragraph (3) of subdivision (e) of Section 65588, that is in effect from July 1, 2014, to December 31, 2028, inclusive.
(ii) A county subject to this subparagraph shall utilize the sum existing in the county’s housing trust fund as of June 30, 2013, for the development and preservation of housing affordable to low- and very low-income households.
(B) A jurisdiction that is classified as suburban pursuant to this paragraph shall report to the Assembly Committee on Housing and Community Development, the Senate Committee on Attachment 1

Site Inventory Guidebook Page 43 May 2020
Housing, and the Department of Housing and Community Development regarding its progress in developing low- and very low income housing consistent with the requirements of Section 65400. The report shall be provided three times: once, on or before December 31, 2019, which report shall address the initial four years of the housing element cycle, a second time, on or before December 31, 2023, which report shall address the subsequent four years of the housing element cycle, and a third time, on or before December 31, 2027, which report shall address the subsequent four years of the housing element cycle and the cycle as a whole. The reports shall be provided consistent with the requirements of Section 9795.
(f) A jurisdiction shall be considered metropolitan if the jurisdiction does not meet the requirements for “suburban area” above and is located in an MSA of 2,000,000 or greater in population, unless that jurisdiction’s population is less than 25,000 in which case it shall be considered suburban.
(g) (1) For sites described in paragraph (3) of subdivision (b), the city or county shall specify the additional development potential for each site within the planning period and shall provide an explanation of the methodology used to determine the development potential. The methodology shall consider factors including the extent to which existing uses may constitute an impediment to additional residential development, the city’s or county’s past experience with converting existing uses to higher density residential development, the current market demand for the existing use, an analysis of any existing leases or other contracts that would perpetuate the existing use or prevent redevelopment of the site for additional residential development, development trends, market conditions, and regulatory or other incentives or standards to encourage additional residential development on these sites.
(2) In addition to the analysis required in paragraph (1), when a city or county is relying on nonvacant sites described in paragraph (3) of subdivision (b) to accommodate 50 percent or more of its housing need for lower income households, the methodology used to determine additional development potential shall demonstrate that the existing use identified pursuant to paragraph (3) of subdivision (b) does not constitute an impediment to additional residential development during the period covered by the housing element. An existing use shall be presumed to impede additional residential development, absent findings based on substantial evidence that the use is likely to be discontinued during the planning period.
(3) Notwithstanding any other law, and in addition to the requirements in paragraphs (1) and (2), sites that currently have residential uses, or within the past five years have had residential uses that have been vacated or demolished, that are or were subject to a recorded covenant, ordinance, or law that restricts rents to levels affordable to persons and families of low or very low income, subject to any other form of rent or price control through a public entity’s valid exercise of its police power, or occupied by low or very low income households, shall be subject to a policy requiring the replacement of all those units affordable to the same or lower income level as a condition of any development on the site.

Replacement requirements shall be consistent with those set forth in paragraph (3) of subdivision (c) of Section 65915.
(h) The program required by subparagraph (A) of paragraph (1) of subdivision (c) of Section 65583 shall accommodate 100 percent of the need for housing for very low and low-income households allocated pursuant to Section 65584 for which site capacity has not been identified in the inventory of sites pursuant to paragraph (3) of subdivision (a) on sites that shall be zoned to permit owner-occupied and rental multifamily residential use by right Attachment 1

Site Inventory Guidebook Page 44 May 2020
for developments in which at least 20 percent of the units are affordable to lower income households during the planning period. These sites shall be zoned with minimum density and development standards that permit at least 16 units per site at a density of at least 16 units per acre in jurisdictions described in clause (i) of subparagraph (B) of paragraph (3) of subdivision (c), shall be at least 20 units per acre in jurisdictions described in clauses (iii) and (iv) of subparagraph (B) of paragraph (3) of subdivision (c) and shall meet the standards set forth in subparagraph (B) of paragraph (5) of subdivision (b). At least 50 percent of the very low and low-income housing need shall be accommodated on sites designated for residential use and for which nonresidential uses or mixed uses are not permitted, except that a city or county may accommodate all of the very low and lowincome housing need on sites designated for mixed uses if those sites allow 100 percent residential use and require that residential use occupy 50 percent of the total floor area of a mixed-use project.
(i) For purposes of this section and Section 65583, the phrase “use by right” shall mean that the local government’s review of the owner-occupied or multifamily residential use may not require a conditional use permit, planned unit development permit, or other discretionary local government review or approval that would constitute a “project” for purposes of Division 13 (commencing with Section 21000) of the Public Resources Code.

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

15.5. (AB 1486) Effective January 1, 2020. Repealed as of December 31, 2028, by its own provisions. See later operative version amended by Sec. 16.5 of Stats. 2019, Ch. 664.) Attachment 1

BRENTWOOD BLVD

AMERICAN AVE

BALFOUR RD

EMPIRE AVE

SAND CREEK RD MINNESOTA AVE

SPYGLASS DR

CHESTNUT ST

GRIFFITH LN

LAKEVIEW DR

OHARA AVE

FAIRVIEW AVE

WALNUT BLVD

SHADY WILLOW LN
STATE ROUTE 4

ADAMS LN
STATE ROUTE 4

APPLE HILL DR

BRIONES VALLEY RD

CENTRAL BLVD

MARSH CREEK RD

BALFOUR RD

OHARA AVE

ST ANDREWS DR

GARIN PKWY

FAIRVIEW AVE

AMBER LN

SAN JOSE AVE

CENTRAL BLVD BRENTWOOD BLVD

GARIN PKWY

E COUNTRY CLUB DR

LONE TREE WAY

GRANT ST

VINEYARDS PKWY

FOOTHILL DR

CREEK RD

VINEYARDS PKWY

SAND CREEK RD

GRANT ST

SELLERS AVE

EMPIRE AVE

PRESIDIO DR
±
Legend
R-HD
R-LD
R-MD
R-VHD
R-VLD
RE
0 0.5 1 0.25 Miles
"UUBDINFOU

Residential General Plan Map

2023-2031 (6th Cycle) Housing Element Update Draft Site Inventory Map ID APN_T Address Zoning GPLU Buildable Acreage Density Assumed Density Residential Propensity Estimated Units Inventory Category Assumed Affordability 1 019032010 2251 Shady Willow Ln PA-1 (MFVHDR) MFVHDR 4.80 15-35 25 100% 120 Innovation Center Low and Very Low 2 019032011 2201 Shady Willow Ln PA-1 (MFVHDR) MFVHDR 4.75 15-35 25 100% 118 Innovation Center Low and Very Low 3 019032029 2301 Shady Willow Ln PA-1 (MFVHDR) MFVHDR 4.88 15-35 25 100% 122 Innovation Center Low and Very Low 4 019020059 5225 Heidorn Ranch Rd PA-1 (MFVHDR) MFVHDR 5.41 15-35 25 100% 135 Innovation Center Low and Very Low 5 019020076 5305 Heidorn Ranch Rd PA-1 (MFVHDR) MFVHDR 4.78 15-35 25 100% 119 Innovation Center Low and Very Low 6 019081022 None - Sand Creek Rd PA-1 (MFVHDR) MFVHDR 11.00 15-35 25 100% 275 Innovation Center Low and Very Low 7 019020055 None - Heidorn Ranch Rd PA-1 (TV) TV 4.02 25-40 32.5 80% 104 Innovation Center Low and Very Low 8 019020083 5315 Heidorn Ranch Rd PA-1 (TV) TV 5.15 25-40 32.5 80% 133.6 Innovation Center Low and Very Low 9 019081020 None - Sand Creek Rd PA-1 (MFVHDR) MFVHDR 17.08 15-35 25 100% 427 Innovation Center Low and Very Low 10 019081021 None - Sand Creek Rd PA-1 (TV) TV 9.23 25-40 32.5 80% 239.2 Innovation Center Low and Very Low 11 019092046 2483 Sand Creek Rd PA-1 (HDR) HDR 28.60 10-20 15 100% 429 Innovation Center Moderate 2,222
12 010840010 None - John Muir Pkwy PD (R-VHD) R-VHD 3.39 20.1-30 25 100% 84 Vacant Land Low and Very Low 13 010840011 None - John Muir Pkwy PD (R-VHD) R-VHD 6.81 20.1-30 25 100% 170 Vacant Land Low and Very Low 14 010840012 None - John Muir Pkwy PD (R-VHD) R-VHD 7.70 20.1-30 25 100% 192 Vacant Land Low and Very Low 18 010010039 2200 Ventura Dr PD-20 R-LD 4.26 1.1 - 5.0 3 100% 12 Vacant Land Above Moderate 19 007440018 None - Foothill Dr PD-20 R-LD 4.55 1.1 - 5.0 3 100% 13 Vacant Land Above Moderate 21 007100126 None - Spyglass Dr PD-20 R-VLD 8.21 1.1 - 3 2 100% 16 Vacant Land Above Moderate 29 019092013 None - Sand Creek Rd PD-35 R-LD 11.48 1.1 - 5.0 3 100% 34 Vacant Land Above Moderate 30 019092034 1777 Apricot Way PD-35 R-LD 9.35 1.1 - 5.0 3 100% 28 Vacant Land Above Moderate 55 019040031 2401 Empire Ave R-3 R-HD 1.14 11.1 - 20 15.5 100% 17 Vacant Land Moderate 56 019040033 2391 Empire Ave R-3 R-HD 1.00 11.1 - 20 15.5 100% 15 Vacant Land Moderate 58 018190018 None - Sunset Rd BBSP BBSP (COIR) 9.83 11-20 15.5 100% 152 Vacant Land Moderate59 018170003 None - Brentwood Blvd BBSP BBSP (COIR) 6.17 11-20 15.5 100% 95 Vacant Land Moderate61 016120024 None - Brentwood Blvd BBSP BBSP (COIR) 5.06 11-20 15.5 100% 78 Vacant Land Moderate62 016150114 None - Brentwood Blvd BBSP BBSP (COIR) 1.58 11-20 15.5 100% 24 Vacant Land Moderate68 018230034 251 Hanson Lane PD-71 R-LD 20.13 1.1 - 5.0 3 100% 60 Vacant Land Above Moderate 72 017110012 760, 780, 800 Minnesota Ave R-1-10 R-LD 11.10 1.1 - 5.0 3 100% 33 Vacant Land Above Moderate 73 016040005 Adams Lane and Gracie Lane R-1-E R-VLD 16.82 1.1 - 3 2 100% 33 Vacant Land Above Moderate 74 018060040 7770 Lone Tree Way PD-29 R-VLD 5.32 1.1 - 3 2 100% 10 Vacant Land Above Moderate 78 016040004 1901 Lone Oak Rd R-1-E R-VLD 10.00 1.1 - 3 2 100% 20 Vacant Land Above Moderate 81 016120020 None - Brentwood Blvd BBSP BBSP (COIR) 10.00 11-20 15.5 100% 155 Vacant Land Above Moderate82 016130006 None - Brentwood Blvd BBSP BBSP (COIR) 10.00 11-20 15.5 100% 155 Vacant Land Above Moderate83 016130007 None - Sycamore Ave BBSP BBSP (COIR) 10.00 11-20 15.5 100% 155 Vacant Land Above Moderate84 018060006 7650 Lone Tree Way R-1-12 R-VLD 10.00 1.1 - 3 2 100% 20 Vacant Land Above Moderate 88 018090020 7451 Lone Tree Way R-1-10 R-LD 5.06 1.1 - 5.0 3 100% 15 Vacant Land Above Moderate 89 018100047 None - Lone Tree Way R-1-10 R-LD 8.64 1.1 - 5.0 3 100% 25 Vacant Land Above Moderate 90 019050026 2313 Windy Springs Lane PD-35 R-LD 3.26 1.1 - 5.0 3 100% 9 Vacant Land Above Moderate 91 019050038 2305 Windy Springs Lane PD-35 R-LD 0.98 1.1 - 5.0 3 100% 2 Vacant Land Above Moderate 1,622
Vacant/Underutilized Residential ParcelsSpecific Plan Parcels Specific Plan Parcel Sub Total
Vacant/Underutilized Residential Parcels Sub Total
Attachment 3Page 510 of 894
Map ID APN_T Address Zoning GPLU Buildable Acreage Density Assumed Density Residential Propensity Estimated Units Inventory Category Assumed Affordability 93 and 105 007380002 Marsh Creek Road PD-64 28 100% 140 Pipeline Above Moderate 94 019092032 1925 Apricot Way PD-35 10.76 100% 37 Pipeline Above Moderate 96 and 97 019031006
South of Amber Lane and west of Shady Willow Lane PA-1 14.431 100% 288 Pipeline Above Moderate 98 018740116 2800 Empire Avenue PD-38 0 100% 160 Pipeline Above Moderate99 010440152 131 Summerset Drive PD-21 0 100% 86 Pipeline Above Moderate 100 016300138
South of Continente Avenue and west of Walnut Boulevard PD-42 0 100% 77 Pipeline Low and Very Low 101 016120025
South of Sand Creek Road and east of O'Hara Avenue BBSP 8.313 100% 166 Pipeline Above Moderate 104 018570039 3405 O'Hara Avenue N/A 100% 14 Pipeline Above Moderate Pipeline Projects Sub Total 968
Pipeline Projects
Attachment 3Page 511 of 894
21 93 105
19 18
99 12
13 14
78 73
81 61
101
82 83
62 100
72 84
74 88
89 59
58 68
98 7
4 5 8 97
1 2
3 56 55
90 91
9 6
29 94
30 11
104

SUNSET RD

BRENTWOOD BLVD

AMERICAN AVE

BALFOUR RD

EMPIRE AVE

SAND CREEK RD MINNESOTA AVE

SPYGLASS DR

DAINTY AVE CHESTNUT ST

LAKEVIEW DR

GRIFFITH LN

OHARA AVE

FAIRVIEW AVE

FOOTHILL
DR

WALNUT BLVD

SHADY WILLOW LN
STATE ROUTE 4

ADAMS LN
STATE ROUTE 4

APPLE HILL DR

BRIONES VALLEY RD

CONCORD AVE

CENTRAL BLVD

MARSH CREEK RD

BALFOUR RD

OHARA AVE

ST ANDREWS DR

GARIN PKWY

FAIRVIEW AVE

AMBER LN

SAN JOSE AVE

CENTRAL BLVD BRENTWOOD BLVD

GARIN PKWY

E COUNTRY CLUB DR

LONE TREE WAY

GRANT ST

VINEYARDS PKWY

FOOTHILL DR

CREEK RD

VINEYARDS PKWY

SAND CREEK RD

GRANT ST

SELLERS AVE

EMPIRE AVE

PRESIDIO DR
±
Legend
Inventory
Innovation Center
Projects in the Pipeline
Vacant Land
Draft Site Inventory Map
0 0.275 0.55 1.1 Miles
"UUBDINFOU


No
21%
6%
80%
2*(2018‐2021 Average Production)
Extremely
Low/ Very Low
Income
Low Income
Moderate
Income
Above
Moderate
Income
Total NOTES
Final 2023 ‐ 2031 RHNA 402 232 247 641 1,552Pipeline Project 0 966 968Projected ADU Production 81 27 270 Total Pipeline Projects and ADU's 81 993 1,238Innovation Center Specific Plan  133 1,712 2,222Vacant Residential Land 50 1,478 1,622Total Existing Zoning Capacity 183 3,190 3,844Total Unit Potential  264 4,183 5,082Units Over/Under 17 3,542 3,844Percent Over/Under 7% 553% 227% Strategy 1
94 164
Step 1:

Count Projects in the Pipeline and
Estimate ADU's
Steps to Accommodate
RHNA
Step 2:

Identify Existing Zoning Capacity
635471
1 DRAFT Sites Analysis Summary Table
6/23/2022
Strategy 1: Reduced Affordability with
Increased ADU Assumptions
Includes 21% LowVl and 6% Mod affordability and
aggressive ADU assumptions
Scenario Builder ‐ Options to Meet RHNA
Includes Rezoning?
Assumed Low/Very Low‐Income Affordability
Assumed Moderate‐Income Affordability
Assumed % of Mixed‐Use Transit Village which is Residential Projected ADU Production Rate (per year over 8‐year period) Step 3:

Compare to RHNA and Create Buffer
0%
162377
2 Attachment 5Page 513 of 894
No
100%
0%
80%
1*(2018‐2021 Average Production)
Extremely
Low/ Very Low
Income
Low Income
Moderate
Income
Above
Moderate
Income
Total NOTES
Final 2023 ‐ 2031 RHNA 402 232 247 641 1,552Pipeline Project 0 966 968Projected ADU Production 41 14 135 Total Pipeline Projects and ADU's 41 980 1,103Innovation Center Specific Plan  429 0 2,222Vacant Residential Land 381 795 1,622Total Existing Zoning Capacity 810 795 3,844 Total Unit Potential  851 1,775 4,947Units Over/Under 604 1,134 3,844Percent Over/Under 245% 177% 219% Strategy 2
DRAFT Sites Analysis Summary Table
6/23/2022
Strategy 2: No Rezoning Required,
HCD Approved Methodology
Includes Total Affordability at 100%, no rezoning, and safe‐harbor ADU assumptions
Scenario Builder ‐ Options to Meet RHNA
Includes Rezoning?
Assumed Low/Very Low‐Income Affordability
Assumed Moderate‐Income Affordability (on Low/VL)
Assumed % of Mixed‐Use Transit Village which is Residential Projected ADU Production Rate (per year over 8‐year period) Step 3:

Compare to RHNA and Create Buffer
266%
80 1,793
2 2,3212,239
1,687
446
82 Step 1:

Count Projects in the Pipeline and
Estimate ADU's
Steps to Accommodate
RHNA
Step 2:

Identify Existing Zoning Capacity
Attachment 5Page 514 of 894
No
30%10%80%
1*(2018‐2021 Average Production)
Extremely
Low/ Very Low
Income
Low Income
Moderate
Income
Above
Moderate
Income
Total NOTES
Final 2023 ‐ 2031 RHNA 402 232 247 641 1,552Pipeline Project 0 966 968Projected ADU Production 41 14 135 Total Pipeline Projects and ADU's 41 980 1,103Innovation Center Specific Plan  223 1,460 2,222Vacant Residential Land 83 1,405 1,622Total Existing Zoning Capacity 306 2,865 3,844Total Unit Potential  347 3,845 4,947Units Over/Under 100 3,204 3,844Percent Over/Under 40% 500% 219% Strategy 3
DRAFT Sites Analysis Summary Table
6/23/2022
Strategy 3: No Rezoning Required,
HCD Approved Methodology with Conservative
Affordability Assumptions
Includes 30% LowVl and 10% Mod Affordability, No Rezoning, and Safe‐ Harbor ADU Assumptions
Scenario Builder ‐ Options to Meet RHNA
Includes Rezoning?
Assumed Low/Very Low‐Income Affordability
Assumed Moderate‐Income Affordability
Assumed % of Mixed‐Use Transit Village which is Residential Projected ADU Production Rate (per year over 8‐year period) Step 3:

Compare to RHNA and Create Buffer
19%
80 539
2 755673
121
134
82 Step 1:

Count Projects in the Pipeline and
Estimate ADU's
Steps to Accommodate
RHNA
Step 2:

Identify Existing Zoning Capacity
Attachment 5Page 515 of 894
EŽ
Ϯϭй
ϲй
ϴϬй
ϮΎ;ϮϬϭϴͲϮϬϮϭǀĞƌĂŐĞWƌŽĚƵĐƚŝŽŶͿ

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

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


EŽ
ϭϬϬй
Ϭй
ϴϬй
ϭΎ;ϮϬϭϴͲϮϬϮϭǀĞƌĂŐĞWƌŽĚƵĐƚŝŽŶͿ

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

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


EŽ
ϯϬйϭϬйϴϬй
ϭΎ;ϮϬϭϴͲϮϬϮϭǀĞƌĂŐĞWƌŽĚƵĐƚŝŽŶͿ

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

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


Legend:

Sites Developed During 6th Cycle
Sites Not Developed and Not Carried
Over to the 6th Cycle
APN GP ZONE Acres Notes
Originally
Estimated
Capacity
Developed
During 5th
Cycle
Units
Developed
Included in
Draft 6th
Cycle
012100020 R-HD R-3 0.36 APN listed does not exist. Couldn't find this site. 4 N/A
016110029 BBSP BBSP 0.25 APN listed does not exist. Couldn't find this site. 4 N/A
017170009 R-HD PD-44 3.77 Six total Low, Medium, and High Density lots were consolidated for a total of 296 units for the
Palmilla Subdivision
48 Yes N/A No
010020014 R-VHD PD-21 0.11 Part of Kindred & Balfour 2 Yes No 010020015 R-VHD PD-21 5.52 Part of Kindred & Balfour 97 Yes No 019031002 R-VHD PD-53 5.42 Amber Lane Apartments 130 Yes No 019031005 R-VHD PD-53 3.56 Amber Lane Apartments 85 Yes No 016170019 PD PD-55 12.91 Completed Project - Sciortino Ranch/Terrene 258 Yes 326 No 013240010 DSP DT 2.57 Park and Ride 33 Yes 0 No
013060017 DSP DT 0.17 Parking Lot 2 Yes N/A No
007580012 PD PD-64 0.98 Completed Project - Barcelona Yes No 007580011 PD PD-64 1.00 Completed Project - Barcelona Yes No 007580005 PD PD-64 0.84 Completed Project - Barcelona Yes No 007580013 PD PD-64 0.91 Completed Project - Barcelona Yes No 007590001 PD PD-64 3.04 Completed Project - Barcelona Yes No 07380002 PD PD-64 18.13 Pipeline Project, Sites 93 and 105 (Cowell Ranch) No Yes
07380003 PD PD-64 13.78 Pipeline Project, Sites 93 and 105 (Cowell Ranch) No Yes
016120025 BBSP BBSP 8.23 Pipeline Project, Site 101 - Silvergate 132 No 166 Yes 019040031 R-HD R-3 1.14 Site 55 15 No N/A Yes
019040033 R-HD R-3 0.99 Site 56 13 No N/A Yes
010840012 R-VHD PD-49 7.70 Sites 12, 13, and 14 on new list 208 No N/A Yes 010840010 R-VHD PD-49 3.39 Sites 12, 13, and 14 on new list 91 No N/A Yes 010840011 R-VHD PD-49 6.81 Sites 12, 13, and 14 on new list 208 No N/A Yes 016120020 BBSP BBSP 12.31 Site 81 197 No N/A Yes
018190018 BBSP BBSP 9.70 Site 58 155 No N/A Yes
018170003 BBSP BBSP 6.11 Site 59 98 No N/A Yes
016130007 BBSP BBSP 5.69 Site 83 91 No N/A Yes
016120024 BBSP BBSP 5.03 Site 61 80 No N/A Yes
016150114 BBSP BBSP 1.59 Site 62 25 No N/A Yes
019020055 PD PD-51 4.02 Became PA-1 97 No N/A Yes
019020073 PD PD-51 19.05 Became PA-1 457 No N/A Yes
019081015 MUPT PD-52 51.40 Became PA-1 247 No N/A Yes
019081003 MUPT PD-52 35.01 Became PA-1 168 No N/A Yes
019081006 MUPT PD-52 9.83 Became PA-1 47 No N/A Yes
019020059 MUPT PD-52 5.50 Became PA-1 26 No N/A Yes
019020024 MUPT PD-52 5.01 Became PA-1 24 No N/A Yes
019081019 MUPT PD-52 4.34 Became PA-1 21 No N/A Yes
019081018 MUPT PD-53 19.18 Became PA-1 95 No N/A Yes
019020074 MUPT PD-53 15.13 Became PA-1 75 No N/A Yes
019081009 MUPT PD-53 9.89 Became PA-1 49 No N/A Yes
019020071 MUPT PD-53 7.52 Became PA-1 37 No N/A Yes
019081020 MUPT PD-53 6.72 Became PA-1 33 No N/A Yes
019031003 MUPT PD-53 5.41 Became PA-1 27 No N/A Yes
016010019 BBSP BBSP 1.01 RDA Parcels are not being included 16 No N/A No 016010020 BBSP BBSP 0.80 RDA Parcels are not being included 13 No N/A No Multifamily Residential Zoning Sites Listed in the 5th Cycle Housing Element Sites Inventory 288
140
72 Sites Carried Over to 6th Cycle
Sites Not Found
350
Attachment 6a

018150011 BBSP BBSP 0.26 Parcels that yield less than 10 units are not being included in 6th Cycle 4 No N/A No
017160004 DSP DT 3.64 RDA Parcels are not being included 24 No N/A No 701209023 DSP DT 1.58 Mobile Home Park can not be included this cycle 20 No N/A No
701209003 DSP DT 1.58 Mobile Home Park can not be included this cycle 20 No N/A No
701209011 DSP DT 1.58 Mobile Home Park can not be included this cycle 20 No N/A No
013132005 DSP DT 0.39 Parcels that yield less than 10 units are not being included in 6th Cycle 5 No N/A No
013132004 DSP DT 0.21 Parcels that yield less than 10 units are not being included in 6th Cycle 3 No N/A No
TOTAL 250.54 3,854 992
Attachment 6a

Legend:

Sites Developed During 6th Cycle
Sites Not Developed and Not Carried
Over to the 6th Cycle
APN GP ZONE Acres Notes
Originally
Estimated
Capacity
Developed
During 5th
Cycle
Developed
Capacity
Included in
Draft 6th
Cycle
R-LD PD-46 Barrington 379 Yes 379 No
R-LD PD-45 Cedarwood 70 Yes 70 No
R-LD R-1 Ferro-Ronconi 130 Yes 130 No
R-HD PD-17 Garin Corners 137 Yes 137 No
R-LD PD-35 Lexington Park 54 Yes 54 No
BBSP BBSP Magnolia 33 Yes 33 No
R-MD PD-16 Mission Grove 132 Yes 132 No
R-MD/HD PD-44 Palmilla 471 Yes 471 No
R-VLD PD-39 Portofino 114 Yes 114 No
R-MD PD-67 Siena Village 38 Yes 38 No
R-LD PD-26 St. Martns Place 5 Yes 5 No
R-LD PD-59 Steeplechase I 139 Yes 139 No
R-LD PD-66 Terreno 14 Yes 14 No
R-LD PD-64 Trilogy 760 Yes 760 No
R-LD PD-41 Parkside Villas - Pipeline Project, Site 94 37 No N/A Yes 019082007 R-LD PD-36 Based on multiple General Plan land use designations and acreage uncertainty, this
parcel is not being included in 6th Cycle
166 No N/A No
019050160 R-LD PD-41 Amber & Windy Springs Lane - Parcels that yield less than 10 units are not being included
in 6th Cycle
4 No N/A No
18060042 R-VLD PD-29 Parcels that yield less than 10 units are not being included in 6th Cycle
3 No N/A No
017010011 R-LD PD-26 Parcels that yield less than 10 units are not being included in 6th Cycle
3 No N/A No
R-LD R-1-8 Siino - Parcels that yield less than 10 units are not being included in 6th Cycle
8 No N/A No
017080007 R-LD PD-26 St. James Tract - Parcels that yield less than 10 units are not being included in 6th Cycle
7 No N/A No
019100012 R-LD R-1-10 Parcels that yield less than 10 units are not being included in 6th Cycle
1 No N/A No
TOTAL 2,705 2,476
Single Family Sites with Approved Entitlements
Entitled Single Family Residential Zoning Sites Listed in the 5th Cycle Housing Element Sites Inventory Sites Not Found
Sites Carried Over to 6th Cycle
Attachment 6b

Legend:

Sites Developed During 6th Cycle
Sites Not Developed and Not Carried
Over to the 6th Cycle
APN GP ZONE Acres Notes
Originally
Estimated
Capacity
Developed
During 5th
Cycle
Developed
Capacity
Included in
Draft 6th
Cycle
012030007 R-LD R-1 5.01 Part of Catchings Ranch Subdivision 14 Yes 16 No 016100002 RE RE 4.20 Parcels that yield less than 10 units are not being included in 6th Cycle
3 No N/A No
019100015 RE RE 2.26 Parcels that yield less than 10 units are not being included in 6th Cycle
1 No N/A No
017010012 R-LD PD-26 2.54 Parcels that yield less than 10 units are not being included in 6th Cycle
6 No N/A No
017100005 R-LD R-1-E 2.50 Parcels that yield less than 10 units are not being included in 6th Cycle
6 No N/A No
017100016 R-LD R-1-E 2.40 Parcels that yield less than 10 units are not being included in 6th Cycle
6 No N/A No
017010014 R-LD PD-26 1.82 Parcels that yield less than 10 units are not being included in 6th Cycle
4 No N/A No
019390123 R-LD PD-6 0.84 Parcels that yield less than 10 units are not being included in 6th Cycle
1 No N/A No
010130070 R-LD R-1-8 0.68 Parcels that yield less than 10 units are not being included in 6th Cycle
1 No N/A No
018060007 R-VLD PEC 4.67 Parcels that yield less than 10 units are not being included in 6th Cycle
8 No N/A No
016030011 R-VLD R-1-E 4.38 Parcels that yield less than 10 units are not being included in 6th Cycle
7 No N/A No
016100028 R-VLD R-1-E 4.15 Parcels that yield less than 10 units are not being included in 6th Cycle
7 No N/A No
018030008 R-VLD PD-29 4.15 Parcels that yield less than 10 units are not being included in 6th Cycle
7 No N/A No
018060051 R-VLD PEC 2.44 Parcels that yield less than 10 units are not being included in 6th Cycle
3 No N/A No
018050046 R-VLD R-1-E 1.63 Parcels that yield less than 10 units are not being included in 6th Cycle
2 No N/A No
018050034 R-VLD R-1-E 1.34 Parcels that yield less than 10 units are not being included in 6th Cycle
1 No N/A No
018050035 R-VLD R-1-E 1.32 Parcels that yield less than 10 units are not being included in 6th Cycle
1 No N/A No
018060010 R-VLD PD-29 1.24 Parcels that yield less than 10 units are not being included in 6th Cycle
1 No N/A No
019680023 R-VLD PD-18 1.21 Parcels that yield less than 10 units are not being included in 6th Cycle
1 No N/A No
018050045 R-VLD R-1-E 1.66 Parcels that yield less than 10 units are not being included in 6th Cycle
1 No N/A No
012070031 R-MD R-2 1.00 Parcels that yield less than 10 units are not being included in 6th Cycle
5 No N/A No
012100043 R-MD R-3 0.86 Parcels that yield less than 10 units are not being included in 6th Cycle
4 No N/A No
018150002 R-LD R-1-10 1.19 Parcels that yield less than 10 units are not being included in 6th Cycle
1 No N/A No
018100044 R-LD R-1-E 1.68 Parcels that yield less than 10 units are not being included in 6th Cycle
3 No N/A No
TOTAL 55.18 94 16
Sites with Existing Development that Can Accommodate Additional Units Underutilized Single Family Residential Zoning Sites Listed in the 5th Cycle Housing Element Sites Inventory Sites Not Found
Sites Carried Over to 6th Cycle
Attachment 6b

Legend:

Sites Developed During 6th Cycle
Sites Not Developed and Not Carried
Over to the 6th Cycle
APN GP ZONE Acres Notes
Originally
Estimated
Capacity
Developed
During 5th
Cycle
Developed
Capacity
Included in
Draft 6th
Cycle
019110050 R-LD PD-6 2.58 APN not found 7
019050112 R-LD PD-41 5.00 APN not found 15
019840109 R-MD PD-53 7.60 APN not consistent with acreage 45 019110051 R-LD PD-57 3.67 APN not found, PD-57 doesn't exist 11 018100042 R-LD PD-59 1.06 APN not found 6
018100042 R-LD R-1-E 7.72 APN not found 18
018080010 R-VLD RE 1.20 APN not found 1
018080012 R-VLD RE 1.02 APN not found 1
018080020 R-VLD RE 0.30 APN not found 1
018080019 R-VLD RE 0.14 APN not found 1
018020010 R-LD R-1 0.40 APN not found 1
018020011 R-LD R-1 0.21 APN not found 1
016170025 PD PD-55 18.57 Completed - Part of Sciortini Ranch 157 Yes 157 No 019161026 R-LD PD-1 0.26 1 Yes 1 No
010020015 R-MD PD-21 6.66 Part of Kindred & Balfour 39 Yes 39 No 010020014 R-MD PD-21 4.66 Part of Kindred & Balfour 27 Yes 27 No 010160043 R-MD PD-24 10.70 Sellers Pointe 64 Yes No
010160043 R-MD PD-24 7.79 Sellers Pointe 46 Yes No
010160038 R-MD PD-24 3.73 Sellers Pointe 22 Yes No
017660017 R-LD PD-26 0.29 Carmel Estates 1 Yes 1 No
017660014 R-LD PD-26 0.27 Carmel Estates 1 Yes 1 No
017660009 R-LD PD-26 0.26 Carmel Estates 1 Yes 1 No
017660069 R-LD PD-26 0.25 Carmel Estates 1 Yes 1 No
017660022 R-LD PD-26 0.21 Carmel Estates 1 Yes 1 No
017660070 R-LD PD-26 0.06 Carmel Estates 1 Yes 1 No
017660071 R-LD PD-26 0.06 Carmel Estates 1 Yes 1 No
012030025 R-LD R-1 3.02 Part of Catchings Ranch Subdivision 9 Yes 8 No 017150054 R-LD R-1-6 0.16 1 Yes 1 No
018110008 R-LD R-1-E 9.28 Maffeo 22 Yes 27 No
016090016 RE RE 3.29 3 Yes 1 No
012070032 R-MD R-2 0.56 3 Yes 1 No
010010039 R-LD PD-20 4.32 Site 18 on new list 12 No Yes 019092013 R-LD PD-35 11.59 Site 29 on new list 34 No Yes 019092034 R-LD PD-35 9.31 Site 30 on new list 27 No Yes 019050026 R-LD PD-35 3.26 Site 90 on new list 9 No Yes
010100014 R-LD PD-47 20.18 Pipeline Project Site 100 on new list 60 No 77 Yes 018230034 R-LD PD-71 19.76 Site 68 on new list 59 No Yes 018090012 R-LD R-1-10 5.14 Pipeline Project Site 104 on new list 15 Yes 14 Yes 016040005 R-VLD RE 16.61 Site 73 on new list 16 No Yes
019130044 R-LD PD-1 1.66 Not a developable parcel 4 No No 019171012 R-LD PD-1 0.22 Parcels that yield less than 10 units are not being included in 6th Cycle
1 No No
010470073 R-MD PD-13 0.05 Parcels that yield less than 10 units are not being included in 6th Cycle
1 No No
019360032 R-LD PD-15 0.13 Parcels that yield less than 10 units are not being included in 6th Cycle
1 No No
019320042 R-LD PD-15 0.07 Parcels that yield less than 10 units are not being included in 6th Cycle
1 No No
019350040 R-LD PD-18 0.05 Parcels that yield less than 10 units are not being included in 6th Cycle
1 No No
Vacant Single Family Residential Zoning Sites Listed in the 5th Cycle Housing Element Sites Inventory Sites Not Found
Sites Carried Over to 6th Cycle
Vacant Single Family Sites (sorted by Zoning Designation) 132
Attachment 6b

019130056 R-VLD PD-18 1.03 Parcels that yield less than 10 units are not being included in 6th Cycle
2 No No
017420046 R-LD PD-2 0.29 Parcels that yield less than 10 units are not being included in 6th Cycle
1 No No
007100097 R-LD PD-20 4.57 Inconsistant Zoning and GP so not included13 No No 007440018 R-LD PD-20 3.67 Parcels that yield less than 10 units are not being included in 6th Cycle
7 No No
010010041 R-LD PD-20 1.48 Parcels that yield less than 10 units are not being included in 6th Cycle
4 No No
007220032 R-LD PD-20 0.42 Parcels that yield less than 10 units are not being included in 6th Cycle
1 No No
007100126 R-VLD PD-20 8.21 Inconsistant Zoning and GP so not included 16 No No 007100079 R-VLD PD-20 1.56 Parcels that yield less than 10 units are not being included in 6th Cycle
3 No No
007100090 R-VLD PD-20 1.37 Parcels that yield less than 10 units are not being included in 6th Cycle
2 No No
007100091 R-VLD PD-20 1.23 Parcels that yield less than 10 units are not being included in 6th Cycle
2 No No
007100095 R-VLD PD-20 0.59 Parcels that yield less than 10 units are not being included in 6th Cycle
1 No No
007100094 R-VLD PD-20 0.50 Parcels that yield less than 10 units are not being included in 6th Cycle
1 No No
007100087 R-VLD PD-20 0.34 Parcels that yield less than 10 units are not being included in 6th Cycle
1 No No
007100088 R-VLD PD-20 0.33 Parcels that yield less than 10 units are not being included in 6th Cycle
1 No No
007100092 R-VLD PD-20 0.15 Parcels that yield less than 10 units are not being included in 6th Cycle
1 No No
007100093 R-VLD PD-20 0.08 Parcels that yield less than 10 units are not being included in 6th Cycle
1 No No
010400048 R-LD PD-21 1.17 Parcels that yield less than 10 units are not being included in 6th Cycle
3 No No
010370043 R-LD PD-21 0.65 Parcels that yield less than 10 units are not being included in 6th Cycle
1 No No
010400056 R-LD PD-21 0.48 Parcels that yield less than 10 units are not being included in 6th Cycle
1 No No
010400051 R-LD PD-21 0.17 Parcels that yield less than 10 units are not being included in 6th Cycle
1 No No
010400055 R-VLD PD-21 0.03 Parcels that yield less than 10 units are not being included in 6th Cycle
1 No No
017010022 R-LD PD-26 3.27 Parcels that yield less than 10 units are not being included in 6th Cycle
8 No No
018060019 R-VLD PD-29 0.53 Parcels that yield less than 10 units are not being included in 6th Cycle
1 No No
018060012 R-VLD PD-29 0.32 Parcels that yield less than 10 units are not being included in 6th Cycle
1 No No
018390028 R-VLD PD-29 0.18 Parcels that yield less than 10 units are not being included in 6th Cycle
1 No No
018650037 R-VLD PD-39 0.98 Parcels that yield less than 10 units are not being included in 6th Cycle
1 No No
019050113 R-LD PD-35 1.26 Parcels that yield less than 10 units are not being included in 6th Cycle
3No No
019050038 R-LD PD-35 0.98 Parcels that yield less than 10 units are not being included in 6th Cycle
2 No No
019770039 R-LD PD-35 0.21 Parcels that yield less than 10 units are not being included in 6th Cycle
1 No No
019060039 RE PD-35 1.34 Parcels that yield less than 10 units are not being included in 6th Cycle
1 No No
019060038 RE PD-35 1.04 Parcels that yield less than 10 units are not being included in 6th Cycle
1 No No
019060037 RE PD-35 1.03 Parcels that yield less than 10 units are not being included in 6th Cycle
1 No No
Attachment 6b

010840016 R-LD PD-49 0.09 Parcels that yield less than 10 units are not being included in 6th Cycle
0 No No
019850100 R-MD PD-53 0.14 Parcels that yield less than 10 units are not being included in 6th Cycle
1 No No
019850099 R-MD PD-53 0.07 Parcels that yield less than 10 units are not being included in 6th Cycle
1 No No
019390120 R-LD PD-6 0.19 Parcels that yield less than 10 units are not being included in 6th Cycle
1 No No
019750055 R-MD PD-6 0.88 Parcels that yield less than 10 units are not being included in 6th Cycle
5 No No
018570005 R-LD PD-60 0.25 Parcels that yield less than 10 units are not being included in 6th Cycle
1 No No
007380031 R-LD PD-64 7.72 Vineyard parcel dedicated to the City 23 No No 012120065 R-LD PD-8 0.27 Parcels that yield less than 10 units are not being included in 6th Cycle
1 No No
012340049 R-LD PD-8 0.14 Parcels that yield less than 10 units are not being included in 6th Cycle
1 No No
012340008 R-LD PD-8 0.04 Parcels that yield less than 10 units are not being included in 6th Cycle
1 No No
012120037 R-LD PD-8 0.03 Parcels that yield less than 10 units are not being included in 6th Cycle
1 No No
019420026 R-LD PD-9 0.36 Parcels that yield less than 10 units are not being included in 6th Cycle
1 No No
012300016 R-LD R-1 2.37 Parcels that yield less than 10 units are not being included in 6th Cycle
7 No No
012030011 R-LD R-1 1.45 Parcels that yield less than 10 units are not being included in 6th Cycle
4 No No
018150004 R-LD R-1-10 0.65 Parcels that yield less than 10 units are not being included in 6th Cycle
1 No No
018150024 R-LD R-1-10 0.38 Parcels that yield less than 10 units are not being included in 6th Cycle
1 No No
018150001 R-LD R-1-10 0.13 Parcels that yield less than 10 units are not being included in 6th Cycle
1 No No
017150059 R-LD R-1-6 0.16 Parcels that yield less than 10 units are not being included in 6th Cycle
1 No No
012063013 R-LD R-1-6 0.12 Parcels that yield less than 10 units are not being included in 6th Cycle
1 No No
017131023 R-LD R-1-6 0.10 Parcels that yield less than 10 units are not being included in 6th Cycle
1 No No
012030030 R-LD R-1-8 0.41 Parcels that yield less than 10 units are not being included in 6th Cycle
1 No No
012030028 R-LD R-1-8 0.27 Parcels that yield less than 10 units are not being included in 6th Cycle
1 No No
010130075 R-LD R-1-8 0.12 Parcels that yield less than 10 units are not being included in 6th Cycle
1 No No
010750051 R-VLD R-1-E 2.57 Parcels that yield less than 10 units are not being included in 6th Cycle
6 No No
016030006 R-VLD R-1-E 0.24 Parcels that yield less than 10 units are not being included in 6th Cycle
1 No No
018080017 R-VLD RE 4.58 Parcels that yield less than 10 units are not being included in 6th Cycle
4 No No
018080018 R-VLD RE 4.02 Parcels that yield less than 10 units are not being included in 6th Cycle
4No No
018080022 R-VLD RE 2.87 Parcels that yield less than 10 units are not being included in 6th Cycle
2 No No
018080025 R-VLD RE 1.07 Parcels that yield less than 10 units are not being included in 6th Cycle
1 No No
016100026 RE RE 1.30 Parcels that yield less than 10 units are not being included in 6th Cycle
1 No No
016100025 RE RE 1.13 Parcels that yield less than 10 units are not being included in 6th Cycle
1 No No
016090024 RE RE 1.01 Parcels that yield less than 10 units are not being included in 6th Cycle
1 No No
Attachment 6b

012050018 R-LD R-2 8.21 Utilized by a storage business so not included in draft inventory
24 No No
013133022 R-MD R-2 0.17 Utilized by a storage business so not included in draft inventory
1 No No
012100048 R-MD R-3 0.22 Utilized by a storage business so not included in draft inventory
1 No No
013170006 R-MD R-3 0.12 Utilized by a storage business so not included in draft inventory
1 No No
TOTAL 276.68 940 492
Attachment 6b

MEMORANDUM
DATE: July 15, 2022
TO: Mayor and City Council

FROM: Jennifer Hagen, Senior Planner
Alexis Morris, Community Development Director
SUBJECT: July 21, 2022 Housing Element Workshop Revised Options including Originally adopted PA-1 Assumptions

BACKGROUND
On July 12, 2022, the City Council continued consideration of recommended changes to the Innovation Center Specific Plan (PA-1) to a later date in order to allow further discussion and analysis of the Specific Plan. The original memo for the July 21, 2022 Special Meeting on the Housing Element Update (dated July 6, 2022, and distributed to City Council on July 7 ,2022) included three strategies to address the City’s RHNA (Regional Housing Needs Allocation) based on the recommended changes to PA-1, not on the originally adopted plan. Based on the City Council direction and the uncertainty related to any changes to the Specific Plan at this time, staff has prepared three revised strategies that are based on the PA-1 Specific Plan currently in effect. The overall number of projected units vary slightly based on different acreages and densities assigned to each land use designation between the two versions of the specific plan and the varying assumptions for each designation.

This memo provides revised tables showing how the methodologies shared in the previous memo published July 7, 2022, work with the existing 2018 PA-1 Specific Plan designations. The table numbers correspond to the same table numbers used in the memo published July 7, 2022, for ease of comparison. Changes are relatively minor and the staff and consultant team will be able to move forward with these revisions without serious disruption to the overall Housing Element Update process. The potential changes to the PA-1 Specific Plan provide a good example of why including a buffer of 15-30% more units than identified in the lower income RHNA is recommended by HCD and staff – circumstances can evolve over the next eight years and sites can develop differently than projected,so a buffer allows the City to absorb those changes and still have other sites available to meet RHNA.

REVISED ANALYSIS OF EXISTING/BASELINE ZONING CAPACITY
In order to provide a comprehensive analysis of the City’s existing zoning capacity to meet the City’s 6th Cycle RHNA, staff utilized the existing residential zoning capacity including capacity within Specific Plan areas, as well as Accessory Dwelling Unit (ADU) projections as described in the previously published memo. (The full discussion of this issue begins on page 4 in the memo published July 7, 2022)
Capacity in Existing Specific Plans
The following table includes updated information using vacant or underutilized parcels within the PA-1 Specific Plan as adopted in 2018 that allow for residential development with capacity to add new housing units.

PA-1 Adopted Residential Land-Use Acreages
Land Use Allowable Density
Range
Mid-Point Acreage
HDR 10-20 du/ac 15 12.42*
MFVHDR 15-35 du/ac 25 40.19
TV/MU 25-40 du/ac 32.5 39.44
*The total acreage designated HDR is 27.02, however 14.42 acres has been included in the pipeline projects already entitled for the Amber Lane Apartments.

Based on the General Plan allowable density, staff is recommending utilizing the assumption that 80%1 of the TV/MU sites would be developed with housing for the purposes of Housing Element projections. Utilizing this assumption would provide the City with a larger buffer in the very low- and low-income categories, allowing the buffer in Strategy 3 to be between the HCD recommended 15 and 30 percent range. If the 80% development assumption were to be reduced to 50%, the buffer in Strategy 3 would be approximately 12% in the very low- and low-income category which would not be supported by HCD. Based on the adopted 2018 PA-1 designations, utilizing the mid-point density, and the assumption that TV/MU sites will be developed with 80% residential, the Housing Element projections would be updated to yield approximately 2,215 units within the Specific Plan area.

REVISED SITE INVENTORY AND AFFORDABILITY ASSUMPTION STRATEGIES (The full discussion of this issue begins on page 8 in the memo published July 7, 2022.) The summary of the three identified strategies from the original memo (Table 4 in the original memo) is updated below to reflect the adopted 2018 PA-1 land use designations. The table is followed by an updated discussion of each strategy.

Table 4: Strategy Summaries – Updated with 2018 PA-1 Specific Plan Designations 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: 684 units
Mod: 263 units
AMod: 4,183 units
Total: 5,075 units
VL/L: 2,557 units
Mod: 608 units
AMod: 1,775 units
Total: 4,940 units
VL/L: 824 units
Mod: 345 units
AMod: 3,771 units
Total: 4,940 units
Buffer 8% Low/Very Low,
6% Moderate-, and
544% Above Moderate
303% Low/Very Low,
146% Moderate-, and
177% Above Moderate
30% Low/Very Low, 40%
Moderate-, and 488%
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.

1 Assumptions utilized in analyzing the environmental impacts for the adopted PA-1 EIR included the assumption that 50% of the TV/MU designation could be developed with up to 2,041 residential units. The PA-1 EIR unit assumptions are used for the purposes of conducting analysis of environmental impacts and are not a “cap” on development. The Housing Element assumptions are used for the purposes of projecting the number of affordable units a site can support and do not need to be consistent with the assumptions used in the PA-1 EIR. Page 528 of 894 Strategy 1: Reduced Affordability with Increased ADU Assumptions (The full discussion of this issue begins on page 9 in the memo published July 7, 2022) Updates to Incorporate Existing 2018 PA-1 Specific Plan Designations Strategy 1 includes assumptions of 27% affordable units (9% very low-, 12% low-, and 6% moderateincome units) on all sites meeting the minimum default density of 30 du/ac, higher ADU projections, and a buffer as close to 0% as possible. Updating this strategy using projections based on the approved 2018 PA-1 Specific Plan could allow the assumed affordability levels to be reduced by 1-2% more to be as close to a 0% buffer as possible. Table 7 below summarizes the results of the revised evaluation of existing residential development capacity utilizing the 2018 PA-1 Specific Plan. Strategy 1 would result in slightly larger capacity than the original assumptions, which would include an 8% buffer in the lower income category. This is the smallest buffer of the three strategies and would likely result in the need to rezone or up zone parcels during the eight year Housing Element Cycle.

Table 7: Summary of Strategy 1 Capacity Analysis

Very
LowIncome
LowIncome ModerateIncome
Above
ModerateIncome Total
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 (2018 Specific Plan) 426 132 1,657 2,215
Vacant Residential Land 94 50 1,478 1,622
Total Unit Potential 684 263 4,128 5,075
Units +/- and Buffer/Gap
% 50 units, 8% 16 units, 6% 3,487 units,
544%
3,837 units,
227%
Strategy 2: No Rezoning Required, HCD Approved Methodology (The full discussion of this issue begins on page 11 in the memo published July 7, 2022.) Updates to Incorporate Existing 2018 PA-1 Specific Plan Designations 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% lower-income affordability for all sites allowing 30 du/ac or more, and 100% moderate-income affordability for all sites allowing between 15-25 du/ac. Table 8 below summarizes the results of revised evaluation of existing residential development capacity utilizing Strategy 2 capacity assumptions based on the approved 2018 PA-1 Specific Plan. Strategy 2 would continue to provide the City with the largest buffer in the very low- and low-income categories and would continue to be the strategy least likely to require rezoning or up zoning in the future.

Table 8: Summary of Strategy 2 Capacity Analysis
Very LowIncome
LowIncomeModerateIncome
Above
ModerateIncome Total
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 (2018 Specific
Plan) 2,029 186 0 2,215
Vacant Residential
Land 446 381 795 1,622
Total Unit Potential 2,557 608 1,775 4,940
Units +/- and
Buffer/Gap % 1,923 units, 303% 361 units,
146%
1,134 units,
177%
3,837 units,
218%
Strategy 3: No Rezoning Required, HCD Approved Methodology with Conservative Affordability Assumptions
(The full discussion of this issue begins on page 12 in the memo published July 7, 2022.) Updates to Incorporate Existing 2018 PA-1 Specific Plan Designations Strategy 3 utilizes the preliminary analysis of RHNA and sites strategies as presented in the initial sections of this report with the 2018 PA-1 capacity. 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, this strategy uses a more conservative assumption that projects 30% lower-income affordability and 10% moderate-income affordability for very high-density sites and 30% moderate-income affordability for high-density sites. Because this strategy would be projected to have fewer affordable units, the City would be more likely than Strategy 2 to need to modify assumptions or up zone additional sites later in the planning period due to “no net loss” requirements.

Table 9 summarizes the results of the revised evaluation of existing residential development capacity utilizing Strategy 3 capacity assumptions based on the approved 2018 PA-1 Specific Plan. Strategy 3 would result in the following projected capacity, which would include a minimum 30% buffer in the lower income category:

Table 9: Summary of Strategy 3 Capacity Analysis
Very LowIncome
LowIncome ModerateIncome
Above
ModerateIncome Total
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 (2018 Specific
Plan) 608 221 1,386 2,215
Vacant Residential
Land 134 83 1,405 1,622
Total Unit Potential 824 345 3,3771 4,940
Units +/- and
Buffer/Gap % 190 units, 30% 98 units,
40%
3,130 units,
488%
3,837 units,
218%

CONCLUSION
In conclusion, the memo published on July 7, 2022 contains detailed description of each strategy and this memo seeks to update the numbers provided in the 2018 PA-1 Specific Plan due to Council’s continuance of consideration of changes to that Specific Plan on July 12.

Staff is recommending that the City Council review, discuss, and receive public comments on the Housing Element Update RHNA sites strategies on July 21 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. Staff and the consultant team will be able to provide an interactive table during the workshop where assumed affordability levels, assumed mixed-use percent build out, ADU assumptions and inventory sites may be adjusted in real time to aid in the decision making process.

Attachments
July 6, 2022 memorandum (published July 7, 2022)

 

 
 



!
"#$ %

&%'(%
)%
*

% +%,--
..
/%0%1.%
/%! 
2345
6 7'-
(8%.%
9:-;18,%! 0%)..

9:-;1<=>%! 0%- + ;%79:-;1- &&-%?%- ( ;%


!@-
1 

%! 

;% - &- %- =%!%
&A
&
--
;%'-
(8%.%
B1
 %CD;%A:-;1-
%

%
!!.1-; ;%&A
(=>%! 0%-E
7C*%-%
;%
&.%A:& ;%- %
0%

!

('
/!!%1 %
--.1 
- 

1
!1%- ; .=%-%

%0%1 ;%
0%
C
CF

!% ;%
--&%,-
(%-
%
G

(!1! A ;
;%! 
!

( ;% 1%.
- %- &.A;!; ;%- %
0%
A=%!.1%


%0 
& ;%
.=%&
-&A;!;


- %-.=%
%%
%


%-- ;%
@-H'I+  G
( ;%%
&&%%
-  %(%- ;
!
%0
(&&
= --.1 
-

+/B 1>%! 
--.1 
-C
JCH%!%0%
%! 
&. ;%


!
A;!;) %F
0%
)  %(-
%-!=%

;%) %F
0%


+&&
= +--.1 
)  %(%--%! 
& ;-%1  .0% &A
A ;A;%
1%1
(&&
= 1>%! 
-

;%/& '-
(8%.%
B1
 %C
/%0%1
( ;%) %F
0%
 D;% !;%
- &&%1 10
%-=!:(

&. 

;%&.%A:& ;%- %
0%

!

('
/!!%1 %
--.1 
-

1
!1%-- 
%

;%'
/) % F
0%
K
%=:A;!;- !;%
&%&%%
!%C
D.0%&A

;%1

(1!%--

&
( ;%'-
(8%.%
B1
 % - .1% 0% ; ;%


!10
%
%! 

A;!;-  %(%--;
=%-%

&.
( =-%
%- %
0%


&&
= --.1 
-CF.1 
;
(- !
-
%A;%
-%%!
( ;%=-%
%- %
0%
-  %(%E
7C*

(&0-C!
- !
(;-
(ED;%
-
 %?%
=
;-
(= - %?%
1
&-&&!%
;-
( .%%  -%(
;-
(
%%
C+& ;% -  %(%--..G%
=%A G% ;%
@-%,-
(K%
%*

%-(
 
-


 %?%
!;
(%-  ;%K%
%*
C
















 
 





 






 





  


 


!   



 !

 







 








 
 




!

  

!

 





 

 

 












  

 

 

 
  


 

"


 

 
#$%&






 




 

 

"



 



 

 





'





 


! 
()*

 !





"

 
+,

 

 

 



 



 
#$%&
!

 

 
 

 





 

-#$%& 



 







 
 




 





./+0 !




 



 

  
1,

 

 



$



&


$2 
! 

3 

 $










$2  
& 

4







 


 










 
 













$2

 


 
 







 

 ! 


!  

 


 
 

-

 









 

 








 

 

!'




 




-

  




 
5





 




 












 
!
6 


7

 "







  






"






 



 


!



3



 
 
5




 




 





 
!
! 

 

!
!  



 



 
!
 




"


! 
 


  
.








 

 






 
 
 

-



 
  



 

!

 
'
 $2



 
'





 

8&


5
 


 








 
 





 
 


 "
 

 

-#$%&5

!


 


9

( !' 


 


 
'







 


 






&



 
 




 








 
!


 

 



 





!""

#$%&' (&)*
#+
!,- !++
./&+



01,!//
2
3&)
%' 


01,!//
2
3&)
%'(&) 1+
2#&2 !""

#$%&' !++
./&+ 45
6 78  9+ 9+ :;;8<= :

7>
? @ABC(#
D
' C(#
EB3

#&
AFFBC(#
D
' C(#
AFFB 3

#& GFBC(#
D
' C(#
AFB 3

#& :;;8<=H I= DCJCKEGL
&+ 3
K@EM
&+ !3
KMANG
&+ O&#%KLFN@
&+ DCJCK@G@A
&+ 3
KNLA
&+ !3
KAPPL
&+ O&#%KMQMP
&+ DCJCKPLL
&+ 3
KGMP
&+ !3
KAMFL
&+ O&#%KMQMP
&+ R7;; FBC(JD
'C( P 3

#&S#
LLGB!$23

#& @EEBC(JD
'C( @ML 3

#&S#
APP !$23

#& AQBC(JD
'C( MF 3

#&S#
LFFB!$23

#& TTU

V>=
0)%'%W%'&&

&%++ C#+&%W%'&&

 &%++ 3
%W%'&)#
X&
#&'@&&

 &%++ Y!""

#$%&'#++
./&+#
$#+
&)+&2&
'(&)&)#++
./&&)#&+&+&)#&#%%(GF

J# Z
"#
%&
+&'[
.
 ## ..
#& #/# &'"
%(
S .
&+#
+&+&)#&#%%(AL&@L

J# # # ..
#& #/# &'"
.

#&S .
&+\

L&)1' %0
+]%.&X&+ C#+&%'"

"
 /

/+++&#"")#+ %


&)#
/&
@FALL&)1' %0
+]%.& X&+*2&
'$
W
($&(.
%&S"#.%'#
+%S"#.%'
+
&#%/#
%+\X&#"" )#+ %


%
.+&)#&
 #&&)
$
%
#$%#
##
%#

+
+#&+ &)+&#&
#/# &'&)/
2
+2&
'()&)
&)+&+(

2%/

&) /%#/

)(.#'
&+(

2%/
()&)
&)+&+
 ..

&$ #


2
&&)

& ' %#
"& #


2
()'\*&+)
%
$&
&)#&+&#""+ &
 ..
& #

'2
#'+&+&)#&
&'%
#..
."AF
&+\







!" #

$%&'()*
+,-./
010-234562078-29*5
:2,*-*-2;06-6
+,+*<0=,+2,-.90+,50-2,6
>*-,-.:646:,2?,2;,-2;0:,2,-:

5,-.90@,0?*<6
,+2*<4*20-2,6
+,20+
-509 :*-+,50962,*-<*9,-:

+,*-,-2;0)*
+,-./
010-2A,208-@0-2*9<*92;0 # B7 #B!CD2;E:
0F)*
+,-./
010-2345620"6+?0

6+6-0@6

62,*-*< A,208-@0-2*96-56<<*956G,
,26++
142,*-+29620.,0+-005052*65590++2;0 E,2H+I0.,*-6
)*
+,-.J005K

*:62,*-CI)JKFL
MNMOPQ
0--,<09)6.0-"A0-,*9R
6--09

$%SOPQK
0=,+T*99,+"E*11
-,2U0@0
*410-2U,90:2*9 /9,VJ*
2;0-,
+"R
6--,-.T6-6.09





W*9V,+49*:005,-.*-2;0 # B7 #B!CD2;E:
0F)*
+,-./
010-2345620"?;,:;61*-.*2;09 :*14*-0-2+"?,

,-:

506-
456205,-@0-2*9*<+,20+2;62:6-6::*11*56202;0E,2H+ I0.,*-6 )*
+,-.J005K

*:62,*-CI)JKFLK+6+2692,-.4*,-2<*9:9062,-.2;0)*
+,-./
010-2 3456205A,208-@0-2*9"+26<<;6+,50-2,<,056
,+2*<+,20+2;62
-5092;00=,+2,-.X0-096
R
6- 6-5Y*-,-.50+,.-62,*-+6

*?<*990+,50-2,6
50@0
*410-262@69,*
+50-+,2,0+LA26<<;6+ 49*@,5056164CK226:;10-2ZF6-5
,+2,50-2,<,-.06:;+,20CK226:;10-2BF"6+?0

6+6 :6
:

62,*-*<2;00+2,16205,0
5*<
-,2+<*906:;G6+05*-2;01,574*,-250-+,26

*?05,- 06:;Y*-,-.U,+29,:2*9X0-096
R
6-50+,.-62,*-L
W*9V+;*4[G\0:2,@0+ K22*-,.;2H+?*9V+;*4"+26<<90]
0+2+2;0E,2E*
-:,
H+,-4
26-55,90:2,*-*-2;0
,+2*<+,20+2* G0:699,05<*9?695<*96-6
+,+,-2;0)*
+,-./
010-2345620L^;,+?*9V+;*4,+,-20-5052* 6::*14
,+;2;0<*

*?,-.*G\0:2,@0+_
!LR90+0-22;0,-,2,6
<9610?*9V<*92;0+,20,-@0-2*9",-:

5,-.)EU6::042056++
142,*-+ 6-549,-:,4
0+2;6216G0
+052*50@0
*42;0,-@0-2*9L
L8-29*5
:02;06-6
+,+*<0=,+2,-.90+,50-2,6
>*-,-.:646:,2?,2;,-2;0:,2,-:

5,-.2;0 490
,1,-69+,20
,+2<9*1?;,:;2;0+,20,-@0-2*9?,

G0:*14,
05"6-50@6

62,*-*<2;0 -
1G09*<
-,2+<*9?;,:;655,2,*-6
+,20+16G0-005052*65590++2;0E,2H+I)JK
2,
,>,-.2;9005,<<090-2+29620.,0+2;62,-:

50@69,-.6<<*956G,
,26++
142,*-+6-5KU3 49*\0:2,*-6++
142,*-+L
BLI0:0,@05,90:2,*-<9*12;0E,2E*
-:,
*-?;,:;A,208-@0-2*9A29620."6+50+:9,G05,- 2;0A,208-@0-2*96-5K<<*956G, ,2K++
142,*-A29620.,0++0:2,*-*<2;,+904*92"2*1*@0 <*9?695?,2;?;0-490469,-.6<<*956G, ,249*\0:2,*-+6-52;0U96<2)*
+,-./
010-2 345620L








 !
" 
#!#
$#%&"'(
 ###%)
)
 *+*,'*+,-./0(123(#!4"5)  67
-*8*+*-9 
62)
-:8*+**8# )
#


(#!4"5)
; <=!""##%
>#)9 
6?-8*+**8# )
#
)
(#!4"5)

!0! (#!1
#2.0(123##
!#8
")# %@!# A#)# )
!
"#9


# 

%

 # $
%$7 

$%9 
B

CD E (#!4"#)
 A#F
=
#")
#$#"7 "" #


 
#!
#8
!)
)#
#  )
$# #!"#
#"$#9

(#!4"8 %%#
)
7

 
7@*+-G8$
#)! )


"*+-G*+**.G39(#!4"5) ./3"#7 
)
7?
*+*,8

##*+*,'*+,-)!)

-9 
/0(12 2##7)
$#
8#7##!
/ 0(12 -8G**#!#$
#$#  

792#>")  )

(#!4"8"#
"8
!

8)
'#)  $
8

# ##$7
""

 # 0(129H 
#$!
I##
 





 ""
##!
0(128

##%
7
 

"


9 

I #$
%7$
7@J)
" (#!
 ""J$)".(J392!(J%
$%
$
8)# )

##
 
""
A#%
'"0(1287#
 



#%$
###A
#)
$)

!!'
 )!)

 (#!4"9 
0" # K
L0(12 2)
#8
#
I
"!"#7#


 """A#0(129H  %
#
7

A# 0(128)
##I#
$)
#"#7"))#

@M ,G9@M,G%#
$)
##7"#!
$)"#"!

I
"#8 
!#) 
)
!#  

7#!
)" )
$!%!#8  %
 #
7!#

"#7$"

8$
%8
%'"
0(12
I
"#9=
;#!7 
@M,G"#7))
$
"#
%4N2

$%

#
"#9H

G8"#;
#
# 
8
! M
%
8
#7;@M,G9M
%
"##
")
;#)) 
@M,G ))
$8##
#G+O # 
%
'"
#
#8
" 

I
"#9
8#)
;#7#7"
9 
(J## 
"
(#!275.(253$#!$# #! %# "
 
$
#2
F
9(J#")#

)##  PQRSTUVWXYZ[URZXRT\R\WRTUV]T^\[V\_`aPbcadSRTZSR\RVRU_`XZ\XWd[ZRUT\eZRTZfUVSd[]gWZhZ[R\XUiRZX jU_UV_kV_dSXdlRdU[bRTZ_ZdS\PcmX\`]_\lZiZ_dUXRT\RdS\WWUnZXd[U_XZ_RU]\d[lUhiWd\[lZndRTfopPage 536 of 894  





 





  
  


 





 






 



!"#$
%#
!"
$
&
'
(#!)%*
"#%
"#!&
!%
+ 
,-


 ,
. /

0

.1

2 
 ,
 -
.,
 2 


 
2 
/


  345
-
   2 

/

 
4/4

6
7 
8


4/
5
/9
,
:
:
2 
/ 4/,,



 
2  2 
4/;



2 
/<   
,


 0/1-
/ 
 2 
=


 -

2 -,
 >?7@<@
4/ =3

A 
B :
2 
/-


  
9

C
C,

,

 :


 D

/,,

 

 
2 - 
0 
1,


E 
/
 



 
F-F/ 


9 
/5- 

G

E 
<95G
E 

  
 



 ,






=


2 , -
  

 9

H
I




  
,

 
 

/  

,
4/;J3K99,
4/
-

 

 

2 


 


-,


 2 

 

 ,

,

 9

>:
 
 

L9F7B ,L
 M

-M 2
B ,L

5-
-
B ,L

2  
-

 -,



D   2 



2
 


/
2  
N

L
 

,



 ,

O

,

N

L
  
 ,


 - 


 ,
 
0KK P1P-
3

M,,
 345


,/

 -



/,,

2  -
7@
H? 







, -

 J3K9,
 



0,,
1> 




4/





/
 




 

F/ 
 




G


2
, - 
0

1- 
 
4/ 
2 
E 
  




  



E -

 


,

-





  



E  
  2 :, 


 
E 
, -




-





  


/
 2  ,,

 
  2 
4/ 

 






/
  
 J3K9
  2 Q


 , 
,  ,
7??-

 


E 
 -
7??

/7?-

 



4/ 
-






/
  -

 J3K9:, 








/
 


2 
/
4/
,/
.  2 
 -

7R?/-

/
S




9,,


/ 

,
 
-
 ,
-

 


 
N

L
4

/ :




,,
,,







/-

N

 L
  

/,

 


02


F
1
/,
  9

2 /
4/
S


/
 
 
 
  
/H
F


 
 /
N

L
 

E 
2< 2 

2 
F

/= M 


 
2 /345,



F
/


 

2 
/

, 
/
. 
 . 
/



 
/
F  
,






.


 2 


. 



 .
S

G


2


F

/,



F
/ -


  >L >>,
345B :
2 
/N .
 9

7 HL
7T,345B :
2 
/N .
 
9

7 Page 537 of 894
 


  







 


 
   




  
   








 
  



 

 

 
  

 
  
    
 
 




   
 

!
"  


 

 ! 

 

 



  
#
 
 


  

 


  



   
$ 


 

   
%"
&
 

   
  

  
 




!
 
' (


   



 

)  

!
   

 *+


,-.


  




 !
  


 *+- 
 
/0
10-
 


 


 2
 
3 



 


  
4 

 
 &
  *+- 
 
/0
10-  
 


 




 !
  
5 3  ,
 /. 



)   



*+ -,  
.





 



!
 

   
 

 


 

  
+0
6/+
  

)  


  /7
 

  
 

 
   
   






!
 
  
  8!93
 

 '

 
$  5,5
!/.,

9 -:2 !; :!<
9

38  . 

 



  
 
  )



 

! 
 83=

 
 
5
!/3>

 

 






 !

 


 2
 

 





&
'

 


 





  
 





 

  



 
?@?ABCDCEFGHDCID@JKE@D@JL?M?LDIB
 



  
>83=
 

 4  

   



 

)  

  
7
 83=

 /
&  7
 83=


 

(



 83=

  
 



  

  



 
 



 
 






 


 

: '
 ,
:'. 
 %$     :  "
 



(1*%N$ 
1++%


    

  Page 538 of 894
 







 

 !
"# "$% &'() *(+ ,
"#,"$% '-./() "#"$ /-.0() +'+ #$ 0-.-+() +*1 23#
$ 4-+() 5*- -6/++789:; 
<8=>?;9;@ABC9;:98DEF=;G>98GH@898DI=J=K9:? L8@MNGM:@JM@O9NG=K@PJMGQG8;9OG=8=>?;9;@A:QGI9:?R;GC9;:98DS@898DK=J=K9:?6;:=AAQ=; T:9>9SGN:QGA@>>@U98DK@PJ@8G8:;:@=NNMG;;:QGI9:?R;5:QI?K>GVWX<6N9;KT;;GN98ATM:QGM NG:=9>YG>@UZ  [\]^_]`abc^]dc`_]efgh`]`a iQ9;98K>TNG;J=MKG>;S@8GNA@MMG;9NG8:9=>T;G;U9:QK=J=K9:?:@=NN8GUQ@T;98DT89:;U9:Q98 :QGI9:?R;;98D>G.A=P9>?=8NPT>:9.A=P9>?MG;9NG8:9=>S@898DN9;:M9K:;Z<>:Q@TDQ=>>O=K=8:@M T8NGMT:9>9SGNJ=MKG>;:Q=:KTMMG8:>?P=98:=98S@898D@MDG8GM=>J>=8NG;9D8=:9@8;:Q=:=>>@U MG;9NG8:9=>NGOG>@JPG8:P=?YG98K>TNGNU9:Q98:QG98OG8:@M?6;:=AAMGK@PPG8N;:Q=::QGA@KT; YG@8;9:G;:Q=:K=8=KK@PP@N=:G:QG>=MDG;:=P@T8:@AYG>@UP=MjG:M=:GQ@T;98D=::QG Q9DQG;:NG8;9:9G;ZiQGMGA@MG68@:=>>MG;9NG8:9=>>?S@8GN;9:G;U9>>8GGN:@YG>9;:GN@8:QGA98=> 98OG8:@M?Z<P=J@A=>>J=MKG>;U9:Q=DG8GM=>J>=8NG;9D8=:9@8:Q=:=>>@U;A@MMG;9NG8:9=> NGOG>@JPG8:kGCK>TN98Dl<.-=8NmJGK9A9Kl>=8=MG=;=;8@:GN=Y@OGn9;98K>TNGNA@MMGAGMG8KGZ  oepeq]_r]`[\]^_]`aspcq]t]qufe`^ iQ9;98K>TNG;O=K=8:@MT8NGMT:9>9SGNJ=MKG>;U9:Q98:QGl<.-mJGK9A9Kl>=8/:Q=:=>>@UA@M MG;9NG8:9=>NGOG>@JPG8:U9:QK=J=K9:?:@=NN8GUQ@T;98DT89:;Z  u]pcf]`cuvhwcq_^ l9JG>98GlM@xGK:;=MGNGA98GN=;MG;9NG8:9=>JM@xGK:;=>MG=N?G8:9:>GN6T8NGMMGO9GU6@MGCJGK:GN :@YGG8:9:>GNNTM98D:QGG9DQ:?G=MJ>=8898DJGM9@N698K>TN98DJM@xGK:;T8NGMK@8;:MTK:9@8YT: UQ9KQU@T>N8@:Q=OGYT9>N98DJGMP9:;A98=>GNY?yT8G'(6+(++Z5iQ9;98K>TNG;8GUJM@J@;GN JM@xGK:;:@YG=JJM@OGNT8NGM:QGI9:?R;MGO9;GN<AA@MN=Y>GW@T;98DzMN98=8KGZ<>:Q@TDQWI{ =>>@U;l9JG>98GlM@xGK:;:@98K>TNGJM@xGK:;KTMMG8:>?T8NGMMGO9GU6;:=AAQ=;@8>?98K>TNGN G8:9:>GNJM@xGK:;:Q=:Q=OGMGKG9OGNI9:?=JJM@O=>Z  |}~uvhdq_]h` WI{Q=;9;;TGN=NG:GMP98=:9@8:@=>>@U>@K=>xTM9;N9K:9@8;:@€K@T8:<{7JM@NTK:9@8=;= K@PJ@8G8:@A:QG;9:G;98OG8:@M?Y=;GN@8=A@MPT>=:Q=:K@8;9NGM;:QG=OGM=DG=88T=>8TPYGM @A<{7JGMP9:;9;;TGN98:QGI9:?@OGM:QG>=;::QMGG?G=M;6PT>:9J>9GN@OGM:QGW@T;98D B>GPG8:R;G9DQ:.?G=MJ>=8898DJGM9@NZL8+(-‚:QGI9:?9;;TGN898GJGMP9:;698+(+(:QGI9:? 9;;TGN+(JGMP9:;6=8N98+(+-:QGI9:?9;;TGN-5ZL8:QGA9M;:;9CP@8:Q;@A+(++6:QGI9:?Q=; @8>?9;;TGN+8GU<{7JGMP9:;Zm98KG:QGI9:?Q=;8@:YGG8=Y>G:@;Q@U:Q=::QGMG9;KTMMG8:>? =8TJU=MN:MG8N98<{7JM@NTK:9@86:QG=OGM=DGAM@P+(-‚6+(+(6=8N+(+-U@T>N8GGN:@YG  /B;:9P=:GNK=J=K9:?U9:Q98l<.-9;Y=;GN@8NM=A:MGO9;9@8;:Q=::QGl>=8898DI@PP9;;9@8MGK@PPG8NGN A@MI9:?I@T8K9>=JJM@O=>@8yT8G+-6+(++6UQ9KQU9>>YGMGO9GUGNY?:QGI9:?I@T8K9>98yT>?+(++Z 
5iQGW@T;98DB>GPG8:5:QVWX<I?K>GMGJ@M:98DJGM9@N:GKQ89K=>>?YGD98;@8yT>?-6+(++6PG=898D:Q=: T89:;A@MUQ9KQYT9>N98DJGMP9:;=MGA98=>GNk9ZGZ6=JJM@OGNA@M@KKTJ=8K?n@8@M=A:GM:Q9;N=:G6K=8YG 98K>TNGN98:QG+(+'.+('-98OG8:@M?Z Page 539 of 894  
 











  
 

  
  

!
"#$% 
  
##







&#  








#

'
 

"#$%   (


'


'% 



 









)
*+,

  
# 
 '
-

*
 
  
'%*
'
 







 -%. '


  /%




 


*

'
 #


'



 
#
0!12 3 4/
#*!124/
#*!125 
/
#*12'
5 
/
# 6$
 
 

 '


' 7 
8 




 
#


8 
#

*

''



 


'9 
:;<=>?@ABCC;DEFGHDFI>JK>LMNOHDFLBJKPFQ<EMGGFDL;<P=PKE RQJFC>S;K>TFDE MUMVMGGFDL;<P=PKE MWWBCXKPFQW HDFI>JK>LMNOHDFLBJKPFQ Y>DEZF[RQJFC>\YZR] !12 ^1 ZF[RQJFC>\ZR] !12 ^ _FL>D;K>RQJFC>\_R] !12 ^1 M<F`>a_FL>D;K>RQJFC>\M_R] 12 ^ :FK;=! 
 
#





'







 
  
 


 #

  


#



 #' #'





 ##'
  

  
b
/

  '
#

b

 

 

 
 
 *
  
$8


*




*




 '8








##



-%. 
'

 #' *
-%.


  * 


 # 


   '!'## 8
 













#


'




  


#




c
 *





'  '
#



   




b
/

  '
#

b

  

 

.
'*

#' 


 
' 













 , d8  
* 
 
 


' 

#





-%.



 

 











  
 !" #

!" #
$

" #

% $

" #

& '('"'()
  *(' '' '*+ ,*) )-..' 



&

/0
1
 23456789:;336<8=>?< 8@62?A6=?<6 BCDEEDEF
23456786GHIJ 234G;78?4< FCKLLKLMN




 ..' '(, "" **O
2HPLQR<<4ST8?4< :6<863U """""" BVBBB WT7T<8X69?G6<8?T= YT<G """""" LVEBB & Z' *) OZ( *-O*+ [;\\63]^TA PF_` PFMaN` LNM` MLD` 
#$
bc/ccbde /b&
#
fbd#

/ H88@6g;<6LVBCBBg4?<8h43i9@4AV74<763<9j636T=943T?96Gk;698?4<?<lj@68@638@6:?8> 74;=G?<7=;G6A3456786GT\\43GTm=6;<?898@T8nT>m6lT?<6G\34n=4jG6<9?8>@4;9?<l G6S6=4An6<89T9AT384\8@6:?8>o9;AGT86GH\\43GTm=6p4;9?<lq3G?<T<76ah@?=6?8nT>966n 74;<863?<8;?8?S6Vp:IG469<48A63n?8T\\43GTm=6;<?8936k;?36G8@34;l@8@6:?8>o9H\\43GTm=6 p4;9?<lq3G?<T<7684m674;<86GT9rA3456786Gs;<?89?<8@6t?869R<S6<843>;<=6998@6>T36 A34A496G43TAA34S6GT9AT384\T9A67?\?7@4;9?<lG6S6=4An6<8au@696;<?89T36v@4j6S63V Tm=684m674;<86G84jT3G8@6:?8>o9XpwH4<76TA345678?9TAA34S6Gm>8@6:?8>aH7743G?<l84 p:Io9xyz{|}~€‚}ƒ„|ƒ }†}ƒy‡ˆ‰z|Š‹yyŒQBCBCUQH88T7@n6<8LU 
u@6T<T=>9?94\ŽTAA34A3?T864<?<lo9@4;=G<48?<7=;G6369?G6<8?T=m;?=G4;8A345678?4<9 369;=8?<l\34n8@6?nA=6n6<8T8?4<4\T5;3?9G?78?4<o9?<7=;9?4<T3>A34l3Tn43A486<8?T= ?<736T96?<G6<9?8>G;684TG6<9?8>m4<;9Vm67T;968@696844=9T36<48T9;m98?8;86\43 TGG3699?<lj@68@638@6;<G63=?<?<lQmT96U4<?<lG6<9?8?69T36TAA34A3?T8684 T774nn4GT868@6XpwH\43=4j63?<74n6@4;96@4=G9a  u@636T367;336<8=>TAA34?nT8?S6=>LC369?G6<8?T=G6S6=4An6<89;<G6336S?6jj?8@T848T=4\ EMM;<?897;336<8=>A34A496GaR\T==4\8@696A3456789j636TAA34S6GT97;336<8=>A34A496GV 8@6:?8>j4;=GlT?<T<TGG?8?4<T=LN=4jPT<GS63>P=4j?<74n6;<?89T<GMDn4G63T86 ?<74n6;<?89aH9<486GTm4S6VT=8@4;l@8@696A3456789T367;336<8=>;<G6336S?6jT<GT36 6=?l?m=684m6?<7=;G6GT92?A6=?<623456789V98T\\@T94<=>?<7=;G6G6<8?8=6GA34567898@T8 @TS63676?S6G:?8>TAA34ST=T92?A6=?<623456789a  q<g;<6BLVBCBBV8@62=T<<?<l:4nn?99?4<3674nn6<G6G7@T<l69848@6:?8>o9H\\43GTm=6 p4;9?<lq3G?<T<768436k;?36TLM`T\\43GTm=6@4;9?<l4m=?lT8?4<\434j<639@?AT<G36<8T= A3456789QM`W63>Y4j]K`Y4j]E`‘4G63T86Uau@6>T=943674nn6<G6G7@T<l6984=?n?88@6 4A8?4<84AT>T\66?<=?6;4\74<983;78?<l8@636k;?36G;<?8984369?G6<8?T=G6S6=4An6<894\NPD ;<?89VT<G36n4S?<l8@6?<=?6;AT>n6<84A8?4<\439?<l=6P\Tn?=>369?G6<8?T=G6S6=4An6<84\LC43 n436;<?89au@6A34A496G7@T<l69T3686<8T8?S6=>97@6G;=6G84m6A3696<86G848@6:?8>:4;<7?= 4<g;=>LBVBCBB\4336S?6jT<GTG4A8?4<a 










 

 


!!"#
$%&'(&)*'+ $,+ '-&)..'

')/'% "$ ) %0)
'-1+.2"$ "#)*

 $
*#'"'))!%
'

# -'
 $ "#+'.' #(  +(
'
% 
%)/$% %&'(%
)-%
'
).%&'(3
4056)7+'- ')/'%) % 8'-)#9) (" #*+
:;%'
'
 %'-%+(
 +")
'')!)#*)..''
'%
'<% %)
'-+.*(*+:=* 
%4056!)#.)
*)..''
%
'*#
$
'-'!'* +( *)." #$/'%%!'!%*(*+.)
$)#9)
7
' + #
 %'-%#$
''
:>)# '
*%) +
'<%*(*+4056!)#? #'&)('
!'8'.

+ #-
'%!'!%*(*+: 
;%&'(&)*'+#8'/$%"#+'.' #(
'
# -'
'*+$'-''' +

."')
 $ $'#*$
!!)##/'% .)#$ '+$#")#)%
'
'8)#('*+$'-  *)."#%
'8$# !
'
'8)#()!8#(" #*+/% 8 '+ 7+!)##8'/:6%' .'-
"*'!'**)*#
/# +
)# '
$#- #$'-
!!3
''' +#*)..$ '))

.% 
'
 .'-%.''..$! +$
'()!@
$A *7

.$)'*+$@
B+)/'*).'
 $
B.)$# '*).'
:=
$)%'
!$7 *C
!!%
"#)8'$$ *)."#%
'8 +'
)!
'
$#*)
'$# '))7'*+$$'%$# !
'
'8)#(D  *%$!)# #!#*E $%
%#
# -'
!)#%&'(&)*'+3
#8'/ $*)
'$# '):6++%#
# -'
'*+$%
.7
+'!)#"'"+'"#)F*
 $<'
'-#
'$' +'8)#( " #*+
%)/8# *%/'++"#)8'$$'!!# !!)#$ 7'+'(

."')
 $)/'%$'!!# 6G2"#)F*')
: 
;%
# -'
"#)8'$$ #)+( 
."+)!%
# -'
 $

."')
% *)+$7 '+'9$) $$#

%&'(3
4056:;%#/'++7 )"")#'( 

/)#C
%)")
' # +'. .)$+). C !!)#$ 7'+'( $
'

."') $F
.

*

#(:6
.. #()!%%#'$'!'$
# -'
 #'*+$$'6 *%.H $7+)/'; 7+I !)++)/$7( $ '+$$' *

'))! *%: 
JKLMNOPQJPMRSTUUJQVMW  PQJPMRSX PQJPMRSY PQJPMRSZ MW[QV\PV]^ 5)49)'-4_'#$ 4$*$6!!)#$ 7'+'( /'%`*# $6G2 6

."')
 
5)49)'-4_'#$ 0&G6""#)8$ ?%)$)+)-( 5)49)'-4_'#$ 0&G6""#)8$ ?%)$)+)-(/'% &) #8 '8 6!!)#$ 7'+'( 6

."')
 ab
cWT\\]QPMd 5) e
 e

ff]QdJKVLVPS
WWTU\PV]^Wg
Bh)/ $i#( h)/ $jB?)$# 


Bh)/ $i#( h)/ $

B ?)$#  @
Bh)/ $i#( h)/ $
B ?)$# 
ff]QdJKLM^VP ]PM^PVJL ihAhkj@H'
 ?)$k
jI'
 6?)$kIl@'
 ;) +kH
l
'
 ihAhk
@
'
 ?)$klH'
 6?)$kmmH'
 ;) +kInIm'
 ihAhkmHH'
 ?)$k@Im'
 6?)$kI
H'
 ;) +kInIm'
 TffMQ
Bh)/Ai#(h)/ m ?)$# o $ HH@B67)8?)$#  jjBh)/Ai#(h)/
IH ?)$# o $ mm 67)8?)$#  nBh)/Ai#(h)/ I ?)$# o $ H

B67)8?)$#  ]]P]WW U\LV[JPV]^W 0'-%+(+'C+()#'--# )+)

 h
+'C+()#'--#) +)

 ?)#+'C+(% 
p# -(
)#'--#) +)

 q6!!)#$ 7'+'(

."')
 #7
$)%
'
'8)#(/'%%

."')% 
'
%  ++)/@
$A *D$! +$
'(E)# .)#*  **)..)$ * " *'(!)#+)/#o'*).'  $
'
%  ++)/H)
H$A **  **)..)$ * " *'(!)# .)$# o'*).' : Page 542 of 894






















 















 !


"










#
 
$
$



 








 
#

#




$
 
 




 


%&'(&')&*'







+


 









'






,




-

 !


"








 ./'











 #
 0


1




2 

 



























  
3456789:;;<=>45?6?@A4B>C7;4D6@C7BE?@?7E5AF7B7=46G64BC7E?HB4@?<B C7BE?@AI4@7H<=A C7BE?@AJ4BH7 KBL<M7N7O76G<@7B@?466A :LL<MM<>4@7>?BKBO7B@<=A    #
PQ  Q  R
 S@=4@7HAT:;;<=>45?6?@A:EEDMU@?<BE R
PQ



V"1W
 "XX&  




"1Y1W
 ZX& )& 
[




\XW
 )X& )& "& S@=4@7HA]:;;<=>45?6?@A:EEDMU@?<BE R PQ



 V"1W
 "XX&  




 "1Y1W
 X& "XX& 
[




\XW
 X& X& "XX& S@=4@7HA^:;;<=>45?6?@A:EEDMU@?<BE R PQ



V"1W
 "XX&  




"1Y1W
 ZX& X& 
[




\XW
 )X& "X& X& 
S@=4@7HAT9

 




_


.
 `ab`ccdefghijc 






 '


. ,





#
 

#

  ,

#


klP


_ 








'






-










#
'




 










 
 


 









#
2 



.  






m n 



#
.

$




o n
P
 #
.





 ,






#

 



  ,
o n 
. 

'







 o
 n
k


 

 #

.









 #


 


#

  
_




 

'






-





,

 









#



 



 $











  


$.
p.




 



#
 




 

 0
 



-





 

#



 


 Page 543 of 894
 










 


  


 

 





 


!
 


 

 !
"



 



!


#
$  

 


 
 
%



 ! 



 &

  



 


   







 


 
 
!



#

 

!

 





 


 
 
 
'  





 







#




 #

  


()
 
!
#    #*
 




 







# 


 

!



 








!
 
!  


 

!
!  


*
+
 % , !

#


!

#


!




-



 
 $
 













!  


# 
   

#


 




 

!#
!.
#
/ 
012345678991:;<=>:<?4@A4BCDE>:<B8@AF<G2;C==<:B12F3FA; HG@<94I1A4J<:;  CKCL C==<:B12F3FA; CMM89NAF<GM O:FJFG13CDE >:<B8@AF<GM HG@:41M4BCDE >:<B8@AF<GM P4:;Q<RHG@<94SPQHT ()U V)W) Q<RHG@<94SQHT ()U VXW" Y<B4:1A4HG@<94SYHT ()U V)W) C2<Z4[Y<B4:1A4HG@<94 SCYHT X)U XV"W 0<A13X(\
 "])
 
^_`abcdefgh^_`aifcj_khlmmngdbo_p_khljjqrsk_ncj  

 
%
 X




"]U

#

 tuU

!v X"U
!v 
/U 
 v 
w



 
  

 
()x
.



!
# 
#
!


 $ 







#
*
y
 #!

  







#   



 !




z*{ $  
*!
 


 


 !
# 


 

#



' 



 


 # 


 


 

!
#    
  !

#

 
.
#
]#
!

'








 -

 


  


'%
 X




%
 X!





!   

!

!

 
'   # 

!  
 | 

 




  









 !



" !



 #$#%
#$%&'(  )$# #%# #) *) +,,#

-!
./0 123456789:225;7<=>;7?5 1>@5<>;5 ABCDD CDE 12345675FGHI123F:67>3;JDAEJAK AKB & (! ) **

 %) 1GLJMN;;3OP7>3;95;752QRKK JRR JSKJA ASAAA TP6P;7U58>F5;7>P<VP;FCW XB JSWKE JSDAA
-Y*%, #*) )+Z% ,+$Z#
I;>78[\LP;F]:^^52\_P@` 
+$a 
+a%+,)#
+ ,,%a %+Z))
+ ##a 
bcdefghijklmjnopqorstu72P75v=J N^u72P75v=J>86?385;S;325w3;>;vx3:<Fy525z:>25FP;FP<7?3:v?P^^32FPy><>7=P88:{@7>3;8 x3:<Fy5{3F>^>5FSP<<F5;8>7=P88:{@7>3;8x3:<F63;7>;:573y5yP85F3;5|>87>;v_5;52P< 1<P;F58>v;P7>3;8P;F7?525^3257?5}3:8>;v~<5{5;7I@FP75{P=y55|5{@7^23{9~GS @:28:P;773u567>3;JXBDJMyQMRQ3^7?5u7P759~G_:>F5<>;58S8>{><P273u72P75v=JP;FA€ 


# 3U5w3;>;vU5z:>25FS}9HG@@23O5F‚57?3F3<3v= u72P75v=A:7><>w587?5@25<>{>;P2=P;P<=8>83^U}GP;F8>75872P75v>58P8@2585;75F>;7?5}9H _:>F5y33ƒ€]P85F3;}9Hv:>F5<>;58S7?59>7={P={Pƒ5P88:{@7>3;8:@73JBB`<3x52L >;63{5P^^32FPy><>7=^32P<<8>758P<<3x>;vRBF:\P632{325SP;FJBB`{3F52P75L>;63{5 P^^32FPy><>7=^32P<<8>758P<<3x>;vy57x55;JXLAXF:\P6€G<7?3:v?:7><>w>;v7?>8P@@23P6?x3:<F 25z:>25PFF>7>3;P<P;P<=8>8P;F4:87>^>6P7>3;3^7?58>758F58>v;P75F^32<3x52>;63{5?3:8>;vS7?>8 >87?57=@>6P<P88:{@7>3;7?P7{38763{{:;>7>58>;9P<>^32;>P?PO5:85F€I7><>w>;v7?>8{57?3F x3:<FP<83@23O>F57?59>7=x>7?7?5<P2v587y:^^52>;7?5O52=<3xLP;F<3xL>;63{56P75v32>58€  „Py<5Ey5<3x8:{{P2>w587?5258:<783^>;>7>P<5OP<:P7>3;3^5|>87>;v258>F5;7>P<F5O5<3@{5;7 6P@P6>7=:7><>w>;vu72P75v=A6P@P6>7=P88:{@7>3;8€u72P75v=Ax3:<F258:<7>;7?5^3<<3x>;v @2345675F6P@P6>7=x?>6?x3:<F>;6<:F5P<P2v5y:^^52>;5P6?>;63{56P75v32=  





 







!" 

# !" 

 $%$%&'()  *$ % *+ ,*& &-.. /"012 3456789:;<447=9>?@= 9A73@B7>@=7 CDEFFEFG 34567897HIJK 345H<89@5= GDLMMLMNO ' )" .. $,  **P 3IQMRS==5TU9@5= ;7=974V MWXENLCEDCWCCC YU8U=9Z7:@H7=9@U> [U=H LLFNGMXEOMWFCC /\ -%& .& &-++. *-P*+ K=@9:]^QU=H _<``74^aUBb &-, + -,,c ,$*
- *.c &-&%*
- &++c %- **
- &Pc 
d94U97e?C85<>HU>:5f7B45B5:7Hg@9A`7g74:@97:U=HU:hU>>74f<``74WU>9A5<eA9A@:g5<>Hf7 h547>@i7>?9594@ee74=5=79>5::jS`9AU9588<447HWA5g7T74W9A7;@9?g5<>Hf7Uf>795hUi7U `@=H@=e9AU9UHH@9@5=U>B45B74>?k5=7H:@97:U47UTU@>Uf>7@=9A7;@9?j  lmnopqrstuvwtxyz{y|}~w~vw}€‚ S`d94U97e?C@:8A5:7=W=547k5=@=eg5<>Hf747ƒ<@47HU=HU>>H7=:@9?U::<hB9@5=:g5<>Hf7 fU:7H5=7„@:9@=ea7=74U>3>U=H7:@e=U9@5=:
9A747`547W9A7†5<:@=e‡>7h7=9KBHU97g5<>Hf7 7„7hB9`45h;‡ˆI47T@7gWB<4:<U=995d789@5=MODFMRfVRNV5`9A7d9U97;‡ˆIa<@H7>@=7:W gA@8AB45T@H7:9AU9UB456789@:7„7hB9`45h;‡ˆI@`9A7U89@T@9?@:85T747Hf?9A785hh5= :7=:77„7hB9@5=9AU9;‡ˆIUBB>@7:5=>?95B456789:gA@8AAUT79A7B597=9@U>`548U<:@=eU :@e=@`@8U=97``7895=9A77=T@45=h7=9j†5g7T74W†;JhU?47ƒ<@479AU959A74B45e4Uh:f7 @=8><H7H9AU985<>H47ƒ<@47UHH@9@5=U>;‡ˆI47T@7gj 

%
‰5Z7k5=@=eZ7ƒ<@47HW†;JIBB45T7HŠ79A5H5>5e?g@9A;5=:74TU9@T7I``54HUf@>@9? I::<hB9@5=:  d94U97e?N<9@>@k7:9A7B47>@h@=U4?U=U>?:@:5`Z†‰IU=H:@97::94U97e@7:U:B47:7=97H@=9A7 @=@9@U>:789@5=:5`9A@:47B549jI::9U97HUf5T7WfU:7H5=†;Je<@H7>@=7:9A7;@9?hU?hUi7 U::<hB9@5=:<B95MDDb>5g74Q@=85h7U``54HUf@>@9?`54U>>:@97:U>>5g@=eNDH<^U854h547WU=H MDDbh5H74U97Q@=85h7U``54HUf@>@9?`54U>>:@97:U>>5g@=e<B95CDH<^U8j†5g7T74WUh547 85=:74TU9@T7U::<hB9@5=g5<>HB456789NDb>5gQ@=85h7U``54HUf@>@9?U=HMDbh5H74U97Q@=85h7 U``54HUf@>@9?`54T74?A@eAQH7=:@9?:@97:U=HNDbh5H74U97Q@=85h7U``54HUf@>@9?`54A@eAQH7=:@9? :@97:jd@=87=59U>>:@97:U47>@i7>?95H7T7>5BU97T7=9A@:>7T7>5`U``54HUf@>@9?W9A7;@9?g5<>H =77H958U47`<>>?h5=@954H7T7>5Bh7=9957=:<479AU9@9479U@=:UH7ƒ<U97:@97:U9U>>9@h7:`549A7 >5g74U=Hh5H74U97@=85h78U97e54@7:j_78U<:77U8A:@97g5<>Hf7B4567897H95AUT7`7g74 U``54HUf>7<=@9:W9A7;@9?g5<>Hf7h547>@i7>?95=77H95h5H@`?U::<hB9@5=:54<Bk5=7 UHH@9@5=U>:@97:>U974@=9A7B>U==@=eB74@5HjIMDDbU``54HUf>7A5<:@=eH7T7>5Bh7=9g5<>H e47U9>?U::@:9@=h779@=e9A7;@9?‹:Z†‰Ij 

 














 



















 






! "





# 
$%&'()*+,--%./01+2.%2(3/45%6%782/9:%'/;8;  <(./=0>? @:70-( =0>? @:70-(A0B(.%2(? @:70-(
9&0C( A0B(.%2(? @:70-(
$02%' DED4?DE4FGHI9 9''07%280: JED D4D DJK LJF FMNND +2.%2(3/45%6%782/O:B(.PQ8;28:3R0:8:3 S 
T

 S UV WW WX S
YZ[ S


 XV\!!\!
] G(-%8:8:3I((B NND DEL ?? JJ) SY^!_`

 Ta ]
UU
!b\WVUbUUU cd
 e !
\X
!b\V]!bWUU $02%'O:82f02(:28%' KNN 4JK 4MgJN JM)JK [ hi^ j
ik" FDF,:82;MF)l FEE,:82;M JEl 4MDEJ,:82;M NEEl 4MgJJ,:82;M DF)l  mnopqrstuvwxuyz{|z}~€xwx~‚ƒ `





b



„








 


kS




b†

‡[

 
T‡ˆYb





!]VW!_a_
a

T‡ˆYk

b
 




T‡ˆY







 
T‡ˆY











 

†

b†TZ
„




 

„

T‡ˆY
 
IP‰$+$Pf+ Y

b







†

‡ [


Š



b








 














 

T
‹
d†ŒYj








 


b






!bUb
Y










 








  
 






 





  
!

"
#!



$

%



 !

!
%&'()

*

+
%
%



 
,"
!



!
!( 
*



%-

%







!


!



! 
!

!



  

(.

!

/ 
0*





"

!

 
(.
 
!!

 1
 

!


23


(4!






 
 


%









&& !
%



( 
0&


5

!6

%'
" 

)


 %












7 







  

!




7 

 




8
 ! 8



9 



!



(.


!















& & !

5
&

4  



&'( 
:;<:=>?@;<
.

%




!


 

)


 



&& !





!%!





 













(*
!



& & !


%
! 

!



!!


 

)


6A4 








!%!







 %
%

!





!

%

 

( 
4!

 (&'*

B 

- (6



B


5
C
 ('*


9!
*

 D('*

C
 2(*
"*
4
.

 3(2&!

 

*

4
 (C
"1

*

(*

"1

*

EFGH EIJKLMFJK
&& !
N-
 
 5

5

!6

%'4   && !

5
&

C

O 5

!6

%' 4   


6

%&


P1

!-
C-
 6


*



 1&'*


 C
"*



 6


&'&


6
C
"'
!

 
*

' 

&' 1

  6


&'&


6
4

 
*

' 

&'

 C &'Q

*

&

!
C 4

5

!
 C

Brentwood 2023-2031 Housing Element
Appendix C: Summary of Community Engagement C-10
C.5 City Council and Community Meeting
This section contains all materials created for the August 30, 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/.

2023-2031 Housing Element Update
City Council and Community Meeting
The City of Brentwood is currently updating its 2023-2031 Housing Element and has released the Public Review Draft. Please join us to learn about the different parts of the draft document as well as how you can provide feedback during the public review period.

When: Tuesday August 30, 2022 at 6:00PM
Where: Zoom - www.brentwoodca.gov/vcc
To view the Public Review Draft Housing Element
and provide feedback, please scan the QR Code or
click the link below:
https://brentwoodhousingelement.com/resources/

Actualización del Elemento de Vivienda 2023-2031
Reunión del Concejo Municipal y la Comunidad
La ciudad de Brentwood se está preparando para publicar el Borrador de Revisión Pública del Elemento de Vivienda 2023-2031. Únase a nosotros en un taller virtual para aprender sobre las diferentes partes del borrador del documento y cómo puede proporcionar comentarios durante el período de revisión pública.

Cuándo: Martes, 30 de agosto de 2022 a las 6:00PM
Dónde: Zoom - www.brentwoodca.gov/vcc
Para ver el Borrador de Revisión Pública del Elemento
de Vivienda y envíe sus comentarios, escanee el código
QR o conéctese a:
https://brentwoodhousingelement.com/resources/

AUGUST 30, 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 meeting, and will be summarized in the meeting minutes. The City cannot guarantee that its

AUGUST 30, 2022

SPECIAL CITY COUNCIL AGENDA
PAGE 2 OF 2
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 AUGUST 30, 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 the 2023-2031 (6th Cycle) Housing Element Update Public Review Draft. (Alexis Morris/Jennifer Hagen)

ADJOURNMENT

POSTING STATEMENT
On August __, 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

CITY COUNCIL AGENDA ITEM A
Meeting Date: August 30, 2022
Subject Title: Introduction of the 2023-2031 Housing Element Update Public Review Draft Prepared By: Jennifer Hagen, Senior Planner
Submitted By: Alexis Morris, Community Development Director Erik Nolthenius, Planning Manager

PURPOSE AND RECOMMENDATION
The City formally initiated the 6th Cycle (2023-2031) Housing Element Update process in October 2021 with substantive public meetings beginning in April. Since then, there have been a number of public meetings and outreach events to review key components of the Housing Element Update. Public input provided at these meetings, along with feedback from the Planning Commission and direction from the City Council, has been incorporated into the Public Review Draft Housing Element (“Draft Housing Element”) introduced in this report. The Draft Housing Element will be available for public review and input from August 25 through September 27.

Tonight, staff is presenting the City Council and the community with an introduction to the Public Review Draft Housing Element (Attachment B), including an overview of the Housing Element Update process and timeline, and instructions on how the public can provide comments and participate in the upcoming public outreach. No action or direction is requested at this time. The City is conducting tonight’s City Council workshop in order to introduce the Public Review Draft Housing Element and to facilitate public comment. Other opportunities for public comment will include a Planning Commission meeting on September 20, and a City Council meeting on September 27. In addition, comments can be sent to staff at any time during the public review period, via the project website, email, or traditional mail correspondence.

PREVIOUS ACTION
The City Council authorized execution of an agreement with Kimley-Horn for consulting services 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 a status report 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 to the City Council and Planning Commission. The City Council directed staff to return with a draft site inventory for review.

On July 21, 2022, staff presented a draft site inventory with an introduction of the analysis of existing residential zoning capacity within the city, as well as an evaluation of site inventory and affordability assumption strategies needed to address the City’s RHNA. The City Council directed staff to move forward with drafting a Housing Element Public Review Draft that reduced buffers

2 within the draft sites inventory to 15%-20%, added policies incentivizing ADU production, and added policies encouraging development on City-owned parcels.

On August 15, 2022, staff presented a revised site inventory to the City Council’s Land Use and Development Committee (LUD) as well as a status report on the Housing Element Update. Staff requested that LUD provide any additional input on the Housing Element Update, including affirmation of staff’s approach to the draft sites inventory. Staff received input and has now completed the Housing Element Public Review Draft.

DISCUSSION
What is a Housing Element?
The Housing Element is one of seven State- 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 provides a vehicle for 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 20231, 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 (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 ensure compliance with the variety of complex housing laws.

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,” is 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.

Public Review Draft Housing Element Review Process
The Draft Housing Element in circulation has been prepared to reflect the feedback and public process to date and is available for public review from August 25 through September 27. The City Council is hosting tonight’s special meeting in order to introduce the Draft Housing Element and to facilitate public comment. Other opportunities for public engagement include a Planning Commission meeting on September 20 and a City Council meeting on September 272.  1 It should be noted that although January 31, 2023 is the statutory deadline to have the Housing Element adopted for Brentwood, there is a 120-day “grace period” that is allowed in order to gain HCD’s finding of compliance or certification.
2 Due to newly imposed requirements under AB 215, the State’s new shortened timeline prevents the City from circulating the draft Housing Element to the City Council for comment before it is released to the public. However, the new law does allow publication of the Housing Element for public review concurrent with Planning Commission and City Council review.

3 Additionally, public comments are encouraged to be submitted to staff via the project website (https://brentwoodhousingelement.com) through a designated Public Review Draft housing Element Feedback Form, which has been attached for reference. In addition to our Public Review feedback form, comments may also be submitted by email or traditional mail correspondence.

Following the public review period, staff and the professional services team (Kimley-Horn) will implement revisions as necessary to the Draft Housing Element, prior to submittal to HCD.

All public and Planning Commission feedback received during the 30-day review period will be reported to the City Council at its meeting on September 27. If recommended by the City Council at its meeting, the document will be submitted to HCD in October, after the required 10-day response period, for HCD’s compulsory review, incorporating any revisions necessary and/or recommended by the City Council. HCD will have 90 days to review and comment on the draft document. After HCD's review period, ending in mid-January, staff will incorporate HCD's comments into another draft of the Housing Element. Additionally, staff and Kimley-Horn are preparing environmental documents to be reviewed with the final draft on the Housing Element in 2023. The updated Housing Element would then be re-submitted to HCD for a further review (30- 60 days) during the first quarter of 2023, with adoption anticipated in spring of 2023.

What Are the Components of the Draft Housing Element?
State law defines the required contents of the Housing Element, with key components that can be found in the following four principal sections and four appendices:

Section 1: Introduction – This section contains a summary of the content, organization, and statutory considerations of the Housing Element.

Section 2: Community Profile – This section contains an analysis of the City’s population, household and employment base, and the characteristics of the housing stock.

Section 3: Housing Constraints, Resources, and Fair Housing – This section examines governmental and nongovernmental constraints on production, maintenance, and affordability of housing, and provides a summary of housing resources, including sites identification and funding and financial considerations, as well as the Affirmatively Furthering Fair Housing (AFFH) section.

Section 4: Housing Plan – This section addresses the City’s identified housing needs, including housing goals, policies, and programs.

Appendix A: Review of Past Performance – This section reviews the 5th Cycle Housing Element update goals and policies, and provides analysis of the City’s efforts with respect to achieving those goals, and considers whether the previous goals and policies should be deleted, carried forward, or modified as part of the new update.

Appendix B: Candidate Sites Analysis – This section includes the draft sites inventory and analyzes the City’s ability to meet current RHNA goals in each income category.

Appendix C: Summary of Community Engagement – This section provides a summary of the public outreach that has been undertaken since the start of the Housing Element Update process and will continue to be updated until the adoption of the Housing Element.

Appendix D: Glossary of Housing Terms – This section provides a comprehensive glossary of all of the acronyms and terms used throughout the Housing Element.

Staff and Kimley-Horn have verified, in accordance with the HCD Housing Element Completeness Checklist, that the Draft Housing Element, included in Attachment A, is reflective of the various

4 State requirements and the public process to date. Below is a detailed summary of each of the relevant sections and appendices to assist with review of the document.

Section 2 – Community Profile: The Community Profile establishes the foundation for understanding Brentwood’s housing needs. It analyzes a range of demographic, economic, and housing-related variables that help define the extent and context of the city's housing-related needs. As illustrated in Figure 1 below, the Community Profile includes an analysis of the city's population, special needs groups, employment, housing stock, and housing affordability.

Information in this section provides a basis from which to build housing goals, policies, and programs to address those needs.

Figure 1: Community Profile

5 Section 3 - Housing Constraints, Resources, and Fair Housing: Analyzes and recommends remedies for existing and potential governmental, nongovernmental, and environmental barriers to housing development. In addition, this section also includes the required Affirmatively Furthering Fair Housing (AFFH) section. Figure 2 illustrates these components, as addressed in this section.

Figure 2: Housing Constraints, Resources, and Fair Housing AFFH is a new requirement for the 6th Cycle and is included per the requirements of a 2018 State law (AB 686). AB 686 requires the Housing Element to comprehensively analyze and address patterns of exclusion and segregation (looking both locally and regionally), and to identify meaningful actions and strategies to address those issues and their "contributing factors." The exhaustive AFFH analysis reflects detailed guidance provided by HCD, as well as best practices from other regions that have already gone through HCD review and certification. The analysis relies on both approved data sets, as well as local knowledge and community input. The analysis includes the following:

• A summary of fair housing outreach and capacity that includes all economic segments of the community;
• An assessment of fair housing issues, including integration and segregation patterns, racially or ethnically concentrated areas of poverty, disparities in access to opportunity, and disproportionate housing needs for all identified populations. Many of the key issues reflect those identified more generally in the housing needs assessment, including overpayment for housing, particularly among renters, and lack of affordability that is most acute for the lower-wage workforce, the disabled, and seniors. Geographically, the area east of Brentwood Boulevard is identified as an area where there may be a greater risk for displacement of existing renters and lower-income residents. Lack of access to fair

6 housing resources, especially for those that do not speak English as a primary language, was further identified as a contributing factor in fair housing issues; • An evaluation of whether the Housing Element's sites inventory improves or exacerbates conditions for fair housing. The analysis concludes that the sites inventory would not worsen fair housing conditions;
• The identification and prioritization of contributing factors related to fair housing issues.

Some of the key contributing factors to fair housing issues in Brentwood include the location and type of housing, lack of affordable, integrated housing for persons with special needs, displacement due to economic pressures, community opposition to housing over time, and lack of marketing and language access regarding housing opportunities and resources; and
• The identification of fair housing goals and actions that directly address the City's contributing factors.

Section 4: Housing Plan: The goals, policies, and programs (also called actions) are a key component in this section, representing the City's proposed "housing plan" with a focus on actionable steps and measures that the City will undertake to increase affordable housing and preserve and improve existing housing.

There are four main goals, with a corresponding set of policies and programs for each. Whereas the policies help to guide and inform future City decision-making and direction with respect to a broad range of housing-related topics, the programs provide actionable steps to implement the Housing Element's goals and to make further progress towards meeting the regional housing need allocation. Timeframes and responsibilities for each program are indicated in the text. The four main goals in the Housing Plan include the following:

H.1 - Housing Goal
Facilitate a diversity of housing opportunities to enhance the City’s living environment and to satisfy the shelter needs of all Brentwood residents.

H.2 - Affordability Goal
Encourage housing that is affordable to all socio-economic segments of Brentwood’s population.

H.3 - Equitable Distribution of Affordable Housing Goal Encourage an equitable distribution of housing for all economic groups throughout the community.

H.4 - Housing Opportunities Goal
Promote equal housing opportunities for all residents of Brentwood.

In developing the policies and programs, staff used those included in the 5th Cycle Housing Element as a starting point, carrying forward many of the same underlying themes, concepts, and ideas. However, the 6th Cycle Draft Housing Element revises and modifies some of the actions to clarify intent, improve specificity and address new State laws. (As a required component of the Housing Element, Appendix A provides a review of the 5th Cycle programs, evaluates the City's progress towards achieving the goals of the programs, and notes whether they have been continued, discontinued, or modified in the update.)

7 Although the changes are limited, for the purposes of reviewing this draft, staff has indicated the correlation between the 5th Cycle and 6th Cycle goals, policies, and programs within the body of the Draft Housing Element by noting them all as either "[NEW]" or "[5th Cycle Action X, modified/expanded]" in brackets in the text. When modified from a prior policy/program, reference is provided back to the 5th Cycle program or policy in question.

Some of the new actions/programs may be required per State law (e.g., AB 2923, AB 1397, and SB 166), some are in response to the requirement to address housing constraints, and others are in response to feedback from the public, Planning Commission, and City Council. New policies and programs are annotated in the Draft Housing Element text with “[NEW]” for reference. Among these are new policies and programs to facilitate housing production, reflecting a range of housing types, sizes, affordability levels, and tenure, and provide access to housing opportunities that meet the diverse needs of the community, including:
• Action H.1b: Support and accommodate the development of Accessory Dwelling Units (ADUs) and Junior Accessory Dwelling Units (JADUs).
• Action H.1c: Monitor the development of ADU and JADU applications, location, affordability, and other relevant features to ensure adequate ADU development. • Action H.1m: Establish written procedures to comply with California Government Code Section 65913.4, as appropriate, to comply with the requirements of Senate Bill 35 (SB 35).
• Action H.1n: Encourage residential development on sites within the Sites Inventory and maximize the development potential, as well as promote existing residential incentives and identify potential new incentives, as appropriate.
• Action H.1o: Revise the General Plan to comply with the requirements of Senate Bill 1000 (SB 1000) to incorporate environmental justice policies within the General Plan and of Senate Bill 1035 (SB 1035) to identify flood hazards and address the risk of fire hazards in the City’s Safety Element.
• Action H.1p: Adopt a replacement-housing program for units lost that are currently occupied by lower-income households or households subject to affordability requirements. • Action H.1q: Monitor housing sites to ensure adequate sites to accommodate the remaining unmet RHNA by each income category pursuant to Senate Bill 330 (SB 330). • Action H.2i: Update the Density Bonus Ordinance in compliance with State law requirements.
• Action H.4a: Affirmatively further fair housing by taking meaningful actions that foster inclusive communities free from barriers, which restrict access to opportunities, based on protected classes.
• Action H.4h: Adopt regulations and procedures that establish a ministerial approval process for low-barrier navigation centers that meet specified requirements consistent with Senate Bill 48 (SB 48).
• Action H.4i: Encourage construction and rehabilitation of housing with supportive services targeted for persons with developmental disabilities, including exploring granting regulatory incentives.
• Action H.4j: Encourage opportunities to accommodate housing that can assist with individuals' transitions from homelessness, including Single Room Occupancy units (SROs).

8 New HCD guidelines also requires that all new goals, policies, and programs are objective and quantifiable in nature. Based on these more stringent guidelines, staff has included specific quantifiable objectives into the following programs and shown in Table 1:
• Action H.1d: Monitor At-Risk Projects and develop strategies including potential expenditure of City housing funds to preserve their ongoing affordability. Housing projects are “at risk” if they are near to reverting or converting to market rate pricing. o Monitor the six units at-risk of converting to market-rate during the planning period. • Action H.1e: Encourage community education regarding the availability of rehabilitation programs.
o Assist in rehabilitating 30 housing units during the planning period. • Action H.2c: Provide a First-Time Homebuyer Assistance Program either directly or through regional partners.
o Assist 20 households during the planning period.
• Action H.2d: Explore a variety of potential financial assistance programs from both the public and private sectors to provide more affordable housing units and affordable housing assistance.
o Assist in providing assistance to 20 extremely low-, 50 very low-, and 50 lowincome units during the planning period. • Action H.4e: Encourage affordable housing developers to provide units for special needs persons or households, when feasible and appropriate.
o Seek opportunities to assist developers with providing 50 special needs units (farmworker, affordable senior, disabled, developmentally disabled, large households, female-headed household, homeless) during the planning period.

Table 1: 6th Planning Cycle Quantified Objectives
Objectives
Units by Income Level
Extremely Total Units
Low
Very
Low Low Moderate Above Moderate
RHNA 402 232 247 641 1,522
Home Repair/
Rehabilitation 30 30
Special Needs Units 50 50
First-Time
Homebuyer 15 5 0 20
Affordable Housing
Assistance 20 50 50 0 0 120
At-Risk Housing
Units 6 0 0 6
Staff has reviewed the above-mentioned quantifiable objectives and believes that through existing City policies and programs, as well as the City’s affordable Housing Ordinance, the objectives are reasonably spread out over the eight-year planning period.

9 Appendix A - Review of Past Performance: This Appendix reviews the prior Housing Element to measure progress in implementing policies and programs. It likewise evaluates which programs were successful and should be continued, and which programs were ineffective and should be removed or modified. Examples of recommended modifications include integrating changes to reflect State law updates (e.g., no net loss (SB 166), Housing Crisis Act (SB 330), supportive housing, environmental justice, etc.) and providing more specificity in terms of City actions.

Appendix B – Candidate Sites Analysis: Identifies locations of available sites for housing development to ensure that there is adequate capacity to address the RHNA in each of the affordability categories.

As shown in Appendix B, the City's existing zoning (i.e., residential development capacity that exists currently within Brentwood’s residential and mixed-use zoning districts) and "pipeline3" of entitled projects is estimated to accommodate approximately 3,069 housing units; this number includes 135 ADUs that are assumed will be built during the Housing Element period.

As seen in Table 2, this estimated capacity reflects a buffer in each income category when compared to the total RHNA allocation (1,552 units). Staff notes that based on City Council and LUD direction, the distribution of units across income categories varies somewhat from the estimates provided in earlier stages of the process. A majority of those changes resulted in reducing the estimated capacity in PA-1 while increasing the affordability assumptions.

Table 2: Summary of Residential Capacity Analysis
Very LowIncome
LowIncome ModerateIncome
Above
ModerateIncome Total
2023-2031 RHNA
Allocation 402 232 247 641 1,552
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) 479 228 813 1,520
Vacant Residential
Land 156 68 222 446
Total Unit Potential 717 337 2,015 3,069
Units +/- and Buffer/Gap
% +83 units, 13% +90 units,
36%
+1,374
units, 214%
+1,966 units,
98%
This approach in the current draft was provided by City Council and LUD in July and August, to allow the City to account for potential future changes to PA-1 currently under consideration by the City Council, review by HCD, and additional public input. The adequacy of the sites inventory will be evaluated by HCD. In any case, during the final phases of Housing Element review that will  3 HCD defines pipeline projects as residential projects that are approved, permitted, or receive a certificate of occupancy after the beginning of the RHNA period.

10 take place in early 2023, the City Council will be able to further modify the inventory to reflect any potential changes to PA-1.

Appendix C - Summary of Community Engagement: Summarizes community outreach and engagement meetings and surveys, with a particular focus on outreach to traditionally underrepresented groups. Included in Appendix D is a summary of input from the initial on-line community survey. The survey concluded in June and included 526 responses. This appendix will continue to be updated until the conclusion of the public review process.

Appendix D - Glossary of Housing Terms: This final section provides a comprehensive glossary of all of the acronyms and terms used throughout the Housing Element.

NEXT STEPS
In addition to tonight’s Special City Council Meeting, there will be additional opportunities for feedback, including a Planning Commission meeting on September 20 and a City Council meeting on September 27. Beyond this current round of review and comment, a number of critical steps remain in the Housing Element Update process, summarized in Figure 3 and described in more detail below.

Figure 3: Review Timeline
• HCD Review of Draft Housing Element (October 2022 – January 2023 and January – March 2023): Following the public review period, the Draft Housing Element, including any revisions recommended by the City Council, will be submitted to HCD. Staff anticipates submitting the Draft Housing Element to HCD in mid-October. HCD then has a full 90 days to complete its review and provide comments to the City (i.e., HCD's initial comments would be expected in approximately mid-January 2023). Staff would likely be required to submit for a subsequent second and possible third draft to HCD for review (January – March 2023) following the initial review.
• Potential City Council, Planning Commission, and/or Public Meetings - Revised Draft Housing Element (January - April 2023): Following receipt of HCD comments, if staff determines that the comments are substantial in nature or that changes may impact current or existing policy direction, staff may be required to hold additional public meetings

11 to seek input on potential revisions to the Housing Element, prior to its resubmittal to HCD.

Until HCD provides initial comments, staff is unable to know if additional City Council direction will be required.
• Resubmittal of Housing Element to HCD (January - March 2023): The revised Housing Element must be re-submitted to HCD, which has 30-60 days to review the document and issue a letter of substantial compliance.
• Adoption Hearings (April-May 2023): The Planning Commission and City Council will conduct public hearings to consider adoption of the final Housing Element.

ATTACHMENTS
Attachment A - Public Review Draft Housing Element Feedback Form Attachment B - Public Review Draft Housing Element










!
"#$%

&'(%%

")%
)*%




& ( 

*+
)(
*'
)%%*

*''%
 

'*
*(


,

% 


(


"-




%
.%
'+"/
*

*&
+
)'*

'
,
%"0"
*%
*((
#%( *
 

'('
'


%*
(*)*(
"


%(*1#*% *%
1#

*
'2
*3

'4(*
52346
*'*')
#
&*&-
!
"#$%

&' *+

*(*

'*

*#78
#%

)(

("(
-4
)%
*
)*%
#




)'*

)%(
(


",,


*'#

'+*(9

(%
*

)(
*')%%*

*
*))%)%*

"*''%


 

'#(%%

*'#
%
$%

&'
%
'

-
:%
%
#%
*
*+





7)
*
,
&&&-+%

&' 



-(
-
;
<  5=

'/
*

6 >
"UUBDINFOU
"

Brentwood 2023-2031 Housing Element
Appendix C: Summary of Community Engagement C-11
C.6 Planning Commission Meeting
This section contains all materials created for the September 20, 2022, Planning Commission meeting.

Participants had the opportunity to make public comments verbally or in written form through the Zoom chat.

1 From:

Sent: Thursday, September 15, 2022 9:42 AM
To:

Subject: We want to hear from you! Brentwood Housing Element Update View this email in your browser
2023-2031 Housing Element Update Public
Review Draft
There is still time to review and provide comments on Brentwood’s Draft Housing Element. Housing Element is one of seven State-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. The Draft Housing Element is available for download or review on the project website HERE. Community members are invited to provide comments directly on the website, via email, via mail, and/or to participate in upcoming community meetings. The public review period will run through September 27th.

Upcoming opportunities for public engagement and input on the Draft Housing Element will be available in September including the following:
 Planning Commission on September 20, and
 City Council hearing on September 27

2 BrentwoodHousingElement.com
For more information, please visit the Housing Element project website which is translatable to Spanish and Chinese. Este sitio web es traducible. 這個網站是可翻譯的！ Please visit the website to:
 Get informed about the Housing Element, review FAQs, and download project documents and reports
 See the project schedule, including upcoming public meetings and other opportunities for engagement
For more information, contact Jennifer Hagen, Senior Planner at [email protected]
Project Website

3 Copyright (C) 2022 City of Brentwood. All rights reserved.

You are receiving this email because you have shown interest in the City of Brentwood Housing Element Update.

Our mailing address is:

City of Brentwood
150 City Park Way
Brentwood, CA 94513-1164
Add us to your address book
Want to change how you receive these emails?
You can update your preferences or unsubscribe

SEPTEMBER 20, 2022

PLANNING COMMISSION AGENDA

TELECONFERENCE, ZOOM
*IMPORTANT NOTICE ABOUT PUBLIC COMMENTS AND MEETING PARTICIPATION* UPDATED SEPTEMBER 15, 2022
Consistent with Contra Costa County Health orders, and in accordance with California Government Code Section 54953(e) concerning teleconference meetings, this Planning Commission meeting will be held exclusively via teleconference, using the Zoom video conferencing system.

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

1. Zoom: https://www.brentwoodca.gov/planningmeetingonline As the City Council Chamber will not be open, the public 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 the Zoom webinar to request to speak. After speaking, please lower the “Raise Hand” feature. The meeting host will call on you, by name, and unmute 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 Planning Administrative Secretary by noon of the meeting date at [email protected] or 925.516.5433.)
The public may alternatively 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 (*6 is to mute/unmute).

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]. Emails not sent to this email address will not be included as public comments, even if sent directly to Planning Commissioners.

Any public comments received up until 5:00 p.m. of the meeting date will be:
 distributed to the Planning Commission via email before the meeting,  posted online for public inspection within one day following the meeting via the following link under the meeting minutes http://brentwoodca.iqm2.com/citizens/default.aspx, and  later 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 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 Planning Commission receives your comments prior to taking action, you are strongly encouraged to submit them in advance of the meeting.

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. In addition, any other disclosable public records related to an agenda item for the open session of this meeting distributed to all or a majority of the Planning Commission less than 72 hours before any meeting will be made available online shortly thereafter.

SEPTEMBER 20, 2022

REGULAR MEETING AGENDA
PAGE 2 OF 3
7:00 PM – PLANNING COMMISSION REGULAR MEETING

CALL TO ORDER & ROLL CALL

PLEDGE OF ALLEGIANCE

PUBLIC COMMENTS
At this time, the public is permitted to address the Planning Commission on items that are on the Consent Calendar, Requests for Future Agenda Items, or items not on the agenda. Persons addressing the Planning Commission are required to limit their remarks to three (3) minutes unless an extension of time is granted by the Chairperson subject to approval of the Planning Commission. Speakers are requested to file their names with the Chairperson on the form provided on the counter near the back of the Chambers. Speakers desiring answers to questions should direct them to the Planning Commission and, if relevant, the Planning Commission may direct them to the appropriate staff member.

PLEASE NOTE THAT THE COMMISSION’S ACTIONS ARE FINAL UNLESS AN APPEAL IS FILED WITH THE CITY CLERK WITHIN TEN CALENDAR DAYS.

CONSENT CALENDAR
All matters listed on the consent calendar are considered routine in nature and will be enacted by one motion. If discussion is required, that particular item will be removed from the consent calendar and will be considered separately.

1. Minutes of the Planning Commission meeting of July 19, 2022. (Drummond)

BUSINESS ITEMS

2. An application for a one-year time extension for Design Review No. 20-009 for a 4,000 square foot replacement cart barn/maintenance building, exterior golf cart parking, a new putting green, construction of bio-treatment basins, and relocation of an existing aboveground gasoline fueling tank associated with the Brentwood Golf Course, located at 100 Summerset Drive (APN 010-020-016). (Yuwiler)

3. Housing Element Update - Introduction and review of the 2023-2031 (6th Cycle) Housing Element Update Public Review Draft. (Hagen)

4. Public Hearing. An amendment to the Priority Area 1 Specific Plan, which governs approximately 431 acres roughly bounded by Lone Tree Way, Heidorn Ranch Road, Old Sand Creek Road, and Shady Willow Lane (the “Priority Area 1 Specific Plan” or “project”).

As originally envisioned by the Priority Area 1 Specific Plan, the project will provide for residential, professional office, technology, medical, manufacturing and research and development uses in a mixed-use business park campus and adjoining neighborhoods.

The Planning Commission may consider and make recommendations to the City Council as to the adoption of text and land use map amendments to the Priority Area 1 Specific Plan (SPA 22-001), to update development standards, land uses, infrastructure and public services, and circulation, as well as economic development and implementation; and the adoption of an ordinance to amend Brentwood Municipal Code Chapter 17.295 (PA-1 [Priority Area One] zone) and the zoning map of the City of Brentwood accordingly (RZ 22-001).

SEPTEMBER 20, 2022

REGULAR MEETING AGENDA
PAGE 3 OF 3
Approval of the project will not result in the approval of any particular development proposal, but rather the underlying planning to facilitate later project review and approval.

The project includes an Addendum to the Environmental Impact Report (EIR) prepared for the Priority Area 1 (PA-1) Specific Plan Project (State Clearinghouse No. 2018042064), which was certified by the City of Brentwood on November 13, 2018 (Certified EIR). In accordance with the California Environmental Quality Act (CEQA), this Addendum analyzes proposed modifications (the Modified Project) to the PA-1 Specific Plan Project approved in 2018, and demonstrates that all of the potential environmental impacts associated with the proposed modifications would be within the envelope of impacts already evaluated in the Certified EIR. (Ewen)

INFORMATIONAL REPORTS FROM COMMITTEES AND UPCOMING MEETING SCHEDULE This portion of the agenda is to provide an opportunity for Planning Commissioners to report on attendance at events and subcommittee meetings.

TRANSPLAN Committee (Roberts) 2
nd Thursday of every month
Design Review Subcommittee (Cross & Sparling) 2
nd and 4th Thursdays of every
month
Land Use and Development Committee (Zeigler) 3
rd Monday of every month

REQUEST FOR FUTURE AGENDA ITEMS
NEW REQUEST(S) Planning Commissioners wishing to have an agenda item placed on a future agenda shall make a request under this section of the agenda. These items will be included on the agenda for a future Planning Commission meeting.

ADJOURNMENT
The next regular Planning Commission meeting is scheduled for October 4, 2022 at 7:00 PM and will be held virtually via the Zoom platform.

NOTICE
In compliance with the Americans with Disabilities Act, if you are a person with a disability and you need disabilityrelated modifications or accommodations to participate in this meeting, please contact the Planning Secretary’s Office at (925) 516-5405 or fax (925) 516-5407. 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 September 15, 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

STAFF REPORT

PLANNING COMMISSION REGULAR MEETING OF
SEPTEMBER 20, 2022
PREPARED BY: Jennifer Hagen, Senior Planner
[email protected]
PROJECT DESCRIPTION: Item No. 3, Introduction and review of the 2023- 2031 Housing Element Update Public Review Draft
GENERAL PLAN: Citywide
ZONING: Citywide
APPLICANT: City of Brentwood
PREVIOUS ACTIONS:

The City Council authorized execution of an agreement with Kimley-Horn for consulting services 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 a status report 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 to the City Council and Planning Commission.

The City Council directed staff to return with a draft site inventory for review.

On July 21, 2022, staff presented a draft site inventory with an introduction of the analysis of existing residential zoning capacity within the city, as well as an evaluation of site inventory and affordability assumption strategies needed to address the City’s RHNA. The City Council directed staff to move forward with drafting a Housing Element Public Review Draft that reduced buffers within the draft sites inventory to 15%-20% (if feasible),added policies incentivizing ADU production, and added policies encouraging development on City-owned parcels.

On August 15, 2022, staff presented a revised site inventory, as well as a status report on the Housing Element Update, to the City Council’s Land Use and Development Committee (LUD).

Staff requested that LUD provide any additional input on the Housing Element Update, including affirmation of staff’s approach to the draft sites inventory. Staff received input and has now completed the Housing Element Public Review Draft.

On August 30, 2022, staff presented an introduction to the City Council on the Public Review Draft Housing Element, including an overview of the Housing Element Update process and timeline, and instructions on how the public can provide comments and participate in the 3 Packet Pg. 50 Page 574 of 894
upcoming public outreach. The meeting was informational and no action or direction was requested or provided.

BACKGROUND:

The City formally initiated the 6th Cycle (2023-2031) Housing Element Update process in October 2021 with substantive public meetings beginning in April. Since then, there have been a number of public meetings and outreach events to review key components of the Housing Element Update. Public input provided at these meetings, along with feedback from the Planning Commission and direction from the City Council, has been incorporated into the Public Review Draft Housing Element (“Draft Housing Element”) introduced in this report. The Draft Housing Element is available for public review and input from August 25 through September 27 and is attached for reference.

On September 20, staff will present the Planning Commission with an introduction to the Public Review Draft Housing Element, including an overview of the Housing Element Update process and timeline. Staff is requesting the Planning Commission's review and feedback on the Draft Housing Element. Feedback will be reported to the City Council at its September 27 meeting, at which time staff will request direction to forward the document, including any modifications recommended by the City Council, to the State Department of Housing and Community Development (HCD) for its required review.

DISCUSSION:

What is a Housing Element?
The Housing Element is one of seven State-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 provides a vehicle for 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 20231, 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 (known as certification) by HCD.

Unlike the majority of the other required General Plan elements, the Housing Element must include very specific information to ensure compliance with the variety of complex housing laws.

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

1 It should be noted that although January 31, 2023 is the statutory deadline to have the Housing Element adopted for Brentwood, there is a 120-day “grace period” that is allowed in order to gain HCD’s finding of compliance or certification.
3 Packet Pg. 51 Page 575 of 894
across income levels. The inventory of available sites, or “Sites Inventory,” is 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.

Public Review Draft Housing Element Review Process
The Draft Housing Element in circulation has been prepared to reflect the feedback and public process to date and is available for public review from August 25 through September 27. The City Council hosted an initial special meeting to introduce the Draft Housing Element and to help initiate and facilitate public comment. Additionally, public comments are encouraged to be submitted to staff via the project website (https://brentwoodhousingelement.com) through a designated Public Review Draft housing Element Feedback Form, which is attached to this report for the Commission’s reference. In addition to the Public Review feedback form, comments may also be submitted by email or traditional mail correspondence2. Following the public review period, staff and the professional services team (Kimley-Horn) will implement revisions as necessary to the Draft Housing Element prior to submittal to HCD.

All public and Planning Commission feedback received during the 30-day review period will be reported to the City Council at its meeting on September 27. If recommended by the City Council at that meeting, the document will be submitted to HCD in October, after the required 10-day response period, for HCD’s compulsory review, incorporating any revisions necessary and/or recommended by the City Council. HCD will have 90 days to review and comment on the draft document. After HCD's review period, ending in mid-January, staff will incorporate HCD's comments into another draft of the Housing Element. Additionally, staff and Kimley-Horn are preparing environmental documents to be reviewed with the final draft on the Housing Element in 2023. The updated Housing Element would then be re-submitted to HCD for a further review (30-60 days) during the first quarter of 2023, with adoption anticipated in spring of 2023.

What Are the Components of the Draft Housing Element?
State law defines the required contents of the Housing Element, with key components that can be found in the following four principal sections and four appendices:

Section 1: Introduction – This section contains a summary of the content, organization, and statutory considerations of the Housing Element.

Section 2: Community Profile – This section contains an analysis of the City’s population, household and employment base, and the characteristics of the housing stock.

Section 3: Housing Constraints, Resources, and Fair Housing – This section examines governmental and nongovernmental constraints on production, maintenance, and affordability of housing, and provides a summary of housing resources, including sites identification and funding and financial considerations, as well as the Affirmatively Furthering Fair Housing (AFFH) section.

Section 4: Housing Plan – This section addresses the City’s identified housing needs, including housing goals, policies, and programs.

2 Email correspondence may be sent to [email protected] and mail correspondence may be sent to the Attention of Jennifer Hagen at 150 City Park Way, Brentwood, Ca 94513 3 Packet Pg. 52 Page 576 of 894
Appendix A: Review of Past Performance – This section reviews the 5th Cycle Housing Element update goals and policies, and provides analysis of the City’s efforts with respect to achieving those goals, and considers whether the previous goals and policies should be deleted, carried forward, or modified as part of the new update.

Appendix B: Candidate Sites Analysis – This section includes the draft sites inventory and analyzes the City’s ability to meet current RHNA goals in each income category.

Appendix C: Summary of Community Engagement – This section provides a summary of the public outreach that has been undertaken since the start of the Housing Element Update process and will continue to be updated until the adoption of the Housing Element.

Appendix D: Glossary of Housing Terms – This section provides a comprehensive glossary of all of the acronyms and terms used throughout the Housing Element.

Staff and Kimley-Horn have verified, in accordance with the HCD Housing Element Completeness Checklist, that the Draft Housing Element is reflective of the various State requirements and the public process to date. Below is a detailed summary of each of the relevant sections and appendices to assist with review of the document.

Section 2 – Community Profile: The Community Profile establishes the foundation for understanding Brentwood’s housing needs. It analyzes a range of demographic, economic, and housing-related variables that help define the extent and context of the city's housing-related needs. As illustrated in Figure 1 below, the Community Profile includes an analysis of the city's population, special needs groups, employment, housing stock, and housing affordability.

Information in this section provides a basis from which to build housing goals, policies, and programs to address those needs.

Figure 1: Community Profile
3 Packet Pg. 53 Page 577 of 894
Section 3 - Housing Constraints, Resources, and Fair Housing: Analyzes and recommends remedies for existing and potential governmental, nongovernmental, and environmental barriers to housing development. In addition, this section also includes the required Affirmatively Furthering Fair Housing (AFFH) section. Figure 2 on the following page illustrates these components, as addressed in this section.

Figure 2: Housing Constraints, Resources, and Fair Housing AFFH is a new requirement for the 6
th Cycle and is included per the requirements of a 2018 State law (AB 686). AB 686 requires the Housing Element to comprehensively analyze and address patterns of exclusion and segregation (looking both locally and regionally), and to identify meaningful actions and strategies to address those issues and their "contributing factors." The exhaustive AFFH analysis reflects detailed guidance provided by HCD, as well as best practices from other regions that have already gone through HCD review and certification.

The analysis relies on both approved data sets, as well as local knowledge and community input. The analysis includes the following:
 A summary of fair housing outreach and capacity that includes all economic segments of the community;
 An assessment of fair housing issues, including integration and segregation patterns, racially or ethnically concentrated areas of poverty, disparities in access to opportunity, and disproportionate housing needs for all identified populations. Many of the key issues reflect those identified more generally in the housing needs assessment, including overpayment for housing, particularly among renters, and lack of affordability that is most acute for the lower-wage workforce, the disabled, and seniors. Geographically, the 3 Packet Pg. 54 Page 578 of 894
area east of Brentwood Boulevard is identified as an area where there may be a greater risk for displacement of existing renters and lower-income residents. Lack of access to fair housing resources, especially for those that do not speak English as a primary language, was further identified as a contributing factor in fair housing issues;  An evaluation of whether the Housing Element's sites inventory improves or exacerbates conditions for fair housing. The analysis concludes that the sites inventory would not worsen fair housing conditions;
 The identification and prioritization of contributing factors related to fair housing issues.

Some of the key contributing factors to fair housing issues in Brentwood include the location and type of housing, lack of affordable, integrated housing for persons with special needs, displacement due to economic pressures, community opposition to housing over time, and lack of marketing and language access regarding housing opportunities and resources; and
 The identification of fair housing goals and actions that directly address the City's contributing factors.

Section 4: Housing Plan: The goals, policies, and programs (also called actions) are a key component in this section, representing the City's proposed "housing plan" with a focus on actionable steps and measures that the City will undertake to increase affordable housing and preserve and improve existing housing.

There are four main goals, with a corresponding set of policies and programs for each. Whereas the policies help to guide and inform future City decision-making and direction with respect to a broad range of housing-related topics, the programs provide actionable steps to implement the Housing Element's goals and to make further progress towards meeting the regional housing need allocation. Timeframes and responsibilities for each program are indicated in the text. The four main goals in the Housing Plan include the following:

H.1 - Housing Goal
Facilitate a diversity of housing opportunities to enhance the City’s living environment and to satisfy the shelter needs of all Brentwood residents.

H.2 - Affordability Goal
Encourage housing that is affordable to all socio-economic segments of Brentwood’s population.

H.3 - Equitable Distribution of Affordable Housing Goal Encourage an equitable distribution of housing for all economic groups throughout the community.

H.4 - Housing Opportunities Goal
Promote equal housing opportunities for all residents of Brentwood.

In developing the policies and programs, staff used those included in the 5th Cycle Housing Element as a starting point, carrying forward many of the same underlying themes, concepts, and ideas. However, the 6
th Cycle Draft Housing Element revises and modifies some of the actions to clarify intent, improve specificity and address new State laws. (As a required component of the Housing Element, Appendix A provides a review of the 5th Cycle programs, 3 Packet Pg. 55 Page 579 of 894
evaluates the City's progress towards achieving the goals of the programs, and notes whether they have been continued, discontinued, or modified in the update.) Although the changes are limited, for the purposes of reviewing this draft, staff has indicated the correlation between the 5th Cycle and 6th Cycle goals, policies, and programs within the body of the Draft Housing Element by noting them all as either "[NEW]" or "[5th Cycle Action X, modified/expanded]" in brackets in the text. When modified from a prior policy/program, reference is provided back to the 5th Cycle program or policy in question.

Some of the new actions/programs may be required per State law (e.g., AB 2923, AB 1397, and SB 166), some are in response to the requirement to address housing constraints, and others are in response to feedback from the public, Planning Commission, and City Council. New policies and programs are annotated in the Draft Housing Element text with “[NEW]” for reference. Among these are new policies and programs to facilitate housing production, reflecting a range of housing types, sizes, affordability levels, and tenure, and provide access to housing opportunities that meet the diverse needs of the community, including:
 Action H.1b: Support and accommodate the development of Accessory Dwelling Units (ADUs) and Junior Accessory Dwelling Units (JADUs).
 Action H.1c: Monitor the development of ADU and JADU applications, location, affordability, and other relevant features to ensure adequate ADU development.  Action H.1m: Establish written procedures to comply with California Government Code Section 65913.4, as appropriate, to comply with the requirements of Senate Bill 35 (SB 35).
 Action H.1n: Encourage residential development on sites within the Sites Inventory and maximize the development potential, as well as promote existing residential incentives and identify potential new incentives, as appropriate.
 Action H.1o: Revise the General Plan to comply with the requirements of Senate Bill 1000 (SB 1000) to incorporate environmental justice policies within the General Plan and of Senate Bill 1035 (SB 1035) to identify flood hazards and address the risk of fire hazards in the City’s Safety Element.
 Action H.1p: Adopt a replacement-housing program for units lost that are currently occupied by lower-income households or households subject to affordability requirements.
 Action H.1q: Monitor housing sites to ensure adequate sites to accommodate the remaining unmet RHNA by each income category pursuant to Senate Bill 330 (SB 330).  Action H.2i: Update the Density Bonus Ordinance in compliance with State law requirements.
 Action H.4a: Affirmatively further fair housing by taking meaningful actions that foster inclusive communities free from barriers, which restrict access to opportunities, based on protected classes.
 Action H.4h: Adopt regulations and procedures that establish a ministerial approval process for low-barrier navigation centers that meet specified requirements consistent with Senate Bill 48 (SB 48).
3 Packet Pg. 56 Page 580 of 894
 Action H.4i: Encourage construction and rehabilitation of housing with supportive services targeted for persons with developmental disabilities, including exploring granting regulatory incentives.
 Action H.4j: Encourage opportunities to accommodate housing that can assist with individuals' transitions from homelessness, including Single Room Occupancy units (SROs).

New HCD guidelines also require that all new goals, policies, and programs are objective and quantifiable in nature. Based on these more stringent guidelines, staff has included specific quantifiable objectives into the following programs and shown in Table 1:
 Action H.1d: Monitor At-Risk Projects and develop strategies including potential expenditure of City housing funds to preserve their ongoing affordability. Housing projects are “at risk” if they are near to reverting or converting to market rate pricing. o Monitor the six units at-risk of converting to market-rate during the planning period.
 Action H.1e: Encourage community education regarding the availability of rehabilitation programs.
o Assist in rehabilitating 30 housing units during the planning period.  Action H.2c: Provide a First-Time Homebuyer Assistance Program either directly or through regional partners.
o Assist 20 households during the planning period.
 Action H.2d: Explore a variety of potential financial assistance programs from both the public and private sectors to provide more affordable housing units and affordable housing assistance.
o Assist in providing assistance to 20 extremely low-, 50 very low-, and 50 lowincome units during the planning period.  Action H.4e: Encourage affordable housing developers to provide units for special needs persons or households, when feasible and appropriate.
o Seek opportunities to assist developers with providing 50 special needs units (farmworker, affordable senior, disabled, developmentally disabled, large households, female-headed household, homeless) during the planning period. 3 Packet Pg. 57 Page 581 of 894
Table 1: 6th Planning Cycle Quantified Objectives
Objectives
Units by Income Level
Extremely Total Units
Low
Very
Low Low Moderate Above Moderate
RHNA 402 232 247 641 1,522
Home Repair/
Rehabilitation 30 30
Special Needs Units 50 50
First-Time
Homebuyer 15 5 0 20
Affordable Housing
Assistance 20 50 50 0 0 120
At-Risk Housing
Units 6 0 0 6
Staff has reviewed the above-mentioned quantifiable objectives and believes that through existing City policies and programs, as well as the City’s affordable Housing Ordinance, the objectives are reasonably spread out over the eight-year planning period.

Appendix A - Review of Past Performance: This Appendix reviews the prior Housing Element to measure progress in implementing policies and programs. It likewise evaluates which programs were successful and should be continued, and which programs were ineffective and should be removed or modified. Examples of recommended modifications include integrating changes to reflect State law updates (e.g., no net loss (SB 166), the Housing Crisis Act (SB 330), supportive housing, environmental justice, etc.) and providing more specificity in terms of City actions.

Appendix B – Candidate Sites Analysis: Identifies locations of available sites for housing development to ensure that there is adequate capacity to address the RHNA in each of the affordability categories.

As shown in Appendix B, the City's existing zoning (i.e., residential development capacity that exists currently within Brentwood’s residential and mixed-use zoning districts) and “pipeline” 3 of
entitled projects is estimated to accommodate approximately 3,069 housing units; this number includes 135 ADUs that are assumed will be built during the Housing Element period.

As seen in Table 2, this estimated capacity reflects a buffer in each income category when compared to the total RHNA allocation (1,552 units), as recommended by HCD. Staff notes that based on City Council and LUD direction, the distribution of units across income categories varies somewhat from the estimates provided in earlier stages of the process. A majority of those changes resulted in reducing the estimated capacity in PA-1 while increasing the affordability assumptions.

3 HCD defines pipeline projects as residential projects that are approved, permitted, or receive a certificate of occupancy after the beginning of the RHNA period. 3 Packet Pg. 58 Page 582 of 894
Table 2: Summary of Residential Capacity Analysis
Very LowIncomeLowIncomeModerateIncome
Above
ModerateIncomeTotal
2023-2031 RHNA
Allocation 402 232 247 641 1,552
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)
479 228 813 1,520
Vacant Residential
Land 156 68 222 446
Total Unit Potential 717 337 2,015 3,069
Units +/- and Buffer/Gap
%
+83 units, 13%
+90 units,
36%
+1,374
units, 214%
+1,966 units,
98%
This approach in the current draft was provided by the City Council and LUD in July and August, to allow the City to account for potential future changes to PA-1 currently under consideration by the City Council, review by HCD, and additional public input. The adequacy of the sites inventory will be evaluated by HCD. In any case, during the final phases of Housing Element review that will take place in early 2023, the City Council will be able to further modify the inventory to reflect any potential changes to PA-1.

Appendix C - Summary of Community Engagement: Summarizes community outreach and engagement meetings and surveys, with a particular focus on outreach to traditionally underrepresented groups. Included in Appendix D is a summary of input from the initial on-line community survey. The survey concluded in June and included 526 responses. This appendix will continue to be updated until the conclusion of the public review process.

Appendix D - Glossary of Housing Terms: This final section provides a comprehensive glossary of all of the acronyms and terms used throughout the Housing Element.

NEXT STEPS
Beyond this current round of review and comment, a number of critical steps remain in the Housing Element Update process, summarized in Figure 3 and described in more detail below. 3 Packet Pg. 59 Page 583 of 894
Figure 3: Review Timeline
 HCD Review of Draft Housing Element (October 2022 – January 2023 and January – March 2023): Following the public review period, the Draft Housing Element, including any revisions recommended by the City Council, will be submitted to HCD. Staff anticipates submitting the Draft Housing Element to HCD in mid-October. HCD then has a full 90 days to complete its review and provide comments to the City (i.e., HCD's initial comments would be expected in approximately mid-January 2023). Staff would likely be required to submit for a subsequent second and possible third draft to HCD for review (January – March 2023) following the initial review.
 Potential City Council, Planning Commission, and/or Public Meetings - Revised Draft Housing Element (January - April 2023): Following receipt of HCD comments, if staff determines that the comments are substantial in nature or that changes may impact current or existing policy direction, staff may be required to hold additional public meetings to seek input on potential revisions to the Housing Element, prior to its resubmittal to HCD. Until HCD provides initial comments, staff is unable to know if additional City Council direction will be required.
 Resubmittal of Housing Element to HCD (January - March 2023): The revised Housing Element must be re-submitted to HCD, which has 30-60 days to review the document and issue a letter of substantial compliance.
 Adoption Hearings (April-May 2023): The Planning Commission and City Council will conduct public hearings to consider adoption of the final Housing Element.

PUBLIC NOTICE
Advertisement of this item was published in The Brentwood Press on September 9, 2022. In addition, email notification was sent to all interested parties who have signed up on the Housing Element website (brentwoodhousingelement.com)
3 Packet Pg. 60 Page 584 of 894

ENVIRONMENTAL ASSESSMENT
The City is still determining the appropriate level of environmental review for this project.

Environment review for this project is anticipated to evaluate the potential environmental impacts associated with the implementation of policies and programs included in the updated Housing Element. As currently proposed, no land use and zoning changes will be required. The final environmental assessment will be presented to the Planning Commission and City Council for consideration at the same time as the Housing Element adoption hearings.

CONCLUSION
Staff seeks the Planning Commission's review and feedback on the Draft Housing Element, including any recommended revisions or modifications before the document is reviewed by the City Council and submitted to HCD for its review.

RECOMMENDATION
Review and provide comments on the 6th Cycle (2023-2031) Draft Housing Element Update.

Attachments:

Public Review Draft Housing Element Feedback Form
Brentwood 6th Cycle Public Review Draft Housing Element 3 Packet Pg. 61 Page 585 of 894




 



!
"#$%

&'(%%

")%
)*%




& ( 

*+
)(
*' )%%*

*''%
 

'*
*(


,

% 


(


"-



 %
.%
'+"/
*

*&
+
)'*

'
,
%"0"
*%
*((
#%( *
 

'(' '


%*
(*)*(
"


%(*1#*% *%
1#

*
'2
*3

'4(*
52346 *'*')
#
&*&-
!
"#$%

&' *+

*(*

'*

*#78
#%

)(
 ("(
-4
)%
*
)*%
#




)'*

)%(
(


",,


*'#

'+*(9
 (%
*

)(
*')%%*

*
*))%)%*

"*''%


 

'#(%%

*'#
%
$%

&' %
'

- :%
%
#%
*
*+





7)
*
,
&&&-+%

&' 



-(
-; <  5=

'/
*

6 >
Attachment A3.a
Packet Pg. 62
Attachment: Public Review Draft Housing Element Feedback Form (2806 : Housing Element Public Review Draft)

3.a
Packet Pg. 63
Attachment: Public Review Draft Housing Element Feedback Form (2806 : Housing Element Public Review Draft)

Brentwood 2023-2031 Housing Element
Appendix C: Summary of Community Engagement C-12
C.7 City Council Meeting
This section contains all materials created for the September 27, 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/.

SEPTEMBER 27, 2022

CITY COUNCIL AGENDA

TELECONFERENCE, ZOOM
*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

1. 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.

1. 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.

SEPTEMBER 27, 2022

CITY COUNCIL AGENDA
PAGE 2 OF 5
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 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 September 27, 2022, at 5:30 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 on the agenda item.

WORKSHOP

1. Review and provide comments on the 2023-2031 (6th Cycle) Draft Housing Element, and authorize submittal of the Draft Housing Element to the State Department of Housing and Community Development. (Alexis Morris/Jennifer Hagen)

ADJOURNMENT
7:00 PM – CITY COUNCIL MEETING

CALL TO ORDER & ROLL CALL

PLEDGE OF ALLEGIANCE

PUBLIC COMMENTS
The public is permitted to speak on items that are listed under Presentations; Informational Reports from Council Members, Committee, Liaisons, and Staff; on the Consent Calendar; Requests for Future Agenda Items, new items; or items not on the agenda. Public comments for scheduled agenda items should wait until that time.

Persons are required to limit their remarks to three (3) minutes unless an extension of time is granted by the Mayor subject to approval of the City Council/Successor Agency. Please use the Raise Your Hand feature in Zoom during this item to speak under Public Comments. Speakers desiring answers to questions should direct them to the City Council/Successor Agency and, if relevant, the City Council/Successor Agency may direct them to the appropriate staff member

SEPTEMBER 27, 2022

CITY COUNCIL AGENDA
PAGE 3 OF 5
A. INFORMATIONAL REPORTS FROM COUNCIL MEMBERS, COMMITTEES,

LIAISONS AND STAFF
This portion of the agenda is to provide an opportunity for Council Members to report on attendance at events, subcommittee meetings, and entities on which the Council Member has been appointed as a liaison and for staff to provide brief updates and/or information to the City Council.

B. CONSENT CALENDAR
All matters listed on the consent calendar are considered routine in nature and will be enacted by one motion. If discussion is required, that particular item will be removed from the consent calendar and will be considered separately.

B.1. A Proclamation proclaiming October as National Breast Cancer Awareness Month B.2. A Proclamation proclaiming October as National ADHD Awareness Month B.3. Second reading of Ordinance No. 1045 amending City Council/Administrative Policy No. 10-7, Purchasing Policy, to update the Types of Purchases Section to clarify individual requirements for Types of Purchases and increase the agreement requirement threshold for Services from $1,000 to $1,500; update the Federal Procurement Section to more closely match the Public Contract Code, Code of Federal Regulations, and the Brentwood Municipal Code; update the Quotes Section to increase availability of goods and services while maintaining best pricing; update the Exceptions Section to facilitate mandatory payments to Federal, State, and Local Governments and add an additional exception for Advertising in Publications; and to update the Miscellaneous Procedures Section to clarify the Long Term Agreements Exceptions (Kerry Breen/Wilton Alderman) B.4. A Resolution requesting the allocation of Fiscal Year 2022/23 Transportation Development Act, Article 3 Pedestrian/Bicycle Project Funding from the Metropolitan Transportation Commission in the amount of $100,000, for the Fairview Avenue sidewalk project. (Miki Tsubota/Steve Kersevan)
B.5. A Resolution certifying that the City of Brentwood is in compliance with the Measure J Growth Management Program and authorizing the City Manager or designee to execute the Growth Management Checklist for calendar years 2020 and 2021 for allocation of Measure J Local Street Maintenance & Improvement funds. (Miki Tsubota/Steve Kersevan)
B.6. A Resolution authorizing the City Manager to execute an Encroachment Agreement with Brentwood Union School District relating to the construction of a theater at Bristow Middle School (Bruce Mulder)
B.7. A Resolution approving the contract documents, awarding the bid, waiving bidding irregularities as immaterial and authorizing the City Manager or designee to execute a construction contract and necessary documents for Brentwood Various Streets and Roads Preservation, CIP Project No. 336-31694, with QA Constructors, Inc. as the lowest responsible and responsive bidder, in the amount of $609,400, plus a 15% contingency of $91,410, for a total not-to-exceed amount of $700,810. (Miki Tsubota/Renee Payette/Meghan Oliveira)

SEPTEMBER 27, 2022

CITY COUNCIL AGENDA
PAGE 4 OF 5
C. PUBLIC HEARINGS
Persons addressing the City Council are asked to raise their hands using the Zoom feature. The Council may adopt reasonable regulations at the onset of the public hearing to facilitate public testimony. These regulations may include time limits. In the absence of such regulations, the public hearing shall follow the protocol for Public Comments
C.1. A Resolution of the City Council of the City of Brentwood 1) adopting the FY 2022/23 Cost Allocation Plan and Schedule of City Fees; 2) Making Certain Supporting Findings, Including the Inapplicability of the California Environmental Quality Act to these Actions; 3) Imposing Said Fees; 4) Establishing a Process for Waiving or Adjusting Certain Fees; and 5) Repealing Resolution No. 2021-137, which adopted the FY 2021/22 Cost Allocation Plan and Schedule of City Fees; Consider the Inclusion of Two New Fees for 1) City Owned Electric Vehicle Charging Stations, and 2) Credit Card Processing (Kerry Breen/Wilton Alderman)
D. BUSINESS ITEMS
D.1. An Interim Urgency Ordinance Implementing a Moratorium on the Issuance of Any New Permit, License, or Entitlement for Any New Tobacco Smoke Shop in the City of Brentwood, and Finding the Action Exempt from CEQA (Alexis Morris/Erik Nolthenius/Damien Brower)
D.2. Adopt a Resolution: 1) Approving, and Authorizing the Mayor to Sign the Fourth Amendment to the June 27, 2017 Amended City Attorney Employment Agreement; 2) Authorizing the Director of Human Resources to make ministerial revision to the Pay Schedule to reflect the changes; and 3) Adopting Appropriations Amendments to the 2022/23 Operating Budget (Sukari Beshears)
D.3. An Ordinance Amending Section 2.08.010 of the Brentwood Municipal Code to Increase City Council Monthly Salaries (Sukari Beshears)
E. REQUEST FOR FUTURE AGENDA ITEMS
E.1. NEW REQUEST(S)
Council Members wishing to have an agenda item placed on a future agenda shall make a request under this section of the agenda. These items will be included on the agenda for the next Council meeting.

E.2. REQUESTED ITEMS
E.2.1. Future agenda item request from Council Member Mendoza for City Council discussion of, and possible direction to staff, related to an amendment of the City Council’s Ethics and Conduct Policy (No. 110-5) to permit the discussion of alleged City policy violations by members of the City Council, when following established procedures could result in a majority of the City Council discussing the allegation outside of a noticed meeting (Tim Ogden/ Damien Brower)

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 less than 72 hours before this meeting is available for inspection at City Hall, located at 150 City Park Way, during normal business hours.

SEPTEMBER 27, 2022

CITY COUNCIL AGENDA
PAGE 5 OF 5
If you challenge the any of the matters listed under 'Public Hearings' in court, you may be limited to raising only those issues you or someone else raised at the public hearing described in this notice, or in written correspondence delivered to the Brentwood City Council at, or prior to, the public hearing. .

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 September 22, 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

CITY COUNCIL AGENDA ITEM NO. 1
Meeting Date: September 27, 2022
Subject/Title: Review and provide comments on the 2023-2031 (6th Cycle) Draft Housing Element, and authorize submittal of the Draft Housing Element to the State Department of Housing and Community Development.

Prepared by: Jennifer Hagen, Senior Planner
Submitted by: Alexis Morris, Director of Community Development

PURPOSE AND RECOMMENDATION
The Public Review Draft Housing Element is available for the required 30 day public review period from August 25 through September 27. The City Council is asked to authorize staff to submit the Draft Housing Element, incorporating any revisions necessary and/or recommended by the City Council, to the State Department of Housing and Community Development (HCD) after the minimum 10 day response period.

Staff recommends that the City Council review and provide comments on the 2023-2031 (6th Cycle) Draft Housing Element, and authorize submittal of the Draft Housing Element to HCD after the minimum 10 day response period.

CITY COUNCIL STRATEGIC INITIATIVES
Focus Area 4: Community Development
Provide a diversity of housing opportunities, including equitable distribution of affordable housing for all socio-economic segments of the Brentwood community. o Update the City’s Housing Element including: an evaluation of the 2015 Housing Element; assessment of housing needs, resources, constraints; approval of an updated Regional Housing Needs Allocation; and adoption of housing goals, policies, and actions.

PREVIOUS ACTIONS
The City Council authorized execution of an agreement with Kimley-Horn for consulting services 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 a status report 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 to the City Council and Planning Commission.

The City Council directed staff to return with a draft site inventory for review.

On July 21, 2022, staff presented a draft site inventory with an introduction of the analysis of existing residential zoning capacity within the city, as well as an evaluation of site inventory and 1 Packet Pg. 6 Page 597 of 894
affordability assumption strategies needed to address the City’s RHNA. The City Council directed staff to move forward with drafting a Housing Element Public Review Draft that reduced buffers within the draft sites inventory to 15%-20% (if feasible), added policies incentivizing ADU production, and added policies encouraging development on City-owned parcels.

On August 15, 2022, staff presented a revised site inventory, as well as a status report on the Housing Element Update, to the City Council’s Land Use and Development Committee (LUD).

Staff requested that LUD provide any additional input on the Housing Element Update, including affirmation of staff’s approach to the draft sites inventory. Staff received input and has now completed the Housing Element Public Review Draft.

On August 30, 2022, staff presented an introduction to the City Council on the Public Review Draft Housing Element, including an overview of the Housing Element Update process and timeline, and instructions on how the public can provide comments and participate in the upcoming public outreach. The meeting was informational and no action or direction was requested or provided.

On September 20, 2022, staff presented the Public Review Draft Housing Element to the Planning Commission, including an overview of the Housing Element Update process and timeline. Due to the timing requirements for publishing the City Council agenda, a summary of the Planning Commission meeting including comments and recommended changes would be included in a supplemental memo that will be distributed to the City Council prior to September 27, 2022 City Council meeting.

BACKGROUND
The City formally initiated the 6th Cycle (2023-2031) Housing Element Update process in October 2021 with substantive public meetings beginning in April. Since then, there have been a number of public meetings and outreach events to review key components of the Housing Element Update. Public input provided at these meetings, along with feedback from the Planning Commission and direction from the City Council, has been incorporated into the Public Review Draft Housing Element (“Draft Housing Element”). The Draft Housing Element has been and will continue to be available for public review and input from August 25 to September 27 and is attached for reference.

On September 27, staff will present the City Council with an introduction to the Public Review Draft Housing Element, including an overview of the Housing Element Update process and timeline, as well as all Planning Commission and public comments to date. All Planning Commission and public comments will be provided ahead of the September 27, 2022, City Council meeting.

DISCUSSION
What is a Housing Element?
The Housing Element is one of seven State-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. 1 Packet Pg. 7 Page 598 of 894
Periodic updating of the Housing Element is required by State law; and thus, the Element provides a vehicle for 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 6
th Cycle) must be adopted by January 20231
, 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 (known as certification) by HCD.

Unlike the majority of the other required General Plan elements, the Housing Element must include very specific information to ensure compliance with the variety of complex housing laws.

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,” is 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.

Public Review Draft Housing Element Review Process
The Draft Housing Element in circulation has been prepared to reflect the feedback and public process to date and is available for public review from August 25 to September 27. The City Council hosted an initial special meeting to introduce the Draft Housing Element and to help initiate and facilitate public comment. Additionally, public comments are encouraged to be submitted to staff via the project website (https://brentwoodhousingelement.com) through a designated Public Review Draft housing Element Feedback Form, which is attached to this report for reference. In addition to the Public Review feedback form, comments may also be submitted by email or traditional mail correspondence.
2 Following the public review period, staff
and the professional services team (Kimley-Horn) will implement revisions as necessary to the Draft Housing Element, prior to submittal to HCD.

All public and Planning Commission feedback received during the 30-day review period will be reported to the City Council at its meeting on September 27. If recommended by the City Council at that meeting, the document will be submitted to HCD in October, after the required 10-day response period, for HCD’s compulsory review, incorporating any revisions necessary and/or recommended by the City Council. HCD will have 90 days to review and comment on the draft document. After HCD's review period, ending in mid-January, staff will incorporate HCD's comments into another draft of the Housing Element. The updated Housing Element would then be re-submitted to HCD for a further review (30-60 days) during the first quarter of 2023, with adoption anticipated in spring of 2023. Additionally, staff and Kimley-Horn are preparing environmental documents to be reviewed with the final draft on the Housing Element in 2023.

1 It should be noted that although January 31, 2023 is the statutory deadline to have the Housing Element adopted for Brentwood, there is a 120-day “grace period” that is allowed in order to gain HCD’s finding of compliance or certification.
2 Email correspondence may be sent to [email protected] and mail correspondence may be sent to the attention of Jennifer Hagen at 150 City Park Way, Brentwood, CA 94513. 1 Packet Pg. 8 Page 599 of 894
What Are the Components of the Draft Housing Element?
State law defines the required contents of the Housing Element, with key components that can be found in the following four principal sections and four appendices:

Section 1: Introduction – This section contains a summary of the content, organization, and statutory considerations of the Housing Element.

Section 2: Community Profile – This section contains an analysis of the City’s population, household and employment base, and the characteristics of the housing stock.

Section 3: Housing Constraints, Resources, and Fair Housing – This section examines governmental and nongovernmental constraints on production, maintenance, and affordability of housing, and provides a summary of housing resources, including sites identification and funding and financial considerations, as well as the Affirmatively Furthering Fair Housing (AFFH) section.

Section 4: Housing Plan – This section addresses the City’s identified housing needs, including housing goals, policies, and programs.

Appendix A: Review of Past Performance – This section reviews the 5th Cycle Housing Element update goals and policies, and provides analysis of the City’s efforts with respect to achieving those goals, and considers whether the previous goals and policies should be deleted, carried forward, or modified as part of the new update.

Appendix B: Candidate Sites Analysis – This section includes the draft sites inventory and analyzes the City’s ability to meet current RHNA goals in each income category.

Appendix C: Summary of Community Engagement – This section provides a summary of the public outreach that has been undertaken since the start of the Housing Element Update process and will continue to be updated until the adoption of the Housing Element.

Appendix D: Glossary of Housing Terms – This section provides a comprehensive glossary of all of the acronyms and terms used throughout the Housing Element.

Staff and Kimley-Horn have verified, in accordance with the HCD Housing Element Completeness Checklist, that the Draft Housing Element is reflective of the various State requirements and the public process to date. Below is a detailed summary of each of the relevant sections and appendices to assist with review of the document.

Section 2 – Community Profile: The Community Profile establishes the foundation for understanding Brentwood’s housing needs. It analyzes a range of demographic, economic, and housing-related variables that help define the extent and context of the city's housing-related needs. As illustrated in Figure 1 below, the Community Profile includes an analysis of the city's population, special needs groups, employment, housing stock, and housing affordability.

Information in this section provides a basis from which to build housing goals, policies, and programs to address those needs.

Figure 1: Community Profile
1 Packet Pg. 9 Page 600 of 894
Section 3 - Housing Constraints, Resources, and Fair Housing: Analyzes and recommends remedies for existing and potential governmental, nongovernmental, and environmental barriers to housing development. In addition, this section also includes the required Affirmatively Furthering Fair Housing (AFFH) section. Figure 2 on the following page illustrates these components, as addressed in this section.

Figure 2: Housing Constraints, Resources, and Fair Housing AFFH is a new requirement for the 6
th Cycle and is included per the requirements of a 2018 State law (AB 686). AB 686 requires the Housing Element to comprehensively analyze and 1 Packet Pg. 10 Page 601 of 894
address patterns of exclusion and segregation (looking both locally and regionally), and to identify meaningful actions and strategies to address those issues and their "contributing factors." The exhaustive AFFH analysis reflects detailed guidance provided by HCD, as well as best practices from other regions that have already gone through HCD review and certification.

The analysis relies on both approved data sets, as well as local knowledge and community input. The analysis includes the following:
 A summary of fair housing outreach and capacity that includes all economic segments of the community;
 An assessment of fair housing issues, including integration and segregation patterns, racially or ethnically concentrated areas of poverty, disparities in access to opportunity, and disproportionate housing needs for all identified populations. Many of the key issues reflect those identified more generally in the housing needs assessment, including overpayment for housing, particularly among renters, and lack of affordability that is most acute for the lower-wage workforce, the disabled, and seniors. Geographically, the area east of Brentwood Boulevard is identified as an area where there may be a greater risk for displacement of existing renters and lower-income residents. Lack of access to fair housing resources, especially for those that do not speak English as a primary language, was further identified as a contributing factor in fair housing issues;  An evaluation of whether the Housing Element's sites inventory improves or exacerbates conditions for fair housing. The analysis concludes that the sites inventory would not worsen fair housing conditions;
 The identification and prioritization of contributing factors related to fair housing issues.

Some of the key contributing factors to fair housing issues in Brentwood include the location and type of housing; lack of affordable, integrated housing for persons with special needs; displacement due to economic pressures; community opposition to housing over time; and lack of marketing and language access regarding housing opportunities and resources; and
 The identification of fair housing goals and actions that directly address the City's contributing factors.

Section 4: Housing Plan: The goals, policies, and programs (also called actions) are a key component in this section, representing the City's proposed "housing plan" with a focus on actionable steps and measures that the City will undertake to increase affordable housing and preserve and improve existing housing.

There are four main goals, with a corresponding set of policies and programs for each. Whereas the policies help to guide and inform future City decision-making and direction with respect to a broad range of housing-related topics, the programs provide actionable steps to implement the Housing Element's goals and to make further progress towards meeting the regional housing need allocation. Timeframes and responsibilities for each program are indicated in the text. The four main goals in the Housing Plan include the following:

H.1 - Housing Goal
Facilitate a diversity of housing opportunities to enhance the City’s living environment and to satisfy the shelter needs of all Brentwood residents.

H.2 - Affordability Goal
1 Packet Pg. 11 Page 602 of 894
Encourage housing that is affordable to all socio-economic segments of Brentwood’s population.

H.3 - Equitable Distribution of Affordable Housing Goal Encourage an equitable distribution of housing for all economic groups throughout the community.

H.4 - Housing Opportunities Goal
Promote equal housing opportunities for all residents of Brentwood.

In developing the policies and programs, staff used those included in the 5th Cycle Housing Element as a starting point, carrying forward many of the same underlying themes, concepts, and ideas. However, the 6
th Cycle Draft Housing Element revises and modifies some of the actions to clarify intent, improve specificity and address new State laws. (As a required component of the Housing Element, Appendix A provides a review of the 5th Cycle programs, evaluates the City's progress towards achieving the goals of the programs, and notes whether they have been continued, discontinued, or modified in the update.) Although the changes are limited, for the purposes of reviewing this draft, staff has indicated the correlation between the 5th Cycle and 6th Cycle goals, policies, and programs within the body of the Draft Housing Element by noting them all as either "[NEW]" or "[5th Cycle Action X, modified/expanded]" in brackets in the text. When modified from a prior policy/program, reference is provided back to the 5th Cycle program or policy in question.

Some of the new actions/programs may be required per State law (e.g., AB 2923, AB 1397, and SB 166), some are in response to the requirement to address housing constraints, and others are in response to feedback from the public, Planning Commission, and City Council. New policies and programs are annotated in the Draft Housing Element text with “[NEW]” for reference. Among these are new policies and programs to facilitate housing production, reflecting a range of housing types, sizes, affordability levels, and tenure, and provide access to housing opportunities that meet the diverse needs of the community, including:
 Action H.1b: Support and accommodate the development of Accessory Dwelling Units (ADUs) and Junior Accessory Dwelling Units (JADUs).
 Action H.1c: Monitor the development of ADU and JADU applications, location, affordability, and other relevant features to ensure adequate ADU development.  Action H.1m: Establish written procedures to comply with California Government Code Section 65913.4, as appropriate, to comply with the requirements of Senate Bill 35 (SB 35).
 Action H.1n: Encourage residential development on sites within the Sites Inventory and maximize the development potential, as well as promote existing residential incentives and identify potential new incentives, as appropriate.
 Action H.1o: Revise the General Plan to comply with the requirements of Senate Bill 1000 (SB 1000) to incorporate environmental justice policies within the General Plan and of Senate Bill 1035 (SB 1035) to identify flood hazards and address the risk of fire hazards in the City’s Safety Element.
1 Packet Pg. 12 Page 603 of 894
 Action H.1p: Adopt a replacement-housing program for units lost that are currently occupied by lower-income households or households subject to affordability requirements.
 Action H.1q: Monitor housing sites to ensure adequate sites to accommodate the remaining unmet RHNA by each income category pursuant to Senate Bill 330 (SB 330).  Action H.2i: Update the Density Bonus Ordinance in compliance with State law requirements.
 Action H.4a: Affirmatively further fair housing by taking meaningful actions that foster inclusive communities free from barriers, which restrict access to opportunities, based on protected classes.
 Action H.4h: Adopt regulations and procedures that establish a ministerial approval process for low-barrier navigation centers that meet specified requirements consistent with Senate Bill 48 (SB 48).
 Action H.4i: Encourage construction and rehabilitation of housing with supportive services targeted for persons with developmental disabilities, including exploring granting regulatory incentives.
 Action H.4j: Encourage opportunities to accommodate housing that can assist with individuals' transitions from homelessness, including Single Room Occupancy units (SROs).

New HCD guidelines also require that all new goals, policies, and programs are objective and quantifiable in nature. Based on these more stringent guidelines, staff has included specific quantifiable objectives into the following programs and shown in Table 1:
 Action H.1d: Monitor At-Risk Projects and develop strategies including potential expenditure of City housing funds to preserve their ongoing affordability. Housing projects are “at risk” if they are near to reverting or converting to market rate pricing. o Monitor units at-risk of converting to market-rate during the planning period.  Action H.1e: Encourage community education regarding the availability of rehabilitation programs.
o Assist in rehabilitating 30 housing units during the planning period.  Action H.2c: Provide a First-Time Homebuyer Assistance Program either directly or through regional partners.
o Assist 20 households during the planning period.
 Action H.2d: Explore a variety of potential financial assistance programs from both the public and private sectors to provide more affordable housing units and affordable housing assistance.
o Assist in providing assistance to 20 extremely low-, 50 very low-, and 50 lowincome units during the planning period.  Action H.4e: Encourage affordable housing developers to provide units for special needs persons or households, when feasible and appropriate.
1 Packet Pg. 13 Page 604 of 894
o Encourage construction of 50 special needs units (farmworker, affordable senior, disabled, developmentally disabled, large households, female-headed household, homeless) during the planning period.

Table 1: 6th Planning Cycle Quantified Objectives
Objectives
Units by Income Level
Extremely Total Units
Low
Very
Low Low Moderate Above Moderate
RHNA 402 232 247 641 1,522
Home Repair/
Rehabilitation 30 30
Special Needs Units 50 50
First-Time
Homebuyer 15 5 0 20
Affordable Housing
Assistance 20 50 50 0 0 120
At-Risk Housing
Units 6 0 0 6
Staff has reviewed the above-mentioned quantifiable objectives and believes that through existing City policies and programs, as well as the City’s affordable Housing Ordinance, the objectives are reasonably spread out over the eight-year planning period.

Appendix A - Review of Past Performance: This Appendix reviews the prior Housing Element to measure progress in implementing policies and programs. It likewise evaluates which programs were successful and should be continued, and which programs were ineffective and should be removed or modified. Examples of recommended modifications include integrating changes to reflect State law updates (e.g., no net loss (SB 166), the Housing Crisis Act (SB 330), supportive housing, environmental justice, etc.) and providing more specificity in terms of City actions.

Appendix B – Candidate Sites Analysis: Identifies locations of available sites for housing development to ensure that there is adequate capacity to address the RHNA in each of the affordability categories.

As shown in Appendix B, the City's existing zoning (i.e., residential development capacity that exists currently within Brentwood’s residential and mixed-use zoning districts) and "pipeline” 3 of
entitled projects is estimated to accommodate approximately 3,069 housing units; this number includes 135 ADUs that are assumed will be built during the Housing Element period.

As seen in Table 2, this estimated capacity reflects a buffer in each income category when compared to the total RHNA allocation (1,552 units), as recommended by HCD. Staff notes that based on City Council and LUD direction, the distribution of units across income categories varies somewhat from the estimates provided in earlier stages of the process. A majority of

3 HCD defines pipeline projects as residential projects that are approved, permitted, or receive a certificate of occupancy after the beginning of the RHNA period. 1 Packet Pg. 14 Page 605 of 894
those changes resulted in reducing the estimated capacity in PA-1 while increasing the affordability assumptions.

Table 2: Summary of Residential Capacity Analysis
Very LowIncomeLowIncomeModerateIncome
Above
ModerateIncomeTotal
2023-2031 RHNA
Allocation
402 232 247 641 1,552
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)
479 228 813 1,520
Vacant Residential
Land 156 68 222 446
Total Unit Potential 717 337 2,015 3,069
Units +/- and Buffer/Gap
%
+83 units, 13%
+90 units,
36%
+1,374
units, 214%
+1,966 units,
98%
This approach in the current draft was provided by the City Council and LUD in July and August, to allow the City to account for potential future changes to PA-1 currently under consideration by the City Council, review by HCD, and additional public input. The adequacy of the sites inventory will be evaluated by HCD. In any case, during the final phases of Housing Element review that will take place in early 2023, the City Council will be able to further modify the inventory to reflect any potential changes to PA-1.

Appendix C - Summary of Community Engagement: Summarizes community outreach and engagement meetings and surveys, with a particular focus on outreach to traditionally underrepresented groups. Included in Appendix D is a summary of input from the initial on-line community survey. The survey concluded in June and included 526 responses. This appendix will continue to be updated until the conclusion of the public review process.

Appendix D - Glossary of Housing Terms: This final section provides a comprehensive glossary of all of the acronyms and terms used throughout the Housing Element.

NEXT STEPS
Beyond this current round of review and comment, a number of critical steps remain in the Housing Element Update process, summarized in Figure 3 and described in more detail below.

Figure 3: Review Timeline
1 Packet Pg. 15 Page 606 of 894
 HCD Review of Draft Housing Element (October 2022 – January 2023 and January – March 2023): Following the public review period, the Draft Housing Element, including any revisions recommended by the City Council, will be submitted to HCD. Staff anticipates submitting the Draft Housing Element to HCD in mid-October. HCD then has a full 90 days to complete its review and provide comments to the City (i.e., HCD's initial comments would be expected in approximately mid-January 2023). Staff would likely be required to submit for a subsequent second and possible third draft to HCD for review (January – March 2023) following the initial review.
 Potential City Council, Planning Commission, and/or Public Meetings - Revised Draft Housing Element (January - April 2023): Following receipt of HCD comments, if staff determines that the comments are substantial in nature or that changes may impact current or existing policy direction, staff may be required to hold additional public meetings to seek input on potential revisions to the Housing Element, prior to its resubmittal to HCD. Until HCD provides initial comments, staff is unable to know if additional City Council direction will be required.
 Resubmittal of Housing Element to HCD (January - March 2023): The revised Housing Element must be re-submitted to HCD, which has 30-60 days to review the document and issue a letter of substantial compliance.
 Adoption Hearings (April-May 2023): The Planning Commission and City Council will conduct public hearings to consider adoption of the final Housing Element.

PUBLIC NOTICE
Advertisement of this item was published in The Brentwood Press on September 9, 2022. In addition, email notification was sent to all interested parties who have signed up on the Housing Element website (brentwoodhousingelement.com)

ENVIRONMENTAL ASSESSMENT
The City is still determining the appropriate level of environmental review for this project.

Environment review for this project is anticipated to evaluate the potential environmental 1 Packet Pg. 16 Page 607 of 894
impacts associated with the implementation of policies and programs included in the updated Housing Element. As currently proposed, no land use and zoning changes will be required. The final environmental assessment will be presented to the Planning Commission and City Council for consideration at the same time as the Housing Element adoption hearings.

FISCAL IMPACT
There is no financial impact anticipated as a result of this discussion. The cost of the update is included in the adopted 2022/23 – 2026/27 Capital Improvement Program (CIP), which includes the Housing Element Update and Safety Element Update, CIP Project No. 337-37258.

CONCLUSION
Staff seeks the City Council’s review and feedback on the Draft Housing Element, including any recommended revisions or modifications as well as authorization to revise the document accordingly and submit to HCD for its review.

Attachments:

Brentwood 6th Cycle Public Review Draft Housing Element 1 Packet Pg. 17 Page 608 of 894
Brentwood 2023-2031 Housing Element
Appendix C: Summary of Community Engagement C-13
C.8 Flyers/Outreach Materials
This section contains all outreach materials distributed to the community providing notice of the Housing Element Update process and opportunities for participation.