City Council Agenda
City of Campbell, 70 N. First St., Campbell, California
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SPECIAL MEETING OF THE CAMPBELL CITY COUNCIL
Tuesday, November 29, 2022 – 6:00 p.m.
City Hall Council Chamber - 70 N. First St., Campbell, California
CALL TO ORDER
ROLL CALL
PUBLIC COMMENT
UNFINISHED BUSINESS
1. Campbell’s Plan for Housing (2023 -2031 Housing Element) to Facilitate Further Refinement of the Housing Opportunity Map and Goals, Policies, and Programs Which Will G uide Housing Development and Services Throughout the Eight-Year Planning Period. (File No. PLN-2021-12) Recommended Action: Direct Staff to submit a revised HCD Draft of Campbell’s Plan for Housing (2023 -2031 Housing Element) to Housing and Community Development (HCD) for review, incorporating public feedback and proposed modifications.
2. Authorize the City Manager to Approve and Execute an Amendment to the Consultant Services Agreement with Metropolitan Planning Group to
Finalize Campbell’s Plan for H ousing (2023 -2031 Housing Element) and Initiate a Corresponding Budget Adjustment. (Resolution/Roll Call Vote) Recommended Action: Adopt a Resolution, authorizing the City Manager to approve and execute an amendment to the Consultant Services Agreement w ith Metropolitan Planning Group (M -Group) to finalize Campbell’s Plan for Housing (2023-2031 Housing Element); and initiate a budget adjustment to appropriate $150,000 for additional contract costs.
ADJOURN
IMPORTANT NOTICE: Materials related to an item o n this agenda submitted to the City Council after distribution of the agenda packet are available for public inspection with the agenda packet in the lobby of City Clerk’s Office, 70 N. First Street, Campbell, CA 95008, during normal business hours. These materials will also be available on the City website at https://www.ci.campbell.ca.us/agendacenter with the agenda packet following the last item of the agenda, subject to staff’s ability to post t he documents prior to the meeting. All documents not posted prior to the meeting will be posted the next business day.
In compliance with the Americans with Disabilities Act, listening assistive devices are available for all meetings held in the City Council Chambers. If you require accommodation, please contact the City Clerk’s Office, (408) 866-2117, at least one week in advance of the meeting.
City
Council
Report
TITLE: Campbell’s Plan for Housing (2023 -2031 Housing Element) to Facilitate Further Refinement of the Housing Opportunity Map and Goals, Policies, and Programs Which Will Guide Housing
Development and Services Throughout the Eight -Year Planning Period. (File No. PLN-2021-12)
RECOMMENDED ACTION
Direct Staff to submit a revised HCD Draft of Campbell’s Plan for Housing (2023 -2031 Housing Element) to Housing and Community Developm ent (HCD) for review, incorporating public feedback and proposed modifications.
BACKGROUND
The City of Campbell is completing its Envision Campbell (2040 General Plan) update in combination with the preparation of Campbell’s Plan for Housing (2023 -2031 Housing Element). The General Plan serves as the City’s blueprint for meeting the community’s long-term vision for the future. The Housing Element, which is part of the General Plan, serves to provide an analysis of the City’s housing needs, identify Housin g Opportunity Sites, and establish Goals, Policies, and Programs which will guide housing development and services throughout the eight -year planning period, demonstrating how the City will satisfy its RHNA (Regional Housing Needs Allocation) and comply wi th applicable housing policies and laws.
Between November 2021 and January 2022, the Planning Commission and City Council provided feedback on the Draft Housing Opportunity Sites (location and density) arriving at an initial inventory which could allow fo r up to 6,644 units. In arriving at this number, the City Council expressed an intent to reduce the total number and/or density of sites prior to final adoption of the Housing Element, following completion of the Environmental Impact Report (EIR), and cons idering additional public review and feedback from Housing and Community Development (HCD), HCD has recommended that all jurisdictions in California at minimum maintain a 30% buffer of Housing Opportunity Sites above the assigned RHNA in the Housing Element.
Between April 2022 and May 2022, the Planning Commission and City Council were presented with information on housing issues and contributing factors in the community, provided feedback on Goals, Policies and Programs aimed to address key challenges.
Item: 1
Category:
Meeting Date: November 29, 2022
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UNFINISHED BUSINESS
Campbell’s Plan for Housing (2023-2031 Housing Element) Page 2 of 28 Based on this feedback, staff prepared the Public Review Draft of Campbell’s Plan for Housing.
On June 9, 2022, the City of Campbell released its Public Review Draft of the Housing Element. The Public Review Draft was circulated for thirty -days for public c omment.
During the public comment period, the City received twelve (12) letters, and one late response.
On August 2, 2022, the City Council held a public hearing to review public comments and proposed modifications to the Draft of Campbell’s Plan for Ho using (2023 -2031 Housing Element) prior to submitting the document to Housing and Community Development (HCD) for their initial 90-day review.
On August 5, 2022, the City of Campbell published its Initial Review Draft of the Housing Element and submitted a copy to HCD for review. Following submittal, staff held deliberative video conference meetings with HCD staff to discuss their initial questions and comments on the Draft Housing Element. Initial feedback from HCD was identified by staff as falling with in two main categories: 1) technical revisions serving to clarify information presented in the Draft Housing Element; and 2) recommendations on modifications to policies and programs. HCD staff advised Campbell staff to consider releasing an updated draft of the Housing Element addressing the technical revisions prior to the distribution of HCD’s formal review letter, so that the letter could be more focused in scope.
On October 26, 2022, the City of Campbell published an updated version of the Housing Element with the technical revisions requested by HCD. This included updating the City’s homelessness figures to include the latest PIT (Point in Time) data and non - substantive clarifications to data, such as providing precise numbers where percentages had previously been provided.
On November 3, 2022, HCD issued its formal review letter on the City’s Draft Housing Element, and on November 15, 2022, staff met with HCD staff to discuss the comments (reference Attachment B – HCD Comment Letter). The subject report reflects recommendations resulting HCD feedback received to date.
On November 22, 2022 , the Planning Commission received a report on the same discussion points covered in this report. Feedback received from the Planning Commission will be provided as a desk item in advance of the meeting and summarized in the staff presentation.
PURPose
This meeting is intended to facilitate feedback from the City Council on p roposed refinements to the Housing Opportunity Map, as well as changes to Goals, Policies and Programs in Campbell’s “Plan for Housing” (2023-2031 Housing Element) responding to comments raised in the HCD Comment Letter (reference Attachment B). This item also 1 Packet Pg. 4
Campbell’s Plan for Housing (2023-2031 Housing Element) Page 3 of 28 serves to provide an update on the General Plan and associated Environmental Review (EIR) associated with the effort.
DISCUSSION
The discussion is organized into two main sections which focus on 1) refinements to the Housing Opportunity Map, and 2) amendments to the Housing Element Goals, Policies and Programs in response to the formal review letter received from HCD. The feedback received from the Council on these topics will be used to prepare the Final Housing Element that will be resubmitted to HCD for their review.
While this report summarizes the significant changes to the Housing Element warranting policy input and direction, staff is also separately completing a table that summarizes all HCD feedback received and staff’s intended response, to be provided to the Co uncil as a desk item.
1) Housing Opportunity Map Refinements
The City of Campbell’s assigned Regional Housing Needs Allocation (RHNA) for the 2023-2031 planning period is 2,977 units.
Table 1 – City of Campbell’s Regional Housing Needs Allocation
As an initial target, Campbell identified potential Housing Opportunity Sites and residential densities that would allow for the development of up to 6,640 units, a target that is over two times higher than the City’s RHNA. It is imp ortant to acknowledge that HCD will only provide “credit” for 5,139 of the 6,640 units identified using their applied methodology, which finds it unreasonable to assume every site will develop at the maximum allowable density, or at the level and mix of af fordability required (reference Attachment C - Housing Opportunity Methodology).
In developing the Draft Housing Opportunity Site Inventory, the Council expressed an intent to reduce the number and/or density of sites identified, prior to final adoption of the Housing Element, by retaining the best sites, and still maintaining a total number of housing units that is above the City’s RHNA plus a 30% buffer as recommended by HCD (approximately 3,870 units).
SITE REFINEMENT CRITERIA
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Campbell’s Plan for Housing (2023-2031 Housing Element) Page 4 of 28 Based on initial Counc il direction, staff identified the following factors recommended to be used as criteria to inform refinements to the Housing Opportunity Site Inventory (staff input, and HCD feedback where applicable, follow each point):
1. Property owner interest or disinterest in housing development.
While property owner interest, or disinterest, does not determine whether a site will be credited by HCD, it does play a significant role in the overall feasibility analysis.
Staff has identified several sites which may warr ant removal based on owner disinterest which is discussed in the following section.
2. Redevelopment potential of City-owned sites.
The Draft Housing Opportunity Site Inventory included two City -owned sites, the First Street Parking Garage, and the City Co rporation Yard. While staff is still in the process of evaluating the feasibility of redeveloping these two sites, a preliminary review of the Parking Assessment District and obligations related to the First Street Parking Garage make it unlikely to redeve lop during the eight - year planning period.
Further, since developing the Draft Housing Opportunity Site Inventory, AB 2097 passed which eliminated parking requirements for projects within ½ mile from public transit, and the City Council established a Sem i-Permanent Parklet program in the downtown. As both actions will result in higher dependency on the First Street Parking Garage to meet current and future downtown parking demand, its retention is warranted until a broader study of the Downtown parking needs is completed.
3. Results of the Draft Environmental Impact Report (EIR).
In developing the Draft Housing Opportunity Site Inventory, the Council identified that the Environmental Impact Report could be used to identify any environmental impacts associat ed with the sites and be used to inform the Council on further revisions or reductions.
The Draft Environmental Impact Report prepared for the General Plan and Housing Element updates did not identify any significant environmental impacts associated wit h specific housing opportunity sites and did not identify any alternatives in the size of the Housing Inventory that would lessen any identified significant environmental impacts (the EIR identifies significant and unavoidable environmental impacts associa ted with Greenhouse Gas Emissions, Air Quality, and Vehicle Miles Traveled - VMT).
As Campbell is located in a geographic central location, with access to mass transit and jobs, the EIR concluded that the provision of more housing sites would result in a reduced environmental impact related to VMT. 1 Packet Pg. 6
Campbell’s Plan for Housing (2023-2031 Housing Element) Page 5 of 28
4. Feedback from Housing and Community Development (HCD ) on the Draft Housing Opportunity Site Inventory.
In the comment letter, HCD provided five points related to the adequacy of the Draft Housing Opportunity Site Inventory:
• Opportunity Areas : HCD commented on the lack of units in higher opportunity or income areas, with a focus on census tracks located in the Northwest and Southeast portions of the city. In response, staff intends to highlight the role t hat SB 9, SB 10, and related programs and policies will address this concern, outside of the Housing Opportunity Sites identified.
This change does not impact the mapped sites.
• Small Sites: HCD commented that sites less than .5 acres are assumed to be inadequate to accommodate lower -income housing unless the city can provide evidence of success in the prior housing element cycle. In response, staff has assigned a greater allocation of moderate -income units to the 64 ‘small -sites’ sites identified, to bet ter adhere to HCD feedback and guidelines. This change does not impact the mapped sites.
• Large Sites : HCD noted that the Site Inventory includes one 16.4 -acre site, with an operating commercial shopping center (i.e., Pruneyard).
While noting there is int erest from the property owner, HCD requested additional clarification in the intended strategy to ‘carve out’ portions of the site for housing. In response, staff intends to provide a narrative to HCD explaining the City’s approach to assigning units to th e property, which provides for the retention of the shopping center. This change does not impact the mapped sites.
• City-owned Sites: In consideration of the two City-owned sites identified by the Housing Opportunity Site Inventory, HCD requested addition al documentation to substantiate the suitability and availability of the properties. Based on initial screening by staff, one of the two City -owned sites has been flagged for removal in response. This comment results in the loss of one site from the inventory.
• Nonvacant Sites : In review of the Housing Opportunity Site Inventory, HCD commented that the housing element relies on nonvacant sites to accommodate more than 50% of the RHNA for lower -income neighborhoods. As a result, HCD has requested the elemen t to provide additional documentation to demonstrate that existing uses will not be an impediment to residential development and will likely discontinue during the planning period – and document the outcomes of that analysis as findings in the resolution i ncluded in the adoption of the Housing Element. 1 Packet Pg. 7
Campbell’s Plan for Housing (2023-2031 Housing Element) Page 6 of 28 Staff acknowledges the comment and intends to provide the requested documentation. This change does not impact the mapped sites.
In addition to the comments included in the letter, in deliberative discussio ns HCD staff broadly advised against removing, or reducing the density, of sites included in the Draft Housing Opportunity Site Inventory. This broader guidance notwithstanding, HCD staff seemed receptive to removing sites where retention would conflict wi th a separate goal or objective (i.e., providing for open space and parks to affirmatively further fair housing) and in response to recent development activity that would impede housing development from occurring within the eight-year planning period.
5. Potential compatibility and adjacency issues identified by the Multi -Family Residential Design Standards work plan.
In developing the Draft Housing Opportunity Site Inventory, members of the City Council expressed concerns that the height and scale of new buildings may not be compatible with any adjacent lower -density residential neighborhoods. In response, staff recommended deferring consideration of such impacts until the Multi-Family Residential Development and Design Standards (hereinafter “Design Stand ards”) were further developed and able to depict how adjacency concerns may be addressed, and then make refinements to the Housing Opportunity Site Inventory in response.
While several tools, and approaches have been identified to address adjacency concerns (i.e., application of form -based zones, large site standards, adjacency standards), the Design Standards under development are not yet refined enough to be presented as solutions. However, the initial work on the Design Standards has shown that it may be difficult to apply design solutions that soften impacts of larger buildings on shallow or smaller lots that are adjacent to single family neighborhoods.
6. Potential for buildings to exceed the 75-foot Citywide height limit.
Members of the City Counc il expressed concerns that buildings may exceed the City-wide maximum height limit of 75 -feet in situations where developers seek approval of a density bonus on top of a higher density residential designation (i.e., 75-units per acre density that would be allowed on select sites near public transit).
In response, the Housing Element and Multi -Family Development and Design Standards will provide a suite of incentives (i.e., Affordable Housing Overlay Zone) and tools (i.e., application of form -based zones, large site standards, adjacency standards) to help encourage developers to stay under the Citywide height limit
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Campbell’s Plan for Housing (2023-2031 Housing Element) Page 7 of 28 While these incentives and tools will not rule out the possibility that buildings will exceed the maximum height limit, the likelihood will be significantly reduced.
While adjustments to the maximum density range may still be considered, staff recommends retaining the maximum density of 75 -units per acre where identified, recognizing market -rate and affordable housing developers have both expressed the need for this density to deliver low-income units to the community.
7. Initial Inventory Point Scores
During the initial housing opportunity site selection process, which occurred between November 2021, and January 2022, the Planning Commission and City Council evaluated sites based on a point score that considered several factors (1 point if “yes” for a factor, 0 points if not):
• Whether the site was greater than a half-acre in area • Whether the site yielded 50 or more units at maximum density. • Whether the site was in a good location (near many amenities, close to light rail, or in a High Opportunity area according to the Tax Credit Allocation Committee’s Opportunity Maps.
• Whether there was property owner interest.
• Whether redevelopment of the site w ould not displace a company that is one of Campbell’s top-100 sales tax producers.
Each of the 131 sites in the Site Inventory was given a point score from 1 (lowest score) to 5 (highest score). When considering refinements to the Housing Opportunity Site Inventory, the point score methodology may continue to play an important role. As a result, the staff recommendation, and options presented, consider removal of sites based on initial point scores.
8. Impact of SB6 & AB 2011 on the Housing Opportunity Site Inventory.
The adoption of two recent state bills (SB 6, AB 2011) will result in the production of more housing in Campbell by allowing for residential development on property zoned for retail and office space. There is inadequate time to study and anal yze to determine if Campbell could include additional housing opportunity sites affected by this legislation, particularly in relation to principles such as AFFH (Affirmatively Furthering Fair Housing), prior to the certification deadline (January 31, 2023 ). Once future guidance is provided by HCD regarding the implementation of these bills and their relationship to Housing Elements and Housing Opportunity sites, this could be considered in the future.
Proposed Refinements to Site Inventory
The followi ng discussion outlines three options, or landing points, which may be considered to refine the City’s Housing Opportunity Site Inventory. These options are intended to ensure the best sites identified are retained, while reducing the City’s Site 1 Packet Pg. 9
Campbell’s Plan for Housing (2023-2031 Housing Element) Page 8 of 28 Inventory, consistent with Council direction, while maintaining an inventory that is above the City’s RHNA plus the 30% buffer recommended by HCD (3,870 units). Considering that the Housing Opportunity Site Inventory needs to account for units at a variety of income levels, in addition to achieving a minimum number of units, staff strongly recommends selecting from the options presented to ensure that an adequate buffer in each income category can be achieved. As an example, if the density of large sites were reduced, and all small sites retained, while it may appear that the total number of units will be achieved, the site inventory will fail to provide for enough low -income housing since large sites have been assigned a higher allocation of low-income units.
Advantages and Disadvantages to a Larger Housing Opportunity Site Inventory
In considering further refinements and reductions to the Site Inventory, the Council should also broadly consider the programmatic advantages and disadvantages of having a site invento ry that is substantially higher than the assigned RHNA. These advantages and disadvantages are summarized below:
Advantages of a Higher Buffer (Larger Inventory)
1) Greater Opportunity for Housing Production – If the City maintains more properties available for housing development, there is a greater chance that enough housing development will occur over the upcoming eight -year Housing Element cycle to meet the City’s housing needs, consistent with the assigned RHNA. As described in prior housing element s taff reports, there are stronger penalties today for cities where actual housing production during the eight -year housing cycle does not meet the assigned RHNA, including a reduction in land use authority in discretionary review of housing projects. As it is unreasonable to assume that each designated housing opportunity site in the city will develop during the upcoming eight-year period, the retention of a broader number of housing sites allows more buffer and flexibility in allowing housing development t o occur at a rate that meets the City’s housing needs and assigned RHNA
2) No Net Loss Provisions – Recent State Legislation (AB 166) requires that the city maintain enough housing capacity under its zoning and general plan designations throughout the eight-year cycle to allow development that meets the City’s assigned RHNA. This legislation not only requires that the City maintain enough capacity for the overall production of housing units, but also document that the properties available for housing have su fficient capacity to allow affordable housing development, providing below market rate units (Moderate, Low, Very Low). The city currently has limited tools to support and facilitate affordable housing production but has identified the creation of new too ls under this Draft Housing Element (amended Inclusionary Housing Ordinance, Linkage Fees, Affordable Housing Overlay Zone, use of city land for affordable housing production) to be implemented in the near future. As it will take a few years for the City t o adopt and onboard these tools, it is likely that housing production in the near term will continue consistent with 1 Packet Pg. 10
Campbell’s Plan for Housing (2023-2031 Housing Element) Page 9 of 28 past practice, resulting in the development of market rate units with a small number of affordable units on housing opportunity sites.
Under this scenario, a risk will be that the development of housing sites at market rate will reduce the identified capacity of Campbell’s housing sites to support below market rate development, requiring Campbell to identify and rezone additional sites for housing during the upcoming eight -year cycle. Maintenance of a large Housing Opportunity Site Inventory will act to ensure that the City maintains sufficient capacity for the development of affordable housing throughout the upcoming cycle.
ABAG / MTC h as published a technical memo providing more narrative regarding this, found here.
Disadvantages of a Higher Buffer (Larger Inventory)
1) Eligibility for By-Right Permit Processing – Sites that the City identifies to support lower income (low - and very-low income) RHNA units may be eligible for “by right 1” processing when they were included in the prior planning period’s housing element (i.e., 5 th cycle housing element) for non -vacant sites, or included in two or more consecutive years (i.e., 4th and 5th cycle housing element) for vacant sites.
By designating fewer sites as housing opportunity sites, the city would reduce the risk that housing opportunity sites remain undeveloped and are thus carried over into a future housing cycle, retaining more land use authority and discretionary oversight.
However, it should be noted that even projects subject to a “by right” approval process, will still need t o comply with objective standards, such as those being prepared as part of the Multi-Family Development and Design Standards work plan.
2) SB 330 Challenges – Under Senate Bill 330 “The Housing Crisis Act of 2019”, jurisdictions are prohibited from downzonin g, or changing the land -use designation for residential and mixed -use areas if the change would result in less -intensive use of the property. As a result, it will be challenging for the city to reduce the density of a Housing Opportunity Site once designat ed, unless comparable increase in density were proposed elsewhere in the community in the same action. As a result, a disadvantage of having a larger housing site inventory is that the changes are largely permanent (you can go up, but not back down) and as a result, limit the City’s options to reconsider housing sites for a lower density or a designation to a non - residential designation in the future.
Refinements Recommended by Staff
As an initial action, staff has recommended the removal of eight (8) sites from the Sites Inventory based on one or more of the criteria outlined in the preceding section of this report, and as described further below.
1 By right means the jurisdiction shall not require a discretionary, local-government review or approval that would constitute a “project” as defined by the California Environmental Quality Act. 1 Packet Pg. 11
Campbell’s Plan for Housing (2023-2031 Housing Element) Page 10 of 28 • Former Denny’s on Bascom Avenue
o Property Owner Disinterest: The City received a letter from the propert y owner expressing disinterest in being designated as a housing opportunity site. While this factor alone is not a basis for removal, follow -up conversations with the ownership revealed that the site is owned by a corporation which is structured around the long-term ownership of commercial property – making redevelopment unlikely in the eight -year planning period.
o Site Reference Number: 152
o Units Lost: 38
Figure 1: Former Denny’s (Colored Red)
• Campbell Industrial Park
o Property Owner Disinterest: The City received a letter from multiple parties representing the ownership of the Campbell Industrial Park expressing disinterest in redeveloping the sites for housing. As sites 12.2, 212.1, and 212.1 recently have invested in façade improvements, and site 181 is nearly fully leased, it is unlikely that these sites will be redeveloped during the eight-year planning period.
o Site Reference Numbers: 12.2, 181, 212.1, and 212.2
o Units Lost: 108
Figure 2: Campbell Industrial Park (Colored Red)
• Former US Bank
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Campbell’s Plan for Housing (2023-2031 Housing Element) Page 11 of 28
o Property Owner Disinterest: While the City has not received a letter of expressing disinterest to redevelop the site for housing, the City recently approved a Conditional Use Permit to allow the relocation of a Social Security Administration office to sit e. As tenant improvements are now nearing completion, and the Social Security Administration has a long - term lease for the property, the likelihood that the subject site will redevelop during the eight-year planning period is very low.
o Site Reference Number: 271
o Units Lost: 17
Figure 3: Social Security Administration Building (Colored Red; with Arrow)
• Jack in the Box
o Property Owner Disinterest: While the City did not receive a letter expressing disinterest, staff acknowledges that Jack in the Box r arely sells its holdings. This is evidenced by the Jack in the Box located on S.
Bascom Avenue, not being sold in the redevelopment of the Revere mixed-use building which surrounds the site on two sides.
o Low Point Score: In addition to a presumed lack o f owner interest, the site scored low for retention due to the size of the site, recognizing it lacks a common owner as is the case with adjoining properties (Sites 268, 269, & 270).
o Site Reference Number: 268
o Units Lost: 11
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Campbell’s Plan for Housing (2023-2031 Housing Element) Page 12 of 28
Figure 4: Jack in the Box (Colored Red; with Arrow)
• First Street Parking Garage
o Redevelopment Potential of City -owned Sites: As previously mentioned, a preliminary review of the Parking Assessment District and obligations related to the First Street Parking Garage appear to make it unlikely to redevelop during the eight-year planning period.
o Potential Compatibility and Adjacency Issues: As the First Street Parking Garage is located across the street from a low -density residential neighborhood, redevelopment of the site at the pl anned for density of 75 - units per acre is anticipated to present compatibility and adjacency concerns for surrounding residents.
o Site Reference Number:3
o Units Lost: 76
Figure 5: First Street Parking Garage (Colored Red)
Additional Site Inventory Refinements - Options
The following discussion outlines two additional options to be considered as refinements to the City’s Housing Opportunity Site Inventory, in addition to the option of only incorporating the initial reductions recommended by staff. The se options are discussed below and depicted in the attached exhibit (reference Attachment A – Housing Opportunity Map Options).
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Campbell’s Plan for Housing (2023-2031 Housing Element) Page 13 of 28
Figure 6: Options Overview
1. Option 1 – Staff Recommended Refinements (4,899 units):
This option would only include remo val of the eight (8) sites identified by staff as described above. Removing these sites from the inventory would result in a total of 123 sites containing 4,899 units. Under this option, the city would maintain a Housing Inventory that is 26.5% above the H CD recommended RHNA ( 4,899 units per Option 1 vs. 3,870 units to achieve RHNA + 30% buffer).
2. Option 2 – Remove Campbell Technology Park (4,446 units):
Option 2 focuses on the removal of the Campbell Technology Park which contains a total of 453 units. Removing these four sites from the inventory would result in a total of 119 sites containing 4,446 units. Under this option, the city would maintain a Housing Inventory that is 14.8% above the HCD recommended RHNA (4,446 units per Option 2 vs. 3,870 units to achieve RHNA + 30% buffer).
Figure 7: Additional Sites Removed Under Option 2 (Brown Crosshatch)
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Campbell’s Plan for Housing (2023-2031 Housing Element) Page 14 of 28 The Campbell Technology Park has been flagged for removal by Option 2 in consideration it received low point scores in categories of access to public transit, grocery, and schools, despite being adjacent to a public park.
While the property owner has expressed interest in redeveloping the site, and identified high vacancy rates within the office park, recent correspondence expresses an interest to reduce the planned density of the site from the intended 26-33 units per acre, to 18 -25 units per acre, to allow the development of detached single-family homes and townhomes (reference Attachment D – Letter Requesting Reduction in Density for Campbell Technology Park).
Separately, it is recognized that the city has a vested interest in the redevelopment of the site as it remains subject to a Disposition and Development Agreement with the city, related to past actions of the City’s Redevelopment Agency (RDA). Recognizing market conditions may not support redevelopment of the site at a density appropriate for the area, and in consideration of the development agreement, the site may warrant removal.
However, staff has recommended that the city maintain the City ’s Corporation Yard as a Housing Opportunity Site and has identified the Campbell Technology Park as a potential option for relocation of the Corporation Yard to allow development of housing at the Corp Yard. Thus, the city may want to keep the site (as a whole or a portion) open for consideration as a Housing Opportunity Site, as a candidate for a potential land swap with the City Corporation Yard.
3. Option 3 – Reduced Inventory (3,889 units):
Option 3 focuses on the removal of 42 sites throughout the c ity which contain a total of 1,010 units. Removing these sites from the Inventory would result in a Housing Inventory with a total of 77 sites, containing 3,889 units. Under this option, the city would maintain a Housing Inventory that is .04% above the assigned RHNA ( 3,889 units per Option 3 vs. 3,870 units to achieve RHNA + 30% buffer).
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Campbell’s Plan for Housing (2023-2031 Housing Element) Page 15 of 28
Figures 8 & 9: Additional Sites Removed per Option 3 – Southwest of Downtown
Figure 10: Additional Site Removed per Option 3 – East of Hamilton Station
Figure 11: Additional Sites Removed per Option 3 – North of Winchester Station
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Campbell’s Plan for Housing (2023-2031 Housing Element) Page 16 of 28 Figure 12: Additional Site Removed per Option 3 – East of Pruneyard
These sites have been flagged for removal due to a combination of their low point score value, small size, and u nit count (properties East of Downtown were originally screened out based on this methodology; but added back in response to Council comments). These sites have also been flagged for removal in response to a lack of interest by the property owners (no lett ers have been received expressing interest in their development).
In addition to the sites identified above, Option 3 would also result in the removal of Site 49 (320 Virginia Avenue). This site is distinct from the others included in Option 3, given that the site is larger and has received a developer interest letter.
Nevertheless, Site 49 has been flagged for removal by Option 3 in consideration the property is the only site in the City’s Housing Opportunity Site Inventory with an open space land use de signation, and that the city may want to consider whether the site should be redeveloped as a public park – recognizing the city needs to plan for new parks to meet residential need in association of new housing.
Figure 13: Additional Site Removed per Option 3 – Near John D. Morgan Park
All these sites are also considered for removal, due to the fact they are anticipated to result in very few, if any, low-income units.
4. Option 4 – Reduced Densities (4,676 units):
Where the previous three options focu s on removing sites, Option 4 shows the impact of reducing densities on select sites due to their proximity to low -density residential neighborhoods. This Option is presented for consideration, recognizing previous Council feedback to limit the impact of l arger buildings on adjacent single-family neighborhoods. Initial work completed for the Multi-Family Development and Design Standards under development , has shown that it is more difficult to apply feasible design tools that buffer the visual intrusion of higher density residential development on adjacent residential neighborhoods on smaller lots. The following summarizes the sites, and density of adjoining uses that may result in compatibility concerns.
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Campbell’s Plan for Housing (2023-2031 Housing Element) Page 17 of 28
• San Tomas Plaza
o Site Reference Number: 207
o Existing Land Use: Neighborhood Commercial
o Studied Density per Housing Element: 60 Units / Gr. Acre o Proposed Density under Option 4: 45 Units / Gr. Acre o Neighboring Residential Land Uses:
▪ 14-20 Units / Gr. Acre (East/North)
▪ <6 Units / Gr. Acre (Northwest)
o Units Lost: 102
Figure 14: San Tomas Plaza (Site: 207)
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Campbell’s Plan for Housing (2023-2031 Housing Element) Page 18 of 28
Figure 15: San Tomas Plaza – Adjacent Residential Land Uses
• Bascom Avenue Properties
o Site Reference Numbers: 155, 276, & 277
o Existing Land Use: General Commercial
o Studied Density per Housing Element: 45 Units / Gr. Acre o Proposed Density under Option 4: 26-33 Units / Gr. Acre
o Neighboring Residential Land Uses:
▪ <6 Units / Gr. Acre (East of Site 276 & 277)
▪ 6-13 Units / Gr. Acre (East of Site 155)
o Units Lost: 8
Figure 16: South Bascom Avenue Properties (Sites: 155, 276 & 277)
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Campbell’s Plan for Housing (2023-2031 Housing Element) Page 19 of 28
Figure 17: South Bascom Avenue Properties – Adjacent Residential Land Uses
• South Campbell Avenue Properties
o Site Reference Number: Multiple
o Existing Land Use: Mixed-Use (14-27 Units / Gr. Ac.) o Studied Density per Housing Element: 60 Units / Gr. Acre o Proposed Density under Option 4: 45 Units / Gr. Acre
o Neighboring Residential Land Uses:
▪ 14 to 27 Units / Gr. Acre (South & East)
▪ 27 Units / Gr. Acre (North)
o Units Lost: 97
Figure 18: South Campbell Properties (Sites: As Depicted with Crosshatch)
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Campbell’s Plan for Housing (2023-2031 Housing Element) Page 20 of 28
Figure 19: South Bascom Avenue Properties – Adjacent Residential Land Uses
• Winchester Boulevard Properties
o Site Reference Number: 155, 276, & 277
o Existing Land Use: Central Commercial
o Studied Density per Housing Element: 45 Units / Gr. Acre o Proposed Density under Option 4: 26-33 Units / Gr. Acre
o Neighboring Residential Land Uses:
▪ <6 Units / Gr. Acre (West; Select Sites)
▪ 6-13 Units / Gr. Acre & 14-20 Units / Gr. Acre (East; Select Sites)
o Units Lost: 16
Figure 20: Winchester Boulevard (Sites: 31, 36, 39,119, 188, & 282)
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Campbell’s Plan for Housing (2023-2031 Housing Element) Page 21 of 28
Figure 21: Winchester Boulevard Properties – Adjacent Residential Land Uses
Options Summary: The following table summarizes the options presented:
Option Summary Unit
Count
Site
Count
Buffer over HCD
Recommendation
Why this Option?
Option 1: Staff
Recommended 4,899
123 26.5% Greatest Buffer
Option 2: Remove Tech. Park 4,446 119 14.8% Low Score; Corp. Yard Option 3: Reduced Inventory 3,889 81 .004% Smallest Buffer Option 4: Reduced Densities 4,676 123 20.8% Sensitive to Residential
As indicated, Option 1 will provide for the greatest number of units, and buffer, beyond the RHNA + 30% recommended by HCD (3,870 units), whereas Option 3 would result in the lowest unit count and buffer. Options 2 through 3 include the removal of the eight sites identified by Option 1.
➢ Staff Recommendation : In consideration of the options presented, staff recommends pursing Option 1, which would result in the retention of all sites and densities except the eight (8) proper ties identified for removal in red . Out of the options presented, staff believes this option is most likely to be accepted by HCD, and as a result, help ensure that the Housing Element will be certified in time.
Option 1 is also recommended by staff sinc e it will provide for additional development capacity that may be required if sites do not develop at the density, or the level and affordability required, recognizing that the SB 166 will require that adequate development opportunities remain available th roughout the eight -year planning period. Finally, this option is recommended by staff to as it helps ensure sites are well dispersed throughout the city also supports strategies and objectives related to Affirmatively Furthering Fair Housing (AFFH).
2) Goals, Policies, and Program Refinements
In addition to considering further refinements to the Housing Inventory, staff is also asking the Commission and Council to provide feedback concerning proposed 1 Packet Pg. 23
Campbell’s Plan for Housing (2023-2031 Housing Element) Page 22 of 28 modifications to the Goals, Policies and Programs in the H ousing Element, in response to the feedback received from HCD. The intent of housing goals, policies, and programs is to provide strategic guidance on how to address specific housing issues and achieve identified objectives. For example, the adoption of an inclusionary housing ordinance and commercial linkage fees are actions that implement the goal of improving housing affordability in Campbell.
HCD’s November 3, 2022, letter on the Draft Housing Element provided comments in several areas requesting that the City modify certain policies and programs to address housing issues and special interest areas. From all the comments included in the HCD letter, staff has identified five major areas that warrant further discussion with the Planning Commission and C ity Council concerning proposed modifications to the Housing Element. These are areas where staff has identified that new policies and programs are needed or areas where staff recommends broader or more systematic modifications to the Housing Element. In addition to these five major areas, there are additional modifications required to the Housing Element to respond to HCD comments.
However, this entails either (a) non -substantial modifications to the document to create better clarity or explanation rega rding a housing topic or program or (b) the provision of additional data and information that will help explain a housing topic or program with recommended modifications to the Housing Element.
Staff is currently finalizing a table documenting all the com ments provided in the HCD letter and the recommended responses by the city (in both the major areas and non - substantive areas) that will be provided to the City Council as a desk item prior to the November 29, 2022, meeting.
The five major areas warrant ing Commission and Council discussion are (a) Homelessness (b) Preservation of At -Risk Units (c) Affirmatively Furthering Fair Housing (d) Housing related Ordinance updates, and (e) Stronger commitment to milestones and actions associated with Housing Programs, as discussed further below:
A. Homelessness
As required by State Law, the Housing Element is required to identify how the city will address the housing needs of all members of the community, including any individuals that are currently unhoused (homele ss). The Draft Housing Element published on October 26, 2022, has several identified policies and programs addressing homelessness, including Policy H -5e, which identifies city support for the agencies that provide services to unhoused individuals and dis tribution of information connecting unhoused individuals to these service agencies.
The HCD Comment letter includes several sections that request that Campbell develop and implement strategies addressing homelessness within the City. This includes individual comments on pages 3 and 4 of the letter identifying the need for the City to provide Extremely Low Income housing and permanent supportive housing for the homeless.
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Campbell’s Plan for Housing (2023-2031 Housing Element) Page 23 of 28 In addition, on October 25, 2022, the County published its Point in Time (PIT) co unts for the Homeless population throughout Santa Clara County that identifies homeless counts within each city in the County. As shown within the published report, Campbell’s unhoused population has increased by 191% since the last count in 2019, increas ing from 74 to 216. Compared with all other cities in Santa Clara County, this represents the highest percentage increase between these reporting periods. The increase in Campbell’s homeless population is highlighted in the HCD letter with a request for t he City to implement more policies and programs addressing homelessness.
Staff recommends that the city enfold in the following programs and actions into the Housing Element addressing homelessness.
• Pursuit of a HomeKey project to create Permanent Sup portive Housing – The State’s HomeKey program provides funding for permanent supportive housing projects including the conversion of motel or hotel rooms into housing units. There are many successful examples throughout California of cities that have used this program to convert motels into housing for extremely low-income individuals who are either homeless or at risk of becoming homeless. One motel in Campbell, the Motel 6, was previously used during the Covid pandemic for a RoomKey project to provide emergency temporary housing. Staff recommends that the City commit to pursuing creation of a permanent supportive housing project in Campbell using HomeKey funding. Under this approach, the City would identify eligible hotels and motels, contact their ownership for interest, and actively apply for HomeKey funding, utilizing support from the County Office of Supportive Housing and potentially the Housing Authority.
• Unhoused Specialist / Homeless Coordinator – The City could hire an unhoused specialist / h omeless coordinator position who would be tasked with directly interfacing with homeless individuals in Campbell, to identify their needs and provide assistance in connecting them to housing and other related services. For comparative purposes, the City of Morgan Hill funds an unhoused specialist that has been successful in working with and supporting the needs of the homeless community. The City could create a full - or part -time staff position or hire a contractor to provide the services. In addition, a s the homeless population is often not geographically bound within one city, Campbell can work with other cities in the West Valley area, including Los Gatos, Saratoga, Monte Sereno, and Cupertino on potential shared funding and support of a coordinator th at provides these support services between the jurisdictions.
• Support of the County of Santa Clara Rapid Rehousing Program – the County currently operates a Rapid Rehousing Program that provides direct financial support and services that act to prevent i ndividuals at risk of becoming homeless or entering homelessness. Campbell can commit to provide more direct financial support to this program to help support Campbell residents that are at risk of homelessness.
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Campbell’s Plan for Housing (2023-2031 Housing Element) Page 24 of 28 • Safe Parking Program – The City’s Campin g Ordinance allows for safe parking programs at Religious Institutions in the City. This allows homeless individuals living in cars or recreational vehicles to park in a secure location and obtain access to onsite services, such as washing / bathing facil ities. The City could provide additional support into this program by providing financial assistance or other services needed to manage the safe parking program.
• Cold Weather Shelter – A cold weather shelter would provide temporary emergency housing to homeless individuals during the coldest days of the year. The City currently operates a cooling center at the Community Center that provides refuge to individuals during the hottest days of the year. The City could support a Cold Weather Shelter by eithe r (a) providing financial support to a religious institution (such as the payment for a security guard) to operate a cold weather shelter or it could identify a space within the Community Center that could be used as a cold weather shelter during very cold days and inclement weather.
B. Preservation of At-Risk Units
The HCD Letter has also requests the City address approximately housing 73 units in the City that will lose below market rate regulatory protections by 2026. As shown in table II -13 of the Hou sing Element, approximately 70 units within the Avalon Bay Housing complex and 3 units within the Gateway project are scheduled to lose existing below market rate regulatory protections in 2026.
Correspondingly, staff has identified the following action s to address this risk and preserve the units as below market rate units.
• Initiate discussions with property owners of these facilities in 2023, three years prior to the expiration, to identify the upcoming expiration date and monitor adherence to tenant noticing requirements.
• Identify and apply for funding sources by 2024 to maintain below market rate affordability of the housing units. Funding from these grant programs would be used to “buy down” the affordability of the at -risk units from a market rate price to below market rate for up to 20 additional years.
• Present preservation options and incentives to owners (rehabilitation assistance and / or mortgage refinance in exchange for long term restrictions) in 2024.
• Work with property owners and pri ority purchasers to implement long term restrictions or actions to maintain affordability in 2025
• Coordinate technical assistance and education with affected tenants in 2025
1 Packet Pg. 26
Campbell’s Plan for Housing (2023-2031 Housing Element) Page 25 of 28 C. Affirmatively Furthering Fair Housing (AFFH)
Under Housing Law, the City must i nclude in its Housing Element actions that address fair housing Issues within the City and must take actions that “affirmatively further fair housing”. This could include actions ensuring that all residents in Campbell, irrespective of race and socio -economic status, have fair access to housing and services within the City and actions by the City to address any legacy issues of racial discrimination or exclusionary practices that have led to segregation. The Draft Housing Element includes several policies a nd programs that address AFFH, specifically Programs H5a through H5y which include actions that address fair housing issues and address special needs populations.
The HCD Letter requests that Campbell provide more policies and programs addressing fair housing, specifically identifying how Campbell will (a) provide more affordable housing opportunities within the City and in areas identified as high resource areas (more affluent and less diverse areas) (b) provide equitable services to areas of the City that are identified as moderate resource based (less affluent and more diverse) and (c) provide broader opportunities for under -represented communities to actively participate in the City’s housing policy and program development.
In response to (a) and (b) above, staff has not identified the need to create new AFFH policies or programs within the Housing Element but is modifying the document to more clearly show how the City has proposed programs and actions that will address the identified fair housing areas. Specifically, the revisions will show that the city has programs to support creation of more affordable housing in the high resource areas of the city to diversify the types of housing that is available and provide more socio - economic diversity. This includes implementing an affordable housing overlay zone, updating its inclusionary housing ordinance and commercial linkage fees, facilitating more ADU production, pursuing an SB 10 ordinance, and utilizing City owned land (the City’s corporation yar d) to create more affordable housing in these areas. In addition, the revisions will document programs and resources the City implements in moderate resource areas to provide greater services and support housing rehabilitation and prevent tenant displacement.
• Housing Commission - In response to (c), staff recommends the City pursue creation of a Housing Commission to allow public engagement and involvement in the implementation of housing policies and programs. Other cities in the County, including Cu pertino, Sunnyvale, Mountain View, and San Jose have Housing Commissions that advise the City Council on housing policies and programs. The structure of the Commission can be designed to foster greater participation and representation by underserved commu nities, including seats allocated to geographic areas or represented by renters in the city.
D. Housing Ordinance Updates
1 Packet Pg. 27
Campbell’s Plan for Housing (2023-2031 Housing Element) Page 26 of 28 Several comments in the HCD Letter request that Campbell update its ordinances to comply with applicable housing laws or remove barr iers to housing production. This includes compliance with State Laws regarding group homes, ADU standards, emergency shelters, permanent supportive housing, and Single Room Occupancy units.
The letter also requests that Campbell identify firm commitments to approve ordinance updates that will facilitate different types of housing unit production (missing middle) and revise parking standards.
Staff recommends adding modifications to the Housing Element identifying that the City will update its ordinances in these areas by December 2023.
Staff believes that a majority of the requested ordinance updates can be accomplished in March 2023. Several of the requested ordinance updates are already included within the workplan to create objective standards, s uch as revisions to parking standards and removal of barriers to allow different types of housing unit production (missing middle).
Several of the requested ordinance updates to comply with State Law can be enfolded into this work effort.
E. Stronger Com mitment to Milestones and Actions associated with Housing programs
Comments within the HCD Letter request that the City identify clearer milestones and commitments to implement identified Housing Programs and Policies. For example, the HCD letter identif ied that several of the City’s programs uses actions such as “study” “evaluate” and “explore” to characterize implementation and requests the city identify clearer process steps, milestones, deliverables, and measurable outcomes.
Correspondingly, staff recommends that the Housing Element be modified to identify more tangible process steps and milestones. For example, regarding Commercial Linkage Fees (Program H1 -b) staff recommends that current language only identifying that a nexus study will be completed by December 2023 be updated to add that the City Council will consider adoption of municipal code ordinances implementing a commercial linkage fee, following completion of a nexus study, in 2024.
GENERAL PLAN & EIR
During the 45-day public review and comment period on the Draft Environmental Impact Report (EIR) and Draft General Plan, the City received six (6) written comment letters that address either the General Plan policy document, the Draft EIR, or some combination of the two. All comments rec eived which relate to the Draft EIR will be responded to in detail as part of the Final EIR. Additionally, staff will compile and organize all comments related to the General Plan policy document and/or Land Use Map, and will present these comments, along with staff recommendations, to the Planning Commission and City Council at a future meeting to receive direction on whether changes should be made to the Draft General Plan.
1 Packet Pg. 28
Campbell’s Plan for Housing (2023-2031 Housing Element) Page 27 of 28 Following City finalization of the Housing Element, the Draft General Plan wil l be reviewed for consistency with the Housing Element, and may be slightly revised, as needed, to ensure consistency between the two documents. This may include revisions to the Land Use Map to reflect the final Housing Element Opportunity Sites, minor clean-up of simple mapping errors identified by staff, as well as any minor text changes to ensure policy consistency between the two documents.
Overall, work on the General Plan will largely be “on -hold” until such time that the city finalizes the Housi ng Element and receives direction from HCD that no additional changes or revisions are required to receive certification.
FISCAL IMPACTS
Both the City’s Housing Opportunity Site Inventory & Goals, Policies, & Programs will result in fiscal impacts. Staff is currently evaluating potential grant funding to support several of the programs described. For example, the City can apply for a Destination Home Capacity Building Grant to financially support an unhoused specialist and for additional consulting / st aff support to help develop a Permanent Supportive Housing project. Staff will intend to return with a consolidated, cost estimate, of all changes in March 2023, for review and consideration with the adoption of the General Plan and Housing Element.
NEXT STEPS
Based on feedback received from the City Council on this item, staff will finalize the Housing Element (incorporating direction, and providing responses to all details and data requested by HCD) and submit the Housing Element back to HCD for review and approval. Following acceptance of the changes by HCD, the Housing Element will return for review and adoption with the General Plan, and Multi -Family Development and Design Standards under development in March of 2023.
Prepared by:
Stephen Rose, Senior Planner
Reviewed by:
1 Packet Pg. 29
Rob Eastwood, Community Development Director
Campbell’s Plan for Housing (2023-2031 Housing Element) Page 28 of 28 Attachment:
a. Refined Housing Opportunity Site Inventory
b. HCD Comment Letter, November 3, 2022
c. Housing Opportunity Methodology
d. Letter Requesting Reduction in Density
1 Packet Pg. 30
Approved by:
Brian Loventhal, City Manager
City of Campbell
6th Cycle Housing Element
Site Inventory Modifications
0 0.5 10.25 Mile
Option 1 (Staff
Recommendation: 4,899
Units)
Keep
Remove
Option 2 (Moderate
Site Inventory: 4,446
Units)
Option 3 (Reduced Site
Inventory: 3,889 Units)
Light Rail Stations
City Boundary
17 85
San Tomas Expy
Winchester Blvd
Hamilton Ave
Campbell Ave
Bascom Ave
Winchester Blvd
Bascom Ave
Hacienda Ave
1.a
Packet Pg. 31
Attachment: Refined Housing Opportunity Site Inventory (Campbell’s Plan for Housing (2023-2031 17 1
132
12.2 94.2
202.1
248241
19 202.2
242 285.3
212.1
136
279
3 219
220
135
91 89
250
21 239
146
31 214.1
35 276
221
243
92.2 90
100.392.1
256
246
159
152
212.2
283
245
145
278
155
181
56 116
62 257
22 258
259
139 25
100.2
260
63 4
214.4
238
277
170
285.2
28 94.1
93.297
93.1 33
95 143.2141
100.1
City of Campbell
6th Cycle Housing Element
Site Inventory Modifications
0 0.25 0.50.13 Mile
Sheet 1 of 5
NE Quadrant
Option 1 (Staff
Recommendation: 4,899
Units)
Keep
Remove
Option 2 (Moderate
Site Inventory: 4,446
Units)
Option 3 (Reduced Site
Inventory: 3,889 Units)
City Boundary
Light Rail Stations
1.a
Packet Pg. 32
Attachment: Refined Housing Opportunity Site Inventory (Campbell’s Plan for Housing (2023-2031 Housing Element)) 188
49 119
165
39 31
274
282
268
121
51204
275
162
286
164
139
36 167
284
5 168
271
179
207
273
205
270
197
269
12.1 192
City of Campbell
6th Cycle Housing Element
Site Inventory Modifications
0 0.25 0.50.13 Mile
Sheet 2 of 5
NW Quadrant
Option 1 (Staff
Recommendation: 4,899
Units)
Keep
Remove
Option 2 (Moderate
Site Inventory: 4,446
Units)
Option 3 (Reduced Site
Inventory: 3,889 Units)
City Boundary
Light Rail Stations
1.a
Packet Pg. 33
Attachment: Refined Housing Opportunity Site Inventory (Campbell’s Plan for Housing (2023-2031 Housing Element)) 32 188
18 49 119
209
7 31
190.2
282
121
191
190.1
23 36
272
30 5
218.1
168
27 218.2
192
29 218.3
190.3
City of Campbell
6th Cycle Housing Element
Site Inventory Modifications
0 0.25 0.50.13 Mile
Sheet 3 of 5
SW Quadrant
Option 1 (Staff
Recommendation: 4,899
Units)
Keep
Remove
Option 2 (Moderate
Site Inventory: 4,446
Units)
Option 3 (Reduced Site
Inventory: 3,889 Units)
City Boundary
Light Rail Stations
1.a
Packet Pg. 34
Attachment: Refined Housing Opportunity Site Inventory (Campbell’s Plan for Housing (2023-2031 Housing Element)) 32 214.2
188
132
49 119
7 31
214.3
214.1
190.2
282
121
191
190.1
36 30
214.4
5 168
192
190.3
City of Campbell
6th Cycle Housing Element
Site Inventory Modifications
0 0.25 0.50.13 Mile
Sheet 4 of 5
SE Quadrant
Option 1 (Staff
Recommendation: 4,899
Units)
Keep
Remove
Option 2 (Moderate
Site Inventory: 4,446
Units)
Option 3 (Reduced Site
Inventory: 3,889 Units)
City Boundary
Light Rail Stations
1.a
Packet Pg. 35
Attachment: Refined Housing Opportunity Site Inventory (Campbell’s Plan for Housing (2023-2031 Housing Element)) 132
244
94.2 119
240 248
241
19 242
285.3
3 91
89 250
21 239
39 31
243
282
92.2 254
255 90
92.1 256
246
245
285.1
62 257
22 258
259
139 25
36 260
261
63 262
214.4
238
179
263
285.2
28 94.1
93.2 97
266
93.1 33
95 City of Campbell
6th Cycle Housing Element
Site Inventory Modifications
0 0.09 0.180.05 Mile
Sheet 5 of 5
Downtown Focus
Option 1 (Staff
Recommendation: 4,899
Units)
Keep
Remove
Option 2 (Moderate
Site Inventory: 4,446
Units)
Option 3 (Reduced Site
Inventory: 3,889 Units)
City Boundary
Light Rail Stations
1.a
Packet Pg. 36
Attachment: Refined Housing Opportunity Site Inventory (Campbell’s Plan for Housing (2023-2031 Housing Element)) City of Campbell
6th Cycle Housing Element
Site Inventory Modifications
0 0.5 10.25 Mile
Option 1 (Staff
Recommendation: 4,899
Units)
Keep
Remove
Option 4 (Selected
Reduced Densities:
4,676 Units)
Light Rail Stations
City Boundary
17 85
San Tomas Expy
Winchester Blvd
Hamilton Ave
Campbell Ave
Bascom Ave
Winchester Blvd
Bascom Ave
Hacienda Ave
1.a
Packet Pg. 37
Attachment: Refined Housing Opportunity Site Inventory (Campbell’s Plan for Housing (2023-2031 17 1
132
12.2 94.2
202.1
248241
19 202.2
242 285.3
212.1
136
279
3 219
220
135
91 89
250
21 239
146
31 214.1
35 276
221
243
92.2 90
100.392.1
256
246
159
152
212.2
283
245
145
278
155
181
56 116
62 257
22 258
259
139 25
100.2
260
63 4
214.4
238
277
170
285.2
28 94.1
93.297
93.1 33
95 143.2141
100.1
City of Campbell
6th Cycle Housing Element
Site Inventory Modifications
0 0.25 0.50.13 Mile
Sheet 1 of 5
NE Quadrant
Option 1 (Staff
Recommendation: 4,899
Units)
Keep
Remove
Option 4 (Selected
Reduced Densities:
4,676 Units)
City Boundary
Light Rail Stations
1.a
Packet Pg. 38
Attachment: Refined Housing Opportunity Site Inventory (Campbell’s Plan for Housing (2023-2031 Housing Element)) 188
49 119
165
39 31
274
282
268
121
51204
275
162
286
164
139
36 167
284
5 168
271
179
207
273
205
270
197
269
12.1 192
City of Campbell
6th Cycle Housing Element
Site Inventory Modifications
0 0.25 0.50.13 Mile
Sheet 2 of 5
NW Quadrant
Option 1 (Staff
Recommendation: 4,899
Units)
Keep
Remove
Option 4 (Selected
Reduced Densities:
4,676 Units)
City Boundary
Light Rail Stations
1.a
Packet Pg. 39
Attachment: Refined Housing Opportunity Site Inventory (Campbell’s Plan for Housing (2023-2031 Housing Element)) 32 188
18 49 119
209
7 31
190.2
282
121
191
190.1
23 36
272
30 5
218.1
168
27 218.2
192
29 218.3
190.3
City of Campbell
6th Cycle Housing Element
Site Inventory Modifications
0 0.25 0.50.13 Mile
Sheet 3 of 5
SW Quadrant
Option 1 (Staff
Recommendation: 4,899
Units)
Keep
Remove
Option 4 (Selected
Reduced Densities:
4,676 Units)
City Boundary
Light Rail Stations
1.a
Packet Pg. 40
Attachment: Refined Housing Opportunity Site Inventory (Campbell’s Plan for Housing (2023-2031 Housing Element)) 32 214.2
188
132
49 119
7 31
214.3
214.1
190.2
282
121
191
190.1
36 30
214.4
5 168
192
190.3
City of Campbell
6th Cycle Housing Element
Site Inventory Modifications
0 0.25 0.50.13 Mile
Sheet 4 of 5
SE Quadrant
Option 1 (Staff
Recommendation: 4,899
Units)
Keep
Remove
Option 4 (Selected
Reduced Densities:
4,676 Units)
City Boundary
Light Rail Stations
1.a
Packet Pg. 41
Attachment: Refined Housing Opportunity Site Inventory (Campbell’s Plan for Housing (2023-2031 Housing Element)) 132
244
94.2 119
240 248
241
19 242
285.3
3 91
89 250
21 239
39 31
243
282
92.2 254
255 90
92.1 256
246
245
285.1
62 257
22 258
259
139 25
36 260
261
63 262
214.4
238
179
263
285.2
28 94.1
93.2 97
266
93.1 33
95 City of Campbell
6th Cycle Housing Element
Site Inventory Modifications
0 0.09 0.180.05 Mile
Sheet 5 of 5
Downtown Focus
Option 1 (Staff
Recommendation: 4,899
Units)
Keep
Remove
Option 4 (Selected
Reduced Densities:
4,676 Units)
City Boundary
Light Rail Stations
1.a
Packet Pg. 42
Attachment: Refined Housing Opportunity Site Inventory (Campbell’s Plan for Housing (2023-2031 Housing Element)) STATE OF CALIFORNIA - BUSINESS, CONSUMER SERVICES AND HOUSING AGENCY GAVIN NEWSOM, Governor
DEPARTMENT OF HOUSING AND COMMUNITY DEVELOPMENT
DIVISION OF HOUSING POLICY DEVELOPMENT
2020 W. El Camino Avenue, Suite 500
Sacramento, CA 95833
(916) 263-2911 / FAX (916) 263-7453
www.hcd.ca.gov
November 3, 2022
Rob Eastwood, Director
Community Development Department
City of Campbell
70 North First Street
Campbell, CA 95008
Dear Rob Eastwood:
RE: City of Campbell’s 6
th Cycle (2023-2031) Draft Housing Element
Thank you for submitting the City of Campbell’s (City) draft housing element update received for review on August 5, 2022 along with draft revisions on October 26, 2022.
Pursuant to Government Code section 65585, subdivision (b), the California Department of Housing and Community Development (HCD) is reporting the results of its review. Our review was facilitated by conversations on September 20 and 27, 2022 with you; Stephen Rose, Senior Planner; and your consultants, Geoff Bradley and Sung Kwon. In addition, HCD considered comments from several stakeholders and members of the community, pursuant to Government Code section 65585, subdivision (c).
The draft element addresses many statutory requirements; however, revisions will be necessary to comply with State Housing Element Law (Article 10.6 of the Gov. Code).
The enclosed Appendix describes the revisions needed to comply with State Housing Element Law.
For your information, pursuant to Assembly Bill 1398 (Chapter 358, Statutes of 2021), if a local government fails to adopt a compliant housing element within 120 days of the statutory deadline (January 31, 2023), then any rezoning to make prior identified sites available or accommodate the regional housing needs allocation (RHNA), including for lower-income households, shall be completed no later than one year from the statutory deadline. Otherwise, the local government’s housing element will no longer comply with State Housing Element Law, and HCD may revoke its finding of substantial compliance pursuant to Government Code section 65585, subdivision (i). Please be aware, if the City fails to adopt a compliant housing element within one year from the statutory deadline, the element cannot be found in substantial compliance until rezones pursuant to Government Code section 65583, subdivision (c) (1) (A) and Government Code section 65583.2, subdivision (c) are completed.
1.b
Packet Pg. 43
Attachment: HCD Comment Letter, November 3, 2022 (Campbell’s Plan for Housing (2023-2031 Housing Element)) Rob Eastwood, Community Development Director
Public participation in the development, adoption and implementation of the housing element is essential to effective housing planning. Throughout the housing element process, the City must continue to engage the community, including organizations that represent lower-income and special needs households, by making information regularly available while considering and incorporating comments where appropriate. Please be aware, any revisions to the element must be posted on the local government’s website and to email a link to all individuals and organizations that have previously requested notices relating to the local government’s housing element at least seven days before submitting to HCD.
Several federal, state, and regional funding programs consider housing element compliance as an eligibility or ranking criteria. For example, the CalTrans Senate Bill (SB) 1 Sustainable Communities grant; the Strategic Growth Council and HCD’s Affordable Housing and Sustainable Communities programs; and HCD’s Permanent Local Housing Allocation consider housing element compliance and/or annual reporting requirements pursuant to Government Code section 65400. With a compliant housing element, the City will meet housing element requirements for these and other funding sources.
For your information, some general plan element updates are triggered by housing element adoption. HCD reminds the City to consider timing provisions and welcomes the opportunity to provide assistance. For information, please see the Technical Advisories issued by the Governor’s Office of Planning and Research at:
https://www.opr.ca.gov/planning/general-plan/guidelines.html.
HCD appreciates the hard work and dedication you; Stephen Rose, Senior Planner; and your consultants, Geoff Bradley and Sung Kwon provided in preparation of the City’s housing element and looks forward to receiving the City’s adopted housing element. If you have any questions or need additional technical assistance, please contact Shawn Danino, of our staff, at [email protected].
Sincerely,
Paul McDougall
Senior Program Manager
Enclosure
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Attachment: HCD Comment Letter, November 3, 2022 (Campbell’s Plan for Housing (2023-2031 Housing Element))
City of Campbell’s 6th Cycle (2023-2031) Draft Housing Element Page 1 November 3, 2022
APPENDIX
CITY OF CAMPBELL
The following changes are necessary to bring the City’s housing element into compliance with Article 10.6 of the Government Code. Accompanying each recommended change, we cite the supporting section of the Government Code.
Housing element technical assistance information is available on HCD’s website at https://www.hcd.ca.gov/hcd-memos. Among other resources, the housing element section contains HCD’s latest technical assistance tool, Building Blocks for Effective Housing Elements (Building Blocks), available at https://www.hcd.ca.gov/building-blocks and includes the Government Code addressing State Housing Element Law and other resources.
A. Review and Revision
Review the previous element to evaluate the appropriateness, effectiveness, and progress in implementation, and reflect the results of this review in the revised element. (Gov. Code, § 65588 (a) and (b).)
Special Housing Needs: As part of the review of programs in the past cycle, the element must provide an evaluation of the effectiveness of goals, policies, and related actions in meeting the housing needs of special needs populations (e.g., elderly, persons with disabilities, large households, female headed households, farmworkers, and persons experiencing homelessness). While the element includes some general reporting such as the City’s website including links to homeless services (p. III.A-6), it should still evaluate whether programs were effective, individually and cumulatively, and add or modify programs appropriately.
B. Housing Needs, Resources, and Constraints
1. Affirmatively further[ing] fair housing in accordance with Chapter 15 (commencing with Section 8899.50) of Division 1 of Title 2…shall include an assessment of fair housing in the jurisdiction. (Gov. Code, § 65583, subd. (c)(10)(A).)
Enforcement and Outreach: While the element describes some outreach and capacity to enforce fair housing laws, it should also address compliance with existing fair housing laws as well as any past or current fair housing lawsuits, findings, settlements, judgements, or complaints.
Racially Concentrated Areas of Affluence (RCAA): The element identifies that “much of the city is identified as within a Racially Concentrated Area of Affluence,” (p. H-II-63) but should also include specific analysis to better formulate appropriate programmatic response. This analysis should utilize local data and knowledge and other relevant factors. For example, the element could examine past land use practices, investments, quality of life relative to the rest of the City and region and then formulate appropriate programs to promote more inclusive communities and equitable quality of life. For
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example, the City should consider additional actions (not limited to the Regional Housing Needs Allocation (RHNA)) to promote housing mobility and improve new housing opportunities throughout the City.
Disparities in Access to Opportunity: The element provides information on the access to opportunity through the TCAC opportunity map but must also provide a complete local and regional analysis of patterns and trends for all components. A comprehensive analysis should include the local and regional disparities of the educational, environmental, and economic scores through local, federal, and/or state data. It should also analyze persons with disabilities as well as access to transit. Please refer to page 35 of the Affirmatively Furthering Fair Housing (AFFH) guidebook (https://www.hcd.ca.gov/community-development/affh/index.shtml#guidance) for specific factors that should be considered when analyzing access to opportunities as it pertains to educational, employment, environmental, transportation, and any other relevant factors.
Disproportionate Housing Needs, including Displacement risk: The element provides some discussion on cost burdened households and overcrowding. However, the element must evaluate trends and patterns within the City, with regards to overpayment, substandard housing and persons experiencing homelessness. This analysis should utilize local data and knowledge and other relevant factors (Please see pages 24 and 25 of HCD’s Guidance at https://www.hcd.ca.gov/planning-and-community- development/affirmatively-furthering-fair-housing). For example, the element could utilize information from the City’s code enforcement to evaluate patterns of housing conditions or could contact service providers regarding patterns (areas of higher need) of persons experiencing homelessness and availability of services. Based on the outcomes of this analysis, the element should add or modify programs as appropriate.
Identified Sites and AFFH: While the element provides some analysis of the identified sites and socio-economic concentrations, the element must analyze the identified sites with regards to the City’s RCAAs. In addition, the element should analyze the lack of units in higher opportunity or income areas, including census tracts in the Northwest and Southeast portion of the City, including two of the City’s census tracts labeled highest opportunity areas by the Tax Credit and Allocation Committee (Figure IV-5), which appear to have no identified sites or opportunity sites. A complete analysis should fully assess how the site inventory is expected to improve and/or exacerbate fair housing conditions, including any isolation of the RHNA. This analysis should address the location, number of units by income group, magnitude of the impact, and could consider topics such housing choice (not limited to the RHNA) in other areas of the City, existing or proposed anti-displacement policies, place-based investments, and how such strategies will improve fair housing conditions when paired with the identified sites.
Based on the outcomes of this analysis, the element should add or modify programs as appropriate.
Contributing Factors to Fair Housing Issues: Based on the outcomes of a complete analysis, the element should re-evaluation and prioritize contributing factors to fair housing issues.
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Attachment: HCD Comment Letter, November 3, 2022 (Campbell’s Plan for Housing (2023-2031 Housing Element))
City of Campbell’s 6th Cycle (2023-2031) Draft Housing Element Page 3 November 3, 2022
Goals, Priorities, Metrics, Actions & Milestones: While the element includes general metrics for some programs, the element must be revised to add or modify goals and actions based on the outcomes of a complete analysis. Goals and actions must specifically respond to the analysis and to the identified and prioritized contributing factors to fair housing issues and must be significant and meaningful enough to overcome identified patterns and trends. Actions must have specific commitment, milestones, geographic targeting and metrics or numerical targets and, as appropriate, address housing mobility enhancement, new housing choices and affordability in higher opportunity or income areas (throughout the City), place-based strategies for community preservation and revitalization and displacement protection.
The element may, for example, commit to a firm date by which it will establish development standards for smaller housing types, including bungalow courts. The element may also, for example, as discussed on the September 27, 2022 call, revise Program H-1m to make a specific commitment for establishing development standards for small units including missing middle housing types that are feasible in higher opportunity or income areas. To improve housing opportunities for persons experiencing homelessness or lower-income households employed in the City, the City may, for example, commit to identifying supportive housing projects in the City as part of Project Homekey and provide a date by which sites will be identified and by which the City will apply for funding. The City may also, for example, revise Program HE-6.D to make specific commitments to improve pedestrian safety and active mobility as a way to increase disparities in access to opportunity. Additionally, the element should commit to assessing and revising programs through a mid-cycle review. Please see HCD’s AFFH memo for more information: https://www.hcd.ca.gov/community- development/affh/docs/affh_document_final_4-27-2021.pdf#page=23.
2. Include an analysis of population and employment trends and documentation of projections and a quantification of the locality's existing and projected needs for all income levels, including extremely low-income households. (Gov. Code, § 65583, subd. (a)(1).)
Include an analysis and documentation of household characteristics, including level of payment compared to ability to pay, housing characteristics, including overcrowding, and housing stock condition. (Gov. Code, § 65583, subd. (a)(2).)
Analyze any special housing needs such as elderly; persons with disabilities, including a developmental disability; large families; farmworkers; families with female heads of households; and families and persons in need of emergency shelter. (Gov. Code, § 65583, subd. (a)(7).)
Extremely Low-Income (ELI): While the element briefly quantifies ELI households but should specifically analyze their housing needs, including tenure, overpayment, available resources and strategies, effectiveness of past program and the magnitude or disproportionate impacts on housing needs. Then, the element should add or modify programs as appropriate.
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Attachment: HCD Comment Letter, November 3, 2022 (Campbell’s Plan for Housing (2023-2031 Housing Element))
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Housing Cost: While the element includes estimated rents for residents, it utilizes American Community Survey (ACS) data. The element should supplement census data with other sources (e.g., local knowledge).
Overpayment: The element must quantify and analyze the number of lower-income households overpaying by tenure (i.e., renter and owner).
Persons Experiencing Homelessness: The element provides some analysis of persons experiencing homelessness and describes some facility capacity in the County ( Table II-25). However, given the magnitude of the need and the significant increase in the Point in Time Count between 2019 and 2022, the City should evaluate resources and strategies, gaps in addressing needs and formulate appropriate strategies to address the unmet need. For example, the element could identify and evaluate capacity for permanent supportive housing, or other housing types, for example Single Room Occupancies (SROs), within the City, to evaluate needs and address unmet needs through program actions.
3. An inventory of land suitable and available for residential development, including vacant sites and sites having realistic and demonstrated potential for redevelopment during the planning period to meet the locality’s housing need for a designated income level, and an analysis of the relationship of zoning and public facilities and services to these sites. (Gov. Code, § 65583, subd. (a)(3).)
Small Sites: The site inventory currently includes 64 sites that are less than 0.5 acres, including several sites with existing housing (p. H-IV-30 and Table A). Sites smaller than a half-acre in size are deemed inadequate to accommodate housing for lower-income housing unless it is demonstrated that sites of equivalent size and affordability were successfully developed during the prior planning period or unless the housing element describes other evidence to HCD that the site is adequate to accommodate lower- income housing (Gov. Code, § 65583.2, subd. (c)(2)(A).). The element identifies several site groupings with potential for consolidation. However, the element must also evaluate whether those sites are suitable to accommodate housing for lower-income households and add or modify programs as appropriate. For example, the element could list past consolidations by the number of parcels, number of owners, zone, number of units, affordability and circumstances leading to consolidation and then relate those trends to the identified sites or could explain the potential for consolidation on a site-by-site basis.
Based on the outcomes of the analysis, the element should modify policies and programs, including a specific commitment to ensure that maximum densities can be accommodated on all sites in the inventory.
Large Sites: The inventory includes several sites over ten acres, including one 16.4- acre site with an operating commercial shopping center. While the element clarifies there is interest from the property owner, it should analyze the suitability of these sites to accommodate housing for lower-income households or rescale assumptions.
The City described its strategy for “carving out” portions of some larger parcels, where some portions of parcels can be developed while maintaining other existing residential and commercial uses. However, the City should clarify the timeline and procedure by which these carveouts will occur. For example, the element should
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Attachment: HCD Comment Letter, November 3, 2022 (Campbell’s Plan for Housing (2023-2031 Housing Element))
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discuss any recent developments of similar size and affordability, opportunities for parceling, phasing or site planning and generally address how housing affordable to lower-income households will occur given typical state funded developments are approximately 50 to 150 units then rescale assumptions if necessary and add or modify programs as appropriate.
City-Owned Sites: The element identified two City-Owned sites to accommodate 231 housing units; however, must analyze the suitability and availability of those sites for development in the planning period, including how the sites will be available (e.g., surplus or lease), any known barriers, an anticipated schedule and other relevant factors. In addition, the element should include a program with numerical objectives that ensure compliance with the Surplus Land Act, provides incentives and actions along with a schedule to facilitate development of City-owned sites. Actions should include outreach with developers, issuing requests for proposals, incentives, fee waivers, priority processing, financial assistance and alternative actions if the sites do not become available at a reasonable point in the planning period (e.g., 2028).
Suitability of Nonvacant Sites: The element must include analysis demonstrating the potential for additional development on nonvacant sites and describes existing property owner interest (p. H-IV-21). While the element mentions underutilized sites were identified based on interest in development, structure/site conditions and development on adjacent sites with similar characteristics, it must support the validity of these factors in demonstrating the potential for redevelopment. For example, the element currently lists prior uses in recent development activity but could also discuss how the recent trends support the various factors. In addition, the element could consider additional factors such existing versus allowable floor area and reflect those values in the sites inventory. Finally, the element should account for the extent existing uses impede additional residential development including market demand for the existing use and existing leases or contracts that would perpetuate the existing use or prevent additional residential development.
The housing element relies upon nonvacant sites to accommodate more than 50 percent of the RHNA for lower-income households. As a result, the housing element must demonstrate existing uses are not an impediment to additional residential development and will likely discontinue in the planning period. (Gov. Code, § 65583.2, subd. (g)(2).) For your information, absent findings in the resolution as part of adoption based on substantial evidence, the existing uses will be presumed to impede additional residential development and will not be utilized toward demonstrating adequate sites to accommodate the RHNA.
Electronic Sites Inventory: For your information, pursuant to Government Code section 65583.3, the City must submit an electronic sites inventory with its adopted housing element. The City must utilize standards, forms, and definitions adopted by HCD.
Please see HCD’s housing element webpage at https://www.hcd.ca.gov/planning-and- community-development/housing-elements for a copy of the form and instructions. The City can reach out to HCD at [email protected] for technical assistance.
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Attachment: HCD Comment Letter, November 3, 2022 (Campbell’s Plan for Housing (2023-2031 Housing Element))
City of Campbell’s 6th Cycle (2023-2031) Draft Housing Element Page 6 November 3, 2022
Zoning for a Variety of Housing Types:
• Single Room Occupancy (SRO) Units: The City categorizes SROs under the definition of rooming and boarding houses, “that are rented to between 3 to 5 persons for profit…”(p. H-II-109). The City should analyze this definition as a possible constraint. In addition, the City allows SROs in only certain zones and requires a Conditional Use Permit (CUP) in all zones allowed. The element should demonstrate zoning, development standards, including parking, and permit procedures encourage and facilitate SROs or add or modify programs as appropriate.
• By-right Permanent Supportive Housing: While the element states that supportive housing is permitted in all residential zoning districts by right (p. H-II-109), supportive housing shall be a use by-right in zones where multifamily and mixed uses are permitted, including nonresidential zones permitting multifamily uses pursuant to Government Code section 65651. The element must demonstrate compliance with these requirements and include programs as appropriate.
• Emergency Shelters: The element was revised to state that emergency shelters are allowed by-right in a “portion of the M-1 zone” and states that the area is “well served by transit and commercial services” (p. H-III-107). However, the element must also identify and analyze any development standards (e.g., spacing, parking, concentration requirements) and other requirements imposed on emergency shelters. Lastly, the element must describe compliance with Government Code section 65583, subdivision a)(4)(A) or include a program to comply with this requirement. For your information, pursuant to Government Code section 65583, subdivision a)(4)(A), parking requirements should be limited to allowing sufficient parking to accommodate all staff working in the emergency shelter, provided that the standards do not require more parking for emergency shelters than other residential or commercial uses within the same zone.
• Accessory Dwelling Units (ADU): HCD records indicate permitted ADUs of 5 in 2018, 8 in 2019, 54 in 2020, and 38 in 2021, figures that are inconsistent with those in the element. The element should reconcile these numbers either in the element or Annual Progress Reports (APRs) and adjust assumptions as appropriate.
After a cursory review of the City’s ordinance, adopted August 16, 2022, HCD discovered some areas which are inconsistent with State ADU Law. HCD will provide a complete listing of ADU non-compliance issues under a separate cover. As a result, the element should add a program to update the City’s ADU ordinance to comply with state law.
4. An analysis of potential and actual governmental constraints upon the maintenance, improvement, or development of housing for all income levels, including the types of housing identified in paragraph (1) of subdivision (c), and for persons with disabilities as identified in the analysis pursuant to paragraph (7), including land use controls, building
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codes and their enforcement, site improvements, fees and other exactions required of developers, and local processing and permit procedures... (Gov. Code, § 65583, subd. (a)(5).)
Land Use Controls: The element must identify and analyze all relevant land use controls impacts as potential constraints on a variety of housing types. The analysis should analyze land use controls independently and cumulatively with other land use controls.
The analysis should specifically address requirements related to parking for small units including SROs and missing middle housing types; height limits particularly in multifamily zones; maximum lot coverages; minimum lot areas; minimum site sizes; public and private open space requirements; lot coverage and limits on allowable densities. The analysis should address any impacts on cost, supply, feasibility, timing, approval certainty and ability to achieve maximum densities and include programs to address identified constraints. Finally, pursuant to public comments, the City must make a firm commitment to reduce its parking requirements across residential zones.
Processing and Permit Procedures: The element identifies that most developments are subject to a Site and Architectural Review and lists various finding, most notably “The project will aid in the harmonious development of the immediate area”. The element then mentions this is similar to other jurisdictions but should evaluate the impacts of the finding on housing supply (number of units), cost, timing, feasibility and particularly approval certainty and then add programs to address identified constraints.
Persons with Disabilities: The element describes the City’s reasonable accommodation process and lists its factors for consideration (pp. H-II-141), including the potential impact on surrounding uses. The element then notes this factor can be addressed by evaluating alternatives to addressing the needs of persons with disabilities. First, a factor such as impact on surrounding uses is essentially a conditional use finding and a reasonable accommodation procedure should be a unique exception process, instead using factors such as whether the accommodation poses a fundamental alternation of zoning and land use – a far different standard that should be employed in a manner to promote access to housing opportunities for persons with disabilities. Second, the surrounding use factor appears to be employed in a manner that seeks to alter requests and fit with the surrounding areas as opposed to considering the exception request. For these reasons alone, the element should identify this finding as a constraint and modify Program H-5g (Reasonable Accommodation) to remove the constraint early in the planning period (within two years).
In addition, the element indicates group homes for seven or more persons are allowed in all residential zones but subjects group homes to a conditional use permit (CUP), unlike other similar uses. The element should specifically analyze these constraints for impacts on housing supply and choices and approval certainty and objectivity for housing for persons with disabilities and include programs as appropriate.
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Attachment: HCD Comment Letter, November 3, 2022 (Campbell’s Plan for Housing (2023-2031 Housing Element))
City of Campbell’s 6th Cycle (2023-2031) Draft Housing Element Page 8 November 3, 2022
C. Housing Programs
1. Include a program which sets forth a schedule of actions during the planning period, each with a timeline for implementation, which may recognize that certain programs are ongoing, such that there will be beneficial impacts of the programs within the planning period, that the local government is undertaking or intends to undertake to implement the policies and achieve the goals and objectives of the Housing Element... (Gov. Code, § 65583, subd. (c).)
Programs must demonstrate that they will have a beneficial impact within the planning period. Beneficial impact means specific commitment to deliverables, measurable metrics or objectives, definitive deadlines, dates, or benchmarks for implementation.
Deliverables should occur early in the planning period to ensure actual housing outcomes. Several programs and actions have timelines that could be moved earlier in the planning period to ensure a beneficial impact. Examples include Programs H-1E (Preapproved ADU Plans), H-1m (Microunit Standards), H-2c (Short term Rental Ordinance), H-3e (Reuse Site Ministerial Review), and H-5t (Employee Housing).
Additionally, programs must have specific commitment to clear housing outcomes or deliverables. Several programs include actions with no description of how those actions will be implemented (e.g., “support”, “study”, “explore”, “evaluate”, etc.,). Programs should be amended, to include specific commitment to a housing related outcome.
Examples include Programs H-1b (Commercial Linkage Fee), H-1c (Affordable Housing Overlay Zone), H-1k (Achieve Target Densities), H-1m (Micro-unit Standards), H-2d (Workforce Housing Ordinance), H-2e (Housing Rehabilitation Loans), H-2g (Preservation of Assisted Housing), H-3a (Parking Requirement Reduction) H-5d (Shared Housing Program), H-5o (ELI Unit Development), and H-5s (City Density Bonus).
2. Identify actions that will be taken to make sites available during the planning period with appropriate zoning and development standards and with services and facilities to accommodate that portion of the city’s or county’s share of the regional housing need for each income level that could not be accommodated on sites identified in the inventory completed pursuant to paragraph (3) of subdivision (a) without rezoning, and to comply with the requirements of Government Code section 65584.09. Sites shall be identified as needed to facilitate and encourage the development of a variety of types of housing for all income levels, including multifamily rental housing, factory-built housing, mobilehomes, housing for agricultural employees, supportive housing, single-room occupancy units, emergency shelters, and transitional housing. (Gov. Code, § 65583, subd. (c)(1).)
As noted in Finding B3, the element does not include a complete site analysis; therefore, the adequacy of sites and zoning were not established. Based on the results of a complete sites inventory and analysis, the City may need to add or revise programs to address a shortfall of sites or zoning available to encourage a variety of housing types.
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Attachment: HCD Comment Letter, November 3, 2022 (Campbell’s Plan for Housing (2023-2031 Housing Element))
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In addition, programs targeting development of publicly owned land (e.g., Program H- 5q) should include a schedule of actions for development in the planning period consistent with the assumptions in the sites inventory, including coordination with developers, requests for proposal, facilitating entitlements, incentives, issuing building permits and compliance with the Surplus Land Act.
3. Address and, where appropriate and legally possible, remove governmental and nongovernmental constraints to the maintenance, improvement, and development of housing, including housing for all income levels and housing for persons with disabilities. The program shall remove constraints to, and provide reasonable accommodations for housing designed for, intended for occupancy by, or with supportive services for, persons with disabilities. (Gov. Code, § 65583, subd. (c)(3).)
As noted in Finding B4, the element requires a complete analysis of potential governmental and nongovernmental constraints. Depending upon the results of that analysis, the City may need to revise or add programs and address and remove or mitigate any identified constraints.
4. Promote and affirmatively further fair housing opportunities and promote housing throughout the community or communities for all persons regardless of race, religion, sex, marital status, ancestry, national origin, color, familial status, or disability, and other characteristics... (Gov. Code, § 65583, subd. (c)(5).)
As noted in Finding B1, the element must include a complete assessment of fair housing. Based on the outcomes of that analysis, the element must add or modify programs.
5. The housing program shall preserve for low-income household the assisted housing developments identified pursuant to paragraph (9) of subdivision (a)... (Gov. Code, § 65583, subd. (c)(6).)
Program H-2g states an objective to “participate in the preservation of at-risk units by providing financial and/or technical assistance” (p. H-IV-55). However, the program should make a specific and firm commitment to maintain the long-term affordability of these units, including a clear commitment of financial assistance or support of funding applications, coordination with qualified entities and support, education and assistance for tenants.
D. Quantified Objectives
Establish the number of housing units, by income level, that can be constructed, rehabilitated, and conserved over a five-year time frame. (Gov. Code, § 65583, subd. (b)(1 & 2).)
While the element includes quantified objectives for new construction, it should also consider quantified objectives for rehabilitation and preservation of existing affordable
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Attachment: HCD Comment Letter, November 3, 2022 (Campbell’s Plan for Housing (2023-2031 Housing Element))
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housing. For your information, the quantified objectives do not represent a ceiling, but rather set a target goal for the City, based on needs, resources, and constraints.
E. Public Participation
Local governments shall make a diligent effort to achieve public participation oof all segments of the community in the development of the Housing Element and the element shall describe this effort. (Gov. Code, § 65583, subd.(c)(9).)
While the City made efforts to include the public through workshops and surveys, moving forward, the City should employ additional methods for public outreach efforts in the future, particularly to include lower-income and special needs households and neighborhoods with higher concentrations of lower-income households. In addition, several comments questioned the lack of commitments around reducing parking minimums and ensuring the feasibility of missing middle housing types. The City should consider these comments and make adjustments as appropriate. The City should also analyze the feasibility of sites identified by members of the public, including the site of a former Elephant Bar and Fry’s Electronics and make adjustments as appropriate. The City could also, for example, target higher densities around the Hamilton 880 corridor. To AFFH, the element could revise Program H-3f and commit to development of a rent stabilization ordinance that limits annual rent increases or develop a city-wide portal for affordable rentals available. Finally, to address noted jobs-housing relationships, the City could also, for example, conduct targeted stakeholder interviews or establish a committee representative of lower-income households and commuters who work inside the City in future public outreach efforts. For additional information, see the Building Blocks at http://www.hcd.ca.gov/community- development/building-blocks/getting-started/public-participation.shtml.
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Attachment: HCD Comment Letter, November 3, 2022 (Campbell’s Plan for Housing (2023-2031 Housing Element)) Attachment C
Housing Opportunity Methodology
Minimum Density Approach
While the Housing Opportunity Site Inventory allows for the development of up to 6,640 units, such an outcome would only be possible if every site built at the maximum density allowed. As it is not reasonable to assume that every site will develop at the m aximum allowable density, or at the level and mix of affordability required per site (i.e., which assumes a mix of very -low, low-, moderate income units), Campbell’s Plan for Housing uses a “Minimum Density ” approach to demonstrate that the inventory will meet the Regional Housing Needs Allocation (RHNA).
Under the Minimum Density Approach, out of the 6,640 units possible, the city would receive “credit” for approximately 5,604 units. Of these unit s, approximately 30% are assumed to be affordable (1,685). While the city could argue that all 6,640 units would be built at the planned for density and level of affordability required, HCD would require a preponderance of evidence to support such claims based on past success. Given the high rate of failure of southern California cities which pursued alternative unit count methodologies, and in consideration that the city was unsuccessful in its previous cycle to achieve its RHNA, the Initial Review Draft relied on the Minimum Density Approach, as explained in greater detail as follows:
Minimum Density Approach: The Minimum Density approach assumes that every Housing Opportunity Site will achieve the minimum density allowed. While this approach may seem st raightforward, the minimum density of a Housing Opportunity Site varies based on the density range of the land use designation and the application of Policy H -
1.4 from the Draft Housing Element, which requires all Housing Opportunity Sites to achieve at least 75% of the maximum density allowed by the General Plan Land Use designation:
Policy H-1.4: Planned for Densities. All housing opportunity sites shall achieve 75 percent of the maximum General Plan Land Use density.
As a result, the minimum density range of some sites is based on the land use designation itself, while for others, the application of Policy H -1.4 sets the floor, as explained by the following examples:
• Example 1: The Transit-Oriented Mixed Use land use designation allows for 57 to 75 units per gross acre. Applying Policy H-1.4, 75% of the maximum density of 75 units per acre is equal to 56.25 units per acre. As the minimum density range of the land use designation is 57 units per acre, which is greater than 56.25 units per acre, the minimum density of the land use itself (i.e., 57 units per acre) is used when calculating the minimum allowable density.
• Example 2: The Medium Density Residential land use designation allows for 18 to 25 units per gross acre. Applying Policy H-1.4, 75% of the
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Attachment: Housing Opportunity Methodology (Campbell’s Plan for Housing (2023-2031 Housing Element)) Attachment C
maximum density of 25 units per acre is equal to 18.75 per acre. As 18.75 units per acre is greater than the minimum density range of the land use designation (i.e., 18), the standard set by Policy H-1.4 is used when calculating the minimum allowable density.
Relying on this policy in the Initial Draft Housing Element submitted to HCD, the Site Inventory results in the production of 5,139 units (out of the 6,640 units possible) from the 131 sites identified. In addition to receiving credit for units i ncluded in the Site Inventory, Pipeline Units (185 units) and ADUs (280 units) also are credited by the methodology resulting in a total yield of 5,604 units.
Income Level
Very Low Low Moderate
Above
Moderate Total
0-50% AMI 51-80% AMI 80-120% AMI >120% AMI
Pipeline 29 4 2 150 185
ADUs 84 84 84 28 280
Site Inventory 1,044 883 624 2,588 5,139
Total Units 1,157 971 710 2,736 5,604
Table 1: Total Unit Count in Initial HCD Draft using Minimum Density Approach
While the methodology results in 1,734 more units, or 44% more, than the 3,870 units recommended by HCD (RHNA + 30% buffer), the amount of buffer in any given income category varies between 9% and 72% as follows:
Income Level
Very Low Low Moderate
Above
Moderate Total
0-50% AMI 51-80% AMI 80-120% AMI >120% AMI
RHNA +
30% buffer 978 564 649 1679 3,870
Total Units 1,157 971 710 2,736 5,604
Unit
Surplus
179
(18%)
407
(72%)
61 (9%)
1057
(62%)
1,734
(44%)
Table 2: Total Unit Surplus by Income Level
When considering potential refinem ents to the Site Inventory, the target of 3, 870 units, distributed by the income categories identified in Table 2 above, will be the basis of the discussion.
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Council
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TITLE: Authorize the City Manager to Approve and Execute an Amendment to the Consultant Services Agreement with Metropolitan Planning Group to Finalize Campbell’s Plan for Housin g (2023 -2031 Housing Element) and Initiate a Corresponding Budget Adjustment. (Resolution/Roll Call Vote)
RECOMMENDED ACTION
Adopt a Resolution, authorizing the City Manager to approve and execute an amendment to the Consultant Services Agreement with Me tropolitan Planning Group (M-Group) to finalize Campbell’s Plan for Housing (2023 -2031 Housing Element); and initiate a budget adjustment to appropriate $150,000 for additional contract costs.
EXECUTIVE SUMMARY
This item seeks to authorize the City Manage r to approve and execute an amendment to the Consultant Services Agreement with Metropolitan Planning Group (M -Group) to finalize the Housing Element and initiate a budget adjustment to appropriate $150,000 for additional contract costs.
BACKGROUND
At it s August 17, 2021, meeting, the City Council authorized the City Manager to dispense with the bidding procedures specified in CMC Section 3.20.050 and negotiate, award, and execute a contract with Metropolitan Planning Group (M -Group) for the preparation of the 2023 -2031 Housing Element and authorize a corresponding budget adjustment. The initial estimate to complete the Housing Element was $309,970, inclusive of a $27,415 contingency.
Between August 2021, and October 2022, the city conducted public outre ach beyond the scope of the original budget (i.e., post -cards to all Campbell properties, pop -up booths, social media), and held a greater number of public hearings with the Planning Commission and City Council than anticipated by the original scope of services.
On June 9, 2022, the City of Campbell released its Public Review Draft of the Housing Element. The Public Review Draft was circulated for thirty -days for public comment.
During the public comment period, the City received twelve (12) letters, and one late response.
Item: 2
Category:
Meeting Date: November 29, 2022
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UNFINISHED BUSINESS
Housing Element Budget Adjustment Page 2 of 4
On August 2, 2022, the City Council held a public hearing to review public comments and proposed modifications to the Draft of Campbell’s Plan for Housing (2023 -2031 Housing Element) prior to submitting the document to Housing and Com munity Development (HCD) for their initial 90-day review.
On August 5, 2022, the City of Campbell published its Initial Review Draft of the Housing Element and submitted a copy to HCD for review. Following submittal, staff held deliberative video confere nce meetings with HCD staff to discuss their initial questions and comments on the Draft Housing Element. Initial feedback from HCD was identified by staff as falling within two main categories: 1) technical revisions serving to clarify information presented in the Draft Housing Element; and 2) recommendations on modifications to policies and programs. HCD staff advised Campbell staff to consider releasing an updated draft of the Housing Element addressing the technical revisions prior to the distribution o f HCD’s formal review letter, so that the letter could be more focused in scope.
On October 26, 2022, the City of Campbell published an updated version of the Housing Element with the technical revisions requested by HCD.
On November 3, 2022, HCD issu ed its formal review letter on the City’s Draft Housing Element, and on November 15, 2022, staff met with HCD staff to discuss the comments.
DISCUSSION
Over the past year, the city has made significant progress preparing its Housing Element for the 2023 -2031 planning period. Throughout the update process, staff and the consultant have conducted significantly greater public outreach than originally anticipated and held more meetings with the Commission and Council than scoped in the service agreement. Furth er, the mapping process has become more dynamic and the need to refine Housing Opportunity Sites through a second round of review carries an additional, unanticipated cost for GIS analysis and related work. Finally, in response to both the initial changes to the Housing Element following deliberative calls with HCD staff, and more significant changes following receipt of the November 3, 2022, letter – additional and ongoing consultant costs have been identified in excess of the $309,970 originally budgeted (see ‘Background’).
With the receipt of the latest comment letter from HCD, staff , and the project consultant M-Group, estimate the additional cost to complete the Housing Element to be approximately $127,360. This estimate includes the cost 1 of hiring a sub-consultant, Karen Warner, based on her experience in gaining HCD compliance with 6 th Cycle Housing Elements in the Southern California Association of Governments (SCAG ) region.
To ensure adequate funds will be available to complete the Housing Elemen t, staff also advises budgeting an additional $22,640 in contingency ; for a budget adjustment 1 Estimated to be $16,000 plus a 10% fee for sub-consultant services. 2 Packet Pg. 59
Housing Element Budget Adjustment Page 3 of 4
totaling $150,000. An itemized summary of the use of these funds has been outlined in the attached Budget Adjustment Request (reference Attachment B).
ADDITIONAL BUDGETARY CONSIDERATIONS
While the cost to complete the Housing Element is anticipated run between $127 ,000 to $150,000 overbudget (see ‘Fiscal Impacts’) ,corresponding work on the General Plan is anticipated to run underbudget.
a. Housing Element:
i. Original Contract Value: $282,555 (base) + $27,500 (contingency) ii. Projected Costs: $127k to $150k additional
iii. Reason: See “Discussion” above.
b. General Plan:
i. Original Contract Value: $448,876 (base) + $50,000 (contingency) ii. Projected Costs: $50k to $100k underbudget
iii. Reason: Mapping efforts originally anticipated to be included as part of the General Plan; now completed by Housing Element.
Given the overlapping and interrelated nature of these work plan items, some costs – such land use mapping originally anticipated to be completed as part of the General Plan update, have been assigned to the Housing Element. As such, in consideration of the proposed budget adjustment it is important to consider the anticipated cost of completing these two major work items comprehensively.
FISCAL IMPACT
The total cost of the contract with M -Group, inclusive of the proposed amendment, is $459,970, inclusive of a $22,640 contingency. This cost would be incurred over two fiscal years (FY 2023/2024). A summary of the costs is as follows:
• $309,970 – Original Services Agreement (Total Cost Authorized) – M-Group • $150,000 – Additional Funds Requested (inclusive of $22,640 contingency) $459,970 – Total Budget
The costs for this contract would be paid from account 101.552.7430. To auth orize the contract expenditures, a Request for Budget Adjustments form (shown as Exhibit A to Attachment A (Resolution) is attached to this staff report. The source of funds would be FY 2023 and FY 2024 expected General Plan Maintenance Fee revenue.
Prepared by:
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Stephen Rose, Senior Planner
Housing Element Budget Adjustment Page 4 of 4
Approved by:
Brian Loventhal, City Manager
Attachment:
a. Draft Resolution
b. M-Group Budget Adjustment Request
c. M-Group Original Service Agreement
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Reviewed by:
Rob Eastwood, Community Development Director
RESOLUTION NO.
BEING A RESOLUTION OF THE CITY COUNCIL OF THE CITY
OF CAMPBELL AUTHORIZING THE CITY MANAGER TO
APPROVE AND EXECUTE A N AMENDMENT TO THE
CONSULTANT S ERVICES AGREEMENT WITH
METROPOLITAN PLANNING GROUP FOR COMPLETION OF
CAMPBELL’S PLAN FOR HO USING ( 2023-2031 HOUSING
ELEMENT) AND INITIATE A CORRESPONDING BUDGET
ADJUSTMENT.
After notification and publi c hearing, as specified by law and after presentation by th e Community Development Director, proponents and opponents, the hearing was closed.
The City Council finds as follows with regard to authorizing the City Manager to approve and execute a n amendment to the Consultant Services Agre ement with Metropolitan Planning Group for the preparation of the 2023-2031 Housing Element and initiation of a corresponding budget adjustment:
WHEREAS, the City of Cam pbell is required by the State to certify its Housing Element by January 31, 2023; and
WHEREAS, the City of Campbell desires the services of qualified consultant s for completion of the 2023-2031 Housing Element; and
WHEREAS, Metropolitan Plannin g Grou p has their familiarity with local policies and regulations and experience preparing the City’s last three Housing Elements, WHEREAS, the City circulated an RFP from March 17, 2021 to April 15, 2021 for the preparation of the Housing Element and received no proposals; and WHEREAS, the City of Campbell Municipal Code authorizes the City to dispense with the formal bidding process if certain conditions are met; and WHEREAS, the purchasing procedures outlined in the City’s Municipal Code (CMC) Section 3.20 .050 state that purchases and contract for ‘supplies, services, and equipment of estimated fair market value greater than fifty thousand dollars’ shall be made according to specified bidding procedures.
WHEREAS, the estimated cost to complete Campbell’s Plan f or Housing ( 2023-2031 Housing Element ), with the staff recommended contingency of $22,640, shall not exceed a total of $150,000; and
WHEREAS, CMC Section 3.20.030 provides that t he bidding proced ures may be dispensed with when any one of eight potential circumstances are found to exist.
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Attachment: Draft Resolution (Housing Element Budget Adjustment) City Council Resolution No. Page 2 of 2 Authorize the City Manager to Dispense with Bidding, Authorize Amendment to Consultant Services Agreement and Initiate Corresponding Budget Adjustment
WHEREAS, the City Council previously found t he following circumstances from CMC
3.20.030 to exist, thereby warranting the bidding procedures to be dispensed with:
• No acc eptable bids were received from any responsible bi dder, after following the procedures set forth in Section 3.20.050 of this chapter for the preparation of the 2023-2031 Housing Element;
• The city seeks the special services, consultation or advice in financial, economic, accounting, engineering, legal , administr ative or other matters from persons specially trained, experienced and competent to perform the special services required;
• The City Coun cil, by a majority vote, determines that i t is in the best interest of the public to dispense with the r equirements of Section 3.20.050, in which case the City Council shall prescribe the appropriate method of purchase.
WHEREAS, approval of the attached Request for Budget Adjustments form shown as Exhibit A to this resolution is necessary to support the proposed contract expenditures.
THEREFORE, BE IT RESOLVED that the City Council hereby authorizes the City Manager approve and execute an amendment to the Consultant Services Agre ement with Metropolitan Planning Group for the preparation of the 2023-2031 Housing Element and initiation of a corresponding budget adjustment as set forth in Exhibit A.
PASSED AND ADOPTED this day of 2022, by the following roll call vote:
AYES: COUNCILMEMBERS:
NOES: COUNCILMEMBERS:
ABSENT: COUNCILMEMBERS:
ABSTAIN: COUNCILMEMBERS:
APPROVED:
___________________________
Paul Resnikoff, Mayor
ATTEST:
____________________________
Andrea Sanders, City Clerk
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Attachment: Draft Resolution (Housing Element Budget Adjustment) Exhibit A
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Attachment: Draft Resolution (Housing Element Budget Adjustment) m-group a new design on urban planning
policy planning urban design environmental review historic preservation community engagement staffing solutions m-group.us 51 E Campbell Ave, #1247, Campbell, CA 95009 408.340.5642
MEMORANDUM
Date: November 8, 2022
To: Rob Eastwood, AICP, Community Development Director
From: Geoff I. Bradley, AICP, Principal, M-Group
Subject: City of Campbell Housing Element Update – Budget Augment Request
As M-Group moves forward with this multi-faceted project, we have exceeded some task-level budgets due to necessary, unanticipated levels of effort with out-of-scope tasks and meetings. Therefore, we are requesting a budget augment for Tasks 1.3, 3.6, 3.7, 3.10, 3.12 and 3.16. Additionally, we are recommending the addition of a sub-consultant.
The following effort has occurred outside the original scope of work, involved more effort than planne d, and may be required moving forward:
1) Project Management (Task 1.3)
2) GIS Analysis for Site Selection & AAFH (Task 3.6)
3) Preparing Admin Draft (Task 3.7)
4) Additional Planning Commission Meetings (Task 3.10) 5) Additional City Council Meetings (Task 3.12)
6) Additional Review (Task 3.16) - New
As a result, we need to request additional budget in the following tasks and overall project management:
M-Group Budget Augment
Task 1.3 – To manage project through an additional HCD Comment review.
Task 3.6 – GIS Analysis for Site Selection . This task was not a tangible addition to the scop e. Quite a bit of GIS analysis was involved with the sites. There were several iterations with various densities in coordination with the General Plan Update. It involved significantly more work than estimated and is over budget by $19k.
Task 3.7 – Prepare Administrative Draft Housing Element. This task also required significantly more work than expected because of requested outline / format ting changes post approval. An additional round of edits occurred post City Council review. Additional ly, there was extra work as a result of needing to re- create lost survey results, extra out of scope review by Lawyer’s Committee Group and Roots Policy Group and is over budget by $26k.
Task 3.10 – Planning Commission Meetings (PC) . This task was budgeted for four meetings. It exce eded the budgeted number of meetings with an extra plann ing commission meeting. With 3 more Planning Commission meetings anticipated, we request a task budget increase to account for a total of four additional out-of-scope PC meetings at $6,165 per meeting.
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Attachment: M-Group Budget Adjustment Request (Housing Element Budget Adjustment) m-group.us 51 E Campbell Ave, #1247, Campbell, CA 95009 408.340.5642
Task 3.12 – City Council Meetings (CC) . This task originally called for six meetings. To date, 6 City Council meetings were completed. We are anticipating four m ore out-of-scope City Council meetings at $5,890 per meeting.
Task 3.16 – Edit Housing Element based on HCD Comments #2 Sub-Consultant - Additionally, we recommend adding Karen Warner as a sub-consultant to help finalize the HEU and to secure HCD certification. Based on her recent experience in gaining HCD compliance on seven 6th cycle housing elements in the SCAG region, Karen will:
• Consult with M-Group in response to HCD’s 11/3/22, comment letter. • Participate in meetings with staff to discuss recommended revisions. • Review the revised Housing Element prior to resubmittal to HCD.
To the extent the City receives a second review letter from HCD identifying outstanding compliance issues, Karen will support M-Group staff in working informally with HCD to develop acceptable responses to gain compliance.
Please see below for a summary of this request:
Tasks Task Description Budget Augment
1.3 Manage project with additional HCD Comment Review $5,600
3.6 GIS Analysis for Site Selection $19,000
3.7 Prepare Admin Draft Housing Element $26,000
3.10 +4 Planning Commission Meetings $24,660
3.12 +4 City Council Meetings (4 future) $23,560
3.16 Edit Housing Element per HCD Comments #2 $10,940 Sub-Consultant Karen Warner – Finalize HEU & Gain HCD Certification $16,000 10% Sub Fee Sub -Consultant Admin Fee (Karen Warner) $1,600 Total Budget Augment $127,360
Thank you for your consideration and please contact me with any questions or concerns.
Sincerely,
GEOFF I. BRADLEY, AICP
Principal + President
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Attachment: M-Group Original Service Agreement (Housing Element Budget Adjustment)
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Attachment: M-Group Original Service Agreement (Housing Element Budget Adjustment) To: Mayor Resnikoff and City Council Members
Date: Nov. 28, 2022
From: Stephen Rose, Senior Planner
Via: Rob Eastwood, Community Development Director
Subject: Item #1 – Housing Inventory & Policy Refinements (PLN-2022-12)
The November 2 9, 2022, City Council staff report indicated that Planning Commission recommendations on this item, provided at their November 22, 2022, meeting, and a table summarizing HCD feedback and staff’s recommended responses by the city (in both the major areas and non-substantive areas) would be provided as a desk item.
This desk item provides: 1) Planning Commission feedback, 2) HCD Comment Summary Table, and 3) a summary of public comments provided at the Planning Commission meeting and in advance of the meeting in writing.
1. Planning Commission Recommendations
a. Housing Opportunity Site Inventory Refinements
The Planning Commission expressed broad support for Option 1, as recommended by staff.
Individual members of the Planning Comm ission provided the following comments and feedback without consensus:
• Option 2 ( Campbell Technology Park - Sites 214.1 t o 21 4.4):
Expressed desire for a southwest portion of the site to be kept in play for a potential trade with the City Corporation yard. Noted a concern that if the site were to be lowered in density, it would develop as an exclusive market-rate neighborhood.
• Option 4 (Reduced Site Inventory): Noted merit for reducing densities for select sites which back onto lower density residential uses , such as those along Winchester and Bascom Avenue. Discouraged lowering the densities of properties southeast of Downtown and San Tomas Plaza (Site 49).
City of Campbell
MEMORANDUM
Desk Item - Item #1 Page 2 of 3 Housing Inventory & Policy Refinements (PLN-2022-12)
• First Street Parking Garage (Site 3): One member of the Commission expressed interest in retaining the parking garage in the site inventory.
• 320 Virginia Avenue (Site 49): Most of the Commission agreed that the site should be designated for housing, despite its existing open space land use designation, recognizing that Virginia Park and John D. Morgan Park are nearby. However, individual members commentated that the site should be required to pay a greater park -in-lieu fee, or provide a greater allocation of af fordable housing unit , in consideration of the change in land use designation.
b. Policy Refinements
The Planning Commission reached consensus in supporting all the recommended modifications to the Goals, Policies and Programs i n the Housing Element i dentified by staff . Additionally, the Comm ission reached consensus in recommending the city pursue a more active mul ti-modal plan that connects with regional planning efforts (such a s the VTA bicycle superhighway plan) to address Affirmatively Furthering Fair Housing (A FFH) principles. Individual Planning Commissioners also identified several other areas for discussion (i.e., declaring a shelter c risis, permitting s ingle-room occupancy units by-right) but agreed that too limited information was available to make an informed recommendation on such points to the Council.
2. HCD Comment Summary Table
A table summarizing all HCD feedback in the November 3, 2022, letter and recommended responses by the city (in both the major areas and non-substantive areas) is provided as Exhibit A.
Major areas for consideration have been covered in the staff report and will be included in the staff presentation.
3. Public Comments
At the November 22, 2022, Planning Commission meeting, four members of the public spoke on the item. Individual comments received included the following:
• Desire for larger site inventory noting that ove r 50% of the inventory relies on non-vacant sites.
• Desire to reduce or eliminate parking minimums.
• Desire for connected bike lanes to support those who do not drive. • Interest in redistributing the affordable housing unit allocations to areas that will be least impacted.
Desk Item - Item #1 Page 3 of 3 Housing Inventory & Policy Refinements (PLN-2022-12)
• Observation that 40% of students attending the school district s erving San Tomas Plaza are low-income.
• Interest to allow roofs to exceed the maximum City wide height limit or revise height limit to focus on limiting the maximum number of stories, to avoid flat topped buildings.
Further, in advance of the Planning Commission hearing, staff received the following comments related to this item that are enclosed
1. 320 Virginia Avenue, Scott Connelly
2. 251 Llewelyn Avenue, Don Taylor
3. 500 E. Hamilton Avenue, Bill Baron
4. Suggestions in Response to HCD Letter, Adam Buchbinder
Encl:
Exhibit A – HCD Comment Summary Table
Exhibit B - Public Feedback
HCD Comment City Response
A. Review and Revision
Special Housing Needs: As part of the review of programs in the past cycle, the element must provide an evaluation of the effectiveness of goals, policies, and related actions in meeting the housing needs of special needs populations (e.g., elderly, persons with disabilities, large households, female headed households, farmworkers, and persons experiencing homelessness). While the element includes some general reporting such as the City’s website including links to homeless services (p. III.A-6), it should still evaluate whether programs were effective, individually and cumulatively, and add or modify programs appropriately.
Staff and the Consulting Team (M-Group) will conduct a review of effectiveness of past policies and actions related to special needs populations.
B. Housing Needs, Resources, and Constraints
Enforcement and Outreach: While the element describes some outreach and capacity to enforce fair housing laws, it should also address compliance with existing fair housing laws as well as any past or current fair housing lawsuits, findings, settlements, judgements, or complaints.
The City has no fair housing lawsuits, settlements, judgements or existing complaints. The Housing Element (hereinafter “Element”) will be updated to clarify this point.
Racially Concentrated Areas of Affluence (RCAA): The element identifies that “much of the city is identified as within a Racially Concentrated Area of Affluence,” (p. H-II-63) but should also include specific analysis to better formulate appropriate programmatic response. This analysis should utilize local data and knowledge and other relevant factors. For example, the element could examine past land use practices, investments, quality of life relative to the rest of the City and region and then formulate appropriate programs to promote more inclusive communities and equitable quality of life. For example, the City should consider additional actions (not limited to the Regional Housing Needs Allocation (RHNA)) to promote housing mobility and improve new housing opportunities throughout the City.
A large percentage of Campbell is mapped as an RCAA.
The Element will be updated to clarify that Campbell has strategies to increase the production of affordable housing within Campbell and the RCAA that will diversify housing types and make Campbell more accessible for individuals of different backgrounds and socio-economic status.
The Element will also be revised to provide more analysis of past land use practices (single family zoning, lower density), including the legacy of racially restrictive covenants.
Disparities in Access to Opportunity: The element provides information on the access to opportunity through the TCAC opportunity map but must also provide a complete local and regional analysis of patterns and trends for all components. A comprehensive analysis should include the local and regional disparities of the educational, environmental, and economic scores through local, federal, and/or state data. It should also analyze persons with disabilities as well as access to transit. Please refer to page 35 of the Affirmatively Furthering Fair Housing (AFFH) guidebook (https://www.hcd.ca.gov/community-
development/affh/index.shtml#guidance) for specific factors that should be considered when analyzing access to opportunities as it pertains to educational, employment, environmental, transportation, and any other relevant factors.
The Element will be revised to augment analysis of TCAC compared to region, breaking out and evaluating Educational, Environmental, Economic Scores separately and analyze results.
Revise the Element to provide greater locational analysis of residences of persons with disabilities and access to transit.
(reference AFFH Guidebook)
Disproportionate Housing Needs, including Displacement risk: The element provides some discussion on cost burdened households and overcrowding.
However, the element must evaluate trends and patterns within the City, with regards to overpayment, substandard housing and persons experiencing homelessness. This analysis should utilize local data and knowledge and other relevant factors (Please see pages 24 and 25 of HCD’s Guidance at https://www.hcd.ca.gov/planning-and-community- development/affirmatively- furthering-fair-housing). For example, the element could utilize information from the City’s code enforcement to evaluate patterns of housing conditions or could contact service providers regarding patterns (areas of higher need) of persons experiencing homelessness and availability of services. Based on the outcomes of this analysis, the element should add or modify programs as appropriate.
The Element will be revised to show additional information on trends regarding homelessness, rent overpayment, and include mapping of code enforcement issues.
The Element will also be revised to document feedback received from service providers - regarding needs of ELI / homeless populations.
Identified Sites and AFFH: While the element provides some analysis of the identified sites and socio-economic concentrations, the element must analyze the identified sites with regards to the City’s RCAAs. In addition, the element should analyze the lack of units in higher opportunity or income areas, including census tracts in the Northwest and Southeast portion of the City, including two of the City’s census tracts labeled highest opportunity areas by the Tax Credit and Allocation Committee (Figure IV-5), which appear to have no identified sites or opportunity sites. A complete analysis should fully assess how the site inventory is expected to improve and/or exacerbate fair housing conditions, including any isolation of the RHNA. This analysis should address the location, number of units by income group, magnitude of the impact, and could consider topics such housing choice (not limited to the RHNA) in other areas of the City, existing or proposed anti-displacement policies, place-based investments, and how such strategies will improve fair housing conditions when paired with the identified sites. Based on the outcomes of this analysis, the element should add or modify programs as appropriate.
Revise the Element to document how the housing opportunity sites are dispersed throughout the City in the different TCAC areas, and limited opportunity for housing opportunity sites in certain parts of the City.
Document other strategies to increase affordable housing in all parts of the city, including ADU, SB9 and SB10 programs.
Clarify and document the City’s approach to facilitating affordable housing development in different areas in the City and expected production of affordable units in different BMR categories.
Document the City’s anit-displacement policies, including contracts with Project Sentinel.
Contributing Factors to Fair Housing Issues: Based on the outcomes of a complete analysis, the element should re-evaluation and prioritize contributing factors to fair housing issues.
Revise Element to show root cause analysis of fair housing issues and document how proposed goals, policies, and actions will address root cause issues.
Goals, Priorities, Metrics, Actions & Milestones: While the element includes general metrics for some programs, the element must be revised to add or modify goals and actions based on the outcomes of a complete analysis. Goals and actions must specifically respond to the analysis and to the identified and prioritized contributing factors to fair housing issues and must be significant and meaningful enough to overcome identified patterns and trends. Actions must have specific commitment, milestones, geographic targeting and metrics or numerical targets and, as appropriate, address housing mobility enhancement, new housing choices and affordability in higher opportunity or income areas (throughout the City), place-based strategies for community preservation and revitalization and displacement protection.
The element may, for example, commit to a firm date by which it will establish development standards for smaller housing types, including bungalow courts.
The element may also, for example, as discussed on the September 27, 2022 call, revise Program H-1m to make a specific commitment for establishing development standards for small units including missing middle housing types that are feasible in higher opportunity or income areas. To improve housing opportunities for persons experiencing homelessness or lower-income households employed in the City, the City may, for example, commit to identifying supportive housing projects in the City as part of Project Homekey and provide a date by which sites will be identified and by which the City will apply for funding. The City may also, for example, revise Program HE-6.D to make specific commitments to improve pedestrian safety and active mobility as a way to increase disparities in access to opportunity. Additionally, the element should commit to assessing and revising programs through a mid-cycle review.
Please see HCD’s AFFH memo for more information:
https://www.hcd.ca.gov/community-
development/affh/docs/affh_document_final_4-27-2021.pdf#page=23.
Revise the Element to clarify the City is updating its Objective Standards that will provide for different housing types, including bungalow courts, scheduled to be adopted in March 2023.
Update Homelessness strategy with identification of creation of a Homekey funded Permanent Supportive Housing project.
Document investments the City has made to improve pedestrian safety – including proposed Hamilton Avenue Precise Plan effort that is intended to improve pedestrian access to the Hamilton Avenue Light Rail.
Commit to a mid-cycle review.
2. Include an analysis of population and employment trends and documentation of projections and a quantification of the locality's existing and projected needs for all income levels, including extremely low-income households. (Gov. Code, § 65583, subd. (a)(1).)
Revise Element to provide more analysis of ELI households.
Include an analysis and documentation of household characteristics, including level of payment compared to ability to pay, housing characteristics, including overcrowding, and housing stock condition. (Gov. Code, § 65583, subd. (a)(2).)
See below
Analyze any special housing needs such as elderly; persons with disabilities, including a developmental disability; large families; farmworkers; families with female heads of households; and families and persons in need of emergency shelter. (Gov. Code
See below
Extremely Low-Income (ELI): While the element briefly quantifies ELI households but should specifically analyze their housing needs, including tenure, overpayment, available resources and strategies, effectiveness of past program Revise Element to show more analysis of ELI households – overpayment, resources available, housing needs, past program actions – new programs including development of permanent supportive housing for ELI households.
and the magnitude or disproportionate impacts on housing needs. Then, the element should add or modify programs as appropriate.
Housing Cost: While the element includes estimated rents for residents, it utilizes American Community Survey (ACS) data. The element should supplement census data with other sources (e.g., local knowledge).
Evaluate what other data is available that can be provided in the Housing Element.
Overpayment: The element must quantify and analyze the number of lower- income households overpaying by tenure (i.e., renter and owner).
Revise Element to provide requested data
Persons Experiencing Homelessness: The element provides some analysis of persons experiencing homelessness and describes some facility capacity in the County ( Table II-25). However, given the magnitude of the need and the significant increase in the Point in Time Count between 2019 and 2022, the City should evaluate resources and strategies, gaps in addressing needs and formulate appropriate strategies to address the unmet need. For example, the element could identify and evaluate capacity for permanent supportive housing, or other housing types, for example Single Room Occupancies (SROs), within the City, to evaluate needs and address unmet needs through program actions.
Develop and enfold in homelessness strategy including development of Permanent Supportive Housing project, creating of an unhoused specialist / homeless coordinator, support for the County’s Rapid Rehousing program ,coordination with the County on the creation of a regional shelter serving the West Valley area.
3. An inventory of land suitable and available for residential development, including vacant sites and sites having realistic and demonstrated potential for redevelopment during the planning period to meet the locality’s housing need for a designated income level, and an analysis of the relationship of zoning and public facilities and services to these sites. (Gov. Code, § 65583, subd. (a)(3).)
See Below
Small Sites: The site inventory currently includes 64 sites that are less than 0.5 acres, including several sites with existing housing (p. H-IV-30 and Table A).
Sites smaller than a half-acre in size are deemed inadequate to accommodate housing for lower-income housing unless it is demonstrated that sites of equivalent size and affordability were successfully developed during the prior planning period or unless the housing element describes other evidence to HCD that the site is adequate to accommodate lower- income housing (Gov. Code, § 65583.2, subd. (c)(2)(A).). The element identifies several site groupings with potential for consolidation. However, the element must also evaluate whether those sites are suitable to accommodate housing for lower-income households and add or modify programs as appropriate. For example, the element could list past consolidations by the number of parcels, number of owners, zone, number of units, affordability and circumstances leading to consolidation and then relate those trends to the identified sites or could explain the potential for consolidation on a site-by-site basis. Based on the outcomes of the analysis, the element should modify policies and programs, including a specific commitment to ensure that maximum densities can be accommodated on all sites in the inventory.
Modify Inventory to remove several smaller sites and revise BMR distirbution to remove assignment to smaller sites.
Large Sites: The inventory includes several sites over ten acres, including one
16.4- acre site with an operating commercial shopping center. While the element clarifies there is interest from the property owner, it should analyze the suitability of these sites to accommodate housing for lower-income households or rescale assumptions. The City described its strategy for “carving out” portions of some larger parcels, where some portions of parcels can be developed while maintaining other existing residential and commercial uses. However, the City should clarify the timeline and procedure by which these carveouts will occur. For example, the element should discuss any recent developments of similar size and affordability, opportunities for parceling, phasing or site planning and generally address how housing affordable to lower-income households will occur given typical state funded developments are approximately 50 to 150 units then rescale assumptions if necessary and add or modify programs as appropriate.
Revise Element to clarify large sites identified will develop as “carve outs”, simulating a smaller site. Document proposed strategies to increase affordable housing production on large sites, including the creation of an Affordable Housing Overlay Zone.
City-Owned Sites: The element identified two City-Owned sites to accommodate 231 housing units; however, must analyze the suitability and availability of those sites for development in the planning period, including how the sites will be available (e.g., surplus or lease), any known barriers, an anticipated schedule and other relevant factors. In addition, the element should include a program with numerical objectives that ensure compliance with the Surplus Land Act, provides incentives and actions along with a schedule to facilitate development of City- owned sites. Actions should include outreach with developers, issuing requests for proposals, incentives, fee waivers, priority processing, financial assistance and alternative actions if the sites do not become available at a reasonable point in the planning period (e.g., 2028).
Update Element to modify approach to city owned sites, removing parking garage, and providing more details and milestones on development of corporation yard.
Suitability of Nonvacant Sites: The element must include analysis demonstrating the potential for additional development on nonvacant sites and describes existing property owner interest (p. H-IV-21). While the element mentions underutilized sites were identified based on interest in development, structure/site conditions and development on adjacent sites with similar characteristics, it must support the validity of these factors in demonstrating the potential for redevelopment. For example, the element currently lists prior uses in recent development activity but could also discuss how the recent trends support the various factors. In addition, the element could consider additional factors such existing versus allowable floor area and reflect those values in the sites inventory. Finally, the element should account for the extent existing uses impede additional residential development including market demand for the existing use and existing leases or contracts that would perpetuate the existing use or prevent additional residential development.
The housing element relies upon nonvacant sites to accommodate more than 50 percent of the RHNA for lower-income households. As a result, the housing element must demonstrate existing uses are not an impediment to additional residential development and will likely discontinue in the planning period. (Gov.
Code, § 65583.2, subd. (g)(2).) For your information, absent findings in the resolution as part of adoption based on substantial evidence, the existing uses will be presumed to impede additional residential development and will not be utilized toward demonstrating adequate sites to accommodate the RHNA.
Modify Element to highlight actions City has taken to encourage redevelopment of non-vacant sites, including significant increase in density and reduction in Parking standards. Document existing developer interest in development of non-vacant sites and facilitate interest letters from property owners / developers on non-vacant sites.
Electronic Sites Inventory: For your information, pursuant to Government Code section 65583.3, the City must submit an electronic sites inventory with its adopted housing element. The City must utilize standards, forms, and definitions adopted by HCD. Please see HCD’s housing element webpage at https://www.hcd.ca.gov/planning-and- community-development/housing-elements for a copy of the form and instructions. The City can reach out to HCD at [email protected] for technical assistance.
Resubmit Element using requested forms.
Zoning for a Variety of Housing Types:
· Single Room Occupancy (SRO) Units: The City categorizes SROs under the definition of rooming and boarding houses, “that are rented to between 3 to 5 persons for profit…”(p. H-II-109). The City should analyze this definition as a possible constraint. In addition, the City allows SROs in only certain zones and requires a Conditional Use Permit (CUP) in all zones allowed. The element should demonstrate zoning, development standards, including parking, and permit procedures encourage and facilitate SROs or add or modify programs as appropriate.
Modify Element to identify City will update its Zoning Ordinance addressing SRO’s and permitting
• By-right Permanent Supportive Housing: While the element states that supportive housing is permitted in all residential zoning districts by right (p. H-II- 109), supportive housing shall be a use by-right in zones where multifamily and mixed uses are permitted, including nonresidential zones permitting multifamily uses pursuant to Government Code section 65651. The element must demonstrate compliance with these requirements and include programs as appropriate.
Modify Element to identify City will update its Zoning Ordinance regarding Permanent Supportive Housing to comply with state law.
• Emergency Shelters: The element was revised to state that emergency shelters are allowed by-right in a “portion of the M-1 zone” and states that the area is “well served by transit and commercial services” (p. H-III-107). However, the element must also identify and analyze any development standards (e.g., spacing, parking, concentration requirements) and other requirements imposed on emergency shelters. Lastly, the element must describe compliance with Government Code section 65583, subdivision a)(4)(A) or include a program to comply with this requirement. For your information, pursuant to Government Code section 65583, subdivision a)(4)(A), parking requirements should be limited to allowing sufficient parking to accommodate all staff working in the emergency
Modify Element to identify that City will update its Zoning Ordinance regarding development standards for emergency shelters. shelter, provided that the standards do not require more parking for emergency shelters than other residential or commercial uses within the same zone.
• Accessory Dwelling Units (ADU): HCD records indicate permitted ADUs of 5 in 2018, 8 in 2019, 54 in 2020, and 38 in 2021, figures that are inconsistent with those in the element. The element should reconcile these numbers either in the element or Annual Progress Reports (APRs) and adjust assumptions as appropriate.
After a cursory review of the City’s ordinance, adopted August 16, 2022, HCD discovered some areas which are inconsistent with State ADU Law. HCD will provide a complete listing of ADU non-compliance issues under a separate cover. As a result, the element should add a program to update the City’s ADU ordinance to comply with state law.
Review and update data and statistics regarding ADU’s.
Land Use Controls: The element must identify and analyze all relevant land use controls impacts as potential constraints on a variety of housing types. The analysis should analyze land use controls independently and cumulatively with other land use controls. The analysis should specifically address requirements related to parking for small units including SROs and missing middle housing types; height limits particularly in multifamily zones; maximum lot coverages; minimum lot areas; minimum site sizes; public and private open space requirements; lot coverage and limits on allowable densities. The analysis should address any impacts on cost, supply, feasibility, timing, approval certainty and ability to achieve maximum densities and include programs to address identified constraints. Finally, pursuant to public comments, the City must make a firm commitment to reduce its parking requirements across residential zones.
Update Element to clarify that the City will adopt Objective Standards in March 2023, addressing this issue.
Processing and Permit Procedures: The element identifies that most developments are subject to a Site and Architectural Review and lists various finding, most notably “The project will aid in the harmonious development of the immediate area”. The element then mentions this is similar to other jurisdictions but should evaluate the impacts of the finding on housing supply (number of units), cost, timing, feasibility and particularly approval certainty and then add programs to address identified constraints.
Update Element to clarify that the City will adopt Objective Standards in March 2023, addressing this issue.
Persons with Disabilities: The element describes the City’s reasonable accommodation process and lists its factors for consideration (pp. H-II-141), including the potential impact on surrounding uses. The element then notes this factor can be addressed by evaluating alternatives to addressing the needs of persons with disabilities. First, a factor such as impact on surrounding uses is essentially a conditional use finding and a reasonable accommodation procedure should be a unique exception process, instead using factors such as whether the accommodation poses a fundamental alternation of zoning and land use – a far different standard that should be employed in a manner to promote access to housing opportunities for persons with disabilities. Second, the surrounding use factor appears to be employed in a manner that seeks to alter requests and fit with the surrounding areas as opposed to considering the exception request. For these reasons alone, the element should identify this finding as a constraint and modify Program H-5g (Reasonable Accommodation) to remove the constraint early in the planning period (within two years).
Modify Element to identify that City will update its Zoning Ordinance regarding standards and findings for Reasonable Accomodation.
In addition, the element indicates group homes for seven or more persons are allowed in all residential zones but subjects group homes to a conditional use permit (CUP), unlike other similar uses. The element should specifically analyze these constraints for impacts on housing supply and choices and approval certainty and objectivity for housing for persons with disabilities and include programs as appropriate.
Modify Element to identify City will update its Zoning Ordinance regarding group homes to comply with state law.
Programs must demonstrate that they will have a beneficial impact within the planning period. Beneficial impact means specific commitment to deliverables, measurable metrics or objectives, definitive deadlines, dates, or benchmarks for implementation. Deliverables should occur early in the planning period to ensure actual housing outcomes. Several programs and actions have timelines that could be moved earlier in the planning period to ensure a beneficial impact.
Examples include Programs H-1E (Preapproved ADU Plans), H-1m (Microunit Standards), H-2c (Short term Rental Ordinance), H-3e (Reuse Site Ministerial Review), and H-5t (Employee Housing).
Evaluate timelines for these programs and update Element .
C. Housing Programs
Additionally, programs must have specific commitment to clear housing outcomes or deliverables. Several programs include actions with no description of how those actions will be implemented (e.g., “support”, “study”, “explore”, “evaluate”, etc.,). Programs should be amended, to include specific commitment to a housing related outcome.
Examples include Programs H-1b (Commercial Linkage Fee), H-1c (Affordable Housing Overlay Zone), H-1k (Achieve Target Densities), H-1m (Micro-unit Standards), H-2d (Workforce Housing Ordinance), H-2e (Housing Rehabilitation Loans), H-2g (Preservation of Assisted Housing), H-3a (Parking Requirement Reduction) H-5d (Shared Housing Program), H-5o (ELI Unit Development), and H-5s (City Density Bonus).
Modify Element to update Milestones for these programs.
As noted in Finding B3, the element does not include a complete site analysis; therefore, the adequacy of sites and zoning were not established. Based on the results of a complete sites inventory and analysis, the City may need to add or revise programs to address a shortfall of sites or zoning available to encourage a variety of housing types.
See response regarding Housing Opportunity Sites.
In addition, programs targeting development of publicly owned land (e.g., Program H- 5q) should include a schedule of actions for development in the planning period consistent with the assumptions in the sites inventory, including coordination with developers, requests for proposal, facilitating entitlements, incentives, issuing building permits and compliance with the Surplus Land Act.
See response regarding City-Owned Housing Opportunity sites.
As noted in Finding B4, the element requires a complete analysis of potential governmental and nongovernmental constraints. Depending upon the results of that analysis, the City may need to revise or add programs and address and remove or mitigate any identified constraints.
See responses above.
As noted in Finding B1, the element must include a complete assessment of fair housing. Based on the outcomes of that analysis, the element must add or modify programs.
See responses above.
Program H-2g states an objective to “participate in the preservation of at-risk units by providing financial and/or technical assistance” (p. H-IV-55). However, the program should make a specific and firm commitment to maintain the long- term affordability of these units, including a clear commitment of financial assistance or support of funding applications, coordination with qualified entities and support, education and assistance for tenants.
Update approach to addressing at-risk units – including actions and timeline to contact landlords, apply for funding to continue to buy down affordability of units and subsequent actions.
While the element includes quantified objectives for new construction, it should also consider quantified objectives for rehabilitation and preservation of existing affordable housing. For your information, the quantified objectives do not represent a ceiling, but rather set a target goal for the City, based on needs, resources, and constraints.
Review Element to consider revisions to quantified objecives.
While the City made efforts to include the public through workshops and surveys, moving forward, the City should employ additional methods for public outreach efforts in the future, particularly to include lower-income and special needs households and neighborhoods with higher concentrations of lower-income households. In addition, several comments questioned the lack of commitments around reducing parking minimums and ensuring the feasibility of missing middle housing types. The City should consider these comments and make adjustments as appropriate. The City should also analyze the feasibility of sites identified by members of the public, including the site of a former Elephant Bar and Fry’s Electronics and make adjustments as appropriate. The City could also, for example, target higher densities around the Hamilton 880 corridor. To AFFH, the element could revise Program H-3f and commit to development of a rent stabilization ordinance that limits annual rent increases or develop a city-wide portal for affordable rentals available. Finally, to address noted jobs-housing relationships, the City could also, for example, conduct targeted stakeholder interviews or establish a committee representative of lower-income households and commuters who work inside the City in future public outreach efforts. For additional information, see the Building Blocks at
http://www.hcd.ca.gov/community- development/building-blocks/getting- started/public-participation.shtml.
Consider creation of Housing Commission and approach to membership on Commission that encourages inclusivity of stakeholders in under- represented groups.
251 Llewellyn Ave • Campbell, CA 95008 • (408)379-3790 • www.PacificClinics.org
November 22, 2022
To the Chair and Members of the Planning Commission :
Pacific Clinics is pleased to learn that our current location and Pulte's housing site at 251 Llewellyn Ave. will remain a “Housing Opportunity Site” under all 3 options staff has recommended.
As you may know, Pulte has been in conversation with the City of Campbell over the past 18 months to expedite their application process, which will not only bring much needed housing to the city, but also help to fill the “missing middle” densities currently lacking in the City's housing stock.
Thank you for your action and please feel free to reach out with any questions you may have.
Kind regards,
Sincerely,
Don Taylor
Regional Executive Director
1 Stephen Rose
From: Bill Baron <[email protected]>
Sent: Tuesday, November 8, 2022 2:20 PM
To: Stephen Rose
Cc: Bill Baron
Subject: RE: 500 E. Hamilton Avenue
Stephen—
Thank you. Since we are conversing about 500 E. Hamilton Avenue, it seems as though the City has identified the site as serving, more broadly, the lower scale of affordability—though we’ll see what the future holds.
For development applications that envision serving the lower scale of affordability levels—a housing type desperately
lacking in today’s housing inventory within Campbell and most of its neighboring cities—we envision a lower per unit square foot average size than that noted by you. Of course, you note it, correctly, in the context of “maximum” average. It could very well be that density should be, arguably, higher depending upon specific project circumstances.
You further note that the “city is working on adopting standards for multi‐family residential development…with our General Plan and Housing Element in March of 2023. That document may impose more restrictive requirements than those under broader consideration by the General Plan”. We understand that this is, indeed, a process. That said, we
would strongly encourage the city to not “impose more restrictive requirements”. Up to this point, from our city halls to the state house—all voices are in general agreement—the bay area remains in an extreme housing shortage. Words such as “impose more restrictive…”, while I know thoughtfully shared serve to negate and in part to marginalize where we find ourselves in our housing crisis.
In my judgement, there is one primary reason our state government has, in essence, co‐opted local land use control— and that’s in large measure due to local jurisdictions not having treated our housing shortage as a crisis. Certainly with words…no question they have—we hear the term all the time. But actions? The numbers of units built in Campbell and its bay area neighboring cities speak volumes and share the facts. Up until quite recently, the state hadn’t really much cared either as to the much ballyhooed “crisis”. But times have most certainly changed—and may further still.
One last comment. Your reference to a potential specific/precise plan is concerning. Such efforts are costly, time consuming and serve to further delay the delivery of solutions to the standing crisis in an area where significant density
can and should otherwise occur. We encourage another way rather than 3 years of a well‐intentioned money pit—all to create an otherwise well‐intentioned vision that may be worthless on arrival as so many differing plans have before throughout the bay area. We encourage collaboration on a specific key issue or two—and more—but do not see the need for a specific/precise plan in this area.
Simply, as we look to continue to work cooperatively together, we equally encourage Campbell staff and leadership to find ways to be less restrictive, less time consuming and less costly in its policy promulgation rather than the alternative.
Regards,
Bill
_____________________________________________
William B. Baron
MANAGING PARTNER
Brandenburg Properties
1122 Willow Street, Suite 200
1 Stephen Rose
Subject: RE: Notes on bike planning.
From: Adam Buchbinder <[email protected]>
Sent: Tuesday, November 8, 2022 6:06 PM
To: Rob Eastwood <[email protected]>; Stephen Rose <[email protected]> Subject: Notes on bike planning.
Hi! I saw Campbell's HCD letter, and I noticed this:
The City may also, for example, revise Program HE‐6.D to make specific commitments to improve pedestrian safety and active mobility as a way to increase disparities in access to opportunity.
I've been working on a bike plan. I suggest the following two programs.
First, complete VTA's bike superhighways project; primarily this means the San Tomas Aquino Creek Trail south through Campbell to the Los Gatos Creek trail, which would connect us to the larger regional bike network. The VTA is the lead agency, and other cities have signed on, but I'm not sure what's stalling the program. The City could make a commitment to our portion.
Second, establish a Bike Master
Plan along the lines of San Mateo's 2020 Plan. This takes a map of the Level of Traffic Stress (like the one the VTA provides), determines where the network could be improved, and ranks projects by a rubric that would produce that sort of connected low‐stress network. (They're targeting LTS 2, I believe.) See the rubric on PDF page 64 here, and the prioritized project list starting on PDF page 72.
Adam Buchbinder