Cities Index.
Agenda packet

Carmel-by-the-Sea City Council
July 7, 2026

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Agenda packet
Meeting
July 7, 2026
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Carmel-by-the-Sea City Council
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652
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Text extracted from the city's file for reading and search. Open the original on carmelbytheseaca.api.civicclerk.com. That file is the official record.

Appendix A – Housing Needs and Fair Housing Report A-23 Carmel-by-the-Sea 6th Cycle Housing Element Amendment July 7, 2026 has the lowest unemployment rate with less than 1 percent of unemployed residents. This indicates an approximate 4.8 percent less than the County, 5 percent less than the Del Rey Oaks, and 3.8 percent less than Pacific Grove.

Table A-6 Unemployment Rate, Carmel-by-the-Sea, 2019
Jurisdictions Unemployment Rate
Monterey County 4.9%
Carmel-by-the-Sea 0.1%
Del Rey Oaks 5.1%
Pacific Grove 3.9%
Source: U.S. Census Bureau, ACS 5-Year Estimates, 2019
The Monterey Bay Area approved Regional Housing Needs Assessment (RHNA) Methodology is broken down into four income levels:
 Very Low Income (50 percent or less of the County’s median income);  Low Income (50-80 percent of the County’s median income);  Moderate Income (80-120 percent of the County’s median income); and  Above moderate Income (120 and above the County’s median income).

Carmel-by-the-Sea’s RHNA allocation is presented below in Table A-7.

Table A-7 Regional Housing Needs Allocation
Income Group Percentage of AMI Share
Extremely Low-Income* <30 57
Very Low-Income <50 56
Low-Income 50-80 74
Moderate-Income 80-120 44
AboveModerate-Income 120+ 118
Total 349
Source: City of Carmel-by-the-Sea, 2023
* Extremely low-income RHNA is found as a subset within the very low-income category for all other tables in this document.

In Monterey County, the median household income in 2019 was an estimated $71,015 compared to Carmel-by-the-Sea at $98,188. Table A-8 lists occupations by mean salary in Monterey County.

According to Table A-8, the occupations that fall below 50 percent of the median income are Food Preparation and Serving-Related Occupations; Personal Care and Services Occupations; and Farming, Fishing, and Forestry Occupations. The majority of occupations in Monterey County have an average income that is low (50-80 percent AMI) or very low (<50 percent AMI). If applied to Carmel-by-theSea, it should be anticipated that affordable housing is needed to accommodate potential low- and very low-income households.

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Appendix A – Housing Needs and Fair Housing Report A-24 Carmel-by-the-Sea 6th Cycle Housing Element Amendment July 7, 2026 Table A-8 Occupations by Mean Salary, Monterey County, 2019 Occupation Salary
Management Occupations $117,738
Business and Financial Operations Occupations $78,900
Computer and Mathematical Occupations $96,980
Architecture and Engineering Occupations $92,554
Life, Physical, and Social Science Occupations $84,516
Community and Social Services Occupations $59,549
Legal Occupations $103,094
Education, Training, and Library Occupations $69,296
Arts, Design, Entertainment, Sports, and Media Occupations $56,599 Healthcare Practitioners and Technical Occupations $115,486 Healthcare Support Occupations $42,625
Protective Service Occupations $70,161
Food Preparation and Serving-Related Occupations $30,127 Building and Grounds Cleaning and Maintenance Occupations $36,330 Personal Care and Service Occupations $31,984
Sales and Related Occupations $42,099
Office and Administrative Support Occupations $44,239
Farming, Fishing, and Forestry Occupations $29,901
Construction and Extraction Occupations $60,870
Installation, Maintenance, and Repair Occupations $54,180 Production Occupations $41,905
Transportation and Material Moving Occupations $37,144
Source: California Employment Development Division, Occupational Wage data, 2019 Household Characteristics
Characteristics of a household include household type and size, income, affordability, and special needs groups. According to HCD, a household is defined as “All persons who occupy a housing unit. The occupants may be a single family, on person living alone, two or more families living together, or any groups of related or unrelated persons who share living arrangements.” Large families, single parent households, female-headed households, or extremely low- and low-income households may be classified as Special Needs groups. Special Needs groups are identified due to the unique nature of household characteristics and potential housing challenges faced. The following section examines household characteristics trends in Carmel-by-the-Sea and the region.

Table A-9 provides an overview of the projected housing units needed in Monterey County, Carmel-bythe-Sea, and nearby cities, Del Rey Oaks and Pacific Grove.22 Carmel-by-the-Sea is forecast to have a household growth of approximately 1 percent by 2045 – an increase of 42 housing units. 22 From AMBAG Regional Growth Forecast, 2022

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Appendix A – Housing Needs and Fair Housing Report A-25 Carmel-by-the-Sea 6th Cycle Housing Element Amendment July 7, 2026 Compared to the County, this reflects 18 percent less projected growth and 2 percent less growth than Pacific Grove. Of the nearby cities, the City of Del Rey Oaks has the highest projected increase in housing unit growth at 61 percent.

Table A-9 Housing Forecast by Jurisdiction, 2015-2045
Jurisdictions
Population Change 2015 - 2045
2015 2020 2025* 2030* 2035* 2040* 2045* Numeric Percent Monterey County 139,177 141,764 146,716 153,852 159,100 162,612 165,328 26,151 19% Carmel-by-the-Sea 3,417 3,437 3,437 3,442 3,450 3,453 3,459 42 1% Del Rey Oaks 741 741 762 809 848 1,052 1,195 454 61%
Pacific Grove 8,184 8,201 8,214 8,267 8,336 8,400 8,463 279 3% Source: AMBAG Regional Growth Forecast, 2022 NOTE: *Projected growth values Household Type and Size
Figure A-12 illustrates household characteristics by type in 2019 for Carmel-by-the-Sea, the County, and nearby cities, Del Rey Oaks and Pacific Grove. In Carmel-by-the-Sea, the largest household type was married-couple family households (47 percent) followed by single-person households (40 percent).

This is consistent with the County and nearby cities. Carmel-by-the-Sea has the lowest percentage of female-headed households (6 percent) compared to the County (13 percent), Del Rey Oaks (7 percent), and Pacific Grove (9 percent).

Figure A-12 Household by Type by Jurisdiction, 2019
Source: U.S. Census Bureau, ACS 5-Year Estimates, 2019
Figure A-13 illustrates household changes between 2010-2019 in Carmel-by-the-Sea. Over the last decade, married-couple family households have remained the largest household type in the City followed by single-person households. Since 2015, married-couple family households have begun declining, while single-person households have increased. Female-headed households experienced the

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Appendix A – Housing Needs and Fair Housing Report A-26 Carmel-by-the-Sea 6th Cycle Housing Element Amendment July 7, 2026 most fluctuation between 2010-2019, showing a steady increase between 2010-2013, then slowly decreasing through 2019 to 6 percent (7 percent decrease between 2013-2019). Male-headed households have slightly increased since 2010 from zero to 2 percent in 2019. These changes in household type over time indicate a need for housing options that appeal to both family-sized and smaller-sized households (keeping affordability in mind).

Figure A-14 illustrates households by household size for Carmel-by-the-Sea, the County, and nearby cities. Carmel-by-the-Sea’s largest household type according to size is 2-person households (42 percent) followed by 1-person households (40 percent). This is consistent with findings in Figure A-13, with married-couple family households remaining the largest household type since 2010 followed by singleperson households. This reflects a demand for affordable housing units appealing to married-couple and single-person households.

Figure A-13 Changes in Household Type, Carmel-by-the-Sea, 2010-2019 Figure A-14 Households by Household Size by Jurisdiction, 2019 Source: U.S. Census Bureau, ACS 5-Year Estimates, 2019

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Appendix A – Housing Needs and Fair Housing Report A-27 Carmel-by-the-Sea 6th Cycle Housing Element Amendment July 7, 2026 Household Income
Affordability is a key component in determining the housing needs of a community. Household income determines the ability of a household to purchase or rent a housing unit. However, fluctuating household incomes may result in the need to spend disproportionate amounts of income on housing costs, referred to as overpayment or cost burden. As a result, this may also lead to overcrowding and/or substandard living conditions.

The following are income categories based on area median income (AMI) according to HCD:
 Extremely low-income: households earning 0-30 percent of AMI;  Very low-income: households earning 30-50 percent of AMI;  Low-income: households earning 50-80 percent of AMI;
 Moderate-income: households earning 80-100 percent of AMI; and  Above-moderate income: households earning 100-120 percent of AMI.

Government Code §65583(a) defines extremely low-income households as earning 30 percent or below area median income, and considers them as a subset of the very low-income category. The extremely low-, very low-, and low-income groups are referred to as lower-income. In Carmel-by-the-Sea 28 percent of households are considered lower-income.

Table A-10 summarizes households by income category in Carmel-by-the-Sea in 2019. Above moderate-income households make up the majority of households in the City (62 percent) followed by lower-income households (28 percent). Approximately 7 percent of households in Carmel-by-the-Sea identify as extremely low-income. This reflects a need for more affordable housing in the City, and in tandem with Figure A-13 and Figure A-14 findings, it is likely the demand for single-person households is accompanied by a need for affordable options.

Table A-10 Households by Income Category, Carmel-by-the-Sea, 2019 Income Category
(% of County MFI) Households Percent
Extremely Low-Income (30% MFI or less) 140 7%
Very Low-Income (30-50% MFI) 170 9%
Low-Income (50-80% MFI) 235 12%
Moderate-Income (80-100% MFI) 185 10%
Above Moderate-Income (>100% MFI) 1,200 62%
Total 1,930 100%
Source: Department of Housing and Urban Development (HUD) Comprehensive Housing Affordability Strategy (CHAS), 2015-2019 Figure A-15 illustrates the median household income in Carmel-by-the-Sea, the County, and nearby cities in 2019. Carmel-by-the-Sea’s median household income was $98,188 – approximately $27,173 higher than the County ($71,015). The City of Del Rey Oaks had the second highest median household income at $95,000 followed by Pacific Grove at $88,250. Understanding Carmel-by-the-Sea’s median household income determines what income category households identify with and what affordability levels look like for the community.

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Appendix A – Housing Needs and Fair Housing Report A-28 Carmel-by-the-Sea 6th Cycle Housing Element Amendment July 7, 2026 Figure A-15 Median Household Income by Jurisdiction, 2019 Source: U.S. Census Bureau, ACS 5-Year Estimates, 2019
Figure A-16 highlights the median household income from 2010 to 2019, throughout the region.

Between 2010 and 2015, Carmel-by-the-Sea’s median household income remained relatively stable, and saw a 31.3 percent increase between the years of 2015 and 2019. Compared to other regional jurisdictions, Monterey County has maintained the lowest median household income, showing a slight decrease from 2010 to 2015, and a 20.8 percent increase from 2015 to 2019. The Cities of Del Rey Oaks and Pacific Grove followed similar trends to Carmel-by-the-Sea in that they increased slightly between the years of 2010 and 2015, and then increased significantly between 2015 and 2019.

Figure A-17 provides a breakdown of 2019 incomes by category in Carmel-by-the-Sea. Approximately 43 percent of households are earning $100,000 or more (more than the City’s annual median income).

Conversely, 26 percent households earn an annual income less than $50,000 ($48,188 less than the City’s annual median income). Approximately 41 percent of households are earning below the City’s annual median income, of which 10 percent earn less than $25,000.

Figure A-16 Regional Median Household Income, 2010-2019 Source: U.S. Census Bureau, ACS 5-Year Estimates, 2010, 2015, 2019

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Appendix A – Housing Needs and Fair Housing Report A-29 Carmel-by-the-Sea 6th Cycle Housing Element Amendment July 7, 2026 Figure A-17 Income by Category, Carmel-by-the-Sea, 2019 Source: U.S. Census Bureau, ACS 5-Year Estimates, 2019
Figure A-18 illustrates median household income across Carmel-by-the-Sea. According to the HCD AFFH Data Viewer, Carmel-by-the-Sea households experience variation in median household income based on location. Households located in the center of the City reportedly earn less than the City’s annual median income ($98,188) and households located in the north and south earn more (>$87,100 - <125,000).

The household income characteristics in Carmel-by-the-Sea reveal a demand for the development of more affordable housing options that appeal to both lower-income and above-moderate households.

Carmel-by-the-Sea is comprised primarily of above moderate-income households (62 percent), most of which identify as married-couple families (47 percent). Nonetheless, 28 percent of households are lower-income and 40 percent of households identify as single-persons. Affordable housing in Carmelby-the-Sea must accommodate these households as well despite their non-majority makeup.

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Appendix A – Housing Needs and Fair Housing Report A-30 Carmel-by-the-Sea 6th Cycle Housing Element Amendment July 7, 2026 Figure A-18 Median Income by Block Group, Carmel-by-the-Sea, 2015-2019 Source: California Department of Housing and Community Development, AFFH Data Viewer

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Appendix A – Housing Needs and Fair Housing Report A-31 Carmel-by-the-Sea 6th Cycle Housing Element Amendment July 7, 2026 Figure A-19 illustrates housing by tenure in Carmel-by-the-Sea, the County, and nearby cities. Fiftyseven (57) percent of households in Carmel-by-the-Sea are owners and 43 percent are renters. This reflects an approximate 6 percent higher owner household population than the County (51 percent), 11 percent higher than Pacific Grove (46 percent), and 14 percent lower than Del Rey Oaks (71 percent).

Figure A-19 Housing Tenure by Jurisdiction, 2019
Source: U.S. Census Bureau, ACS 5-Year Estimate, 2019
A.3 Disproportionate Housing Needs
Housing Problems and Severe Housing Problems
The following section details housing problems and severe housing problems in Carmel-by-the-Sea according to the Census Bureau Comprehensive Housing Affordability Strategy (CHAS).

Disproportionate Housing Needs
“Disproportionate housing needs generally refers to a condition in which there are significant disparities in the proportion of members of a protected class experiencing a category of housing need when compared to the proportion of members of any other relevant groups, or the total population experiencing that category of housing need in the applicable geographic area. For purposes of this definition, categories of housing need are based on such factors as cost burden and severe cost burden, overcrowding, homelessness, and substandard housing conditions.” Source: California Department of Housing and Community Development Guidance, 2021, page 39.

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Appendix A – Housing Needs and Fair Housing Report A-32 Carmel-by-the-Sea 6th Cycle Housing Element Amendment July 7, 2026 The CHAS data set provides in-depth analysis on housing needs by income level according to types of households. According to CHAS, housing problems are defined as having one or more of the following variables:
 Incomplete kitchen facilities;
 Incomplete plumbing facilities;
 More than one person per room; and
 Cost burden greater than 30 percent.

Severe housing problems are defined as having one or more of the following variables:
 Incomplete kitchen facilities;
 Incomplete plumbing facilities;
 More than 1.5 persons per room; and
 Cost burden greater than 50 percent.

Additionally, CHAS defines cost burden as the ratio of housing costs to household income. The following defines cost burden by renter and owner:
 Renter Cost Burden: gross rent (contract rent plus utilities); and  Owner Cost Burden: select monthly owner costs including mortgage payment, utilities, association fees, insurance, and real estate taxes.

Figure A-20 and Figure A-21 illustrate housing problems by tenure and severe housing problems by tenure in Carmel-by-the-Sea during 2019. Approximately 60 percent of renter households have at least one of four housing problems and 36 percent have at least one of four severe housing problems. In contrast, 47 percent of owner households experience at least one housing problem and 25 percent have at least one severe housing problem.

Figure A-20 Housing Problems by Tenure, Carmel-by-the-Sea, 2015-2019 Source: U.S. Census Bureau, CHAS Data, 2015-2019
Note: The four housing problems are: incomplete kitchen facilities, incomplete plumbing facilities, more than 1 person per room, and cost burden greater than 30%.

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Appendix A – Housing Needs and Fair Housing Report A-33 Carmel-by-the-Sea 6th Cycle Housing Element Amendment July 7, 2026 Figure A-21 Severe Housing Problems by Tenure, Carmel-by-the-Sea, 2015-2019 Source: U.S. Census Bureau, CHAS Data, 2015-2019
Note: The four housing problems are: incomplete kitchen facilities, incomplete plumbing facilities, more than 1.5 person per room, and cost burden greater than 50%.

Overcrowding
Understanding the prevalence of overcrowded households within a community helps determine the need for affordable and adequately sized housing units for the community. Overcrowding is defined as a household with more than one occupant per room excluding bathrooms and kitchens. Units with more than 1.5 persons per room are considered severely overcrowded. Overcrowding may occur due to a lack of available affordable and/or adequately sized housing units. Cultural norms and customs combined with low-income or lack of adequately size housing units can result in overcrowding too. For example, in Asian culture, households are often comprised of multi-generations. If this custom is also compounded by low-income or lack of adequately sized housing units overcrowding may occur.

Figure A-22 illustrates overcrowding by severity in Carmel-by-the-Sea, the County, and nearby cities in 2019. The City of Del Rey Oaks households experience the least amount of overcrowding (0.8 percent) and no severe overcrowding, compared to Carmel-by-the-Sea households that experience zero percent moderate overcrowding, but 6 percent severe overcrowding. Monterey County has a higher overall percentage of households that experience overcrowding (9 percent) and severe overcrowding (5 percent) compared to Carmel-by-the-Sea.

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Appendix A – Housing Needs and Fair Housing Report A-34 Carmel-by-the-Sea 6th Cycle Housing Element Amendment July 7, 2026 Figure A-22 Overcrowding by Severity by Jurisdiction, 2019 Source: U.S. Census Bureau, ACS 5-Year Estimate, 2019
Figure A-23 illustrates overcrowding by tenure and severity in Carmel-by-the-Sea during 2019. Renter households in Carmel-by-the-Sea experience 8 percent more overcrowding than owner households.

While renter households do not experience overcrowding (more than 1-person per room), 10 percent experience severe overcrowding (more 1.5-persons per room). Similarly, owner households in Carmelby-the-Sea do not experience overcrowding, but 2 percent do experience severe overcrowding.

Figure A-23 Overcrowding by Tenure and Severity, Carmel-by-the-Sea, 2019 Source: U.S. Census Bureau, ACS 5-Year Estimate, 2019
Figure A-24 illustrates overcrowded households in Carmel-by-the-Sea. According to the HCD AFFH Data Viewer, Carmel-by-the-Sea households experience no variation in overcrowding based on location.

In the City, overcrowding rates are less than 8.2 percent.

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Appendix A – Housing Needs and Fair Housing Report A-35 Carmel-by-the-Sea 6th Cycle Housing Element Amendment July 7, 2026 Figure A-24 Overcrowded Households, Carmel-by-the-Sea
Source: California Department of Housing and Community Development, AFFH Data Viewer

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Appendix A – Housing Needs and Fair Housing Report A-36 Carmel-by-the-Sea 6th Cycle Housing Element Amendment July 7, 2026 Cost Burden
According to HCD, overpayment or cost burden is measured as households spending more than 30 percent of their gross income including utilities for housing; severe overpayment or severe cost burden is measured as households spending 50 percent or more of their gross income for housing. For the duration of this report, overpayment will be referred to as cost burden.

The cost burden rates of owners and renters in a community provide insight to housing needs such as, the affordability of the local housing market and the availability of housing units that accommodate household needs like size and housing type. Additionally, federal and state agencies examine cost burden to determine a community’s need for housing assistance.

Figure A-25 illustrates cost burden severity in Carmel-by-the-Sea, the County, and nearby cities.

Carmel-by-the-Sea household cost burden rates are similar to the County. In Carmel-by-the-Sea, 46 percent of households experience some level of cost burdened, of which 23 percent are severely cost burdened, while the County has a cost burden rate of 22 percent and a severe cost burden rate of 18 percent. The cities of Del Rey Oaks and Pacific Grove have slightly lower rates of cost burden overall with 67 percent and 61 percent of households experiencing no cost burden, respectively.

Overall, the City of Del Rey Oaks has the lowest percent of households experiencing any type of cost burden. It is important to relate Carmel-by-the-Sea’s approximate 46 percent cost burden with its 10 percent population of overcrowded renter households, as these may be indicators of an unaffordable and homogenous local housing market.

Figure A-25 Cost Burden Severity by Jurisdiction, 2015-2019 Source: U.S. Census Bureau, CHAS Data, 2015-2019

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Appendix A – Housing Needs and Fair Housing Report A-37 Carmel-by-the-Sea 6th Cycle Housing Element Amendment July 7, 2026 Figure A-26 illustrates cost burden by tenure in Carmel-by-the-Sea. Renter and owner households experience similar levels of cost burden. Renter households experience 24 percent cost burden and 23 percent severe cost burden (47 percent total), whereas owner households experience 23 percent cost burden and 22 percent severe cost burden (45 percent total). This reflects a 1 percent difference between cost burden and severe cost burden for renter and owner households, respectively.

Figure A-26 Cost Burden by Tenure, Carmel-by-the-Sea, 2015-2019 Source: U.S. Census Bureau, CHAS Data, 2015-2019
Figure A-27 illustrates cost burden of home owners in Carmel-by-the-Sea. According to the HCD AFFH Data Viewer, the highest rates of cost burden among homeowners in Carmel-by-the-Sea are concentrated in the central and southern regions of the City. In these regions, 80 percent of owner households experience cost burden. In the northern region of the City, 40-60 percent of owner households experience cost burden.

Figure A-28 illustrates cost burden of renters in Carmel-by-the-Sea. When analyzing concentrations of cost burden among renter-occupied households in Carmel-by-the-Sea, there is no variation based on location. Between 40-60 percent of renter-households experience cost burden across the City.

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Appendix A – Housing Needs and Fair Housing Report A-38 Carmel-by-the-Sea 6th Cycle Housing Element Amendment July 7, 2026 Figure A-27 Cost Burden by Home Owners, Carmel-by-the-Sea, 2015-2019 Source: California Department of Housing and Community Development, AFFH Data Viewer

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Appendix A – Housing Needs and Fair Housing Report A-39 Carmel-by-the-Sea 6th Cycle Housing Element Amendment July 7, 2026 Figure A-28 Cost Burden by Renter Households, Carmel-by-the-Sea, 2015-2019 Source: California Department of Housing and Community Development, AFFH Data Viewer

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Appendix A – Housing Needs and Fair Housing Report A-40 Carmel-by-the-Sea 6th Cycle Housing Element Amendment July 7, 2026 A.4 Special Needs Groups
Special needs groups are those that may face particular challenges in obtaining adequate housing due to inherent circumstances such as age, disabilities, household size, income level, age, and occupation. Large families, single parent households, female-headed households, or extremely low- and low-income households, and homeless persons may be classified as Special Needs groups. Special Needs groups are identified due to the unique nature of household characteristics and potential housing challenges faced.

Table A-11 provides a summary of special needs groups in Carmel-by-the-Sea.

Table A-11 Overview of Special Needs Groups
Special Needs Groups Count
Percent of Total
Households
Percent of Total
Population
Total population 3,830 -- 100%
Total occupied units (households) 1,925 100% --
Extremely Low-income (0-30% of HAMFI) households 140 households 7% -- Total Senior Population 1,657 persons -- 43%
Senior Owner-Households 763 households 40% --
Senior Renter-Households 283 households 15% --
Persons with Disabilities1 406 persons -- 12%
Persons with Developmental Disabilities2 <70 persons -- -- Large Households 70 households 4% --
Single-Parent Households 153 households 8% --
Single-Parent, Female Headed Households with
Children (under 18) below poverty line
0 households -- --
People Living in Poverty 111 persons -- 3%
Farmworkers3 26,929 persons -- --
Migrant Farmworkers 4,972 persons -- --
Seasonal Farmworkers 12,123 persons -- --
Permanent Farmworkers 14,806 persons -- --
Persons Experiencing Homelessness4 1 person -- --
Source: U.S. Census Bureau, ACS 5-Year Estimate, 2019; U.S. Census Bureau CHAS 2015-2019 Data; USDA Statistics Services; California Department of Developmental Services, Consumer Count by California ZIP Code and Residence Type (2021).

Notes:

1. This estimate uses U.S. Census Bureau ACS 5-Year Estimates for 2021.

2. Data provided by California Department of Developmental Services and taken at the ZIP code level.

3. Agriculture, forestry, fishing and hunting and mining industry. Farmworker data is taken of the population 16 years and older. Data provided by USDA Statistics Services and taken at the County level for 2017; includes permanent and seasonal farmworkers.

4. Total results from 2022 Monterey County Homeless County and Survey Comprehensive Report.

Extremely Low-Income Households and Poverty Status
Extremely low-income (ELI) households are those that earn less than 30 percent of the median family income (MFI).

Very low-income households are those that earn 50 percent of less of the MFI. Extremely low-income households typically face a combination of housing challenges related to income status, family size/type, disability status, access to housing opportunities, and other household characteristics.

Additionally, ELI households are more likely to experience overcrowding, cost burden, and

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Appendix A – Housing Needs and Fair Housing Report A-41 Carmel-by-the-Sea 6th Cycle Housing Element Amendment July 7, 2026 substandard housing conditions. Extremely low-income households are typically minimum-wage workers, disabled persons, farmworkers, and seniors on fixed incomes.

Table A-12 provides a breakdown of extremely low-income households in Carmel-by-the-Sea. The 2015-2019 Comprehensive Housing Affordability Strategy (CHAS) data indicates there were approximately 140 ELI households (7 percent of total households) in Carmel-by-the-Sea. Of the extremely low-income households in Carmel-by-the-Sea, 29 percent are renter-occupied households and 71 percent are owner-occupied households, or 2 percent and 5 percent of all households, respectively.

When analyzing cost burden of ELI households, approximately 120 ELI households experience severe cost burden (paying more than 50 percent of median gross income on housing) and 140 experience moderate cost burden (paying more than 30 percent of median gross income on housing). Of the ELI households experiencing some form of cost burden, the majority are owner-occupied households.

Data for overcrowding by income level is not available for Carmel-by-the-Sea. However, because owner-occupied households represent the majority of ELI households and experience higher rates of cost burden, overcrowding, substandard housing issues it may be assumed that ELI households experience overcrowding.

The projected RHNA for ELI households was based on the assumption that 50 percent of very lowincome households qualify as extremely low-income households. The very low-income housing need is 113 housing units, of which the City estimates 57 housing units will accommodate the extremely lowincome housing need.

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Appendix A – Housing Needs and Fair Housing Report A-42 Carmel-by-the-Sea 6th Cycle Housing Element Amendment July 7, 2026 Table A-12 Extremely Low-Income Households, Carmel-by-the-Sea, 2015-2019 Households Number
Percentage of Total
Households
Total occupied units (households) 1,925 100%
Total Lower-income (0-80% of HAMFI) households 545 28%
Extremely Low-income (0-30% of HAMFI) households 140 7% Extremely Low-income renters 40 2%
Extremely Low-income owners 100 5%
Lower-income households paying more than 50% 270 14%
Extremely Low-income paying more than 50% 120 6%
ELI Renter HH severely cost burdened 20 1%
ELI Owner HH severely cost burdened 100 5%
Lower-income households paying more than 30% 430 22%
Extremely Low-income paying more than 30% 140 7%
ELI Renter HH moderately cost burdened 40 2%
ELI Owner HH moderately cost burdened 100 5%
Lower-income households experiencing 1 of 4 Housing Problems 450 23% Extremely Low-income households experiencing 1 of 4 Housing Problems 140 7% ELI Renter HH experiencing 1 of 4 Housing Problems 40 2% ELI Owner HH experiencing 1 of 4 Housing Problems 100 5% Source: U.S. Department of Housing and Urban Development (HUD), Comprehensive Housing Affordability Strategy (CHAS) 2015-2019.

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

The four housing problems are: incomplete kitchen facilities, incomplete plumbing facilities, more than 1 person per room, and cost burden greater than 30%.

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

In 2019, approximately 111 persons were identified as living below the poverty line.23 Figure A-29 illustrates the percent of the population in Carmel-by-the-Sea living below the poverty line in 2019 by race and ethnicity. Despite being the smallest population in the City (comprising .1 percent of the population), the Black or African American population is estimated to have the highest rate of poverty (50 percent); however, the low sample size makes it difficult to draw conclusions about this population.

In contrast, the non-Hispanic White population represents 87 percent of the total population and only 2 percent is living below the poverty line. The Hispanic or Latinx population experiences the second highest rate of poverty with 13 percent living below the poverty line. 23 From U.S. Census Bureau ACS 5-Year Estimate, 2019, Table S1701

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Appendix A – Housing Needs and Fair Housing Report A-43 Carmel-by-the-Sea 6th Cycle Housing Element Amendment July 7, 2026 Figure A-29 Percent Living Below the Poverty Line by Race and Ethnicity, Carmel-by-theSea, 2019 Source: U.S. Census Bureau, ACS 5-Year Estimate, 2019
Note: Race/Ethnicity represents percentage of the total population* In Carmel-by-the-Sea, housing costs may pose a challenge to residents that are from Extremely LowIncome households. With a median home value of $2,070,835 (compared to a median home value of $561,490 in Monterey County), ELI residents may find it difficult to achieve homeownership.

Additionally, ELI residents typically experience limited accessibility to suitable transportation services to commute from home to work.

To address the needs of ELI households, the City will adopt housing programs to facilitate the construction of affordable and supportive housing for ELI households. Policies that will directly impact ELI households in Carmel-by-the-Sea include:
 Policy 3.1: Incentivize affordable housing development, with an emphasis on affordable housing built to accommodate Extremely Low-Income residents. Encourage the private sector to produce affordable housing;
 Policy 4.1: Support energy and water conservation programs to reduce the consumption of these resources in housing and to reduce housing costs; and  Policy 5.1: Support and enforce fair housing laws. Expand fair housing choice by promoting housing opportunities and removing impediments to fair housing.

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Appendix A – Housing Needs and Fair Housing Report A-44 Carmel-by-the-Sea 6th Cycle Housing Element Amendment July 7, 2026 The City is committed to implementing a suite of programs which emphasize the provision of multifamily housing and non-traditional housing types to provide a variety of housing types to meet the needs of ELI households, including Program 1.1.H, 3.1.B, 3.3.A, 3.3.B, and 3.3.D (see Chapter 2).

Additionally, the City has identified the following service providers and programs to assist residents that are from an Extremely Low-Income household:
 Fair Housing Education;
 Housing Choice Voucher Program;
 211 Monterey/United Way;
 Community Housing Improvement Systems and Planning Association, Inc. (CHISPA) Housing;
 Monterey-Salinas Transit; and
 Independent Transportation Network of Monterey (ITN Monterey).

Seniors
Seniors are identified as individuals 65 years and older. Senior households often experience a combination of factors that can make accessing or keeping affordable housing a challenge. They often live on fixed incomes and are more likely to have disabilities, chronic health conditions, and/or reduced mobility. Seniors who rent may be at even greater risk for housing challenges than those who own, due to income differences between these groups.

Figure A-30 illustrates the senior population in Carmel-by-the-Sea, the County, and nearby cities.

Compared to the County and nearby cities, Carmel-by-the-Sea has the highest senior population (43 percent), approximately 30 percent more than the County and 16 percent more than Pacific Grove.

Figure A-30 Senior Population by Jurisdiction, 2019
Source: U.S. Census Bureau, 2019
Note: Senior population is defined as persons 65 years and older.

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Appendix A – Housing Needs and Fair Housing Report A-45 Carmel-by-the-Sea 6th Cycle Housing Element Amendment July 7, 2026 Figure A-31 illustrates senior housing by tenure in Carmel-by-the-Sea during 2019. Senior households in Carmel-by-the-Sea are primarily owners (73 percent). Similarly, the senior households of the County (73 percent) and nearby cities of Del Rey Oaks (91 percent) and Pacific Grove (68 percent) are majority owners.

Figure A-31 Senior Housing by Tenure, Carmel-by-the-Sea, 2019 Source: U.S. Census Bureau, 2019
Note: Senior population is identified as persons 65 years and older.

Figure A-32 illustrates senior households by their income. 14 percent of Carmel-by-the-Sea’s senior households earn a yearly income of $200,000 or more). However, an estimated 61 percent of senior households earn less than the City’s median household income ($98,188).

Figure A-32 Senior Households by Income, Carmel-by-the-Sea, 2019 Source: U.S. Census Bureau, 2019
Note: Senior population is identified as persons 65 years and older.

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Appendix A – Housing Needs and Fair Housing Report A-46 Carmel-by-the-Sea 6th Cycle Housing Element Amendment July 7, 2026 In Carmel-by-the-Sea, housing costs does not necessarily pose a challenge to the City’s senior residents, as over 70 percent of the City’s senior population owns a home (see Figure A-31). However, elderly residents may be more likely experience limited accessibility to suitable transportation services, and limited mobility.

The Carmel Foundation offers a variety of recreational opportunities for the seniors of Carmel-by-theSea, including affordable lunches; activities and classes; free medical equipment loans; day excursions outside of the Monterey-Carmel area to museums, plays and shopping; free blood pressure checks; and caregiver support groups. The Foundation also provides 50 affordable apartments for low-income seniors and partners with senior-serving agencies to provide additional services including the following:
 Legal Services for Seniors, providing free legal consultations;  Alliance on Aging, providing assistance with Medicare or supplemental insurance;  Visiting Nurse Association & Hospice (VNA), providing a grief support group; and  Independent Transportation Network (ITN) Monterey County, offers rides to seniors in Monterey County.

In addition to The Carmel Foundation, the City has identified the following service providers and programs to assist seniors:
 The Salvation Army Good Samaritan Center;
 Meals on Wheels of the Monterey Peninsula;
 Seniors Helping Seniors;
 Seaside Recreation Services – Senior Center Programs;  Habitat for Humanity Monterey;
 Monterey County Aging and Disability Resource Connection (ADRC); and  Monterey-Salinas Transit Courtesy Card Rides.

People with Disabilities
People with disabilities face additional housing challenges. Encompassing a broad group of individuals living with a variety of physical, cognitive and sensory impairments, many people with disabilities live on fixed incomes and are in need of specialized care, yet often rely on family members for assistance due to the high cost of care. When it comes to housing, people with disabilities are not only in need of affordable housing but accessibly designed housing, which offers greater mobility and opportunity for independence. Unfortunately, the need typically outweighs what is available, particularly in a housing market with such high demand. People with disabilities are at a high risk for housing insecurity, homelessness, and institutionalization, particularly when they lose aging caregivers.

Figure A-33 illustrates population by disability status in Carmel-by-the-Sea, the County, and nearby cities in 2021. Twelve percent of the population in Carmel-by-the-Sea has some form of disability, which is on par with nearby cities. The cities of Del Rey Oaks and Pacific Grove each have a

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Appendix A – Housing Needs and Fair Housing Report A-47 Carmel-by-the-Sea 6th Cycle Housing Element Amendment July 7, 2026 population of 13 percent and 12 percent, respectively, with a disability. The County has the lowest percentage of persons with a disability at 9 percent.

Figure A-33 Population by Disability Status by Jurisdiction, 2021 Source: U.S. Census Bureau, 2021
Over the last decade, the population of persons with disabilities has increased in Carmel-by-the-Sea.

Figure A-34 illustrates trends in persons with disabilities in Carmel-by-the-Sea between 2012-2021. In 2014, the population of persons with disabilities began to steadily increase from 12 percent to its highest point at 22 percent in 2018. In 2019, the upward trend in persons with disabilities began to decline reaching 16 percent, and eventually hitting 12 percent in 2021. Overall, the population of persons with disabilities has increased 3 percent since 2012.

Figure A-34 Trends in Persons with Disabilities, Carmel-by-the-Sea, 2012-2021 Source: U.S. Census Bureau, 2012-2021

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Appendix A – Housing Needs and Fair Housing Report A-48 Carmel-by-the-Sea 6th Cycle Housing Element Amendment July 7, 2026 Table A-13 provides an overview of disability by type and age in Carmel-by-the-Sea during 2021.

Hearing difficulty is the most widespread disability in Carmel-by-the-Sea (41 percent) with the highest concentration in persons 65 years of age and older. Self-care difficulty is the least common disability with 7 percent experiencing this in Carmel-by-the-Sea. Overall, seniors (persons aged 65+) makeup the largest demographic with a disability (50 percent).

Table A-13 Disability Status by Age, Carmel-by-the-Sea, 2021 Disability Type Under 18 18-64 65 and Over Total
Percent of Population
with a Disability
Hearing Difficulty 20 0 305 325 41%
Vision Difficulty 20 0 50 70 9%
Cognitive Difficulty 0 29 46 75 9%
Ambulatory Difficulty 0 0 142 142 18%
Self-care Difficulty 0 0 56 56 7%
Independent Living Difficulty 0 0 130 130 16%
Total 40 29 729 798 100%
Source: U.S. Census Bureau, ACS 5-Year Estimate, 2021
Note: These disabilities are counted separately and are not mutually exclusive, as an individual may report more than one disability. These counts should not be summed.

State law also requires Housing Elements to examine the housing needs of people with developmental disabilities. Developmental disabilities are defined as severe, chronic, and attributed to a mental or physical impairment that begins before a person turns 18 years old. This can include Down’s Syndrome, autism, epilepsy, cerebral palsy, and mild to severe mental retardation. Some people with developmental disabilities are unable to work, rely on Supplemental Security Income, and live with family members. In addition to their specific housing needs, they are at increased risk of housing insecurity after an aging parent or family member is no longer able to care for them.

Table A-14 shows the population with developmental disabilities by age in Carmel-by-the-Sea. In Carmel-by-the-Sea, of the 798 persons with a disability, approximately less than 70 have a developmental disability. Of these, less than 31 are children/young adults (i.e., under the age of 18) and less than 36 are adults.

Table A-15 shows the population with developmental disabilities by residence in Carmel-by-the-Sea.

The most common living arrangement for individuals with developmental disabilities in Carmel-by-theSea is the home of parent/family/guardian.

Table A-14 Population with Developmental Disabilities by Age, Carmel-by-the-Sea, 2021 Age Group Number
Age Under 18 <31
Age 18+ <36
Source: California Department of Developmental Services, Consumer Count by California ZIP Code and Age Group (2021).

Note: Universe: Population with developmental disabilities. Notes: The California Department of Developmental Services is responsible for overseeing the coordination and delivery of services to more than 330,000 Californians with developmental disabilities including cerebral palsy, intellectual disability, Down syndrome, autism, epilepsy, and related conditions. The California Department of Developmental Services provides ZIP code level counts. To get jurisdiction-level estimates, ZIP code counts were crosswalked to jurisdictions using census block population counts from Census 2010 SF1 to determine the share of a ZIP code to assign to a given jurisdiction.

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Appendix A – Housing Needs and Fair Housing Report A-49 Carmel-by-the-Sea 6th Cycle Housing Element Amendment July 7, 2026 Table A-15 Population with Developmental Disabilities by Residence, Carmel-by-the-Sea, 2021 Residence Type Number
Home of Parent/Family/Guardian <38
Foster/Family Home 0
Independent/Supported Living <11
Other 0
Community Care Facility <11
Intermediate Care Facility 0
Source: California Department of Developmental Services, Consumer Count by California ZIP Code and Residence Type (2021).

Note: Universe: Population with developmental disabilities. Notes: The California Department of Developmental Services is responsible for overseeing the coordination and delivery of services to more than 330,000 Californians with developmental disabilities including cerebral palsy, intellectual disability, Down syndrome, autism, epilepsy, and related conditions. The California Department of Developmental Services provides ZIP code level counts. To get jurisdiction-level estimates, ZIP code counts were crosswalked to jurisdictions using census block population counts from Census 2010 SF1 to determine the share of a ZIP code to assign to a given jurisdiction.

In Carmel-by-the-Sea, the majority of the residents that have disabilities are also age 65 and over. The service organizations listed in the “Seniors” section above includes several resources that accommodate seniors with disabilities, including the Carmel Foundation, which provides meal delivery, assists seniors in finding in-home care resources, and more.

The City’s Municipal Code establishes procedures for persons with disabilities seeking equal access to housing including reasonable accommodation for person with disabilities. Additionally, the City follows the requirements of California Building Code Title 24 which establishes provisions for accessible building design. Currently, the City is implementing their Capital Improvement Plan (CIP), which includes sidewalk improvements, grading streets to correct slope, and installation of ADA ramps. The City’s Police Department and Carmel Youth Center are also undergoing building improvements, which include ADA accessibility features for public use.

In addition to the City’s efforts to provide an accessible community environment, the following service providers and programs are available in Monterey County to assist residents that are living with disabilities:
 Monterey County Aging and Adult Services;
 Monterey County Aging and Disability Resource Connection (ADRC);  Paradigm Adult Services;
 Special Kids Connect;
 Monterey-Salinas Transit Courtesy Card Rides;
 Independent Transportation Network of Monterey (ITN Monterey); and  MST Rides ADA Paratransit Agency.

Large Households
Large households are defined as households of five or more individuals. Large households often have different housing needs than smaller households. Household income and local housing markets can greatly impact a household’s ability to afford adequately sized housing. If a city’s rental housing stock

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Appendix A – Housing Needs and Fair Housing Report A-50 Carmel-by-the-Sea 6th Cycle Housing Element Amendment July 7, 2026 does not include larger apartments, large households who rent could end up living in overcrowded conditions. Similarly, large households may experience overpayment as a result of a high housing market and limited availability.

Figure A-35 illustrates 2019 households by size and tenure in Carmel-by-the-Sea. The City has 70 large households, of which 57 percent are renter-occupied households. Owner-occupied households makeup the majority of 1-person and 2-person households, whereas renter-occupied households makeup the majority of all 3-5 person households. This combined with a total cost burden rate of 46 percent for renter households (Figure A-25), suggests it is likely that large households in Carmel-by-the-Sea may experience overcrowding and/or overpayment.

Figure A-35 Households by Size and Tenure, Carmel-by-the-Sea, 2019 Source: U.S. Census Bureau, ACS 5-Year Estimate, 2019
In Carmel-by-the-Sea, housing costs may pose a challenge to large households, as they are more likely to rent as opposed to purchasing a home, and experience higher cost-burden and overcrowding. With a median home value of $2,070,835 (compared to a median home value of $561,490 in Monterey County), large households may find it difficult to achieve homeownership. Furthermore, finding suitable transportation may be a challenge as well.

Generally, large households in Carmel-by-the-Sea can benefit from general programs and services for lower and moderate-income persons, including the Housing Authority of the County of Monterey Housing Choice Voucher program, and various community and social services provided by non-profit organizations in the region. Program 3.2.C has been included in this Housing Element to encourage the development of family friendly affordable housing units (see Chapter 2).

The City also has the ability to leverage city-owned sites to incentivize the development of larger, family friendly units that accommodate a minimum of three bedrooms per unit. The City will work with nonprofit affordable housing developers to encourage housing development that meets the needs of large

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Appendix A – Housing Needs and Fair Housing Report A-51 Carmel-by-the-Sea 6th Cycle Housing Element Amendment July 7, 2026 households. Further, the City’s parking standards are based on a per unit requirement and will not pose a constraint to the development of larger units, which in some jurisdictions is determined by unit size.

In addition to the City’s efforts to enable the development of family friendly residential units, the following service providers and programs are available in Monterey County to assist large households:
 Housing Choice Voucher Program;
 Fair Housing Education;
 Monterey County Down-payment Assistance Program;
 Monterey-Salinas Transit; and
 Monterey Dial-A-Ride Program.

Single-Parent Households
Households headed by one person are often at greater risk of housing insecurity, particularly femaleheaded households, who may be supporting children or a family with only one income.

In Carmel-by-the-Sea, the largest proportion of households are married-couple family households at 47 percent, while female-headed households make up 6 percent, and male-headed households make up 2 percent of all households (Figure A-12). Figure A-36 shows single-parent households in Carmel-by-theSea, the County, and nearby cities. Compared to the County and nearby cities, Carmel-by-the-Sea’s ratio of single-parent households is on par. Carmel-by-the-Sea’s single-parent households are predominantly female-headed family households (75 percent). Male-headed family households makeup 25 percent.

Figure A-36 Single-Parent Households by Jurisdiction, 2019 Source: U.S. Census Bureau, ACS 5-Year Estimate, 2019
Over the last decade, male-headed family households have slightly increased in Carmel-by-the-Sea, while female-headed family households have decreased. Figure A-37 illustrates trends in single-parent households in Carmel-by-the-Sea between 2010-2019.24
24 The data reports female- and male-headed family household as a percentage of total households in Carmel-by-the-Sea.

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Appendix A – Housing Needs and Fair Housing Report A-52 Carmel-by-the-Sea 6th Cycle Housing Element Amendment July 7, 2026 Figure A-37 Trends in Single-Parent Households, Carmel-by-the-Sea, 2010-2019 During this period, male-headed households increased from zero percent in 2010 up to 2 percent by 2015. From 2016-2018, the male-headed family households remained at 1 percent until increasing to 2 percent by 2019. Comparatively, female-headed family households decreased a total of 3 percent between 2010-2019. From 2010-2013, female-headed family households steadily increased reaching its highest point at 13 percent in 2013. By 2014, the group experienced a 2 percent decrease and remained constant until 2018 when it began to decline, reaching 6 percent in 2019.

Female-headed households with children may face particular housing challenges, with pervasive gender inequality resulting in lower wages for women. Moreover, the added need for childcare can make finding a home that is affordable more challenging. In 2019, there were no single-parent households that fell in the Below Poverty Level category in Carmel-by-the-Sea.

Limited household income constrains the ability of single-parent households to afford adequate housing, childcare, health care, and other necessities. The Carmel Unified School District (CUSD) operates several programs that provide child care and early education services that may assist low income single-parent households, including the following:
 Universal Pre-Kindergarten at Carmelo School – Offers free enrollment early learning programs serving children aged four years old at several CUSD elementary sites and preschool sites.
 River Rec – Offers school age child care to assist working families in securing affordable quality child care, located at River Elementary School in Carmel. The program offers morning programs from 7:00 am to 8:40 am; afternoon programs from 2:00 pm to 6:00 pm; and full days from 7:00 am to 6:00 pm.
 Tular Rex – Offers school age child care to assist working families in securing affordable quality child care, located at Tularcitos Elementary School in Carmel Valley. The program offers morning programs from 7:00 am to 8:40 am; afternoon programs from 2:00 pm to 6:00 pm; and full days from 7:00 am to 6:00 pm.

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Appendix A – Housing Needs and Fair Housing Report A-53 Carmel-by-the-Sea 6th Cycle Housing Element Amendment July 7, 2026 The Carmel Youth Center, located at Torres Street and Fourth Avenue in Carmel-by-the-Sea, is a nonprofit youth center that has historically provided youth services in the community, including after school care and summer programs. The Carmel Youth Center accepts scholarship funding for lowincome households in need of affordable child care services. The Center is currently under review by the State to receive licensure and is expected to reopen by Summer 2024.

Due to the small geographical size of the city, childcare reflects the population size. Similar to many cities, demand is high for child care services in Carmel-by-the-Sea. Therefore, many lower-income residents rely on county resources, especially for subsidized child care. Monterey County Child Care provides resources for low-income households searching for subsidized child care and early learning programs. However, many resources are located outside of Carmel-by-the-Sea in the Salinas region, which may place transportation and access pressures on households in need of these services.

In an effort to relieve some of the housing and transportation issues that single-parent households may face, the City has identified the following service providers and programs to assist single-parent households:
 Housing Choice Voucher Program;
 Fair Housing Education;
 Monterey County Down-payment Assistance Program; and
 Monterey-Salinas Transit.

Farmworkers
Across the state, housing for farmworkers has been recognized as an important and unique concern.

Farmworkers generally receive wages that are considerably lower than other jobs and may have temporary housing needs. Finding decent and affordable housing can be challenging, particularly in the current housing market.

According to the U.S. Department of Agriculture Census of Farmworkers, the number of permanent farm workers in Monterey County has decreased since 2002, totaling 14,806 in 2017, and the number of seasonal farm workers has also decreased, totaling 12,123 in 2017. Figure A-38 shows hired farm labor in Monterey County between 2002-2017.

Agriculture consisting of crop farming and livestock grazing is the largest industry in Monterey County and contributes a significant amount of money to the County’s economy. Out of approximately 1.3 million acres of County land dedicated to agriculture, most of this area (approximately 80 percent) is used for grazing. The most productive and lucrative farmlands in the County are located in the North County, Greater Salinas, and Central Salinas Valley Planning Areas.

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Appendix A – Housing Needs and Fair Housing Report A-54 Carmel-by-the-Sea 6th Cycle Housing Element Amendment July 7, 2026 Figure A-38 Hired Farm Labor, Monterey County, 2002-2017 Source: U.S. Department of Agriculture, Census of Farmworkers (2002, 2007, 2012, 2017), Table 7: Hired Farm Labor.

Notes: Universe: Hired farm workers (including direct hires and agricultural service workers who are often hired through labor contractors). Farm workers are considered seasonal if they work on a farm less than 150 days in a year, while farm workers who work on a farm more than 150 days are considered to be permanent workers for that farm.

According to the 2021 American Census Survey (ACS) data, zero percent of individuals residing in Carmel-by-the-Sea households reported that they were employed in the Agriculture, Forestry, or Fishing and Hunting industry.25 According to the Department of Conservation’s Important Farmland Categories, the City of Carmel-by-the-Sea is entirely designated as “Urban and Built-up Land” and does not contain any important or prime farmlands.26 There are no agricultural lands or agriculturally zoned properties within the City limits. There are no farm labor housing developments in the City nor are there projects assisted with Rural Housing Administration financing; however, the City shares the responsibility for farmworker housing as farmworkers may work within 75 miles of agricultural land uses (including dairy, vineyards, and produce) and the City is within 75 miles of these uses. While HCD has no established metrics, the United States Department of Agriculture, (USDA) considers farmworkers that work at a specific location within 75 miles of their home to be “settled” and thus permanent members of their home community.

The California Institute for Rural Studies released a Farmworker Housing Study and Action Plan for Salinas Valley and Pajaro Valley in April 2018. Key findings of the Study included:
 A survey of 420 farmworkers in the laborshed as well as interviews with employers and other stakeholders was conducted to gather primary data. Among the farmworkers surveyed, men and women were relatively evenly distributed across age groups with 75 percent of the 25 Source: U.S. Census Bureau ACT 5-year Estimate, 2021, Table C24070 26 Source: California Department of Conservation Important Farmland Categories https://www.conservation.ca.gov/dlrp/fmmp/Pages/Important-Farmland-Categories.aspx

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Appendix A – Housing Needs and Fair Housing Report A-55 Carmel-by-the-Sea 6th Cycle Housing Element Amendment July 7, 2026 interviewees married. The clear majority of the immigrant farmworker interviewees had very few years of schooling. They were 92 percent immigrants (not born in the U.S.). About one fifth were follow-the-crop migrants (FTC) who had traveled outside the two-County (Monterey and Santa Cruz counties) area for agricultural employment;  Most households of farmworkers interviewed included non-family members who were for the most part other farmworkers. There are consistently stunningly high rates of residences that are above the severely crowded condition of 2.0 people per room. This is true of almost all the subgroups of the population. Often more than 5 people per bathroom;  About 40 percent of respondents live in houses, 30 percent in apartments. Another 19 percent live in rented rooms without kitchens – either in houses or apartments. Another 12 percent live in “other” types of dwellings. Eighty-nine percent of farmworkers were renters and 11 percent owners. Of those who reported as owners, a quarter owns mobile homes; and Other characteristics of those interviewed included:
 Most have only completed primary school;
 Wages ranged from a median of $12.79 per hour, mean of $13.64, with median annual income of $25,000;
 The majority do not work all year in agriculture – 7.5 months is the median;  44 percent of migrants work all year, 20 percent of non-migrants work year-round;  Average age at arrival is about 20;
 Median number of years in the U.S. is 15 years;
 Median age was 37;
 Median number of years with current employer is 4 years; a quarter worked for their employer for 8 years or more;
 Two-thirds are from four states in Mexico:
 Oaxaca 21 percent;
 Michoacan 19 percent;
 Jalisco 14 percent;
 Guanajuato 10 percent;
 13 percent self-identified as indigenous Mixtec, Triqui, Zapotec;  They work in a range of crops throughout the region;
 46 percent participate in harvest;
 16 percent are packers;

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Appendix A – Housing Needs and Fair Housing Report A-56 Carmel-by-the-Sea 6th Cycle Housing Element Amendment July 7, 2026  38 percent participate in all other farm-related tasks such as:
• Weeding;
• Irrigating;
• Thinning;
• Pruning;
• Loading;
• Driving; and
• Operating machines.

The farmworker housing demand model developed as part of the study calculates the total housing units needed of all types, based on target People Per Dwelling (PPD), and total permanent affordable farmworker housing based on the current rate that farmworkers access subsidized housing.

Key findings of the demand model were:
 An additional 33,159 units of farmworker housing are needed to alleviate critical overcrowding in farmworker households that are occupied at 7.00 PPD to the average PPD of 3.23 in Monterey County and the average PPD 2.60 in Santa Cruz County;  A total of 4,393 units of permanent affordable farmworker housing are needed to maintain the present “access rate” of 7.6 percent of farmworkers to subsidized housing; and  The data from this study indicate an overwhelming need for affordable permanent yearround family housing.

The housing needs of farmworkers are addressed under Carmel-by-the-Sea’s overall programs for affordability consistent with the California Institute for Rural Studies 2018 report. Although the City does not have agricultural uses, and therefore, no housing designated specifically for farmworkers – the City supports the County of Monterey’s efforts to educate the public on resources that are available for agricultural workers. The City has included Program 5.1.D to identify and publicize resources that are available throughout the region for agricultural employees. Additionally, Program 1.3.B establishes an amendment to the zoning code to define and permit employee housing, including agricultural employees, consistent with state law.

The City has identified the following regional service providers and programs to assist farm-worker households within the greater Monterey County region:
 Spanish Farmworkers Resource Line;
 The Center for Community Advocacy; and
 Farm and Food Worker Relief Program.

Persons Experiencing Homelessness
Homelessness remains an urgent challenge in many communities across the state, reflecting a range of social, economic, and psychological factors. Rising housing costs result in increased risks of community members experiencing homelessness. Addressing the specific housing needs for the unhoused

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Appendix A – Housing Needs and Fair Housing Report A-57 Carmel-by-the-Sea 6th Cycle Housing Element Amendment July 7, 2026 population remains a priority throughout the region, particularly since homelessness is disproportionately experienced by people of color, people with disabilities, those struggling with addiction and those dealing with traumatic life circumstances.

Table A-16 show changes in the homeless population between 2017-2022 in Carmel-by-the-Sea, the County and neighboring jurisdictions. According to the 2022 Monterey Homeless Count and Survey Comprehensive Report, Carmel-by-the-Sea has seen a decrease in homeless persons since 2017, totaling one person in 2022. Similarly, the Monterey Bay Area overall has seen a decrease in homeless populations with the exception of Seaside.

Table A-16 Homeless Population by Jurisdiction, 2017-2022 Jurisdiction
Unsheltered Sheltered Total 2019-2022 %
2017 2019 2022 2017 2019 2022 2017 2019 2022 Change
Monterey (City) 292 167 74 46 37 27 338 204 101 -50%
Carmel-by-the-Sea 16 6 1 0 0 0 16 6 1 *
Del Rey Oaks 111 0 2 0 0 0 111 0 2 *
Seaside 40 126 90 58 56 62 98 182 152 -16%
Pacific Grove 35 14 29 0 0 0 35 14 29 *
Total 509 315 198 104 93 89 613 408 287 -66%
Source: 2022 Monterey Homeless Count and Survey Comprehensive Report NOTE: % change was not calculated when jurisdiction was below 25 individuals.

Table A-17 shows household type and shelter status in Monterey County in 2019. In Monterey County, the most common type of household experiencing homelessness are those without children in their care. Among households experiencing homelessness that do not have children, 83 percent are unsheltered. Similarly, the majority of homeless households with children are unsheltered (45 percent).

Table A-17 Homelessness by Household Type and Shelter Status, Monterey County, 2019 Jurisdiction
People in Households
Composed Solely of
Children Under 18
People in Households
with Adults and Children
People in Households
without Children
Under 18
Count Percent Count Percent Count Percent Total
Sheltered –Emergency Shelter 0 0% 146 22% 218 11% 364
Sheltered – Transitional Housing 0 0% 218 33% 124 6% 342 Unsheltered 10 100% 303 45% 1,685 83% 2,340
Total 10 100% 667 100% 2,027 100% 2,704
Source: U.S. Department of Housing and Urban Development (HUD), Continuum of Care (CoC) Homeless Populations and Subpopulations Reports (2019). For the data table behind this figure, please refer to the Data Packet Workbook, Table HOMELS-01.

Notes: Universe: Population experiencing homelessness. This data is based on Point-in-Time (PIT) information provided to HUD by CoCs in the application for CoC Homeless Assistance Programs. The PIT provides a count of sheltered and unsheltered homeless persons on a single night during the last 10 days in January. Each Bay Area County is its own CoC, and so data for this table is provided at the county-level. Per HCD’s requirements, jurisdictions will need to supplement this county-level data with local estimates of people experiencing homelessness.

Housing and transportation costs can be barriers to residents that are experiencing homelessness. With a median home value of $2,070,835 (compared to a median home value of $561,490 in Monterey County), those experiencing homelessness would need wrap-around support, access to community services, and State/Federal assistance to end the cycle of homelessness. Many individuals that are

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Appendix A – Housing Needs and Fair Housing Report A-58 Carmel-by-the-Sea 6th Cycle Housing Element Amendment July 7, 2026 homeless may experience difficulties with: finding emergency shelter, having access to food and jobtraining resources. Lack of adequate transportation to commute to job interviews and appointments with social service providers may also be an obstacle to individuals experiencing homelessness.

The following facilities offer supportive housing services in Monterey County and Carmel-by-the-Sea for homeless and special needs low-income persons:
 Habitat for Humanity Monterey;
 Peacock Acres;
 Interfaith Outreach of Monterey;
 Community for Human Services – Casa De Noche Buena: A 20-35-beds year-round shelter for homeless women and families. Capacity depends on the number of children in families.

Provides case management, housing navigation, meals, laundry facilities, mail service, social recreation activities, and linkages to income, education, and employment. A partnership with Gathering for Women Monterey. Located at 1292 Olympia Ave., Seaside;  Community Human Services – Safe Place Youth Shelter: A 12-bed year-round shelter for youth ages 18-21. Case management is available to all clients. Check-in is from 7:00-9:00 pm.

Located at 590 Pearl Street, Monterey; and
 Interim, Inc. – MCHOME: Provides emergency shelter, outreach, housing, and intensive, integrated services to homeless adults with psychiatric disabilities. MCHOME’s goal is to move individuals with psychiatric disabilities off the street and into housing. Located in Monterey.

The majority of resources for the homeless population are provided at the county level due to a lack of need in the City, as well as a lack of resources to provide services at the City level.

A.5 Access to Opportunity
This section discusses disparities in access to opportunity among protected classes including access to quality education, employment, transportation, and environment. The California Tax Credit Allocation Committee (TCAC) in collaboration with HCD developed a series of opportunity maps that help to identify areas of the community with good or poor access to opportunity for residents. These maps were developed to align funding allocations with the goal of improving outcomes for low-income residents – particularly children.

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Appendix A – Housing Needs and Fair Housing Report A-59 Carmel-by-the-Sea 6th Cycle Housing Element Amendment July 7, 2026 Access to Opportunity
“Access to opportunity is a concept to approximate place-based characteristics linked to critical life outcomes. Access to opportunity oftentimes means both improving the quality of life for residents of low-income communities, as well as supporting mobility and access to ‘high resource’ neighborhoods. This encompasses education, employment, economic development, safe and decent housing, low rates of violent crime, transportation, and other opportunities, including recreation, food and healthy environment (air, water, safe neighborhood, safety from environmental hazards, social services, and cultural institutions).” Source: California Department of Housing and Community Development Guidance, 2021, page 34.

The opportunity maps highlight areas of highest resource, high resource, moderate resource, moderate resource (rapidly changing), low resource, and high segregation and poverty. TCAC provides opportunity maps for access to opportunity in quality education, employment, transportation, and environment. Opportunity scores are presented on a scale from zero to one and the higher the number, the more positive the outcomes.

Disparities in Access to Opportunity
As can be seen in Figure A-39, Carmel-by-the-Sea is considered a highest resource area as is much of western Monterey County. According to the HCD AFFH Data Viewer TCAC Opportunity Map, there are no areas of variation in access to opportunity across the City.

Economic
TCAC’s economic opportunity score is comprised of poverty, adult educational attainment, employment, job proximity, and median home value. Figure A-40 shows concentrations of economic outcomes in Carmel-by-the-Sea. According the HCD AFFH Data Viewer TCAC Economic Opportunity Map, all areas of Carmel-by-the-Sea have a high economic opportunity score of 0.75-1.0.

This reflects a high level of opportunity for economic advancement for residents in Carmel-by-the-Sea.

HUD’S Job Proximity index utilizes Longitudinal Employer-Household Dynamic estimates to examine the distance from a given neighborhood to all job locations within the Salinas-Monterey Area and measures the accessibility to job opportunities at the census block group level. Because the size of employment centers and the supply of labor differ across the region, the distance from any single job location is positively weighted by the size of employment (job opportunities) at that location and inversely weighted by the labor supply (competition) to that location.27 The higher the index value, the better the access to employment opportunities for residents in a neighborhood. 27 HUD. AFFH-T Data Documentation Data Version AFFHT0006 (2020).

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Appendix A – Housing Needs and Fair Housing Report A-60 Carmel-by-the-Sea 6th Cycle Housing Element Amendment July 7, 2026 Figure A-39 TCAC Opportunity Composite Score, Carmel-by-the-Sea, 2022 Source: California Department of Housing and Community Development AFFH Data Viewer

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Appendix A – Housing Needs and Fair Housing Report A-61 Carmel-by-the-Sea 6th Cycle Housing Element Amendment July 7, 2026 Figure A-40 TCAC Opportunity Economic Score, Carmel-by-the-Sea, 2022 Source: California Department of Housing and Community Development AFFH Data Viewer

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Appendix A – Housing Needs and Fair Housing Report A-62 Carmel-by-the-Sea 6th Cycle Housing Element Amendment July 7, 2026 As shown in Figure A-41, access to employment opportunities does not differ across Carmel-by-theSea. The entirety of the city has a jobs proximity index score of at least 80, indicating adequate access to employment opportunities for residents across the city.

According to data presented in Section A.2, Population, Employment, and Household Characteristics, the city is a net importer of workers (Figure A-11), which likely comes as a result of the small geographical size of the city and limited housing availability. Further, the city is a tourist destination, providing ample job opportunities to sustain the local economy. However, the combination of low housing stock and high job opportunity can perpetuate a jobs to housing imbalance. To encourage the development of a variety of new housing types affordable to a range of incomes, the City has developed a suite of programs, including Program 1.1.G, which encourages the development of on-site employee housing at overnight visitor accommodation centers in the city. See Chapter 2 for a full list of implementation programs.

It is intended that through the implementation of these housing programs, the City will enable local employees to obtain affordable housing in the city.

Education
TCAC’s education score is based on math proficiency, reading proficiency, high school graduation rates, and the student poverty rate. Opportunity scores are presented on a scale from zero to one and the higher the number, the more positive the outcomes.

Figure A-42 shows the level of TCAC educational opportunity across Carmel-by-the-Sea. According to TCAC’s Educational Opportunity Map, Carmel-by-the-Sea scores between 0.75-1.0 indicating a high level of positive educational outcomes for residents in Carmel-by-the-Sea.

Carmel-by-the-Sea is served by the Carmel Unified School District (CUSD), along with elementary, middle, and high schools within the City and school district. As of 2022, the State of California School Dashboard highlights a 97.9 percent graduation rate among all students enrolled in Carmel High School, which is higher than the statewide average (87.4 percent) and County average (88.5 percent).

When broken down by race/ethnicity, Hispanic and White students graduated at a high rate (97.4 percent for both groups). There is no performance data available for the graduation rates of African American, Asian, Filipino, and American Indian students at Carmel High.

Additionally, there is no performance data available for the graduation rates of students with a disability within Carmel High.

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Appendix A – Housing Needs and Fair Housing Report A-63 Carmel-by-the-Sea 6th Cycle Housing Element Amendment July 7, 2026 Figure A-41 Jobs Proximity Index, Carmel-by-the-Sea
Source: California Department of Housing and Community Development AFFH Data Viewer

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Appendix A – Housing Needs and Fair Housing Report A-64 Carmel-by-the-Sea 6th Cycle Housing Element Amendment July 7, 2026 Figure A-42 TCAC Opportunity Education Score, Carmel-by-the-Sea, 2022 Source: California Department of Housing and Community Development AFFH Data Viewer

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Appendix A – Housing Needs and Fair Housing Report A-65 Carmel-by-the-Sea 6th Cycle Housing Element Amendment July 7, 2026 Environment
TCAC’s opportunity areas environmental scores are based on the CalEnviroScreen 4.0 indicators, which identify areas disproportionately vulnerable to pollution sources such as ozone, PM2.5, diesel PM, pesticides, toxic release, traffic, cleanup sites, groundwater threats, hazardous waste, impaired water bodies, and solid waste sites.

Figure A-43 shows TCAC environmental outcomes across Carmel-by-the-Sea. According to the HCD AFFH Data Viewer TCAC Environmental Opportunity Map, Carmel-by-the-Sea scores between 0.75-

1.0 indicating a low level of environmental pollution burden and positive outcomes for residents in Carmel-by-the-Sea.

The Social Vulnerability Index (SVI) provided by the Center for Disease Control (CDC)ranks census tracts based on their ability to respond to a disaster and includes four themes of socioeconomic status, household composition, race or ethnicity, and housing and transportation.

Figure A-44 shows SVI levels across Carmel-by-the-Sea. Carmel-by-the-Sea scores low on the SVI (less than 0.25) indicating that the City is slightly vulnerable to disasters, but highly equipped to respond to them. Just outside of the City’s borders, however, vulnerability levels increase to 0.25-0.5. This is likely due to a difference in jurisdictional resources.

Disparities Specific to the Population Living with a Disability In Carmel-by-the-Sea, 12.3 percent of the population is living with at least one disability, compared to

8.8 percent in Monterey County. The most common disabilities in the City are: hearing difficulty (9.9 percent), ambulatory difficulty (4.4 percent), and independent living difficulty (4.3 percent). For the population 65 and over, the share of the population with hearing difficulties increases to 19.3 percent.

In an effort to improve accessibility features for residents living with disabilities, the City will allocate funding from its Capital Improvement Program (CIP) to improve curb cuts, sidewalks, and slopes within Carmel-by-the-Sea.

Disparities in Access to Transportation
Reliable public transit access and active transportation options (walking and biking) are imperative for low-income residents and/or persons with disabilities to connect to employment opportunities. Access to employment via public transit and active transportation can reduce income burden and increase housing mobility, which enables residents to locate housing in more areas.28 Lack of transportation options can impede fair housing choice and continue to reinforce barriers for low-income residents in accessing opportunities.
28 Ong, Paul and Evelyn Blumenberg. 1998. https://escholarship.org/uc/item/6d897664#author

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Appendix A – Housing Needs and Fair Housing Report A-66 Carmel-by-the-Sea 6th Cycle Housing Element Amendment July 7, 2026 Figure A-43 TCAC Opportunity Environmental Score, Carmel-by-the-Sea, 2022 Source: California Department of Housing and Community Development AFFH Data Viewer

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Appendix A – Housing Needs and Fair Housing Report A-67 Carmel-by-the-Sea 6th Cycle Housing Element Amendment July 7, 2026 Figure A-44 Social Vulnerability Index, Carmel-by-the-Sea, 2018 Source: California Department of Housing and Community Development AFFH Data Viewer

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Appendix A – Housing Needs and Fair Housing Report A-68 Carmel-by-the-Sea 6th Cycle Housing Element Amendment July 7, 2026 Regional Trends
Monterey County generally has widespread access to public transit. Transportation Agency for Monterey County (TAMC) and Monterey-Salinas Transit (MST) all serve Monterey County. TAMC serves as the county’s regional transportation agency responsible for planning and financial programming of transportation projects in the county. Through local and statewide funding, TAMC provides funding for public transit services operated by MST. MST provides a variety of local bus services through a total of 36 routes where service originates from two primary locations: the Monterey Transit Plaza, in downtown Monterey, and the Salinas Transit Center, in downtown Salinas. From there, routes branch out through the western cities of Marina, Sand City, Monterey, Pacific Grove, Carmel-by-the-Sea, and then the eastern cities, including Salinas, Gonzales, Soledad, Greenfield, and King City. In addition, MST provides a connection to Watsonville Transit Center as the primary connector to Santa Cruz Metro to Santa Cruz and San Jose centers. MST offers a paratransit program (RIDES) in cooperation with the Americans with Disabilities Act for those who have a disability that prevents them from using MST’s regular fixed-route bus service. Each bus is equipped with a wheelchair lift, and a service corridor extends 0.75 mile from any of the MST bus routes throughout the Monterey Peninsula, Carmel-by-the-Sea, Carmel Valley, Salinas, Chualar, Gonzales, Greenfield, Soledad, and King City with connection to Watsonville Transit Center.

College students ride free with valid student photo identification during the Fall and Spring semesters.

Amtrak rail service has a station in Salinas as part of the Coast Starlight line that extends north as far as Seattle, Washington.

Monterey County received an average AllTransit performance score of 4.2 which equates to a low combination of trips per week and number of jobs accessible by transit.29 Nearly 73 percent of workers in the county live within 0.5 mile of transit. Almost all major employment centers in Monterey County are served by some form of public transit. However, having regional access to jobs by means of public transit does not necessarily translate into stable employment. Some residents with unique needs, such as households with children, have unique travel patterns that may prevent them from working far from home due to childcare needs, access to schools, and other considerations.

From a regional standpoint, MST services approximately 2.2 million passengers on an annual basis of which 76 percent of the passengers come from a historically underrepresented (non-White) background with an annual household income under $40,000.30 Monterey-Salinas Transit also reports that 25 percent of all trips begin in a disadvantaged community, and 20 percent of the passengers serviced by MST have a disability and are dependent on others for mobility and transport. Compared to all other jurisdictions serviced by MST, Carmel-by-the-Sea has the sixth highest monthly ridership (MontereySalinas Transit, 2023). 29 AllTransit.org. 2022. County: Monterey, AllTransit Metrics. https://alltransit.cnt.org/metrics/?addr=monterey+county 30 https://carmel.novusagenda.com/agendapublic/CoverSheet.aspx?ItemID=5838&MeetingID=1350

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Appendix A – Housing Needs and Fair Housing Report A-69 Carmel-by-the-Sea 6th Cycle Housing Element Amendment July 7, 2026 Local Trends
In the City of Carmel-by-the-Sea, public transportation is serviced by Monterey-Salinas Transit (MST) which offers two fixed route bus lines in Carmel-by-the-Sea (Routes 5 and 94). Route 5 connects Carmel-by-the-Sea to the City of Monterey, operating from 6:15 am to 9:15 pm on weekdays and from 7:15 am to 7:15 pm on weekends. Route 94 connects Carmel-by-the-Sea to the cities of Monterey, Del Rey Oaks, and Seaside, operating from 9:50 am to 3:50 pm every day.

Carmel-by-the-Sea is generally accessible by local transit. The city has an AllTransit Performance Score of 5.4, which is slightly higher than overall Monterey County. According to AllTransit, 100 percent of workers live within one half mile of transit.31
Walk Score is a tool that produces a walkability index by assigning a numerical walkability score to cities and neighborhood. Walkability is measured by analyzing population density, distance to amenities, and road metrics such as block length and intersection density. Overall, Carmel-by-the-Sea has a walk score of 96, which is an above average walk score and indicates most daily errands do not require a car.

In an effort to lower the disparities in access to transit, the City has collaborated with MST to ensure that 100 percent of the City’s residents live within a half mile of transit stops. The City coordinates with the County of Monterey to provide transportation to elderly residents (through the Senior Rideshare Program), and individuals with disabilities through the Independent Transportation Network of Monterey (ITN Monterey) and the MST Rides ADA Paratransit Agency. Additionally, MST provides a Courtesy Card for riders that are 18 years of age and younger; 65 years of age and older; veterans; caregivers; and disabled individuals. Discounted GoPasses are available to commuters for monthly, weekly, and daily rates. Emergency Guaranteed Ride Home (EGRH) is also a service provided by MST, which provides a guaranteed ride home in an emergency to registered uses who use alternative transportation to get to work. The EGRH program is available to commuters who live or work in Monterey County and who ride the bus, carpool, vanpool, ride a bicycle or walk to work at least one day a week.

Housing Mobility Enhancement
Being that the City of Carmel-by-the-Sea is the highest resource community when compared to the rest of the region, the City will promote housing mobility as a means of removing barriers to higher opportunity areas and strategically enhancing access to housing choices and affordability to provide more inclusivity in the City and region. To enhance housing mobility, the City has included the following programs in Chapter 2 of the Housing Element:
 3.2.B: Housing Mobility;
 3.2.C: Family Friendly Housing;
 1.1.E: Affordable Housing on Religious Facility Properties;  1.1.H: Accessory Dwelling Units;
31 AllTransit.org. 2022. City: Carmel-by-the-Sea, AllTransit Metrics. https://alltransit.cnt.org/metrics/

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Appendix A – Housing Needs and Fair Housing Report A-70 Carmel-by-the-Sea 6th Cycle Housing Element Amendment July 7, 2026  1.1.G: Hotel Employee Housing Program;
 2.1.B: Permanent Housing;
 3.1.B: Housing for Extremely-Low Income Households;
 5.1.A: Fair Housing Services; and
 5.1.B: Housing Choice Voucher Program.

For a complete list of programs. Refer to Chapter 2 of the Housing Element.

A.6 Housing Stock Characteristics
Carmel-by-the-Sea’s housing stock is defined as all housing units within its jurisdiction. Characteristics of housing stock include housing type, age, condition, tenure, vacancy rates, costs, affordability, and growth. The following section provides an in-depth analysis of the housing stock in Carmel-by-the-Sea to determine how/if the current the housing stock meets the needs of existing and future residents.

Housing Growth
Table A-18 provides an overview of housing growth trends between 2010-2019 in Carmel-by-the-Sea, the County, and nearby cities. Between 2010-2019, Carmel-by-the-Sea housing unit estimates grew approximately 6 percent, more than the County and Del Rey Oaks, but 2 percent less than Pacific Grove. These estimates show the majority of housing growth in Carmel-by-the-Sea occurred between 2015-2019 (8 percent).

Table A-18 Housing Unit Growth Trends by Jurisdiction, 2010-2019 Jurisdiction 2010 2015 2019
Percent Change
2010-2015
Percent Change
2015-2019
Monterey County 138,833 139,794 141,820 1% 1%
Carmel-by-the-Sea 3,606 3,532 3,832 -2% 8%
Del Rey Oaks 752 733 745 -3% 2%
Pacific Grove 7,723 8,411 8,347 9% -1%
Source: U.S. Census Bureau, ACS 5-Year Estimate, 2010-2019 Housing Type
Table A-19 provides a comparison of housing unit types in Carmel-by-the-Sea, the County, and nearby cities. In Carmel-by-the-Sea, single-family detached units are the most common housing type (87 percent). This aligns with the County (63 percent), Del Rey Oaks (76 percent), and Pacific Grove (60 percent) having majority single-family detached units. Overall, Carmel-by-the-Sea has the highest percentage of single-family detached units compared to the County and nearby cities, but the lowest percentage of multifamily housing units (10 percent).

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Appendix A – Housing Needs and Fair Housing Report A-71 Carmel-by-the-Sea 6th Cycle Housing Element Amendment July 7, 2026 Table A-19 Housing Units by Type by Jurisdiction, 2019
Jurisdiction
Single-Family
Detached
Single-Family
Attached Multi-Family Mobile Homes Total
Count Percent Count Percent Count Percent Count Percent Units Monterey County 88,721 63% 8,796 6% 37,734 27% 6,529 5% 141,820 Carmel-by-the-Sea 3,319 87% 54 1% 367 10% 92 2% 3,832
Del Rey Oaks 567 76% 49 7% 118 16% 11 2% 745
Pacific Grove 5,023 60% 497 6% 2,668 32% 159 2% 8,347
Source: U.S. Census Bureau, ACS 5-Year Estimate, 2019 NOTE: Table indicates total housing units.

Figure A-45 illustrates housing type trends in Carmel-by-the-Sea between 2010-2019. In 2010, the majority of housing types were single-family detached homes (82 percent); this has since increased to 87 percent in 2019. Multifamily housing (2+ units) has decreased by 3 percent since 2010 accounting for only 10 percent of housing types in 2019. In 2010, mobile homes comprised the smallest percentage of housing type in Carmel-by-the-Sea, and have since slightly increased to 2 percent in 2019.

Figure A-45 Housing by Type in Carmel-by-the-Sea, 2010-2019 Source: U.S. Census Bureau, ACS 5-Year Estimate, 2010-2019 Due to the limited supply of adequately sized units to accommodate larger households, large families often face significant difficulty in locating adequately sized, affordable housing. Figure A-46 illustrates the existing housing stock by number of bedrooms in Carmel-by-the-Sea. As shown in Figure A-46, the majority of existing housing units are two- and three-bedroom units, followed by studio units.

Approximately 20 housing units include five or more bedrooms (1 percent); 176 housing units include four bedrooms (5 percent); 1,408 housing units include three bedrooms (37 percent); 1,503 housing units include two bedrooms (39 percent); 299 housing units include one bedroom (8 percent); and 426 housing units include no bedroom (11 percent).

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Appendix A – Housing Needs and Fair Housing Report A-72 Carmel-by-the-Sea 6th Cycle Housing Element Amendment July 7, 2026 Figure A-46 Housing Stock by Number of Bedrooms, Carmel-by-the-Sea, 2019 Source: U.S. Census Bureau, ACS 5-Year Estimate, 2019
Housing Availability and Tenure
Housing tenure refers to individuals who own or rent a housing unit. The number of residents who own their homes compared to those who rent their homes can help identify the level of housing insecurity (i.e., ability for individuals to stay in their homes) in a city and region. Generally, renters may be displaced more quickly if prices increase. Additionally, housing tenure may be an indicator of housing affordability (i.e., if the local housing market has high barriers to entry, there may be more renter households than owner households).

In Carmel-by-the-Sea, the housing stock includes 828 renter-occupied housing units and 1,099 owneroccupied housing units (Table A-20). When analyzing housing unit type in tandem with tenure, the majority of all housing units are single-family detached (87 percent), of which 17 percent are renteroccupied and 32 percent are owner-occupied (Figure A-18; Table A-20).

Table A-20 Housing Units by Type and Tenure, Carmel-by-the-Sea, 2019 Tenure
Single-Family
Detached
Single-Family
Attached Multi-Family Mobile Homes
Count Percent Count Percent Count Percent Count Percent Total Units Renter-Occupied 568 69% 19 2% 221 27% 20 2% 828
Owner-Occupied 1,076 98% 0 0% 23 2% 0 0% 1,099
Source: U.S. Census Bureau, ACS 5-Year Estimate, 2019 NOTE: Table indicates total occupied housing units.

Table A-21 provides an overview of household size by tenure for Carmel-by-the-Sea, the County, and nearby cities. In Carmel-by-the-Sea, the average household size is 2.04, of which the majority of larger households are comprised of renter-occupied units (2.13 persons/unit). An average household size of

2.04 suggests a need for more small housing units. This aligns with 82 percent of Carmel-by-the-Sea’s population being comprised of 1-2 person households (Figure A-14). Compared to the County and nearby cities, Carmel-by-the-Sea has the lowest average household size (2.04 persons/unit). The County has a high average household size of 3.27 suggesting a need for large housing units and even a need for smaller independent units such as ADUs/JADUs for extended family.

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Appendix A – Housing Needs and Fair Housing Report A-73 Carmel-by-the-Sea 6th Cycle Housing Element Amendment July 7, 2026 Table A-21 Household Size by Tenure by Jurisdiction, 2019 Jurisdiction Owner-Occupied Renter-Occupied Average Household Size Monterey County 3.13 3.41 3.27
Carmel-by-the-Sea 1.97 2.13 2.04
Del Rey Oaks 2.29 2.49 2.35
Pacific Grove 2.34 2.15 2.23
Source: U.S. Census Bureau, ACS 5-Year Estimate, 2019
Figure A-47 illustrates 2019 household tenure by race in Carmel-by-the-Sea. Tenure by race varies some in Carmel-by-the-Sea as the majority of all households are non-Hispanic White (87 percent), of which 58 percent are owner-households and 42 percent are renter-households (Figure A-4; Figure A-45).

Hispanic or Latino households (8 percent) makeup the second largest population in Carmel-by-the-Sea, of which 72 percent are owner-households and 28 percent are renter-households. Less than 1 percent of Black or African American, Native Hawaiian or Other Pacific Islander, and American Indian or Alaska Native households are represented in the City’s housing market.

Figure A-48 illustrates vacancy rates in Carmel-by-the-Sea, the County, and nearby cities. Carmel-bythe-Sea has a vacancy rate of 50 percent. This reflects a 40 percent higher vacancy rate than the County (10 percent) and 32 percent higher than Pacific Grove (18 percent).

Figure A-49 illustrates vacancy trends in Carmel-by-the-Sea from 2010-2019. Over the course of nearly a decade, the City has experienced a stable vacancy average of 51 percent. This is staggeringly high considering the current housing crisis. Additionally, this affects the accuracy of data reporting for the City, as the majority of homeowners do not live in Carmel-by-the-Sea full time, thus resulting in skewed data collection.

Figure A-47 Household Tenure by Race, Carmel-by-the-Sea, 2019 Source: U.S. Census Bureau, ACS 5-Year Estimate, 2019

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Appendix A – Housing Needs and Fair Housing Report A-74 Carmel-by-the-Sea 6th Cycle Housing Element Amendment July 7, 2026 Figure A-48 Vacancy Rates by Jurisdiction, 2019
Source: U.S. Census Bureau, ACS 5-Year Estimate, 2019
Figure A-49 Vacancy Trends, Carmel-by-the-Sea, 2010-2019 Source: U.S. Census Bureau, ACS 5-Year Estimate, 2019
Table A-22 shows vacant housing units by type, revealing 80 percent of Carmel-by-the-Sea’s vacant units are for seasonal, recreational, or occasional use, aligning with the 51 percent average vacancy trends (Figure A-49). The high percentage of vacant housing units is largely impacted by tourism and second-home ownership. This creates a significant barrier for current and potential residents to enter the local housing market and hinders opportunities to correct the housing crisis, address diversity, and provide inclusive housing options to promote a vibrant and active community.

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Appendix A – Housing Needs and Fair Housing Report A-75 Carmel-by-the-Sea 6th Cycle Housing Element Amendment July 7, 2026 Table A-22 Vacant Housing Units by Type, Carmel-by-the-Sea, 2019 Housing Unit Type Estimate Percentage
For rent 96 5%
Rented, not occupied 12 1%
For sale only 11 1%
Sold, not occupied 49 3%
For seasonal, recreational, or occasional use 1,522 80% For migrant workers 0 0%
Other vacant 215 11%
Total 1,905 100%
Source: U.S. Census Bureau, ACS 5-Year Estimate, 2019
Table A-23 shows housing permits issued by the City of Carmel-by-the-Sea by income group. Between 2015 and 2021, 18 housing units were issued permits in Carmel-by-the-Sea which represents 58 percent of the RHNA number of 31 units assigned in the 5th Cycle Housing Element.

Table A-23 Housing Permits by Income Group, Carmel-by-the-Sea, 2015-2021 Income Group Number Percent
Very Low-Income Permits 0 0.0%
Low-Income Permits 0 0.0%
Moderate-Income Permits 0 0.0%
Above Moderate-Income Permits 18 58.0%
Total 18 58.0%
Source: California Department of Housing and Community Development (HCD), 5th Cycle Annual Progress Report Permit Summary (2022).

Note: Universe: Housing permits issued between 2015 and 2021. Notes: HCD uses the following definitions for the four income categories: Very Low Income: units affordable to households making less than 50 percent of the Area Median Income for the county in which the jurisdiction is located. Low Income: units affordable to households making between 50 percent and 80 percent of the Area Median Income for the county in which the jurisdiction is located. Moderate Income: units affordable to households making between 80 percent and 120 percent of the Area Median Income for the county in which the jurisdiction is located. Above Moderate Income: units affordable to households making above 120 percent of the Area Median Income for the county in which the jurisdiction is located.

Assisted Housing Developments At-Risk of Conversion
While there is an immense need to produce new affordable housing units, ensuring that the existing affordable housing stock remains affordable is equally important. Additionally, it is typically faster and less expensive to preserve currently affordable units that are at risk of converting to market-rate than it is to build new affordable housing.

The California Housing Partnership Preservation Database is the state’s most comprehensive source of information on subsidized affordable housing at risk of losing its affordable status and converting to market-rate housing.32 According to the database, there are no federal or state assisted units in Carmelby-the-Sea. 32 This database does not include all deed-restricted affordable units in the state, so there may be at-risk assisted units in a jurisdiction that are not captured.

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Appendix A – Housing Needs and Fair Housing Report A-76 Carmel-by-the-Sea 6th Cycle Housing Element Amendment July 7, 2026 A variety of affordable housing projects provided through an assortment of local programs serves the Carmel-by-the-Sea. Each of the following projects serves as an example of the methods and incentives used by the City to achieve production of affordable housing units.

Oliver White Building and Viejo Carmel
The mixed-use Oliver White building contains four residential units, one of which is a ModerateIncome unit in perpetuity. Originally this site was developed with a single-story commercial building.

The owner and City worked together to achieve a second story of residential apartments at a density of 44 units per acre.

The Viejo Carmel project is a larger example of infill development that provides affordable housing.

The 20,000 square-foot site was occupied by semi-industrial uses and offices. The site was razed and redeveloped with ten condominiums and ten apartments at a density of 44 units per acre. Without density bonuses, the site could only achieve 15 residential units. With density bonuses, an additional two Low-Income rental apartments in perpetuity were approved. Additionally, the parking requirement for the low-income units was reduced.

Norton Court Apartments
The Norton Court Apartments for seniors is operated by the Carmel Foundation. As part of this 24- unit project, the City entered into a 50-year agreement to lease the property for one dollar per year to the Carmel Foundation. This amounts to a substantial land subsidy provided by the City that offsets a large part of the cost of developing housing. The units are restricted as Low- and Moderate-Income.

Rents are maintained as affordable to lower-income seniors strictly through private donations raised by the Carmel Foundation.

Trevvett and Haseltine Courts
Trevvett and Haseltine Courts were developed with funding from the Carmel Foundation. Rents for the combined 26 rental apartments are maintained as affordable to lower-income seniors with private donations raised by the Foundation.

San Carlos Lodge
This site was granted a major addition and allowed the conversion of some existing apartments to transient overnight visitor accommodation units. As a condition, the project retained two of the existing apartments as affordable housing for Moderate-Income households in perpetuity.

The City’s inventory of affordable units is listed below in Table A-24.

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Appendix A – Housing Needs and Fair Housing Report A-77 Carmel-by-the-Sea 6th Cycle Housing Element Amendment July 7, 2026 Table A-24 Inventory of Assisted Rental Housing
Development Name Total Units Household Type Provided By Expiration of
Affordability
Oliver White 1 Moderate Density Bonus In perpetuity
Viejo Carmel 2 Low Density Bonus In perpetuity
Norton Court 24 Senior Low Lease Subsidy
Specific Plan
Not defined
San Carlos Lodge 2 Moderate Condition of Approval In perpetuity Trevvett Court 14 Senior, Very-Low &
Low
Private non-profit
Specific Plan
30 years
Haseltine Court 12 Senior Private non-profit Not applicable Hasegawa 1 Low Inclusionary In perpetuity
Carl 1 Senior Inclusionary 2027
Mandurrago 2 Senior Inclusionary In perpetuity
Gonzales 1 Low Inclusionary In perpetuity
Ravel Corporation 1 Low Inclusionary In perpetuity
Trini Iye 1 Moderate Inclusionary In perpetuity
Total 62
Source: City of Carmel-by-the-Sea Community Planning and Building Department, 2023 Potential Loss of Assisted Housing Units
Housing units developed with public subsidies are an important source of affordable housing to lowerincome households. Preserving the long-term affordability of such housing units is the most costeffective means for providing decent and affordable housing in a community. Recognizing this important resource, State Housing Element law requires that a jurisdiction examine the potential loss of publicly subsidized multi-family rental housing for lower-income household due to expiration of deed restrictions, affordability covenants, and /or subsidy contracts. All of the affordable housing units in Carmel are privately funded.

Norton Court, Trevvett Court, and Haseltine Court are operated by the Carmel Foundation, a 501(c)(3) charitable organization providing affordable senior housing units. The Foundation does not accept government funding. The Foundation currently has a 5-7 year wait list on these properties and does not intend to convert any units to market rate housing within this Housing Element cycle.

Norton Court receives a subsidized property lease from the City, and is located within a Specific Plan area that requires “24 efficient and moderately priced housing units for the elderly and handicapped residents of Carmel-By-The-Sea”. Further, the Specific Plan requires 21 studio units at 500 square feet each and 3 one-bedroom units at 572 square feet each.

Trevvett Court is also located within a Specific Plan area that requires “all 14 units be reserved for senior citizens of low or very low-income status for a period of at least 30 years.” Housing units within Trevvett Court range from 400-600 square feet in size.

Units in the Oliver White Building, Viejo Carmel, and Sand Carlos Lodge are restricted as affordable housing in perpetuity.

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Appendix A – Housing Needs and Fair Housing Report A-78 Carmel-by-the-Sea 6th Cycle Housing Element Amendment July 7, 2026 One unit in the Carl development is listed with an expiration date of 2027. City staff are further researching the terms of this affordable unit. To maintain the existing affordable housing stock, the City can either preserve the existing affordable units or facilitate the development of new units.

Depending on the circumstances of at-risk projects, different options may be used to preserve or replace the units. Preservation options typically include: 1) construction of replacement units; 2) provision of rental assistance to tenants; 3) transfer of the project to nonprofit ownership; and 4) purchase of affordability covenants. These options are described below and the City’s focus is on construction of replacement units and rental assistance.

Construction of Replacement Units
The construction of new affordable housing units is a means of replacing the at-risk units should they be converted to market-rate units. The cost of developing housing depends on a variety of factors, including density, size of the units (i.e. square footage and number of bedrooms), location, labor, materials and land costs, and type of construction. The City is implementing a number of programs to encourage development of new affordable units to increase the City’s affordable housing stock.

Rental Assistance
Rental subsidies using non-federal (state, local, or other) funding sources can be used to maintain affordability of at-risk units. These rent subsidies can be structured to mirror the federal Housing Choice Voucher (Section 8) program. Under Section 8, HUD pays the difference between what tenants can pay (defined as 30 percent of household income) and what HUD estimates as the fair market rent on the unit. The feasibility of this alternative is highly dependent on the availability of other funding sources necessary to make rent subsidies available and the willingness of property owners to accept rental vouchers if they can be provided. Housing Choice Vouchers are available through the Housing Authority of Monterey County.

Transfer of Ownership
Transferring ownership of an at-risk project to a nonprofit housing provider is generally one of the least costly ways to ensure that at-risk units remain affordable for the long term. By transferring property ownership to a nonprofit organization whose mission includes affordable housing, the risk of losing the low-income restrictions is minimized, and the project would become potentially eligible for a greater range of governments assistance.

Purchase of Affordability Covenants
Another option to preserve the affordability of at-risk projects is to provide an incentive package to the owners to maintain the projects as affordable housing. Incentives could include bringing down the interest rate on the remaining loan balance, providing loans for capital improvements, and/or supplementing subsidies. The feasibility of this option depends on whether the complex is too highly leveraged. By providing lump sum financial incentives or ongoing subsidies in the form of rents or

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Appendix A – Housing Needs and Fair Housing Report A-79 Carmel-by-the-Sea 6th Cycle Housing Element Amendment July 7, 2026 reduced mortgage interest rates to the owner, the City can ensure that some of all of the units remain affordable.

Displacement
Because of increasing housing prices, displacement is a major concern in the Monterey Bay Area.

Displacement has the most severe impacts on low- and moderate-income residents. When individuals or families are forced to leave their homes and communities, they also lose their support network.

According to the California Department of Housing and Community Development (HCD) AFFH Data Viewer and the Urban Displacement Project 2022 estimates, Carmel-by-the-Sea renter-occupied households earning between 0-80 percent AMI are at low risk of potential displacement or gentrification in the northern region of the City. Mapping of the central and southern regions of the City show sufficient data was not captured to definitively report displacement risk. Figure A-51 illustrates displacement risk in Carmel-by-the-Sea.

Housing Age and Condition
Housing age and condition are factors considered in overall housing quality as they may affect the structural integrity and ability to adequately function for a household. Thus, the age and condition of a house may indicate the need for major repairs to the foundation, plumbing, or roof.

Figure A-50 illustrates housing stock by age in Carmel-by-the-Sea. In Carmel-by-the-Sea, 95 percent of the housing stock was built prior to 1999 and is over 20 years old. Thirty-seven (37) percent of the housing stock was built between 1940-1959 and 2 percent was built in 2010 or later.

Figure A-50 Housing Stock by Age, Carmel-by-the-Sea, 2019 Source: U.S. Census Bureau, ACS 5-Year Estimate, 2019

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Appendix A – Housing Needs and Fair Housing Report A-80 Carmel-by-the-Sea 6th Cycle Housing Element Amendment July 7, 2026 Figure A-51 Displacement Risk, Carmel-by-the-Sea, 2022
Source: California Department of Housing and Community Development AFFH Data Viewer

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Appendix A – Housing Needs and Fair Housing Report A-81 Carmel-by-the-Sea 6th Cycle Housing Element Amendment July 7, 2026 According to historical data from Carmel-by-the-Sea’s Code Compliance Coordinator, the City estimates that there are approximately five-six (5-6) units in need of rehabilitation. This 6th Cycle Housing Element proposes the following policies and programs to address and facilitate the rehabilitation of these units.
 Policy 2.1: Maintain and encourage expansion of permanent residential housing stock in the Residential and Commercial Districts;
 Policy 2.2: Preserve and protect the scale of established neighborhoods while encouraging property improvement;
 Policy 2.3: Preserve and expand affordable and rental housing opportunities to enable local employees to live in the community where they work; and  Policy 2.4: Preserve the existing housing stock.

All programs and policies can be found in Chapter 2 of the Housing Element.

The City’s Code Compliance Officer works to educate property owners about income-based financing opportunities for the rehabilitation of substandard units. Code Compliance receives a limited number of complaints related to Health and Safety and associated substandard units. Over the last four years Code Compliance has received 11 property maintenance complaints and approximately five to six of these cases indicated a need for repairs related to substandard housing issues. Cases are complaint driven and the city does not reach out to property owners with methods to fund repairs.33 According to Code Compliance records from October 202334 and November 2023,35 the majority of property maintenance complaints include conducting remodeling work and electrical maintenance without the proper permits and authorization. Based on Code Compliance records and on-site local knowledge, the complaints are spread across the city. However, the southern region of the city has received complaints more frequently than other areas in the city.

As indicated by the 102 building permit applications received by the City in October and November of 2023 (49 building permits as of October 2023 and 53 building permits as of November 2023), many residents in Carmel-by-the-Sea are interested in maintaining the upkeep of their residences, and fixing any structural issues that may need to be repaired – to prevent their residences from becoming “substandard.” However, to the City's knowledge, all units have a functioning kitchen, indoor plumbing, and electricity, and are not “substandard.” The majority of building permit applications include new roofing; electrical repairs; plumbing repairs; water heater replacement; window replacement; bathroom remodels; foundation upgrades; and exterior repairs (new paint/siding). As a proactive measure and to assist low-income property owners, the City will distribute information on inspection services, housing rehabilitation programs, and alternative ways to finance home repairs (Program 2.4.A, see Chapter 2). Based on Code Compliance reports, the City will specifically monitor and provide resources to residential units located in the southern region of the city. 33 Correspondence with Code Compliance Officer December 15, 2023 34 https://carmel.novusagenda.com/agendapublic/CoverSheet.aspx?ItemID=5833&MeetingID=1505 35 https://carmel.novusagenda.com/agendapublic/CoverSheet.aspx?ItemID=5929&MeetingID=1543

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Appendix A – Housing Needs and Fair Housing Report A-82 Carmel-by-the-Sea 6th Cycle Housing Element Amendment July 7, 2026 Housing Costs and Affordability
Identifying the cost of owning or renting a home in a city helps determine the affordability of housing at different income levels. Understanding housing affordability also informs what types and sizes of housing are needed by the community’s households.

Home Prices and Rental Costs
Table A-25 show changes in median home values between 2019-2022 in Carmel-by-the-Sea, the County and nearby cities. According to Zillow Home Value Index data, the median home value in Carmel-bythe-Sea was estimated at $1,299,387 in December 2019. By 2022, the median home value in Carmel-bythe-Sea increased approximately 59 percent due to market demand. By comparison, the median home value in the County was valued at $561,490 in December 2019 and experienced a 39 percent increase by 2022.

Table A-25 Median Home Value by Jurisdiction, 2019-2022 Jurisdiction
Median Home Value Percent Change
2019 2020 2021 2022 2019-2022
Monterey County $561,490 $632,834 $735,469 $778,164 39% Carmel-by-the-Sea $1,299,387 $1,450,127 $1,912,421 $2,070,835 59% Del Rey Oaks $630,204 $701,060 $779,099 $840,663 33%
Seaside $550,015 $616,786 $690,126 $729,055 33%
Pacific Grove $943,900 $1,032,675 $1,237,054 $1,294,881 37% Source: Zillow Home Value Index, 2019-2022
Note: Housing value estimates were taken from December for years 2019-2022.

Rental Affordability
Similar to home value prices, rental prices have also increased over the last decade. This significantly affects lower-income households as they are typically majority renters. High rental prices can exacerbate housing challenges such as overcrowding and cost burden if adequate rental stock is not available to suit household needs.

Table A-26 shows average rent estimates by unit size in Carmel-by-the-Sea based on 2023 Zillow rental market data. Included in the table is Housing and Urban Development’s (HUD) Fair Market Rents (FMR) for 2023, which establishes rental subsidy limits for Section 8 housing voucher recipients.

Table A-26 Average Rent by Number of Bedrooms, Carmel-by-the-Sea, 2023 Unit Type Average Rents Fair Market Rents (HUD)
Studio $2,200 $2,112
One bedroom $2,500 $2,194
Two bedrooms $4,000 $2,675
Three bedrooms $5,459 $3,790
Four+ bedrooms n/a $4,144
Source: Zillow, 2023; HUD, Fair Market Rent Documentation System, 2023 Notes: Zillow rental value estimates were taken from March 2023. No rental units with four + bedrooms are listed as available within the Carmelby-the-Sea City boundary. Fair Market Rent values are based on Salinas, CA MSA

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Appendix A – Housing Needs and Fair Housing Report A-83 Carmel-by-the-Sea 6th Cycle Housing Element Amendment July 7, 2026 Table A-27 reports the maximum monthly housing costs affordable to households according to income group in Monterey County. Income groups are based on the HCD 2022 State Income Limits Report, which considers housing affordable assuming a household can pay up to 30 percent of its monthly income toward housing. In Table A-27, maximum affordable sales prices are based on the following assumptions: 6.42 percent interest rate,36 30-year fixed loan, and a 5 percent down payment.

Table A-27 Housing Affordability, Carmel-by-the-Sea, 2022 Income Group HCD Income Limits
Maximum Affordable Price
Monthly Rental Ownership
Extremely Low (0-30% AMI)
One Person $23,900 $598 $100,340
Two Person $27,300 $683 $114,614
Three Person $30,700 $768 $128,889
Four Person $34,100 $853 $143,163
Very Low (30-50% AMI)
One Person $39,800 $995 $167,093
Two Person $45,500 $1,138 $191,024
Three Person $51,200 $1,280 $214,954
Four Person $56,850 $1,421 $238,675
Low (50-80% AMI)
One Person $63,700 $1,593 $267,433
Two Person $72,800 $1,820 $305,638
Three Person $81,900 $2,048 $343,843
Four Person $91,000 $2,275 $382,048
Moderate (80-120% AMI)
One Person $75,650 $1,891 $317,603
Two Person $86,500 $2,163 $363,155
Three Person $97,300 $2,433 $408,497
Four Person $108,100 $2,700 $453,839
Source: California Department of Housing and Community Development, State Income Limits, 2022, Monterey County As mentioned in Table A-25, the median home price in Carmel-by-the-Sea in December 2022 was $2,070,835 which is only affordable to above moderate-income households earning approximately $495,000 or more annually (62 percent of Carmel-by-the-Sea households are categorized as above moderate-income).
36 Interest rate based on December 29, 2022 interest rate according to Freddie Mac Primary Mortgage Market Survey

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Appendix A – Housing Needs and Fair Housing Report A-84 Carmel-by-the-Sea 6th Cycle Housing Element Amendment July 7, 2026 A.7 Fair Housing Enforcement and Outreach Capacity
This section discusses fair housing legal cases and inquiries, fair housing protections and enforcement, and outreach capacity.

Fair Housing Legal Cases and Inquiries
California fair housing law extends beyond the protections in the Federal Fair Housing Act (FHA). In addition to the FHA protected classes – race, color, ancestry/national origin, religion, disability, sex, and familial status – California law offers protections for age, sexual orientation, gender identity or expression, genetic information, marital status, military or veteran status, and source of income (including federal housing assistance vouchers).

The California Department of Fair Employment in Housing (DFEH) was established in 1980 and is now the largest civil rights agency in the United States. According to their website, the DFEH’s mission is, “to protect the people of California from unlawful discrimination in employment, housing and public accommodations (businesses), and from hate violence and human trafficking in accordance with the Fair Employment and Housing Act (FEHA), Unruh Civil Rights Act, Disabled Persons Act, and Ralph Civil Rights Act.”37
DFEH receives, evaluates, and investigates fair housing complaints. DFEH plays a particularly significant role in investigating fair housing complaints against protected classes that are not included in federal legislation and therefore not investigated by HUD. DFEH’s website provides detailed instructions for filing a complaint, the complaint process, appealing a decision, and other frequently asked questions.38 Fair housing complaints can also be submitted to HUD for investigation.

Additionally, Monterey County has a number of local resource and enforcement organizations:
 The Housing Authority of the County of Monterey: A public agency that provides rental assistance and develops and manages affordable housing throughout Monterey County, California;
 South County Housing: A non-profit community development corporation. The organization’s mission is to promote viable neighborhoods that enhance healthy, sustainable communities by collaboratively providing affordable housing and promoting neighborhood services;
 Public Interest Law Project: a nonprofit support center for California legal services and other public interest law programs. The California Affordable Housing Law Project (CAHLP) is a project of the Public Interest Law Project. CAHLP concentrates primarily on the enforcement of California’s Housing Element and redevelopment statutes and of state and federal relocation assistance and fair housing laws;  Coalition of Homeless Service Providers: Advocate on the subject of homelessness with policy makers, public funders, and those with lived experience; and 37 From State of California, Civil Rights Department
38 From State of California, Civil Rights Department Complaint Process

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Appendix A – Housing Needs and Fair Housing Report A-85 Carmel-by-the-Sea 6th Cycle Housing Element Amendment July 7, 2026  California Rural Legal Assistance (CRLA): a nonprofit legal service program created to help California’s low-income individuals and communities. CRLA provides low-income rural Californians with free legal assistance and a variety of community education and outreach programs. Half of its resources are committed to multi-client cases that grapple with the root causes of poverty, with the goal of improving conditions for farmworkers, single parents, school children, the elderly, people with disabilities, and entire communities.

Between 2012 and 2017, 53 fair housing complaints in Monterey County had been filed with the California Department of Fair Employment and Housing (DFEH). Among the complaints countywide, most were related to physical disabilities (23 instances) and familial/marital status (ten instances).

Discrimination based on race was also common (seven instances). A complaint may involve multiple acts of discrimination and vice versa. A total of 57 acts of discrimination were recorded in Monterey County. Refusal to rent (17 instances), discriminatory statements (12 instances), and denial of reasonable accommodation/modifications (12 instances) were the most common discriminatory acts in the County.39
In 2020, a total of six discrimination cases were found with the Office of Fair Housing and Equal Opportunity. Fifty percent of the cases were filed on the basis of disability bias. None of the complaints alleged racial bias. Figure A-52 illustrates that out of all of the FHEO cases filed in the state of California in 2020 (398), only between 1 and 2.5 percent of the cases were filed in Monterey County.

None of the discrimination cases filed in Monterey County in 2020 took place in Carmel-by-the-Sea.40 A total of six discrimination complaints were filed within Monterey County during 2020. Of those cases, three of them alleged discrimination based on disability. Figure A-53 illustrates this statistic by showing that 40.01 to 65 percent of the cases filed in Monterey County during 2020 reflected disability bias. None of the FHEO complaints occurred in the City of Carmel-by-the-Sea.

NFHA identifies three significant trends in 2020 that are relevant for this AFFH:
 First, fair lending cases referred to the Department of Justice from federal banking regulators has been declining, indicating that state and local government entities may want to play a larger role in examining fair lending barriers to homeownership;  Second, NFHA identified a significant increase in the number of complaints of harassment – 1,071 complaints in 2020 compared to 761 in 2019; and
 Finally, NFHA found that 73 percent of all fair housing complaints in 2020 were processed by private fair housing organizations, rather than state, local, and federal government agencies – reinforcing the need for local, active fair housing organizations and increased funding for such organizations.41
39 From California Department of Fair Employment & Housing, 2018; Monterey County Regional Analysis of Impediments to Fair Housing Choice, 2019
40 City of Carmel-by-the-Sea, 2023
41 From Gentry, A. (2021, September 4). Annual fair housing report shows increase in housing harassment. NFHA

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Appendix A – Housing Needs and Fair Housing Report A-86 Carmel-by-the-Sea 6th Cycle Housing Element Amendment July 7, 2026 Figure A-52 FHEO Cases Total, Monterey County, 2020
Source: California Department of Housing and Community Development AFFH Data Viewer

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Appendix A – Housing Needs and Fair Housing Report A-87 Carmel-by-the-Sea 6th Cycle Housing Element Amendment July 7, 2026 Figure A-53 FHEO Cases, Disability Bias, Monterey County, 2020 Source: California Department of Housing and Community Development AFFH Data Viewer

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Appendix A – Housing Needs and Fair Housing Report A-88 Carmel-by-the-Sea 6th Cycle Housing Element Amendment July 7, 2026 Outreach and Capacity
Currently, Carmel-by-the-Sea’s website contains information about local fair housing ordinances. The website describes the steps residents should take if they feel they have faced discrimination and are seeking information about filing complaints (e.g., link to HUD’s and State of California fair housing pages). The site also references the organizations that provide fair housing services and assistance to City residents.

The following organizations offer fair housing services and assistance to the residents of Carmel-by-theSea:
 Conflict Resolution and Mediation Center;
 Legal Services for Seniors;
 California Rural Legal Assistance;
 ECHO Fair Housing Services
 HUD Housing Assistance;
 Central Coast Center for Independent Living; and
 Center for Community Advocacy.

Compliance with State Fair Housing Law
The City of Carmel-by-the-Sea complies with existing fair housing laws and regulations by ensuring all residents have equal access to housing programs, services, and resources and supporting residents in filing complains on housing discrimination. Carmel-by-the-Sea is compliant with the following State laws that promote fair and affordable housing. The City has not been alleged or found in violation of the following:
 Fair Housing Act of 1968 – The City has adopted housing policies that prohibit housing discrimination based on protected characteristics and ensuring equal access to housing programs and services.
 California Fair Employment and Housing Act (FEHA) (Part 2.8 (commencing with Section 12900) of Division 3 or Title 2) – The City complies with the Fair Employment and Housing Act by upholding policies that prohibit housing discrimination based on protected characteristics and enforces these policies by supporting residents seeking to file a complaint to the FHEO or who wish to pursue legal action.
 Government Code §65008 – The City does not discriminate or deny any individual or group of individuals the right to residence, land ownership, tenancy, or other land use on the basis of one’s membership or perceived membership in a protected class, method of financing, and/or the intended occupancy. The City has adopted housing policies that prohibit discrimination based on protected characteristics. Further, the City has received zero FHEO complaints, and is committed to conducting outreach and educating residents on Fair Housing Law. Program 5.1.A in this Housing Element commits the City to providing information on fair housing and services offered in the region (see Chapter 2).

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Appendix A – Housing Needs and Fair Housing Report A-89 Carmel-by-the-Sea 6th Cycle Housing Element Amendment July 7, 2026  Government Code §11135 et. seq. – The City does not discriminate or deny any individual or group of individuals access to programs or activities operated, administered, or funded with financial assistance from the state, regardless of one’s membership or perceived membership in a protected class. The City included Programs 5.1.B, 5.1.C, and 5.1.D in this Housing Element to promote affordable housing opportunities and resources, including Housing Choice Vouchers, shared housing programs, and farmworker housing resources (see Chapter 2).
 Assembly Bill 686 – The City has included this assessment of fair housing and identifies strategies to increase housing opportunities for all residents, with specific actions to reduce housing disparities for disadvantaged communities.
 Density Bonus Law – The City last updated their Density Bonus provisions in the Municipal Code in 2016. In compliance with State law, the City will update its Density Bonus provisions outlined in the Municipal Code to be consistent with recent changes to the State Density Bonus Law. Program 3.1.C will regulate this amendment to the Code.  Senate Bill (SB) 35 – The City was previously not subject to the requirements of SB 35 due to its location in the coastal zone. However, as of October 2023, SB 423 now expands SB 35 measures to cities located in the coastal zone under specific criteria. The City is now subject to SB 35 and SB 423 requirements and will comply with State law as established in this Housing Element through Program 1.3.D (see Chapter 2).
 Rehabilitation Act of 1973 – The City does not discriminate against persons with disabilities and promotes equal opportunities, accessibility, and independence for individuals with disabilities.
 American Disabilities Act – The City’s Municipal Code establishes procedures for persons with disabilities seeking equal access to housing including reasonable accommodation for persons with disabilities. The City ensures housing developers comply with the American Disabilities Act through permit process review. The City includes Program 3.2.A to amend the Municipal Code regulations related to reasonable accommodations (see Chapter 2).  Housing Accountability Act (Gov. Code. §65589.5) requiring adoption of a Housing Element and compliance with RHNA allocations – The City will comply with the Housing Accountability Act by approving any eligible housing development projects, including those with at least 20 percent affordable units to lower-income households.  No Net Loss Law (Gov. Code §65863) requiring that adequate sites be maintained to accommodate unmet RHNA allocations – The City complies with the No Net Loss Law by identifying sites that can accommodate the City’s RHNA. The City also maintains minimum density requirements for multi-family housing developments in the R-4 district. To further encourage the development of affordable housing, the City is committed to amending the Municipal Code to amend the base zoning for the SC, RC, and CC commercial districts and the R-4 multi-family residential development district to allow a minimum of 33 dwelling units per acre.

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Appendix A – Housing Needs and Fair Housing Report A-90 Carmel-by-the-Sea 6th Cycle Housing Element Amendment July 7, 2026  Limits on Growth Controls Law (Gov. Code. §65302.8) – The City complies with the Limits on Growth Controls Law. The City is surrounded by County development and has not adopted any mandatory general plan elements which limit the number of housing units.  Housing Element Law (Gov. Code §65583(c)(5),(c)(10) – The City has included this analysis of fair housing and identifies strategies to increase housing opportunities for all residents, with specific actions to reduce housing disparities for lower-income households.

Housing Specific Policies Enacted Locally
The City of Carmel-by-the-Sea identified the following local policies that contribute to the regulatory environment for affordable housing development in the City:

Policy 1.1: Ensure adequate sites are available to meet the City’s projected housing growth needs.

Policy 1.3: Reduce or eliminate governmental constraints on the provision of affordable housing. Direct public funding resources to the conservation of existing housing units in neighborhoods where continued residential use is appropriate.

Policy 2.3: Preserve and expand affordable and rental housing opportunities to enable local employees to live in the community where they work.

Policy 2.4: Preserve the existing housing stock.

Policy 3.2: Recognize the special needs of persons with disabilities and the need to retain flexibility in the design review process to accommodate these needs.

Fair Housing and Sites Inventory Assessment
This portion of the Housing Needs and Fair Housing Report analyzes the relation between the housing opportunity sites and AFFH (affirmatively furthering fair housing)-related issues. Government Code §65583(c)(10) requires the housing opportunity sites to be analyzed with respect to AFFH to ensure that sites designated for low-income households are dispersed equitably throughout the city rather than concentrated in areas of high segregation and poverty or low-resource areas that have historically been underserved, and conversely, that sites designated for above moderate-income households are not concentrated in areas of high resources. By comparing the Site Inventory to the fair housing indicators in this assessment, this section analyzes whether the sites included in the Housing Element Site Inventory improve or exacerbate fair housing conditions, patterns of segregation, and access to opportunity. The City’s sites inventory is shown in Figure A-54 and includes pending projects, potential hotel-to-residential conversion sites, religious facility properties, potential live/work units and mixed income incentive program sites, as well as additional opportunity sites. As the specific hotels to participate in the conversion program cannot be determined at this time, this figure illustrates the location of all hotels in the City except those in single-family zones. The sites inventory is described in detail in Appendix C of this Housing Element.

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Appendix A – Housing Needs and Fair Housing Report A-91 Carmel-by-the-Sea 6th Cycle Housing Element Amendment July 7, 2026 Figure A-54 Sites Inventory

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Appendix A – Housing Needs and Fair Housing Report A-92 Carmel-by-the-Sea 6th Cycle Housing Element Amendment July 7, 2026 Segregation and Integration
Race/Ethnicity
According to HCD AFFH Data Viewer 3.0 estimates (2022 Census), less than 20 percent of the population in both Carmel block groups belong to non-White groups. The northern block group has a slightly larger non-White population (14.8 percent) compared to the southern block group (5.6 percent). However, populations are predominantly White citywide. As shown in Figure A-55, opportunity sites for hotel to residential conversions are scattered throughout the City and are not concentrated in a single area. Approximately 39 percent of hotel conversion opportunity sites are in the south block group and 61 percent are in the north block group.

Amongst all other RHNA sites (pending projects, religious facility properties, live/work units, mixed income incentive program sites, and additional opportunity sites), 57 percent are in the north block group and 43 percent are in the south block group. A slightly larger proportion of lower income RHNA units are in the south block group (54 percent) compared to the north block group (46 percent).

The City’s RHNA strategy does not concentrate units of any income level in neighborhoods with heightened non-White populations. As discussed above, the City as a whole is predominantly White and sites of all types are scattered throughout Carmel-by-the-Sea.

Persons with Disabilities
According to HCD AFFH Data Viewer 3.0 estimates (2018-2022 ACS), both Carmel tracts have populations of persons with disabilities representing between 10 and 20 percent of the tract population.

Persons with disabilities in the north and south tracts are comparable (15.6 percent and 10.5 percent, respectively). As discussed above, RHNA sites are distributed throughout the City and are not concentrated in a single neighborhood alone. Further, there are no concentrations of RHNA units of any income level in areas with uniquely high or low populations of persons with disabilities.

Familial Status
Most children (>80 percent) in both Carmel-by-the-Sea tracts live in married couple households.

Further, less than 11 percent of children in both tracts live in single-parent female-headed households.

In the southern tract, 100 percent of children reside in married couple households. A slightly larger proportion of RHNA units (not including hotel conversion sites) are in the southern tract compared to the northern (80 lower income units vs. 69 lower income units, respectively). Hotel conversion sites are distributed throughout the City and are not concentrated in a single neighborhood alone. There are no areas with acutely large populations of children residing in single-parent households. Further, the City’s sites strategy does not concentrate RHNA units of any income level in a single area of the City alone.

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Appendix A – Housing Needs and Fair Housing Report A-93 Carmel-by-the-Sea 6th Cycle Housing Element Amendment July 7, 2026 Figure A-55 Sites Inventory and Non-White Population by Block Group (2022)

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Appendix A – Housing Needs and Fair Housing Report A-94 Carmel-by-the-Sea 6th Cycle Housing Element Amendment July 7, 2026 Income
The sites inventory and low to moderate income (LMI) populations are shown at the block group-level in Figure A-56. LMI populations are based on HCD AFFH Data Viewer 3.0 estimates (HUD 2024) and are considered tracts or block groups with LMI populations exceeding 50 percent. The block group encompassing the central area of the City has the largest LMI population of 58.3 percent and is the only block group in Carmel-by-the-Sea that is considered an LMI area.

As shown in Table A-28 and Figure A-56 below, hotel to residential conversion opportunity sites are distributed throughout the City in all four Carmel-by-the-Sea block groups. Most hotel sites (63.8 percent) are in block groups that are not considered LMI areas, while 36.2 percent are in the central block group where 58.3 percent of households are low or moderate income. Amongst all other RHNA units, 57 percent are in the block group that is considered an LMI area (Table A-29). However, RHNA units are not concentrated in the LMI area alone. Housing opportunities have been identified citywide and are not concentrated in a single neighborhood. The distribution of RHNA units throughout block groups with variable LMI household populations aims to increase housing mobility by providing new housing opportunities citywide, and serve existing communities in need of additional housing opportunities.

Table A-28 Distribution of Potential Hotel-to-Residential Conversion Opportunity Sites by LMI Population (2024)
LMI Population (Block Group) Hotel Rooms Percent
<25% 252 25.2%
25-50% 385 38.5%
50-75% 362 36.2%
>75% 0 0.0%
Total 999 100.0%
Source: HCD AFFH Data Viewer 3.0, HUD 2024.

Table A-29 Distribution of RHNA Units by LMI Population (2024) LMI Population
(Block Group)
Lower Moderate Above Moderate Total
Units Percent Units Percent Units Percent Units Percent <25% 0 0.0% 0 0.0% 0 0.0% 0 0.0%
25-50% 69 46.3% 1 50.0% 32 37.2% 102 43.0%
50-75% 80 53.7% 1 50.0% 54 62.8% 135 57.0%
>75% 0 0.0% 0 0.0% 0 0.0% 0 0.0%
Total 149 100.0% 2 100.0% 86 100.0% 237 100.0%
Source: HCD AFFH Data Viewer 3.0, HUD 2024.

Note: Includes pending projects, religious facility properties, live/work units, mixed income incentive program sites, and additional opportunity sites.

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Appendix A – Housing Needs and Fair Housing Report A-95 Carmel-by-the-Sea 6th Cycle Housing Element Amendment July 7, 2026 Figure A-56 Sites Inventory and LMI Population by Block Group (2024)

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Appendix A – Housing Needs and Fair Housing Report A-96 Carmel-by-the-Sea 6th Cycle Housing Element Amendment July 7, 2026 Racially/Ethnically Concentrated Areas
Racially/Ethnically Concentrated Areas of Poverty (R/ECAPs) and TCAC Areas of High Segregation and Poverty
There are no HUD R/ECAPs or TCAC/HCD areas of high segregation and poverty that have been identified in Carmel-by-the-Sea. Therefore, no RHNA units are located in areas with these designations.

Racially Concentrated Areas of Affluence (RCAA)
There are no RCAAs that have been identified in Carmel-by-the-Sea. Therefore, no RHNA units are located in areas with this designation.

Access to Opportunities
Both Carmel-by-the-Sea tracts are considered TCAC/HCD highest resource areas. Therefore, all RHNA units are located in highest resource areas.

Environmental Opportunities
The TCAC/HCD Opportunity Maps include an Environmental Burden Flag layer based on the California Office of Environmental Health Hazard Assessment (OEHHA)’s CalEnviroScreen 4.0 tool (CES) indicators. Based on the 2025 TCAC/HCD maps, there are no tracts in Carmel-by-the-Sea that have the Environmental Burden Flag. The CalEnviroScreen 4.0 map for Carmel-by-the-Sea identifies the degree to which communities are considered burdened by pollution by comparing the scores of each census tract to every other census tract in the state. Both Carmel-by-the-Sea tracts scored in the highest quintile for environmental conditions, indicating more positive environmental factors.

Therefore, there are no RHNA units in areas with worse environmental conditions.

Disproportionate Housing Needs
Cost Burden
Between 40 and 60 percent of owners in both Carmel-by-the-Sea tracts are cost burdened. A slightly higher proportion of the owner population in the north tract are cost burdened (59.3 percent) compared to the south tract (45.5 percent). As discussed above, RHNA units are dispersed throughout the City and are not concentrated in a single neighborhood. Approximately 57 percent of RHNA units (pending projects, religious facility properties, live/work, mixed income incentive program sites, and additional opportunity sites) are in the southern tract where 45.5 percent of owners are cost burdened.

The sites inventory is shown in relation to cost burdened renters in Figure A-57, Table A-30, and Table A-31. A larger proportion of renters in the southern tract are cost burdened (64.8 percent) compared to the northern tract (43.6 percent). Potential hotel conversion sites are scattered throughout the City. Of the potential hotel conversion sites, 60.8 percent are in the northern tract where a smaller proportion of renter households experience cost burden. Conversely, a slightly larger proportion of non-hotel RHNA units (57 percent) are in the southern tract where a larger proportion of renter households are cost burdened. Of RHNA units identified through pending projects, religious facility properties, live/work

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Appendix A – Housing Needs and Fair Housing Report A-97 Carmel-by-the-Sea 6th Cycle Housing Element Amendment July 7, 2026 units, mixed income incentive program sites, and additional opportunity sites, 53.7 percent of lower income units, 50 percent of moderate income units, and 62.8 percent of above moderate income units are in the southern tract where the cost burdened renter population is more prevalent. It is also relevant to note that the northern tract, where only 43.6 percent of renters are cost burdened, has a larger overall renter population representing 53.8 percent of the tract population (438 renter households). The southern tract, where 64.8 percent of renters are cost burdened, has a renter population of only 244 households (31.6 percent of the tract population).

Overall, the City’s RHNA strategy distributes housing opportunities throughout the City and does not concentrate units of any income level in a single neighborhood alone. Further, the sites strategy does not concentrate lower income units in the southern tract where the cost burdened renter population is higher at a rate exceeding the above moderate income unit share. The sites strategy increases housing mobility by supporting housing development citywide, while also serving existing needs.

Table A-30 Distribution of Potential Hotel-to-Residential Conversion Opportunity Sites by Cost Burdened Renters (2022)
Overpaying Renters
(Tract) Hotel Rooms Percent
<20% 0 0.0%
20-30% 0 0.0%
30-40% 0 0.0%
40-60% 607 60.8%
60-80% 392 39.2%
>80% 0 0.0%
Total 999 100.0%
Source: HCD AFFH Data Viewer 3.0, 2018-2022 ACS.

Table A-31 Distribution of RHNA Units by Cost Burdened Renters (2022) Overpaying Renters
(Tract)
Lower Moderate Above Moderate Total
Units Percent Units Percent Units Percent Units Percent <20% 0 0.0% 0 0.0% 0 0.0% 0 0.0%
20-30% 0 0.0% 0 0.0% 0 0.0% 0 0.0%
30-40% 0 0.0% 0 0.0% 0 0.0% 0 0.0%
40-60% 69 46.3% 1 50.0% 32 37.2% 102 43.0%
60-80% 80 53.7% 1 50.0% 54 62.8% 135 57.0%
>80% 0 0.0% 0 0.0% 0 0.0% 0 0.0%
Total 149 100.0% 2 100.0% 86 100.0% 237 100.0%
Source: HCD AFFH Data Viewer 3.0, 2018-2022 ACS.

Note: Includes pending projects, religious facility properties, live/work units, mixed income incentive program sites, and additional opportunity sites.

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Appendix A – Housing Needs and Fair Housing Report A-98 Carmel-by-the-Sea 6th Cycle Housing Element Amendment July 7, 2026 Figure A-57 Sites Inventory and Cost Burdened Renters by Tract (2022)

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Appendix A – Housing Needs and Fair Housing Report A-99 Carmel-by-the-Sea 6th Cycle Housing Element Amendment July 7, 2026 Figure A-58 Sites Inventory and Displacement Risk by Tract (2022)

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Appendix A – Housing Needs and Fair Housing Report A-100 Carmel-by-the-Sea 6th Cycle Housing Element Amendment July 7, 2026 Overcrowding
Neither tract in the City has a population of overcrowded households exceeding five percent.

Therefore, there are no RHNA units in areas where overcrowding is an issue.

Displacement
The Urban Displacement Project (UDP) designates census tracts as “sensitive communities” if the share of very low-income residents is greater than 20 percent and have any of the two following characteristics:
 The share of renters is above 40 percent
 The share of people of color is above 50 percent
 The share of very low-income households that are severely rent burdened is above the county median
 The percent change in rent is above the county median for rent increases According to the UDP, the north Carmel-by-the-Sea tract is considered an area with a lower displacement risk. The southern tract does not have displacement risk data due to the small population.

Therefore, there are no RHNA sites in areas with a heightened displacement risk.

Fair Housing and Sites Inventory Assessment Summary
The City’s sites inventory includes a variety of housing opportunities located throughout the City.

There are no RHNA units of any income levels concentrated in a single area of the City. Further, due to the relatively small footprint of the City (approximately one square mile), demographic populations are generally homogenous citywide. Due to the spread of the RHNA sites and the lack of concentrated vulnerable populations (i.e., non-White, persons with disabilities, cost burdened households), the sites inventory does not exacerbate existing fair housing conditions. Sites selected to meet the RHNA aim to serve a variety of populations (i.e., lower, moderate, and above moderate income households, live/work units, mixed income). Additionally, the location of the sites supports housing mobility by facilitating new housing opportunities suitable for all income levels throughout all areas of Carmel-by-the-Sea, while also serving existing vulnerable populations such as lower income households and cost burdened renters.

A.8 Fair Housing Recommendations
Contributing Factors and Fair Housing Action Plan
The disparities in housing choice and access to opportunity discussed above stem from historical actions, socioeconomic factors that limit employment and income growth, barriers to open housing choice, and until recently, very limited resources to respond to needs.

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Appendix A – Housing Needs and Fair Housing Report A-101 Carmel-by-the-Sea 6th Cycle Housing Element Amendment July 7, 2026 Local Knowledge of Contributing Factors to Fair Housing To better inform this Housing Element to meet the needs of residents of Carmel-by-the-Sea, the City solicited the input of the public with prompted questions. All responses were taken into consideration for incorporation into the Housing Element to guide policies and programs that address the housing needs of existing and future residents.

Question: How can the supply of affordable housing be increased to meet the needs of our community?
Community members offered the following solutions:
 Encourage ADUs;
 Encourage second-story additions to single-story buildings downtown specifically for affordable housing;
 Change the zoning code to allow 3-story buildings downtown specifically for affordable housing;
 Set a maximum square footage limit on housing units in downtown to spur the creation of more small units rather than just a few large units;
 Create objective (yes/no checklist-style) design standards for new housing projects that include affordable units;
 Less short-term rental places, more long-term rental options;  Build housing on the outskirts and empty parking lots;  Annex land outside City for affordable housing; and
 Continue to ensure the built environment is subordinate to the natural environment.

Question: In your experience in Carmel-by-the-Sea, what has contributed to the fair housing issues? What solutions do you envision to address these issues?  Information about affordable units.
 Down payment assistance.
 Tenant assistance resources.

Priority of Contributing Factors
The City of Carmel-by-the-Sea has prioritized the following contributing factors to the Fair Housing issues mentioned above. Table A-32 presents prioritized fair housing issues and contributing factors, as well as the City’s programs to support a solution-oriented approach to affirmatively furthering fair housing.

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Appendix A – Housing Needs and Fair Housing Report A-102 Carmel-by-the-Sea 6th Cycle Housing Element Amendment July 7, 2026 Table A-32 Fair Housing Issues, Contributing Factors, and AFFH Programmatic Actions Fair Housing Issue Contributing Factor(s) AFFH Programmatic Action Priority Household Characteristics
Carmel-by-the-Sea has significantly lower
proportions of racial and ethnic minorities
compared to Monterey County and the
AMBAG region. Lack of inclusionary
housing may contribute to the lack of
protected classes in the community.
• Lack of racial and ethnic diversity within the City;
and
• Lack of adequate affordable housing options.

Program 1.1.B: Development on Small Sites
Program 1.1.C: Live/Work Housing

1.1.D: Mixed-Income Incentive Program
Program 2.1.A: Incentives for Mixed-Use
Development
Program 3.1.C: Density Bonus
Program 3.1.D: Reduced Entitlement and
Development Fees
High
Disproportionate Housing Needs
Forty-six (46) percent of Carmel-by-the-Sea
households are cost burdened households,
of which 24 percent are renter-occupied
households and 23 percent are owneroccupied.
• Lack of affordable housing;
• Lack of adequate housing stock that meets the needs
of residents; and
• Jobs-worker imbalance.

Program 1.1.B: Development on Small Sites
Program 1.1.E: Affordable Housing on Religious
Facility Properties
Program 1.1.F: Hotel-to-Residential Conversion
(Home ‘Key’ Transfer)
Program 1.1.G: Hotel Employee Housing Program
Program 1.1.H: Accessory Dwelling Units
Program 3.1.B: Housing for Extremely-Low Income
Households
Program 1.3.B: Employee Housing
Program 2.4.A: Housing Rehabilitation and
Maintenance Information
Program 3.1.C: Density Bonus
High
Special Needs Groups
In Carmel-by-the-Sea, extremely low-income
and special needs groups
experience disproportionate impacts of
poverty, increasing the challenge of
obtaining adequate housing in the City.
• Lack of affordable housing;
• Jobs-worker imbalance;
• Lack of accessible units for individuals with disabilities; and
• Lack of Transitional and Supportive
Housing/Emergency Shelters.

Program 1.3.E: Emergency Shelters
Program 3.1.B: Housing for Extremely-Low
Income Households
Program 3.2.A: Reasonable Accommodation
Procedures
Program 3.2.C: Family Friendly Housing
Program 3.3.A: Zoning for Transitional and
Supportive Housing
Program 3.3.B: Low-Barrier Navigation Centers
Program 3.3.C: Unlicensed Residential Care
Facilities
Program 3.3.D: Single Room Occupancy (SRO)
Units
Program 5.1.D: Farmworker Housing
High

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Appendix A – Housing Needs and Fair Housing Report A-103 Carmel-by-the-Sea 6th Cycle Housing Element Amendment July 7, 2026 Fair Housing Issue Contributing Factor(s) AFFH Programmatic Action Priority Housing Stock
Carmel-by-the-Sea’s lack of affordable
housing production, limited variety of
housing types, and increasing housing costs
create barriers to enter the local housing
market.
• Since 2015, there have been 18 housing permits in
the City for only above moderate-income households;
and
• Lack of developable land, and the City is subject to
coastal zone ordinances.

Program 1.1.B: Development on Small Sites
Program 1.1.E: Affordable Housing on Religious
Facility Properties
Program 1.1.F: Hotel-to-Residential Conversion
(Home ‘Key’ Transfer)
Program 1.1.G: Hotel Employee Housing Program
Program 1.1.H: Accessory Dwelling Units
Program 1.4.A: Modify or Eliminate Onerous Use
Permits
Program 1.4.B: Objective Design Standards
Program 1.4.C: By-Right Approval
Program 2.1.B: Permanent Housing
Program 2.3.A: Preserve and Increase Upper Floor
Residential Uses
Program 3.1.E: Reduced Parking Requirements
Program 3.1.F: Expedited Processing Procedures
Program 3.1.G: Establish Minimum Densities
High
Access to Opportunity
Low production of affordable housing in
Carmel-by-the-Sea limits housing choices
for low-income households, and has a
disproportionate impact on Hispanic or
Latino, Asian, and Black/African American
households.
• Of the 18 housing permits issued in Carmel-by-theSea since 2015, zero were issued for lower-income households (lack of affordable housing); and
• Costs of land,materials, and labor which limit
profitability of affordable housing.

Program 1.1.C: Live/Work Housing
Program 1.1.G: Hotel Employee Housing Program
Program 1.2.A: Water Distribution Prioritization for
Affordable Housing
Program 1.3.A: Condominium Conversions
Program 1.3.B: Employee Housing
Program 2.1.D: Establish Affordable Housing Trust
Fund
Program 3.1.A: Mixed-Use Affordable Housing
Program 3.1.C: Density Bonus
Program 3.2.B: Housing Mobility
Program 4.1.A: Water Conservation
High
Fair Housing Enforcement
No residents filed fair housing complaints in
Carmel-by-the-Sea, indicating a lack of
cause for complaint, or, alternatively, a
potential lack of awareness about fair
housing rights.
• Lack of access to information about fair housing
rights; and
• Limited knowledge of fair housing by residents.

Program 2.1.C:Monitor Affordable Housing Stock
Program 5.1.A: Fair Housing Services
Program 5.1.B: Housing Choice Voucher Program
Program 5.2.A: Support Community Organizations
Medium
Source: City of Carmel-by-the-Sea; EMC Planning Group

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Appendix A – Housing Needs and Fair Housing Report A-104 Carmel-by-the-Sea 6th Cycle Housing Element Amendment July 7, 2026 A.9 Conclusion
To address the fair housing issues identified in this Housing Needs and Fair Housing report, the programs listed in the above section are included in Chapter 2 of this Housing Element.

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Housing Constraints

APPENDIX B

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Appendix B – Housing Constraints B-ii
Carmel-by-the-Sea 6th Cycle Housing Element Amendment July 7, 2026 Table of Contents
Appendix B Housing Constraints.......................................................................................................................................B-1 B.1 Introduction ............................................................................................................................................................B-1 B.2 GovernmentalConstraints....................................................................................................................................B-1 B.3 Non-Governmental Constraints........................................................................................................................B-57 Tables
Table B-1 - Residential Land Use Designations ..............................................................................................................B-3 Table B-2 - Residential Uses Permitted by Zone.............................................................................................................B-6 Table B-3 - Residential Development Standards...........................................................................................................B-12 Table B-4 - R-1 District Base Floor Area and Bonus Floor Area Standards for Typical Lots..............................B-13 Table B-5 - Maximum Density Standards.......................................................................................................................B-15 Table B-6 - Maximum Height Standards........................................................................................................................B-16 Table B-7 - Minimum Off-Street Parking Requirements.............................................................................................B-19 Table B-8 - Summary of Community Planning & Building Fees (2023-2024).........................................................B-41 Table B-9 - Jurisdictional Comparison of Average Design Review/Study Fees......................................................B-44 Table B-10 - Estimate of Total Development Fees Imposed .....................................................................................B-45 Table B-11 - Review/Approval Requirements and Processing Times.......................................................................B-49 Table B-12 - Permit Streamlining Act Processing Times.............................................................................................B-50 Table B-13 - Summary of Governmental Constraints..................................................................................................B-56 Table B-14 - Summary of Non-Governmental Constraints........................................................................................B-66

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Appendix B – Housing Constraints B-1
Carmel-by-the-Sea 6th Cycle Housing Element Amendment July 7, 2026 Appendix B
Housing Constraints
B.1 Introduction
Housing development is affected by public regulations and other forces. This chapter discusses both governmental and non-governmental constraints that affect housing in the City of Carmel-by-the- Sea.

Governmental constraints consist of policies, requirements, or other actions imposed by various levels of government on land, housing ownership, and development. In addition to local standards, the City follows building and design requirements put forth by state laws, the California Building Code, Subdivision Map Act, energy conservation requirements, as well as other regulatory standards.

However, Federal and State agency regulations that may constrain development are beyond the City’s control and are therefore not addressed in this document. Non-governmental constraints are other conditions that impact housing development such as market factors, environmental setting, land availability, and construction costs.

B.2 Governmental Constraints
Governmental constraints are policies, standards, requirements, or actions imposed by the various levels of government upon land, housing ownership and development. Although Federal and State agencies play a role in the imposition of governmental constraints, these agencies are beyond the influence of local government and are therefore not addressed in this document. As appropriate, the City will monitor federal and state legislation that impacts housing. The City will update its Municipal Code, as needed to comply with any new housing related planning or zoning laws enacted by the State during the 6th Cycle Planning Period (2023-2031).

Infrastructure Constraints
Water Supply
The primary infrastructure constraint to the development of housing in Carmel is the lack of potable water. The lack of a reliable available water supply continues to limit growth in Carmel and throughout the Monterey Peninsula region.

Carmel is under the jurisdiction of the Monterey Peninsula Water Management District (MPWMD) and receives its water from the California-American Water Company (Cal-Am). The MPWMD has permit authority over the production and distribution of all water supplies within the Monterey Peninsula region, and allocates water supplies to cities and unincorporated County areas within its jurisdiction.

Water service by Cal-Am is constrained by State Water Resources Control Board (SWRCB) Order WR 95-10,1 which determined that in 1995 approximately 70 percent of Cal-Am supply was based on 1 See Order No. WR 95-10,
https://www.waterboards.ca.gov/waterrights/board_decisions/adopted_orders/orders/1995/wro95-10.pdf

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Appendix B – Housing Constraints B-2
Carmel-by-the-Sea 6th Cycle Housing Element Amendment July 7, 2026 unlawful diversion from the Carmel River. Order 95-10 requires that any new water supply be used to reduce diversions from the Carmel River prior to allowing new users.

Furthermore, SWRCB issued a Cease-and-Desist order to Cal-Am in 20082 to further restrict water use which limits the placement of new water meters to service new development.

According to the MPWMD June 1, 2023 Technical Memorandum – Summary of Water Supply Requirements for Housing, the City requires 40 acre-feet (AF) to meet the City’s RHNA (349 units).

The City has approximately 16.661 acre-feet of available water3 for general distribution which represents a water deficit of approximately 23.364 AF. There is also Malpaso Water Company water entitled to certain limited properties whose owners were previously able to purchase water directly from the Water Company.4 The Sites Inventory clearly identifies whether water is a constraint for each identified property. This is the only water available to the City until the District supplies increase and new allocations are made to each city in the District. Based on current supplies, sufficient water is not widely available to fully accommodate additional development commensurate with the City’s total RHNA. The City will continue to work with local and regional agencies to explore options for additional water supplies during the 6th Cycle Housing Element planning period.

The 6th Cycle Housing Element includes a program (program 1.2.A) to work with local and regional agencies to pursue new water supplies and includes prioritizing allocation of the City’s 16.661 acre-feet of water for affordable housing through the development of a water distribution policy. The City is currently working with the MPWMD to utilize water-saving fixtures for every building permit application, which helps to minimize water usage and thereby conserve water for future allocation in new developments. The City of Carmel is also supportive of Pure Water Monterey’s and Cal-Am’s efforts to provide additional water for new units and promote desalination.

Wastewater
The Carmel Area Wastewater District (CAWD) collects and conveys wastewater from a business or residence to the wastewater treatment plant using underground pipes and lift stations. The CAWD collection system is comprised of approximately 81 miles of gravity sewers ranging in size from 6 inches to 27 inches in diameter together with nearly 4 miles of force mains, 7 pump stations, and over 1,500 manholes.

Two trunk sewers serve the City of Carmel and the Hatton Fields areas. Within the City of Carmel-bythe-Sea pump stations are located at 1) the westerly terminus of 8th Avenue (at Scenic Drive), 2) the intersection of Monte Verde Street and Sixteenth Avenue, 3) west side of Scenic Road approximately 2 See Order WR 2009-0060,
https://www.waterboards.ca.gov/waterrights/board_decisions/adopted_orders/orders/2009/wro2009_0060.pdf 3 See September 2025 MPWMD Monthly Allocation Report
www.mpwmd.net/asd/board/boardpacket/2025/10202025/19/Item-19-Exh-19-A.pdf 4 See September 2025 MPWMD Monthly Allocation Report – Entitlements - www.mpwmd.net/asd/board/boardpacket/2025/10202025/19/Item-19-Exh-19-B.pdf

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Appendix B – Housing Constraints B-3
Carmel-by-the-Sea 6th Cycle Housing Element Amendment July 7, 2026 200 feet south of Ocean View Avenue All pump stations have been upgraded to allow remote monitoring and have capabilities for standby power and emergency bypass.

The District’s permitted capacity is 3.0 million gallons per day (MGD), and their current average daily dry weather flow is approximately 1.2 to 1.3 MGD.

The City is required to plan for an additional 349 residential housing units in this planning cycle. Based on capacity and communication with the District, the CAWD has adequate treatment capacity to serve these units.5
General Plan and Land Use Controls
Each city and county in California must prepare a comprehensive, long-term General Plan to guide its future. The Land Use Element of the General Plan establishes the basic land uses and density of development within each jurisdiction. Under state law, the General Plan elements must be internally consistent, and each jurisdiction’s zoning must be consistent with its General Plan. Thus, the Land Use Element must provide suitable locations and densities to implement the policies of the Housing Element.

The City’s development policies, standards and requirements were established with the intent of maintaining the long-term health, safety, and welfare of the community. To achieve this, the City has implemented a range of procedures, regulations and fees associated with all local development. Specific land use and development constraints, such as zoning regulations, governmental fees, building code standards, design review, and processing and permitting time can greatly influence the type and cost of construction that occurs.

The City of Carmel-by-the-Sea General Plan/Coastal Land Use Plan (General Plan) was adopted in 2003 and most recently amended in 2015. The General Plan Land Use Element identifies land use designations and development intensities for all land within City boundaries. Land Use designations include Core Commercial, Residential/Commercial, Multi-Family Residential, Single Family Residential, and Open Space/Recreation/Cultural. The Residential/Commercial land use designation encourages mixed use buildings and is intended to provide for a mix of residential dwellings and a limited range of office and service uses in scale with the character of the community. Table B-1, Residential Land Use Designations, identifies the residential land use designations and their maximum permitted densities.

Table B-1 Residential Land Use Designations
Designation Maximum Density
Single-Family Residential 11 du/acre
Multi-Family Residential 33 du/acre, 44 du/acre (with affordable housing) Commercial/Residential 33 du/acre
Core Commercial 33 du/acre
Source: Carmel-by-the-Sea 2003 General Plan
5 May 17, 2023 email correspondence with CAWD

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Appendix B – Housing Constraints B-4
Carmel-by-the-Sea 6th Cycle Housing Element Amendment July 7, 2026 The range of residential densities provided by Carmel-by-the-Sea’s General Plan is sufficient to accommodate a range of housing types and affordability levels. It does not, therefore, pose an undue governmental constraint on the development of housing for the community.

Local Coastal Program and Coastal Land Use Plan
The California Coastal Act was established to balance landowners’ rights to develop and the public’s right to enjoy the coastline. This resulted in an area defined as the Coastal Zone which is regulated to ensure orderly, long-range conservation, use, and management of the natural, scenic, cultural, recreational, and manmade resources of the coast. All of the Carmel-by-the-Sea is located within the Coastal Zone, which in this area extends from the coast of Carmel Bay east to California State Highway 1.

Carmel-by-the-Sea’s Local Coastal Program (LCP) was certified by the Coastal Commission in 2004, enabling the City to issue Coastal Development Permits (CDPs). This gives the City authority over local development applications, with appeal oversight maintained by the Coastal Commission in limited areas of the City identified on the Carmel Zoning Map as the Beach & Riparian Overlay/Coastal Commission Appeal Jurisdiction. Land uses within the appeal jurisdiction are limited to single-family residential and open space. The Commission also retains permanent coastal permit jurisdiction over development proposed on tidelands, submerged lands, and public trust lands.

The LCP includes the following General Plan Elements: Land Use, Circulation, Coastal Access and Recreation, and Coastal Resource Management; the Zoning Ordinance (Implementation Plan); and, Appendices A through I of the General Plan and Zoning Ordinance.

The presence of land use regulation via the LCP, in general, means that housing development in Carmel-by-the-Sea faces a high bar to succeed. Most recent remedies brought forward by the California legislature to facilitate housing development are either outright inapplicable in the Coastal Zone or are secondary to California Coastal Commission policies that protect habitat resources (SB 9).

Zoning Code
The City of Carmel-by-the-Sea Zoning Code (City Municipal Code Title 17, Chapter 17.08- Residential Zoning Districts) establishes regulatory standards that dictate the type, location, density, and scale of residential development within the City’s boundaries. Essentially, all zoning districts allow residential development. Below are the two primary zoning districts within the city that allow for residential uses:
 R-1 Single-Family Residential District; and
 R-4 Multifamily Residential District

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Appendix B – Housing Constraints B-5
Carmel-by-the-Sea 6th Cycle Housing Element Amendment July 7, 2026 In addition, the following zoning districts provide for some residential uses above commercial uses or on ground floor after review and approval of a conditional use permit.  SC Service Commercial;
 CC Central Commercial District; and
 RC Residential and Limited Commercial
The following public and quasi-public zoning districts also permit limited residential uses:
 P-2 Improved Parklands (Park and Recreation District);  A-2 Community and Cultural (Other Public District); and  A-3 Senior Citizen Facility (Other Public District).

The City of Carmel-by-the-Sea Municipal Code (CMC) provides zoning regulations that are more specific than the General Plan Land Use designations. The R-1 (Single-Family Residential) district provides an appropriate land area for permanent single-family residential uses and structures and to enhance and maintain the residential character of the City. The R-4 (Multifamily Residential) district is intended to serve two purposes: 1) to provide an appropriate location for a mix of multifamily residential dwelling units convenient to the commercial area; and 2) to serve as a buffer or transitional zone between the commercial area and the single-family residential district.

Commercial zoning districts that permit residential uses include:
 The Central Commercial (CC) District, which is intended to provide an appropriate location for a broad range of retail, residential and service uses. Uses which generate high pedestrian traffic and which do not have large space requirements are appropriate in this district.

Residential uses are appropriate on the second floor of structures.  The Service Commercial (SC) District, which is intended to provide an appropriate location for services, offices, residential and limited retail activities that primarily serve local needs.

This district is intended to provide a distinct transition between the more intense activities in the CC district and the less intense activities in the districts on its periphery. Mixed uses of commercial and residential activities are appropriate throughout this district.  The Residential and Limited Commercial (RC) District seeks to provide an appropriate location for permanent and transient residential uses, service and office uses, and limited retail uses that do not adversely impact the residential neighborhood. This district is intended to provide a transition and buffer between the more intense activities in the CC and SC districts and the less intense activities in the R-1 and R-4 districts.

To encourage the development of multi-family residential development, the City has included Program

3.1.G, which includes an amendment to the Municipal Code to restrict new single-family development in the R-4, CC, RC, and SC Districts (see Chapter 2). Existing single-family dwellings in these districts will be considered legal nonconforming uses.

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Appendix B – Housing Constraints B-6
Carmel-by-the-Sea 6th Cycle Housing Element Amendment July 7, 2026 Certain public and quasi-public zoning districts also permit limited residential uses. The Park and Recreation (P-2) District permits single-family, senior citizen housing, and family day care uses which are limited to the use and maintenance of existing buildings for nonprofit organizations, governmental buildings and uses, and residential use. Sites located in the Community and Cultural Center (A-2) District and Senior Citizen Facility (A-3) District permit senior citizen housing outright.

Table B-2, Residential Uses Permitted by Zone, shows residential uses, the zoning districts in which they are permitted, and whether they are permitted by-right (without discretionary action) or with a conditional use permit (CUP). The City’s Municipal Code is available online:
(https://www.codepublishing.com/CA/CarmelbytheSea/).

Table B-2 Residential Uses Permitted by Zone
Residential Use
Residential
Zoning Districts Commercial Zoning Districts
Public and Quasi-Public
Districts (Park and Recreation
& Other Public Districts)
R-1 R-4 CC SC RC P-2 A-2 A-3
Single-Family P P C-L-5 C C P-L-1 - -
Accessory Dwelling Units
Accessory Dwelling Unit (Interior) P P –- –- –- –- –- –- Accessory Dwelling Unit (New Structure) P P –- –- –- –- –- –- Class I Accessory Dwelling Unit P – –- –- –- –- –- –-
Class II Accessory Dwelling Unit P – –- –- –- –- –- –-
Studio P P –- –- –- –- –- –-
Guesthouse (Noncommercial) C – –- –- –- –- –- –-
Multifamily Dwellings
0-22 dwelling units/acre – P P P P – – –
22 dwelling units/acre – C – – –
23-33 dwelling units/acre – C C C C – – –
34-44 dwelling units/acre – C C C C – – –
45-88 dwelling units/acre – - C C C – – –
Senior Citizen Housing R-L-5 P P P P P-L-1 P P

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Appendix B – Housing Constraints B-7
Carmel-by-the-Sea 6th Cycle Housing Element Amendment July 7, 2026 Residential Use
Residential
Zoning Districts Commercial Zoning Districts
Public and Quasi-Public
Districts (Park and Recreation
& Other Public Districts)
R-1 R-4 CC SC RC P-2 A-2 A-3
Family Day Care
Small Family R-L-5 P – – P P-L-1 – –
Large Family – C-4 – C C P-L-1 – –
Group Residential – C – – – – – –
Transient Rental, Legal Nonconforming – R-L-6 C-L-7 C-L-7 C-L-7 –- – – Transient Rental, Housing Incentive – R-L-7 C-L-8 C-L-8 C-L-8 -– –- – Source: CMC Title 17 Zoning 2023
Key:
(P) permitted use classifications.
(L) use classifications that are permitted, subject to certain specific limitations noted by the number designations and listed at the end of Schedule II-1 (CMC Section 17.08.040) and Schedule II-B (CMC Section 17.14.030). (C) use classifications permitted after review and approval of a conditional use permit by the Planning Commission. Conditions or standards may apply to these uses, noted by the number designations and listed at the end of Schedule II-1. (–) prohibited
Residential Districts Specific Limitations and Conditions R-L-1 Limited to advertising, consumer credit reporting, secretarial and court reporting, equipment maintenance and repair, personnel supply services, and nonretail computer services and repair.

R-L-2 Allowed only on existing quasi-public use sites established prior to December 1, 1980, or added as an accessory use to such existing uses.

R-L-3 Limited to existing units established prior to January 1, 1967, and/or authorized by a use permit issued between 1967 and 1990. *Note: These provisions approved by voter referendum.

R-L-4 Limited to existing commercial spaces established prior to 1993 and occupied by commercial uses continuously since that time.

R-L-5 Limited to occupancy within a single-family residence.

R-L-6 Limited to permits approved prior to the adoption of Ordinance 2019-03.

R-L-7 Limited to transient rental units approved through the issuance of a conditional use permit as an incentive for the creation of new housing units. See CMC 17.14.040(W)(2)(b).

Commercial Districts Specific Limitations and Conditions C-L-1 Limited to advertising, consumer credit reporting, secretarial court reporting, equipment maintenance and repair, personnel supply services, and nonretail computer services and repair. C-L-2. Allowed only as accessory use to gasoline stations and limited to a maximum of 300 square feet. No sales of alcohol are permitted. See CMC 17.14.040(D)(2) and (J)(2).

C-L-3 Any establishments with activities generating noise, odors, deliveries by large vehicles, high traffic by customers, or requiring large storage needs are not permitted.

C-L-4 Limited to offices for the following categories: operators of nonresidential buildings, apartment buildings, dwellings, real estate agents and managers, and title companies.

C-L-5 Limited to sites that are already developed with a single-family dwelling, or that were originally developed as, or used as, a singlefamily dwelling but have since been converted to another use. Existing single-family dwellings can be maintained, altered, repaired and/or redeveloped. R-1 district floor area ratio standards shall apply to these sites.

C-L-6 Subject to the same regulations as apply to other family residential dwellings in the same zone. C-L-7. Limited to permits approved prior to the adoption of Ordinance 2019-03.

C-L-8 Limited to transient rental units approved through the issuance of a conditional use permit as an incentive for the creation of new housing units. See CMC 17.14.040(W)(2)(b). Public and Quasi-Public Districts Specific Limitations and Conditions P-L-1 Limited to the use and maintenance of existing buildings for nonprofit organizations, governmental buildings and uses, and residential use. P-L-2: Limited to facilities serving only park visitors and/or tenants of park buildings.

P-L-3 Limited to schools for theater arts.

P-L-4 Limited to workshops and classes connected with the arts.

P-L-5 Only as an accessory use, when in connection with any other authorized use.

Use Permits
The use permit (UP) (or conditional use permit (CUP)) requirement is implemented as an additional regulatory tool and adds extra regulations, review, and required findings, to a variety of development standards that affect multi-family development. The UP requirement for residential developments between 23 and 33 du/acre does not have specific findings creating uncertainty for developers of

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Appendix B – Housing Constraints B-8
Carmel-by-the-Sea 6th Cycle Housing Element Amendment July 7, 2026 housing projects. Densities between 34 and 44 du/acre also require a UP and special findings are outlined in Municipal Code Section 17.64.190 (Residential Construction at Densities Between 33 and 44 Units Per Acre). Because the City does not have an inclusionary zoning ordinance, the UP findings are used as a tool to require affordable housing within this density range. For example, in the R-4 District, residential projects with densities between 33 and 44 du/acre must provide at least 20 percent of all units for lower-income households, 10 percent of all units for very low-income households, or 50 percent of all units for senior housing. In the CC, SC, and RC Districts, residential projects with densities between 33 and 44 du/acre are eligible for State Density Bonus Law as set forth in Government Code Section 65915 et seq.

Residential projects with densities between 45 and 88 du/acre are also subject to a UP and special findings that require the project to be 100 percent affordable to lower-income households.

Municipal Code Section 17.14.150 Building Height requires a use permit for additional underground floors used for parking vehicles, storage and mechanical equipment. The additional use permit requirement can affect how much parking can be accommodated which limits the number of units, particularly for smaller projects, and affects the financial feasibility of the proposed development.

There are opportunities to reduce redundancies and facilitate residential construction while still enabling development to meet City regulations. Taking an overall critical look at the application of use permits and removing this permit requirement where it does not add any necessary regulations related to safety and welfare will remove a regulatory constraint that adds to residential developer uncertainty, extends the permit entitlement process, and overall residential development costs. The 6th Cycle Housing Element includes a program to eliminate unnecessary use permits.

Commercial Overnight Visitor Accommodation
Pursuant to Coastal Zone requirements, the City has recognized existing overnight visitor accommodation (hotel/motel/inn) as an important coastal visitor asset and economic base in the community. There are a number of older (some non-conforming) hotels/motels/inns in the R-1, CC, RC, and SC zoning districts, located in key areas of the City. These commercial establishments can be targeted for transition and the existing buildings rehabilitated converted to permanent multi- family residences.

In an effort to maintain a strong residential component within the City, the Municipal Code Section

17.56.060 includes numerical limits on the total number of hotel/motel/inn units; however, the numerical limits increase the value of the existing commercial units and act as a disincentive for older establishments to be refurbished into multi-family units. The limit also acts as a disincentive to add onsite employee housing because scarce square footage is more valuable as an overnight visitor accommodation use rather than a residential use that serves lower-income employees.

Enabling older overnight visitor accommodation commercial uses to relocate to more appropriate commercial sites while allowing the establishments to retain the current number of hotel/motel/inn rooms, would facilitate continued overnight tourism while diversifying the housing stock by requiring

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Appendix B – Housing Constraints B-9
Carmel-by-the-Sea 6th Cycle Housing Element Amendment July 7, 2026 the refurbishment of existing buildings to permanent rental housing. In order to encourage these properties to transition into permanent multi-family residences, and to retain the same number of existing overnight visitor accommodation rooms for coastal visitor access (as desired by the California Coastal Commission), the City will develop Program 1.1.F to incentivize both the transfer of development rights of overnight visitor accommodations to other appropriate commercial sites while requiring the conversion of existing overnight visitor accommodation properties to permanent rental multi-family residences.

Additionally, the City has several overnight visitor accommodation properties that would greatly benefit from incorporating affordable on-site employee housing. These new rental permanent residential units would alleviate the current lack of housing options that many lower-income employees who work at hotels/motels/inns in Carmel face. As an incentive to commercial overnight visitor accommodation property owners to provide on-site affordable employee housing, the City will offer an additional overnight accommodation room for every on-site housing unit created. This incentive will serve to increase affordable rental housing, offset the loss of revenues for the business owners, and maintain visitor-serving coastal access.

Overlay Zoning Districts
Overlay districts are zoning districts established by the City to carry out specific purposes. They are governed by a set of regulations that address specific subjects such as archaeologically significant resources or environmentally sensitive habitat areas. The City currently has overlay districts that address the following:
 Archeological significance;
 Parks;
 Beach and Riparian areas;
 Environmentally Sensitive Habitats;
 Annexed County Lots; and
 Downtown Conservation District.

Overlay districts can be constraints to development, or they can be used as a tool to encourage certain types of development. The existing overlays do not function as constraints to development.

Development Standards
With the exception of building heights, development standards in Carmel-by-the-Sea are typical for a small residential community. As for building heights, the City limits building heights to two stories above ground and 30 feet or less, which can render higher allowable densities (up to 44 du/ac with affordable housing) unachievable.

The City has discussed the possibility of increasing height limits, but community resistance to increasing the height limit has been consistent and is primarily based on a desire to protect the historic character of the downtown. Some community members have suggested allowing mezzanines as a third interior

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Appendix B – Housing Constraints B-10
Carmel-by-the-Sea 6th Cycle Housing Element Amendment July 7, 2026 story, if it could be accomplished without appearing as a three-story building. The Zoning Code permits multi-family dwellings in all commercial districts and existing underutilized commercial spaces can be repurposed for residential uses.

Table B-3, Residential Development Standards, summarizes residential development standards in Carmel-by-the-Sea.

Density, Building Intensity, and Height
Density, building intensity or floor area ratio (FAR), and building height are established in the Land Use Element and implemented by the Municipal Code. The following details allowed densities, building intensity, and heights in all residential districts (R-1, R-4, CC, SC, and RC).

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Appendix B – Housing Constraints B-12
Carmel-by-the-Sea 6th Cycle Housing Element Amendment July 7, 2026 Table B-3 Residential Development Standards
Zoning
Minimum
Lot Area (sq
ft)
Setbacks
Maximum
Height1,2,3
Maximum
Floor Area
(sq ft)
Maximum Lot
Coverage or Density
(R-4)
Front
(in feet)
Minimum Side
Yard
(in feet) Rear
Residential Districts
R-1 2,5001
4,000
15 Interior Street
Side
15 24 feet
2 stories
Less than 45
percent of
the area of
the building
site2
2,4003
22% of the base floor
area
3 5
R-4 4,000 No setback.
5 – if across from
R-4, RC;

7.5 across from R-1
No
setback4,5
N/A No setback.
10 – if
abutting R1 or R-4
26 feet
2 stories
N/A 33 units/acre
44 units/acre with
density bonus
Commercial Districts
CC N/A No setback.
5 – if across from
R-4, RC;

7.5 across from R-1
No
setback4
N/A No setback
10 – if
abutting
R-1 or R-4
30 feet
2 stories
N/A1 One story – 95% of the
site area
Two story – 135% of the
site area 150% with 15%
bonus
SC N/A No setback.
5 – if across from
R-4, RC;

7.5 across from R-1
No
setback4
N/A No setback
10 – if
abutting
R-1 or R-4
30 feet
2 stories
N/A One story – 95% of the
site area
Two story – 135% of the
site area 150% with 15%
bonus
RC N/A No setback.
5 – if across from
R-4, RC;

7.5 across from R-1
No
setback4
N/A No setback
10 – if
abutting
R-1 or R-4
26 feet
2 stories
N/A One story – 70% of the
site area
Two story – 80% of the
site area 95% with 15%
bonus
Source: CMC Title 17 2023

1. Lots of record in existence on February 4, 1948.

2. Applies to sites less than 4,000 square feet.

3. The maximum potential floor area on a site is the sum of the base floor area plus any bonus floor area. The City uses a sliding scale to determine maximum floor area and site coverage.

4. If abutting R-4 or RC district a side yard setback of at least 5 feet along at least 50 percent of each side property line. The remaining 50 percent requires no setback unless the faces a public street. Any site abutting R-1 district requires a setback of five feet along entire side yard.

5. Buildings shall not be less than six feet from any other buildings on the same site.

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Appendix B – Housing Constraints B-13
Carmel-by-the-Sea 6th Cycle Housing Element Amendment July 7, 2026 Floor Area Ratio
Floor Area Ratio (FAR) expresses the ratio of building square footage to land square footage and allows for flexibility in design as long as other development standards (such as height and setbacks) are compliant. The following are floor area ratio standards according to square footage in the R-1 District.  On sites less than 4,000 square feet, the maximum base floor area cannot exceed 45 percent of the area of the building site;
 On sites between 4,000 and 10,000 square feet, the base floor area is restricted to less than 45 percent of the area of the building site. The following formula applies to calculate the exact allowed base floor area: Building Site Area (0.45 – ((Sq. Ft. Over 4,000) (0.02))/1,000; and  On sites larger than 10,000 square feet, the base floor area is as stated in Table B-4. The maximum allowed floor area on any building site 22,000 square feet or larger cannot exceed 6,000 square feet.

Table B-4 R-1 District Base Floor Area and Bonus Floor Area Standards for Typical Lots Site Area
(Square Feet)
Base Floor Area
(Square Feet)
Maximum Bonus Floor Area
(Square Feet)
Maximum Total Floor Area*
(Square Feet)
4,000 1,800 600 2,400
5,000 2,150 717 2,867
6,000 2,460 820 3,280
7,000 2,730 910 3,640
8,000 2,960 987 3,947
9,000 3,150 1,050 4,200
10,000 3,300 1,100 4,400
11,000 3,450 1,150 4,600
12,000 3,600 1,200 4,800
13,000 3,735 1,245 4,980
14,000 3,870 1,290 4,160
15,000 4,005 1,335 5,340
16,000 4,140 1,380 5,520
17,000 4,255 1,418 5,673
18,000 4,370 1,457 5,827
19,000 4,485 1,495 5,980
Source: City of Carmel-by-the-Sea Municipal Code Title 17 Notes *The “maximum total floor area” equals the base floor area plus the bonus floor area. The numbers in this column would require half of the total floor area to be located in a basement.

In an effort to maximize development of parcels zoned for R-4 uses, the City does not apply FAR as a restriction. Additionally, to encourage the development of multi-family rental units, sites of 4,000 square feet or less in area may be developed with apartments, condominiums, or a combination of both. On sites that are greater than 4,000 square feet or more in size, at least 50 percent of all residential units on the site must be provided as rental apartment units. This encourages the development of rental units and does not pose a constraint to multi-family rental housing.

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Appendix B – Housing Constraints B-14
Carmel-by-the-Sea 6th Cycle Housing Element Amendment July 7, 2026 In the Commercial Districts, the maximum floor area ratio is 10,000 square feet. The following are floor area ratio standards according to square footage in the Commercial Districts.  CC and SC Districts: the basic floor area ratio allowed for one-story buildings is 95 percent of the site area and for two-story buildings is 135 percent of the site area. In addition to the basic floor area ratio, two-story buildings may qualify for a maximum 15 percent bonus, which allows a floor area ratio up to 150 percent of the site area.  RC District: the basic floor area ratio allowed for one-story buildings is 70 percent of the site area and for two-story buildings is 80 percent. In addition to the base floor area ratio, two story buildings may qualify for a bonus of up to 15 percent, which allows a floor area ratio up to 95 percent of the site area.

Additionally, the City allows a floor area bonus for affordable housing projects in all commercial districts and the R-4 District as follows:

A. Moderate Income. Up to five percent for projects if at least 25 percent of the units in a housing project are reserved for persons of moderate income as defined in Chapter 17.70 CMC;
B. Low Income. Up to 10 percent for projects if at least 20 percent of the units in a housing project are reserved for persons of low income as defined in Chapter 17.70 CMC; or C. Very Low Income. Up to 15 percent for projects if at least 10 percent of the units in a housing project are reserved for persons of very low income as defined in Chapter 17.70 CMC.

The City has utilized FAR to restrict the allowed building size of units as a means to retain a village-like character and as an attempt to yield more affordable residential units. However, despite units being smaller in size, the cost of labor and land value outweighs the potential for affordability.

Restricting the building size also renders larger proportions of lots undevelopable. The City should consider increasing the allowed FAR to increase the developability of land.

Density
As shown in Table B-5, maximum base densities range from 0-22 dwelling units per acre, and when density bonuses are enabled, up to 88 dwelling units per acre. The City’s bonus density and density bonus allow higher densities in the Multi-Family (R-4) and Commercial Districts (CC, SC, and RC).

To enable residential development at higher densities, the City included Program 3.1.G, which establishes a minimum density of 22 dwelling units per acre and a maximum density of 40 units per acre for the R-4, SC, CC, and RC districts. This intention is rooted in facilitating a higher yield of units to enable the development of affordable residential units.

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Appendix B – Housing Constraints B-15
Carmel-by-the-Sea 6th Cycle Housing Element Amendment July 7, 2026 Table B-5 Maximum Density Standards
Permitted Base Zoning Bonus Density Density Bonus
R-1 District 2-11 du/ac - -
R-4 District 0-33 du/ac* (up to 44 du/ac when affordable) Up to 44 du/ac - CC District 0-22 du/ac* (up to 88 du/ac when 100 percent affordable) - Up to 88 du/ac SC District 0-22 du/ac* (up to 88 du/ac when 100 percent affordable) - Up to 88 du/ac RC District 0-22 du/ac* (up to 88 du/ac when 100 percent affordable) - Up to 88 du/ac Source: City of Carmel-by-the-Sea Municipal Code 17.08.040; 17.64.190 Notes: *The City proposes Program 3.1.G to establish a minimum density of 22 dwelling units per acre to enable high densities in the multi-family and commercial districts.

The current maximum density standards for multifamily housing, which is permitted in the R-4, CC, SC, and RC Districts, poses a constraint to the development of affordable rental units due to the limited potential yield of units. This impacts the feasibility of affordable residential projects. To enable the development of affordable residential units at a higher yield, the City proposes to establish a minimum density of 33 dwelling units per acre to the base zoning for the R-4, CC, SC, and RC Districts. This minimum density will eliminate the underutilization of sites, resulting in a higher yield of residential units, which will increase the feasibility to develop affordable units.

Program 3.1.G establishes and monitors the amendment to the Municipal Code to establish the minimum density to the aforementioned districts.

Lot Coverage
As shown above in Table B-5, maximum lot coverage varies according to zoning district. The R-1 District is the most restrictive in lot coverage, allowing a maximum of 22 percent of the base floor area.

The R-4 District does not define lot coverage, rather the City utilizes a maximum density of up to 33 dwelling units per acre, or up to 44 dwelling units per acre when using a density bonus. The CC and SC Districts both allow a maximum lot coverage of 95 percent of the site area for one-story buildings; 135 percent of the site area for two-story buildings; and 150 percent of the site area with a 15 percent bonus.

The RC District allows a maximum lot coverage of 70 percent of the site area for one-story buildings; 80 percent of the site area for two-story buildings; and 95 percent of the site area with a 15 percent bonus.

The City’s development standards for lot coverage in the R-4 District poses a considerable constraint on the development of affordable residential units. However, the City proposes to establish a minimum density of 33 dwelling units per acre for the base zoning, to increase the density and allowed lot coverage on sites. As previously stated, establishing a minimum density will eliminate the underutilization of sites, resulting in a higher yield of residential units, which will increase the feasibility to develop affordable units. Program 3.1.G establishes and monitors the amendment to the Municipal Code to establish the minimum density to the aforementioned Districts.

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Appendix B – Housing Constraints B-16
Carmel-by-the-Sea 6th Cycle Housing Element Amendment July 7, 2026 Height
As shown in Table B-6, maximum base height ranges from 18 to 30 feet and a maximum of two stories are allowed in the City’s residential and commercial districts. Maximum height, coupled with FAR, was specifically determined on a neighborhood basis to character and scale, either to preserve existing lower density neighborhoods or encourage medium-density development, such as in the Commercial District.

Table B-6 Maximum Height Standards
R-1
District
R-1-BR
District
R-1-PO
District
R-4
District RC3 CC3 SC3
Number of stories allowed 2 2 11 22 2 2 2
Roof height of first story (ft) 18 18 18 - - - -
Roof height of second story (ft) 24 18 24* 26 26 30 30
Source: City of Carmel-by-the-Sea Municipal Code Title 17 Notes:

1. See CMC 17.20.100, Required Planning Commission Review, and CMC 17.20.110, Review Criteria

2. Block 37, Lots 3, 5, 7, 8, 9, 10, 11, 12, 13, 14, 15, 16, 17, 18, 20, 21, 22 and 24 within R-4 District require development approval by Planning Commission due to potential effects on significant coastal viewshed (CMC 17.12.050).

3. Building sites which face, abut or adjoin any property in the R-1 district shall be limited to a height of 24 feet (CMC 17.14.150).

The R-1 District permits a maximum height of 24 feet. The R-1 Park Overlay District has specific development standards for two story developments. The Planning Commission must make the following required findings for approval:

1. That due to the topography of the site relative to the adjoining park or open space land, the proposed building would not exceed the height or bulk of an 18-foot one-story structure built on a site at the same grade as the adjoining park or that topography and height are irrelevant because of the location of the building on the site avoids view of the buildings from the park; and

2. That those portions of the building visible from the park will exhibit a human scale and residential character through the use of simple building forms and natural materials that will not detract from the enjoyment of the park or open space by the public.

These required findings have not been a constraint to development within the City.

The R-1 Beach and Riparian Overlay District has the lowest maximum height standard at 18 feet. This Overlay District serves to provide review standards applicable to public and private property development located near public beach lands to ensure proposed development is compatible with the City’s coastal resources and the State’s Coastal Act (CMC 17.20.120).

The R-4 District permits a maximum height of 26 feet. Specific requirements pertaining to viewsheds may apply to new developments in the R-4 District (CMC 17.12.050). This is due to the City’s proximity to the coast and areas designated with significant coastal views. Development approval by the Planning Commission is required if development is located in Block 37, including Lots 3, 5, 7, 8, 9, 10, 11, 12, 13, 14, 15, 16, 17, 18, 20, 21, 22, and 24 (CMC 17.12.050). The review process includes the following finding.

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Appendix B – Housing Constraints B-17
Carmel-by-the-Sea 6th Cycle Housing Element Amendment July 7, 2026  No structure shall be approved for construction and no vegetation shall be planted or maintained within the viewshed at a height that exceeds the 350-foot contour elevation as referenced on the topographic survey dated June 1983 by Clayton B. Neill Jr. (W.O. #6415) (CMC 17.12.050).

The review process and required findings are minimal and developed in accordance with the Local Coastal Program. To ensure height allowance does not impede residential development in the R-4 District in the future, the City should evaluate the impacts of increasing the height allowance.

Currently, the Municipal Code does not pose an undue constraint to the development of multifamily residential units.

The Commercial District (RC, CC, SC) permits a maximum height of 30 feet. All newly constructed second story floor area, including area in new buildings, remodeled buildings and replacement, rebuilt or reconstructed buildings, shall be occupied by residential dwellings only and shall not be used for any commercial land use (CMC 17.14.050F). This requirement for second story development in the Commercial District has resulted in recent residential development and conversations with interested property owners, as many properties within the Commercial District are in need of remodeling.

Therefore, the Municipal Code does not pose an undue constraint on residential development in the Commercial District.

Open Space Courtyards and Intra-Block Walkways
The City’s development standards related to open space courtyards and intra-block walkways have been developed to conserve the City’s unique charm and design character. As a result, the City has established regulatory processes for the construction of new and alterations to existing courtyards and intra-block walkways. Courtyards and intra-block walkways are permitted in the Commercial District (CC, SC, RC).

Courtyards are defined as an open space on private property that is linked to an adjoining sidewalk or walkway in such a manner as to encourage public access. Courtyards are required to be enclosed on at least two sides by buildings and must remain open to the sky. The City allows a floor area bonus for courtyards with a minimum width of 20 feet and a minimum area of 400 square feet.

Intra-block walkways are defined as publicly accessible ground level pedestrian paths providing a connecting route between two or more different streets around a block. The City allows a floor area bonus for intra-block walkways with a minimum width of four feet.

All proposals to alter the size, location or configuration of a courtyard or intra-block walkway require review by the Planning Commission. Generally, such changes are approved only if the Commission finds that the proposed change would be an improvement over existing conditions such as improving public access, allowing for creation of new or better link with courtyards or walkways nearby or eliminating a safety hazard. Existing courtyards and intra-block walkways are not to be removed. This review process includes a single hearing, which can be completed concurrently with design review.

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Appendix B – Housing Constraints B-18
Carmel-by-the-Sea 6th Cycle Housing Element Amendment July 7, 2026 The City’s current development standards for courtyards and intra-block walkways may pose some level of constraint to the development of affordable residential units based on the requirement of Planning Commission review. However, with new construction, the development of courtyards and intra-block walkways will likely improve existing conditions and therefore be approved with ease.

Development standards related to courtyards and intra-block walkways have not impeded development, resulted in fewer units or lower density development in the City. Currently, the City has three ongoing multi-family rental projects that incorporate courtyards and or intra-block walkways: Ulrika Plaza, Scandia Lopez/Hakim, and JB Pastor.

The Ulrika Plaza project is fully entitled and advancing towards development, with building permits anticipated by May 2024. This project aims to develop 12 market-rate rental residential units.

Similarly, the Scandia Lopez/Hakim project is fully entitled, and building permits are in development and expected to be submitted by June 2024. This project is designed to introduce an additional three new rental residential units to the historic Percy Parkes Building. The project did not include any incentives, concessions, or bonuses. The project did benefit from an existing code provision that waives on-site parking in the Central Commercial District.

Regarding the JB Pastor project, the developer has requested a preliminary review by the Planning Commission to gather feedback on the design before submitting a formal application. This project aims to develop eight market-rate rental residential units.

Overall, the development standards related to courtyards and intra-block walkways have not discouraged development within the City.

Parking Requirements
The City’s parking requirements are generally in line with typical parking requirements. In the R-1 District, 1 on-site parking space per dwelling must be provided on sites of 8,000 square feet or less in area and 2 on-site parking spaces per dwelling on sites larger than 8,000 square feet in area. One parking space must be provided for each guesthouse. (CMC 17.10.030(F)(1)).

Under the current Municipal Code, R-1 zone sites with Class II accessory dwelling units (accessory dwelling units that are legal nonconforming units that were established prior to April 5, 1988) are required to provide a minimum of one parking space on-site at the time of approval. Upon enlargement or improvement of a Class II unit, one parking space each for the primary dwelling on the site and for the accessory dwelling unit are required. Improvements to accessory dwelling units are allowed even if one or both parking spaces encroaches into a setback. Accessory dwelling units built after 1988, or that were improved, are required to provide one parking space behind all setbacks for the accessory dwelling unit and are required to comply with all parking requirements established in Chapter 17.38 CMC, OffStreet Parking Requirements, for other development on the site.

The City’s ADU ordinance was last updated in 2017 (Ord. 2017-10 § 1 (Exh. A), 2017). The City is in the process of updating its ADU Ordinance to incorporate state laws that have expanded since 2017,

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Appendix B – Housing Constraints B-19
Carmel-by-the-Sea 6th Cycle Housing Element Amendment July 7, 2026 and to clarify the ADU permitting process for property owners. The City intends to remove all parking requirements for ADUs in the updated ADU Ordinance. Program 1.1.H establishes and monitors the implementation of Municipal Code amendments related to ADUs (see Chapter 2).

Table B-7 summarizes off-street parking requirements as shown in Table A of CMC 17.38.020, for all uses, projects, developments and redevelopments; note that accessory dwelling units are not included in Table A of CMC 17.38.020 but are included in Table B-7 below. The parking requirements outlined in Table B-7 fully satisfy parking requirements for individual projects.

New projects or developments shall only be allowed when meeting all parking requirements of this chapter and the requirements of any conditional use permit, subdivision approval or specific plan applicable to the property. Proposed uses within existing buildings may replace existing uses as long as any existing parking deficiencies on the property are not increased by the replacement. Proposed additions of floor area, new shops or dwelling units, or other similar changes in land use resulting in a net increase in parking requirements, as set forth in this chapter, shall provide all required parking generated by the new activities on the site. Parking can be provided on-site, off-site, or through payment of in-lieu fees.

Table B-7 Minimum Off-Street Parking Requirements
Land Use Basis for Requirement
Land Use District Parking Factors
CC SC RC R4
Permanent Residential Use Spaces per Dwelling Unit 1 1 1.5 1.5 Accessory Dwelling Units Spaces per Dwelling Unit 0 0 0 0 Affordable Housing for Moderate-,
Low- or Very Low-Income
Spaces per Dwelling Unit 1/2 1/2 1/2 1/2
Senior Housing, Cooperative
Housing or Group Care Facilities
Spaces per Dwelling Unit 1/3 1/3 1/3 1/3
Guest Spaces per Each Four Full Units 1 1 1 1
Nursing Home or Other Resident
Care Facility
Spaces per Patient or Resident N/A 1/3 1/3 1/3
Commercial Retail or Service Uses
Not Otherwise Specified in This
Table
Spaces per 600 Square Feet of
Commercial Floor Area or per
Business/Shop Space, whichever is
Greater
1 1 1 1
SIC 701: Hotels and Motels Spaces per Rental Unit,
Including Manager’s Unit
1 1 1 1
Source: CMC 17.38.020(C) Table A: Minimum Parking Requirements Note: The City follows State ADU law. When an ADU is created through the conversion of a garage or carport, replacement of the off-street parking space(s) are not required. Additionally, because parking is not required to be provided for ADUs located within one half-mile walking distance of public transit, ADUs in Carmel-by-the-Sea do not require parking.

Parking costs contribute significantly to the cost of development in Carmel-by-the-Sea and this flexibility often makes affordable housing more feasible. The City has adopted a reduced parking requirement from one space to one-half space per dwelling unit for affordable housing units (Program

1.1.B, see Chapter 2). This program also establishes waived parking requirements for affordable housing units in the CC District and reduced parking standards for senior housing developments.

Program 3.1.E establishes reduced parking requirements for affordable residential development,

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Appendix B – Housing Constraints B-20
Carmel-by-the-Sea 6th Cycle Housing Element Amendment July 7, 2026 including waiving in-lieu fees for affordable units. As a result of these concessions, potential constraints to development associated with existing parking standards will be reduced.

Cumulative Impacts
Overall, the City’s existing land use controls may pose potential constraints on the development of affordable housing as a result of limited building size; limited maximum density and lot coverage standards in the R-4 District; limited height standards in the R-4 District; and open space and intrablock walkway review requirements for new development and altering existing structures. The City should consider the following to reduce potential barriers to developing affordable housing:

1. Currently, FAR requirements for the city’s Commercial Districts do not pose a constraint to the development of multi-family housing. However, to ensure FAR does not result in the underutilization of parcels in the future, the City should consider increasing the allowed FAR;

2. The current maximum density standards for multi-family housing, which is permitted in the R-4 (max. 33 dwelling units per acre), CC, SC, and RC (max. 22 dwelling units per acre) Districts, pose a constraint to the development of affordable rental units due to the limited potential yield of units. This impacts the financial feasibility of affordable residential projects. The City includes Program 3.1.G to establish a minimum density of 22 dwelling units per acre and a maximum density of 40 dwelling units per acre for the base zoning in the R-4, CC, SC, and RC Districts (see Chapter 2);

3. Currently, development standards for maximum building height do not pose a constraint to the development of multi-family housing. However, to ensure height allowance does not impede residential development in the R-4 District in the future, the City should evaluate the impacts of increasing the height allowance;

4. While the City’s parking standards do not inherently pose a constraint to development, parking costs generally impact the cost of development. To offset parking costs associated with development, the City has reduced parking requirements in the CC District for affordable housing units and senior housing units (Program 1.1.B, see Chapter 2).

Additionally, Program 3.1.E reduces parking requirements in the R-4, RC, and SC Districts (see Chapter 2).

Objective Design and Development Standards
The City currently lacks a strictly objective set of design guidelines. Detailed design guidelines for the R-1 District and high-level design guidelines for commercial zones are presently in place; however, the current design guidelines include a mix of objective and subjective criteria. While the City’s existing R-1 design guidelines are being updated this year, the City does not currently have plans to develop a set of strictly objective standards for multi-family or mixed-use projects.

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Appendix B – Housing Constraints B-21
Carmel-by-the-Sea 6th Cycle Housing Element Amendment July 7, 2026 The lack of “Objective Design Standards” currently poses a constraint to residential development.

Guidelines that are subjective, or zoning districts that lack clear development standards, increase uncertainty and risk for housing developers. Objective Design Standards provide a measure of clarity that proposed developments will be measured against and provide the community with assurance that developments will conform with measurable objective standards. The City proposes to develop objective design standards for mixed-use and multi-family residential projects that include affordable housing.

Zoning for a Variety of Housing
California Housing Element Law requires the housing element to provide for a variety of housing types including multi-family rental housing, factory-built housing, mobile homes, housing for agricultural employees, supportive housing, single-room occupancy units, emergency shelters, and transitional housing (Government Code §65583 and §65583.2). Providing development opportunities for a variety of housing types promotes diversity in housing price, style, and size, and contributes to neighborhood stability by offering more affordable housing and accommodating a diverse income mix. Table B-2 (above) shows the housing types permitted in Carmel-by-the-Sea.

Single-Family Dwelling Units
A single-family dwelling is defined as any building containing or more habitable rooms with facilities for living, sleeping, cooking, and eating and containing no more than one kitchen (CMC 17.70).

Single-family dwelling units are permitted in all residential districts (R-1 and R-4); conditionally permitted in commercial zones (CC, SC, and RC) and public and quasi-public Districts.

Multifamily Dwelling Units
A multifamily dwelling is defined as a building or group of buildings on a single building site that, in whole or in part, is designed for, or occupied by, members of two or more families dwelling independently of each other in separate areas or units.

Multifamily and duplex housing units constitute approximately 13 percent of Carmel’s housing stock.

Multifamily dwelling units between 0-22 dwelling units per acre are permitted in the R-4, CC, SC, and RC Districts. Multifamily dwelling units between 22-44 dwelling units per acre are conditionally allowed in the R-4 District, and up to 88 dwelling units per acre is conditionally allowed in the CC, SC, and RC Districts.

The conditional use permit (CUP) for residential developments greater than 22 dwelling units per acre is a development constraint to higher density development. Site design review is required for multifamily projects, and the CUP process adds very limited value to the review process for projects of this size and scale. To lessen this regulatory constraint, the City will amend the Code to eliminate unnecessary use permits (Program 1.4.A, see Chapter 2).

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Appendix B – Housing Constraints B-22
Carmel-by-the-Sea 6th Cycle Housing Element Amendment July 7, 2026 Accessory Dwelling Units (ADUs)
An accessory dwelling unit (or ADU) is defined as an attached or detached residential dwelling which provides complete independent living facilities for one or more persons, including permanent provisions for living, sleeping, eating, cooking, and sanitation, which is located on the same parcel as a single-family dwelling (CMC 17.68.030). Based on their relatively small size, and because they do not require paying for land or major new infrastructure, ADUs and Junior ADUs (JADU) are considered affordable by design. ADUs can provide affordable housing options for family members, seniors, students, in-home health care providers, and other small household types. ADUs can also be useful to generate additional rental income for the homeowner, making homeownership more financially feasible.

Additionally, the City has a high rate of second home (vacation) ownership. Encouraging ADUs and JADUs may be appealing to second homeowners because ADUs will provide a higher level of security to the property if there is a full-time resident, and will add an income stream to a property that lies vacant for a high proportion of the year. Most importantly, ADUs and JADUs can provide muchneeded affordable smaller housing units.

The City’s ADU ordinance was last updated in 2017 (Ord. 2017-10 §1 (Exh. A), 2017). Carmel-by- theSea is currently following the requirements of State law in the review and approval of ADUs and JADUs. The City is in the process of updating its ADU Ordinance to incorporate state laws that have expanded since 2017, and to clarify the ADU permitting process for property owners.

In recent years, the California Legislature has passed a series of bills aimed at encouraging single- family homeowners to add ADUs to their property by requiring local jurisdictions to adopt regulations to facilitate their production and streamline their approval. The State passed legislation in 2017, 2019, 2020, and 2021 to further assist and support the development of ADUs, including by- right approval for units less than 800 square feet. ADUs are also permitted in commercial structures per state law.

The City permits one guesthouse on sites of 6,000 square feet or greater upon approval of a use permit.

Guesthouses shall contain no food preparation facilities of any kind, but are permitted to have a bathroom with a toilet, sink and bathing facility. A guesthouse on any building site may be converted to an accessory dwelling unit, generally requiring the permitting of kitchen sink and facilities. Converting existing guesthouses to fully functional ADUs, or JADUs, represents a cost- effective method to increase the City’s housing stock, requiring only a building permit. These opportunities could be strong candidates for prioritization of the City’s limited water distribution.

The City is also exploring the development of standardized pre-approved ADU plans. Standardized plans can eliminate the costs of designing a custom ADU, and assures property owners the unit type and size is already approved by the City. Pre-approved plans can also make construction more affordable if the designs are using materials that are easily sourced and standard-sized.

The City of Carmel-by-the-Sea has included Program 1.1.H to establish and monitor the amendment of its Municipal Code to be consistent with ADU and JADU state law, and develop standardized ADU plans (see Chapter 2).

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Appendix B – Housing Constraints B-23
Carmel-by-the-Sea 6th Cycle Housing Element Amendment July 7, 2026 Manufactured Housing / Mobile Homes
State law requires manufactured homes be permitted equally anywhere that single-family homes are permitted. Mobile homes are an affordable homeownership for farmworkers and other very low-, low-, and moderate-income households.

There are no mobile home parks located in Carmel-by-the-Sea. The City permits mobile homes on a permanent foundation as a single-family residential use, subject only to the design review requirements as any other single-family residential use in the same zone pursuant to state law California Government Code §65852.3. Such housing is subject to the same development standards and design review criteria as traditional forms of housing construction. The City has included Program 1.3.C to establish and monitor the amendment of the Municipal Code to clarify this type of housing as a permitted use in the R-1 District.

Group Homes
The Zoning Code defines group residential as “Shared living quarters without separate kitchens or bathrooms for each room or unit, including boardinghouses, dormitories, and private residential clubs, but excluding guesthouses.” As described above, state-licensed group homes are permitted under the regulations for Community Care Facilities and Residential Care Facilities. Unlicensed group homes are not currently identified as a permitted use in any zoning district.

The City has not identified any zoning or other land-use regulations that could discriminate against persons with disabilities or impede the availability of such housing for these individuals. Examples of the ways in which the City facilitates housing for persons with disabilities through its regulatory and permitting procedures are:
 As discussed above, the City Zoning Code allows residential care facilities for six or fewer persons subject to the same standards and procedures as apply to other residential dwellings of the same type in the same zone;
 The City has also adopted reduced parking requirements (0.33-space per unit or bed) for Senior Housing, Cooperative Housing, Group Care Facilities, Nursing Homes and Other Residential Care Facilities. Retrofitting of dwellings to meet the needs of persons with disabilities is also an eligible activity under the City’s Housing Rehabilitation Program.

Construction and rehabilitation activities are also subject to the Federal Americans with Disabilities Act requirements and the City is active in promoting ADA compliance; and  The City defines family as “an individual or two or more persons living together as a single nonprofit housekeeping unit and sharing common living, sleeping, cooking, and eating facilities,” which is consistent with state law.

Single-Room Occupancy (SRO) Units
Single room occupancy (SRO) housing are one-room units intended for occupancy by a single individual. It is distinct from a studio or efficiency unit, in that a studio is a one-room unit that must

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Appendix B – Housing Constraints B-24
Carmel-by-the-Sea 6th Cycle Housing Element Amendment July 7, 2026 contain a kitchen and bathroom. Although SRO units are not required to have a kitchen or bathroom, many SROs have one or the other.

The City’s Zoning Code does not explicitly define single room occupancy housing, although CMC

17.08.050(F) allows guesthouses, studios, and multi-family units as small as 400 square feet. The Code also requires that all multi-family projects of three or more units include a mix of unit sizes, and at least 25 percent of all units are required to be 400 to 650 square feet in size. The City has included Program

3.3.D to establish and monitor the amendment of the Municipal Code to codify SROs.

Transitional and Supportive Housing
Transitional housing is generally defined as a facility that provides shelter for homeless individuals, and generally involves integration with other social services and counseling programs to assist in the transition of self-sufficiency through the acquisition of permanent income and housing. Transitional housing is temporary housing (generally six months to two years) for a homeless individual or family who is transitioning to permanent housing. This housing can take several forms, including group housing or multi-family units, and often includes a supportive services component to allow individuals to gain necessary life skills in support of independent living. There are no known transitional housing facilities in the City.

Supportive housing is generally defined as permanent, affordable housing with on-site services that help residents transition into stable, more productive lives. Services may include childcare, after- school tutoring, career counseling, etc.

The City’s Municipal Code permits transitional and supportive housing by-right in all districts that permit residential uses including the CC, SC, RC and R-4 Districts, regardless of the number of persons the facility serves compliant with SB 2 passed in 2007. The City has included Program 3.3.A to establish and monitor the amendment of the Municipal Code to further clarify transitional and supportive housing in the R-1 district as a permitted use.

Emergency Shelters
Emergency shelters are generally defined as a facility which provides immediate short-term housing for homeless individuals.

Emergency shelters for the homeless is defined as a residential facility, lodging house, or dwelling, where no rent is paid, that provides temporary accommodation to homeless persons and/or families.

Pursuant to Senate Bill (SB) 2, jurisdictions with an unmet need for emergency shelters are required to identify a zone(s) where emergency shelters will be allowed as a permitted use without a conditional use permit or other discretionary permit. The identified zone must have sufficient capacity to accommodate the shelter need, and at a minimum provide capacity for at least one year- round shelter. Permit processing, development and management standards for emergency shelters must be objective and facilitate the development of, or conversion to, emergency shelters.

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Appendix B – Housing Constraints B-25
Carmel-by-the-Sea 6th Cycle Housing Element Amendment July 7, 2026 There are no emergency shelters or homeless services located in the City. However, the Zoning Code allows siting of emergency shelters as community social service facilities, which are defined in CMC

17.68 as “Any noncommercial housing facility, such as homeless shelters or emergency shelters, which may also provide meals, showers, and/or laundry facilities. Specialized programs and services related to the needs of the residents may also be provided. This classification excludes transitional housing facilities that provide long-term living accommodations.” Community social service facilities are permitted by-right in the CC, SC, and RC districts (CMC 17.14.030, Schedule II- B) as well as with a CUP in the R-1 and R-4 districts (CMC 17.08.040, Schedule II-1) and A-3 District (CMC 17.18.070, Schedule II-D). Residential uses are permitted in all of these Districts.

In addition, shelters for families and single women with children are permitted at all churches in the community as a part of their social outreach functions. Religious facilities are conditionally permitted in the R-1 district (only on existing quasi-public use sites established prior to December 1, 1980, or added as an accessory use to such existing uses) and allowed with a conditional use permit (CUP) in the RC district.

AB 2339 passed in 2022, expands the definition of emergency shelters to include low barrier navigation centers and bridge housing. AB 2339 also requires that the zone(s) permitting emergency shelters byright be zones that are also suitable for residential uses.

As described in Appendix A – Housing Needs and Fair Housing Report, the 2022 Monterey Homeless Count and Survey Comprehensive Report prepared by Applied Survey Research estimated there was only one transient resident in the City as of 2022 who is presently being sheltered at a local religious facility. AB 2339 provides a general guidance of 200 square feet per person. A site area of approximately 2,000 square feet (0.04 acres) would be sufficient to house up to 10 people, and therefore accommodate the City’s homeless population of one person. Overall, a total of 39-acres in the City are zoned for commercial uses (CC, SC, and RC). As later shown in Appendix C –Sites Inventory, the Sites Inventory identifies approximately 1.54 acres of underutilized CC, SC, and RC sites in the Commercial District.

Specifically, 11 of these sites are larger than 0.04 acres, which would be appropriate for a small sized shelter facility and adequate to accommodate the City’s one unsheltered homeless resident, and up to a maximum of 10 people.

New shelters are often installed through adaptive reuse of existing buildings rather than through new construction due to costs and funding limitations. The CC, SC, and RC zones contain older commercial uses that may be renovated for other purposes such as emergency shelters. Recently, the City has seen an uptick in renovations and second-floor residential additions in the Commercial District. The CC, SC, and RC sites are centrally located along major transportation routes, and therefore have access to public transportation and services in the community, including faith-based organizations that offer assistance to the needy. As discussed in Appendix A – Housing Needs and Fair Housing Report, the majority of resources for persons experiencing housing insecurity are provided at the county level and by nonprofits located outside of Carmel-by-the-Sea due to a lack of need in the city and limited resources at the city level. Existing resources within the region include the following:

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Appendix B – Housing Constraints B-26
Carmel-by-the-Sea 6th Cycle Housing Element Amendment July 7, 2026  The Carmel Foundation – Located at the Southeast Corner of 8th and Lincoln Street in Carmel- by-the-Sea, the Foundation provides services to resident aged 65 and older who have limited financial resources. Services provided by the Foundation include, blood pressure checks, health counseling, low-income housing, legal services, etc.  Community Human Services: Super Kids/Super Teens Mental Health Services – Located at 835 Forest Avenue, Pacific Grove, the organization provides school-based counseling to elementary, middle school, and high school students. The organization’s services are free of charge and include individual and group counseling, consultation with parents, education workshops, and information.
 Community Human Services: Safe Place Youth Shelter and Navigation Center – Located at 590 Pearl Street, Monterey, the organization provides assistance and resources to youth aged 18 to 24, including street outreach, survival aid, temporary shelter, counseling, family reunification, and aftercare. The organization provides weekly meals; crisis intervention; food, clothing, and hygiene products; drug and alcohol education; and life skills education.  Community Human Services: Casa de Noche Buena – Located at 1292 Olympia Avenue, Seaside, the organization provides services to women and families with children, including shelter, melas, and various supportive services designed to lead to permanent housing.  Monterey County Mobile Clinic – Available at several locations throughout Monterey County, however, the nearest locations are at The Salvation Army Day Center at 800 Scott Street in Sand City and Gathering for Women at 147 El Dorado Street in Monterey. The mobile clinic is available at The Salvation Army Day Center in Sand City every fourth Tuesday and available at Gathering for Women in Monterey every second Tuesday. Services provided include general dentistry and emergency dental care, and medical services such as preventive care, women’s care, and acute and chronic condition management.

To clearly identify emergency shelters as a permitted use in the CC, SC, and RC districts (CMC

17.14.030), the City has included Program 1.3.E to establish and monitor an amendment to the Municipal Code to define emergency shelters in compliance with AB 2339 Statutes of 2022, and to clearly state they are a permitted use by-right, requiring no discretionary review in the CC, SC, and RC commercial districts.

Low Barrier Navigation Centers
Assembly Bill (AB) 101, adopted in 2019, requires approval by-right of low barrier navigation centers that meet the requirements of state law. A “Low Barrier Navigation Center” is a housing first, lowbarrier, service-enriched shelter focused on moving people into permanent housing that provides temporary living facilities while case managers connect individuals experiencing homelessness to income, public benefits, health services, shelter, and housing. If the City receives applications for these uses, it will process them as required by state law. Program 3.3.B has been included in the element to develop by-right procedures for processing low-barrier navigation centers.

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Appendix B – Housing Constraints B-27
Carmel-by-the-Sea 6th Cycle Housing Element Amendment July 7, 2026 Community Care Facilities
To maintain compliance with the Lanterman Developmental Disabilities Services Act (Lanterman Act), the City currently permits small licensed residential or community care facilities serving six or fewer individuals in all residential zoning districts by-right and licensed facilities serving seven or more individuals in all residential zoning districts with approval of a Conditional Use Permit (CUP). Larger community care facilities (greater than six persons) may be required to meet certain conditions, including restrictions on hours of operation, security, loading requirements, and management. These conditions are comparable to all similar uses within the designated zoning district and would not impose constraints to the development of care facilities. The City will amend the Municipal Code to address unlicensed residential care facilities with seven or more persons (Program 3.3.C).

Senior Housing
As previously noted, several zoning districts within the City already permit and accommodate for senior housing. The A-2 zoning district (Cultural and Community District, i.e., the Sunset Center) and the A-3 zoning district (Senior Citizen Facility District) permits by-right housing for seniors.

Constraints for People with Disabilities
Both the Federal Fair Housing Act and the California Fair Employment and Housing Act impose an affirmative duty on local governments to make reasonable accommodations (i.e., modifications or exceptions) in their zoning and other land use regulations when such accommodations may be necessary to afford disabled persons an equal opportunity to use and enjoy a dwelling. For example, it may be a reasonable accommodation to allow covered ramps in the setbacks of properties that have already been developed to accommodate residents with mobility impairments. The City adopted a reasonable accommodation policy (City Council Policy C11-01) in July 2011. This policy provides a reasonable accommodation in the land use and zoning context to ensure equal access to housing and facilitate the development of housing for individuals with disabilities. The policy provides individuals with disabilities or developers of housing for people with disabilities flexibility in the application of land use, zoning and building regulations, policies, practices and procedures.

Since 2015, the City has approved seven applications for reasonable accommodations ranging from allowing a pig as a companion animal to a person with a disability, additional site coverage for pathways and driveways, an exterior wheelchair lift, and the provision of a walk-in shower in a detached artist studio. The following findings have not been a constraint to accommodating requests for exceptions to land use, zoning, and building regulations, policies, practices, or procedures.

The City's reasonable accommodation policy contains the following five required findings:

1. That the housing, which is the subject of the request for reasonable accommodation, will be used by an individual with disabilities protected under fair housing laws; and

2. That the requested accommodation is necessary to make housing available to an individual with disabilities protected under the fair housing laws and cannot reasonably be accomplished without special accommodations; and

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Appendix B – Housing Constraints B-28
Carmel-by-the-Sea 6th Cycle Housing Element Amendment July 7, 2026

3. That the requested accommodation will not impose an undue financial or administrative burden on the City; and

4. That the requested accommodation will not require a fundamental alteration in the nature of the City's land use, zoning, building or Local Coastal Program; and

5. That the requested accommodation will not result in a significant and unavoidable negative impact on adjacent uses or structures.

The findings requirement, “that the requested accommodation will not result in a significant and unavoidable negative impact on adjacent uses or structures” is a discretionary standard that could impose constraints on improvements to make housing accessible to persons with disabilities. To eliminate subjectivity in the review of requests for reasonable accommodations, the City will amend the Municipal Code to remove the findings requirement for requested accommodations stating, “the requested accommodation will not result in a significant and unavoidable negative impact on adjacent uses or structures.” Program 3.2.A will establish and monitor these amendments to the City’s Municipal Code.

Requests for reasonable accommodation are typically reviewed by the Director of Community Planning and Building. However, if the approval does not require review by a City Board, Commission, or Council, the Director may refer the request to the Planning Commission.

Reasonable accommodation requests are reviewed by the Planning Commission if the request is part of a new development. However, this is not typical for Carmel-by-the-Sea and all requests received have been reviewed at a staff level with the development permits. As set forth in CMC Chapter 17.54, any decision to approve, deny, or conditionally approve any permit made by the Director, City Forester, Planning Commission, or Historic Resources Board may be appealed by any aggrieved party. Municipal Code Chapter 17.70 defines an “aggrieved party” as “any person who, in person or through a representative, appeared at a City public hearing in connection with the decision or action appealed, or who, by other appropriate means prior to a hearing, informed the City of the nature of his/her concerns or who for good cause was unable to do either (i.e., defective notice). “Aggrieved person” includes the applicant for a permit.” If the final reviewing authority is the City Council, the decision shall be final.

To address potential obstacles in the approval process for requests for reasonable accommodation, the City has included Program 3.2.A. This program proposes an amendment to the definition of aggrieved parties in the Municipal Code. An exception for reasonable accommodation appeals will limit the parties eligible to appeal a request for reasonable accommodation to the applicant or the personal beneficiary.

Community Care Facilities
The City currently permits community care facilities in several zoning districts. Community care facilities refers to facilities providing non-medical care and supervision under license from the California Department of Social Services. This classification excludes hospitals, residential care facilities,

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Appendix B – Housing Constraints B-29
Carmel-by-the-Sea 6th Cycle Housing Element Amendment July 7, 2026 family day care homes, day care centers, and transitional housing. Community care facilities are permitted in the CC, SC, and RC districts as well as by conditional use permit in the R-4 district.

To encourage the development of community care facilities, the City has included Program 1.4.A to establish and monitor the elimination of use permit requirements for licensed community care facilities of seven or more persons (see Chapter 2).

Residential Care Facilities
Residential care facilities include facilities that are licensed by the State of California to provide living accommodations and 24-hour, primarily non-medical care and supervision for persons in need of personal services, supervision, protection, or assistance. Living accommodations are shared living quarters with or without separate kitchens or bathrooms for each room or unit. This classification includes facilities that are operated for profit as well as those operated by public or nonprofit institutions.

The City defines Residential Care Facilities according to size or age as follows:
 Residential Care, General. A residential care facility providing 24-hour nonmedical care for more than six persons in need of personal services, supervision, protection, or assistance.

This classification includes hospices, board and care homes, and similar establishments that are licensed by the State of California. These types of facilities are conditionally permitted in the SC and RC Districts.
 Residential Care, Limited. A residential care facility providing 24-hour nonmedical care for six or fewer persons in need of personal services, supervision, protection, or assistance essential for sustaining the activities of daily living. This classification includes only those facilities licensed for residential care by the State of California. These types of facilities are subject to the same regulations as applied to other family residential dwellings in the CC, SC, and RC Districts. In the R-1 District, they are permitted as single-family homes. In the R-4 District, they are permitted by-right with no restrictions.  Residential Care, Senior. A residential care facility providing 24-hour medical or nonmedical care for more than six persons 60 years of age or older in need of personal services, supervision, protection, or assistance for sustaining the activities of daily living. This classification includes nursing homes for the elderly, life care or continuing care homes, and similar facilities licensed for residential care by the State of California. These types of facilities are conditionally permitted in the SC, RC, and R-4 Districts.

The following include general findings required for all conditional use permits:

1. That the proposed use will not be in conflict with the City’s General Plan;

2. That the proposed use will comply with all zoning standards applicable to the use and zoning district;

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Appendix B – Housing Constraints B-30
Carmel-by-the-Sea 6th Cycle Housing Element Amendment July 7, 2026

3. That granting the use permit will not set a precedent for the approval of similar uses whose incremental effect will be detrimental to the City, or will be in conflict with the General Plan;

4. That the proposed use will not make excessive demands on the provision of public services, including water supply, sewer capacity, energy supply, communication facilities, police protection, and fire protection;

5. That the proposed use will not be injurious to public health, safety or welfare;

6. That the proposed use will be compatible with surrounding land uses and will not conflict with the purpose established for the district within which it will be located; and

7. That the proposed use will not generate adverse impacts affecting health, safety, or welfare of neighboring properties or uses.

In addition to the general findings for all use permits listed above, use permits for commercial uses also require all of the following findings:

1. That allowing the proposed use will not conflict with the City’s goal of achieving and maintaining a balanced mix of uses that serve the needs of both local and nonlocal populations;

2. That proposed use will provide adequate ingress and egress to and from the proposed location; and

3. That the capacity of surrounding streets is adequate to serve the automobile and delivery truck traffic generated by the proposed use. (Ord. 2004-02 § 1, 2004; Ord. 2004-01 §1, 2004).

The review process for a CUP in the Commercial District includes one hearing of the Planning Commission. The required findings for a CUP in the Commercial District include a total of 10 required findings that the Planning Commission must make to determine eligibility. The required findings include subjectivity and may pose potential barriers to the development of licensed residential care facilities. Program 1.4.A establishes an amendment to the Municipal Code to remove subjectivity from the required findings for a CUP (see Chapter 2). Additionally, the program establishes the elimination of CUP requirements for licensed residential care facilities of seven or more persons (see Chapter 2).

These modifications to the Municipal Code will remove potential constraints to the development of residential care facilities.

Short-Term Rentals
To preserve Carmel-by-the-Sea’s residential character, no home or accessory dwelling unit may be rented for less than 30 consecutive days in a residential zoning district. This current restriction is intended to ensure that residential units are available for full-time residential use. The City has a high number of motels and hotels to service the tourism industry and transient guests.

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Appendix B – Housing Constraints B-31
Carmel-by-the-Sea 6th Cycle Housing Element Amendment July 7, 2026 Employee Housing Act
The housing needs analysis in Appendix A of this Housing Element indicates that there are no farmworkers or agricultural employment in Carmel-by-the-Sea. Accordingly, the City has not identified a need for specialized farmworker housing beyond overall programs for housing affordability.

The City included Program 1.3.B to amend the Municipal Code in compliance with Health and Safety Code §17021.5, to define and permit employee housing for six or fewer employees to be treated as a single-family structure and permitted in the same manner as other dwellings of the same type in the same zone (see Chapter 2).

Site Plan and Design Review
Architectural design is important in Carmel-by-the-Sea. The historic character of Carmel’s built environment has been shaped by decades of careful and deliberative design review (referred to as “design study” in Carmel) that addresses such features as site design, architectural style, building materials, color palettes, fenestration, tree placement, and landscaping. This attention to detail has resulted in a beautiful, forested village atmosphere that continues to capture the imagination of people from around the world who visit and even choose to make Carmel their home.

The same design review process that has contributed to Carmel becoming a world-famous destination, however, has also impacted its ability to provide housing for lower-income households and by extension housing for a less affluent and diverse population. In this way, Carmel has in some ways become a victim of its own success. Many of the actors, artists, and writers who made Carmel their home in the early 20th century came from modest beginnings and travelled to the area not to live in custom luxury homes, but to experience and become part of a “rich” artistic community. They came for inspiration, not exclusivity.

Part of the challenge, then, is for Carmel to find a way back to its roots – to provide space again for the next generation of the artistically gifted who have yet to make their mark on the world, a space that contains a full mix of incomes and backgrounds within which the artist can find meaning and inspiration.

The following subsection provides a detailed description of Carmel’s design review process.

Residential Design Review Process
The City has two distinct permitting procedures for projects in the R-1 and projects in all other Districts (CC, SC, RC, and R-4). In the R-1 District, development is comprised of single-family residential projects, typically one custom luxury single-family home (as opposed to subdivisions with multiple residences). There are very specific objective and subjective design standards for single-family homes. Two public hearings at the Planning Commission are required: a Concept Review hearing and a Final Details hearing. In all other Districts, the permit procedure requires additional entitlements in the form of Use Permits but only one public hearing at the Planning Commission, as opposed to two for

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Appendix B – Housing Constraints B-32
Carmel-by-the-Sea 6th Cycle Housing Element Amendment July 7, 2026 single-family residences. Note the following two programs aimed to streamline mixed-use and multifamily residential projects.

Program 1.4.A: Eliminate Unnecessary Use Permits proposes to evaluate the current requirements for Use Permits and eliminate them where feasible to streamline mixed-use and multi-family residential projects in the CC, SC, RC, and R-4 Districts.

Program 1.4.B: Objective Design Standards proposes the creation of objective design standards for mixed-use and multi-family residential projects that include affordable housing. Reducing the number of entitlements required and developing objective design standards are expected to reduce the amount of time required to process housing projects. This is an opportunity for the City to express the design aesthetic that is important to preserving the character of the village while providing clear guidance to developers who desire to build in Carmel.

The typical residential development review process for Carmel-by-the-Sea generally falls under two design study “tracks”: Track 1 and Track 2. A Design Study application is a discretionary review that can include both objective and subjective standards. A hearing is limited to single family projects that qualify as a substantial alteration, or additions greater than 10 percent of the existing floor area, or demolitions and new construction.

Residential Track 1 Design Study
Track 1 Major Design Study Applications are projects that can be approved at the staff level and typically do not require a public hearing. “Track 1 Major” projects are projects involving additions of less than 10 percent of the existing floor area, or projects with multiple minor components (Track 1 Minor) that together add complexity and require a more detailed review.

The Track 1 Major review is also limited to projects that: 1) do not require significant cuts to the roots/limbs of any “significant” or “moderately significant” trees; 2) do not require the demolition or substantial alteration of any dwelling unit; and 3) are sited and designed to protect public views to and along the ocean and scenic coastal access.

The major steps involved with a Track 1 Design Study Application are as follows:

1. Submit a Design Study Application – This is the formal project application.

2. Staff Review and Decision – Staff will review the application for completeness and consistency with the Zoning Code and the Residential Design Guidelines. The City Planning Division reviews applications for completeness within 30 days to comply with the Permit Streamlining Act. Carmel Municipal Code Section 17.52.020.D codified the Permit Streamlining Act and requires that within 30 days of the date the City receives any application for a development permit as defined by State law, the Department shall review the application to determine if it is complete and provide written notification to the applicant (see CMC 17.52.020.D). If the application is incomplete or inconsistent with the Zoning Code or the Design Guidelines, staff will notify the project applicant of the changes

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Appendix B – Housing Constraints B-33
Carmel-by-the-Sea 6th Cycle Housing Element Amendment July 7, 2026 that are required. If the application is complete and approvable, staff will notify the applicant that the application has been approved. If approved, an approval packet is completed and issued. The approval packet consists of (1) an Approval Letter, (2) Conditions of Approval, (3) a Notice of Approval, (4) an Affidavit of Posting of the Notice of Approval, and (5) stamped approved plans. The Approval Letter will inform the applicant if a Building Permit or Notice of Authorized Work is required.

3. Noticing/Appeal Period - The Notice of Approval is required to be posted on-site by the applicant for a 10-calendar day appeal period. For Track 1 Major projects, the approval notice is also mailed by the City to neighbors within 100 feet of the property.

4. Building Permit/Notice of Authorized Work – Following the end of the appeal period, and assuming no appeals are filed, the applicant may apply for either a Building Permit or, if not applicable, will receive a Notice of Authorized Work.

Residential Track 2 Design Study
Track 2 Design Study Applications are for new residential construction, large additions and substantial alterations that require Planning Commission approval. The purpose of the Track 2 Design Study is to promote orderly development, to ensure high quality neighborhood design that is harmonious with its surroundings, to implement the General Plan, and to preserve and promote the visual character of the City. The major steps involved with a Track 2 Design Study Application are as follows:

1. Submit a Preliminary Site Assessment Application – This is required for all Track 2 Projects.

After the assessment is completed by Planning and Forestry staff, the applicant will move on to submitting their project application.

2. Submit a Design Study Application – This is the formal project application. Planning staff will review it for completeness and provide early feedback. The City Planning Division reviews applications for completeness within 30 days to comply with the Permit Streamlining Act. Carmel Municipal Code Section 17.52.020.D codified the Permit Streamlining Act and requires that within 30 days of the date the City receives any application for a development permit as defined by State law, the Department shall review the application to determine if it is complete and provide written notification to the applicant (see CMC 17.52.020.D).

3. Participate in a Forest and Beach Commission Hearing (if tree removal is proposed): A request to remove or prune a significant tree must be approved by the Forest and Beach Commission (FBC) prior to determining completeness of the application. The removal or pruning of any tree will require a separate tree removal application be submitted (Permit Type: Tree with Construction).

4. Install Staking and Flagging (story poles) – “Story poles” provide a visual representation of the proposed project for the public and the Planning Commission. The Coastal Act requires a visual analysis for new development within a coastal zone to ensure significant coastal

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Appendix B – Housing Constraints B-34
Carmel-by-the-Sea 6th Cycle Housing Element Amendment July 7, 2026 views are not obstructed – the entire city is within the coastal zone. Story poles not only reflect the scale of a project but also help to identify conflicts with surrounding significant trees, significant view impacts, and solar impacts. Story poles must be installed and heights certified by a California licensed surveyor or civil engineer at least 10 days prior to the scheduled Concept Hearing. To avoid having to relocate or reposition the story poles, it is recommended that story poles be installed after the application has been deemed complete.

5. Participate in a Historic Resource Board Hearing (properties located on the City’s Inventory of Historic Resources) – Projects on historic sites are subject to additional review from a city- retained historical consultant and review by the Historic Resources Board (HRB) prior to consideration by the Planning Commission. The historic status of a property will be determined during the Preliminary Site Assessment, if not already documented.

6. Participate in a Concept Hearing – The Concept Review phase by the Planning Commission (PC) will address site planning, access, building massing and neighborhood design issues, such as privacy and view impacts. Projects are evaluated using both the development standards in the Zoning Code and the Residential Design Guidelines – Introduction and Design Concept Review.

7. Obtain a Volume Study – A volume standard was codified c. 2004 as an additional development standard for single-family residential homes to regulate mass and bulk. Each site is permitted a certain amount of exterior volume. Volume is defined as the total space occupied by all structures located above average grade. Following Concept acceptance by the Planning Commission, staff will send the architectural design plans to a City-retained architect/engineer to calculate the volume. A deposit will be collected at the time of application submittal and the unused balance will be returned to the applicant. The cost of a volume study averages $700.

8. Participate in a Final Details Hearing – In this review by the Planning Commission (PC), the project is reviewed for compliance with the City’s Residential Design Guidelines – Final Details Review. Issues such as landscaping, architectural character, and exterior materials are evaluated.

9. Final Approval and Appeal Period – The Planning Commission’s approval is subject to a 10-working-day appeal period. Story poles must remain in place until the appeal period has expired. At the conclusion of the appeal period, and assuming no appeals are filed, the applicant may proceed with submitting an application for a Building Permit. If an appeal is filed, the appeal will be considered by the City Council at the next available council meeting.

10. Decisions of the City Council are final unless the project is located within the Coastal Commission appeal jurisdiction. In such cases, the decision of the City Council can be appealed to the Coastal Commission. In the 5th Cycle, no housing projects were appealed to the Coastal Commission.

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Appendix B – Housing Constraints B-35
Carmel-by-the-Sea 6th Cycle Housing Element Amendment July 7, 2026 To remove potential barriers to the development of multi-family housing, the City has included Program 3.1.F, to amend the Municipal Code to allow 3-D modeling or other visual analysis in lieu of story poles for multi-family developments.

Commercial Design Review Process
Per CMC 17.58.030, Commercial Design Review, the City has established two tracks for design review of projects proposing new construction, alterations, rebuilds, additions, demolitions, and other exterior design changes in the Central Commercial (CC), Service Commercial (SC), Residential and Limited Commercial (RC) districts and the Multifamily Residential (R-4) district: Track One and Track Two.

Several factors differentiate residential from commercial design review. Unlike residential development in the R-1 District, development in the CC, SC, RC, and R-4 Districts is not subject to a Preliminary Site Assessment, nor a Volume Study, and it is exceptionally rare for a project in the commercial zones to require review by the Forest & Beach Commission. In the 5th Cycle planning period, only one commercial development project (Del Dono II, in 2018) was required to go to the Forest & Beach Commission for a tree removal permit.

Additionally, while commercial development is subject to the City’s Commercial Design Guidelines (2000) and, if located within Carmel Plaza, the Carmel Plaza Storefront Design Guidelines (2001), these guidelines are notably less stringent than the City’s Residential Design Guidelines. As described in CMC 17.14, Commercial Zoning Districts, proposed projects need not strictly comply with every guideline to be approved, but deviations should be minor and reasonably related to good design principles and site conditions. The basic standard of review in the commercial district is whether the project constitutes an improvement over existing conditions.

Commercial Track One Design Review
The Director may approve Track One applications for design changes in all commercial zoning districts (CC, SC, and RC) and the R-4 district based on a determination that such projects comply with the Zoning Code and all applicable commercial design guidelines.

Commercial Track Two Design Review
The Planning Commission reviews and approves Track Two applications. This is a discretionary process for reviewing substantial design changes in commercial zoning districts and the R-4 district and involves one required public hearing. Substantial changes include but are not limited to the construction of new buildings, additions to existing buildings, new parking facilities, and installation of antennas. The major steps involved with a Commercial Track 2 Design Study Application are as follows.

1. Submit a Design Review Application – This is the formal project application. Planning staff will review it for completeness and provide early feedback. The City Planning Division reviews applications for completeness within 30 days to comply with the Permit Streamlining Act. Carmel Municipal Code Section 17.52.020.D codified the Permit Streamlining Act and requires that within 30 days of the date the City receives any application for a development permit as defined by State law, the Department shall review

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Appendix B – Housing Constraints B-36
Carmel-by-the-Sea 6th Cycle Housing Element Amendment July 7, 2026 the application to determine if it is complete and provide written notification to the applicant (see CMC 17.52.020.D).

2. Install Staking and Flagging (story poles) – “Story poles” provide a visual representation of the proposed project for the public and the Planning Commission. Story poles not only reflect the scale of a project but also help to identify conflicts with surrounding significant trees, significant view impacts, and solar impacts. Story poles must be installed and heights certified by a California licensed surveyor or civil engineer at least 10 days prior to the scheduled Hearing. To avoid having to relocate or reposition the story poles, it is recommended story poles be installed after the application has been deemed complete.

3. Participate in a Historic Resource Board Hearing (properties located on the City’s Inventory of Historic Resources) – Projects on historic sites are subject to additional review from a city- retained historical consultant and review by the Historic Resources Board (HRB) prior to consideration by the Planning Commission. The historic status of a property will be determined as part of a Historic Evaluation application, if not already documented.

4. Participate in one Planning Commission Hearing – The Planning Commission (PC) will evaluate the project using the development standards in the Zoning Code and the Commercial Design Guidelines (2000) and, if located within Carmel Plaza, the Carmel Plaza Storefront Design Guidelines (2001).

5. Final Approval and Appeal Period – The Planning Commission’s approval is subject to a 10- working day appeal period. Story poles must remain in place until the appeal period has expired. At the conclusion of the appeal period, and assuming no appeals are filed, the applicant may proceed with submitting an application for a Building Permit. If an appeal is filed, the appeal will be considered by the City Council at the next available council meeting.

6. Decisions of the City Council are final unless the project is located within the Coastal Commission appeal jurisdiction. In such cases, the decision of the City Council can be appealed to the Coastal Commission. In the 5th Cycle, no housing projects were appealed to the Coastal Commission.

As previously stated, to remove potential barriers to the development of multi-family housing, the City has included Program 3.1.F, to amend the Municipal Code to allow 3-D modeling or other visual analysis in lieu of story poles for multi-family developments.

Residential Design Approval Findings
As applicable to the project, the Planning Director, Historic Preservation Board, or the Planning Commission have authority to approve, approve with modifications and/or conditions, or deny an application for design review based on the following findings.

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Appendix B – Housing Constraints B-37
Carmel-by-the-Sea 6th Cycle Housing Element Amendment July 7, 2026 Findings for Design Review Approval
Prior to approving an application for design review in any district, the Planning Director, Historic Preservation Board or the Planning Commission must make the following findings.

1. Conform to the applicable policies of the General Plan and the Local Coastal Program;

2. Comply with all applicable provisions of the Municipal Code; and

3. Are consistent with applicable adopted design review guidelines (CMC 17.58.060).

Additional Findings for Design Review Approval in the R-1 District The Planning Commission shall make all of the following findings before granting design review approval in the R-1 District.

1. The project conforms with all zoning standards applicable to the site, or has received appropriate use permits, variances or exceptions consistent with the Zoning Ordinance.

2. The project contributes to neighborhood character including the type of forest resources present, the character of the street, the response to local topography and the treatment of open space resources such as setbacks and landscaping.

3. The project is compatible with, and sensitive to, the natural features and built environment of the site and of the surrounding area. The project respects the constraints of the site and avoids excessive grading, cuts and fills. Construction on steep slopes is minimized to the extent feasible and abrupt changes in grade is minimized or mitigated.

4. The project maintains the City’s principles of modesty and simplicity and preserves the City’s tradition of simple homes set amidst a forest landscape. The project uses simple building forms and simple roof forms without complexity that would attract undue attention to the site.

5. The project does not present excess visual mass or bulk to public view or to adjoining properties. The project relates to a human scale in form, elements and in the detailing of doors, windows, roofs and walkways.

6. Project details and materials (e.g., windows, doors, chimneys, roofs, and stonework) are fully integrated and consistent throughout the design. Building materials are used in a manner that is visually consistent with the proposed architecture. All fenestration is appropriate in size and consistent with a human scale.

7. The project is consistent with the City’s design objectives for protection and enhancement of the urbanized forest and open space resources. Open space is distributed around buildings to provide visual relief from structural bulk and a distinct separation from buildings on adjacent sites.

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Appendix B – Housing Constraints B-38
Carmel-by-the-Sea 6th Cycle Housing Element Amendment July 7, 2026

8. All demolitions, remodels, and substantial alterations are consistent with the following findings:
a. The design uses simple/modest building forms and a limited number of roof planes, and a restrained employment of offsets and appendages consistent with the City’s design objectives.
b. The mass of the building relates to the context of other homes in the vicinity that are in conformance with the City’s design guidelines related to mass and scale. c. The development is similar in size, scale, and form to buildings on the immediate block and neighborhood.
d. The development does not require removal of any significant trees unless necessary to provide a viable economic use of the property or protect public health and safety. All moderately significant trees have been protected to the maximum extent feasible. All buildings and structures will be set back a minimum of six feet from significant trees.

To eliminate potential subjectivity and provide clarity in the design review and development process, the City intends to adopt Objective Design and Development Standards for multi-family residential developments. Program 1.4.B establishes and monitors the creation and adoption process for the standards.

Forest and Beach Commission Review
Upon submittal of design study, building permit or other application for alteration of a property, the Forest and Beach Commission shall determine if the subject property requires the removal or pruning of a significant tree. A tree removal permit is required for trees on vacant lots or lots planned for new construction, alterations, or rebuilding that meet the following standards (CMC 17.48).

A. Removal, replacement, cutting down, or destruction of any tree identified on the Carmel-bythe-Sea Recommended Tree List (see LUP Appendix G2: Forest Management Plan) having:
i. An average diameter of greater than two inches; or
ii. A circumference greater than six and one-fourth inches, measured at a point four and one- half feet above the ground level.

B. Any alteration of a tree that would remove:
i. Roots greater than two inches in diameter; or
ii. Live limbs greater than four inches in diameter.

Removal of Pine, Redwood, Oak, and Cypress Trees When Not Related to Construction. A tree removal permit shall be required for the removal, replacement, cutting down, or destruction of any pine, redwood, oak, or cypress tree having:

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Appendix B – Housing Constraints B-39
Carmel-by-the-Sea 6th Cycle Housing Element Amendment July 7, 2026 A. A diameter equal to or greater than four inches measured at a height 4.5 feet above the ground; or
B. A circumference greater than 19 inches.

Removal of Other Tree Species When Not Related to Construction. A tree removal permit shall be required for the removal, replacement, cutting down, or destruction of any species of tree capable of growing to a minimum of 25 feet in height growing on private property and having:

A. A diameter equal to or greater than 10 inches; or
B. A circumference greater than 32 inches.

City staff are responsible for informing the applicant of the deficiencies in the application within 15 working days of receipt of the application. Once an application is determined to be complete, the application will be scheduled for review. This consists of one (1) public hearing, unless information is received after the Forest and Beach Commission agenda packet has been distributed, which may provide grounds for continuation of the application.

If a subject property is determined to have significant trees, a permit application must be submitted, which the Forest and Beach Commission review and make a determination whether a significant tree is involved. The Forest and Beach Commission must make the following required findings.

1. That removal of the tree is required to protect public health or safety; or

2. That the following four conditions exist:
a. The existing site is vacant or is developed to an extent less than one-third of the base floor area allowed by the zoning applicable to the site; b. The available land area of the site not occupied by significant trees (including land within six feet of the trunk of significant trees) does not adequately and practically provide space for development of at least one-third of the base floor area allowed by the zoning for the site;
c. The issuance of a variance for development in one or more setbacks has been considered and would not provide a remedy or would be inappropriate due to a significant overriding inconsistency with another policy or ordinance of the LCP; and d. Failure to authorize removal of the tree(s) would deprive the owner of all reasonable economic use of the property. (Ord. 2004-02 § 1, 2004; Ord. 2004-01 §1, 2004).

While the findings of approval for removal of trees are objective, the Forest and Beach Commission may condition a permit on replacement of trees planted at a place, of a species, and of a size designated by the City Forester or Forest and Beach Commission. This may pose a constraint on the development of housing, as the person requesting the permit will be required to pay the cost of obtaining and planting the replacement trees. Further, finding 2.B poses a constraint to the development of multifamily housing on the basis of base floor area. Program 1.3.F has been included in the Housing

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Appendix B – Housing Constraints B-40
Carmel-by-the-Sea 6th Cycle Housing Element Amendment July 7, 2026 Element to review and modify the required finding to remove constraints to the development of multifamily housing (see Chapter 2).

Additionally, the potential for multiple hearings by different review bodies may pose a barrier to development due to timeliness. To remove barriers to the development of multi-family housing, the City has developed Program 3.1.F, which enables expedited permit processing procedures, including the implementation of a concurrent permitting procedure for projects that require several permits (see Chapter 2). For example, if a project requires Forest and Beach Commission review in addition to general planning entitlements, the highest-level review authority would review the project details and approve or disapprove the project. This will streamline the permitting process and eliminate the potential for multiple hearings.

Historic Resources Review
Upon submittal of a design study, building permit or other application for alteration of a property, the City shall determine if the subject property contains historic resources and is therefore eligible for the Carmel Inventory of Historic Resources (updated annually). If it is determined that the property contains historic resources, the applicant shall be required to obtain a determination of consistency with the Secretary of the Interior’s Standards for the Treatment of Historic Properties as part of the project review process, as required by CEQA and state law.

Minor Alterations
Determinations of consistency for minor alterations shall be reviewed by City staff for compliance with the Secretary of the Interior’s Standards for the Treatment of Historic Properties. City staff review times typically take between three to six months. Minor alterations that are found not to comply with the Secretary’s Standards shall be considered and processed as major alterations requiring an evaluation by a qualified professional and final action by the Historic Resources Board. Decisions of the Board are appealable to the City Council.

Major Alterations
Determinations of consistency for major alterations shall require an evaluation by a qualified professional and shall be reviewed and approved by the Historic Resources Board. Decisions of the Board are appealable to the City Council. Review times by the Historic Resources Board typically take between 6 and 8 months.

The City’s current approach to conserving historic resources does not present a constraint to constructing new residential units. The City values historic resources and has an associate planner on staff that is trained in historic preservation and facilitating rehabilitation of historic properties. The City will ensure that proper record keeping is conducted to track historic resources within the City, and do its due diligence to ensure these resources are utilized efficiently.

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Appendix B – Housing Constraints B-41
Carmel-by-the-Sea 6th Cycle Housing Element Amendment July 7, 2026 Community Planning and Building Fees
The City charges fees and assessments to cover the costs of processing permits. Processing fees are commensurate with the fees for the rest of the County of Monterey. Compared to the high costs of undeveloped, unimproved land and high site development costs in the City, processing and connection fees are negligible and, therefore, do not present a constraint to development. However, the partial waiving of such fees would help reduce the cost of any proposed affordable housing. The City’s current fee schedule is shown below in Table B-8, Summary of Community Planning & Building Fees (2023-2024). Note the summary provided in Table B-8 is a summary, and excludes fees related to such items as commemorative bench dedications, signage, public works/forestry, public safety, and administrative services. The full fee schedule is available online at the City’s website.6 Table B-8 Summary of Community Planning & Building Fees (2023-2024) Application/Permit Type Fee
Design Study and Review
Track 1 Design Review/Study - Minor $690 per application Track 1 Design Review/Study - Major $990 per application Track 1 Design Rev/Study-Streamline $355 per application Track 1 Design Rev/Study - Referral to Planning
Commission
$1,785 per application in addition to the base Track 1 fee Track 1 Design Rev/Study-Referral to Historic Resources Board
$1,785 per application in addition to the base Track 1 fee Track 2 Design Review - Minor $3,910 per application
Track 2 Design Review - Major $5,935 per application
Track 2 Design Rev - Major New Commercial Building $2,830 per application plus a deposit determined by staff with charges at the fully allocated hourly rates for Project Planner Preliminary Site Assessment $1,495 per application
Volumetric Analysis $135 per application plus $1,500 deposit with charges at the fully allocated hourly rates plus any outside costs.

Use Permit and Other Services
Use Permit $3,060 per application
Use Permit Amendment $2,765 per application
Temporary Use Permit $165 per application
Restricted Comm Use Transfer Request $565 per application Water Credit Transfer Request $3,100 per application
Variance $1,790 per application
Pre-Application Review - Staff $1,365 per application with 50% of this fee credited towards future planning fees for this project.

Preliminary Review - Planning Commission $3,750 per application with 50% of this fee credited towards future planning fees for this project.

Coastal Dev. Permit - Development $175 per application - Added to other Planning fees Coastal Dev. Permit - Event $740 per application
Landscape Plan Check/Inspection $690 per plan/inspection Planning Technical Assistance Fully allocated hourly rate after 15 mins Tobacco Retail License Current fee as adopted by the Monterey County Board of Supervisors
6 https://ci.carmel.ca.us/sites/main/files/file-attachments/fy_23-24_master_fee_schedule.pdf?1694542754

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Appendix B – Housing Constraints B-42
Carmel-by-the-Sea 6th Cycle Housing Element Amendment July 7, 2026 Application/Permit Type Fee
Extraordinary Development Deposit amount TBD based on scope of project, with charges at the fully allocated hourly rates plus any outside costs
Amendments, Annexations, and Agreements
Specific Plan/Specific Plan Amendment General Plan
Amendment
Sphere Of Influence Amendment Zoning Code Amendment
$5,000 deposit with charges at the fully allocated hourly rates plus outside costs
Annexation Development Agreement $10,000 deposit with charges at the fully allocated hourly rates plus outside costs
Environmental Review, Maps, and Lot Lines
Environmental Review (IS/ND/EIR) Contract cost plus 10% Environmental Notice of Exemption $495 per application plus County fees Mitigation Monitoring $3,000 deposit with charges at the fully allocated hourly rates plus outside costs.

Tentative/Final Map $4,000 deposit with charges at the fully allocated hourly rates plus any outside costs.

Amended Final Map $1,000 deposit with charges at the fully allocated hourly rates plus any outside costs.

Certificate Of Compliance $750 per application plus actual contract cost Lot Line Adjustment/Subdivision - Planning Commission $1,055 per application plus actual contract cost Lot Merger - Staff Review $855 per application plus actual contract cost Historic Evaluation
Prelim (Phase 1) Historical Evaluation - Staff $310 per application Phase 1 Historic Evaluation - Qualified Professional $405 per application plus actual cost for Historian review with $1,500 deposit
Phase 2 Historic Evaluation-Historic Resources Board
Review
$2,040 per application plus actual cost for Historian review with $1,500 deposit
Appeal To Historic Resources Board $1,500 per application plus actual cost for Historian review with $1,500 deposit
Mills Act Contract Processing $3,430 per application
Mills Act Maintenance Plan Review $1,000 deposit
Mills Act 5-Year Inspection $500 deposit
Mills Act 10-Year Maintenance Plan Review $1,000 deposit Determinations, Extensions, and Appeals
Planning Commission Code Determination $1,740 per application Zoning Compliance Determination Fully allocated hourly rates for all personnel involved with a one hour minimum
Time Extension - Staff $400 per application
Time Extension - Planning Commission $1,080 per application Time Extension - City Council $1,045 per application
Public Hearing Continuance - Planning Commission $830 per continuance Public Hearing Continuance - Council $835 per continuance Appeal To Planning Commission $1,945 per appeal – No charge for appeals of Coastal Development Permits (CDPs) in the Coastal Commission Appeal Jurisdiction (CMC 17.20.140)
Appeal To City Council $2,085 per appeal - No charge for appeals of Coastal Development Permits (CDPs) in the Coastal Commission Appeal Jurisdiction (CMC 17.20.140)

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Appendix B – Housing Constraints B-43
Carmel-by-the-Sea 6th Cycle Housing Element Amendment July 7, 2026 Application/Permit Type Fee
Building Services
Building Relocation Deposit determined by staff with charges at the fully allocated hourly rates for all personnel involved plus any outside costs Large Family Day Care (Residential) $2,320 per application General Plan Update 3.5% of all Building & Safety permits Building Plan Check Based on Building and Safety Construction Valuation Building Inspection Based on Building and Safety Construction Valuation Building Re-Inspection $145 per re-inspection
Permit Application Extension $95 per extension (maximum of 4) Permit Extension $150 per extension (maximum of 2)
Building Permit Pre-Applic. Confer. $340 per application Building Single Trade Permit $165 per permit
On-Site Driveway Permit $395 per permit
Solar Plan Check/Inspection Permit Plan Check and Inspection- $450 plus $15 per kW over 15kW Re-Roof Permit $260 per permit
Building Board Appeal $1,135 per appeal
Duplicate Inspection Card $60 per card
Building Technical Assistance Charge the fully allocated hourly rate for all personnel involved after 15 minutes.

Stop Work Investigation $620 per investigation plus double the permit fee Temporary Certificate Of Occupancy $225 per application Alternate Materials/Methods Review $220 per application plus actual cost of City Staff for all time over one hour.

Building Phased Work Request $315 per application
Building Technology Surcharge $8 per permit
Encroachment Permit
Temporary Encroachment Permit $345 per permit
Permanent Encroachment Permit Other - $475 per permit and $4.25/lineal foot or $432 per permit and $2.13/lineal foot (aerial installation) Plus cost of damage to public right-of-way or street as determined by the Public Works Director.

Traffic control plan review/inspection $675 per review plus $405 per each additional review Use of credit card/debit card 2.5% of charged amount
Source: City of Carmel-by-the-Sea Fee Schedule Effective September 9, 2023 – June 30, 2024 In comparison with other jurisdictions in the County of Monterey, the fees in Carmel-by-the-Sea for new residential projects – both single-family and multi-family units – are generally in line. Table B-9, provides a comparison between the cities of Carmel-by-the-Sea, Pacific Grove, and Monterey, which are geographically, socioeconomically and demographically similar in size and types of residential development. Data for Monterey County has also been provided for context.

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Appendix B – Housing Constraints B-44
Carmel-by-the-Sea 6th Cycle Housing Element Amendment July 7, 2026 Table B-9 Jurisdictional Comparison of Average Design Review/Study Fees Residential Development
Application Type(s) Carmel-by-the- Sea Pacific Grove City of Monterey Monterey County Staff/Admin $6901/$9902 $2413/9784 $3625/$1,2986 $5507/$1,6508 Non-Staff/Admin (i.e., Planning
Commission)
$3,9109/5,93510 $3,48111/$4,25912 $2,10213/$4,62014 $3,30015 Source: City of Carmel-by-the-Sea Fee Schedule Effective September 9, 2023 – June 30, 2024; City of Pacific Grove Master Fee Schedule Effective July 1, 2023 – June 30, 2024; City of Monterey Master Fee Schedule, Fiscal Year 2024; Monterey County Article IX-Land Use Housing & Community Development Fee Schedule.

Notes:

1. Track 1 Design Review/Study - Minor

2. Track 1 Design Review/Study – Major

3. Counter Review & Determination – no new square footage

4. Counter Review & Determination - new square footage

5. Architectural Review – Admin Minor

6. Architectural Review – Admin Major

7. Design Approval – Over the Counter

8. Design Approval – Administrative, review & approval required, no hearing required

9. Track 2 Design Review/Study – Minor

10. Track 2 Design Review/Study - Major

11. Architectural Permit – Single Family

12. Architectural Permit – Multifamily four units or less

13. Architectural Review – ARC Minor

14. Architectural Review – ARC Major

15. Design Approval, public hearing required
Note: The design study fees provided above do not reflect fees incurred if historic evaluation(s) is required, or a Preliminary Site Assessment, or other potentially relevant fees. See Table B-4 for a Summary of Community Planning & Building Fees, and Table B-6 for Estimate of Total Development Fees Imposed.

The City is not a full-service municipality; several agencies and special districts levy fees on new development for the provision of basic urban services. These agencies and special districts include the following.
 California American Water (Cal-Am);
 Monterey Peninsula Water Management District;
 Carmel Unified School District;
 Carmel Area Wastewater District;
 Carmel Fire Department (service provided by contract with Monterey Fire Department; and  Transportation Agency for Monterey County (TAMC).

Special district fees add to development costs in the City. Carmel is under the jurisdiction of the Monterey Peninsula Water Management District (water district) and receives its water from the California-American Water Company (Cal-Am).

Cal-Am charges non-refundable Connection Fees as determined by CPUC guidelines. The fee is based on the meter size which is as follows:

1. ⅝” Meter - $3,000 (single-family)

2. 1” Meter - $5,000 (small multi-family)

3. 1½” Meter - $10,000 (large multi-family

4. 2” Meter - $16,000 (large volume requirement ex. hotel.)

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Appendix B – Housing Constraints B-45
Carmel-by-the-Sea 6th Cycle Housing Element Amendment July 7, 2026 The MPWMD has permit authority over the production and distribution of all water supplies within the Monterey Peninsula region, and allocates water supplies to cities and County areas within its jurisdiction. According to the water district, the City, as of June 2023, has a total available water allocation of 2.661-acre feet, which represents only three (3) percent of the water district’s total available allocation across the district, which includes all of the Monterey Peninsula south to Carmel Valley and portions of the Santa Lucia Range. The current MPWMD permit fees are governed by the Fees and Charges Table (effective August 16, 2021) and start at $1,800 plus $90 per hour for more than 20 hours.

The Carmel Unified School District requires the payment of an impact fee of $0.49 per square foot for new residential construction. The school district does not offer any discounts for the payment of impact fees.

The Carmel Area Wastewater District charges a new residential connection fee of $8,242.66 and charges an annual rate of $1,005.94 for residential uses.

TAMC established a Regional Impact Fee (RDIF) program to address required mitigation for traffic impacts. Accessory Dwelling Units under 750 square feet are exempt from impact fees. Carmel-by- theSea is located with Zone 3: Peninsula/South Coast benefit zone and also subject to additional infill fee.

Impact fees are calculated using an online spreadsheet and fees range from $4,599.04 for an Above Moderate single-family home, to $9,313.70 for a 5-unit Low-Income apartment to $28,161 for a 10-unit Above-Moderate condo or townhome. Impact fee discounts are applied to affordable units and are dependent on the affordability level.

Fees charged by these outside agencies vary according to project types and size and increase development costs. The City does not control fees for outside agencies, but outside agency fees are a constraint and add to the overall cost of development. See Table B-10, Estimates of Total Development Fees Imposed, below.

Table B-10 Estimate of Total Development Fees Imposed
Single-Family* Multi-Family (10 units) **
Track 2 Major Design Study $5,935 $5,935
Preliminary Site Assessment (includes fee for
Phase I Historic Evaluation)
$1,495 N/A
Phase II Historic Evaluation (applicable only for
existing historic buildings proposed for expansion)
$2,040 plus $1,500 consultant deposit N/A
Volume Study $135, plus $1,500 consultant deposit N/A
Use Permit N/A $3,060
Building Permit fee $4,872 $9,872
Subtotal $17,477 $18,867

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