The Housing Element is an excellent opportunity for Clayton to mitigate climate change and negative environmental impacts in Clayton. In California, about 40% of climate pollution comes from transportation, the bulk of that from gasoline- and diesel-burning vehicles on our roads.
Building more of the right housing in the right places can mitigate climate impacts and reduce housing costs and inequities. But in order to do this we need to change the way we build: as we encourage and engage in equitable, fire-safe infill development, it is imperative that we think about how we can really maximize the benefits that we’re getting from our land. We need to build more infill housing in existing urban areas and that infill housing — and all housing — needs to include a healthy amount of green infrastructure like bioswales, carbon sequestering trees that provide canopy cover and can mitigate the urban heat island effect, native plants that can provide habitat, and other nature-based solutions to climate risks.
We believe that by adjusting zoning and development standards strategically, Clayton can exercise maximum control over its future while also reducing greenhouse gas (GHG) emissions and addressing our climate, housing, and equity crises. By considering the feasibility of proposed housing sites, Clayton can ensure the Department of Housing and Community Development (HCD) deems the new housing element legally compliant and accepts Clayton’s housing element. 1 As Clayton begins their update process, we would like to offer three priorities to base Clayton’s policies and actions around.
1. Increase density within existing communities in non-high fire severity zones and away from flood zones. We must build more housing in existing communities to create healthy, resilient, and affordable housing and protect our open spaces to provide climate benefits. Concentrating growth in places with low or even moderate wildfire hazard risk and outside of anticipated flood zones is necessary to address the need for building more homes while avoiding unnecessary pressure for sprawl and unsustainable shoreline development. a. Clayton has many commercial sites that could be strengthened through the addition of mixed-income or affordable housing. Large parking lots and setbacks of legacy office development represent opportunities to create mixed-uses that lower greenhouse gas emissions, create vitality and increase walkability. b. Increase heights and remove restrictions on density in non-fire or flood severity areas where existing or new high-capacity transit is planned to encourage housing and the creation of mixed-use corridors.
2. Ensure fair and inclusive zoning policies that make housing accessible to everyone.
The compounding crises of climate change and housing affordability disproportionately impact low-income and communities of color. In order to address our housing, climate, and equity crises, we need to change the stigma around multifamily home structures.
Furthermore, current housing policies have resulted in people being unable to afford to live where they work, creating long unsustainable commutes—both for the environment and for our social fabric. Cities need to actively plan for diverse housing options that are accessible to people of all backgrounds and income levels using the principles of Fair Housing. a. Affordable Housing - Sites to meet Clayton’s low and very low-income RHNA should focus on feasibility. This means identifying good locations near transit, schools and jobs. Such sites will ensure that affordable housing developers seeking will be competitive in applying for funding. Pleasanton also should try to align such the densities of these opportunity sites with affordable housing finance mechanisms.
Typical Low-Income Housing Tax Credit affordable housing developments contain between 40 and 75 units. The density yields of sites should reflect this rather than simply reverting to the statutory minimum density of 30 dwelling units per acre for low-income and very low-income housing under RHNA (the so-called Mullin Densities) regardless of the size of the site.
b. Missing Middle – Clayton should also focus on creating opportunities for “missing middle” housing like townhouses and duplexes. In Clayton, 90.4% of housing is owner occupied, the majority of which is single-family homes. Multifamily housing provides housing opportunities for families who cannot afford to buy or rent single-family homes in Clayton.
3. Require nature-based solutions for climate resilience in future developments. To ensure that Clayton’s current and future homes are resilient to climate risks like wildfire and flooding, Clayton must be better equipped to help communities struck by natural disasters rebuild and respond rapidly and inclusively. Clayton should require developers to integrate green infrastructure into development and the public right-of-way adjacent to developments at a level that exceeds water quality mandates and ensures that the community has an opportunity to provide input. New infill development has the opportunity to rejuvenate parts 2 of Clayton that currently contribute negatively to GHG emissions, urban heat islands and pose fire and flood risks.
a. Implement nature-based adaptation - or consider relocating - critical public assets threatened by sea-level rise or rising groundwater.
b. Require and incentivize green infrastructure in future developments and when possible, use green infrastructure as a preferred alternative. c. Consider permit streamlining for new housing that exceeds current green infrastructure requirements.
d. Reduce mandatory parking minimums to encourage environmentally friendly transit modes like walking, cycling, taking public transit, and purchasing fewer cars.
To support our vision for Clayton, Greenbelt Alliance and other partnering organizations have crafted a go-to guide for accelerating equitable adaptation to the climate crisis; The Resilience Playbook. The Playbook brings together curated strategies, recommendations, and tools to support local decision makers and community leaders wherever they are in their journey.
We look forward to continuing to engage with Clayton and the community on how this vital work can move forward in the new year.
Sincerely,
Zoe Siegel
Director of Climate Resilience,
Greenbelt Alliance
Karen Rosenberg
Resilience Fellow, Greenbelt
Alliance
Derek Sagehorn
Housing Element Coordinator,
East Bay for Everyone
Laura deTar
Executive Director, Fresh
Approach
Tina Neuhasel
President and CEO,
Sustainable Contra Costa
Lynda Deschambault
Executive Director,
Contra Costa Climate Leaders
Alexi Lindeman
Chair, Sustainable Leaders In
Action
Peri Lindeman
Youth Environmentalist,
Antioch
Abigail Stofer
Youth Environmentalist,
Walnut Creek
Stella Lin
Youth Environmentalist, San
Ramon
Olivia Johnson
Youth Environmentalist,
Brentwood
Ian Cohen
Youth Environmentalist,
Brentwood
Selam Asfaw
Youth Environmentalist,
Brentwood
Diana Salazar
Youth Environmentalist,
Brentwood
Gabriel Vitan
Youth Environmentalist,
Brentwood
Xaylee Minchey
Youth Environmentalist,
Brentwood
Rachel Kimball,
Youth Environmentalist,
Antioch
Kyle Suen
Youth Environmentalist,
Walnut Creek
3 January 4, 2022
Dana Ayers (via email - [email protected])
Community Development Director
City of Clayton
6000 Heritage Trail
Clayton, CA 94517
To Whom It May Concern,
East Bay for Everyone and the undersigned organizations write to provide comments on the City of Clayton’s 6th Cycle Housing Element efforts for the January 4, 2022 City Council meeting.
As a preliminary matter we note that AB1397 requires recycled and nonvacant sites in a previous housing element to be rezoned for by-right development of 20% low-income projects. If the proposed site is vacant and recycled from the previous two cycles, it must also be rezoned for by-right approval.
Of the sites identified in the Preliminary 6th Cycle Sites (Attachment 3 of the staff report) compiled by the City of Clayton and MIG, approximately 70% are recycled from the 4th and/or 5th cycle housing elements.
The following preliminary sites are vacant and have been part of the City of Clayton’s Housing Element for the 4th and 5th cycle housing elements:
● Site E - proposed 20 dwelling units/acre (DUA) and is vacant. ● Site G - proposed 20 DUA and is vacant.
● Site N - proposed 20 DUA and is vacant.
1 Clayton Preliminary Sites for 6th Cycle HE
January 4, 2022
These sites should be re-zoned for by-right approval as required by AB1397.
In addition the following sites are non-vacant and have been previously part of 4th or 5th cycle housing elements:
● Site F - proposed 20 DUA, previously part of the 5th cycle and contains three existing residential uses.
● Site H - proposed 20 DUA, previously part of 4th and 5th cycles and contains existing residential uses.
● Site I - proposed 10 DUA on 13 acres, previously part of the 4th cycle and contains two existing residential uses.
○ The density of this site should be increased to 20 DUA or more in order to maximize the likelihood of development given the existing high value residential uses.
● Site J - proposed 5 DUA and previously part of the 4th cycle and 5th cycles. Two of the parcels are vacant greenfield locations. The northern third parcel contains three large existing residential uses.
○ It is unlikely that these residential uses will be redeveloped at a density of 5 DUA. ○ Furthermore the southern two parcels are 1000 feet from an active quarry. ○ This site should be removed from consideration.
● Site M - proposed 20 DUA and previously part of the 4th cycle and 5th cycles. This site contains existing residential and agricultural uses.
● Site O - proposed 20 DUA, previously part of 4th and 5th cycles and contains existing residential uses.
The above-mentioned sites should be rezoned to allow for by-right development for projects that include 20% low-income units as required by AB1397, excluding Site J which should be removed entirely from sites.
In addition we offer the following comments:
● Site K - proposed 3 DUA, previously part of the 5th cycle. This site is on a steep hillside between existing residential uses. There are significant difficulties in developing this site and it should be removed from consideration.
● Sites P, Q, and R are welcome additions to the site inventory. Please provide a copy of a letter from the property owners stating they are open to developing the site at the prescribed density. We encourage the City of Clayton to partner with East Bay Housing Organizations to highlight these opportunities for development. ● Sites A and S - proposed 20 DUA, These sites are existing churches(Saint John's Episcopal Parish and Clayton Community Church). Please provide a copy of a letter from the property owners stating they are open to developing the site at the prescribed density. The church-owned properties will likely require collaboration with non-profit 2 From: T Cianfrano
To: Housing Element
Subject: New Housing Element requirements
Date: Friday, May 20, 2022 9:00:00 AM
Much as been said about the impact of adding 560 units in this round of the housing element. For the most part, the impacts have focused on traffic, air quality, fire escape routes, etc . No one has addressed the impact on the water supply to support this and other proposed growth. The only factor considered is the need for “affordable” housing. These homes can be built much faster than infrastructure components.
All indications is that the drought will continue and in fact, worsen due to climate change. What is being done to address “ALL” impacts?
Sent from Mail for Windows
From: William P. Jordan
To: Dana Ayers; Janet Calderon
Subject: Housing Element Item on Agenda
Date: Tuesday, May 24, 2022 4:59:21 PM
Please consider adding 6530 and 6500 Marsh Creek Rd. to have 30 units as you have done to 6470 Marsh Creek Rd.
Also, the commission should know construction documents for all three building permits are finished and Dana has received architectural and landscape last week for her review.
Once approved, we’ll submit to county.
Btw, its dicey down at the county building department for permits and we are hopeful to get them by deadline.
Time is of the essence for our submittals.
Sent from my iPhone
Clayton Preliminary Sites for 6th Cycle HE
January 4, 2022
housing organizations. We encourage the City of Clayton to partner with East Bay Housing Organizations to highlight these opportunities for development. ● We encourage the City of Clayton to remember that Mullin Densities of 20 DUA are merely a floor rather than a ceiling. Therefore, any reduction in units below the RHNA shortfall due to removal of potential sites should be re-allocated to redeveloped or new sites above the 20 DUA threshold of Mullin Densities.
● In looking for replacement sites, we encourage Clayton to consider adding additional density on sites within walking distance of downtown, with little or no parking minimum.
These locations would be perfect for seniors looking to downsize or car-light families.
We look forward to continuing to engage with the City of Clayton as it develops its plan to accommodate growth and inclusive development. If you are conducting meetings with community organizations to discuss the Housing Element this spring, we would love to take part.
Sincerely,
Maxwell Davis
East Bay for Everyone
Zoe Siegal
Greenbelt Alliance
Zac Bowling
East Bay YIMBY
Rafa Sonnefeld
YIMBY Law
cc: [email protected]
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