Coronado City Council
April 9, 2024

City of Coronado Page 1824
Attachment 9
Report List
Report No. Other IDs Year Author(s) Title Affiliation
SD-11460 NADB-R - 1131460;
Other - PROJECT 05-
251;
2007 REDDY, SEETHA N. A PROGRAMMATIC APPROACH FOR

NATIONAL REGISTER ELIGIBILITY

DETERMINATIONS OF PREHISTORIC

SITES WITHIN THE SOUTHERN COAST

ARCHAEOLOGICAL REGION, CALIFORNIA

STATISTICAL RESEARCH,
INC.

Voided - REDDY19
SD-12732 NADB-R - 1132732;
Other - CONTRACT
NUMBER N68711-
93-M-1141;
1994 MANLEY, WILLIAM R. HISTORIC AND ARCHAEOLOGICAL

RESOURCES PROTECTION PLAN (HARP)

FOR NAVAL AMPHIBIOUS BASE

CORONADO, CALIFORNIA
MANLEY, WILLIAM R.

Voided - MANLEY17
SD-13988
SD-16023
NADB-R - 1133988;
Voided -
YATSKOA03
2012 YATSKO, ANDY HAWAII-SOUTHERN CALIFORNIA

TRAINING AND TESTING ACTIVITIES,

VARIOUS OCEAN AREAS, SOUTHERN

CALIFORNIA

UNITED STATES NAVY
NADB-R - 1136023; RECON
Other - RECON
Project Number
4224A;
Other - Subcontract
No. WG-03-S-047
2008 Underwood, Jackson EVALUATION OF SEVEN POTENTIAL
ARCHAEOLOGICAL SITES ON THE U.S.

NAVY SILVER STRAND TRAINING

COMPLEX, CORONADO, SAN DIEGO

COUNTY, CALIFORNIA
SD-17955 NADB-R - 1137955 2017 BRUCE, BONNIE and
CARRIE D. WILLS

CULTURAL RESOURCES RECORDS

SEARCH AND SITE VISIT RESULTS FOR

ENVIRONMENTAL

ASSESSMENT
AT&T MOBILITY, LLC CANDIDATE SD0399 SPECIALISTS, INC.
(NAVY GATEWAY INN), 3628 TULAGI

ROAD, SAN DIEGO, SAN DIEGO COUNTY,

CALIFORNIA

City of Coronado Page 1825
Attachment 9
Coronado HEU - Resources - APE
PrimCo PrimNo TrinNo Label OtherID DocSource DigDate DigOrg Notes Confidenti PNumber Trinomial Shape None Identified
City of Coronado Page 1826
Attachment 9
Coronado HEU - Historic Addresses - APE

CHRONOLOGICA

PNUMBER TRINOMIAL PLACEMENT L SITE TYPE
None Identified
City of Coronado Page 1827
STATE OF CALIFORNIA - BUSINESS, CONSUMER SERVICES AND HOUSING AGENCY GAVIN NEWSOM, Governor

DEPARTMENT OF HOUSING AND COMMUNITY DEVELOPMENT

DIVISION OF HOUSING POLICY DEVELOPMENT
2020 W. El Camino Avenue, Suite 500
Sacramento, CA 95833
(916) 263-2911 / FAX (916) 263-7453
www.hcd.ca.gov
March 5, 2024
Richard Grunow, Director
Community Development Department
City of Coronado
1825 Strand Way
Coronado, CA 92118
Dear Richard Grunow:

RE: City of Coronado’s 6th Cycle (2021-2029) Revised Draft Housing Element Thank you for submitting the City of Coronado’s (City) revised draft housing element received for review on January 17, 2024. Pursuant to Government Code section 65585, the California Department of Housing and Community Development (HCD) is reporting the results of its review.

The revised draft element addresses some of the findings from HCD’s prior reviews (May 12, 2021, November 8, 2021 and December 15, 2023); however, in many cases, the element was not revised to address HCD’s prior review. Additionally, in some cases, the element removed or modified revisions from prior versions and therefore no longer addresses the statutory findings from prior reviews. Revisions will be necessary to substantially comply with State Housing Element Law (Gov. Code, § 65580 et seq). The enclosed Appendix describes the revisions needed to substantially comply with State Housing Element Law.

In addition, pursuant to Assembly Bill 1398 (Chapter 358, Statutes of 2021), a jurisdiction that did not adopt a compliant housing element within one year from the statutory deadline cannot be found in compliance until rezones to make prior identified sites available or accommodate a shortfall of sites are completed pursuant to Government Code sections 65583, subdivision (c)(1)(A), and 65583.2, subdivision (c).

As this year has passed and necessary rezones are not complete (e.g., Program H-1.F (General Plan Update Program) and Program H-1.G (Development Standards)), the housing element will remain out of compliance until the City completes all the necessary rezones.

Public participation in the development, adoption, and implementation of the housing element is essential to effective housing planning. Throughout the housing element process, the City should continue to engage the community, including organizations that represent lower-income and special needs households, by making information regularly Attachment 10
City of Coronado Page 1828
Richard Grunow, Director

available and considering and incorporating comments where appropriate. Please be aware, the City must post any revisions to the element on the City’s website and email a link to all individuals and organizations that have previously requested notices relating to the local government’s housing element at least seven days before submitting to HCD.

Several federal, state, and regional funding programs consider housing element compliance as an eligibility or ranking criterion. For example, the CalTrans Senate Bill (SB) 1 Sustainable Communities grant, the Affordable Housing and Sustainable Communities program, and HCD’s Permanent Local Housing Allocation consider housing element compliance and/or annual reporting requirements pursuant to Government Code section 65400. With a compliant housing element, the City will meet housing element requirements for these and other funding sources.

We are committed to assisting the City in addressing all statutory requirements of State Housing Element Law. Please note that under the stipulated judgment between the City and HCD, the City is required to adopt a substantially compliant housing element no later than April 16, 2024. HCD welcomes the opportunity to meet with the City and provide technical assistance on future submittals. If you have any questions or need additional technical assistance, please contact Sohab Mehmood, of our staff, at [email protected].

Sincerely,
Paul McDougall
Senior Program Manager
Enclosure
Attachment 10
City of Coronado Page 1829
City of Coronado’s 6th Cycle (2021-2029) Revised Draft Housing Element Page 1 March 5, 2024

APPENDIX

CITY OF CORONADO
The following changes are necessary to bring the City’s housing element into compliance with Article 10.6 of the Government Code. Accompanying each recommended change, we cite the supporting section of the Government Code.

Housing element technical assistance information is available on HCD’s website at https://www.hcd.ca.gov/planning-and-community-development/hcd-memos. Among other resources, the housing element section contains HCD’s latest technical assistance tool, Building Blocks for Effective Housing Elements (Building Blocks), available at https://www.hcd.ca.gov/planning-and-community-development/housing-elements/buildingblocks and includes the Government Code addressing State Housing Element Law and other resources.

A. Housing Needs, Resources, and Constraints

1. Affirmatively further[ing] fair housing in accordance with Chapter 15 (commencing with Section 8899.50) of Division 1 of Title 2…shall include an assessment of fair housing in the jurisdiction. (Gov. Code, § 65583, subd. (c)(10)(A).) Enforcement: The element was revised to describe the different local and state fair housing laws and included a high-level statement that the City complies with all these provisions (p. B-71). However, as found in HCD's prior review, the element must address specifically how the City complies with these laws. Please visit pages 29-30 of HCD Affirmatively Furthering Fair Housing(AFFH) guidance memo:
https://www.hcd.ca.gov/community-development/affh/docs/affh_document_final_4-27- 2021.pdf.

Racially Concentrated Areas of Affluence (RCAA): The element was revised to indicate that subsidies are important to addressing RCAA and building affordable housing (p. B-34).

However, as found in HCD’s prior reviews, the analysis must still address trends, conditions, coincidence with other fair housing factors (e.g., race, highest resource, overpayment), effectiveness or absence of past strategies (e.g., lack of publicly assisted housing and lack of multifamily zoning), local data and knowledge and other relevant factors. Based on the outcomes of a complete analysis, the element should add or modify programs to AFFH and, in particular, add housing mobility strategies to promote housing choices and affordability throughout the City.

2. Analyze any special housing needs such as elderly; persons with disabilities, including a developmental disability; large families; farmworkers; families with female heads of households; and families and persons in need of emergency shelter. (Gov. Code, § 65583, subd. (a)(7).)
Special Needs Households: The element was revised to include a listing of some general resources and proposed programs and policies to address special needs populations (pp. 2-32-34). The analysis also indicated that during the last planning Attachment 10
City of Coronado Page 1830
City of Coronado’s 6th Cycle (2021-2029) Revised Draft Housing Element Page 2 March 5, 2024
period, no special needs units were constructed (p. 5-1), recognizing that the City's efforts to address special needs populations were largely ineffective for eight years. Due to the ineffectiveness of the programs and actions from the last planning period, the element must include a robust analysis identifying and evaluating gaps in resources and significant actions with specific commitments to addressing the needs of these populations.

3. An inventory of land suitable and available for residential development, including vacant sites and sites having realistic and demonstrated potential for redevelopment during the planning period to meet the locality’s housing need for a designated income level, and an analysis of the relationship of zoning and public facilities and services to these sites. (Gov. Code, § 65583, subd. (a)(3).)
Navy Sites: The element identified a portion of the regional housing need allocation (RHNA) to be accommodated on Navy-Owned sites, specifically 374 units, including 305 units for lower-income households. Previous iterations of the element indicated that these units will meet the US census definition of a unit; indicated there are no known barriers to development; that the Navy has acquired funding for these units, and that this project will be completed by the end of the planning period (p. 7-27). To address HCD’s prior reviews, the element was revised to indicate that construction is anticipated to begin in 2029, which differed from previous statements where the element had indicated that construction will be completed by 2028 (p. 7-31). As found in HCD’s prior reviews, the analysis should also discuss any remaining steps for development and a general schedule for development in the planning period. Based on a complete analysis, the element should add or modify programs, as appropriate.

Suitability of Nonvacant Sites: For your information and as noted in HCD’s prior reviews, the housing element relies upon nonvacant sites to accommodate more than 50 percent of the RHNA for lower-income households. The housing element must demonstrate existing uses are not an impediment to additional residential development and will likely discontinue in the planning period. (Gov. Code, § 65583.2, subd. (g)(2).) Absent findings (e.g., adoption resolution) based on substantial evidence, the existing uses will be presumed to impede additional residential development and will not be utilized toward demonstrating adequate sites to accommodate the RHNA.

Electronic Sites Inventory: Pursuant to Government Code section 65583.3, subdivision (b), upon adoption of the housing element, the City must submit an electronic version of the sites inventory with its adopted housing element to [email protected]. The City must utilize standards, forms, and definitions adopted by HCD.

While the City has submitted an electronic version of the sites inventory, HCD notified the City of several corrections needed to process and accept the City’s electronic sites inventory. The City must address any corrections to the sites inventory and resubmit.

The City can reach out to HCD at [email protected] for technical assistance.

Zoning for a Variety of Housing Types (Supportive and Transitional Housing): Previous versions of the element included the appropriate revisions and commitments to address the statutory requirements related to supportive and transitional housing, including byAttachment 10 City of Coronado Page 1831
City of Coronado’s 6th Cycle (2021-2029) Revised Draft Housing Element Page 3 March 5, 2024
right permanent supportive housing (without discretionary action) pursuant to AB 2162 (Statutes of 2018). Specifically, in prior reviews, HCD provided the City with sample language that replaced the statement “ensure alignment” with “review and amend to comply with….” The element was now revised in Program H-5.B (Supportive Housing and Low-Barrier Navigation Centers) to remove HCD’s recommended language and the City’s revised language no longer specifically commits to comply with statutory requirements. Specifically, the revised element continues to state, “ensure alignment.” Furthermore, the revised language now commits the City to “authorizing” supportive and transitional housing rather than “permitting” this use. Lastly, the revised Program indicates that the City will authorize transitional and supportive housing as “comparable uses.” These revisions do not address HCD’s prior reviews and the statutory requirements. The element must commit to permitting transitional and supportive housing as a residential use in all zones and only subject to those restrictions that apply to other residential dwellings of the same type in the same zone. Additionally, the element must commit to amending zoning and procedures to comply with AB 2162 (Statutes of 2018).

4. An analysis of potential and actual governmental constraints upon the maintenance, improvement, or development of housing for all income levels, including the types of housing identified in paragraph (1) of subdivision (c), and for persons with disabilities as identified in the analysis pursuant to paragraph (7), including land use controls, building codes and their enforcement, site improvements, fees and other exactions required of developers, and local processing and permit procedures... (Gov. Code, § 65583, subd. (a)(5).)
Land Use Controls: The element must analyze the impacts of land use controls on housing cost, supply (number of units), and ability to achieve maximum densities and identify and address constraints on development, as follows:
• Heights – The element was revised to state that the City's height requirements are not a constraint to development (p. 3-9). The element also stated that the City recognizes the typical height requirements should include one story for every 10 units per acre and each floor can be measured between 9-12 feet. However, the height requirements are a constraint to development, affordability, supply and achieving maximum densities. The element must include or modify programs to revise the City's height requirements and facilitate achieving maximum allowable densities.

For your information, generally, one story of height for every ten units per acre and 12-feet of height per story are acceptable benchmarks for evaluating heights.

The City’s height requirement particularly for the R-3 and R-4 zone differ from these benchmarks and can have impacts on housing choices, affordability, and ability to achieve maximum densities. For example, the R-4 zone permits 40 units per acre. This would result in a maximum height requirement of no less than four stories and 48 feet. The element must include a commitment to increase height requirements for several zones, including the R-3, R-4, and zones accommodating the City's rezone to accommodate the RHNA.

Attachment 10
City of Coronado Page 1832
City of Coronado’s 6th Cycle (2021-2029) Revised Draft Housing Element Page 4 March 5, 2024
• Parking – HCD’s prior reviews found that the City's parking requirements for multifamily housing projects is considered a constraint and the element must include or modify programs committing to reducing parking requirements for smaller bedroom types (e.g., one space for studio and one-bedroom units) for all multifamily developments irrespective of income levels. Prior versions of the element committed to reducing parking requirements for affordable housing projects. HCD's December 15, 2023 review found that parking should be reduced for multifamily regardless of income. The element was revised to now include Program H-5.M (Parking Standards Evaluation and Amendment) committing to evaluating and identifying strategies to reduce parking requirements. However, while this Program commits to evaluation, identification and exploring alternatives, it does not commit to reducing parking requirements. Further, this Program does not commit to anything beyond studying, evaluating, and exploring. As found in HCD's prior reviews, the element must include a program with specific commitment to reducing parking requirements for smaller bedroom types (e.g., one space for studio and one-bedroom units) for all multifamily developments regardless of income levels.
• Rezones – The City is rezoning sites to accommodate it's RHNA. HCD's prior review found that the element must include program(s) committing to establishing development standards that facilitate achieving maximum densities. The element was revised to include Program H-1.G (Establishment of Development Standards). This Program generally commits to establishing development standards that are similar to other jurisdictions, ensuring that these standards align with community values and are compatible with the community character.

However, as found in HCD's prior review, the Program should specifically commit to establishing development standards that facilitate maximum densities.

Design Review: HCD's prior reviews found that the element must analyze and address the City's design review process, namely the subjective approval findings. The element was revised to include Program H-5.L (Design Review) committing to removing findings related to "inappropriate, incompatible, bizarre, exotic". However, the analysis indicates additional subjective findings and criteria beyond the findings referenced in Program H5.L including but not limited to "harmonious, good, durable quality, etc.," The element must add or modify programs that specifically commit to promoting objectivity and certainty in the design review process.

Constraints on Housing for Persons with Disabilities (Reasonable Accommodation):

HCD's prior reviews found that the City considers impacts on surrounding uses as part of its decision-making criteria when granting a reasonable accommodation and that the element must include a commitment to removing these criterion. The element was revised to include Program H-5.K (Reasonable Accommodation Ordinance). This Program states that the City will still assess whether a reasonable accommodation request "poses a detriment to surrounding uses" (p. 8-37). As found in HCD's prior reviews, a reasonable accommodation should be a unique exception process from a conditional use permit, especially given its importance in addressing barriers to housing for persons with disabilities. The City should not be evaluating impacts on surrounding uses when reviewing a reasonable accommodation request. The Program must commit Attachment 10
City of Coronado Page 1833
City of Coronado’s 6th Cycle (2021-2029) Revised Draft Housing Element Page 5 March 5, 2024
to remove all criteria related to evaluating reasonable accommodation requests for impacts on surrounding uses.

5. Analyze existing assisted housing developments that are eligible to change to non-lowincome housing uses during the next 10 years due to termination of subsidy contracts, mortgage prepayment, or expiration of use restrictions. (Gov. Code, § 65583, subd. (a)(9) through 65583(a)(9)(D).).

HCD's prior reviews found that the analysis of at-risk units must 1) estimate and analyze the costs of replacement versus preserving these units 2) identify of public and private nonprofit corporations known to the City to have the legal and managerial capacity to acquire and manage at-risk units and 3) identify local, state, and federal funding programs. The element was revised to discuss available funding and qualified entities.

However, while the element generally described what could impact the costs for preservation versus replacement of these units (p.6-1), as found in HCD's prior reviews, the element must estimate the actual costs of preserving versus replacing the 55 units at-risk of converting to market rate.

B. Housing Programs

1. Identify actions that will be taken to make sites available during the planning period with appropriate zoning and development standards and with services and facilities to accommodate that portion of the city’s or county’s share of the regional housing need for each income level that could not be accommodated on sites identified in the inventory completed pursuant to paragraph (3) of subdivision (a) without rezoning, and to comply with the requirements of Government Code section 65584.09. Sites shall be identified as needed to facilitate and encourage the development of a variety of types of housing for all income levels, including multifamily rental housing, factory-built housing, mobilehomes, housing for agricultural employees, supportive housing, single-room occupancy units, emergency shelters, and transitional housing. (Gov. Code, § 65583, subd. (c)(1).)
As noted in Finding A3, the element does not include a complete site analysis; therefore, the adequacy of sites and zoning were not established. Based on the results of a complete sites inventory and analysis, the City may need to add or revise programs to address a shortfall of sites or zoning available to encourage a variety of housing types. In addition, the element should be revised as follows:

Program H-4.D (AB 1486 City-Owned Land): The element identified City-Owned sites to accommodate a portion of the RHNA. The element was revised with various actions to facilitate development on City-Owned sites including outreach, requests for proposals (RFP), and exploring partnerships. However, while the element included some actions, several of these actions did not include a specific commitment or a schedule to facilitate these efforts. For example, the element indicated that it would explore partnerships and funding. However, the Program should specifically commit to establishing partnerships and pursuing funding with timelines. Additionally, the element must include a discrete timeline for the various other actions that were listed in this Program including the Attachment 10
City of Coronado Page 1834
City of Coronado’s 6th Cycle (2021-2029) Revised Draft Housing Element Page 6 March 5, 2024
issuance of RFPs, establishing streamlined reviews, and providing development incentives. Lastly, the element should include additional efforts to facilitate development on these sites such as commitment to facilitate entitlements and issue permits by a specific date consistent with the assumptions in the sites inventory.

Program H-1.E (Track Navy Housing Development): HCD’s prior reviews found that this Program must be revised to reflect any remaining steps and a schedule of actions for completing construction of the identified RHNA units on the Navy site. Additionally, previous versions of this program indicated that construction was expected to be complete by 2029 (the end of the planning period). The Program is now revised to indicate that construction is anticipated to begin on the last day of the planning period (p. 8-6). As found in HCD’s prior reviews, this Program should be revised to reflect any remaining steps and a schedule of actions for completing construction of the identified RHNA units on the Navy site.

2. Address and, where appropriate and legally possible, remove governmental and nongovernmental constraints to the maintenance, improvement, and development of housing, including housing for all income levels and housing for persons with disabilities. The program shall remove constraints to, and provide reasonable accommodations for housing designed for, intended for occupancy by, or with supportive services for, persons with disabilities. (Gov. Code, § 65583, subd. (c)(3).) As noted in Finding A4, the element requires a complete analysis of potential governmental constraints. Depending upon the results of that analysis, the City may need to revise or add programs and address and remove or mitigate any identified constraints.

3. Promote and affirmatively further fair housing opportunities and promote housing throughout the community or communities for all persons regardless of race, religion, sex, marital status, ancestry, national origin, color, familial status, or disability, and other characteristics... (Gov. Code, § 65583, subd. (c)(5).)
As found in HCD’s prior reviews, the City is predominantly high and highest resource, higher income, and some neighborhoods are considered RCAA. As a result, the element must include a significant suite of programs to promote housing mobility or housing choices and affordability throughout the City. These programs should not be limited to the RHNA and, instead, target significant and meaningful change.

The element was revised with some additional actions, metrics, and geographic targeting; however, as found in HCD’s prior reviews, the element must include additional actions that promote housing choices and affordability throughout the City.

Additional examples include promoting more housing choices and affordability in other lower-density areas (e.g., missing middle housing types), identifying additional multifamily areas and additional religious institutional sites, and enhancing accessory dwelling units (ADU), junior accessory dwelling units (JADU) or additional conversion of existing space, and home sharing strategies.

Attachment 10
City of Coronado Page 1835
Summary of HCD Review Findings and Responses
Official Findings Letter - received on 12/15/23
Section Topic/Requested Revision Response/Action
All Highlighted changes from last draft?
Informed HCD no redline version for
the first draft as a bulk of it was new
content given all the changes.,
Agreed with HCD that we will include
redline from prelim draft revisions and
on.

Ch. 2 –
Community
Profile
Special needs: Homelessness - Homelessness 2020 counts; update analysis including special needs and AFFH with new PIT counts for 2023 Revised write-up - pg. 2-31 to 2-32
Special needs - full analysis e.g., existing needs, resources, assessment of gaps, proposed policies/programs, factors preventing development
Added write-up identifying the
existing resources and proposed
programs for special needs groups–
pg. 2-32 to 2-34.

ELI - Existing (tenure) and projected ELI HH Added a write-up on quantifying the projections - pg. 2-30
Navy Housing - Current status, remaining steps, barriers, timelines? Added status and development process write-up - pg. 2-27
Housing costs for SF - Need local data Revised write-up with updated data – pg. 2-39
Ch. 3 -
Constraints
On/off site improvements – typical standards? Frontage? Infrastructure updates beyond typical e.g., frontage?
Revised write-up – pg. 3-13 and 3-29
Building codes – any local amendments? Revised write-up – pg. 3-29 Written procedure for SB 35?
Revised write-up to reference
program for SB 35 – pg. 3-34 and pg.
8 - 36
Manufactured homes - Demonstrate compliance; permitted in the same manner as SF homes
Revised write-up – pg. 3-15
Emergency shelters - AB 2339 requirements including zone that allows residential use, PIT count inconsistent, capacity analysis, suitability of sites, suitability of zones, def of ES expanded
Revised write-up – pg. 3-15 to 3-16
SROs - Demonstrate zoning and policies to facilitate Added write-up – pg. 3-14 Attachment 11
City of Coronado Page 1836
Nongovernmental constraints - density requests less than identified in the inventory
Revised write-up – pg. 3-4
Land use controls - program H-2-H; reducing parking for affordable housing and Heights
Revised write-up and referenced
programs - pg. 3-9 to 3-12
Code enforcement – local amendments Revised write-up – pg. 3-29 Fees – cumulative breakdowns
This was not revised as it was already
provided. Was not requested again
in the official findings letter.

Group homes of 7 or more and 6 or fewer – 7 or more Revised write-up – pg. 3-17 RA process – removing surrounding use finding Revised write-up – pg. 3-24 to 3-25 Inclusionary – analysis; incentives for compliance and interactions with SDBL
Revised write-up – pg. 3-23
Permit Process – site plan review; when is it required? Findings? Approval criteria, etc.

Revised Local Processing and Permit
Procedures section to remove
discussion of in-depth site plan
approval discussion and revised
Single Family and Multifamily
Dwellings write-up to address site
plan review – pg. 3-31
Design Review – Analysis Added write-up – pg. 3-33 and
included new program – pg. 8-41
Compliance with state law – SB 35 and transparency requirements (GC 65940.1 (a)(1)(A))
Revised write-up to reference
program – pg. 3-34
Nongov constraints – requests to develop at densities below those identified in the inventory
Revised write-up – pg. 3-4
Ch. 4 -
Housing
Resources
and
Opportunities
Realistic capacity – using max densities? Indicates assuming max density or near max
Carryover from older draft, revised
language, and removed verbiage no
longer applicable to the updated
draft – pg.4-2
Ch. 5 –
Review of
Past
Performance
Special Needs Analysis
Revised section intro statement
regarding accomplishments with
respect to special needs groups and
updated 5th cycle program status
where needed throughout the
section.

Ch. 3 –
Constraints
(continued)
Attachment 11
City of Coronado Page 1837
Ch. 6 – At -
Risk
At-risk analysis - Assessment of risk, replacement vs. preservation costs, qualified entities, funding
Added write-up – pg. 6-1 to 6-4
Ch. 7 – Sites
Inventory
Inventory – APN by acreage and GP
Updated Table 7-16 to add GP
designation and individual acreage
to multi-parcel sites – pg. 7-57 to 7-60
Environmental analysis/conditions - Specific to sites Added environmental constraints write up – pg. 7-32
Ch. 8 –
Housing Plan
AFFH Programs - Geographic targeting, increased actions, metrics Revised programs to add
geographic targeting and metrics
where applicable – AFFH programs
under Goal 3, pg. 8-19 to 8-29
ADUs – Program H-1-A -Include more proactive outreach actions (could loop into Program H-2-I, H-3-E), strengthen incentives, and revise monitoring components
Revised program – pg. 8-3
Rezone program –
Program H-1-F - Need by-right provisions for 20% affordable, minimum density requirements, acreage being rezoned, # of units and sites needing rezone, and commitment to 65583.2 (h) and (i), Martinez vs.

Clovis
Revised program – pg. 8-7 to 8-8
Mid-cycle review –
Program H-1-C - Include stronger commitments to adjustment + add monitoring for carriage homes, pipeline
Revised program – pg. 8-4 to 8-5
Navy housing –
Program H-1-E - Modifications to programs based on analysis Revised program to address status
and next steps – pg. 8-6
Program H-2-J - Include education about permitting and entitlement process + incentives for religious institutions
Revised program – pg. 8-16
Carriage Homes –
Program H-4-A - Outreach and education about available incentives e.g., proactive outreach. Could tie into other programs/efforts related to ADUs and revise monitoring components
Revised program – pg. 8-31
At-risk units – Program H-4-B - Stronger actions for units at-risk of converting during the planning period
Revised program – pg. 8-32 to 8-33
City-owned sites – Program H-4-D - Additional actions, steps, dates Revised program – pg. 8-30 to 8-31 LBNC and Supportive housing - Program H-5-B - Add statutory references to programs
Revised program - pg. 8-34 to 8-35
Program H-5-C - Add zoning and development standards Revised program - pg. 8-38 Program H-5-D - Add amend Revised program - pg. 8-38 to 8-39 Attachment 11
City of Coronado Page 1838
Quantified objectives - Add objectives for rehab and preservation Updated objective figures – pg. 8-39 Sites to be rezoned by income level (lower, Mod, AM, total) Housing Mobility - Program H-1-A – ADUs: Proactive outreach and stronger monitoring.

Revised program – pg. 8-3 to 8-4
Housing Mobility - Program H-2-B – funding: Could make housing mobility by adding a metric e.g., # of affordable units.

Added metrics – pg. 8-11 to 8-12
Housing Mobility - Program H-2-E – HCV: increase HCV allocation:

Revise to also include increase HCV usage through outreach and educational actions.

Revised program – pg. 8-13
Housing Mobility - Program H-2-H – assist in the development of several actions; Add metrics.

Revised program and updated
metrics as applicable – pg. 8-14 to 8-
15 Housing Mobility - Program H-2-J – faith-based properties: Strong potential to be housing mobility program beyond the RHNA when metrics are included and add metrics.

Revised program – pg. 8-16
Housing Mobility - Program H-3-A, Program H-3-B, H-3-C – ELI assistance, special needs and senior households: add metrics, Could add a combined metric for all programs.

Kept as stand along programs but
updated metrics where applicable –
pg. 8-19 to 8-20
Housing Mobility - Program H-4-A – carriage homes: Proactive outreach and stronger monitoring.

Revised program – pg. 8-31
Housing Mobility - Program H-4-D – city-owned land: Additional actions needed.

Revised program - pg. 8-34 to 8-35
Housing Mobility - Program H-2-C – improve referrals to AH units: Add metrics and Expand to beyond the City; improve referrals for residents and the region to AH units in the City.

Added metrics as applicable and
revised program – pg. 8-12
Housing Mobility - Program H-2-G – regional collaboration: Add metrics if possible.

Added metrics where applicable –
pg. 8-14
Housing Mobility - Program H-2-I – advertise available resources: Add metrics, could expand this for regional access by including the housing authority and other regional partners, and could expand to include information materials on other program efforts including ADUs, sites, carriage homes, etc.

Revised program and added metrics
where applicable – pg. 8-15 to 8-16
Housing Mobility - Program H-3-E – AFFH outreach and education:

Add metrics for creating regional access.

Added metrics where applicable –
pg. 8-23 to 8-25
Housing Mobility - Program H-3-I: Could create one combined metric to reflect regional efforts with programs above.

Kept as separate program but
updated metrics where applicable
Ch. 8 –
Housing Plan
(continued)
Attachment 11
City of Coronado Page 1839
and revised program – pg. 8-26 to 8-
29 Appendix BAFFH
Enforcement - Compliance with state and federal FH laws Revised write up adding additional
fair housing laws and a statement
indicating adherence – pg. B-72
RCAA - Expand on analysis, census tract that is mod resource, include local data knowledge, other relevant factors
Revised write-up to provide more
analysis and factors that impact
strategies used to address RCAAs –
pg. B-34
Attachment 11
City of Coronado Page 1840
Official Findings Letter - received on 12/15/23
Section Topic/Requested Revision Response/Action
Ch. 2 –
Community
Profile
Extremely Low-Income Households (ELI): The element must quantify the projected number of ELI households. The projected housing need for ELI households can be calculated by using available census data to determine the number of very low-income households that qualify as ELI households or presume that 50 percent of the regional housing needs allocation (RHNA) for very low-income households qualify as ELI households.

Added a write-up on
quantifying the projections -
pg. 2-30
Ch. 3 -
Constraints
Emergency Shelters: The element was revised to include an updated point-intime count related to the emergency shelters analysis (pp. 3-14). However, this does not address HCD’s prior reviews and recent changes in state laws. As of March 31, 2023, AB 2339 (2022) is now applicable to the City. AB 2339 (2022) specifies how cities and counties plan for emergency shelters and ensure sufficient and suitable capacity.

Revised write-up – pg. 3-15 to
3-16; Updated program – pg.
8-38 to 8-39
Emergency Shelters: Allowable Zones – The element identifies the commercial zone (C zone) to accommodate emergency shelters. However, pursuant to AB 2339 (2022), the element must demonstrate the identified zone for emergency shelters also allow residential uses. Specifically, the element must demonstrate whether the City’s commercial zone allows residential uses.

Based on a complete analysis, the element may need to add or modify programs identifying zone(s) that will permit emergency shelters without discretion, that also allow other residential uses.

Revised write-up – pg. 3-15 to
3-16; Updated program – pg.
8-38 to 8-39
Emergency Shelters: Suitability and Capacity – As found in HCD’s prior review, the element must analyze both the suitability and capacity of the C zone. The analysis should address identifying the number of parcels available to accommodate the need, typical parcels sizes and whether the sites are nonvacant. For nonvacant sites identified to accommodate the need, the analysis must address the likelihood the existing uses is likely to be discontinued during the planning period. To analyze the suitability of the zone, the element should address existing uses, surrounding uses, any conditions inappropriate for human habitability and access to services.

Revised write-up – pg. 3-15 to
3-16; Updated program – pg.
8-38 to 8-39
Definition of Emergency Shelters – The element must also address whether the City’s definition of emergency shelters includes other interim interventions, including but not limited to, navigation centers, bridge housing, and respite or recuperative care, pursuant to Government Code section 65583, subdivision Revised write-up – pg. 3-15 to
3-16; Updated program – pg.
8-38 to 8-39
Attachment 11
City of Coronado Page 1841
(a)(4). Based on a complete analysis, the element may need to add or modify programs to comply with state law.

Heights – The element indicates that the R-3 zone has a maximum allowable density of 28 du/ac and allows up to two stories. Further, the element notes that the R-4 zone has a maximum allowable density of 40 du/ac and allows up to three stories. However, the element must analyze the height limitations for impacts on cost, supply, affordability and, particularly, ability to achieve maximum densities.

Revised write-up – pg. 3-9 to
3-10; updated program – pg.
8-41
Parking – HCD’s prior reviews found that the element must address and analyze the City’s parking requirements; specifically requiring two spaces for multifamily units. Prior revisions of the element analyzed the City’s policies to providing concessions and exceptions to the current requirements. The element was now revised to include Program 2-H.2 (Assist in the Development of Affordable Housing) committing to reducing parking requirements to one space per unit for affordable housing projects. However, requiring two spaces per unit for multifamily projects is generally considered a constraint, regardless of income levels. The element should include or modify a program committing to reducing parking requirements for smaller bedroom types (e.g., one space for studio and one-bedroom units) for all multifamily developments irrespective of income levels.

Revised write-up – pg. 3-10 to
3-12; updated program – pg.
8-41 to 8-42
Design Review – The element was not revised from the prior reviews to address this finding. While the element described the design review requirements and process, as found in HCD’s prior review, the element still should analyze and address the City’s subjective approval findings. For example, the element notes that the City requires that designs are not “inappropriate, incompatible, bizarre, and exotic…” and “colors must be harmonious…” (pp. 3-31). The element must analyze these requirements for impacts on cost, supply, feasibility, and approval certainty of housing. Based on a complete analysis, the element may need to add or modify programs to address any potential constraints.

Added write-up – pg. 3-33
and included new program –
pg. 8-41
Site Plan Review – The element should include an analysis of the Site Plan Review requirements. The element was revised to indicate that an analysis of the Site Plan requirements was incorporated in the discussion of single-family and multifamily permit processes. However, neither of these sections directly addressed the site plan review requirements. The element must be revised to evaluate the site plan requirements including the review process, approval body, the number of public hearing if any, approval findings and any other Revised Local Processing
and Permit Procedures
section to remove discussion
of in-depth site plan
approval discussion and
revised Single Family and
Multifamily Dwellings write-up
Ch. 3 –
Constraints
(continued)
Attachment 11
City of Coronado Page 1842
relevant information. The analysis should evaluate these requirements for impacts on cost, supply, feasibility, and approval certainty of housing. Based on a complete analysis, the element may need to add or modify programs to address any potential constraints.
to address site plan review –
pg. 3-31
Reasonable Accommodation – The element includes a discussion regarding the City’s reasonable accommodation procedure including the required approval findings. Specifically, to grant a reasonable accommodation, the City can consider impacts on surrounding uses as part of its decision-making criteria – essentially a conditional use permit finding. HCD’s prior reviews found that this is considered a constraint and the City must include a program committing to remove this criterion. The element was revised to remove the language regarding impacts on surrounding uses from the analysis (pp. 3-23).

However, upon further review of the City’s zoning code, it appears that this language is still part of the City’s zoning code. As found in HCD’s prior reviews, a reasonable accommodation should be a unique exception process from a conditional use permit, especially given its importance in addressing barriers to housing for persons with disabilities. The element must include a program to amend the Reasonable Accommodation Ordinance and remove constraints, namely the “potential impact on surrounding uses” approval criteria.

Revised write-up to
reference drafted program –
pg. 3-25 and program
drafted – pg. 8-41
Group Homes for Seven or More – The element notes that group homes for seven or more is only allowed in one residential zone (R-4 zone) and subject to a major use permit. As found in HCD’s prior reviews, zoning should simply implement a barrier-free definition of family instead of subjecting, potentially persons with disabilities, to special regulations such as the number of persons, population types and licenses. These housing types should not be excluded from residential zones, most notably low-density zones, which can constrain the availability of housing choices for persons with disabilities. Additionally, requiring these housing types to obtain a special use or conditional use permit (CUP) could potentially subject housing for persons with disabilities to higher discretionary standards where an applicant must demonstrate compatibility with the neighborhood, unlike other residential uses. The element must include or modify programs with a specific commitment to allow these uses similar to other residential uses in all residential zones.

Revised write-up on site
planning for group homes of
seven or more – pg. 3-17
Ch. 3 –
Constraints
(continued)
Attachment 11
City of Coronado Page 1843
Ch. 4 –
Housing
Resources
and
Opportunities
Realistic Capacity: The element noted that the City assumed 50-75 percent of maximum allowable densities when determining realistic capacity on sites (pp. 7-25, 7-27 and 7-40). However, on page 4-2, the element states that realistic capacity was determined by multiplying the buildable acreage by the maximum permitted density. The element must be revised to reconcile this information and accurately discuss the methodology for determining realistic capacity.

Carry over from older draft,
revised language and
removed verbiage no longer
applicable to the updated
draft – pg.4-2
Ch. 5 –
Previous
Cycle
Review
Review and Revision - The element must provide an evaluation of the cumulative effectiveness of past goals, policies, and related actions in meeting the housing needs of special needs populations (e.g., elderly, persons with disabilities, large households, female-headed households, farmworkers, and persons experiencing homelessness) and revise programs as appropriate.

Revised section intro
statement regarding
accomplishments with
respect to special needs
groups and updated 5th
cycle program status where
needed throughout the
section.

Ch. 6 - At
Risk Units
The element was revised to include a listing of local funding sources to preserve at-risk units. However, this does not address the required analysis.

While previous submittals of the housing element generally addressed this finding, that information was removed from this submittal.

The element indicates 55 units at risk of converting to market-rate in the next ten years. For units that are at-risk of converting within a 10-year period, the element must include an analysis. An analysis must 1) estimate and analyze the costs of replacement versus preserving these units and 2) identification of public and private nonprofit corporations known to the City to have the legal and managerial capacity to acquire and manage at-risk units. Lastly, while the element included a limited list of local funding sources available to acquire at-risk units, it should also identify and consider the availability of federal and state funding programs.

Added write up – pg. 6-1 to
6-4
Ch. 7 - Sites
Inventory
Progress in Meeting the RHNA: The City’s RHNA may be reduced by the number of new units built, approved, or pending since June 30, 2020; however, the element must demonstrate the availability of these units during the planning period. The element identified 146 units for above-moderate income households as credit towards the RHNA (p. 7-5). The element stated that these units are expected to either begin development or “in some cases” be built during the planning period and that most projects from the prior planning period were generally constructed (p. 7-7). However, this does not demonstrate the availability that these units will be built and available during Revised the
approved/entitled/under
construction write up on pg.
7-4 to 7-5 and table 7-3 with
the status notes, pg. 7-7 to 7-
10 Attachment 11
City of Coronado Page 1844
the planning period. To demonstrate the availability of units within the planning period, the element should include an analysis of the City’s past completion rates on pipeline projects, outreach with project developers, and describe any expiration dates on entitlements, anticipated timelines for final approvals, and any remaining steps for projects to receive final entitlements, including potential barriers to development in the planning period.

Parcel Listing: The element lists parcels by various factors such as size, zoning, densities and affordability in Table 7-16 (p. 7-46). However, the parcel listing must be revised to also include each parcel by general plan designation.

Updated Table 7-16 to add
GP designation and
individual acreage to multiparcel sites – pg. 7-57 to 7-60 Navy Sites: The element identified a portion of the RHNA to be accommodated on Navy-Owned sites, specifically, 374 units including 305 units for lower-income households. The element discussed how these sites will meet the US census definition of a unit, indicated there are no known barriers to development, that the Navy has acquired funding for these units, and that this project will be completed by the end of the planning period. However, the analysis should also discuss any remaining steps for development and a general schedule for development in the planning period. Based on a complete analysis, the element may need to add or modify programs, as appropriate.

Updated the site profile to
include securement of
federal funding - pg. 7-27
and updated the Navy
program with language from
the stipulated agreement –
pg. 8-6. Also referenced
development process in
Community Profile – pg. 2-27
Suitability of Nonvacant Sites: the site profiles did not discuss or expand on the information listed in the inventory (e.g., owner interest and ILV). Instead, the site profiles were revised to state that City staff has not received any opposition from property owners regarding the inclusion of these sites. This information is inconsistent and generally does not support the assertion that there is property owner interest for these sites. The element must accurately and consistently include information regarding property owner interest and ILV within each site profile. To expand on the discussion of property owner interest, the element could discuss the extent of owner interest including whether the property owners are interested in selling or redeveloping their properties with the densities identified in the inventory during the planning period.

In addition, the housing element relies upon nonvacant sites to accommodate more than 50 percent of the RHNA for lower-income households. For your information, the housing element must demonstrate existing uses are not an impediment to additional residential development and will likely discontinue in the planning period. (Gov. Code, § 65583.2, subd. (g)(2).) Absent findings (e.g., adoption resolution) based on substantial Updated site profiles to
discuss owner interest (if
applicable) and added ILV
ratio along with any other
suitability details – pg. 7-18 to
7-27
Ch. 7 –
Sites
Inventory
(continued)
Attachment 11
City of Coronado Page 1845
evidence, the existing uses will be presumed to impede additional residential development and will not be utilized toward demonstrating adequate sites to accommodate the RHNA.

Large Sites: Sites larger than ten acres in size or smaller than a half-acre in size are deemed inadequate to accommodate housing for lower-income households unless it is demonstrated, with sufficient evidence, that sites are suitable to accommodate housing for lower-income households. The element identifies Site 7 that is 12 acres in size to accommodate a portion of the lowerincome RHNA. The element was revised to include a high-level statement that the City intends on using a portion of the site that will be 10 acres or less to accommodate the additional units within underutilized areas and affordability is based on the City’s inclusionary policy. However, the analysis should discuss information about how these areas are considered underutilized and how the site will likely be built to facilitate affordability to lower-income households. For example, the analysis could discuss the existing uses, size of these underutilized spaces, potential future site planning scenarios and how those areas to be redeveloped facilitate affordability.

Revised the write up on pg.
7-42 and updated site
profiles for site 7 to clarify
underutilized ac and how
development will occur – pg.
7-24
Electronic Sites Inventory: Pursuant to Government Code section 65583.3, subdivision (b), the City must submit an electronic version of the sites inventory with its adopted housing element utilizing the standards, forms, and definitions adopted by HCD. While the City has submitted an electronic version of the sites inventory, if changes occur, any future re-adopted versions of the element must also submit the electronic version of the sites inventory.

City to submit to indicated
sites email at the same time
when sending the draft HEU
to HCD – submittal date on
or before 1/19.

Ch. 8 –
Housing Plan
Rezones –the housing element proposes to rezone several sites to accommodate a maximum allowable density of 60 du/ac. As such, the element should either include a discussion of proposed development standards to complement the rezones or include a program committing to establish development standards (heights, lot coverage, setbacks, etc.,) that facilitate achieving the proposed maximum densities.

Added program to address
establishing development
standards for zoning districts
up to 60 du/ac – pg. 8-7 to 8-
8 Program H-4.D (AB 1486 City-Owned Land): The element identified CityOwned sites to accommodate a portion of the RHNA. While the element included a program committing to making these sites available through the Surplus Land Act (SLA), the program must be revised to encourage and facilitate development of these sites during the planning period. This includes a specific commitment to comply with the SLA throughout the planning period, provide incentives and actions along with a schedule to facilitate development of City-Owned sites. Actions should include outreach with Updated program – pg. 8-34
to 8-35
Ch. 7 –
Sites
Inventory
(continued)
Attachment 11
City of Coronado Page 1846
developers, issuing requests for proposals, incentives, fee waivers, priority processing, financial assistance and alternative actions by a specified date if the sites do not progress toward development in the planning period.

Program H-1.E (Track Navy Housing Development): this Program must be revised to reflect any remaining steps and a schedule of actions for completing construction of the identified RHNA units on the Navy site.

Updated Navy program –
pg. 8-6 and tied into the MidCycle Review program – pg. 8-4 to 8-5
AFFH Programs (including housing mobility): the City is predominantly high and highest resource, higher income, and some neighborhoods are considered racially concentrated area of affluence (RCAA). As a result, the element must include a significant suite of programs to promote housing mobility or housing choices and affordability throughout the City. These programs should not be limited to the RHNA and, instead, target significant and meaningful change. While the element was revised to include some metrics or numeric objectives, geographic targeting and a few actions such as accessory dwelling units (ADU) and carriage homes, it should include additional actions that promote housing choices and affordability throughout the City. Additional examples include promoting more housing choices and affordability in other lower-density areas (e.g., missing middle housing types), identifying additional multifamily areas, additional religious institutional sites, and enhancing ADU’s, junior accessory dwelling units (JADU) or additional conversion of existing space, and home sharing strategies.

Updated Housing Mobility
program – pg. 8-26 to 8-28
and Housing Opportunities
program – pg. 8-20 to 8-22
Quantified Objectives: The element must establish quantified objectives by income group, including extremely low-income units for new construction, rehabilitation and conservation, including preservation. While the element now includes conservation objectives for preservation of units at-risk of converting to market rate uses, conservation objectives should not be limited to the preservation of at-risk units. Conservation objectives may include the variety of strategies employed by the City to promote tenant stability, code enforcement and repair programs that conserve the housing stock, Additionally, the element currently establishes rehabilitation objectives of zero in the planning period for all income groups and should consider increasing objectives to better reflect the housing needs of the community.

Rehabilitation objectives are not limited to activities carried out by the City.

Updated objective figures –
pg. 8-41
Ch. 8 –
Housing
Plan
(continued)
Attachment 11
City of Coronado Page 1847
Appendix B -
AFFH
Enforcement: While the element includes information on how the City complies with federal fair housing laws, it must also address compliance with state and local fair housing laws.

Revised write-up adding
additional fair housing laws
and a statement indicating
adherence – pg. B-72
Racially Concentrated Areas of Affluence (RCAA): While the element was revised to include some analysis of income and RCAA, the analysis must still address trends, conditions, coincidence with other fair housing factors (e.g., race, highest resource, overpayment), effectiveness or absence of past strategies (e.g., lack of publicly assisted housing and lack of multifamily zoning), local data and knowledge and other relevant factors.

Revised write-up to provide
more analysis and factors
that impact strategies used
to address RCAAs – pg. B-34
Special Needs Households: While the element was revised to include a listing of proposed programs, as found in HCD’s prior review, the element still should include a complete analysis of the existing needs and resources for special needs populations including seniors, farmworkers, persons experiencing homelessness, persons with disabilities including developmental disabilities, and ELI households. The analysis must include an evaluation of existing resources to meet the housing needs (availability of shelter beds, number of large units, number of deed restricted units, etc.,), an assessment of any gaps in resources, and proposed policies, programs, and funding to help address those gaps.

Added write-up identifying
the existing resources and
proposed programs for
special needs groups – pg. 2-
32 to 2-33.

Attachment 11
City of Coronado Page 1848
Official Findings Letter - Received on 3/6/24
Appendix B –
AFFH (continued)
Enforcement: the element must address specifically how the City complies with fair housing laws.

Revised write-up adding
language addressing how the
City adheres to specific fair
housing laws, reference to new
fair housing programs in the
Housing Element and references
to County-wide fair housing
programs/resources – pg. B-72
Racially Concentrated Areas of Affluence (RCAA): the analysis must still address trends, conditions, coincidence with other fair housing factors (e.g., race, highest resource, overpayment), effectiveness or absence of past strategies (e.g., lack of publicly assisted housing and lack of multifamily zoning), local data and knowledge and other relevant factors. Based on the outcomes of a complete analysis, the element should add or modify programs to AFFH and, in particular, add housing mobility strategies to promote housing choices and affordability throughout the City.

Added language on history of
development and trends as well
as past strategies (i.e.,
Redevelopment dissolution) and
lack of public subsidies – pg. B34
Ch. 2 –
Community
Profile
Special Needs Households: the element must include a robust analysis identifying and evaluating gaps in resources and significant actions with specific commitments to addressing the needs of these populations.

Added a write-up on the cost of
affordable housing and the lack
of public subsidies as causes for
the lack of special needs
housing - pg. 2-21
Ch. 7 – Sites
Inventory
Navy Sites: the analysis should also discuss any remaining steps for development and a general schedule for development in the planning period. Based on a complete analysis, the element should add or modify programs, as appropriate. Language was added to program H-1.E Track Navy Housing Development regarding
timeframes for communications with the Navy.

Added language on additional
steps City will take to monitor
progress on Navy housing in
Chapter 8, Housing Plan – pg. 8-
6 Suitability of Nonvacant Sites: the housing element relies upon nonvacant sites to accommodate more than 50 percent of the RHNA for lower-income households. The housing element must demonstrate existing uses are not an impediment to additional residential development and will likely discontinue in the planning period. Absent findings (e.g., adoption resolution) based on substantial evidence, the existing uses will be presumed to impede additional residential Added language regarding
developer interest – pg. 7-18 to
7-27
Attachment 11
City of Coronado Page 1849
development and will not be utilized toward demonstrating adequate sites to accommodate the RHNA.

Electronic Sites Inventory: the City must submit an electronic version of the sites inventory with its adopted housing element utilizing the standards, forms, and definitions adopted by HCD. Any changes in the element must also submit the electronic version of the sites inventory.

An updated version of the sites
inventory will be submitted with
the final housing element
document.

Zoning for a Variety of Housing Types (Supportive and Transitional Housing): The element must commit to permitting transitional and supportive housing as a residential use in all zones and only subject to those restrictions that apply to other residential dwellings of the same type in the same zone. Additionally, the element must commit to amending zoning and procedures to comply with AB 2162 (Statutes of 2018).

Language for Program H-5.B.

Supportive Housing and Low
Barrier Navigation Centers was
edited in Chapter 8, Housing
Plan, to reflect the HCD required
language – pg. 8-7
Ch. 3 -
Constraints
Land Use Controls:

Heights – the current height requirements are a constraint to development, affordability, supply and achieving maximum densities.

The element must include or modify programs to revise the City's height requirements and facilitate achieving maximum allowable densities. For your information, generally, one story of height for every ten units per acre and 12-feet of height per story are acceptable benchmarks for evaluating heights. The City’s height requirement particularly for the R-3 and R-4 zone differ from these benchmarks and can have impacts on housing choices, affordability, and ability to achieve maximum densities. For example, the R-4 zone permits 40 units per acre. This would result in a maximum height requirement of no less than four stories and 48 feet. The element must include a commitment to increase height requirements for several zones, including the R-3, R-4, and zones accommodating the City's rezone to accommodate the RHNA.

Parking – Program H-5.M (Parking Standards Evaluation and Amendment) does not commit to anything beyond studying, evaluating, and exploring and does not reduce parking
requirements. This Program must include a specific commitment to reducing parking requirements for smaller bedroom types (e.g., one space for studio and one-bedroom units) for all multifamily developments regardless of income levels.

Revised program language for
the following:
• H-1.F. General Plan Update –
language added to amend
zoning to allow for building
heights as specified by HCD -
pg. 8-7
• H-5.M. Parking Standards
Evaluation and Amendment,
H-2.H. Assist with the
Development of Affordable
Housing, H-3.B. Housing
Opportunities for Persons with
Special Needs - included
adopting and implementing
reduced parking
requirements for all
affordable units and all
studio and one-bedroom
units in multi-family projects –
pg. 8-41
Ch. 7 – Sites
Inventory
(continued)
Attachment 11
City of Coronado Page 1850
Rezones – Program H-1.G (Establishment of Development Standards).

This Program should specifically commit to establishing development standards that facilitate maximum densities.

Design Review: the constraints analysis indicates additional subjective findings and criteria in Program H-5.L including but not limited to "harmonious, good, durable quality, etc.," The element must add or modify programs that specifically commit to promoting objectivity and certainty in the design review process.

Added objective design
standards as a City action under
Program H-3.I. Housing Mobility –
pg. 8-26 to 8-29
Reasonable Accommodation – Program H-5.K (Reasonable
Accommodation Ordinance). This Program states that the City will still assess whether a reasonable accommodation request "poses a detriment to surrounding uses" (p. 8-37). The program must commit to remove all criteria related to evaluating reasonable accommodation requests for impacts on surrounding uses.

Revised program language for
Program H-5.K. Reasonable
Accommodation Ordinance
Amendment – pg. 8-41.

Ch. 6 - At Risk
Units
The element must estimate the actual costs of preserving versus replacing the 55 units at-risk of converting to market rate.

Estimated cost of acquiring the
55 at-risk units was added – pg.
6-2.

Ch. 8 – Housing
Plan
Program H-4.D (AB 1486 City-Owned Land): Several actions did not include a specific commitment or a schedule to facilitate these efforts. For example, the element indicated that it would explore partnerships and funding. However, the Program should specifically commit to establishing partnerships and pursuing funding with timelines. Additionally, the element must include a discrete timeline for the various other actions that were listed in this Program including the issuance of RFPs, establishing streamlined reviews, and providing development incentives. Lastly, the element should include additional efforts to facilitate development on these sites such as commitment to facilitate entitlements and issue permits by a specific date consistent with the assumptions in the sites inventory.

Program H-1.E (Track Navy Housing Development): the program should be revised to reflect any remaining steps and a schedule of actions for completing construction of the identified RHNA units on the Navy site.

AFFH Programs: the City is predominantly high and highest resource, higher income, and some neighborhoods are considered RCAA. As a result, the element must include a significant suite of programs to promote housing mobility or housing choices and affordability • Revised language to add
information required by HCD
for Program H-4.D – pgs. 8-34
to 8-35
• Revised language for
Program H-1.E. Track Navy
Housing Development – pg. 8-

6. • Added a number of new
actions for Program H-3.I.

Housing Mobility per HCD
requirements – pg. 8-26 to 8-

29. Ch. 3 –
Constraints
(continued)
Attachment 11
City of Coronado Page 1851
throughout the City. These programs should not be limited to the RHNA and, instead, target significant and meaningful change.

The element must include additional actions that promote housing choices and affordability throughout the City. Additional examples include promoting more housing choices and affordability in other lower-density areas (e.g., missing middle housing types), identifying additional multifamily areas and additional religious institutional sites, and enhancing accessory dwelling units (ADU), junior accessory dwelling units (JADU) or additional conversion of existing space, and home sharing strategies.

Attachment 11
City of Coronado Page 1852

THIS PAGE INTENTIONALLY LEFT BLANK
City of Coronado Page 1853
RESOLUTION NO. 2024-01

A RESOLUTION OF THE PLANNING COMMISSION OF

THE CITY OF CORONADO RECOMMENDING THAT

THE CITY COUNCIL NOT ADOPT THE DRAFT
HOUSING ELEMENT UPDATE FOR THE 2021-2029

HOUSING ELEMENT PLANNING PERIOD,

AMENDMENTS TO THE LAND USE ELEMENT OF THE

GENERAL PLAN, OR THE ENVIRONMENTAL

ASSESSMENT AND NOT ADOPT AN ORDINANCE FOR

THE ASSOCIATED MUNICIPAL CODE AMENDMENTS,

INCLUDING THE ORANGE AVENUE CORRIDOR

SPECIFIC PLAN, AND LOCAL COASTAL PROGRAM

AMENDMENTS
WHEREAS, State Housing Element law (Government Code Section 65580 et seq.) requires that the City Council adopt a Housing Element for the eight-year period 2021- 2029 to accommodate the City of Coronado regional housing need allocation (RHNA) of 912 housing units, comprised of 481 lower-income units, 159 moderate-income units, and 272 above moderate-income units; and
WHEREAS, to comply with State Housing Element law, the City of Coronado has prepared the Housing Element 2021-2029 (the Housing Element) in compliance with State Housing Element Law and has identified sites that can accommodate housing units meeting the City’s RHNA; and
WHEREAS, as provided in Government Code Section 65350 et. seq., adoption of the Housing Element 2021-2029 constitutes a General Plan Amendment; WHEREAS, as provided in Government Code Section 65352-65352.5, the City mailed a public notice to all California Native American Tribes provided by the Native American Heritage Commission and to other entities listed and no California Native American tribe requested consultation; and
WHEREAS, the City conducted community outreach, including public workshops, to gather public input; and
WHEREAS, the Sixth Cycle Housing Element was prepared based on input from the City Council, Planning Commission, community members and organizations, public comments, and the California Department of Housing and Community Development; WHEREAS, on December 15, 2023, the City received a letter from HCD providing its findings regarding the draft Housing Element; and Attachment 12
City of Coronado Page 1854
WHEREAS, on January 2, 2024, the City published a revised draft Housing Element responding to HCD’s findings and requested public comment on the draft, and on January 12, 2024 a revised draft Housing Element was published addressing public comments received; and
WHEREAS, on January 17, 2024, the City submitted the revised Draft Housing Element to HCD; and
WHEREAS, on March 5, 2024, the City received a letter from HCD stating that the draft Housing Element is not currently in substantial compliance with State Housing Element Law and outlined steps to bring it in to compliance; and WHEREAS, City staff, working in consultation with HCD, drafted amendments to the draft Housing Element that would bring the plan into substantial compliance with State Housing Element Law; and
WHEREAS, the Housing Element Update identifies proposed actions to meet each of the City’s stated housing goals including provide a broad range of housing opportunities; provide a broad range of affordable housing opportunities that serve people that live and work in Coronado; provide equal housing opportunities that are accessible to all segments of the Coronado community; encourage conservation and maintenance of Coronado’s housing stock, neighborhoods, and history; minimize governmental constraints related to housing; and promote environmentally sound policies and practices in residential development to reduce exposure to environmental hazards for all residents; and
WHEREAS, the proposed adoption of the Housing Element and its associated implementing actions has been prepared pursuant to a judgment entered by the Superior Court of San Diego County on November 8, 2023 and therefore these actions are not subject to the California Environmental Quality Act (“CEQA”) pursuant to Section 65759 of the Government Code, however an Environmental Assessment, the content of which substantially conforms to the required content for a draft environmental impact report set forth in Article 9 (commencing with Section 15140) of Title 14 of the California Code of Regulations, was prepared prior to adoption of the Housing Element and was taken into consideration by the Planning Commission prior to its recommendation to the City Council; and
WHEREAS, on March 26, 2024, the City of Coronado Planning Commission held a duly noticed public hearing and recommended that the City Council not adopt a resolution to approve the Housing Element Update, amendments to the General Plan Land Use Element, or the Environmental Assessment on the Housing Element Update, Attachment 12
City of Coronado Page 1855
and to also not adopt an ordinance for the associated Municipal Code and Local Coastal Program amendments, which took into consideration the following:

A. All documentation associated with the Housing Element Update, the General Plan Land Use Element amendments, the Environmental Assessment, as well as the Municipal Code and Local Coastal Program amendments, its related staff report, and all comments submitted either in writing or verbally on the Housing Element Update; B. The findings made by the California Department of Housing and Community Development (HCD) included in HCD's letter to the City dated March 5, 2024 as required by Government Code Section 65585(e);
C. Oral testimony from staff and members of the public made a part of the public record at said public hearings.

NOW, THEREFORE, BE IT RESOLVED that the Planning Commission recommends that the City Council of the City of Coronado not adopt the draft Housing Element Update or any associated amendments:

PASSED ADOPTED, AND APPROVED by the Planning Commission of the City Coronado, California, at a regular meeting thereof this 26 th day of March 2024, by the
following vote, to wit:

AYES:

NAYS:

ABSTAIN:

ABSENT:
_____________________________
Scott Metzger, Vice Chair
Planning Commission
Attest:
________________________________
Rich Grunow
Director of Community Development
Attachment 12
City of Coronado Page 1856

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City of Coronado Page 1857
From: Catherine Wilson
To: Jesse Brown
Cc: Brad Wilson; Jeri Hickman
Subject: Reduced parking for low income housing
Date: Tuesday, March 19, 2024 2:42:46 PM
Attachments: image001.jpg
CAUTION: This email is from an EXTERNAL source. Ensure you trust this sender before clicking on any links or attachments.

Hi Jesse, My name is Catherine Wilson and my husband and I live at . as well as have a local insurance office at . Our concern is we just heard about the lowering of the restriction for parking for the units that will be going across the street from us. I don’t see how they can possibly build without putting in under ground parking for all of the units.

There is no street parking available around our blocks all day. They would be ticketed at Ferry Landing. Please let the powers that be know that this will greatly impact the current businesses and homes already in the area. Thank you.

Have a terrific day!
Catherine M. Wilson
Wilson and Company Insurance Services, Inc.

Coronado, CA 92178
www.wilsonandcompanyinsurance.com
Attachment 13
City of Coronado Page 1858
From: [email protected]
To: Jesse Brown
Subject: Hearing March 26, 2024, at 3pm.

Date: Tuesday, March 19, 2024 4:18:43 PM
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Jesse,
My name is Jeri Hickman and my husband, and I live at . We are strongly opposed to reducing parking requirements for affordable housing developments. The Smart and Final parcel has one bus stop and ridership is way down. (the reason the summer shuttle service is cancelled for May and June). Traffic is already a nightmare at our location. There is no public street parking available after 7:30 a.m.

It’s simply mind boggling to think about the possibility of 116 units being allowed at the Smart and Final parcel and the corner of 2nd and C location. Our unit is directly across the street for the S& F loading dock. Raising the current height limit is going to destroy our views and any natural light coming into the front facing units. 116 units means at least 232 people, cars, dogs, and bikes. It is going to destroy our enjoyment and quality of life. I simply do not understand why affordable housing is being forced upon the most expensive real estate market and waterfront property in San Diego.

Can’t the City Manager, Mayor and Council members fight harder to increase the housing element numbers on the military base property?
Please print and or fwd this email to all Council members prior to the March 26th Public Hearing.

Thank you,
Jeri Hickman
Coronado, CA 92118
[email protected]
Attachment 13
City of Coronado Page 1859
From: Judy Delaney
To: Jesse Brown
Cc: Jeri Hickman
Subject: Hearing March 26
Date: Wednesday, March 20, 2024 7:52:11 AM
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My name is Judy Delaney and my husband Tim and I live at , Regatta Bay condos.

We are strongly opposed to reducing parking requirements for affordable housing developments. Why can’t you consider underground parking? The Hotel Del has done it successfully and they are right on the ocean.

Traffic is already a nightmare at our location. There is no public street parking available after 7:30 a.m.

There are (including us) 4 retired military officers that have homes in Regatta Bay. We have earned, fought, saved and paid to have this location. Now our investment and living conditions are on the line because of subsidize housing.

Please help us.

Thank you kindly,
Judy Delaney and Lt. Col. Tim Delaney, USMC, Retired
Sent from my iPhone
Attachment 13
City of Coronado Page 1860
From: Donna Gasparrelli Corr
To: Jesse Brown
Subject: Smart and Final land for affordable housing
Date: Thursday, March 21, 2024 1:43:16 PM
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Hello Jesse,
My husband Michael Corr and I are very concerned about the proposed affordable housing project on the land between 1st and second and B and C avenues.

We understand why we need more affordable housing in Coronado but think that the suggested development does not take into account the lack of parking this area already has. The other major concern is the size and height of the projected building.

We moved to Coronado just two years ago from downtown San Diego. One of the reasons we purchased here was that the city limited building height to just three stories. Coronado is a suburban and small business area now. By raising the height limit and squeezing in as many apartments/condos as possible it will change the feel and look of Coronado.

Please share our concerns with the powers that be. We hope Coronado will remain a suburb and not become extension of downtown San Diego.

Sincerely,
Donna Corr
Attachment 13
City of Coronado Page 1861
From: Heintz Family
To: Jesse Brown
Subject: Hearing March 26, 2024, 3pm
Date: Thursday, March 21, 2024 3:54:12 PM
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Hi Jesse,
My name is Mary Heintz, and my husband Jim and I live at , in the Regatta Bay condos.

We are strongly opposed to lowering the parking requirements for affordable housing. If there is only one parking spot requirement per unit, tenants will try to find street parking for second cars. Each unit must have 2 underground parking spots to reduce tenants and guests from seeking public street parking. There is no available street parking in our neighborhood.

This would greatly impact people who own businesses and homes in this area.

We are also opposed to dropping current height restrictions for this high-density project.

Removing the current height limits will change the entire character of our neighborhood.

They should not be allowed to exceed the height of any nearby existing developments.

This builder/developer should be required to meet the same requirements that past developments had to meet.

We feel that the high-density housing is already lowering our property values, and do not want more concessions made for this project. I hope the builder/developer will be held to making the housing attractive and high quality.

We will be at the meeting next Tuesday.

Thank you for your consideration.

Sincerely,
Mary Heintz
Attachment 13
City of Coronado Page 1862
From: Vicki Schwebach
To: Jesse Brown
Subject: Submission for consideration at the March 26th Public Hearing Date: Friday, March 22, 2024 10:05:11 AM
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Hello Jesse,
Please submit my letter for the boards review on March 26. Please make copies for everyone to read. Thank you very much for all of your support and consideration!
Vicki Schwebach
Compacted, high rise, zero parking and congested city streets is not the answer to the affordable Housing solution in Coronado. I vehemently oppose the Planning Commission’s proposed solution to the Housing Element, specifically the affordable housing proposal located between 1st and 2nd, B and C.

My name is Vicki Schwebach, i live at . I am a 20 year veteran, I’ve worked my entire life to be able to afford the beauty and sanctity of Coronado. This is my home.

I live adjacent to the proposed construction of the low income project, located between 1st and 2nd, B and C.

Affordable housing in one of the costliest areas of San Diego is an oxymoron. It’s very clear this project is being forced to fit in an area not suitable for its intention, to provide affordable housing to low income earners. Reducing parking requirements to one per additional unit is a joke. If we lived in a car less society, it’s feasible. Lifting the current height restrictions to 4 stories and 42 feet further proves a square peg is trying to fit in a round hole. Stop the insanity and step back for a moment to realize the impact 116 units will have on this existing high density area. The gateway to the island, and in most cases the first glimpse of Coronado millions of visitors see every year. 116 units, over 230 people, cars, pets, bikes and if truly low income, commuters crossing the bridge, or taking the ferry to work each and every day.

Is this the Coronado we want to leave for future generations? Crowded, congested, and overbuilt industrial looking buildings. In exchange we give up the core beauty of a small town. HG Felton’s portfolio of building projects resemble cheap, industrial and crowded renditions of urban living. Review the numerous reports from current residents of HG Felton’s buildings. Are we ready to give up our beautiful city with unique homes, built for families to enjoy for generations to come? Are we willing to give up being able to walk our children to school or let them ride their bikes, safely to school, to shop at grocery stores , dine at local restaurants where there is adequate parking? Or to sit outside a restaurant, enjoying the beautiful views, instead of looking at an industrial complex… Is this what we are willing to trade for affordable housing for the few? Have you spent a 4th of July on the island recently? Typically those who live here will park our cars and risk riding our bikes to complete our daily chores, knowing that once the ever busy week is complete, the island will return to somewhat normal congestion. Where one can safely drive their car and park even close to a grocery store, restaurant,or one of the many offices located along B and C. Now take the Fourth of July week and make it a daily occurrence. That is what we are asking to impose on our citizens of Coronado who live in the area where the proposed affordable housing project is being considered.

Cramming Affordable housing in Coronado will only work if Coronado is affordable! Vicki Schwebach
Sent from my iPhone
Attachment 13
City of Coronado Page 1863
From: Kathy Lompa
To: Jesse Brown
Subject: Coronado development
Date: Friday, March 22, 2024 7:15:26 PM
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Hello Jesse,
My name is Kathy Lompa. My husband Frederic and myself own . So far we love living there.

I’m afraid this “will be coming to a big stop when you push this housing through.

My husband is a disabled veteran and the disabled parking in our area is never available when we need it. On top of that I have stage 4 cancer and I’m hoping to live the time I have remaining in the beautiful area we have chosen for our home.

I believe your plan will lower our property value but not our property tax. It will impact the area with many cars using street parking . We do not want this change, please reevaluate our situation from the perspective of the residents and businesses in this area . You are planning development in an area that is already so expensive that people that planned and saved for it all their lives can barely afford. I certainly hope you thought about the trickle down effect this will cause.

The city has already caused the car wash on C to close and the owners have lost everything, how do you sleep at night? What if this was happening at your home?
Sincerely,
Kathy Lompa
Sent from my iPhone
Attachment 13
City of Coronado Page 1864
From: Terri Lea
To: Jesse Brown
Subject: Smart and Final Affordable Housing Project
Date: Sunday, March 24, 2024 6:51:28 AM
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Hello Jesse,
My name is Terri Lea and I live at . I am concerned as well as dismayed by the proposed affordable housing project at the Smart and Final location and the direction it appears to be headed. It now looks as though it may be expanding beyond the initial proposal to possibly include properties surrounding and across from Smart and Final on 2nd St. Quite possibly HGFenton is planning ahead.

I envision what that building might look like with that many units and the change in height restrictions and it seems monstrously large and tall for this area of Coronado. Those previous height restrictions were there for a reason and I doubt whether that reason has changed.

The reduction of parking requirements in an area that already deals with lack of public parking and congested streets is not a good idea. It has been reported in other areas where affordable housing has been built that these parking reductions have caused residents and businesses alike frustratingly searching for parking and sometimes at quite a distance away. I can’t imagine how much more difficult it is going to be for our maintenance and repair or delivery personnel to find parking as they are already vying for spots to park during daylight hours.

I know the state thinks this will encourage people to use the bus, but time and time again, it has been reported that it does not for various reasons. It takes considerable time by bus to get to many places here in San Diego county. I don’t have a car and rely on public transportation so I can attest that it is time consuming.

I am retired, so I chose this area to purchase my home because of the walkable proximity to medical facilities, restaurants, and a major grocery. I try to shop locally as much as possible and have items delivered when necessary. If I were in a lower income bracket it would be difficult to shop strictly local especially if the most affordable restaurants and grocery stores are no longer here. Residents will want their vehicles for the freedom that it gives them and there isn’t enough street parking.

I am not opposed to the concept of affordable housing and realize we do have a need, but hopefully not at the expense of urbanizing the village and over loading the already congested streets.

Sincerely,
Terri Lea
Attachment 13
City of Coronado Page 1865
From: [email protected]
To: Jesse Brown
Subject: Proposed Development at Smart & Final lot
Date: Sunday, March 24, 2024 12:15:43 PM
Attachments: image002.png
Importance: High
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March 22, 2024
Mr. Jesse Brown
Principal Planner, City of Coronado
Development Department
Via email
Dear Mr. Brown,
I am writing to you to express very
significant concerns over the proposed
new housing development at the Smart &
Final location in Coronado.

I am writing to you both personally (address
is , directly next to Smart &
Final) and as President of The Village in
Coronado HOA where I serve as President.

I have attended public meetings before and
I understand the constraints that the city
has had in dealing with the state, the
housing mandates and required plan
Attachment 13
City of Coronado Page 1866
development laws. However, now the
responsibility clearly shifts to Coronado
to approach this issue wisely and carefully.

The irresponsible projection of
potentially 100+ new units, of only 1 car
per unit, the raising of the height limits to
4+ stories is simply all beyond
reasonable imagination. It is a plan that
will destabilize the entire city and destroy
home values anywhere near this end of
town. While we are willing to consider
and review reasonable plans for the
improvement of the entire area – we
cannot in any way support the tentative
plan.

The unreasonable forecast of
transportation with the buses (did you
not just cut the free summer shuttle way
back because of low usage?) and the
ferry schedule is not a feasible option for
many.

Why should current residents have new
rules (density and height limits) foisted
upon them while we have had to abide by
stricter regulations for the good of all?
Has any city official spent any
Attachment 13
City of Coronado Page 1867
considerable time at this end of time to
understand the noise and traffic during
critical times (the answer is obvious to
us).

What about the flooding that the
businesses and homes have endured
during the recent storms – this will only
get worse.

Why have we been kept in the dark (e.g.,
without any consultation) about obvious
plans that you have discussed with the
developer? They must develop plans that
provide a reasonable return – but that
should not drive city council decisions –
your role is to protect and enhance the
quality of life in this town!
I hope it is understood that the residents at
this end of town will not sit idly by while this
plan is agreed to behind the scenes. Only an
open and transparent discussion among all
parties can ensure the best outcome
without further hinderances.

We will willingly engage in those types of
discussions – but not accept anything that
is shoved down our throats without the right
processes. We look forward to those
Attachment 13
City of Coronado Page 1868
discussions.

Sincerely,
Doug Porter
[email protected]
Attachment 13
City of Coronado Page 1869
From: Peg and Bob Eddy
To: Jesse Brown
Cc: John Duncan; Richard Bailey; Casey Tanaka
Subject: Opposition to Proposed development in Smart and Final lot Date: Sunday, March 24, 2024 7:48:39 PM
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As a resident of The Village in Coronado condo complex at , I am writing to formally protest the planned development of four stories of housing units on the adjacent Fenton property on First Street.

Have you personally, or any of your associates, visited First Street from 5 to 6:30 a.m. on weekday mornings and witnessed the heavy traffic from personnel heading to North Island? Have you personally, or any of your associates in the planning department, witnessed the heavy traffic and lack of parking spaces on the weekends? Have you surveyed the merchants with businesses at the Ferry Landing regarding this proposed development?
Although Coronado is apparently required by Sacramento to somewhere invent dirt on which an inordinate and preposterously determined number of housing units must be developed, putting 116 units in the Smart and Final lot in a FOUR Story building and adjacent properties is quite frankly, unacceptable! The added traffic, noise, worsening of the parking debacle, plus FOUR stories of housing will not only be a burden to Coronado's infrastructure, sewer, water and safety services, but property values of current housing will certainly experience a major decline.

From a practical standpoint,who, pray tell, can afford to commute by ferry or take the limited public transportation to San Diego for a minimum wage job? I assume that many of the proposed units will be classified "lower income" and as such will be rented to individuals holding minimum wage jobs who most probably won't be able to afford the commute to jobs in San Diego.

In addition, the first time I heard about said development was from the notice I received this month regarding the March 26 Planning Commission Meeting. Having lived at since 2018, did I miss a mailed notice about any proposed development on that space? I have received notices about the proposed refurbishment of the Ferry Landing. Fortunately, with citizens' and residents' input that original design was modified so that the character of that locale matches the overall "flavor" of Coronado. To envision a four story mega development towering in the area across from the Ferry Landing is a horror show!
In summary, I echo the sentiments of our HOA President, Doug Porter:
"The irresponsible projection of potentially 100+ new units, of only 1 car per unit, the raising of the height limits to 4+ stories is simply all beyond reasonable imagination. It is a plan that will destabilize the entire city and destroy home values anywhere near this end of town. While we are
willing to consider and review reasonable plans for the improvement of the entire area – wecannot in any way support the tentative plan."
The agenda for this Tuesday's morning all but indicates that the Planning Commission will "bless" this development and recommend that the Coronado City Council adapt its recommendation to approve.

I am hereby going on official record as vehemently OPPOSED to this plan.

With adequate time provided, I am quite sure that we residents can come up with an acceptable alternative that will maintain current property values, maintain the "flavor" of Coronado and the Ferry Landing neighborhood and accommodate a reasonable amount of housing units without ruining the entire area.

Attachment 13
City of Coronado Page 1870
Please do not ruin our neighborhood.

Sincerely,
Peggy Eddy
Attachment 13
City of Coronado Page 1871
From: Peter Rullan
To: Jesse Brown
Subject: SMART AND FINAL PROJECT
Date: Sunday, March 24, 2024 10:12:04 PM
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Dear Mr. Brown:

As a physician, parent and land-owner of 3 properties I Coronado, I urge you to reconsider the plans to build 116 units on the current land where Smart and Final is located. While this project will generate taxes for the city, it will also generate more traffic and parking problems for this neighborhood. I don’t recall being asked to attend a city council meeting to give our opinion on this project.

Thank you for your attention.

Peter P. Rullan, MD
(Owner of )
Attachment 13
City of Coronado Page 1872
Attachment 13
City of Coronado Page 1873

1. Increased traffic at peak times in an already congested area

2. Zoning height changes. How can you change existing zoning restrictions for a new development while previously developed property could not take advantage of this. This could expose the City to potential lawsuits.

3. The proposed extreme density will adversely affect all existing homeowners.

I request that you decline this proposal or at least make it adhere to existing zoning regulations.

Tom Ball
[email protected]
NAI FMA Realty
Attachment 13
City of Coronado Page 1874
From: DANA WELCH
To: Jesse Brown
Subject: Comments for 3/26/24 Planning Commission meeting-Parking minimums Date: Monday, March 25, 2024 10:27:34 AM
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Thank you Planning Commission for your work on the Housing Element Update. This is a big project and I know many staff and community members have been involved.

It's disappointing to read that the state housing department (HCD) is requiring a reduction of the minimum number of parking spaces per unit of all multiple family developments.

As two of the sites on the "top 10" list are near 1st Street, and could add up to 96 units if built (58 units suggested for Smart & Final lot, 38 units suggested for 149 A Street), that area alone could see at least 192 cars (assuming 2 per unit) driving around 1st Street daily seeking parking with a wide variety of others doing the same:

Visitors to Ferry Landing, Port walkway/bikeway
Attendees at Little League field, Tidelands Park
Staff seeking parking who work at hospital, ferry landing businesses Vehicles parked long term due to military deployment
Residents hoping to park near where they live
Building housing in this community without appropriate numbers of parking spots is poor planning.

Providing housing without a place for the resident’s car doesn’t make sense in a town with existing and severe traffic and parking impacts.

It's frustrating that the state is not allowing city leaders to make decisions on parking when they are ones who know the community dynamics firsthand.

When some of these lots are built on, the driving and parking conditions in town will deteriorate noticeably. There is only so much negative impact that can be absorbed or mitigated. These realities make me sad for the future of Coronado.

Thank you for listening.

Dana Welch
1st Street
Attachment 13
City of Coronado Page 1875
From: Tom Fetter
To: Jesse Brown
Subject: Housing Element Update
Date: Monday, March 25, 2024 1:29:41 PM
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Jesse,
Thank you for returning my call about the Public Hearing regarding the Housing Element so promptly this morning. I appreciate your explanation and understand the position on this matter that the City of Coronado has with the State.

Although our property at . has been listed, we
have no intention of converting our use from professional office space to residential.

Thank you for your service to the community.

Tom Fetter
Attachment 13
City of Coronado Page 1876
March 26, 2024
To: Coronado Mayor, City Council Members, Planning Commission, City Manager and Staff Re: Coronado Draft Housing Element and Plans for Affordable Housing Thank you for the opportunity to comment on the City’s current Draft Housing Element and the City’s plans for providing more affordable housing in Coronado.

The plan includes the following considerations and challenges:
• Providing housing to meet the needs of all income levels is critical to the social and economic health of a city.
• It can be challenging for coastal cities like Coronado with limited housing to attract teachers, public safety officers, and military personnel, and other middle-income professionals because of the high cost of housing. The Housing Element Update will help Coronado meet the existing and future needs of the community. • Without an approved housing plan, the State can issue fines, revoke the City's permitting authority, and the City will be ineligible for certain grants.

I suggest the City explore more options for housing that are equitable and less impactful than the current areas identified in the new draft.

Land at the Coronado Cays and public golf course should also be considered as feasible locations for housing.

Although these areas will be contested by some Coronado residents, the need for housing should take precedence, and a more equitable distribution of housing should be made.

Also consider issuing housing vouchers, supported by City funds, to allow for more rental opportunities in existing apartments, condos, houses, and ADU’s.

And explore offering tax and building incentives to property owners who provide affordable housing, especially for people who work and provide services in Coronado.

Our Coronado community includes both the Village and the Cays. Please consider all land areas so that no one area is heavily impacted. And research more creative ways to meet our housing goals.

Environmental Requirements:

All new buildings should be required to add solar power to meet the State’s requirements for reducing greenhouse gas emissions. To further reduce our carbon footprint, also consider restricting the use of natural gas appliances. And add these requirements to all new City building permits.

Thank you.

Stephanie Kaupp
[email protected]
Attachment 13
City of Coronado Page 1877
From: Coronado MainStreet <[email protected]> Sent: Tuesday, March 26, 2024 12:40 PM
To: Kelsea Holian <[email protected]>
Subject: Public Comment ‐ Planning Comission Meeting
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Dear Kelsea,
I hope you can help me distribute our public comment for todays Planning Commission meeting.

Thank you,
Dear Members of the Coronado City Planning Commission,
I hope this message finds you well. As a representative of Coronado Mainstreet, I am writing to express our understanding of the challenges the City faces in meeting its Regional Housing Needs Allocation (RHNA). However, we urge you not to move forward with the proposed radical deviations from the city code. While we acknowledge the need for housing development, we believe that the potential impacts of these deviations could be mitigated through alternative means.

Concerns Raised:

1. Height Limitations: Allowing for four-story buildings raises concerns about the visual impact on the city’s skyline and character. We question why such a significant departure from current regulations is necessary and whether it aligns with the overall aesthetic and feel of Coronado, neighboring houses view blockage, etc.

2. Setback Reduction: Reduced setbacks can affect privacy, natural light, and airflow for existing residents. It is crucial to consider how these changes may impact the quality of life for those living in close proximity to new developments.

3. Mixed-Use Zoning: The proposal to allow mixed-use developments contradicts existing city regulations. This shift raises questions about consistency in planning decisions and whether it serves the best interests of all stakeholders involved.

4. Parking Requirements: Insufficient parking provisions will lead to congestion, insufficient street availability, and inconvenience for both residents and visitors. It is essential to evaluate the potential strain on existing infrastructure and amenities caused by inadequate parking solutions.

Attachment 13
City of Coronado Page 1878
In conclusion, while we recognize the importance of addressing housing needs in Coronado, we believe that there are alternative approaches that could achieve this goal without compromising the integrity of our community. We urge you to consider these concerns carefully before making a decision that could have lasting implications for our city’s future.

Thank you for your attention to this matter.

Karla Robles‐Puig
Executive Director
(619) 437‐0254  |  CoronadoMainStreet.com
[email protected]
826 Orange Ave #635, Coronado, CA 92118
Attachment 13
City of Coronado Page 1879