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
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
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
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
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
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
(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
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
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
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
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
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
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
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
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
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
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
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