Cotati City Council
Agenda Staff Report
Item type: PRESENTATIONS
To: City Council
Subject: Consideration and Review of the draft 6th Cycle Housing Element Housing Opportunity Site Map
Date: June 14, 2022
Written by: Noah Housh, Director of Community Development Recommendation
It is recommended that the City Council review the draft 6th Cycle Housing Opportunity Site Map and provide input on the specific sites proposed for removal and inclusion on the map as Housing Opportunity Sites.
Background
The State Government Code requires that all housing elements include an “inventory of land suitable for residential development, including vacant sites and sites having the potential for redevelopment” (Section 65583(a)(3)). It further requires that the Housing Element analyze existing zoning and availability of infrastructure serving these sites to demonstrate that these sites can realistically develop with housing during the planning period.. Through this process, the City must demonstrate that it has a sufficient amount of appropriately zoned land to accommodate its fair share of the region’s housing need between January 1, 2023 and December 31, 2030.
Demonstrating an adequate land supply is only part of the task, however. Cotati must also show that this supply is capable of supporting housing demand from all economic segments of the community, including lower income households. This means identifying sufficient land for both multi-family housing as well as single family housing, in order to accommodate a wide variety of housing types to meet all needs of the community. In 2004, Assembly Bill 2348 further clarified the adequate sites requirement, stipulating that the inventory must include the size of each site, its address or assessor’s parcel number, a description of the existing use, a description of any environmental and infrastructure constraints, and information demonstrating the feasibility of developing those sites that are not currently vacant. In 2017, Assembly Bill 1397 implemented stricter standards for site identification, including a realistic capacity analysis and stronger justification for non-vacant sites or sites identified in previous Housing Elements. The law also provides specific density requirements for sites identified to meet the lower income RHNA.
Analysis/Discussion
The attached graphic identifies sites proposed to be included in the 6th Cycle Housing Element, and the sites included in the 5th Cycle Housing Element. Staff has recommended that certain sites from the previous Housing Element are retained and identified others to be removed for the 6th Cycle Housing Element. This presentation is intended to allow City Council feedback on the proposed sites, and to identify any concerns with the proposed properties.
When a site is identified as a Housing Opportunity Site, it doesn’t change the underlying zoning of the property, nor does it guarantee that housing will be built in the planning period. The exercise of identifying adequate development capacity through sites. Based on new sites criteria, certain sites may receive additional allowances for by-right development or be subject to additional antidisplacement measures.
Specifically, a nonvacant site that was identified in a previous Housing Element or any site used in two previous Housing Elements must now allow ministerial approval for residential development if at least 20% of units are affordable to lower-income households. If any identified Housing Opportunity Site has existing residential units, it may be subject to replacement housing requirements similar to projects that utilize the State density bonus.
In addition to the individual sites analysis, the Housing Element must also analyze the distribution of Housing Opportunity Sites throughout the City for fair housing considerations. The location and distribution of sites by income level should improve conditions of socioeconomic and geographic distribution within the City. If the analysis identifies that patterns of segregation are exacerbated, additional programs may need to be included within the Housing Element to address those conditions pursuant to AB 686.
Following this presentation, staff will work with the consultants to finalize the list of Housing Opportunity Sites and create an administrative “back-up” list of properties. The sites receiving the formal designation of “Housing Opportunity Site” will demonstrate to the State that the City of Cotati has adequate sites available to meet the City’s 6th Cycle RHNA allocation of 234 units. The sites added to the “back-up” list are intended to allow the City flexibility in land use decision making throughout the 6th Cycle Housing Element planning period (2023-2030). Under new Housing Element law (SB 166), if the City chooses to approve a nonresidential project on a Housing Opportunity Site, or a project that did not meet the anticipated density or affordability, a “back-up” property from this list could then be used to supplement the list of Housing Opportunity Sites in line with the State’s RHNA requirements on an annual basis.
Financial Considerations
There are no direct financial implications for the City’s determination of properties to include on the Housing Opportunity Sites list, or the “administrative back up” list. The costs associated with this process were included in the Housing Element consultant contracts, and staff anticipates providing adequate properties in the draft HE document to demonstrate compliance with the State mandates.
Environmental Issues
This action is exempt from the California Environmental Quality Act (CEQA) because it is not a project which has a potential for resulting in either a direct physical change in the environment, or a reasonably foreseeable indirect physical change in the environment, pursuant to CEQA Guideline section 15378. The Housing Element document itself will receive complete analysis and a determination under the requirements of CEQA.
Attachments:
Cotati May 2022 Housing Opportunity Sites Map (PNG)