Figure 23: TCAC Opportunity Maps (2022) – Composite Score Source: 2022 TCAC/HCD Opportunity Areas/Resource Areas
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Figure 24: Population Living in Resource Areas by Race
Source: California Tax Credit Allocation Committee (TCAC)/California Housing and Community Development (HCD), Opportunity Maps (2020); U.S. Census Bureau, American Community Survey 5-Year Data (2015- 2019), Table B03002
Education
2021 TCAC Opportunity Areas Education Scores shown in Figure 25Figure 25Figure 25 provide an index for measuring the level of educational outcomes within a census tract. The higher the score, the more positive the outcomes. All census tracts that intersect through Cotati score between 0.25 – 0.50, indicating less positive education outcomes in the City.
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Figure 25: TCAC Opportunity Areas (2022) Education Score by Tract Source: 2022 TCAC/HCD Opportunity Areas/Resource Areas – Education Cotati-Rohnert Park Unified School District serves 5,766 students from Transitional Kindergarten to Grade 12 in its eleven schools. The City is also close to two higher education institutions, Sonoma State University and Santa Rosa Junior College which offer various certificate and degree programs.
The California School Dashboard calculates the number of Socioeconomically Disadvantaged students in a district based on the number of students who are eligible for free or reduced priced meals or have parents/guardians who did not receive a high school diploma. In the Cotati-Rohnert Park Unified School District, 46.2% of students fall into this category (Table 38Table 38Table 38). The District has an enrollment of 5,766 students, 46% being socioeconomically disadvantaged and 17% being English learners. The largest racial/ethnic group is Hispanic with 43.5%.
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Table 38: Cotati-Rohnert Park Unified District Student Demographics Student Group Total Percentage
English Learners 986 17.20%
Foster Youth 29 0.50%
Homeless 22 0.40%
Socioeconomically Disadvantaged 2,641 46.20%
Students with Disabilities 730 12.80%
Race/Ethnicity Total Percentage
African American 108 1.90%
American Indian 38 0.70%
Asian 171 3.00%
Filipino 63 1.10%
Hispanic 2,489 43.50%
Pacific Islander 27 0.50%
Two or More Races 366 6.40%
White 2,206 38.60%
Total Enrollment 5,468
Source: California School Dashboard, Cotati-Rohnert Park Unified, 2019 The California Assessment of Student Performance and Progress from 2018-2019 for all grades shows that the school district scores for Level 4 (Exceeds) is higher than for the County and State for English Language. The Math scores are lower than both the County and State.
Figure 26: English Language Arts/Literacy Distribution – All Grades, 2018-2019 Source: California Assessment of Student Performance and Progress
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Figure 27: Mathematics Achievement Distribution – All Grades, 2018-2019 Source: California Assessment of Student Performance and Progress Access to Healthy Environment
In October 2021, the California Office for Environmental Health Hazard Assessment (COEHHA) released the fourth version of CalEnviroScreen, a tool that uses environmental, health, and socio-economic indicators to map and compare community environmental scores. A community within the 75th percentile or above is one with higher levels of pollution and/or has other negative environmental traits and is categorized as a “disadvantaged community.” The City of Cotati contains no census tracts within the 75th percentile and therefore does not contain any Disadvantaged Communities by COEHHA metrics.
Figure 28: CalEnviroScreen 4.0 Percentiles by Census Tracts in Cotati Source: CalEnviroScreen 4.0, 2021 - Tract
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As shown in Figure 29Figure 29Figure 29, Cotati has similar environmental conditions to most similarly sized jurisdictions in the region.
Figure 29: CalEnviroScreen 4.0 Percentiles by Census Tracts in the Region Source: CalEnviroScreen 4.0, 2021 - Tract
The California Healthy Places Index (HPI) combines 25 community characteristics, like access to healthcare, housing, education, and more, into a single indexed HPI score. The healthier a community, the higher the HPI score. The HPI applies a positive frame focusing on assets a community has have they can build on, rather than what is lacking. According to this index, Cotati has healthier clean environmental conditions than 84.8% of other California Cities/Towns. Cotati’s Ozone quality scores particularly highly on this index in 96.4 percentile.
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Figure 30: Clean Environment Conditions in Cotati Compared to Other California Cities/Towns
Source: The California Healthy Places Index (HPI)
Transportation
Affordable and reliable transportation is of paramount importance to households affected by low incomes and rising housing prices. In Sonoma County, households without cars have the options of bus and train transit, bicycling, walking and an increasing network of ride-hail companies, also known as Transportation Network Companies (TNCs), all of which are less expensive than owning and driving a car or truck. Ideally, public transit would link people to job opportunities and services, especially low-income residents who are often transit-dependent. Affordable and reliable access to employment via public transportation can reduce the need for public assistance and increase housing mobility, which enables residents to locate housing outside of traditionally lower- and moderate-income neighborhoods. The lack of a robust public transit system, employment opportunities, and affordable housing may impede fair housing choice by limiting housing choice. In addition, elderly and disabled persons also often rely on public transit to visit doctors, go shopping, or attend activities at community facilities. Public transit operators work to provide access to job opportunities, public services, and affordable housing.
Sonoma-Marin Area Rail Transit (SMART) is the San Francisco Bay Area’s newest transportation option for public transit, offering passenger rail service in Sonoma and Marin counties. SMART’s rail corridor includes 11 stations, from the Sonoma County Airport to Larkspur. The Cotati station is located at 980 East Cotati Avenue. SMART connects passengers to jobs, education centers, retail hubs and housing along the Sonoma-Marin corridor, and a bicycle-pedestrian pathway. In the future, SMART
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service will be extended to Windsor, Healdsburg, and Cloverdale, and provide over 70 miles of passenger rail service. The eastern portion of Cotati has closer proximity to SMART access, and Program 1-4 is included in the Housing Element to prioritize citywide bicycle and pedestrian circulation in capital improvement for greater connection with regional transportation systems.
Figure 31: Sonoma-Marin Area Rail Transit (SMART) Service Corridor Map Sonoma County Transit (SCT), Golden Gate Transit (GGT) and Paratransit provide bus services in Cotati. SCT is the primary transit provider for all Sonoma County jurisdictions; it provides regularly scheduled fixed-route service to major activity centers and transit hubs within the City limits. Four SCT routes serve the City of Cotati:
Route 48/48X travels daily between Santa Rosa and Petaluma and serves Rohnert Park and Cotati (on Old Redwood Highway). Route 48X is an express route deviation of Route 48 that bypasses the Rohnert Park and Cotati neighborhoods along Adrian Drive.
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Route 26 travels between Sebastopol and Sonoma State University on weekdays, serving the Cotati Park & Ride lot on the west side of US 101 along the way.
Route 10 offers local service between Old Redwood Highway in Cotati and Rohnert Park’s shopping areas, Sonoma State University and, on school days, to Rohnert Park primary and secondary schools.
Route 44 provides daily service between Petaluma, Cotati, Rohnert Park, and Santa Rosa. All routes operate on approximately 45- to 90-minute headways. Sonoma County Transit staff indicated that all service routes in Cotati operate well within maximum capacity levels.
All routes operate on approximately 45- to 90-minute headways. Sonoma County Transit staff indicated that all service routes in Cotati operate well within maximum capacity levels.
Figure 32: Sonoma County Transit System Map
Source: Sonoma County Transit, 2022
Golden Gate Transit Routes 80 and 101 serve Cotati with stops located at either the Hub or the St. Joseph’s Park and Ride. Commute service to and from San Francisco is provided on weekdays in the morning and evening hours at approximately onehour intervals between 4:00 and 9:00 AM and 6:00 and 10:00 PM, with stops in
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various communities along the US 101 corridor including Santa Rosa to the north and various cities in Marin County to the south. Weekend service is provided hourly between approximately 4:00 AM and 10:00 PM. No capacity issues were identified on existing service routes.
Paratransit, also known as dial-a-ride or door-to-door service, is available for those that are unable to independently use the transit system due to a physical or mental disability. Individuals must register and be certified as ADA eligible before using the service. The ADA requires paratransit operators to service areas within three-quarters of a mile of their respective, public fixed-route service. Volunteer Wheels serves as the ADA paratransit operator for Sonoma County Transit and the City of Cotati.
Service hours are Monday through Friday from 5:00 AM to 11:00 PM and Sunday and Sunday from 7:00 AM to 9:00 PM. Ride reservations can be scheduled daily.
SCT supports the needs of the disabled community by ensuring that all bus lines are accessible through wheelchair lifts, with at least two on each bus. In addition, the agency offers half-priced fares to youth between the ages of five and eighteen, senior passengers 65 years and over, Medicare card holders, children under the age of five, U.S. veterans, college students, and disabled passengers with identification.
The County of Sonoma partners with public and nonprofit agencies to provide senior transportation support. This includes the Medical Transportation Management (MTM), Non-Emergent Medical Transportation (NEMT), Sonoma County Area Agenda on Aging, Center for Volunteer and Nonprofit Leadership, and others. There are also volunteer driver programs currently supported by the Area Agency on Aging.
In June 2018, Sonoma County Transit began its first “Fare-Free” local route. This program has resulted in a significant increase in ridership on the “Fare-Free” routes and riders have cited the ease of boarding without needing to plan for paying for a ride or purchasing a pass as an attraction.
The California Health Places Index (HPI) uses Active Commuting and Automobile access as indicators of healthy transportation conditions in a jurisdiction. Cotati has healthier transportation conditions than 76.2% of other California cities according to this index. The rate of Active Commuting in the City is low but still within the 70.7 percentile. Ride share and micromobility options continue to gradually fill in transportation options around traditional fixed route public options.
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Figure 33: California Healthy Places Index: Transportation in Cotati Source: California Healthy Places Index
Sonoma County Transportation Authority (SCTA) outlines current and future options for public transit in their Comprehensive Transportation Plan, Moving Forward 2050.
This public document is updated every five years to ensure the plan is relevant and meets community needs. In the most recent update, released in September 2021, SCTA outlines “Equity Priority Communities” and “2020 Caltrans Active Transportation Program Disadvantaged Communities.” There is one small section of northern Cotati that falls within an Equity Priority Community areas as identified using MTC Plan Bay Area criteria; however there are no identified 2020 Caltrans Active Transportation Program Disadvantaged Communities.
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Figure 34: Sonoma County Equity Priority Communities
Source: Sonoma County Transportation Authority
The Plan suggests that rising transportation costs impact household incomes and affordability throughout Sonoma County. The Center for Neighborhood Technology (CNT) estimates that transportation and housing costs accounted for over 50% of household incomes in our county. Reducing household transportation will increase countywide affordability and improve quality of life in Sonoma County.
Economic Development and Job Access
The TCAC Opportunity Maps accounts for regional differences in access to opportunities within census tracts. The Economic Domain factors in the following indicators to generate Economic Scores for each tract:
Poverty: Percent of population with income level above 200% of federal poverty line
Adult Education: Percent of adults with a bachelor’s degree or above Employment: Percent of adults aged 20-64 who are employed in the civilian labor force or in the armed forces
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Job Proximity: Number of jobs filled by workers with less than a BA that all within a given radius of each census tract
Median Home Value: Value of owner-occupied units
A score of less than 0.25 (yellow) indicates a less positive economic outcome, while scoring greater than 0.75 (dark green) indicates greater access to economic opportunities. Most of Cotati scores in the lowest quartile by these metrics.
Figure 35: TCAC Opportunity Areas (2021) Economic Scores in Cotati Source: TCAC/HCD Opportunity Areas/Resource Areas (2021) – Economic Adequate access to FDIC-regulated banks reduces the likelihood of discrimination in lending and credit services as well as predatory lending practices that further racial and socio-economic inequities. Cotati has one of the smallest populations of all jurisdictions in Sonoma County as well as one of the smallest proportions of minority populations. The City has one FDIC-regulated full-service brick and mortar bank branches (Table 39).
Table 39: FDIC-Regulated Bank Branches by Sonoma County Municipality Municipality Population5 % Minority
Population
FDIC-Regulated
Full-Service
Brick and
Mortar
Branches
FDICRegulated NonBrick and
Mortar
Branches
Santa Rosa, CA 178,127 48.8% 38 11
Petaluma, CA 59,776 33.4% 10 1
Rohnert Park, CA 44,390 41% 8 0
Windsor, CA 26,344 46.7% 4 2
Healdsburg, CA 11,340 36.8% 11 0
Sonoma, CA 10,739 27.9% 11 0
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Cloverdale, CA 8,996 42.2% 2 0
Cotati, CA 7,584 25.9% 1 0
Sebastopol, CA 7,521 21.7% 6 0
County Total 488,863 40.6% 99 13
Source: All FDIC-related data derived from: Federal Deposit Insurance Corporation, 2022 https://www7.fdic.gov/idasp/advSearch_warp_download_all.asp?intTab=1.
Future housing needs depend in part on the trajectory of the local workforce. Changes in the types and pay levels of jobs available in Cotati and the surrounding region will impact the type and cost of housing that current and future residents can afford.
Employment trends indicate a need for a range of housing types that support Cotati residents who are employed in various industries. There is a particular need for more moderate- and lower-income housing units to support workers in the retail, manufacturing, and other lower-wage industries.
“Projections 2040” is the most recent in the Association of Bay Area Governments’ (ABAG) series of data on demographic, economic, and land use changes in coming decades, the current version covering the period between 2010 and 2040. The projections in Table 40Table 40Table 40 illustrates how Cotati will grow economically both in terms of the number of jobs and employed residents. Excluding past years, the period of largest job growth and employed resident in Cotati is expected in 2030.
Table 40: Projected Change in Jobs and Employed Residents in Cotati between 2010 and 2040
Year Jobs % Change Employed
Residents % Change
2010 2,705 4,120
2015 2,830 1.0% 4,535 10.1%
2020 2,905 4.8% 4,620 1.9%
2025 2,930 6.9% 4,825 4.4%
2030 2,900 11.5% 5,245 8.7%
2035 2,905 2.3% 5,250 0.1%
2040 2,955 10.8% 5,650 7.6%
Source: ABAG/MTC, Plan Bay Area 2040 Projections, 2017
Employment inflow/outflow analyses highlight the movement of workers commuting into and out of Cotati (Figure 36Figure 36Figure 36) and are useful in understanding the ratio between residents who are employed within the City and those who are employed outside of the City as well as how many workers are commuting to work from outside of the City.
As shown in Figure 36Figure 36Figure 36, Cotati is a net exporter of workers which means most employed people in Cotati commute outside of the City for work. Of the 6,843 workers who live and/or work in Cotati, 161 (2.4%) are employed and live in Cotati, 3,742 (54.7%) live in but are employed outside of Cotati, and 2,940 (43.0%) live outside but are employed in Cotati. Further analysis of worker flow is
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needed to determine if there is a housing need for non-resident employees (i.e., average length of commutes, city-wide VMT analysis, etc.).
Figure 36: Inflow and Outflow of Workers in Cotati
*Note: Arrows do not indicate directionality of worker flow Source: OntheMap.ces.census.gov, 2019
Figure 37Figure 37Figure 37 ranks jurisdictions in Sonoma County based on its respective jobs-to-housing ratio. The higher the ranking, the stronger the jobs-tohousing ratio which means that the City more adequately provides housings according to the number of jobs and vice-versa. Sonoma and Sebastopol top the list with jobs-to-housing ratios above 1.4 (i.e., 1.4 jobs produced for every home built). Not significantly far behind, Cotati produces 1.3 jobs for every home built. All Sonoma County jurisdictions rank well below the average Bay Area jurisdiction given that cities like San Francisco and San Jose produce more than three jobs for every permitted home according to the State of Housing in Sonoma County 2022 report.
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Figure 37: Ratio of All Jobs to Homes in Sonoma County Jurisdictions Source: California Department of Housing and Community Development, Annual Progress Reports, Generation Housing Disparities in Access to Opportunity: Fair Housing Issues and Contributing Factors
Cotati residents have access to a high-quality healthy environment, and there are no notable disparities in access to transportation, jobs, or education by protected class.
4.5.5 Disproportionate Housing Needs, Including Displacement Disproportionate housing needs generally refer to significant disparities in the proportion of members of a protected class experiencing a category of housing needs when compared to the proportion of members of any other relevant groups, or the total population experiencing that category of housing need in the applicable geographic area. For purposes of this definition, categories of housing need are based on such factors as cost burden and severe cost burden, overcrowding, homelessness, and substandard housing conditions. This section analyzes these four housing needs categories as they apply to the City of Cotati.
Cost Burden and Severe Cost Burden
Housing cost burden is commonly measured as the percentage of gross income spent on housing, with 30% threshold for 'cost burden' and 50% the threshold for 'severe cost burden.' A lower-income household spending the same percent of income on housing as a higher-income household is therefore more likely to experience a ‘cost burden.' Some of the implications of high-cost burden can include housing-induced poverty, where overspending on housing leaves households little financial resources for other expenditures, and reduced savings which can impact asset accumulation. The typical contract rent for an apartment in Cotati was $1,470 in 2019. Rental prices increased by 41.3% from 2009 to 2019.
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To rent a typical apartment without cost burden, a household would need to make $59,120 per year. 18
Additionally, rental costs for listed market rate units are higher than the typical contract rent for established leases, with a median monthly rental cost of $2,800 (Table 41).
Table 41: Current Market Rate Rental Costs
# Bedrooms 1 2 3 4 5 All Units
Median Rent $1,913 $2,550 $3,000 $3,575 $4,725 $28,00
Source: Zillow.com, Accessed 1/19/22
Home prices have skyrocketed in the last decade; however, most homeowners have mortgages with fixed rates or own outright and are therefore less likely to be impacted by market increases. Renters on the other hand are subject to rent increases based on market rates and tend to experience a greater cost burden. This is the case in Cotati where 47% of renters are either cost-burdened or severely costburdened while only 27% of homeowners are either cost burdened or severely costburdened (Figure 38Figure 38Figure 38).
Figure 38: Cost Burden by Tenure in Cotati, 2019
Source: U.S. Census Bureau, American Community Survey 5-Year Data (2015-2019) 18 Housing Needs Data Report: Cotati, ABAG/MTC Staff and Baird + Driskell Community Planning, 2021-04-02
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Rates of cost burden also vary across income categories. Over half of extremely lowincome households in Cotati are severely cost-burdened. The proportion of severely cost-burdened households becomes exponentially smaller as income increases (Figure 39Figure 39Figure 39). This indicates that the lowest income households are in the greatest need of affordable housing in Cotati.
Figure 39: Cost Burden by Income Level in Cotati
Source: U.S. Department of Housing and Urban Development (HUD), Comprehensive Housing Affordability Strategy (CHAS) ACS tabulation, 2013-2017 release
Compared to Sonoma County and the State, Cotati has comparable rates of housing cost burden. In both Cotati and the Bay Area, 36.1% of households experience cost burden while in Sonoma County that number is slightly higher at 38.9% (Table 42Table 42Table 42). Overpayment rates for renters were in the same quintile citywide, whereas homeowners in the sprawling westerly census tract exhibited higher rates of cost burden.
Table 42: Cost Burden Severity in Cotati, County, State Geography
0%-30% of
Income Used for
Housing
30%-50% of
Income Used for
Housing
50%+ of Income
Used for Housing
Cotati 62.4% 22.4% 13.7%
Sonoma County 58.7% 21.5% 17.4%
Bay Area 61.7% 19.7% 16.4%
Source: U.S. Census Bureau, American Community Survey 5-Year Data (2015-2019), Table B25070, B25091
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Overcrowding
Households having more than 1.01 to 1.5 persons per room are considered overcrowded and those having more than 1.51 persons per room are considered severely overcrowded. The person per room analysis excludes bathrooms, porches foyers, halls, and half-rooms. Residential overcrowding reflects demographic and socioeconomic conditions as it has been correlated with increased risks of contracting communicable diseases, higher rates of respiratory illness, and greater vulnerability to being homeless.
Older-adult immigrant and recent immigrant communities, families with low incomes and renter-occupied households are more likely to experience household crowding.
A form of residential overcrowding known as "doubling up" is co-residing with family members or friends for economic reasons. Doubling up is the most reported living situation for families and individuals before the onset of homelessness.19 In Cotati, rates of overcrowding are highest for Hispanic households followed by Other Race or Multiple. Non-Hispanic White households experience the lowest rates of overcrowding followed by Hispanic and Non-Hispanic White households (Figure 40Figure 40Figure 40). Hispanic and Asian households both experience higher rates of overcrowding than the city average. As with the data discussed for disability status above, age may play a factor in racial and ethnic disparities in overcrowding. Younger adults are more likely to have minor children in their households, which, in turn, increases the likelihood of overcrowding. Conversely, older adults are more likely to reside in one- or two-person households.
Census tracts across the City exhibit similar rates of overcrowding at around 2-3%. 19 California Department of Health and Human Services
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Figure 40: Occupants Per Room for Households by Race and Ethnicity Source: 2015-2019 American Community Survey 5-Year Estimates Cotati has 3% more households that experience both overcrowding and severe overcrowding than in Sonoma County and the Bay Area. This may be partially attributed to the number of Sonoma Stata University students who rent locally rather than living on campus in dormitories.
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Figure 41: Overcrowding Severity in Cotati, Sonoma County and the Bay Area Source: U.S. Department of Housing and Urban Development (HUD), Comprehensive Housing Affordability Strategy (CHAS) ACS tabulation, 2013-2017 release
Substandard Housing
As defined by the U.S. Census, there are two types of substandard housing problems:
(1) Households without hot and cold piped water, a flush toilet and a bathtub or shower; and (2) Households with kitchen facilities that lack a sink with piped water, a range or stove, or a refrigerator. In Cotati, less than 1.2% of both owners and renters experience either of these two types of substandard housing problems (Table 43Table 43Table 43). Cotati has more substandard housing issues among homeowners than renters, while Sonoma County has more substandard housing issues among renters than owners. Data indicate a similar rate of substandard housing issues across the City, and lower rates than the neighboring cities of Rohnert Park, Santa Rosa, and Sebastopol.
Table 43: Substandard Housing Issues
Cotati Sonoma County
Building Amenity Owner Renter Owner Renter
Lacking Complete Kitchen 1.2% 0.8% 0.4% 1.7%
Lacking Plumbing 1.2% 0.0% 0.4% 0.6%
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Source: U.S. Census Bureau, American Community Survey 5-Year Data (2015-2019), Table B25053, Table B25043, Table B25049
Homelessness
Those experiencing homelessness include individuals or families who lack or are perceived to lack a fixed, regular, and adequate nighttime residence, or who have a primary nighttime residence in a shelter, on the street, in a vehicle, or in an enclosure or structure that is not authorized or fit for human habitation. People experiencing homelessness have the most immediate housing needs of any population group and are most vulnerable to violence and criminalization due to their unhoused status.
California accounts for almost half (47%) of the U.S. homeless population and Sonoma County has the fourth highest number of homeless individuals for large suburban areas in the country. The 2020 Sonoma County Point-In-Time Count reported 2,745 individuals experiencing homelessness, a seven percent decrease in homeless persons since 2019. Of those experiencing homelessness in the County, the majority (63%) are white men. Between 2019 and 2020, the number of sheltered populations increased by five percent.20
The 2020 Point-In-Time Count totaled 37 individuals experiencing homelessness in Cotati which was down from 44 individuals in 2014. All 37 of these individuals were counted as unsheltered (Table 44Table 44Table 44). Of all Cotati’s residents, 0.04% are unhoused, compared to 0.5% for Sonoma County as a whole.
Table 44: Homeless Persons in Cotati by Shelter Status
Shelter Status 2018 2019 2020
Unsheltered 1 44 37
Sheltered 0 0 0
Total 1 44 37
Source: 2020 Sonoma County Homeless Census Comprehensive Report Displacement
Shifts in neighborhood composition are framed and perpetuated by established patterns of racial inequity and segregation. Neighborhood change occurs as a result of three processes: movement of people, public policies, and investments, such as capital improvements and planned transit stops, and flows of private capital.21 These processes can disproportionally impact people of color, as well as lower income households, persons with disabilities, large households, and persons at-risk or experiencing homelessness. They can also displace people to the extent of homelessness.
20 County of Sonoma Community Development Commission “Project Homekey” page 21 Zuk, M., et al. (2015). Gentrification, Displacement, and the Role of Public Investment. Federal Reserve Bank of San Francisco, 32.
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For the purposes of this assessment, displacement is used to describe any involuntary household move caused by property owner action or market changes.
Displacement is fueled by a combination of rising housing costs, rising income inequality, stagnant wages, and insufficient market-rate housing production.22 Decades of disinvestment in low-income communities, couples with investor speculation, can result in a rent gap or a disparity between current rental income and the land, and potentially achievable rental income if the property is converted to its most profitable use.
The University of California, Berkeley (UCB)’s Urban Displacement Project Bay Area Model 2020 identifies most census tracts in Cotati as Low-Income/Susceptible to Displacement. A smaller tract in the most southeastern part of the city is Stable Moderate/Mixed Income. As shown in Figure 43, Cotati has a similar or lower displacement risk compared to most jurisdictions in the region.
Figure 42: Urban Displacement Project Bay Area Model 2020 - Cotati Source: Chapple, K., & Thomas, T., and Zuk, M. (2021). Urban Displacement Project website. Berkeley, CA:
Urban Displacement Project.
22 Been, V., Ingrid, E., & O’Regan, K. (2019). Supply Skepticism: Housing Supply and Affordability. Housing Policy Debate, 29(1), 25-40.
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Figure 43: Urban Displacement Project Bay Area Model 2020 – North Bay Region
Source: Chapple, K., & Thomas, T., and Zuk, M. (2021). Urban Displacement Project website. Berkeley, CA:
Urban Displacement Project.
Figure 44Figure 44Figure 44 identifies areas that at risk of flooding and/or disasterdriven displacement. The Special Flood Hazard Areas in Cotati exist along the northeastern border of the City where there are 0.2% (light purple) and 1% (dark purple) Annual Chance Flood Hazard areas and a Regulatory Floodway. The northwestern part of the City also has a wide area that has 0.2% annual chance of flooding.
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Figure 44: Special Flood Hazard Areas (FEMA, 2020) in Cotati Source: Flood Hazard Areas from the Flood Insurance Rate Map created by the Federal Emergency Management Agency (FEMA)
Disproportionate Housing Needs and Displacement: Fair Housing Issues and Contributing Factors
The risk of displacement due to economic pressures was ranked and the most important factor contributing to fair housing issues in Cotati. The rising cost of housing in Cotati, Sonoma County, and across the Bay Area region is driving displacement of the most vulnerable populations. This is not only disruptive and, in some cases, traumatic for displaced households, but is also a primary driver of segregation at the regional scale. Despite some risk of displacement due to natural disasters, the displacement identified by the contributing factors analysis was exclusively focused on economic displacement, deemed a larger risk. Factors that contribute to disproportionate housing needs in the City of Cotati include economic pressures and community opposition. Programs described in the table below, including Program 4-3: Nondiscrimination and Fair Housing Information and Program 2-2 Streamlining Housing Development, will help to ensure that residents, tenants and property owners are aware of their rights and obligations under the law, including tenant protection measures, and will reduce discretionary reviews and permitting levels for affordable housing projects.
4.5.6 Summary of Fair Housing Goals and Priorities Based on Identified Contributing Factors
Table 45: Prioritization of Contributing Factors
Prioritized Contributing
Factors
Meaningful Actions
Displacement of residents
due to economic pressures
Program 4-1 Antidisplacement Actions
Pursue grant opportunities to create a residential
rehabilitation program for lower income residents.
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Priority: High Explore a Condominium Conversion ordinance to limit the loss of rental housing stock, as applicable.
Continue to promote programs for housing stability and eviction prevention.
Prepare a directory of trusted community partners willing to promote these programs. Utilize these partnerships to share resources in a culturally sensitive manner and
incorporate place-based outreach.
Program 1-5 Preservation of Affordable Housing
Provide committed assistance to protect 28 at-risk units Monitor developments at risk of converting from deedrestricted affordable housing Program 3-4 Housing Choice Vouchers
Monitor the status of the Section 8 waiting list on a quarterly basis and issue a citywide notification via the City’s mailing list upon periodic opening of the waiting list Community Opposition
Priority: Moderate
Program 2-2 Streamlining Housing Development
Develop a written streamlined application process in
accordance with SB 35 and SB 330, including the preapplication and the procedure. Develop Objective Design and Development Standards for multi-family, single-family and mixed-use projects.
Program 1-3 Non-Profit and Agency Coordination
Convene an annual discussion on Housing Fair between
housing developers, decisionmakers, advocates, and other interested parties and continue working with and develop new relationships with local agencies, nonprofit housing providers, and local organizations.
Lack of affordable units
appropriately sized for
large families
Priority: Moderate
Program 3-2 Funding for Affordable and Special Needs Housing Continue to seek funding for affordable and special needs housing, including affordable housing for large households Use the Housing Fund to make housing available to very low to moderate-income Cotati residents, with an
emphasis on very low and low income units for individuals and large families, affordable senior housing, and
transitional/supportive housing.
Lack of awareness of and
funding for fair housing
outreach and enforcement
Priority: Low
Program 1-3 Non-Profit and Agency Coordination
Convene an annual discussion on Housing Fair between
housing developers, decisionmakers, advocates, and other interested parties and continue working with and develop new relationships with local agencies, nonprofit housing providers, and local organizations.
Program 4-3 Nondiscrimination and Fair Housing Information Require bilingual (English/Spanish) availability of rental agreements by 2025.
Continue to maintain an inventory of existing affordable rental housing and affordable ownership opportunities and programs on the City website.
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Continue to provide information regarding equal housing opportunity laws and the City's equal housing
opportunities procedures to the public at City Hall, the Police Department and the City’s website. Include
information about Fair Housing of Sonoma County to
ensure residents with grievances can connect to the
appropriate agencies and services.
Lack of public investment in
neighborhoods, including
services & amenities
Priority: Low
Program 1-4: Capital Improvement Program
Maintain infrastructure in Lower Resource Areas
Program 2-6: Santero Way Specific PlanRezoning
Increase capacity for transit-oriented development in the Moderate Resource Area
Program 3-6: Prohousing Designation
Review policies and programs within one year of Housing Element Adoption. If eligible, apply to receive the
Prohousing Designation and receive an advantage in
applications for competitive funding sources, including funding for infrastructure and transit.
4.5.7 Housing Sites and AFFH Considerations
Housing sites identified to meet Cotati’s RHNA are distributed throughout the community in a manner that affirmatively furthers fair housing. While Cotati only contains areas designated as Low Resource and Moderate Resource, sites are distributed throughout these two areas, not concentrated by income, and supported by fair housing programs.
The resource designations of both Census tracts are influenced by activity outside City limits. The Low Resource westerly tract is influenced by residents from the northern boundary at Wilfred Avenue including the entirety of western Rohnert Park and wrapping around Cotati to the unincorporated community of Penngrove. The Moderate Resource easterly tract is influenced by the L Section of Rohnert Park.
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Figure 45: Housing Sites and Resource Areas
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Source: HCD/TCAC Opportunity Maps, 2022
Segregation and Integration
The Assessment of Fair Housing found no identifiable clusters of segregation by race, ethnicity, income, or protected classes. Cotati is generally more integrated than most nearby jurisdictions. Housing sites are dispersed throughout the community and promote integration.
Table 46: Housing Sites and Segregation Indicators
Census
Tract
Block
Group
Housing
Sites
Housing
Units
LowerIncome
Housing
Units
Population
with a
disability,
Tract
% Households in
renter-occupied
housing units,
Tract
% Hispanic
Population,
Block Group
% Non-White
Population,
Block Group
151201 5 4 498512 49 849 36% 35% 44%
151203 1 32 104 11 555 41% 23% 35%
151203 2 0 51 0 555 41% 15% 20%
151203 4 3 19 0 555 41% 22% 35%
151204 1 2 42 3 350 42% 17% 27%
151204 2 21 2761 245 350 42% 25% 37%
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151204
301 13 01 061 030 442 428% 2130% 4033%
Source: American Community Survey 2019, 5-Year Estimates Racially and Ethnically Concentrated Areas of Poverty
There are no racially/ethnically concentrated areas of poverty or racially concentrated areas of affluence within Cotati. The location of housing sites does not affect these conditions.
Disparities in Access to Opportunity
There are minimal disparities in access to opportunity by protected class and income throughout Cotati. Sites on the western side of the City are located in a Lower Resource area. Particularly, sites west of the freeway have less access to transportation and are further from amenities and resources. Program 1-4: Capital Improvement Program (CIP) is included to address this need. The block group with the most lower-income capacity is located in the area with the highest job proximity index score, improving access to opportunity. Most sites identified are located within Low Resource areas. Under Program 2-6, the City will rezone land within its Moderate Resource area to allow higher density housing and improve access to opportunity.
Table 47: Housing Sites and Access to Opportunity
Census
Tract
Block
Group Sites Units
LowerIncome
Housing
Units
2022
TCAC/HCD
Resource
Level
2022
TCAC/HCD
Educational
Score
2022
TCAC/HCD
Environmental
Score
2022
TCAC/HCD
Economic
Score
Job
Proximity
Index
Score
151201 5 4
5124
98 49 Low 0.33 0.43 0.1 82
151203 1 32 104 11 Moderate 0.43 0.97 0.22 2
151203 2 0 51 0 Moderate 0.43 0.97 0.22 5
151203 4 3 19 0 Moderate 0.43 0.97 0.22 3
151204 1 2 42 3 Low 0.26 0.77 0.26 10
151204 2 21 6127 452 Low 0.26 0.77 0.26 17
151204
151301 31 10 610 300 Low 0.26 0.95 0.11 510
Sources: HCD/TCAC Opportunity Area Maps, 2022; HUD Job Proximity Index, 2014-2017 Disproportionate Housing Needs Including Displacement
Risk of displacement and cost burden are highest amongst low-income renter households. The location of housing sites will not exacerbate these conditions, and programs are included to address this need, including Program 4-1:
Antidisplacement Actions.
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Table 48: Housing Sites and Housing Needs Indicators
Census Tract Block
Group
Housing
Sites
Housing
Units
LowerIncome
Housing
Units
% LMI
Population,
Block Group
Median
Income,
block group
151201 5 4 498512 49 70% $47,120
151203 1 23 104 11 48% $65,417
151203 2 0 51 0 20% 126983
151203 4 3 19 0 43% 65469
151204 1 2 42 3 32% $75,542
151204 2 21 6127 452 36% $71,250
151204151301 31 10 610 300 3875% 77143$57,202
Source: HUD, Low to Moderate Income Population, 2015; American Community Survey, Median Income, 2019 5-Year Estimates
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Packet Pg. 304 Attachment: Attachment 1, Exhibit B2-TC - Cotati Adoption Draft Technical Background Report - Tracked Changes (Housing Element Update) 2023-2031 Housing Element Update
Addendum Evaluation
State Clearinghouse # 2013082037
prepared by
City of Cotati
Community Development Department
201 West Sierra Avenue
Cotati, California 94931
Contact: Noah Housh, Director of Community Development
prepared with the assistance of
Rincon Consultants, Inc.
449 15th Street, Suite 303
Oakland, California 94612
March 2023
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Packet Pg. 305 Attachment: Cotati HE_Final Addendum_March 2023-Signed (Housing Element Update) 2023-2031 Housing Element Update
Addendum Evaluation
State Clearinghouse # 2013082037
prepared by
City of Cotati
Community Development Department
201 West Sierra Avenue
Cotati, California 94931
Contact: Noah Housh, Director of Community Development
prepared with the assistance of
Rincon Consultants, Inc.
449 15th Street, Suite 303
Oakland, California 94612
March 2023
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Table of Contents
1 Introduction and Project Summary ................................................................................................1
1.1 Project Title.........................................................................................................................1
1.2 Lead Agency/Project Sponsor Name and Address..............................................................1
1.3 Contact Person and Phone Number ...................................................................................1
1.4 Project Location ..................................................................................................................1
1.5 Project Description..............................................................................................................1
1.6 Discretionary Action............................................................................................................3
1.7 Prior Environmental Document(s) ......................................................................................3
1.8 Location of Prior Environmental Document(s) ...................................................................3 2 Project Context...............................................................................................................................4
2.1 Purpose of the Housing Element ........................................................................................4
2.2 Updates to the Housing Element........................................................................................4
2.3 Regional Housing Needs Allocation ....................................................................................5
2.4 Changes in State Law ..........................................................................................................5
2.5 City of Cotati General Plan..................................................................................................6
2.6 Cotati General Plan EIR .......................................................................................................6
2.7 Housing Element Update ....................................................................................................8 3 Overview of CEQA Guidelines Section 15164 and Section 15162 ................................................10 4 Environmental Effects and Determination...................................................................................12
4.1 Environmental Areas Determined to Have New or Substantially More Severe Significant Effects Compared to Those Identified in the Previous EIR..............................12
4.2 Determination...................................................................................................................12 5 Addendum Evaluation Methodology............................................................................................14
5.1 General Plan Consistency..................................................................................................14
5.2 Preliminary Environmental Constraints............................................................................16 6 Addendum Evaluation ..................................................................................................................17
6.1 Aesthetics..........................................................................................................................17
6.2 Agriculture and Forestry ...................................................................................................18
6.3 Air Quality .........................................................................................................................19
6.4 Biological Resources..........................................................................................................20
6.5 Cultural Resources............................................................................................................21
6.6 Energy ...............................................................................................................................22
6.7 Geology and Soils..............................................................................................................23
6.8 Greenhouse Gas Emissions...............................................................................................24
6.9 Hazards and Hazardous Materials ....................................................................................25
6.10 Hydrology and Water Quality ...........................................................................................26
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ii
6.11 Land Use and Planning......................................................................................................27
6.12 Mineral Resources ............................................................................................................28
6.13 Noise .................................................................................................................................29
6.14 Population and Housing....................................................................................................30
6.15 Public Services...................................................................................................................31
6.16 Recreation.........................................................................................................................32
6.17 Transportation ..................................................................................................................33
6.18 Tribal Cultural Resources..................................................................................................35
6.19 Utilities..............................................................................................................................36
6.20 Wildfire..............................................................................................................................37 7 Conclusion.....................................................................................................................................39 8 References....................................................................................................................................40
8.1 Bibliography ......................................................................................................................40
8.2 List of Preparers................................................................................................................40 Tables
Table 1 2023-2031 Regional Housing Needs Allocation..................................................................5 Table 2 Summary of Areas of Potential Impact under the General Plan EIR...................................7 Table 3 Housing Unit Yield per Site Category ................................................................................15 Figures
Figure 1 Regional Project Location ...................................................................................................2 Appendices
Appendix A Coast Miwok Ethnographic Context
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Acronyms and Abbreviations
AB Assembly Bill
ABAG Association of Bay Area Governments
ADU accessory dwelling unit
AMI Area Median Income
BAAQMD Bay Area Air Quality Management District
CAPCOA California Air Pollution Control Officers Association CEQA California Environmental Quality Act
CCR California Code of Regulations
EIR Environmental Impact Report
FHSZ Fire Hazard Severity Zone
GHG greenhouse gas
HCD California Department of Housing and Community Development LOS level of service
RHNA Regional Housing Needs Assessment
SB Senate Bill
SOI Sphere of Influence
SR State Route
TCAC Tax Credit Allocation Committee
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1 Introduction and Project Summary
1.1 Project Title
City of Cotati 2023-2031 Housing Element Update
1.2 Lead Agency/Project Sponsor Name and Address
City of Cotati
Community Development Department
201 West Sierra Avenue
Cotati, California 94931
1.3 Contact Person and Phone Number
Noah Housh, Director of Community Development
(707) 665-3635
1.4 Project Location
The City of Cotati (City) is located in Sonoma County, approximately 17 miles east of the Pacific Ocean, 40 miles north of San Francisco, and 7 miles south of Santa Rosa. The city is north of Petaluma, south of Rohnert Park, and west of the Sonoma Mountains. Much of the city is situated along U.S. Highway 101 (US 101), with State Route 116 (SR 116) entering the city from the northwest. The Housing Element Update’s planning boundaries include all land within the Cotati city limits, as shown in Figure 1.
1.5 Project Description
The project consists of a comprehensive update to the City of Cotati 2023-2031 Housing Element Update (herein referred to as “Housing Element update” or “project”). The City’s General Plan underwent extensive environmental review in the form of an Environmental Impact Report (EIR), which was certified in 2015. The EIR for the Cotati General Plan is a comprehensive document and includes discussion of alternatives and growth-inducing impacts associated with urban development in the city at the time it was developed.
State law requires that housing elements be updated every eight years (California Government Code Sections 65580 to 65589.8). The Housing Element update identifies residential sites adequate to accommodate a variety of housing types for all income levels and needs of special population groups, defined under State law (California Government Code Section 65583). It analyzes governmental constraints to housing maintenance, improvement, and development; addresses conservation and improvement of the condition of existing affordable housing stock; and outlines policies that promote housing opportunities for all persons. The City’s Housing Element is being updated as part of the State’s 6th cycle Regional Housing Needs Allocation (RHNA). For Cotati, the planning period runs from 2023 through 2031.
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2 Figure 1 Regional Project Location
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The project would bring the City’s Housing Element into compliance with State legislation passed since the publication of the previous (5th cycle) Housing Element (adopted in 2015). The Housing Element update includes a housing sites inventory (Section 3 and Appendix D of the Housing Element) that demonstrates how the City plans to meet its 6th cycle RHNA. However, no formal land use changes, rezoning, or physical development are proposed as part of the Housing Element update.
The Housing Element update establishes objectives and policies designed to guide future development as the City works to achieve State-mandated housing goals. Future development will require project-specific developmental review as potential impacts are location-specific and cannot be assessed in a meaningful way until a project site and development proposal are identified. When a specific development proposal is considered for approval, that project would be subject to adopted development guidelines/standards and it must incorporate applicable mitigation measures developed in the General Plan EIR (in accordance with CEQA Guidelines Section 15168[c][3]). If a subsequent activity (in this case a specific development proposal) would have effects not identified in the certified EIR (the General Plan EIR and this Addendum), the City must prepare additional environmental documentation to comply with CEQA.
This Addendum, therefore, analyzes the changes and potential impacts related to the adoption of Housing Element update. This Addendum is intended to demonstrate consistency of the Housing Element update with the existing General Plan EIR to comply with CEQA. In particular, and in line with Public Resources Code Section 21083.3, this Addendum assesses whether the Housing Element update, as a policy and programs document, includes impacts not addressed or previously analyzed in the General Plan EIR.
1.6 Discretionary Action
Implementation of the Housing Element would require the following discretionary actions by the City of Cotati Planning Commission and/or City Council:
▪ Adoption of the updated Housing Element and General Plan Amendment The California Department of Housing and Community Development (HCD) reviews and determines whether the proposed Housing Element complies with State law. Aside from HCD, no other approvals by outside public agencies are required.
1.7 Prior Environmental Document(s)
City of Cotati, General Plan Update Environmental Impact Report (General Plan Update EIR). State Clearinghouse Number 2013082037, certified March 2015.
1.8 Location of Prior Environmental Document(s)
City of Cotati, Planning Department Website: http://cotati.generalplan.org/content/environmentaldocuments/index.html
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4 2 Project Context
The California Legislature has identified the attainment of a decent home and suitable living environment for every resident as the State’s major housing goal. Recognizing the important role of local planning programs in pursuing this goal, the legislature mandated that all cities and counties prepare a housing element as part of their comprehensive general plans. Government Code Sections 65580 to 65589.8 set forth the specific components to be contained in a community’s housing element.
2.1 Purpose of the Housing Element
The Housing Element of the General Plan is designed to provide the City with a coordinated and comprehensive strategy for promoting the production of safe, decent, and affordable housing within the community. A priority of both State and local governments, Government Code Section 65580 states that “the availability of housing is of vital statewide importance, and the early attainment of decent housing and a suitable living environment for every Californian, including farmworkers, is a priority of the highest order.”
Pursuant to State law, the Housing Element has two main purposes:
1. To provide an assessment of both current and future housing needs and constraints in meeting these needs
2. To provide a strategy that establishes housing goals, policies, and programs The Housing Element is one of the eight General Plan elements the State mandates in Government Code Section 65302. The Housing Element serves as an integrated part of the General Plan but is updated more frequently to ensure its relevancy and accuracy. The Housing Element identifies strategies and programs that focus on:
1. Conserving and improving existing affordable housing
2. Maximizing housing opportunities throughout the community
3. Assisting in the provision of affordable housing
4. Removing governmental and other constraints to housing investment
5. Promoting fair and equal housing opportunities
The residential character of Cotati is largely determined by the variety, location, and maintenance of its housing. The Housing Element is an official response to the need to provide housing for all economic segments of the population, establishing goals, policies, and programs that will guide City decision making and set forth an action plan to implement these housing programs through an established planning period.
2.2 Updates to the Housing Element
State law requires that housing elements be updated every eight years (California Government Code Section 65588). The Housing Element must identify residential sites adequate to accommodate a variety of housing types for all income levels and to meet the needs of special population groups as
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defined under State law (California Government Code Section 65583). The Housing Element analyzes market and governmental constraints to housing maintenance, improvement, and development; addresses conservation and improvement of the condition of existing affordable housing stock; and outlines policies that promote housing opportunities for all persons.
2.3 Regional Housing Needs Allocation
The RHNA reflects the HCD’s determination of the projected housing needs in a region by household income level as a percent of the Area Median Income (AMI). The Association of Bay Area Governments (ABAG) was tasked with allocating this regional housing need among the jurisdictions in the ABAG region, which includes Sonoma County. Table 1 shows the breakdown of the RHNA for the City of Cotati during the 2023-2031 planning period.
Table 1 2023-2031 Regional Housing Needs Allocation
Income Group
Cotati
Unit Needs
Percent of
Total Units
Regional
Unit Needs (ABAG)
Percent of
Regional Units
Very low ( 50% AMI) 60 25.6% 114,442 25.9%
Low (> 50-80% AMI) 34 14.5% 65,892 14.9%
Moderate (>80-120% AMI) 39 16.7% 72,712 16.5%
Above Moderate (>120% AMI) 101 43.2% 188,130 42.6%
Total 234 100.0% 441,176 100.0%
AMI = Area Median Income (established annually by the Department of Housing and Urban Development) Source: ABAG 2022
The City had 3,215 households as of January 2022. Throughout the city, approximately 65 percent of housing units were single-family, including approximately 46 percent single-family detached units and approximately 19 percent single-family attached units; multi-family dwelling units comprised approximately 32 percent of the city’s housing stock; and the remaining approximately 4 percent were mobile homes (California Department of Finance 2022).
2.4 Changes in State Law
The following items represent substantive changes to State housing law since the City’s last Housing Element was adopted and certified in 2015. The Housing Element update has incorporated and addressed all pertinent housing law changes.
▪ Affordable Housing Streamlined Approval Process: Senate Bill 35 (2017) ▪ Additional Housing Element Sites Analysis Requirements: Assembly Bill 1397 (2017) ▪ Affirmatively Furthering Fair Housing: Assembly Bill 686 (2017) ▪ No-Net-Loss Zoning: Senate Bill 166 (2017)
▪ By Right Transitional and Permanent Supportive Housing: Assembly Bill 2162 (2018) ▪ Housing Crisis Act of 2019: Senate Bill 330
▪ Standardization of Sites Inventory Analysis and Reporting: Senate Bill 6 (2019)
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6 ▪ California Housing Opportunity and More Efficiency (HOME) Act: Senate Bill 9 (2022) ▪ Senate Bill 10 (2022)
2.5 City of Cotati General Plan
State law mandates that each city and county in California adopt "a comprehensive, long-term general plan,” for the physical development of its planning area. The Cotati General Plan planning area includes all lands within the city limits and Sphere of Influence (SOI). The purpose of the General Plan is to plan for important community issues such as new growth, housing needs, and environmental protection. Furthermore, the General Plan is used to project future demand for services such as sewer, water, roadways, parks, and emergency services.
The Cotati General Plan, adopted in March 2015, is a long-term document which identifies the community’s vision for the future and provides a framework that will guide decisions on growth, development, and conservation of open space and resources in a manner that is consistent with the quality of life desired by the city's residents and businesses.
The General Plan policy document contains the goals and policies that will guide future decisions within the city and identifies action items (implementation measures) to ensure the vision and goals of the General Plan are carried out. The General Plan also contains a revised Land Use Map, which serves as a general guide to the distribution of land uses throughout the city.
State law requires that every General Plan, at a minimum, address certain subject categories (called "elements"), which include land use, circulation, housing, conservation, open space, noise, safety, and environmental justice. A General Plan may also address other subjects that are of importance to the community future, such as sustainability, community design, and public art. Cotati’s General Plan includes the following elements:
▪ Circulation
▪ Community Health & Wellness
▪ Community Services & Facilities
▪ Conservation
▪ Economic Vitality
▪ Land Use
▪ Noise
▪ Open Space
▪ Safety
2.6 Cotati General Plan EIR
The City of Cotati General Plan Update EIR (herein called the General Plan EIR) addressed the potential environmental effects of the planned buildout of Cotati through the 20-year period and concluded that implementation of the General Plan would result in environmental impacts as detailed in Table 2. Actions and policies were incorporated into the General Plan EIR to reduce potential impacts from project development under the General Plan.
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Table 2 Summary of Areas of Potential Impact under the General Plan EIR Issue Area
Level of Significance
after Mitigation
Mitigation Proposed
in the General Plan EIR
Aesthetics and Visual Resources Significant and
Unavoidable
Mitigated to the greatest extent feasible
through General Plan policies and actions.
No additional feasible mitigation is available.
Air Quality Less than Significant General Plan policies and actions mitigate this impact to a less than significant level
Biological Resources Less than Significant General Plan policies and actions mitigate this impact to a less than significant level
Cultural Resources Less than Significant General Plan policies and actions mitigate this impact to a less than significant level
Geology and Soils Less than Significant General Plan policies and actions mitigate this impact to a less than significant level
Greenhouse Gases and Climate Change Less than Significant General Plan policies and actions mitigate this impact to a less than significant level
Hazards and Hazardous Materials Less than Significant General Plan policies and actions mitigate this impact to a less than significant level
Hydrology and Water Quality Less than Significant General Plan policies and actions mitigate this impact to a less than significant level
Land Use, Agriculture, and Population Less than Significant General Plan policies and actions mitigate this impact to a less than significant level
Noise Significant and
Unavoidable
Mitigated to the greatest extent feasible
through General Plan policies and actions.
No additional feasible mitigation is available.
Public Services and Recreation Less than Significant General Plan policies and actions mitigate this impact to a less than significant level
Transportation and Circulation Significant and
Unavoidable
Mitigated to the greatest extent feasible
through General Plan policies and actions.
No additional feasible mitigation is available.
Utilities Significant and
Unavoidable
Mitigated to the greatest extent feasible
through General Plan policies and actions.
No additional feasible mitigation is available.
Cumulative/Other CEQA-Required Topics Significant and
Unavoidable
Mitigated to the greatest extent feasible
through General Plan policies and actions.
No additional feasible mitigation is available.
Source: City of Cotati 2014
General Plan Assumptions
The General Plan buildout analysis assumes a 20-year horizon to the year 2035. The General Plan will accommodate future growth in Cotati, including new businesses, expansion of existing businesses, and new residential uses.
The General Plan EIR addresses two buildout scenarios to evaluate the maximum projected development that could occur within city limits under the proposed general plan and the maximum projected development that could occur within the entire planning area. As shown in Table 2-3 on page 2.0-10 of the General Plan EIR, the General Plan could yield up to 1,541 new housing units within the city limits which would increase the population within city limits by approximately 3,775 units and result in approximately 6,766 employment opportunities. Full buildout conditions in the
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8 entire planning area, as shown in Table 2-4 on page 2.0-11, could yield 2,140 new housing units resulting in a population growth of approximately 5,243 residents and approximately 8,819 new employment opportunities in the city and SOI. It should be noted that the SOI is not included in the Housing Element update.
2.7 Housing Element Update
The 2023-2031 Housing Element has the following major components:
▪ Section I: Introduction and Summary: introduces the overall Housing Element update effort, a summary of housing needs and constraints, a Fair Housing summary, and a review of the effectiveness of the 2015 Housing Element and the City’s progress in its implementation. ▪ Section II: Housing Strategy: sets forth the City’s Housing Strategy, which is comprised of the Goals, Policies, and Programs that it intends to implement over the next 8-year planning cycle.
The City’s Quantified Objectives are also included in this section. ▪ Section III: Housing Sites: presents a detailed Housing Site Inventory, including a discussion of the availability of services, and compares this inventory to the City’s projected housing needs. ▪ Section IV: Technical Background Report: provides statutorily required data including an assessment of housing needs and programs, an analysis of nongovernmental and governmental constraints to affordable housing provision, a discussion of special needs populations, and an assessment of fair housing. Pre-certified housing and demographic data provided by ABAG is included here.
Goals, Policies, and Programs
The primary objective of the Housing Element is to encourage the production of new housing units to meet the RHNA and housing for special needs populations. This is done by adopting a series of policies and programs which aim to conserve and improve existing housing stock; expand affordable housing opportunities; provide adequate sites and funding to accommodate housing needs of all economic segments of the community; promote housing opportunities for all persons regardless of race, gender, age, marital, status, ancestry, national origin, color, or sexual orientation; and ensure public participation in the development of the City’s housing policies. The Housing Element update goals, policies, and programs are summarized below and referenced throughout this Addendum as appropriate.
Goal H-1: Resilient & Safe Housing
The City’s goal to conserve and improve the existing housing supply to provide adequate, safe, and decent housing for all Cotati residents is supported by policies that encourage housing rehabilitation and preservation, assist with homeownership opportunities, enforce local building codes, encourage development of accessory dwelling units, expand energy and water efficiency, seek funding to support programs, and facilitate resident awareness of assistance programs.
Goal H-2: Housing Production
The City’s goal to provide adequate sites to accommodate the housing needs of all economic segments of the community is supported by policies that ensure adequate land designated for residential or mixed-use development is available to meet the RHNA, ensure that public infrastructure accommodates the City’s fair share of regional housing needs, encourage mixed use
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development, facilitate and encourage the construction of accessory dwelling units, encourage housing development on infill sites, and assist in the development of affordable housing.
Goal H-3: Affordable, Attainable & Accessible Housing
The City’s goal to expand affordable housing opportunities for lower income households and persons with special housing needs, including seniors, disabled persons, developmentally disabled persons, and homeless persons and families is supported by policies that incentivize discretionary affordable housing development and lower income housing, provide density bonuses to eligible projects, encourage housing for large and intergenerational families, eliminate barriers to safe and accessible housing for people with disabilities, and facilitate linkages for at-risk individuals and families to organizations and service groups that provide support services.
Goal H-4: Affirmatively Furthering Fair Housing
The City’s goal to promote housing opportunities for all persons regardless of race, gender, age, marital status, ancestry, national origin, color, or sexual orientation is supported by a policy that works to eliminate unlawful discrimination in housing.
Goal H-5: Community Engagement
The City’s goal to ensure public participation in the development of the city’s housing policies is supported by a policy that encourages and facilitates public participation in the formulation and review of the City’s housing and development policies.
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10 3 Overview of CEQA Guidelines Section
15164 and Section 15162
CEQA Guidelines Sections 15162 and 15164 set forth the criteria for determining the appropriate additional environmental documentation, if any, to be completed when a project has a previously certified EIR.
CEQA Guidelines Section 15164 states that a lead agency shall prepare an addendum to a previously certified EIR if some changes or additions are necessary, but none of the conditions described in Section 15162 calling for preparation of a subsequent EIR have occurred. CEQA Guidelines Section 15162(a) states that no Subsequent or Supplemental EIR shall be prepared for a project with a certified EIR unless the lead agency determines, based on substantial evidence in the light of the whole record, one or more of the following:
1. Substantial changes are proposed in the project that will require major revisions of the previous EIR due to the involvement of new significant environmental effects or a substantial increase in the severity of previously identified significant effects.
2. Substantial changes occur with respect to the circumstances under which the project is undertaken which will require major revisions of the previous EIR due to the involvement of new significant environmental effects or a substantial increase in the severity of previously identified significant effects.
3. New information of substantial importance, which was not known and could not have been known with the exercise of reasonable diligence at the time the previous EIR was certified as complete, shows any of the following:
A. The project will have one or more significant effects not discussed in the previous EIR.
B. Significant effects previously examined will be substantially more severe than shown in the previous EIR.
C. Mitigation measures or alternatives previously found not to be feasible would in fact be feasible and would substantially reduce one or more significant effects of the project, but the project proponents decline to adopt the mitigation measure or alternative.
D. Mitigation measures or alternatives that are considerably different from those analyzed in the previous EIR would substantially reduce one or more significant effects on the environment, but the project proponents decline to adopt the mitigation measure or alternative.
The analysis pursuant to CEQA Guidelines Section 15162 demonstrates whether the lead agency can approve the activity as being within the scope of the existing certified EIR, that an addendum to the existing EIR would be appropriate, and no new environmental document, such as a new EIR, would be required. The addendum need not be circulated for public review but can be included in or attached to the Final EIR, and the decision-making body shall consider the addendum with the Final EIR prior to deciding on the project.
The City has prepared this Addendum Evaluation, pursuant to CEQA Guidelines Sections 15162 and 15164, to evaluate whether the project’s environmental impacts are covered by and within the scope of the 2013 Cotati General Plan Update Final EIR (November 2014, State Clearinghouse Number 2013082037). The following Addendum Evaluation details any changes in the project,
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changes in circumstances under which the project is undertaken, and/or "new information of substantial importance" that may cause one or more effects to environmental resources.
The responses herein substantiate and support the City’s determination that the Housing Element update policies and programs are within the scope of the General Plan EIR, do not require subsequent action under CEQA Guidelines Section 15162 and, in conjunction with the EIR, adequately analyze potential environmental impacts.
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12 4 Environmental Effects and Determination
4.1 Environmental Areas Determined to Have New or
Substantially More Severe Significant Effects
Compared to Those Identified in the Previous EIR
The subject areas checked below were determined to be new significant environmental effects or to be previously identified effects that have a substantial increase in severity either due to a change in project, change in circumstances, or new information of substantial importance, as indicated by the checklist and discussion on the following pages.
■ NONE
□ Aesthetics □ Agriculture and
Forestry Resources
□ Air Quality
□ Biological Resources □ Cultural Resources □ Energy
□ Geology/Soils □ Greenhouse Gas
Emissions
□ Hazards & Hazardous
Materials
□ Hydrology/Water Quality □ Land Use/Planning □ Mineral Resources □ Noise □ Population/Housing □ Public Services
□ Recreation □ Transportation □ Tribal Cultural Resources □ Utilities/Service Systems □ Wildfire □ Mandatory Findings of Significance
4.2 Determination
Based on this analysis:
□ Substantial changes are proposed in the project or there are substantial changes in the circumstances under which the project will be undertaken that will require major revisions to the previous EIR due to the involvement of significant new environmental effects or a substantial increase in the severity of previously identified significant effects. Or, there is "new information of substantial importance," as that term is used in CEQA Guidelines Section 15162(a)(3). Therefore, a SUBSEQUENT or SUPPLEMENTAL EIR is required.
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■ No substantial changes are proposed in the project and there are no substantial changes in the circumstances under which the project will be undertaken that will require major revisions to the previous EIR due to the involvement of significant new environmental effects or a substantial increase in the severity of previously identified significant effects.
Also, there is no "new information of substantial importance" as that term is used in CEQA Guidelines Section 15162(a)(3). Therefore, the previously certified EIR is adequate and this evaluation serves as an ADDENDUM to the 2013 Cotati General Plan Update Environmental Impact Report (General Plan FEIR). State Clearinghouse Number 2013082037 dated November 2014.
Signature Date
Printed Name Title
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14 5 Addendum Evaluation Methodology
5.1 General Plan Consistency
To promote a uniform and compatible vision for the development of the community, California law requires the General Plan be internally consistent in its goals and policies. The Housing Element is a component of the General Plan, and thus, the Housing Element update is consistent with the vision of the General Plan and is supported by goals and policies of the other General Plan elements.
General Plan elements and policies that affect housing are summarized below:
▪ The Circulation Element correlates closely with the Land Use Element, and identifies the general locations and extent of existing and proposed major thoroughfares, transportation routes, and alternative transportation facilities necessary to support a multi-modal transportation system.
This element is intended to facilitate mobility of people and goods throughout Cotati by a variety of transportation modes, including bicycle, pedestrian, and rail. ▪ The Community Services and Facilities Element sets forth standards for public service and utility systems including water, wastewater, solid waste, schools, medical facilities, libraries, parks, recreation, and historic preservation.
▪ The Conservation Element addresses the conservation, development, and use of natural resources, riparian environments, native plant and animal species, soils, mineral deposits, cultural/historical resources, air quality, and alternative energy. It also details plans and measures for preserving open space for natural resources and the managed production of resources.
▪ The Economic Vitality Element is designed to support and enhance the City’s economy, through programs to retain existing and attract new business, create jobs, to help maintain existing jobs, and to improve overall opportunities for businesses in the City. ▪ The Land Use Element designates the general distribution and intensity of residential, commercial, industrial, open space, public/quasi-public, and other categories of public and private land uses. The Land Use Element includes the Land Use Map, which identifies land use designations for each parcel in the city limits and SOI. ▪ The Noise Element establishes standards and policies to protect the community from the harmful and annoying effects of exposure to excessive noise levels. This element includes strategies to reduce land use conflicts that may result in exposure to unacceptable noise levels. ▪ The Open Space Element addresses the preservation of open space for the conservation of natural resources, and public health and safety related to open space and recreational opportunities. This element also includes provisions for parks and recreational facilities throughout the City.
▪ The Safety Element establishes policies and programs to protect the community from risk associated with geologic, flood, and fire hazards, as well as setting standards for emergency preparedness.
New State law requires that the Safety Element be updated to address climate adaptation upon revision of the Housing Element. The City will ensure compliance with this requirement by updating and adopting its updated Safety Element to follow the 2023 Housing Element. Further, new
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statewide bills have been passed to address the inequitable distribution of pollution and associated health effects in low-income communities and communities of color. While the City of Cotati does not currently have any disadvantaged communities as defined by SB 535, neighborhoods within Cotati that are designated as Low Resource in the 2022 Tax Credit Allocation Committee (TCAC) Opportunity Areas will be analyzed and discussed as part of the Assessment of Fair Housing.
Accommodation of the RHNA
As described in Section 2.3, the City of Cotati’s RHNA for the current planning period is 234 units, including 60 very low-income housing units, 34 low-income housing units, 39 moderate income housing units, and 101 above moderate-income housing units. The City must demonstrate the availability of sites with appropriate zoning and development standards that can facilitate and encourage the development of such units. The Housing Element update includes a housing strategy that accommodates the RHNA plus a buffer of additional housing sites as recommended by HCD. As shown in Table 3, the City anticipates the development of 30 ADUs during the eight-year planning period and 689 units would be facilitated from planned and approved (pipeline) projects which can count towards the RHNA.
Table 3 Housing Unit Yield per Site Category
Very Low Low Moderate Above Moderate Total
RHNA 30 34 39 101 234
ADUs 9 9 9 3 30
Pipeline 119 35 535 689
Housing Sites 30 39 36 105
Total Units After Programs 167 83 574 824
RHNA Surplus 73 44 473 590
Percent Buffer 78% 113% 438% 252%
Source: ABAG 2022
The 824 units that would be facilitated by the Housing Element update would not exceed the 1,541 units included in the buildout capacity estimated under the General Plan and analyzed in the General Plan EIR. Furthermore, the Housing Element update would be consistent with State requirements for the RHNA to plan adequately to meet existing and projected housing needs for all economic segments of the community. In addition, the Housing Element update would first be submitted to the HCD for review and approval to ensure that it would adequately address the housing needs and demands of the City.
A detailed discussion of the Housing Element update development assumptions and housing plan is provided below.
▪ Accessory Dwelling Units (ADUs) and Junior ADUs. The City anticipates the upward trend in the development of ADUs and JADUs throughout the 6th Cycle will increase and is supporting that assumption with programs to facilitate and incentivize production. As shown in Table 3, the City anticipates the development of 30 ADUs during the eight-year planning period. ▪ Planned, Approved, and Pending Projects. The Housing Element Update provides a brief description of approved and under review pipeline projects anticipated to accommodate up to 689 total units.
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16 ▪ Housing Sites. Site 1 (vacant site) is within the Northern Gateway zone of the Downtown Specific Plan area. This site would accommodate 5 units. Sites 2 and 3 (non-vacant sites) would accommodate a total of 100 units.
5.2 Preliminary Environmental Constraints
State housing law requires the City to review both governmental and non-governmental constraints to the maintenance and production of housing for all income levels. Since local governmental actions can restrict the development and increase the cost of housing, State law requires the Housing Element to “address and, where appropriate and legally possible, remove governmental constraints to the maintenance, improvement, and development of housing” (Government Code Section 65583[c][3]).
Several factors can constrain residential development. These include market constraints, such as development costs and interest rates, and governmental constraints, which include land use controls, fees, processing times, and development standards, among others. In addition, environmental and infrastructure constraints can also impede residential development. For purposes of the Addendum Evaluation, only the potential environmental constraints, as they relate to CEQA, were evaluated.
Environmental constraints to residential development typically relate to the presence of sensitive habitat, flooding, topography, and other natural and physical characteristics that can limit the amount of development in an area or increase the cost of development. The Housing Element update, in and of itself, does not propose specific development projects, but rather puts forth goals, policies, and programs that regulate or encourage new housing development in Cotati. Future housing development projects would be subject to developmental review to determine potential impacts specific to that project site.
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6 Addendum Evaluation
6.1 Aesthetics
General Plan EIR Findings
Aesthetics are discussed in Section 3.1, Aesthetics and Visual Resources, of the General Plan EIR. The General Plan EIR determined that while General Plan policies and actions are intended to maintain and enhance the overall visual character of the Planning Area, the potential for new development to interrupt scenic views, impact scenic resources, or degrade the quality of public views would remain significant and unavoidable.
The General Plan EIR stated that implementation of General Plan policies and actions would continue to require the review of all development proposals, planning projects and infrastructure projects to reduce lighting impacts on adjacent properties and to reduce lighting impacts to the night sky. Implementation of General Plan policies and actions related to the regulation and reduction of daytime glare and nighttime lighting would reduce such impacts to a less than significant level.
Addendum Analysis
Policies and actions in the General Plan that were referenced in the General Plan EIR would help reduce impacts to the greatest extent possible. These policies and actions would be required with implementation of the Housing Element update.
The Housing Element update is a policy document consistent with the General Plan. The Housing Element update identifies sites located throughout the city designated for residential development, which were evaluated previously for potential environmental impacts in the General Plan EIR. The Housing Element update also identifies sites that can accommodate ADUs as well as vacant and nonvacant properties that could accommodate new or additional housing units. Since non-vacant sites already contain some type of development, housing that may be built on these sites would not create a substantial change from current conditions. Similarly, most vacant sites are urban infill sites where development and infrastructure is already present adjacent to such sites. The units facilitated by the Housing Element update would not exceed the buildout capacity estimated under the General Plan and analyzed in the General Plan EIR.
The Housing Element update, in and of itself, does not propose specific projects but puts forth goals and policies that regulate various aspects of new housing development in Cotati. Because it is a policy document, the Housing Element update would not, in and of itself, result in impacts to scenic vistas, scenic resources, or visual character, and would not create new sources of substantial light or glare which adversely affects views.
Future development facilitated by the Housing Element update would undergo project-specific developmental review, including design review, and would be subject to adopted development guidelines, including standards that govern visual quality and community design.
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18 Conclusion
The adoption of the Housing Element update does not involve changes to the current adopted land uses and the housing units facilitated by the Housing Element update would not exceed the buildout capacity specified in the General Plan EIR. The Housing Element update would not result in impacts beyond those addressed or analyzed in the General Plan EIR nor present new information that shows impacts would be more significant than those described in the General Plan EIR. Therefore, the General Plan EIR applies to the Housing Element update and no additional environmental assessment of aesthetics is required.
6.2 Agriculture and Forestry
General Plan EIR Findings
Agriculture and Forestry Resources are discussed in Section 3.9, Land Use, of the General Plan EIR.
The General Plan EIR found that impacts regarding the potential to conflict with existing farmlands, agricultural zoning or Williamson Act Contracts, and the conversion of farmlands, including prime farmland, unique farmland, and farmland of statewide importance would be less than significant.
There are no lands within or adjacent to the City that are currently zoned as forest land, timber, or timber production. The General Plan EIR found no impacts to forest land, timber, or timber production.
Addendum Analysis
The General Plan goals and policies protect rural (Agricultural and Rural Residential) and natural open space lands from urbanization. These goals and policies would remain in effect with implementation of the Housing Element update. None of the sites identified in the Housing Element update are designated as Agriculture.
The Housing Element update is a policy document consistent with the General Plan. The Housing Element update identifies sites located throughout the city designated for residential development, which were evaluated previously for potential environmental impacts in the General Plan EIR. The Housing Element update also identifies sites that can accommodate ADUs as well as vacant and nonvacant properties that could accommodate new or additional housing units. Since non-vacant sites already contain some type of development, housing that may be built on these sites would not create a substantial change from current conditions. Similarly, most vacant sites are urban infill sites where development and infrastructure is already present adjacent to such sites. The units facilitated by the Housing Element update would not exceed the buildout capacity estimated under the General Plan and analyzed in the General Plan EIR.
The Housing Element update, in and of itself, does not propose specific projects but puts forth goals and policies that regulate various aspects of new housing development in Cotati. Because it is a policy document, the Housing Element update would not, in and of itself, result in impacts to agriculture or forestry.
Future development facilitated by the Housing Element update would undergo project-specific developmental review and be required to comply with any applicable requirements regarding agriculture and forestry including General Plan policies and actions.
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Conclusion
The adoption of the Housing Element update does not involve changes to the current adopted land uses and the housing units facilitated by the Housing Element update would not exceed the buildout capacity specified in the General Plan EIR. The Housing Element update would not result in impacts beyond those addressed or analyzed in the General Plan EIR nor present new information that shows impacts would be more significant than those described in the General Plan EIR. Therefore, the General Plan EIR applies to the Housing Element update and no additional environmental assessment of agriculture or forestry is required.
6.3 Air Quality
General Plan EIR Findings
Air quality is discussed in Section 3.2, Air Quality, of the General Plan EIR. The General Plan EIR determined that impacts to air quality would be less than significant regarding the potential to conflict with applicable air quality plans, cumulatively considerable net increase of criteria pollutants for which the region is in non-attainment, exposure of sensitive receptors to pollutant concentrations, and the potential to create objectionable odors. The General Plan includes numerous goals and polices to reduce potential air quality impacts, and the City is required to enforce compliance with regional plans and programs that reduce air quality impacts.
Addendum Analysis
Policies and actions in the General Plan that were referenced in the General Plan EIR would help reduce impacts to less than significant levels. These policies and actions would be required with implementation of the Housing Element update.
The Housing Element update is a policy document consistent with the General Plan. The Housing Element update identifies sites located throughout the city designated for residential development, which were evaluated previously for potential environmental impacts in the General Plan EIR. The Housing Element update also identifies sites that can accommodate ADUs as well as vacant and nonvacant properties that could accommodate new or additional housing units. Since non-vacant sites already contain some type of development, housing that may be built on these sites would not create a substantial change from current conditions. Similarly, most vacant sites are urban infill sites where development and infrastructure is already present adjacent to such sites. The units facilitated by the Housing Element update would not exceed the buildout capacity estimated under the General Plan and analyzed in the General Plan EIR.
Potential air quality-related impacts cannot be assessed in a meaningful way until the project site and development design is known, including the number of units, potential residents, and potential vehicle miles traveled. Short-term air quality impacts resulting from construction of the sites, such as dust generated by clearing and grading activities, exhaust emissions from gas- and dieselpowered construction equipment, and vehicular emissions associated with the commuting of construction workers will be subject to Bay Area Air Quality Management District rules and regulations. The Housing Element update, in and of itself, does not propose specific projects but puts forth goals and policies that regulate various aspects of new housing development in Cotati.
Because it is a policy document, the Housing Element update would not, in and of itself, result in impacts to air quality.
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20 Future development facilitated by the Housing Element update would undergo project-specific developmental review and be required to comply with adopted General Plan policies and actions regarding air quality and any applicable State and regional air quality plans.
Conclusion
The adoption of the Housing Element update does not involve changes to the current adopted land uses and the housing units facilitated by the Housing Element update would not exceed the buildout capacity specified in the General Plan EIR. The Housing Element update would not result in impacts beyond those addressed or analyzed in the General Plan EIR nor present new information that shows impacts would be more significant than those described in the General Plan EIR. Therefore, the General Plan EIR applies to the Housing Element update and no additional environmental assessment of air quality is required.
6.4 Biological Resources
General Plan EIR Findings
Biological resources are discussed in Section 3.3, Biological and Natural Resources, of the General Plan EIR. The General Plan EIR determined that while implementation of projects proposed under the General Plan may have the potential to result in impacts to special status species, riparian habitat or other sensitive natural communities, adherence to the policies and action measures listed in the General Plan EIR, as well as federal and state regulations, would reduce impacts to these resources to a less than significant level. It further stated that all projects proposed under General Plan implementation would be required to comply with the General Plan and adopted state, federal, and local regulations for the protection of special status plants and wildlife, including habitat.
Impacts were determined to be less than significant.
The General Plan EIR found that the General Plan would not conflict with any local policies or ordinances protecting biological resources, the provisions of an adopted Habitat Conservation Plan, Natural Community Conservation Plan, or other approved local, regional, or state habitat conservation plan. Impacts were determined to be less than significant.
Addendum Analysis
Policies and actions in the General Plan that were referenced in the General Plan EIR would help reduce impacts to less than significant levels. These policies and actions would be required with implementation of the Housing Element update.
The Housing Element update is a policy document consistent with the General Plan. The Housing Element update identifies sites located throughout the city designated for residential development, which were evaluated previously for potential environmental impacts in the General Plan EIR. The Housing Element update also identifies sites that can accommodate ADUs as well as vacant and nonvacant properties that could accommodate new or additional housing units. Since non-vacant sites already contain some type of development, housing that may be built on these sites would not create a substantial change from current conditions. Similarly, most vacant sites are urban infill sites where development and infrastructure is already present adjacent to such sites. The units facilitated by the Housing Element update would not exceed the buildout capacity estimated under the General Plan and analyzed in the General Plan EIR.
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The Housing Element update, in and of itself, does not propose specific projects but puts forth goals and policies that regulate various aspects of new housing development in Cotati. Because it is a policy document, the Housing Element update would not, in and of itself, result in impacts to biological resources.
Future development facilitated by the Housing Element update would undergo project-specific developmental review and be required to comply with the General Plan policies and actions regarding biological resources, and adopted state, federal, and local regulations for the protection of special status plants and wildlife, including habitat.
Conclusion
The adoption of the Housing Element update does not involve changes to the current adopted land uses and the housing units facilitated by the Housing Element update would not exceed the buildout capacity specified in the General Plan EIR. The Housing Element update would not result in impacts beyond those addressed or analyzed in the General Plan EIR nor present new information that shows impacts would be more significant than those described in the General Plan EIR. Therefore, the General Plan EIR applies to the Housing Element update and no additional environmental assessment of biological resources is required.
6.5 Cultural Resources
General Plan EIR Findings
Cultural resources are discussed in Section 3.4, Cultural Resources, of the General Plan EIR. The General Plan EIR determined that with implementation of General Plan policies and actions, and State law, impacts to historical resources, archaeological resources, and human remains would be less than significant.
Addendum Analysis
Policies and actions in the General Plan that were referenced in the General Plan EIR would help reduce impacts to less than significant levels. These policies and actions would be required with implementation of the Housing Element update.
The Housing Element update is a policy document consistent with the General Plan. The Housing Element update identifies sites located throughout the city designated for residential development, which were evaluated previously for potential environmental impacts in the General Plan EIR. The Housing Element update also identifies sites that can accommodate ADUs as well as vacant and nonvacant properties that could accommodate new or additional housing units. Since non-vacant sites already contain some type of development, housing that may be built on these sites would not create a substantial change from current conditions. Similarly, most vacant sites are urban infill sites where development and infrastructure is already present adjacent to such sites. The units facilitated by the Housing Element update would not exceed the buildout capacity estimated under the General Plan and analyzed in the General Plan EIR.
The Housing Element update, in and of itself, does not propose specific projects but puts forth goals and policies that regulate various aspects of new housing development in Cotati. Because it is a policy document, the Housing Element update would not, in and of itself, result in impacts to cultural resources. Although known historic and prehistoric resource sites are located within Cotati’s SOI, and 36 cultural resources have been recorded within the General Plan Planning Area, future
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22 development facilitated by the Housing Element update would be evaluated for compliance with the City’s General Plan, Municipal Code, and any other applicable State and local regulations regarding cultural resources including California Health and Safety Code Section 7050.5 and California Public Resources Code Section 5097.98.
Conclusion
The adoption of the Housing Element update does not involve changes to the current adopted land uses and the housing units facilitated by the Housing Element update would not exceed the buildout capacity specified in the General Plan EIR. The Housing Element update would not result in impacts beyond those addressed or analyzed in the General Plan EIR nor present new information that shows impacts would be more significant than those described in the General Plan EIR. Therefore, the General Plan EIR applies to the Housing Element update and no additional environmental assessment of cultural resources is required.
6.6 Energy
General Plan EIR Findings
The General Plan EIR does not include a separate section regarding energy since it was not required under the CEQA Guidelines Appendix G checklist at the time the report was prepared; however, energy is discussed in Section 4.3, Significant Irreversible Effects, of the General Plan EIR. The General Plan EIR found that General Plan policies focus on energy efficiency in the design, materials, construction, and use of buildings, the use of alternative energy systems, and alternative transportation modes. A discussion of energy impacts is provided herein to supplement the General Plan EIR.
Addendum Analysis
Policies and actions in the General Plan that were referenced in the General Plan EIR would help reduce impacts to the greatest extent possible. These policies and actions would be required with implementation of the Housing Element update.
The Housing Element update is a policy document consistent with the General Plan. The Housing Element update identifies sites located throughout the city designated for residential development, which were evaluated previously for potential environmental impacts in the General Plan EIR. The Housing Element update also identifies sites that can accommodate ADUs as well as vacant and nonvacant properties that could accommodate new or additional housing units. Since non-vacant sites already contain some type of development, housing that may be built on these sites would not create a substantial change from current conditions. Similarly, most vacant sites are urban infill sites where development and infrastructure is already present adjacent to such sites. The units facilitated by the Housing Element update would not exceed the buildout capacity estimated under the General Plan and analyzed in the General Plan EIR.
The Housing Element update, in and of itself, does not propose specific projects but puts forth goals and policies that regulate various aspects of new housing development in Cotati. Because it is a policy document, the Housing Element update would not, in and of itself, result in impacts to energy.
Future development facilitated by the Housing Element update would undergo project-specific developmental review and be required to adhere to applicable regulations and General Plan policies
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and actions related to energy resources and energy consumption with new residential construction, including California Code of Regulations (CCR) Title 20, Division 2, Chapter 4, Energy Conservation; CCR Title 24, Part 6, California Energy Code; and CCR Title 24, Part 11, California Green Building Standards Code, Tier 1.
Conclusion
The adoption of the Housing Element update does not involve changes to the current adopted land uses and the housing units facilitated by the Housing Element update would not exceed the buildout capacity specified in the General Plan EIR. The Housing Element update would not result in impacts beyond those addressed or analyzed in the General Plan EIR nor present new information that shows impacts would be more significant than those described in the General Plan EIR. Therefore, the General Plan EIR applies to the Housing Element update and no additional environmental assessment of energy is required.
6.7 Geology and Soils
General Plan EIR Findings
Geology and soils are discussed in Section 3.5, Geology and Soils, of the General Plan EIR. General Plan policies and actions require geotechnical investigations to be completed for all construction in areas with potential geological hazards and require that recommendations from the geotechnical analysis are incorporated into the project’s design and engineering. The General Plan EIR determined that with implementation of General Plan policies and actions as well as applicable State and City regulations, impacts to geology and soils would be less than significant for adverse effects related to ground shaking, seismic-related ground failure, unstable soils, expansive soils, landslide, and loss of topsoil or soil erosion.
The General Plan EIR determined that there would be no septic tanks or alternative wastewater disposal systems utilized for new development as all new wastewater generated from General Plan land uses would be sent to the (regional) Laguna Treatment Plant for treatment. Impacts would be less than significant.
Paleontological resources are discussed in Section 3.4, Cultural Resources, of the General Plan EIR.
There are no known paleontological resources in the General Plan Planning Area and future development would be analyzed for potential environmental impacts pursuant to State and local regulations regarding paleontological resources. Impacts would be less than significant.
Addendum Analysis
Policies and actions in the General Plan that were referenced in the General Plan EIR would help reduce impacts to less than significant levels. These policies and actions would be required with implementation of the Housing Element update.
The Housing Element update is a policy document consistent with the General Plan. The Housing Element update identifies sites located throughout the city designated for residential development, which were evaluated previously for potential environmental impacts in the General Plan EIR. The Housing Element update also identifies sites that can accommodate ADUs as well as vacant and nonvacant properties that could accommodate new or additional housing units. Since non-vacant sites already contain some type of development, housing that may be built on these sites would not create a substantial change from current conditions. Similarly, most vacant sites are urban infill sites
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24 where development and infrastructure is already present adjacent to such sites. The units facilitated by the Housing Element update would not exceed the buildout capacity estimated under the General Plan and analyzed in the General Plan EIR.
The Housing Element update, in and of itself, does not propose specific projects but puts forth goals and policies that regulate various aspects of new housing development in Cotati. Because it is a policy document, the Housing Element update would not, in and of itself, result in impacts to geology and soils.
Future development facilitated by the Housing Element update would undergo project-specific developmental review to address potential impacts related to geology and soils, including adherence to State and City grading and building standards and requirements. Proponents of the individual projects may need to prepare geotechnical investigations prior to project design. Future development would be required to adhere to General Plan policies and actions related to paleontological resources.
Conclusion
The adoption of the Housing Element update does not involve changes to the current adopted land uses and the housing units facilitated by the Housing Element update would not exceed the buildout capacity specified in the General Plan EIR. The Housing Element update would not result in impacts beyond those addressed or analyzed in the General Plan EIR nor present new information that shows impacts would be more significant than those described in the General Plan EIR. Therefore, the General Plan EIR applies to the Housing Element update and no additional environmental assessment of geology and soils is required.
6.8 Greenhouse Gas Emissions
General Plan EIR Findings
Greenhouse gas (GHG) emissions are discussed in Section 3.6, Greenhouse Gases and Climate Change, of the General Plan EIR. The General Plan EIR determined that the General Plan policies and actions are consistent with the policy guidance provided by California Air Pollution Control Officers Association (CAPCOA) through the 2009 Model Policies for Greenhouse Gases in General Plans, which is consistent with the Assembly Bill (AB) 32 Scoping Plan, and GHG reduction measures recommended by the Bay Area Air Quality Management District. Impacts related to the generation of GHG emissions were determined to be less than significant.
The General Plan EIR determined that compliance with the City’s Green Building Standards would reduce GHG emissions from future development to less than significant levels and ensure future development consistent with the General Plan would be consistent with all applicable plans and policies adopted for the purpose of reducing GHG emissions. Impacts were determined to be less than significant.
Addendum Analysis
Policies and actions in the General Plan that were referenced in the General Plan EIR would help reduce impacts to less than significant levels. These policies and actions would be required with implementation of the Housing Element update.
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The Housing Element update is a policy document consistent with the General Plan. The Housing Element update identifies sites located throughout the city designated for residential development, which were evaluated previously for potential environmental impacts in the General Plan EIR. The Housing Element update also identifies sites that can accommodate ADUs as well as vacant and nonvacant properties that could accommodate new or additional housing units. Since non-vacant sites already contain some type of development, housing that may be built on these sites would not create a substantial change from current conditions. Similarly, most vacant sites are urban infill sites where development and infrastructure is already present adjacent to such sites. The units facilitated by the Housing Element update would not exceed the buildout capacity estimated under the General Plan and analyzed in the General Plan EIR.
The Housing Element update, in and of itself, does not propose specific projects but puts forth goals and policies that regulate various aspects of new housing development in Cotati. Because it is a policy document, the Housing Element update would not, in and of itself, result in impacts to GHG emissions.
Future development facilitated by the Housing Element update would undergo project-specific developmental review and would be required to adhere to State and City building standards and policies designed to reduce GHG emissions with new residential construction, such as CCR Title 20, Division 2, State Energy Resources Conservation and Development Commission; and CCR Title 24, Part 11, California Green Building Standards Code, Tier 1.
Conclusion
The adoption of the Housing Element update does not involve changes to the current adopted land uses and the housing units facilitated by the Housing Element update would not exceed the buildout capacity specified in the General Plan EIR. The Housing Element update would not result in impacts beyond those addressed or analyzed in the General Plan EIR nor present new information that shows impacts would be more significant than those described in the General Plan EIR. Therefore, the General Plan EIR applies to the Housing Element update and no additional environmental assessment of GHG emissions is required.
6.9 Hazards and Hazardous Materials
General Plan EIR Findings
Hazards and hazardous materials are discussed in Section 3.7, Hazards, of the General Plan EIR. The General Plan EIR determined that impacts for hazardous materials would be less than significant with implementation of General Plan policies and actions for impacts related to the routine transport, use, or disposal of hazardous materials; the emission of acutely hazardous materials, substances, or waste within 0.25 mile of an existing or proposed school; and development on or near sites listed as hazardous material sites pursuant to Government Code Section 65962.5.
The City of Cotati does not have any airport facilities located within the city limits, SOI, of urban growth boundary. Impacts related to safety hazards from nearby airports would be less than significant.
The General Plan EIR determined that community safety facilities would be located outside of identified hazard areas to ensure these facilities are available in the event of a natural disaster and projects are not anticipated to remove or impede evacuation routes. It determined that the General
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26 Plan does not include land uses, policies, or other components that conflict with adopted emergency response or evacuation plans. Impacts would be less than significant.
The General Plan EIR determined that with implementation of General Plan policies and actions, impacts regarding wildland fires would be less than significant.
Addendum Analysis
Policies and actions in the General Plan that were referenced in the General Plan EIR would help reduce impacts to less than significant levels. These policies and actions would be required with implementation of the Housing Element update.
The Housing Element update is a policy document consistent with the General Plan. The Housing Element update identifies sites located throughout the city designated for residential development, which were evaluated previously for potential environmental impacts in the General Plan EIR. The Housing Element update also identifies sites that can accommodate ADUs as well as vacant and nonvacant properties that could accommodate new or additional housing units. Since non-vacant sites already contain some type of development, housing that may be built on these sites would not create a substantial change from current conditions. Similarly, most vacant sites are urban infill sites where development and infrastructure is already present adjacent to such sites. The units facilitated by the Housing Element update would not exceed the buildout capacity estimated under the General Plan and analyzed in the General Plan EIR.
The Housing Element update, in and of itself, does not propose specific projects but puts forth goals and policies that regulate various aspects of new housing development in Cotati. Because it is a policy document, the Housing Element update would not, in and of itself, result in impacts to hazards and hazardous materials.
Future development facilitated by the Housing Element update would undergo project-specific developmental review and would be required to comply with all applicable General Plan policies and actions as well as State and local regulations regarding hazards and hazardous materials.
Conclusion
The adoption of the Housing Element update does not involve changes to the current adopted land uses and the housing units facilitated by the Housing Element update would not exceed the buildout capacity specified in the General Plan EIR. The Housing Element update would not result in impacts beyond those addressed or analyzed in the General Plan EIR nor present new information that shows impacts would be more significant than those described in the General Plan EIR. Therefore, the General Plan EIR applies to the Housing Element update and no additional environmental assessment of hazards and hazardous materials is required.
6.10 Hydrology and Water Quality
General Plan EIR Findings
Hydrology and water quality impacts are discussed in Section 3.8, Hydrology and Water Quality, of the General Plan EIR. The General Plan EIR determined that with implementation of General Plan policies and actions, impacts to hydrology and water quality would be less than significant relating to violating any water quality standards or waste discharge requirements, substantially decreasing groundwater supplies or interfering substantially with groundwater recharge, creating or
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contributing to runoff water which would exceed the capacity of existing or planned stormwater drainage systems, degrading water quality, and exposing people or structures to a significant risk of loss, injury or death involving flooding.
Addendum Analysis
Policies and actions in the General Plan that were referenced in the General Plan EIR would help reduce impacts to less than significant levels. These policies and actions would be required with implementation of the Housing Element update.
The Housing Element update is a policy document consistent with the General Plan. The Housing Element update identifies sites located throughout the city designated for residential development, which were evaluated previously for potential environmental impacts in the General Plan EIR. The Housing Element update also identifies sites that can accommodate ADUs as well as vacant and nonvacant properties that could accommodate new or additional housing units. Since non-vacant sites already contain some type of development, housing that may be built on these sites would not create a substantial change from current conditions. Similarly, most vacant sites are urban infill sites where development and infrastructure is already present adjacent to such sites. The units facilitated by the Housing Element update would not exceed the buildout capacity estimated under the General Plan and analyzed in the General Plan EIR.
The Housing Element update, in and of itself, does not propose specific projects but puts forth goals and policies that regulate various aspects of new housing development in Cotati. Because it is a policy document, the Housing Element update would not, in and of itself, result in impacts to hydrology and water quality.
Future development facilitated by the Housing Element update would undergo project-specific developmental review and be required to comply with General Plan policies and actions and all applicable regulations regarding hydrology and water quality.
Conclusion
The adoption of the Housing Element update does not involve changes to the current adopted land uses and the housing units facilitated by the Housing Element update would not exceed the buildout capacity specified in the General Plan EIR. The Housing Element update would not result in impacts beyond those addressed or analyzed in the General Plan EIR nor present new information that shows impacts would be more significant than those described in the General Plan EIR. Therefore, the General Plan EIR applies to the Housing Element update and no additional environmental assessment of hydrology and water quality is required.
6.11 Land Use and Planning
General Plan EIR Findings
Land use and planning is discussed in Section 3.9, Land Use, of the General Plan EIR. The General Plan EIR determined that impacts to land use would be less than significant regarding conflicts with applicable land use plans, policies, or regulations.
The General Plan does not include any new areas designated for urbanization or new roadways, infrastructure, or other features that would divide existing communities and impacts were determined to be less than significant.
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28 Addendum Analysis
Policies and actions in the General Plan that were referenced in the General Plan EIR would help reduce impacts to less than significant levels. These policies and actions would be required with implementation of the Housing Element update.
The Housing Element update is a policy document consistent with the General Plan. The Housing Element update identifies sites located throughout the city designated for residential development, which were evaluated previously for potential environmental impacts in the General Plan EIR. The Housing Element update also identifies sites that can accommodate ADUs as well as vacant and nonvacant properties that could accommodate new or additional housing units. Since non-vacant sites already contain some type of development, housing that may be built on these sites would not create a substantial change from current conditions. Similarly, most vacant sites are urban infill sites where development and infrastructure is already present adjacent to such sites. The units facilitated by the Housing Element update would not exceed the buildout capacity estimated under the General Plan and analyzed in the General Plan EIR.
The Housing Element update, in and of itself, does not propose specific projects but puts forth goals and policies that regulate various aspects of new housing development in Cotati. Because it is a policy document, the Housing Element update would not, in and of itself, result in impacts to land use and planning. The Housing element update does not involve changes to the current adopted land uses.
Future development facilitated by the Housing Element update would undergo project-specific developmental review and be required to comply with General Plan policies and actions and all applicable regulations regarding land use.
Conclusion
The adoption of the Housing Element update does not involve changes to the current adopted land uses and the housing units facilitated by the Housing Element update would not exceed the buildout capacity specified in the General Plan EIR. The Housing Element update would not result in impacts beyond those addressed or analyzed in the General Plan EIR nor present new information that shows impacts would be more significant than those described in the General Plan EIR. Therefore, the General Plan EIR applies to the Housing Element update and no additional environmental assessment of land use and planning is required.
6.12 Mineral Resources
General Plan EIR Findings
A background discussion of mineral resources is provided in Section 3.5, Geology and Soils, of the General Plan EIR. The General Plan EIR only provides background information regarding mineral resources. Therefore, a discussion of potential impacts to mineral resources is provided herein to supplement the General Plan EIR.
Addendum Analysis
The Planning Area does not contain land classified as Mineral Resource Zone 2 (MRZ-2) known mineral resources (California Department Of Conservation Division Of Mines And Geology 1987).
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The Stony Point Rock Quarry, located approximately 2 miles south of Cotati, is the nearest mineral extraction site.
The Housing Element update is a policy document consistent with the General Plan. The Housing Element update identifies sites located throughout the city designated for residential development, which were evaluated previously for potential environmental impacts in the General Plan EIR. The Housing Element update also identifies sites that can accommodate ADUs as well as vacant and nonvacant properties that could accommodate new or additional housing units. Since non-vacant sites already contain some type of development, housing that may be built on these sites would not create a substantial change from current conditions. Similarly, most vacant sites are urban infill sites where development and infrastructure is already present adjacent to such sites. The units facilitated by the Housing Element update would not exceed the buildout capacity estimated under the General Plan and analyzed in the General Plan EIR.
The Housing Element update, in and of itself, does not propose specific projects but puts forth goals and policies that regulate various aspects of new housing development in Cotati. Because it is a policy document, the Housing Element update would not, in and of itself, result in impacts to mineral resources.
Future development facilitated by the Housing Element update would undergo project-specific developmental review and would be required to adhere to applicable regulations regarding mineral resources.
Conclusion
The adoption of the Housing Element update does not involve changes to the current adopted land uses and the housing units facilitated by the Housing Element update would not exceed the buildout capacity specified in the General Plan EIR. The Housing Element update would not result in impacts beyond those addressed or analyzed in the General Plan EIR nor present new information that shows impacts would be more significant than those described in the General Plan EIR. Therefore, the General Plan EIR applies to the Housing Element update and no additional environmental assessment of mineral resources is required.
6.13 Noise
General Plan EIR Findings
Noise is discussed in Section 3.10, Noise, of the General Plan EIR. The General Plan EIR determined that implementation of the General Plan would result in significant and unavoidable impacts relative to noise from traffic noise sources and cumulative noise levels associated with traffic. Railroad, construction, and stationary source noise impacts were found to be less than significant with implementation of General Plan actions and policies.
The General Plan EIR found that the General Plan would not impact an airport compatibility plan or expose people residing or working in the project area because the project is not located within an airport land use plan or within two miles of a public airport or public use airport.
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Policies and actions in the General Plan that were referenced in the General Plan EIR would help reduce impacts to the greatest extent possible. These policies and actions would be required with implementation of the Housing Element update.
The Housing Element update is a policy document consistent with the General Plan. The Housing Element update identifies sites located throughout the city designated for residential development, which were evaluated previously for potential environmental impacts in the General Plan EIR. The Housing Element update also identifies sites that can accommodate ADUs as well as vacant and nonvacant properties that could accommodate new or additional housing units. Since non-vacant sites already contain some type of development, housing that may be built on these sites would not create a substantial change from current conditions. Similarly, most vacant sites are urban infill sites where development and infrastructure is already present adjacent to such sites. The units facilitated by the Housing Element update would not exceed the buildout capacity estimated under the General Plan and analyzed in the General Plan EIR.
The Housing Element update, in and of itself, does not propose specific projects but puts forth goals and policies that regulate various aspects of new housing development in Cotati. Because it is a policy document, the Housing Element update would not, in and of itself, result in impacts to noise.
Future development facilitated by the Housing Element update would undergo project-specific developmental review and would be required to adhere to General Plan policies and actions related to noise and applicable noise regulations.
Conclusion
The adoption of the Housing Element update does not involve changes to the current adopted land uses and the housing units facilitated by the Housing Element update would not exceed the buildout capacity specified in the General Plan EIR. The Housing Element update would not result in impacts beyond those addressed or analyzed in the General Plan EIR nor present new information that shows impacts would be more significant than those described in the General Plan EIR. Therefore, the General Plan EIR applies to the Housing Element update and no additional environmental assessment of noise is required.
6.14 Population and Housing
General Plan EIR Findings
Population and housing is discussed Section 3.9, Land Use, of the General Plan EIR. The General Plan EIR determined implementation of the General Plan would result in less than significant impacts relating to unplanned population growth and the displacement of substantial numbers of people or existing housing.
Addendum Analysis
The Housing Element update is a policy document consistent with the General Plan. As discussed in Section 2, Project Context, of this Addendum, the 824 units that would be facilitated by the Housing Element update would not exceed the 1,541 units included in the buildout capacity estimated under the General Plan and analyzed in the General Plan EIR. The California Department of Finance estimates Cotati has an average household size of 2.4 residents per unit (California Department of
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Finance 2022). The potential increase of 1,978 residents that would result from implementation of the Housing Element update would not exceed the population growth anticipated under the General Plan of 3,775 new residents.
The Housing Element update is a policy document consistent with the General Plan. The Housing Element update identifies sites located throughout the city designated for residential development, which were evaluated previously for potential environmental impacts in the General Plan EIR. The Housing Element update also identifies sites that can accommodate ADUs as well as vacant and nonvacant properties that could accommodate new or additional housing units. Since non-vacant sites already contain some type of development, housing that may be built on these sites would not create a substantial change from current conditions. Similarly, most vacant sites are urban infill sites where development and infrastructure is already present adjacent to such sites. The units facilitated by the Housing Element update would not exceed the buildout capacity estimated under the General Plan and analyzed in the General Plan EIR.
The Housing Element update, in and of itself, does not propose specific projects but puts forth goals and policies that regulate various aspects of new housing development in Cotati. Because it is a policy document, the Housing Element update would not, in and of itself, result in impacts to population and housing. The additional units facilitated by the Housing Element update would assist in meeting the identified housing needs of the City’s communities and City’s RHNA and would not exceed that previously evaluated under the General Plan EIR.
Conclusion
The adoption of the Housing Element update does not involve changes to the current adopted land uses and the housing units facilitated by the Housing Element update would not exceed the buildout capacity specified in the General Plan EIR. The Housing Element update would not result in impacts beyond those addressed or analyzed in the General Plan EIR nor present new information that shows impacts would be more significant than those described in the General Plan EIR. Therefore, the General Plan EIR applies to the Housing Element update and no additional environmental assessment of population and housing is required.
6.15 Public Services
General Plan EIR Findings
Public services are discussion in Section 3.11, Public Services and Recreation, of the General Plan EIR.
The General Plan EIR determined that implementation of the General Plan would not result in substantial adverse physical impacts associated with new or physically altered public services facilities, including those related to fire, police, schools, parks, and libraries, and impacts would be less than significant.
Addendum Analysis
As discussed in Section 2, Project Context, and Section 6.14, Population and Housing, of this Addendum, the potential increase in residential units and population that would occur from implementation of the Housing Element update would not exceed growth anticipated under the General Plan. Therefore, the demand for public services and recreational facilities would not exceed that previously evaluated in the General Plan EIR.
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32 The Housing Element update is a policy document consistent with the General Plan. The Housing Element update identifies sites located throughout the city designated for residential development, which were evaluated previously for potential environmental impacts in the General Plan EIR. The Housing Element update also identifies sites that can accommodate ADUs as well as vacant and nonvacant properties that could accommodate new or additional housing units. Since non-vacant sites already contain some type of development, housing that may be built on these sites would not create a substantial change from current conditions. Similarly, most vacant sites are urban infill sites where development and infrastructure is already present adjacent to such sites. The units facilitated by the Housing Element update would not exceed the buildout capacity estimated under the General Plan and analyzed in the General Plan EIR.
The Housing Element update, in and of itself, does not propose specific projects but puts forth goals and policies that regulate various aspects of new housing development in Cotati. Because it is a policy document, the Housing Element update would not, in and of itself, result in impacts to public services.
The demand for public services would not exceed that previously evaluated in the General Plan EIR.
Future development facilitated by the Housing Element update would undergo project-specific developmental review, and would be evaluated for conformance with the General Plan policies and actions, State law, City Municipal Code including the payment of fees, and other applicable regulations.
Conclusion
The adoption of the Housing Element update does not involve changes to the current adopted land uses and the housing units facilitated by the Housing Element update would not exceed the buildout capacity specified in the General Plan EIR. The Housing Element update would not result in impacts beyond those addressed or analyzed in the General Plan EIR nor present new information that shows impacts would be more significant than those described in the General Plan EIR. Therefore, the General Plan EIR applies to the Housing Element update and no additional environmental assessment of public services is required.
6.16 Recreation
General Plan EIR Findings
Recreation is discussed in Section 3.11, Public Services and Recreation, of the General Plan EIR. The General Plan EIR determined that implementation of the General Plan would not result in substantial adverse physical impacts associated with the deterioration of existing parks and recreation facilities or the construction of new parks or recreation facilities. Impacts would be less than significant.
Addendum Analysis
The City of Cotati General Plan requires a park standard of a minimum of one acre per 200 residents. Buildout of the General Plan would result in the need for approximately 17.5 acres of new parks and recreation facilities to serve projected buildout growth within the City limits, and 26 acres of new parks and recreation facilities to served projected buildout growth within the Planning Area.
As discussed in Section 2, Project Context, and Section 6.14, Population and Housing, of this Addendum, the potential increase in residential units and population that would occur from
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implementation of the Housing Element update would not exceed growth anticipated under the General Plan. Therefore, the demand for new parks and recreational facilities would not exceed that anticipated under the General Plan.
The Housing Element update is a policy document consistent with the General Plan. The Housing Element update identifies sites located throughout the city designated for residential development, which were evaluated previously for potential environmental impacts in the General Plan EIR. The Housing Element update also identifies sites that can accommodate ADUs as well as vacant and nonvacant properties that could accommodate new or additional housing units. Since non-vacant sites already contain some type of development, housing that may be built on these sites would not create a substantial change from current conditions. Similarly, most vacant sites are urban infill sites where development and infrastructure is already present adjacent to such sites. The units facilitated by the Housing Element update would not exceed the buildout capacity estimated under the General Plan and analyzed in the General Plan EIR.
The Housing Element update, in and of itself, does not propose specific projects but puts forth goals and policies that regulate various aspects of new housing development in Cotati. Because it is a policy document, the Housing Element update would not, in and of itself, result in impacts to recreation or recreation facilities.
The demand for recreational facilities would not exceed that previously evaluated in the General Plan EIR. Future development facilitated by the Housing Element update would undergo projectspecific developmental review, and would be evaluated for conformance with the General Plan policies and actions, State law, City Municipal Code including the dedication of land or the payment of fees and other applicable regulations.
Conclusion
The adoption of the Housing Element update does not involve changes to the current adopted land uses and the housing units facilitated by the Housing Element update would not exceed the buildout capacity specified in the General Plan EIR. The Housing Element update would not result in impacts beyond those addressed or analyzed in the General Plan EIR nor present new information that shows impacts would be more significant than those described in the General Plan EIR. Therefore, the General Plan EIR applies to the Housing Element update and no additional environmental assessment of recreation is required.
6.17 Transportation
General Plan EIR Findings
Transportation is evaluated in Section 3.12, Transportation and Circulation, of the General Plan EIR.
The General Plan EIR analyzed Level of Service (LOS) as the methodology to assess significance and found that implementation of the General Plan would result in acceptable operation of LOS D or better at all study intersections under Cotati’s jurisdiction. However, several segments on US 101 are projected to operate unacceptably at LOS F in the future (year 2040) due to regional growth including buildout of the General Plan. Therefore, the impact to US 101 was determined to be significant and unavoidable.
The General EIR determined that uncertainty exists as to whether funding will be available to achieve all General Plan policies and actions related to future circulation improvements including the widening of Gravenstein Highway (SR 116), a regional highway facility owned and operated by
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34 Caltrans that also serves local traffic within Cotati. Therefore, the potential for implementation of the General Plan to conflict with local policies would be significant and unavoidable.
The General Plan EIR determined that the General Plan does not contain provisions that would increase hazards due to design features of incompatible uses and roadway facilities in Cotati are not expected to impede emergency access. These impacts would be less than significant.
Since certification of the EIR and pursuant to Senate Bill (SB) 743, transportation impacts are evaluated using vehicle miles traveled (VMT) instead of LOS.
Addendum Analysis
Policies and actions in the General Plan that were referenced in the General Plan EIR would help reduce impacts to the greatest extent possible. These policies and actions would be required with implementation of the Housing Element update.
The Housing Element update is a policy document consistent with the General Plan. The Housing Element update identifies sites located throughout the city designated for residential development, which were evaluated previously for potential environmental impacts in the General Plan EIR. The Housing Element update also identifies sites that can accommodate ADUs as well as vacant and nonvacant properties that could accommodate new or additional housing units. Since non-vacant sites already contain some type of development, housing that may be built on these sites would not create a substantial change from current conditions. Similarly, most vacant sites are urban infill sites where development and infrastructure is already present adjacent to such sites. The units facilitated by the Housing Element update would not exceed the buildout capacity estimated under the General Plan and analyzed in the General Plan EIR. Additionally, the proposed housing sites would concentrate housing development in the city rather than in the SOI, which would reduce overall vehicle miles traveled.
The Housing Element update, in and of itself, does not propose specific projects but puts forth goals and policies that regulate various aspects of new housing development in Cotati. Because it is a policy document, the Housing Element update would not, in and of itself, result in impacts to transportation.
Future development facilitated by the Housing Element update would undergo project-specific developmental review and be required to adhere to General Plan policies and all applicable regulations and requirements related to transportation.
Conclusion
The adoption of the Housing Element update does not involve changes to the current adopted land uses and the housing units facilitated by the Housing Element update would not exceed the buildout capacity specified in the General Plan EIR. The Housing Element update would not result in impacts beyond those addressed or analyzed in the General Plan EIR nor present new information that shows impacts would be more significant than those described in the General Plan EIR. Therefore, the General Plan EIR applies to the Housing Element update and no additional environmental assessment of transportation is required.
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6.18 Tribal Cultural Resources
General Plan EIR Findings
Tribal Cultural Resources was added to the 2016 CEQA Guidelines as a separate environmental issue area. Thus, the General Plan EIR (published in September 2014) does not include a chapter or section dedicated to analysis of impacts to tribal cultural resources. However, it does analyze general impacts to historical and cultural resources (including archeological resources that may originate from Native American tribes) in Section 3.5, Cultural Resources. As the Notice of Preparation for the General Plan EIR was published before July 1, 2015, tribal consultation pursuant to Assembly Bill (AB) 52 was not required.
In 2011 during the General Plan update process, the City sent letters to the Native American Heritage Commission, the Federated Indians of Graton Rancheria, and the Cotati Historical Society to request information regarding the Planning Area. The Native American Heritage Commission responded indicating that they had no specific information regarding cultural resources within the Planning Area. The Federated Indians of Graton Rancheria responded indicating that because the General Plan Update falls under Senate Bill (SB) 18 they would initiate consultation directly with the City. The City met with the Federated Indians of Graton Rancheria and the Cotati Historical Society.
Addendum Analysis
The ethnographic context of the Coast Miwok is provided as Appendix A to this document. This appendix provides supplementary background information.
The Housing Element update is a policy document consistent with the General Plan. The Housing Element update identifies sites located throughout the city designated for residential development, which were evaluated previously for potential environmental impacts in the General Plan EIR. The Housing Element update also identifies sites that can accommodate ADUs as well as vacant and nonvacant properties that could accommodate new or additional housing units. Since non-vacant sites already contain some type of development, housing that may be built on these sites would not create a substantial change from current conditions. Similarly, most vacant sites are urban infill sites where development and infrastructure is already present adjacent to such sites. The units facilitated by the Housing Element update would not exceed the buildout capacity estimated under the General Plan and analyzed in the General Plan EIR.
The Housing Element update, in and of itself, does not propose specific projects but puts forth goals and policies that regulate various aspects of new housing development in Cotati. Because it is a policy document, the Housing Element update would not, in and of itself, result in impacts to tribal cultural resources.
On April 18, 2022 during the Housing Element update process, the City sent a letter to the Federated Indians of Graton Rancheria to initiate AB 52 and SB 18 consultation. The tribe responded on May 3, 2022, requesting both AB 52 and SB 18 consultation. The City met with the tribe on September 28, 2022 and December 12, 2022, and consultation is ongoing. Additional AB 52 and SB 18 consultation letters were sent to the Cloverdale Rancheria of Pomo Indians, Dry Creek Rancheria of Pomo Indians, Guidiville Indian Rancheria, Lytton Rancheria, Middletown Rancheria of Pomo Indians, Mishewal-Wappo Tribe of Alexander Valley, Pinoleville Pomo Indians, and Robinson Rancheria of Pomo Indians on July 1, 2022. None of these tribes requested consultation. No previously unidentified tribal cultural resources within the city have been identified during consultation, and the Housing Element update would not result in increased impacts to potential
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36 tribal cultural resources. However, future development facilitated under the Housing Element update would undergo project-specific developmental review and be required to comply with General Plan policies and actions and all applicable regulations that help protect and conserve tribal cultural resources.
Conclusion
The adoption of the Housing Element update does not involve changes to the current adopted land uses and the housing units facilitated by the Housing Element update would not exceed the buildout capacity specified in the General Plan EIR. The Housing Element update would not result in impacts beyond those addressed or analyzed in the General Plan EIR nor present new information that shows impacts would be more significant than those described in the General Plan EIR. Therefore, the General Plan EIR applies to the Housing Element update and no additional environmental assessment of tribal cultural resources is required.
6.19 Utilities
General Plan EIR Findings
Utilities are discussed in Section 3.13, Utilities, of the General Plan EIR. The General Plan EIR determined that the potential to exceed wastewater treatment capacity or the requirements of the Regional Water Quality Control Board would be cumulatively considerable and significant and unavoidable. The General Plan EIR further determined that impacts related to water supply, stormwater drainage, and solid waste would be less than significant.
Addendum Analysis
Policies and actions in the General Plan that were referenced in the General Plan EIR would help reduce impacts to the greatest extent possible. These policies and actions would be required with implementation of the Housing Element update.
The Housing Element update is a policy document consistent with the General Plan. The Housing Element update identifies sites located throughout the city designated for residential development, which were evaluated previously for potential environmental impacts in the General Plan EIR. The Housing Element update also identifies sites that can accommodate ADUs as well as vacant and nonvacant properties that could accommodate new or additional housing units. Since non-vacant sites already contain some type of development, housing that may be built on these sites would not create a substantial change from current conditions. Similarly, most vacant sites are urban infill sites where development and infrastructure is already present adjacent to such sites. The units facilitated by the Housing Element update would not exceed the buildout capacity estimated under the General Plan and analyzed in the General Plan EIR.
The Housing Element update, in and of itself, does not propose specific projects but puts forth goals and policies that regulate various aspects of new housing development in Cotati. Because it is a policy document, the Housing Element update would not, in and of itself, result in impacts to utilities.
Future development facilitated by the Housing Element update would undergo project-specific developmental review and be subject to adopted development guidelines and other regulatory requirements concerning water, wastewater, storm drains, solid waste, and other infrastructure; water supply; and wastewater treatment systems.
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Addendum Evaluation
State Clearinghouse # 2013082037 37
Conclusion
The adoption of the Housing Element update does not involve changes to the current adopted land uses and the housing units facilitated by the Housing Element update would not exceed the buildout capacity specified in the General Plan EIR. The Housing Element update would not result in impacts beyond those addressed or analyzed in the General Plan EIR nor present new information that shows impacts would be more significant than those described in the General Plan EIR. Therefore, the General Plan EIR applies to the Housing Element update and no additional environmental assessment of utilities is required.
6.20 Wildfire
General Plan EIR Findings
The General Plan EIR discusses wildfire in Section 3.7, Hazards, and determined that the City of Cotati is not categorized as a "Very High" Fire Hazard Severity Zone (FHSZ) by the California Department of Forestry and Fire Protection. A portion of the SOI is in a State Responsibility Area and categorized as a "Moderate" FHSZ. The closest "Very High" FHSZ is located east of SR 12, over 10 miles from the eastern city limits. The General Plan EIR states that as future development and infrastructure projects are considered by the City, each project would be evaluated for potential impacts, specific to the project, associated with wildland fire hazards as required under CEQA.
Impacts regarding potential to expose people or structures to a significant risk of loss, injury or death involving wildland fires, including where wildlands are adjacent to urbanized areas or where residences are intermixed with wildlands would be less than significant.
Addendum Analysis
The City of Cotati is not in a State Responsibility Area or Very High Fire Hazard Severity Area (California Department of Forestry and Fire Protection 2007). A portion of the Cotati SOI remains in a State Responsibility Area categorized as a “Moderate” FHSZ.
Policies and actions in the General Plan that were referenced in the General Plan EIR would help reduce impacts to the greatest extent possible. These policies and actions would be required with implementation of the Housing Element update.
The Housing Element update is a policy document consistent with the General Plan. The Housing Element update identifies sites located throughout the city designated for residential development, which were evaluated previously for potential environmental impacts in the General Plan EIR. The Housing Element update also identifies sites that can accommodate ADUs as well as vacant and nonvacant properties that could accommodate new or additional housing units. Since non-vacant sites already contain some type of development, housing that may be built on these sites would not create a substantial change from current conditions. Similarly, most vacant sites are urban infill sites where development and infrastructure is already present adjacent to such sites. The units facilitated by the Housing Element update would not exceed the buildout capacity estimated under the General Plan and analyzed in the General Plan EIR.
The Housing Element update, in and of itself, does not propose specific projects but puts forth goals and policies that regulate various aspects of new housing development in Cotati. Because it is a policy document, the Housing Element update would not, in and of itself, result in impacts to wildfire.
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38 Future development facilitated by the Housing Element update would be required to adhere to General Plan and other State and local regulatory requirements concerning wildfire hazards and emergency response. Additionally, the Housing Element update would concentrate housing development as infill development in the city and in areas with existing adequate emergency response services.
Conclusion
The adoption of the Housing Element update does not involve changes to the current adopted land uses and the housing units facilitated by the Housing Element update would not exceed the buildout capacity specified in the General Plan EIR. The Housing Element update would not result in impacts beyond those addressed or analyzed in the General Plan EIR nor present new information that shows impacts would be more significant than those described in the General Plan EIR. Therefore, the General Plan EIR applies to the Housing Element update and no additional environmental assessment of wildfire is required.
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Addendum Evaluation
State Clearinghouse # 2013082037 39
7 Conclusion
The City of Cotati, acting as the lead agency, determined that an addendum is the appropriate environmental document under CEQA because the proposed project would not require revisions to the certified General Plan EIR due to the involvement of new significant environmental effects or substantial increases in the severity of significant effects previously identified in the General Plan EIR.
There are no changed circumstances or new information that meets the standards for requiring further environmental review under CEQA Guidelines Section 15162. Thus, these circumstances and information would not result in new or more severe impacts beyond what were addressed in the General Plan EIR and would not meet any other standards under CEQA Guidelines Section 15162(a)(3). No additional analysis is required based on the discussions throughout this addendum.
The proposed Housing Element update would not involve development in areas not assumed for development in the General Plan EIR, nor would it result in population growth and density beyond what was analyzed in the General Plan EIR. The project would not result in significant or substantially more severe impacts that were not discussed in the General Plan EIR. Also, there are no previously identified significant effects which, as a result of substantial new information that was not known at the time of the previous environmental review, would be substantially more severe than discussed in the General Plan EIR. Accordingly, no additional CEQA review is required.
CEQA Guidelines Section 15164 states that “[t]he lead agency or a responsible agency shall prepare an addendum to a previously certified EIR if some changes or additions are necessary but none of the conditions described in CEQA Guidelines Section 15162 calling for preparation of a subsequent EIR have occurred.” An addendum is therefore appropriate because, as explained above, none of the conditions calling for preparation of a subsequent EIR have occurred.
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40 8 References
8.1 Bibliography
Association of Bay Area Government Regional Housing Needs Allocation (ABAG). 2022. https://abag.ca.gov/sites/default/files/documents/2022- 04/Final_RHNA_Methodology_Report_2023-2031_March2022_Update.pdf California Department of Conservation Division of Mines And Geology. Aggregate Materials In The San Francisco-Monterey Bay Area - SPECIAL REPORT 146 Part III Classification of Aggregate Resource Areas NORTH SAN FRANCISCO BAY PRODUCTION-CONSUMPTION REGION. 1987.
California Department of Finance. 2022. https://dof.ca.gov/Forecasting/Demographics/Estimates/E5/ California Department of Forestry and Fire Protection. 2007. FHSZ Viewer. https://egis.fire.ca.gov/FHSZ/ (accessed November 2022).
California Geological Survey Department of Conservation. 2013. Update of Mineral Land Classification: Aggregate Materials In the North San Francisco Bay Production-Consumption Region, Sonoma, Napa, Marin, And Southwestern Solano Counties, California.
Cotati, City of. 2014. Cotati General Plan Update Draft Environmental Impact Report. September 2014.
http://cotati.generalplan.org/sites/default/files/Public%20Draft%20EIR_Cotati%20GP.pdf _____. 2015. Cotati General Plan. Adopted March 24, 2015. http://cotati.generalplan.org/sites/default/files/Cotati%20General%20Plan_Adopted_Final_ 3-24-15_0.pdf
8.2 List of Preparers
Rincon Consultants, Inc. prepared this Addendum under contract to the City of Cotati. Persons involved in data gathering analysis, project management, and quality control are listed below.
RINCON CONSULTANTS, INC.
Matt Maddox, AICP, Principal-in-Charge
Aileen Mahoney, Project Manager
Amber McEldowney, Environmental Planner
Leanna Flaherty, Cultural Resources Specialist
Debra Jane Seltzer, Production Specialist
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A
Coast Miwok Ethnographic Context
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The City of Cotati is located in the traditional tribal territory of the Coast Miwok. Coast Miwok territory is centered on Marin and Sonoma Counties, extending roughly from Duncan’s Point south to Point Bonita, with the inland boundary east of the Sonoma River (Kelly 1978:414; Kroeber 1925:443). The Miwok Language consists of two dialect groups: the southern, or Marin group, and the western, or Bodega group (Kelly 1978:414).
The pre-contact Coast Miwok inhabited villages made up of conical dwellings, semi-subterranean sweathouses, and dance houses (Kelly 1978:417). Each village had a chief to oversee village affairs and social and ceremonial life was organized around moieties, or dichotomous groups, classed as either Land or Water (Kelly 1978:419).
Coast Miwok subsistence was based on hunting, gathering, and fishing (Kelly 1978: 415-417). Dried acorns and kelp were primary food sources during the winter and early spring when food was scarce.
Coast Miwok relied heavily on nearshore fish and shellfish and on fish from rivers, marshes, and the bay.
Hunting focused on deer, elk, bear, and small game. The material culture of the Coast Miwok included clamshell disk beads as currency, and a variety of stone tools, shell ornaments, ceremonial artifacts, and baskets (Kelly 1978: 417-418).
The Coast Miwok were exploited for labor by Mission Dolores, established in 1800 in San Francisco, and later by the Mexican land grant holders. As a direct result of the establishment of the mission system, the Coast Miwok population dramatically declined. After the establishment of the United States, the Coast Miwok were legally prevented from owning land in their traditional territories. Despite this, the Coast Miwok continued to populate the Marin area, often working as farm workers or in the fishing industry (Milliken et al. 2009; Federated Indians of Graton Rancheria 2016).
In 1920, the Bureau of Indian Affairs purchased a 15.45-acre tract of land in Graton, CA which was put into a federal trust and thus, the Graton Rancheria was formed. The development of the Graton Rancheria effectively consolidated the Coast Miwok and Southern Pomo groups into one entity, establishing them as a federally recognized tribe (Federated Indians of Graton Rancheria 2016).
However, in 1958 Congress passed the California Rancheria Act of 1958 which led the termination of 41 California Rancherias, including the Graton Rancheria. Graton Rancheria was removed from federal trust and federal recognition of the tribe was terminated. Despite this setback, tribal members continued to protect their cultural identity, preserving important tribal and archaeological sites within their traditional and ancestral territory. Between 1990 and 1992 tribal members traveled to Washington, D.C., in effort to restore their federal status but it wasn’t until 2000 that President Clinton finally signed legislation restoring federal recognition to the tribe, which had been renamed the Federated Indians of Grafton Rancheria. The tribe was able to purchase 254 acres of land in 2005 for its reservation located near Rohnert Park, CA where they now operate the Graton Resort and Casino, and in doing so, the tribe is able to provide programs and services to Tribal Citizens (Federated Indians of Graton Rancheria 2016).
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Federated Indians of Graton Rancheria
2016 History. Electronic Resource. https://gratonrancheria.com/culture/history/. Accessed September 27, 2021.
Kroeber, Alfred L.
1925 Handbook of the Indians of California. Bulletin 78, Bureau of American Ethnology, Smithsonian Institution. Government Printing Office, Washington, D.C. Reprinted 1976 by Dover Publications, Inc., New York.
Kelly, Isabel
1978 Coast Miwok. In Handbook of North American Indians, Vol. 8 (California), edited by William C. Sturtevant and Robert F. Heizer, pp. 414-425. Smithsonian Institution, Washington, D.C.
Milliken, Randall, Laurence Shoup, and Beverly Ortiz
2009 Ohlone/Costanoan Indians of the San Francisco Peninsula and Their Neighbors, Yesterday and Today. National Park Service, Golden Gate National Recreation Area, San Francisco, California.
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Packet Pg. 379 Attachment: PC Reso 23-03 (Housing Element Update) RESOLUTION NO.
A RESOLUTION OF THE COUNCIL OF THE CITY OF COTATI ADOPTING A
GENERAL PLAN AMENDMENT TO UPDATE THE HOUSING ELEMENT OF THE GENERAL PLAN FOR THE PERIOD OF 2023-2031, TO AFFIRMATIVELY FURTHER
FAIR HOUSING, AND TO COMPLY WITH ALL ASPECTS OF STATE HOUSING
ELEMENT LAW
WHEREAS, the California Government Code Section 65302 mandates that each city shall include a Housing Element in its General Plan, and that the Housing Element be updated periodically to reflect current conditions and legal requirements and set forth goals, policies and programs for the preservation, improvement and development of housing for all economic segments of the community and housing for persons with special needs; and WHEREAS, State Housing Element Law (Government Code Sections 65580 et seq.) requires that the City Council adopt a Housing Element for the eight-year period 2023-2031 to accommodate the City of Cotati regional housing need allocation (“RHNA”) of 234 housing units, comprised of 60 very-low income units, 34 low-income units, 39 moderate-income units, and 101 above moderate-income units; and
WHEREAS, the City of Cotati has prepared Housing Element Update 2023-2031 (“Housing Element”) in compliance with State Housing Element Law; and WHEREAS, as provided in Government Code Section 65350 et. seq., an update of the Housing Element constitutes a General Plan Amendment; and WHEREAS, an Addendum to the 2015 General Plan EIR was prepared in accordance with the California Environmental Quality Act (CEQA) Section 15164(a), which allows for the preparation of an Addendum to a previously certified EIR where there are no changes to the conditions or new significant environmental effects, where the changes undertaken are not substantial, and where no new mitigation measures are needed; and WHEREAS, as provided in Government Code Sections 65352 – 65352.5, the City of Cotati referred the Housing Element to all California Native American tribes on the contact list provided by the Native American Heritage Commission and to other entities listed and no tribes requested consultation; and
WHEREAS, the Housing Element must be adopted to comply with State law, accommodate the RHNA, affirmatively further fair housing, and facilitate and encourage a variety of housing types for all income levels, including multifamily housing (Gov. Code Sections 65583.2 and 65583(c)); and
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WHEREAS, the City conducted extensive community outreach since late 2021 including public workshops before the Planning Commission and City Council, community events, a bilingual community housing priorities survey, a stakeholder workshop that included developers and community-based organizations, and robust outreach through the City’s social media channels; and
WHEREAS, in accordance with Government Code Section 65585 (b), on November 18, 2022, the City submitted the draft Housing Element to the State Department of Housing and Community Development (HCD) for its review; and
WHEREAS, in February, HCD contacted the City with a list of questions and concerns about the adequacy of the draft Housing Element, and based upon those questions, City staff revised the draft Housing Element to include additional information and data, made the revised draft publicly available for seven calendar days, and submitted the revised draft to HCD; and WHEREAS, on February 16, 2023, the City received a letter from HCD providing its findings regarding the draft Housing Element, as revised; and WHEREAS, City staff reviewed the findings and again revised the draft Housing Element to incorporate HCD’s comments and requested changes, creating the adoption draft Housing Element; and
WHEREAS, on March 20, 2023, the Planning Commission conducted a duly and properly noticed public hearing, reviewed the adoption draft Housing Element and all pertinent maps, documents and exhibits, including HCD’s findings, the City’s response to HCD’s findings, the staff report and all attachments, all oral and written public comments, and the CEQA Addendum; and after doing so, recommended City Council certification of the Addendum to the 2015 General Plan EIR and determined the Housing Element to be consistent with State law and the General Plan of the City of Cotati; and
WHEREAS, on March 28, 2023, the City Council conducted a duly and properly noticed public hearing, reviewed the adoption draft Housing Element and all pertinent maps, documents and exhibits, including HCD’s findings, the City’s response to HCD’s findings, the staff report and all attachments, all oral and written public comments, and the CEQA Addendum; and after doing so, desires to approve certification of the Addendum to the 2015 General Plan EIR and determination that the Housing Element is consistent with State law and the General Plan of the City of Cotati.
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NOW, THEREFORE, BE IT RESOLVED, that the above recitations are true and correct and are incorporated by reference into this action.
BE IT FURTHER RESOLVED, that the adoption of the Housing Element Update will not have a significant effect on the environment and an Addendum to the 2015 General Plan EIR has been prepared for the project and has been recommended for certification by the City Council.
BE IT FURTHER RESOLVED, that the City Council make the following findings:
a) The Housing Element Update is internally consistent with the Cotati General Plan. b) As required by Government Code Section 65585(e), the City Council has considered the findings made by the Department of Housing and Community Development included in the Department’s letter to the City of Cotati dated February 16, 2023, consistent with Government Code Section 65585(f), and as described in Exhibit A to this Resolution, incorporated herein by this reference, the Housing Element has been amended in response to the findings of the Department to substantially comply with the requirements of State Housing Element Law as interpreted by HCD. c) The Housing Element substantially complies with State Housing Element Law, as provided in Government Code 65580 et seq. and contains all provisions required by State Housing Element Law.
d) Based on substantial evidence in the record, the existing uses on the non-vacant sites identified in the site inventory to accommodate the RHNA are likely to be discontinued during the planning period or otherwise do not constitute an impediment to planned residential development on the site during the planning period.
BE IT FURTHER RESOLVED, that the City Council of the City of Cotati: rescind the current Housing Element and adopt this Resolution certifying the General Plan Environmental Impact Report Addendum (Exhibit C) and adopting the Housing Element General Plan Amendment (Exhibit B); and
BE IT FURTHER RESOLVED, that the City Manager is hereby delegated the authority to make additional non-substantive changes to the adopted Housing Element, including its Technical Background Report and Appendices, to address further requirements from HCD necessary to achieve State certification.
IT IS HEREBY CERTIFIED that the foregoing resolution was duly adopted at a regular meeting of the City Council of the City of Cotati held on the March 28th, 2023, by the following vote, to wit:
Approved:________________________________
Mayor
Attest:____________________________
Kevin Patterson, Deputy City Clerk
Approved as to form:
____________________________
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City Attorney
Attachments:
Exhibit A Cotati Housing Element Statutory Requirements Checklist (2023-03-21) (DOCX)
Exhibit B1 - Cotati Adoption Draft Housing Element (2023-03-20) (PDF) Attachment 1, Exhibit B2 - Cotati Adoption Draft Technical Background Report (PDF) Exhibit B3 - Cotati Adoption Draft Housing Element Appendices (2023-03-20) (PDF) Exhibit C - Cotati HE_Final Addendum_March 2023 (PDF)
Exhibit C1 - Final_EIR_Cotati_GPU (PDF)
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Cotati City Council Resolution xx Exhibit A
COTATI CITY COUNCIL RESOLUTION XX EXHIBIT A: CONFORMANCE OF HOUSING ELEMENT WITH STATE LAW REQUIREMENTS, ARTICLE 10.6 [65580 – 65589.11]
GOVERNMENT CODE PROVISION HOUSING ELEMENT COMPLIANCE
Section 65583
The housing element shall consist of an
identification and analysis of existing and
projected housing needs and a statement of
goals, policies, quantified objectives,
financial resources, and scheduled programs
for the preservation, improvement, and
development of housing.
4.2 Housing Needs Data
2.1 Housing Strategy
2.2 Quantified Objectives
4.3 Local Housing Programs and Resources
The housing element shall identify adequate
sites for housing, including rental housing,
factory-built housing, mobilehomes, and
emergency shelters, and shall make
adequate provision for the existing and
projected needs of all economic segments of
the community.
4.3.2 Zoning for a Variety of Housing Types
3.2 Projected Development and RHNA Credit
3.3 Realistic Capacity of Sites Zoned for
Housing
The element shall contain all of the
following:
(a) An assessment of housing needs and an
inventory of resources and constraints
relevant to the meeting of these needs. The
assessment and inventory shall include all of
the following:
4.2 Housing Needs Data
4.4 Housing Constraints Analysis
Appendix E Housing Needs Data Report
(a)(1) An analysis of population and
employment trends and documentation of
projections
1.9 Changing Housing Needs and
Demographics
4.5.4 Economic Development and Job Access
Appendix E Housing Needs Data Report
(a)(1) A quantification of the locality’s
existing and projected housing needs for all
income levels, including extremely low
income households, as defined in
subdivision (b) of Section 50105 and Section
50106 of the Health and Safety Code. These
existing and projected needs shall include
the locality’s share of the regional housing
need in accordance with Section 65584.
Local agencies shall calculate the subset of
1.9.2 Household Incomes and Housing
Affordability
1.13 Regional Housing Needs Allocation
4.2.2 Housing Needs AnalysisAppendix E
Housing Needs Data Report
10.a
Packet Pg. 384 Attachment: Exhibit A Cotati Housing Element Statutory Requirements Checklist (2023-03-21) (Housing Element CC Resolution) Cotati City Council Resolution xx Exhibit A
very low income households allotted under
Section 65584 that qualify as extremely low
income households. The local agency may
either use available census data to calculate
the percentage of very low income
households that qualify as extremely low
income households or presume that 50
percent of the very low income households
qualify as extremely low income households.
The number of extremely low income
households and very low income households
shall equal the jurisdiction’s allocation of
very low income households pursuant to
Section 65584.
(a)(2) An analysis and documentation of
household characteristics, including level of
payment compared to ability to pay,
1.9.2 Household Incomes and Housing
Affordability
4.2.2 Housing Needs Analysis4.5.5
Disproportionate Housing Needs, Including
Displacement
(a)(2) housing characteristics, including
overcrowding, and
1.9 Changing Housing Needs and
Demographics
1.10 Characteristics of Housing Stock
4.5.5 Disproportionate Housing Needs,
Including Displacement
Appendix E Housing Needs Data Report
(a)(2) housing stock condition. 1.10 Characteristics of Housing Stock
4.5.5 Disproportionate Housing Needs,
Including DisplacementAppendix E Housing
Needs Data Report
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Packet Pg. 385 Attachment: Exhibit A Cotati Housing Element Statutory Requirements Checklist (2023-03-21) (Housing Element CC Resolution) Cotati City Council Resolution xx Exhibit A
(a)(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, and an
analysis of the relationship of the sites
identified in the land inventory to the
jurisdiction’s duty to affirmatively further
fair housing. Note: Please see Section
65583.2 regarding the land inventory.
3 Housing Sites
[Note that AB 2339 (Chapter 654, Statutes
of 2022) amended Section 65583(a)(4). It
does not apply to ABAG-area housing
elements unless the first draft of the
housing element is submitted to ABAG after
January 31, 2023 or a draft is submitted
after April 1, 2023. Therefore the sections
below include the statutory provisions of
Section 65583(a)(4) effective in 2022.
Jurisdictions adopting their housing
element after January 1, 2023 should
describe why AB 2339 is not applicable to
them.]
AB 2339 is addressed in this draft
4.2.3 Zoning for a Variety of Housing Types
(a)(4)(A) The identification of a zone or
zones where emergency shelters are allowed
as a permitted use without a conditional use
or other discretionary permit. The identified
zone or zones shall include sufficient
capacity to accommodate the need for
emergency shelter identified in paragraph
(7), except that each local government shall
identify a zone or zones that can
accommodate at least one year-round
emergency shelter.
4.2.3 Zoning for a Variety of Housing Types
(a)(4)(A) If the local government cannot
identify a zone or zones with sufficient
capacity, the local government shall include
Not applicable
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a program to amend its zoning ordinance to
meet the requirements of this paragraph
within one year of the adoption of the
housing element. The local government may
identify additional zones where emergency
shelters are permitted with a conditional use
permit.
(a)(4)(A) The local government shall also
demonstrate that existing or proposed
permit processing, development, and
management standards are objective and
encourage and facilitate the development of,
or conversion to, emergency shelters.
4.2.3 Zoning for a Variety of Housing Types
(a)(4)(A) Emergency shelters may only be
subject to those development and
management standards that apply to
residential or commercial development
within the same zone except that a local
government may apply written, objective
standards that include all of the following:
(i) The maximum number of beds or persons
permitted to be served nightly by the facility.
(ii) Sufficient parking to accommodate all
staff working in the emergency shelter,
provided that the standards do not require
more parking for emergency shelters than
other residential or commercial uses within
the same zone.
(iii) The size and location of exterior and
interior onsite waiting and client intake
areas.
(iv) The provision of onsite management.
(v) The proximity to other emergency
shelters, provided that emergency shelters
are not required to be more than 300 feet
apart.
(vi) The length of stay.
(vii) Lighting.
(viii) Security during hours that the
emergency shelter is in operation.
4.2.3 Zoning for a Variety of Housing Types
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(a)(4)(B) The permit processing,
development, and management standards
applied under this paragraph shall not be
deemed to be discretionary acts within the
meaning of the California Environmental
Quality Act (Division 13 (commencing with
Section 21000) of the Public Resources
Code).
4.2.3 Zoning for a Variety of Housing Types
(a)(4)(C) A local government that can
demonstrate to the satisfaction of the
department the existence of one or more
emergency shelters either within its
jurisdiction or pursuant to a
multijurisdictional agreement that can
accommodate that jurisdiction’s need for
emergency shelter identified in paragraph
(7) may comply with the zoning
requirements of subparagraph (A) by
identifying a zone or zones where new
emergency shelters are allowed with a
conditional use permit.
4.2.3 Zoning for a Variety of Housing Types
(a)(4)(D) A local government with an existing
ordinance or ordinances that comply with
this paragraph shall not be required to take
additional action to identify zones for
emergency shelters. The housing element
must only describe how existing ordinances,
policies, and standards are consistent with
the requirements of this paragraph.
4.2.3 Zoning for a Variety of Housing Types
(a)(5) 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 [Note: The types
of housing identified in Section 65583(c)(1)
include multifamily rental housing, factorybuilt housing, mobilehomes, housing for agricultural employees, supportive housing,
single-room occupancy units, emergency
shelters, and transitional housing.]
4.2.3 Zoning for a Variety of Housing Types
4.4 Housing Constraints Analysis
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(a)(5) for persons with disabilities as
identified in the analysis pursuant to
paragraph (7),
4.4.2 Potential Governmental Constraints
(a)(5) including land use controls, 4.4.2 Potential Governmental Constraints (a)(5) building codes and their enforcement, 4.4.2 Potential Governmental Constraints (a)(5) site improvements, 4.4.3 Environmental and Infrastructure Constraints
(a)(5) fees and other exactions required of
developers,
4.4.2 Potential Governmental Constraints
(a)(5) local processing and permit
procedures,
4.4.2 Potential Governmental Constraints
(a)(5) and any locally adopted ordinances
that directly impact the cost and supply of
residential development.
4.3.4 Planning and Zoning Incentives
(a)(5) The analysis shall also demonstrate
local efforts to remove governmental
constraints that hinder the locality from
meeting its share of the regional housing
need in accordance with Section 65584
4.4.2 Potential Governmental Constraints
(a)(5) and from meeting the need for
housing for persons with disabilities,
supportive housing, transitional housing,
and emergency shelters identified pursuant
to paragraph (7).
4.2.2 Housing Needs Analysis
4.2.3 Zoning for a Variety of Housing Types
4.4.2 Potential Governmental Constraints
(a)(6) An analysis of potential and actual
nongovernmental constraints upon the
maintenance, improvement, or development
of housing for all income levels, including
the availability of financing,
4.4.1 Non-Governmental Constraints
(a)(6) the price of land, 4.4.1 Non-Governmental Constraints (a)(6) the cost of construction, 4.4.1 Non-Governmental Constraints (a)(6) the requests to develop housing at
densities below those anticipated in the
analysis required by subdivision (c) of
Section 65583.2,
4.4.2 Potential Governmental Constraints
(a)(6) and the length of time between
receiving approval for a housing
development and submittal of an application
for building permits for that housing
development that hinder the construction of
4.4.1 Non-Governmental Constraints
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a locality’s share of the regional housing
need in accordance with Section 65584.
(a)(6) The analysis shall also demonstrate
local efforts to remove nongovernmental
constraints that create a gap between the
locality’s planning for the development of
housing for all income levels and the
construction of that housing.
4.4.1 Nongovernmental Constraints
(a)(7) An analysis of any special housing
needs, such as those of the
4.2.2 Housing Needs Analysis
(a)(7) elderly; 4.2.2 Housing Needs Analysis
(a)(7) persons with disabilities, including a
developmental disability, as defined in
Section 4512 of the Welfare and Institutions
Code;
4.2.2 Housing Needs Analysis
(a)(7) large families; 4.2.2 Housing Needs Analysis
(a)(7) farmworkers; 4.2.2 Housing Needs Analysis
(a)(7) families with female heads of
households;
4.2.2 Housing Needs Analysis
(a)(7) and families and persons in need of
emergency shelter.
4.2.2 Housing Needs Analysis
4.5.5 Disproportionate Housing Needs,
Including Displacement
4.2.3 Zoning for a Variety of Housing Types
(a)(7) The need for emergency shelter shall
be assessed based on the capacity necessary
to accommodate the most recent homeless
point-in-time count conducted before the
start of the planning period, the need for
emergency shelter based on number of beds
available on a year-round and seasonal basis,
the number of shelter beds that go unused
on an average monthly basis within a oneyear period, and the percentage of those in emergency shelters that move to permanent
housing solutions.
4.2.2 Housing Needs Analysis
4.5.5 Disproportionate Housing Needs,
Including Displacement
4.2.3 Zoning for a Variety of Housing Types
(a)(7) The need for emergency shelter may
be reduced by the number of supportive
housing units that are identified in an
adopted 10-year plan to end chronic
homelessness and that are either vacant or
for which funding has been identified to
Not required
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allow construction during the planning
period.
(a)(7) An analysis of special housing needs
by a city or county may include an analysis of
the need for frequent user coordinated care
housing services.
Not required
(a)(8) An analysis of opportunities for energy
conservation with respect to residential
development. Cities and counties are
encouraged to include weatherization and
energy efficiency improvements as part of
publicly subsidized housing rehabilitation
projects. This may include energy efficiency
measures that encompass the building
envelope, its heating and cooling systems,
and its electrical system.
Program 1-8: Residential Building
Decarbonization
(a)(9) An analysis of existing assisted housing
developments that are eligible to change
from low-income housing uses during the
next 10 years due to termination of subsidy
contracts, mortgage prepayment, or
expiration of restrictions on use. “Assisted
housing developments,” for the purpose of
this section, shall mean multifamily rental
housing that receives governmental
assistance under federal programs listed in
subdivision (a) of Section 65863.10, state
and local multifamily revenue bond
programs, local redevelopment programs,
the federal Community Development Block
Grant Program, or local in-lieu fees. “Assisted
housing developments” shall also include
multifamily rental units that were developed
pursuant to a local inclusionary housing
program or used to qualify for a density
bonus pursuant to Section 65915.
4.3.3 At-Risk Assisted Housing Developments
Appendix E Housing Needs Data Packet
(a)(9)(A) The analysis shall include a listing of
each development by project name and
address, the type of governmental
assistance received, the earliest possible
date of change from low-income use, and
No Projects at Risk
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the total number of elderly and nonelderly
units that could be lost from the locality’s
low-income housing stock in each year
during the 10-year period. For purposes of
state and federally funded projects, the
analysis required by this subparagraph need
only contain information available on a
statewide basis.
(a)(9)(B) The analysis shall estimate the total
cost of producing new rental housing that is
comparable in size and rent levels, to replace
the units that could change from low-income
use, and an estimated cost of preserving the
assisted housing developments. This cost
analysis for replacement housing may be
done aggregately for each five-year period
and does not have to contain a project-byproject cost estimate.
No Projects at Risk
(a)(9)(C) The analysis shall identify public
and private nonprofit corporations known to
the local government that have legal and
managerial capacity to acquire and manage
these housing developments.
No Projects at Risk
(a)(9)(D) The analysis shall identify and
consider the use of all federal, state, and
local financing and subsidy programs that
can be used to preserve, for lower income
households, the assisted housing
developments, identified in this paragraph,
including, but not limited to, federal
Community Development Block Grant
Program funds, tax increment funds received
by a redevelopment agency of the
community, and administrative fees received
by a housing authority operating within the
community. In considering the use of these
financing and subsidy programs, the analysis
shall identify the amounts of funds under
each available program that have not been
legally obligated for other purposes and that
No Projects at Risk
4.3.1 Resources: Housing Assistance
Programs
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could be available for use in preserving
assisted housing developments.
(b) (1) A statement of the community’s
goals, quantified objectives, and policies
relative to affirmatively furthering fair
housing and to the maintenance,
preservation, improvement, and
development of housing.
2.2 Quantified Objectives
(2) It is recognized that the total housing
needs identified pursuant to subdivision (a)
may exceed available resources and the
community’s ability to satisfy this need
within the content of the general plan
requirements outlined in Article 5
(commencing with Section 65300). Under
these circumstances, the quantified
objectives need not be identical to the total
housing needs. The quantified objectives
shall establish the maximum number of
housing units by income category, including
extremely low income, that can be
constructed, rehabilitated, and conserved
over a five-year time period.
2.2 Quantified Objectives
(c) A program that sets forth a schedule of
actions during the planning period, each
with a timeline for implementation, that
may recognize that certain programs are
ongoing, such that there will be beneficial
impacts of the programs within the planning
period, that the local government is
undertaking or intends to undertake to
implement the policies and achieve the
goals and objectives of the housing element
2.1 Housing Strategy
(c) through the administration of land use
and development controls,
2.1 Housing Strategy
(c) the provision of regulatory concessions
and incentives,
2.1 Housing Strategy
(c) the utilization of appropriate federal and
state financing and subsidy programs when
available,
2.1 Housing Strategy
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(c) and the utilization of moneys in a lowand moderate-income housing fund of an agency if the locality has established a
redevelopment project area pursuant to the
Community Redevelopment Law (Division 24
(commencing with Section 33000) of the
Health and Safety Code).
N/A
In order to make adequate provision for the
housing needs of all economic segments of
the community, the program shall do all of
the following:
2.1 Housing Strategy
(c)(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 Section 65584.09.
2.1 Housing Strategy
(c)(1) Sites shall be identified as needed to
affirmatively further fair housing
2.1 Housing Strategy
3 Housing Sites
4.5.7 Housing Sites and AFFH Considerations
(c)(1) and to facilitate and encourage the
development of a variety of types of housing
for all income levels, including multifamily
rental housing,
2.1 Housing Strategy
3 Housing Sites
4.3.2 Provisions for a Variety of Housing
Types
(c)(1) factory-built housing, 2.1 Housing Strategy
3 Housing Sites
4.3.2 Provisions for a Variety of Housing
Types
(c)(1) mobilehomes, 2.1 Housing Strategy
3 Housing Sites
4.3.2 Provisions for a Variety of Housing
Types
(c)(1) housing for agricultural employees, 2.1 Housing Strategy 3 Housing Sites
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4.3.2 Provisions for a Variety of Housing
Types
(c)(1) supportive housing, 2.1 Housing Strategy
3 Housing Sites
4.3.2 Provisions for a Variety of Housing
Types
(c)(1) single-room occupancy units, 2.1 Housing Strategy 3 Housing Sites
4.3.2 Provisions for a Variety of Housing
Types
(c)(1) emergency shelters, 2.1 Housing Strategy
3 Housing Sites
4.3.2 Provisions for a Variety of Housing
Types
(c)(1) and transitional housing. 2.1 Housing Strategy
3 Housing Sites
4.3.2 Provisions for a Variety of Housing
Types
(c)(1)(A) Where the inventory of sites,
pursuant to paragraph (3) of subdivision (a),
does not identify adequate sites to
accommodate the need for groups of all
household income levels pursuant to Section
65584, rezoning of those sites, including
adoption of minimum density and
development standards, for jurisdictions
with an eight-year housing element planning
period pursuant to Section 65588, shall be
completed no later than three years after
either the date the housing element is
adopted pursuant to subdivision (f) of
Section 65585 or the date that is 90 days
after receipt of comments from the
department pursuant to subdivision (b) of
Section 65585, whichever is earlier, unless
the deadline is extended pursuant to
subdivision (f). Notwithstanding the
foregoing, for a local government that fails
to adopt a housing element that the
department has found to be in substantial
compliance with this article within 120 days
2.1 Housing Strategy
3 Housing Sites
3.4 Programs to Assist in the Development
of Housing
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of the statutory deadline in Section 65588
for adoption of the housing element,
rezoning of those sites, including adoption of
minimum density and development
standards, shall be completed no later than
one year from the statutory deadline in
Section 65588 for adoption of the housing
element.
(c)(1)(B) Where the inventory of sites,
pursuant to paragraph (3) of subdivision (a),
does not identify adequate sites to
accommodate the need for groups of all
household income levels pursuant to Section
65584, the program shall identify sites that
can be developed for housing within the
planning period pursuant to subdivision (h)
of Section 65583.2. The identification of
sites shall include all components specified
in Section 65583.2. Note: Please see Section
65583.2 regarding the land inventory and
conformance with subdivision (h).
2.1 Housing Strategy
3 Housing Sites
3.4 Programs to Assist in the Development
of Housing
(c)(1)(C) Where the inventory of sites
pursuant to paragraph (3) of subdivision (a)
does not identify adequate sites to
accommodate the need for farmworker
housing, the program shall provide for
sufficient sites to meet the need with zoning
that permits farmworker housing use by
right, including density and development
standards that could accommodate and
facilitate the feasibility of the development
of farmworker housing for low- and very low
income households.
2.1 Housing Strategy
3 Housing Sites
3.4 Programs to Assist in the Development
of Housing
4.3.2 Provisions for a Variety of Housing
Types
(c)(2) Assist in the development of adequate
housing to meet the needs of extremely low,
very low, low-, and moderate-income
households.
2.1 Housing Strategy
3.4 Programs to Assist in the Development
of Housing
(c)(3) Address and, where appropriate and
legally possible, remove governmental and
nongovernmental constraints to the
maintenance, improvement, and
2.1 Housing Strategy
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development of housing, including housing
for all income levels
(c)(3) 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.
2.1 Housing Strategy
(c)(3) Transitional housing and supportive
housing shall be considered a residential use
of property and shall be subject only to
those restrictions that apply to other
residential dwellings of the same type in the
same zone.
2.1 Housing Strategy
(c)(3)Supportive housing, as defined in
Section 65650, shall be a use by right in all
zones where multifamily and mixed uses are
permitted, as provided in Article 11
(commencing with Section 65650).
2.1 Housing Strategy
(c)(4) Conserve and improve the condition of
the existing affordable housing stock, which
may include addressing ways to mitigate the
loss of dwelling units demolished by public
or private action.
2.1 Housing Strategy
(c)(5) 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 protected by the California
Fair Employment and Housing Act (Part 2.8
(commencing with Section 12900) of
Division 3 of Title 2), Section 65008, and any
other state and federal fair housing and
planning law.
2.1 Housing Strategy
(c)(6) Preserve for lower income households
the assisted housing developments
identified pursuant to paragraph (9) of
subdivision (a).
2.1 Housing Strategy
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(c)(6) The program for preservation of the
assisted housing developments shall utilize,
to the extent necessary, all available federal,
state, and local financing and subsidy
programs identified in paragraph (9) of
subdivision (a), except where a community
has other urgent needs for which alternative
funding sources are not available.
2.1 Housing Strategy
(c)(6) The program may include strategies
that involve local regulation and technical
assistance.
2.1 Housing Strategy
(c)(7) Develop a plan that incentivizes and
promotes the creation of accessory dwelling
units that can be offered at affordable rent,
as defined in Section 50053 of the Health
and Safety Code, for very low, low-, or
moderate-income households. For purposes
of this paragraph, “accessory dwelling units”
has the same meaning as “accessory
dwelling unit” as defined in paragraph (4) of
subdivision (i) of Section 65852.2.\
2.1 Housing Strategy
(c)(8) Include an identification of the
agencies and officials responsible for the
implementation of the various actions and
the means by which consistency will be
achieved with other general plan elements
and community goals.
2.1 Housing Strategy
(c)(9) Include a diligent effort by the local
government to achieve public participation
of all economic segments of the community
in the development of the housing element,
and the program shall describe this effort.
1.4 Public Participation
Appendix C: Community Engagement &
Input
Appendix D: Community Survey Results
(c)(10)(A) Affirmatively further fair housing
in accordance with Chapter 15 (commencing
with Section 8899.50) of Division 1 of Title 2.
The program shall include an assessment of
fair housing in the jurisdiction that shall
include all of the following components:
4.5 Assessment of Fair Housing
(c)(10)(A)(i) A summary of fair housing issues
in the jurisdiction
4.5.6 Summary of Fair Housing Goals and
Priorities Based on Identified Contributing
Factors
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(c)(10)(A)(i) and an assessment of the
jurisdiction’s fair housing enforcement and
fair housing outreach capacity.
4.5.2 Fair Housing Enforcement and
Outreach Capacity
(c)(10)(A)(ii) An analysis of available federal,
state, and local data and knowledge to
identify integration and segregation patterns
and trends,
4.5.3 Segregation and Integration Patterns
and Trends
(c)(10)(A)(ii)racially or ethnically
concentrated areas of poverty and affluence,
4.5.3 Segregation and Integration Patterns
and Trends
(c)(10)(A)(ii) disparities in access to
opportunity,
4.5.4 Disparities in Access to Opportunities
(c)(10)(A)(ii) and disproportionate housing
needs,
4.5.5 Disproportionate Housing Needs,
Including Displacement
(c)(10)(A)(ii) including displacement risk. 4.5.5 Disproportionate Housing Needs, Including Displacement
(c)(10)(A)(ii) The analysis shall identify and
examine such patterns, trends, areas,
disparities, and needs, both within the
jurisdiction.
4.5 Assessment of Fair Housing
(c)(10)(A)(ii) and comparing the jurisdiction
to the region in which it is located, based on
race and other characteristics protected by
the California Fair Employment and Housing
Act (Part 2.8 (commencing with Section
12900) of Division 3 of Title 2) and Section
65008.
4.5 Assessment of Fair Housing
(c)(10)(A)(iii) An assessment of the
contributing factors, including the local and
regional historical origins
4.5.6 Summary of Fair Housing Goals and
Priorities Based on Identified Contributing
Factors
(c)(10)(A)(iii) and current policies and
practices, for the fair housing issues
identified under clauses (i) and (ii).
4.5.6 Summary of Fair Housing Goals and
Priorities Based on Identified Contributing
Factors
(c)(10)(A)(iv) An identification of the
jurisdiction’s fair housing priorities and
goals, giving highest priority to those factors
identified in clause (iii) that limit or deny fair
housing choice or access to opportunity, or
negatively impact fair housing or civil rights
compliance,
4.5.6 Summary of Fair Housing Goals and
Priorities Based on Identified Contributing
Factors
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(c)(10)(A)(iv) and identifying the metrics and
milestones for determining what fair housing
results will be achieved.
2.1 Housing Strategy
(c)(10)(A)(v) Strategies and actions to
implement those priorities and goals, which
may include, but are not limited to,
enhancing mobility strategies
4.5.6 Summary of Fair Housing Goals and
Priorities Based on Identified Contributing
Factors
2.1 Housing Strategy
(c)(10)(A)(v) and encouraging development
of new affordable housing in areas of
opportunity,
4.5.6 Summary of Fair Housing Goals and
Priorities Based on Identified Contributing
Factors
2.1 Housing Strategy
(c)(10)(A)(v) as well as place-based strategies
to encourage community revitalization,
including preservation of existing affordable
housing,
.5.6 Summary of Fair Housing Goals and
Priorities Based on Identified Contributing
Factors
2.1 Housing Strategy
(c)(10)(A)(v) and protecting existing
residents from displacement.
.5.6 Summary of Fair Housing Goals and
Priorities Based on Identified Contributing
Factors
2.1 Housing Strategy
(c)(10)(B) A jurisdiction that completes or
revises an assessment of fair housing
pursuant to Subpart A (commencing with
Section 5.150) of Part 5 of Subtitle A of Title
24 of the Code of Federal Regulations, as
published in Volume 80 of the Federal
Register, Number 136, page 42272, dated
July 16, 2015, or an analysis of impediments
to fair housing choice in accordance with the
requirements of Section 91.225 of Title 24 of
the Code of Federal Regulations in effect
before August 17, 2015, may incorporate
relevant portions of that assessment or
revised assessment of fair housing or
analysis or revised analysis of impediments
to fair housing into its housing element.
4.5 Assessment of Fair Housing
(c)(10)(C) The requirements of this
paragraph shall apply to housing elements
due to be revised pursuant to Section 65588
on or after January 1, 2021.
4.5 Assessment of Fair Housing
(d)(1) A local government may satisfy all or
part of its requirement to identify a zone or
Not required and not utilized.
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zones suitable for the development of
emergency shelters pursuant to paragraph
(4) of subdivision (a) by adopting and
implementing a multijurisdictional
agreement, with a maximum of two other
adjacent communities, that requires the
participating jurisdictions to develop at least
one year-round emergency shelter within
two years of the beginning of the planning
period.
(d)(2) The agreement shall allocate a portion
of the new shelter capacity to each
jurisdiction as credit toward its emergency
shelter need, and each jurisdiction shall
describe how the capacity was allocated as
part of its housing element.
Not required and not utilized.
(d)(3) Each member jurisdiction of a
multijurisdictional agreement shall describe
in its housing element all of the following:
Not required and not utilized.
(d)(3)(A) How the joint facility will meet the
jurisdiction’s emergency shelter need.
(d)(3)(B) The jurisdiction’s contribution to
the facility for both the development and
ongoing operation and management of the
facility.
(d)(3)(C) The amount and source of the
funding that the jurisdiction contributes to
the facility.
Not required and not utilized.
(d)(4) The aggregate capacity claimed by the
participating jurisdictions in their housing
elements shall not exceed the actual
capacity of the shelter.
Not required and not utilized.
(e) Except as otherwise provided in this
article, amendments to this article that alter
the required content of a housing element
shall apply to both of the following: [Note
that this provision is applicable to AB 2339
(Chapter 654, Statutes of 2022), which
amended Section 65583(a)(4). Jurisdictions
adopting their housing element after
4.2.3 Zoning for a Variety of Housing Types
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January 1, 2023 should describe why this
amendment is not applicable to them.]
(1) A housing element or housing element
amendment prepared pursuant to
subdivision (e) of Section 65588 or Section
65584.02, when a city, county, or city and
county submits a draft to the department for
review pursuant to Section 65585 more than
90 days after the effective date of the
amendment to this section.
4.2.3 Zoning for a Variety of Housing Types
(2) Any housing element or housing element
amendment prepared pursuant to
subdivision (e) of Section 65588 or Section
65584.02, when the city, county, or city and
county fails to submit the first draft to the
department before the due date specified in
Section 65588 or 65584.02.
4.2.3 Zoning for a Variety of Housing Types
(f) – (j): Not applicable
Section 65583.1(a)
(a) The Department of Housing and
Community Development, in evaluating a
proposed or adopted housing element for
substantial compliance with this article, …
may also allow a city or county to identify
sites for accessory dwelling units based on
the number of accessory dwelling units
developed in the prior housing element
planning period whether or not the units are
permitted by right, the need for these units
in the community, the resources or
incentives available for their development,
and any other relevant factors, as
determined by the department.
3.2.1 ADUs and JADUs
(b) Sites that contain permanent housing
units located on a military base undergoing
closure or conversion as a result of action
pursuant to the Defense Authorization
Amendments and Base Closure and
Realignment Act (Public Law 100-526), the
Defense Base Closure and Realignment Act
of 1990 (Public Law 101-510), or any
Not required and not utilized.
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Packet Pg. 402 Attachment: Exhibit A Cotati Housing Element Statutory Requirements Checklist (2023-03-21) (Housing Element CC Resolution) Cotati City Council Resolution xx Exhibit A
subsequent act requiring the closure or
conversion of a military base may be
identified as an adequate site if the housing
element demonstrates that the housing
units will be available for occupancy by
households within the planning period of
the element. No sites containing housing
units scheduled or planned for demolition or
conversion to nonresidential uses shall
qualify as an adequate site.
Section 65583.2
(a) A city’s or county’s inventory of land
suitable for residential development
pursuant to paragraph (3) of subdivision (a)
of Section 65583 shall be used to identify
sites throughout the community, consistent
with paragraph (10) of subdivision (c) of
Section 65583,
3.3 Realistic Capacity of Sites Zoned for
Housing
(a) that can be developed for housing within
the planning period and that are sufficient to
provide for the jurisdiction’s share of the
regional housing need for all income levels
pursuant to Section 65584. As used in this
section, “land suitable for residential
development” includes all of the following
sites that meet the standards set forth in
subdivisions (c) and (g):
3.3 Realistic Capacity of Sites Zoned for
Housing
(a)(1) Vacant sites zoned for residential use. 3.3.1 Vacant Sites (a)(2) Vacant sites zoned for nonresidential
use that allows residential development.
3.3.1 Vacant Sites
(a)(3) Residentially zoned sites that are
capable of being developed at a higher
density, including sites owned or leased by a
city, county, or city and county
3.3.2 Non-Vacant Sites
(a)(4) Sites zoned for nonresidential use that
can be redeveloped for residential use, and
for which the housing element includes a
program to rezone the site, as necessary,
rezoned for, to permit residential use,
including sites owned or leased by a city,
county, or city and county.
3.3.2 Non-Vacant Sites
10.a
Packet Pg. 403 Attachment: Exhibit A Cotati Housing Element Statutory Requirements Checklist (2023-03-21) (Housing Element CC Resolution) Cotati City Council Resolution xx Exhibit A
(b) The inventory of land shall include all of
the following:
3.3 Realistic Capacity of Sites Zoned for
Housing
Appendix B: Sites Inventory
(b)(1) A listing of properties by assessor
parcel number.
3.3 Realistic Capacity of Sites Zoned for
Housing
Appendix B: Sites Inventory
(b)(2) The size of each property listed
pursuant to paragraph (1), and the general
plan designation and zoning of each
property.
3.3 Realistic Capacity of Sites Zoned for
Housing
Appendix B: Sites Inventory
(b)(3) For nonvacant sites, a description of
the existing use of each property.
3.3.2 Non-Vacant Sites Appendix
B: Sites Inventory
(b)(3) If a site subject to this paragraph is
owned by the city or county, the description
shall also include whether there are any
plans to dispose of the property during the
planning period and how the city or county
will comply with Article 8 (commencing with
Section 54220) of Chapter 5 of Part 1 of
Division 2 of Title 5.
Not required and not utilized.
(b)(4) A general description of any
environmental constraints to the
development of housing within the
jurisdiction, the documentation for which
has been made available to the jurisdiction.
This information need not be identified on a
site-specific basis.
3.8 Environmental Considerations
4.4.3 Environmental and Infrastructure
Constraints
(b)(5)(A) A description of existing or planned
water, sewer, and other dry utilities supply,
including the availability and access to
distribution facilities.
3.7 Infrastructure Considerations
4.4.3 Environmental and Infrastructure
Constraints
B: Sites Inventory
(b)(5)(B) Parcels included in the inventory
must have sufficient water, sewer, and dry
utilities supply available and accessible to
support housing development or be
included in an existing general plan program
or other mandatory program or plan,
including a program or plan of a public or
private entity providing water or sewer
service, to secure sufficient water, sewer,
and dry utilities supply to support housing
3.7 Infrastructure Considerations
4.4.3 Environmental and Infrastructure
Constraints
B: Sites Inventory
10.a
Packet Pg. 404 Attachment: Exhibit A Cotati Housing Element Statutory Requirements Checklist (2023-03-21) (Housing Element CC Resolution) Cotati City Council Resolution xx Exhibit A
development. This paragraph does not
impose any additional duty on the city or
county to construct, finance, or otherwise
provide water, sewer, or dry utilities to
parcels included in the inventory.
(b)(6) Sites identified as available for housing
for above moderate-income households in
areas not served by public sewer systems.
This information need not be identified on a
site-specific basis.
All housing sites identified for all income
levels have access to public sewer systems.
Not applicable.
(b)(7) A map that shows the location of the
sites included in the inventory, such as the
land use map from the jurisdiction’s general
plan, for reference purposes only.
3.3 Realistic Capacity of Sites Zoned for
Housing
Figure 15
(c) Based on the information provided in
subdivision (b), a city or county shall
determine whether each site in the
inventory can accommodate the
development of some portion of its share of
the regional housing need by income level
during the planning period, as determined
pursuant to Section 65584. The inventory
shall specify for each site the number of
units that can realistically be accommodated
on that site and whether the site is adequate
to accommodate lower income housing,
moderate-income housing, or above
moderate-income housing.
3.3.3 Sites Suitability Analysis
(c) A nonvacant site identified pursuant to
paragraph (3) or (4) of subdivision (a) in a
prior housing element and a vacant site that
has been included in two or more
consecutive planning periods that was not
approved to develop a portion of the
locality’s housing need shall not be deemed
adequate to accommodate a portion of the
housing need for lower income households
that must be accommodated in the current
housing element planning period unless the
site is zoned at residential densities
consistent with paragraph (3) of this
3.3.3 Sites Suitability Analysis
3.4 Programs to Assist in the Development
of Housing
2.2 Housing Strategy
Program 3-1: Sites Used in Multiple Planning
Periods
10.a
Packet Pg. 405 Attachment: Exhibit A Cotati Housing Element Statutory Requirements Checklist (2023-03-21) (Housing Element CC Resolution) Cotati City Council Resolution xx Exhibit A
subdivision and the site is subject to a
program in the housing element requiring
rezoning within three years of the beginning
of the planning period to allow residential
use by right for housing developments in
which at least 20 percent of the units are
affordable to lower income households. An
unincorporated area in a nonmetropolitan
county pursuant to clause (ii) of
subparagraph (B) of paragraph (3) shall not
be subject to the requirements of this
subdivision to allow residential use by right.
(c) Notwithstanding the foregoing, for a local
government that fails to adopt a housing
element that the department has found to
be in substantial compliance with state law
within 120 days of the statutory deadline in
Section 65588 for adoption of the housing
element, rezoning pursuant to this
subdivision shall be completed no later than
one year from the statutory deadline in
Section 65588 for adoption of the housing
element.
2.2 Housing Strategy
(c) The analysis shall determine whether the
inventory can provide for a variety of types
of housing, including multifamily rental
housing,
4.2.3 Zoning for a Variety of Housing Types
(c) factory-built housing, mobilehomes, 4.2.3 Zoning for a Variety of Housing Types (c) housing for agricultural employees,
supportive housing,
4.2.3 Zoning for a Variety of Housing Types
(c) single-room occupancy units, 4.2.3 Zoning for a Variety of Housing Types (c) emergency shelters, and 4.2.3 Zoning for a Variety of Housing Types (c) transitional housing 4.2.3 Zoning for a Variety of Housing Types (c) and whether the inventory affirmatively
furthers fair housing .
3.6 Fair Housing Considerations
4.5.7 Housing Sites and AFFH Considerations
(c) The city or county shall determine the
number of housing units that can be
accommodated on each site as follows:
3.3 Realistic Capacity of Sites Zoned for
Housing
(c)(1) If local law or regulations require the
development of a site at a minimum density,
the department shall accept the planning
3.3 Realistic Capacity of Sites Zoned for
Housing
10.a
Packet Pg. 406 Attachment: Exhibit A Cotati Housing Element Statutory Requirements Checklist (2023-03-21) (Housing Element CC Resolution) Cotati City Council Resolution xx Exhibit A
agency’s calculation of the total housing unit
capacity on that site based on the
established minimum density. If the city or
county does not adopt a law or regulation
requiring the development of a site at a
minimum density, then it shall demonstrate
how the number of units determined for
that site pursuant to this subdivision will be
accommodated.
(c)(2) The number of units calculated
pursuant to paragraph (1) shall be adjusted
as necessary, based on the land use controls
and site improvements requirement
identified in paragraph (5) of subdivision (a)
of Section 65583,
3.3 Realistic Capacity of Sites Zoned for
Housing
4.4.2 Potential Governmental Constraints
(c)(2) the realistic development capacity for
the site,
3.3 Realistic Capacity of Sites Zoned for
Housing
3.5 Development Trends and Realistic
Capacity Analysis
(c)(2) typical densities of existing or
approved residential developments at a
similar affordability level in that jurisdiction,
3.3 Realistic Capacity of Sites Zoned for
Housing
3.5 Development Trends and Realistic
Capacity Analysis
4.4.2 Potential Governmental Constraints
(c)(2) and on the current or planned
availability and accessibility of sufficient
water, sewer, and dry utilities.
3.3 Realistic Capacity of Sites Zoned for
Housing
3.7 Infrastructure Considerations
(c)(2)(A) A site smaller than half an acre shall
not be deemed adequate to accommodate
lower income housing need unless the
locality can demonstrate that sites of
equivalent size were successfully developed
during the prior planning period for an
equivalent number of lower income housing
units as projected for the site or unless the
locality provides other evidence to the
department that the site is adequate to
accommodate lower income housing.
3.3 Realistic Capacity of Sites Zoned for
Housing
10.a
Packet Pg. 407 Attachment: Exhibit A Cotati Housing Element Statutory Requirements Checklist (2023-03-21) (Housing Element CC Resolution) Cotati City Council Resolution xx Exhibit A
(c)(2)(B) A site larger than 10 acres shall not
be deemed adequate to accommodate
lower income housing need unless the
locality can demonstrate that sites of
equivalent size were successfully developed
during the prior planning period for an
equivalent number of lower income housing
units as projected for the site or unless the
locality provides other evidence to the
department that the site can be developed
as lower income housing.
3.3 Realistic Capacity of Sites Zoned for
Housing
3.5 Development Trends and Realistic
Capacity Analysis
(c)(2)(B) For purposes of this subparagraph,
“site” means that portion of a parcel or
parcels designated to accommodate lower
income housing needs pursuant to this
subdivision.
3.3 Realistic Capacity of Sites Zoned for
Housing
(c)(2)(C) A site may be presumed to be
realistic for development to accommodate
lower income housing need if, at the time of
the adoption of the housing element, a
development affordable to lower income
households has been proposed and
approved for development on the site.
3.3 Realistic Capacity of Sites Zoned for
Housing
(c)(3) For the number of units calculated to
accommodate its share of the regional
housing need for lower income households
pursuant to paragraph (2), a city or county
shall do either of the following:
3.3 Realistic Capacity of Sites Zoned for
Housing
(c)(3)(A) Provide an analysis demonstrating
how the adopted densities accommodate
this need. The analysis shall include, but is
not limited to, factors such as market
demand, financial feasibility, or information
based on development project experience
within a zone or zones that provide housing
for lower income households.
3.3 Realistic Capacity of Sites Zoned for
Housing
(c)(3)(B) The following densities shall be
deemed appropriate to accommodate
housing for lower income households:
(i) For an incorporated city within a
nonmetropolitan county and for a
3.3 Realistic Capacity of Sites Zoned for
Housing
10.a
Packet Pg. 408 Attachment: Exhibit A Cotati Housing Element Statutory Requirements Checklist (2023-03-21) (Housing Element CC Resolution) Cotati City Council Resolution xx Exhibit A
nonmetropolitan county that has a
micropolitan area: sites allowing at least 15
units per acre.
(ii) For an unincorporated area in a
nonmetropolitan county not included in
clause (i): sites allowing at least 10 units per
acre.
(iii) For a suburban jurisdiction: sites
allowing at least 20 units per acre.
(iv) For a jurisdiction in a metropolitan
county: sites allowing at least 30 units per
acre.
(4)(A) For a metropolitan jurisdiction: 3.3 Realistic Capacity of Sites Zoned for Housing
(4)(A)(i) At least 25 percent of the
jurisdiction’s share of the regional housing
need for moderate-income housing shall be
allocated to sites with zoning that allows at
least 4 units of housing, but not more than
100 units per acre of housing.
3.3 Realistic Capacity of Sites Zoned for
Housing
(4)(A)(ii) At least 25 percent of the
jurisdiction’s share of the regional housing
need for above moderate-income housing
shall be allocated to sites with zoning that
allows at least 4 units of housing.
3.3 Realistic Capacity of Sites Zoned for
Housing
(B) The allocation of moderate-income and
above moderate-income housing to sites
pursuant to this paragraph shall not be a
basis for the jurisdiction to do either of the
following:
(i) Deny a project that does not comply with
the allocation.
(ii) Impose a price minimum, price
maximum, price control, or any other
exaction or condition of approval in lieu
thereof. This clause does not prohibit a
jurisdiction from imposing any price
minimum, price maximum, price control,
exaction, or condition in lieu thereof,
pursuant to any other law.
3.3 Realistic Capacity of Sites Zoned for
Housing
10.a
Packet Pg. 409 Attachment: Exhibit A Cotati Housing Element Statutory Requirements Checklist (2023-03-21) (Housing Element CC Resolution) Cotati City Council Resolution xx Exhibit A
(iii) The provisions of this subparagraph do
not constitute a change in, but are
declaratory of, existing law with regard to
the allocation of sites pursuant to this
section.
(C) This paragraph does not apply to an
unincorporated area.
No response needed.
(D) For purposes of this paragraph: No response needed. (i) “Housing development project” has the
same meaning as defined in paragraph (2) of
subdivision (h) of Section 65589.5.
Definition; no response needed.
(ii) “Unit of housing” does not include an
accessory dwelling unit or junior accessory
dwelling unit that could be approved
pursuant to Section 65852.2 or Section
65852.22 or through a local ordinance or
other provision implementing either of
those sections. This paragraph shall not limit
the ability of a local government to count
the actual production of accessory dwelling
units or junior accessory dwelling units in an
annual progress report submitted pursuant
to Section 65400 or other progress report as
determined by the department.
No response needed.
(E) Nothing in this subdivision shall preclude
the subdivision of a parcel, provided that the
subdivision is subject to the Subdivision Map
Act (Division 2 (commencing with Section
66410)) or any other applicable law
authorizing the subdivision of land.
No response needed.
(d) For purposes of this section, a
metropolitan county, nonmetropolitan
county, and nonmetropolitan county with a
micropolitan area shall be as determined by
the United States Census Bureau. A
nonmetropolitan county with a micropolitan
area includes the following counties: Del
Norte, Humboldt, Lake, Mendocino, Nevada,
Tehama, and Tuolumne and other counties
as may be determined by the United States
Census Bureau to be nonmetropolitan
No response needed.
10.a
Packet Pg. 410 Attachment: Exhibit A Cotati Housing Element Statutory Requirements Checklist (2023-03-21) (Housing Element CC Resolution) Cotati City Council Resolution xx Exhibit A
counties with micropolitan areas in the
future.
(e) (1) Except as provided in paragraph (2), a
jurisdiction shall be considered suburban if
the jurisdiction does not meet the
requirements of clauses (i) and (ii) of
subparagraph (B) of paragraph (3) of
subdivision (c) and is located in a
Metropolitan Statistical Area (MSA) of less
than 2,000,000 in population, unless that
jurisdiction’s population is greater than
100,000, in which case it shall be considered
metropolitan. A county, not including the
City and County of San Francisco, shall be
considered suburban unless the county is in
an MSA of 2,000,000 or greater in
population in which case the county shall be
considered metropolitan.
No response needed.
(2)(A)(i) Notwithstanding paragraph (1), if a
county that is in the San Francisco-OaklandFremont California MSA has a population of less than 400,000, that county shall be
considered suburban. If this county includes
an incorporated city that has a population of
less than 100,000, this city shall also be
considered suburban. This paragraph shall
apply to a housing element revision cycle, as
described in subparagraph (A) of paragraph
(3) of subdivision (e) of Section 65588, that
is in effect from July 1, 2014, to December
31, 2028, inclusive.
No response needed.
(2)(A)(ii) A county subject to this
subparagraph shall utilize the sum existing in
the county’s housing trust fund as of June
30, 2013, for the development and
preservation of housing affordable to lowand very low income households.
No response needed.
(2)(B) A jurisdiction that is classified as
suburban pursuant to this paragraph shall
report to the Assembly Committee on
Housing and Community Development, the
No response needed.
10.a
Packet Pg. 411 Attachment: Exhibit A Cotati Housing Element Statutory Requirements Checklist (2023-03-21) (Housing Element CC Resolution) Cotati City Council Resolution xx Exhibit A
Senate Committee on Housing, and the
Department of Housing and Community
Development regarding its progress in
developing low- and very low income
housing consistent with the requirements of
Section 65400. The report shall be provided
three times: once, on or before December
31, 2019, which report shall address the
initial four years of the housing element
cycle, a second time, on or before December
31, 2023, which report shall address the
subsequent four years of the housing
element cycle, and a third time, on or before
December 31, 2027, which report shall
address the subsequent four years of the
housing element cycle and the cycle as a
whole. The reports shall be provided
consistent with the requirements of Section
9795.
(f) A jurisdiction shall be considered
metropolitan if the jurisdiction does not
meet the requirements for “suburban area”
above and is located in an MSA of 2,000,000
or greater in population, unless that
jurisdiction’s population is less than 25,000
in which case it shall be considered
suburban.
(g)(1) For sites described in paragraph (3) of
subdivision (b) [non-vacant sites], the city or
county shall specify the additional
development potential for each site within
the planning period and shall provide an
explanation of the methodology used to
determine the development potential.
3.3.2 Non-Vacant Sites
3.3.3 Sites Suitability Analysis
(g)(1) The methodology shall consider
factors including the extent to which existing
uses may constitute an impediment to
additional residential development,
3.3.2 Non-Vacant Sites
3.3.3 Sites Suitability Analysis
10.a
Packet Pg. 412 Attachment: Exhibit A Cotati Housing Element Statutory Requirements Checklist (2023-03-21) (Housing Element CC Resolution) Cotati City Council Resolution xx Exhibit A
(g)(1) the city’s or county’s past experience
with converting existing uses to higher
density residential development,
3.3.2 Non-Vacant Sites
3.3.3 Sites Suitability Analysis
3.5 Development Trends and Realistic
Capacity Analysis
(g)(1) the current market demand for the
existing use,
3.3.2 Non-Vacant Sites
3.3.3 Sites Suitability Analysis
(g)(1) an analysis of any existing leases or
other contracts that would perpetuate the
existing use or prevent redevelopment of
the site for additional residential
development,
3.3.2 Non-Vacant Sites
3.3.3 Sites Suitability Analysis
(g)(1) development trends, 3.3.2 Non-Vacant Sites
3.3.3 Sites Suitability Analysis
3.5 Development Trends and Realistic
Capacity Analysis
(g)(1) market conditions, 3.3.2 Non-Vacant Sites
3.3.3 Sites Suitability Analysis
(g)(1) and regulatory or other incentives or
standards to encourage additional
residential development on these sites.
3.3.2 Non-Vacant Sites
3.3.3 Sites Suitability Analysis
4.3 Local Housing Programs & Resources
(g)(2) In addition to the analysis required in
paragraph (1), when a city or county is
relying on nonvacant sites described in
paragraph (3) of subdivision (b) to
accommodate 50 percent or more of its
housing need for lower income households,
the methodology used to determine
additional development potential shall
demonstrate that the existing use identified
pursuant to paragraph (3) of subdivision (b)
does not constitute an impediment to
additional residential development during
the period covered by the housing element.
An existing use shall be presumed to impede
additional residential development, absent
findings based on substantial evidence that
the use is likely to be discontinued during
the planning period.
Not relevant.
(g)(3) Notwithstanding any other law, and in
addition to the requirements in paragraphs
(1) and (2), sites that currently have
3.3.2 Non-Vacant Sites
3.3.3 Sites Suitability Analysis
2.2 Housing Strategy
10.a
Packet Pg. 413 Attachment: Exhibit A Cotati Housing Element Statutory Requirements Checklist (2023-03-21) (Housing Element CC Resolution) Cotati City Council Resolution xx Exhibit A
residential uses, or within the past five years
have had residential uses that have been
vacated or demolished, that are or were
subject to a recorded covenant, ordinance,
or law that restricts rents to levels affordable
to persons and families of low or very low
income, subject to any other form of rent or
price control through a public entity’s valid
exercise of its police power, or occupied by
low or very low income households, shall be
subject to a policy requiring the replacement
of all those units affordable to the same or
lower income level as a condition of any
development on the site. Replacement
requirements shall be consistent with those
set forth in paragraph (3) of subdivision (c)
of Section 65915.
Program 4-1: Anti-Displacement Actions
(h) The program required by subparagraph
(A) of paragraph (1) of subdivision (c) of
Section 65583 shall accommodate 100
percent of the need for housing for very low
and low-income households allocated
pursuant to Section 65584 for which site
capacity has not been identified in the
inventory of sites pursuant to paragraph (3)
of subdivision (a) on sites that shall be zoned
to permit owner-occupied and rental
multifamily residential use by right for
developments in which at least 20 percent of
the units are affordable to lower income
households during the planning period.
3.3 Realistic Capacity of Sites Zoned for
Housing
3.4 Programs to Assist in the Development
Of Housing
(h) These sites shall be zoned with minimum
density and development standards that
permit at least
3.4 Programs to Assist in the Development
Of Housing
(h) 16 units per site at a density of at least
16 units per acre in jurisdictions described in
clause (i) of subparagraph (B) of paragraph
(3) of subdivision (c),
3.4 Programs to Assist in the Development
Of Housing
(h) shall be at least 20 units per acre in
jurisdictions described in clauses (iii) and (iv)
3.4 Programs to Assist in the Development
Of Housing
10.a
Packet Pg. 414 Attachment: Exhibit A Cotati Housing Element Statutory Requirements Checklist (2023-03-21) (Housing Element CC Resolution) Cotati City Council Resolution xx Exhibit A
of subparagraph (B) of paragraph (3) of
subdivision (c)
(h) and shall meet the standards set forth in
subparagraph (B) of paragraph (5) of
subdivision (b).
3.4 Programs to Assist in the Development
Of Housing
(h) At least 50 percent of the very low and
low-income housing need shall be
accommodated on sites designated for
residential use and for which nonresidential
uses or mixed uses are not permitted, except
that a city or county may accommodate all
of the very low and low-income housing
need on sites designated for mixed uses if
those sites allow 100 percent residential use
and require that residential use occupy 50
percent of the total floor area of a mixed-use
project.
3.3 Realistic Capacity of Sites Zoned for
Housing
(i) For purposes of this section and Section
65583, the phrase “use by right” shall mean
that the local government’s review of the
owner-occupied or multifamily residential
use may not require a conditional use
permit, planned unit development permit,
or other discretionary local government
review or approval that would constitute a
“project” for purposes of Division 13
(commencing with Section 21000) of the
Public Resources Code. Any subdivision of
the sites shall be subject to all laws,
including, but not limited to, the local
government ordinance implementing the
Subdivision Map Act.
3.4 Programs to Assist in the Development
Of Housing
(i) A local ordinance may provide that “use
by right” does not exempt the use from
design review. However, that design review
shall not constitute a “project” for purposes
of Division 13 (commencing with Section
21000) of the Public Resources Code.
No response needed.
(i) Use by right for all rental multifamily
residential housing shall be provided in
4.2.3 Zoning for a Variety of Housing Types
10.a
Packet Pg. 415 Attachment: Exhibit A Cotati Housing Element Statutory Requirements Checklist (2023-03-21) (Housing Element CC Resolution) Cotati City Council Resolution xx Exhibit A
accordance with subdivision (f) of Section
65589.5.
(j) Notwithstanding any other provision of
this section, within one-half mile of a
Sonoma-Marin Area Rail Transit station,
housing density requirements in place on
June 30, 2014, shall apply.
No response necessary.
10.a
Packet Pg. 416 Attachment: Exhibit A Cotati Housing Element Statutory Requirements Checklist (2023-03-21) (Housing Element CC Resolution)
10.b
Packet Pg. 417 Attachment: Exhibit B1 - Cotati Adoption Draft Housing Element (2023-03-20) (Housing Element CC Resolution)
CONTENTS
SECTION I: INTRODUCTION & SUMMARY ........................................................... 1
1.1 INTRODUCTION .............................................................................................. 1
1.2 DEFINITION AND PURPOSE ............................................................................ 1
1.3 CONSISTENCY WITH STATE LAWS AND GENERAL PLAN .............................. 1
1.4 PUBLIC PARTICIPATION ................................................................................. 2
1.5 ORGANIZATION OF THE HOUSING ELEMENT ............................................... 2
1.6 DEFINITION OF TERMS ................................................................................... 3
1.7 DATA SOURCES .............................................................................................. 4
1.8 COMMUNITY PROFILE .................................................................................... 6
1.9 CHANGING HOUSING NEEDS AND DEMOGRAPHICS.................................... 7
1.9.1 Population Characteristics and Trends ................................................................... 7 Age Composition ............................................................................................................ 8 Race and Ethnicity ........................................................................................................... 8 Employment and Income ............................................................................................... 9
1.9.2 Household Incomes and Housing Affordability .................................................. 10
1.9.3 Special Needs Populations .................................................................................... 12 Homeless ........................................................................................................................ 12 Disabled .......................................................................................................................... 12 Elderly ............................................................................................................................. 13 Large Households ......................................................................................................... 14 Female-Headed Households ....................................................................................... 15 Farmworkers .................................................................................................................. 15
1.10 CHARACTERISTICS OF HOUSING STOCK ................................................... 16 Type ................................................................................................................................. 16 Tenure ............................................................................................................................. 16 Age and Condition ........................................................................................................ 17 Overcrowding ................................................................................................................ 18 Vacancy ........................................................................................................................... 19 Prices ............................................................................................................................... 20 Preservation of Assisted Units at Risk of Conversion ................................................ 21
1.11 SUMMARY OF CONSTRAINTS .................................................................... 21
1.12 SUMMARY OF FAIR HOUSING ANALYSIS .................................................. 22 Ensuring Equitable Zoning Practices .......................................................................... 23
1.13 REGIONAL HOUSING NEEDS ALLOCATION ............................................... 24
1.14 2015 COTATI HOUSING ELEMENT REVIEW ............................................... 25
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Packet Pg. 418 Attachment: Exhibit B1 - Cotati Adoption Draft Housing Element (2023-03-20) (Housing Element CC Resolution) Progress Implementing Programs .............................................................................. 25 Lessons Learned ............................................................................................................ 26
1.15 PROGRAM CHANGES IN 2023 HOUSING ELEMENT .................................. 26 SECTION II: HOUSING STRATEGY ....................................................................... 27
2.1 HOUSING STRATEGY .................................................................................... 27 Goal H-1: Resilient & Safe Housing ................................................................................. 28 Program 1-1 Housing Rehabilitation ........................................................................... 29 Program 1-2: Home Ownership .................................................................................. 30 Program 1-3: Non-Profit and Agency Coordination – Existing Housing Needs .... 30 Program 1-4: Capital Improvement Program ............................................................ 31 Program 1-5: Preservation of Affordable Housing .................................................... 31 Program 1-6: Preservation of Mobile Home Parks .................................................... 32 Program 1-7: Essential Housing Bond Financing Program...................................... 33 Program 1-8: Residential Building Decarbonization ................................................ 33 Goal H-2: Housing Production ........................................................................................ 34 Program 2-1: Adequate Housing Sites ....................................................................... 36 Program 2-2: Streamlining Housing Development .................................................. 37 Program 2-3: Accessory Dwelling Units (ADUs) ........................................................ 38 Program 2-4: Cottage Housing ................................................................................... 39 Program 2-5: Continuum of Care and Crisis Response ............................................ 40 Program 2-6: Santero Way Rezoning to Affirmatively Further Fair Housing ......... 40 Program 2-7: Support Development of Proposed Projects ..................................... 40 Goal H-3: Affordable, Attainable & Accessible Housing ............................................. 41 Program 3-1: Zoning for a Variety of Housing Types................................................ 42 Program 3-2: Funding for Affordable and Special Needs Housing........................ 43 Program 3-3: Maintain Adequate Staff ....................................................................... 44 Program 3-4: Housing Choice Vouchers .................................................................... 44 Program 3-5: Review Processing Fees ........................................................................ 45 Program 3-6: Prohousing Designation ....................................................................... 45 Goal H-4: Affirmatively Furthering Fair Housing ........................................................... 46 Program 4-1: Anti-Displacement Actions ................................................................... 46 Program 4-2: Housing Discrimination Complaints ................................................... 47 Program 4-3: Nondiscrimination & Fair Housing Information ................................. 48 Program 4-4: Reasonable Accommodation .............................................................. 49 Program 4-5: Limit Code Enforcement Activities ...................................................... 49 Program 4-6: Culturally Appropriate Facilitation and Involvement ........................ 49 Goal H-5: Community Engagement ............................................................................... 50 Program 5-1: Annual Report ........................................................................................ 50
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Packet Pg. 419 Attachment: Exhibit B1 - Cotati Adoption Draft Housing Element (2023-03-20) (Housing Element CC Resolution) Program 5-2: Workshops and Public Hearings ......................................................... 50 Program 5-3: Stakeholder Engagement .................................................................... 51 Program 5-4: Accessible & Transparent Information................................................ 51
2.2 QUANTIFIED OBJECTIVES ............................................................................ 52 SECTION III: HOUSING SITES .............................................................................. 53
3.1 CONTEXT ...................................................................................................... 53
3.2 PROJECTED DEVELOPMENT AND RHNA CREDIT ........................................ 54
3.2.1 ADUs and JADUs ................................................................................................. 54
3.2.2 Planned, Approved, and Pending Projects ...................................................... 55 Cotati Station .................................................................................................................. 57 Cotati Village .................................................................................................................. 57 East Cotati Cottage Housing ........................................................................................ 58 La Plaza View .................................................................................................................. 58 Lasker Lane ..................................................................................................................... 58 Pink Viking ...................................................................................................................... 58 Redwood Row ................................................................................................................ 59 Red’s Residential ............................................................................................................ 59
3.3 REALISTIC CAPACITY OF SITES ZONED FOR HOUSING ............................... 59
3.3.1 Vacant Sites........................................................................................................... 61
3.3.2 Non-Vacant Sites .................................................................................................. 62
3.3.3 Sites Suitability Analysis ...................................................................................... 63
3.4 PROGRAMS TO ASSIST IN THE DEVELOPMENT OF HOUSING .................... 66 Program 1-7: Essential Bond Financing Program ..................................................... 66 Program 2-1: Adequate Housing Sites ....................................................................... 66 Program 2-3: Accessory Dwelling Units ..................................................................... 66 Program 2-4: Cottage Housing ................................................................................... 66 Program 2-6: Santero Way Rezoning .......................................................................... 66 Program 2-7: Supporting Development on Inventory Sites .................................... 66 Program 3-1: Sites Used in Multiple Planning Periods ............................................. 67 Program 4-1: Anti-Displacement Actions ................................................................... 67
3.5 DEVELOPMENT TRENDS AND REALISTIC CAPACITY ANALYSIS .................. 67
3.6 FAIR HOUSING CONSIDERATIONS............................................................... 68
3.6.1 Improved Conditions .......................................................................................... 69
3.6.2 Exacerbated Conditions ..................................................................................... 69
3.7 INFRASTRUCTURE CONSIDERATIONS ......................................................... 69
3.7.1 Water ..................................................................................................................... 70
3.7.2 Sewer ..................................................................................................................... 70
3.7.3 Other Utilities ....................................................................................................... 70
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Packet Pg. 420 Attachment: Exhibit B1 - Cotati Adoption Draft Housing Element (2023-03-20) (Housing Element CC Resolution)
3.8 ENVIRONMENTAL CONSIDERATIONS ......................................................... 70
3.8.1 Fire ......................................................................................................................... 71
3.8.2 Seismic Hazards ................................................................................................... 71
3.8.3 Flood ..................................................................................................................... 73
3.8.4 Special Status Species ......................................................................................... 74
3.9 CONCLUSION ................................................................................................ 76
FIGURES
Figure 1: City of Cotati Location within Sonoma County ................................................................ 7 Figure 2: Population by Age, 2000-2019 .......................................................................................... 8 Figure 3: Resident Employment by Industry ................................................................................. 10 Figure 4: Household Income Level by Household Size ............................................................... 11 Figure 5: Cost Burden by Income Level ......................................................................................... 12 Figure 6: Disability by Type ............................................................................................................. 13 Figure 7: Households by Household Size ...................................................................................... 15 Figure 8: Housing Type Trends ....................................................................................................... 16 Figure 9: Housing Tenure by Age ................................................................................................... 17 Figure 10: Housing Units by Year Structure Built .......................................................................... 18 Figure 11: Overcrowding Severity .................................................................................................. 19 Figure 12: Occupancy Status........................................................................................................... 20 Figure 13: Median Home Values, 2001-2021 ................................................................................ 21 Figure 14: Location of Planned, Approved, and Pending Projects ............................................ 57 Figure 15: Location of Housing Opportunity Sites ....................................................................... 60 Figure 16: Housing Opportunity Sites by Opportunity Area ....................................................... 69 Figure 17: Fire Hazard Severity Zones ........................................................................................... 71 Figure 18: Earthquake Hazard Zones ............................................................................................. 72 Figure 19: Deep-Seated Landslide Susceptibility ......................................................................... 72 Figure 20: Flood Hazard Zones ....................................................................................................... 73 Figure 21: California Tiger Salamander Range ............................................................................. 75 TABLES
Table 1: Comparative Trends in Racial and Ethnic Composition, 2010-2020 .............................. 8 Table 2: Cotati Regional Housing Needs Allocation (RHNA), 2023-2031 ................................. 24 Table 3: Progress in Achieving 2015 Quantified Objectives by Income.................................... 26 Table 4: Summary of Quantified Objectives, City of Cotati, 2023-2031 .................................... 52 Table 5: Cotati Regional Housing Needs Allocation (RHNA), 2023-2031 ................................. 53 Table 6: ADU Permits Issued or Completed by Year in Cotati .................................................... 55 Table 7: Assumed Affordability for 6th Cycle ADUs ..................................................................... 55 Table 8: Planned, Approved, and Pending Projects for RHNA Credit ....................................... 56 Table 9: RHNA and Site Capacity .................................................................................................... 60 Table 10: Capacity of Sites Allowing Residential Development ................................................. 61 Table 11: Development Trends ...................................................................................................... 67
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Packet Pg. 421 Attachment: Exhibit B1 - Cotati Adoption Draft Housing Element (2023-03-20) (Housing Element CC Resolution) 1 SECTION I: INTRODUCTION & SUMMARY
1.1 INTRODUCTION
This chapter of the Cotati General Plan presents goals, policies, programs, and supporting information related to the provision of housing for existing and future residents of the City. The purpose of the Housing Element is twofold:
Present specific policies and actions for housing development to meet Cotati’s specific, identified housing needs; and
Meet regional standards and achieve State certification, pursuant to statutory requirements.
1.2 DEFINITION AND PURPOSE
The Housing Element of the General Plan is a detailed statement of the housing goals, policies, programs, and quantified objectives for the City. The Element is based on a comprehensive technical assessment of existing housing policies and programs; current and projected housing needs, especially related to low-income households and special needs populations; an analysis of market, environmental, governmental, and other factors that constrain housing production; an assessment of ways that the City can affirmatively further fair housing for its residents; an inventory of sites available for housing construction; and an assessment of new programs and policies that can enhance housing production in the City.
The purpose of the Housing Element is to guide decision-making by elected and appointed officials. Specifically, the Housing Element sets forth how the City will address the need for housing, especially by low- and moderate-income families, and special needs families and individuals. The Housing Element also provides housing-related data and information to the public.
1.3 CONSISTENCY WITH STATE LAWS AND GENERAL PLAN
State law requires that the General Plan include an integrated, consistent set of goals and policies. The City of Cotati’s General Plan contains elements relating to land use, circulation, housing, community wellness, noise, conservation, open space, economic development, and safety. The 2023 Housing Element provides goals, policies, and implementation measures that are consistent with all other elements of the General Plan; amendments to the City’s Land Use Element are planned for immediately after adoption of the Housing Element. As the General Plan is amended in the future, the City will ensure the Housing Element remains consistent with the General Plan.
New State law requires that the Safety Element be updated to address climate adaptation upon revision of the Housing Element. The City will ensure compliance with this requirement by updating and adopting its updated Safety Element to follow the 2023 Housing Element. The City will provide a copy of the Housing Element to the water and sewer service providers and has coordinated with these agencies regarding the State-mandated water and sewer service
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Packet Pg. 422 Attachment: Exhibit B1 - Cotati Adoption Draft Housing Element (2023-03-20) (Housing Element CC Resolution) 2 priority for housing projects that will help Cotati in meeting its regional housing need for lowerincome households (Government Code Section 65589.7).
Multiple statewide bills have been passed to address the inequitable distribution of pollution and associated health effects in low-income communities and communities of color. SB 535 requires the California Environmental Protection Agency (CalEPA) to define disadvantaged communities and SB 1000 requires local governments to identify those disadvantaged communities in their jurisdiction and address environmental justice in their general plans accordingly. As defined by SB 535, Cotati does not currently have any disadvantaged communities. However, Cotati contains a Census tract designated as Low Resource in the 2022 TCAC Opportunity Areas and these neighborhoods will be analyzed and discussed as part of the Assessment of Fair Housing (Section 4.5).
1.4 PUBLIC PARTICIPATION
The public participation requirement of Housing Element law presents an opportunity to engage constituents in defining housing issues, and in creating solutions that both meet the needs of the community and the requirements of state law. It is the cornerstone of the process.
The 6th Cycle Housing Element Update was conducted during the COVID-19 global pandemic and outreach had to be adjusted to allow and encourage meaningful public participation and input without requiring community members to meet or gather in-person. Staff and consultants made use of multiple in-person and digital platforms to facilitate public input. In-person contact included door-to-door canvassing and tabling at events including the Halloween Carnival, Holiday Shop-and Stroll and Cotati Farmers Market. All public surveys and community events were presented bilingually to ensure that all residents had an opportunity to be heard.
As outreach continued, there was evidence of concern that State requirements conflict with community values, creating conflict and tension. These issues were addressed by staff and consultants.
1.5 ORGANIZATION OF THE HOUSING ELEMENT
The Housing Element is organized into four main sections:
Section 1 introduces the overall Housing Element update effort, a summary of housing needs and constraints, a Fair Housing summary, and a review of the effectiveness of the 2015 Housing Element and the City’s progress in its implementation.
Section 2 sets forth the City’s Housing Strategy, which is comprised of the Goals, Policies, and Programs that it intends to implement over the next 8-year planning cycle. The City’s Quantified Objectives are also included in Section 2. Section 3 presents a detailed Housing Site Inventory, including a discussion of the availability of services, and compares this inventory to the City’s projected housing needs.
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Packet Pg. 423 Attachment: Exhibit B1 - Cotati Adoption Draft Housing Element (2023-03-20) (Housing Element CC Resolution) 3 Section 4, the Technical Background Report, provides statutorily required data including an assessment of housing needs & programs, an analysis of nongovernmental and governmental constraints to affordable housing provision, a discussion of special needs populations, and an assessment of fair housing. Precertified housing and demographic data provided by the Association of Bay Area Governments (ABAG/MTC) is included here.
Given the detail and lengthy analysis in developing the Housing Element, the Technical Background Report also contains the following appendices:
Appendix A: 5th Cycle Housing Element Implementation Progress Appendix B: Sites Inventory
Appendix C: Community Engagement & Input
Appendix D: Community Survey Results
Appendix E: ABAG/MTC Housing Needs Data Packet
Appendix F: ABAG/MTC Segregation Report
1.6 DEFINITION OF TERMS
Throughout the Housing Element, a variety of technical terms related to income levels are used in describing and quantifying conditions and objectives. The definitions of these terms follow:
Above Moderate-Income Households – Households earning over 120% of the County AMI, adjusted for household size.
Acutely Low-Income – Households earning not more than 15% of the County AMI, adjusted for household size.
Affordable Housing – Housing that costs no more than 30% of a low-, very low-, or extremely low-income household’s gross monthly income. For rental housing, the residents may pay up to 30% of gross income on rent plus tenant-paid utilities. For homeownership, the residents may pay up to 30% on the combination of mortgage payments, taxes, insurance, and homeowners' dues. Area Median Income (AMI) – The income figure representing the middle point of the County household income. Fifty percent of households earn more than or equal to this figure and 50% earn less than or equal to this figure. The AMI varies according to the size of the household. For the year 2022, the AMI for a fourperson household in County of Sonoma was $112,800. Extremely Low-Income Households (ELI) – Households earning not more than 30% of the County AMI, adjusted for household size.
Federal Poverty Threshold – issued by the Census Bureau and varies by family size, number of children, elderly. There is no geographic variation. For 2021, the poverty threshold for a single person under age 65 was 14,097, for a three-family
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Packet Pg. 424 Attachment: Exhibit B1 - Cotati Adoption Draft Housing Element (2023-03-20) (Housing Element CC Resolution) 4 unit with two children, it was $21,831. (Note: this differs from the Federal Poverty Guidelines issued by Health & Human Services).
Low-Income Households – Households earning between 51-80% of the County AMI, adjusted for household size.
Missing Middle Housing – a range of house-scale buildings with multiple units compatible in scale and form with detached single-family homes. (Source:
MissingMiddleHousing.com).
Moderate-Income Households – Households earning 81-120% of the County AMI, adjusted for household size.
Plexes – a single structure that contains more than one dwelling unit. The units share common walls, and each typically has an outside entrance. Examples include duplex, triplex, quadruplex, etc.
Very Low-Income Households (VLI) – Households earning between 31-50% of the County AMI, adjusted for household size.
1.7 DATA SOURCES
The 2021 Housing Element Update makes full use of the pre-certified data package provided by the Association of Bay Area Governments (ABAG), which is contained in its entirety in the Section 4 Technical Background Report. In addition to the ABAG dataset, the following sources of data were used to help identify historic patterns of segregation, assess constraints to housing and the market conditions in Cotati; and to better identify specific housing needs:
U.S. Census 2010 and 2020
2015-2019 American Community Survey 5-Year Estimates
U.S. Census Bureau, Longitudinal Employer-Household Dynamics, Workplace Area Characteristics (WAC) files (Jobs); Residence Area Characteristics (RAC) files (Employed Residents), 2010-2018
U.S. Census Bureau, Longitudinal Employer-Household Dynamics, Workplace Area Characteristics (WAC) files (Jobs); Residence Area Characteristics (RAC) files (Employed Residents), 2010-2018
U.S. Department of Agriculture, Census of Farmworkers; 2002, 2007, 2012, 2017 U.S. Bureau of Labor Statistics, Quarterly Census of Employment and Wages (QCEW), 2020 first-quarter industry employment
U.S. Department of Housing and Urban Development (HUD), Consolidated Housing Affordability Strategy (CHAS), 2013-2017 release
U.S. Department of Housing and Urban Development (HUD), Comprehensive Housing Affordability Strategy (CHAS) ACS tabulation, 2013-2017 release U.S. Department of Housing and Urban Development, Section 202/811 Supportive Housing Programs, 2010 Program Fact Sheet
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Packet Pg. 425 Attachment: Exhibit B1 - Cotati Adoption Draft Housing Element (2023-03-20) (Housing Element CC Resolution) 5 U.S. Department of Education, National Center for Education Statistics, 2020 U.S. House of Representatives, US Code Low-Income Housing Preservation and Resident Homeownership, accessed January 1, 2022
U.S. Department of Housing and Urban Development (HUD), Continuum of Care (CoC) Homeless Populations and Subpopulations Reports (2019) California Tax Credit Allocation Committee, Opportunity Area Index, 2020, 2021 California Department of Finance, E-5 Population and Housing Estimates for Cities, Counties, and the State, 2020-2022
California Employment Development Department, Local Area Unemployment Statistics (LAUS), Sub-county areas monthly updates, 2010-2021 County of Sonoma, Grand Jury Report, June 2022
City of Cotati, Annual Progress Reports, 2015-2021
UC Berkeley, Urban Displacement Project
Redfin Housing Market Trends, May 2022
U.S. Department of Agriculture, Census of Farmworkers; 2002, 2007, 2012, 2017 U.S. Bureau of Labor Statistics, Quarterly Census of Employment and Wages (QCEW), 2020 first-quarter industry employment
U.S. Department of Housing and Urban Development (HUD), Consolidated Housing Affordability Strategy (CHAS), 2013-2017 release
U.S. Department of Housing and Urban Development (HUD), Comprehensive Housing Affordability Strategy (CHAS) ACS tabulation, 2013-2017 release U.S. Department of Housing and Urban Development, Section 202/811 Supportive Housing Programs, 2010 Program Fact Sheet
U.S. Department of Education, National Center for Education Statistics, 2020 U.S. House of Representatives, US Code Low-Income Housing Preservation and Resident Homeownership, accessed January 1, 2022
U.S. Department of Housing and Urban Development (HUD), Continuum of Care (CoC) Homeless Populations and Subpopulations Reports (2019) California Tax Credit Allocation Committee, Opportunity Area Index, 2020, 2021 California Department of Finance, E-5 Population and Housing Estimates for Cities, Counties, and the State, 2020-2022
California Employment Development Department, Local Area Unemployment Statistics (LAUS), Sub-county areas monthly updates, 2010-2021. County of Sonoma, Grand Jury Report, June 2022
City of Cotati, Annual Progress Reports, 2015-2021
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Packet Pg. 426 Attachment: Exhibit B1 - Cotati Adoption Draft Housing Element (2023-03-20) (Housing Element CC Resolution) 6 UC Berkeley, Urban Displacement Project
Redfin Housing Market Trends, May 2022
1.8 COMMUNITY PROFILE
Cotati is located in central Sonoma County along US Highway 101 in the northern San Francisco Bay Area. It lies within the southeastern portion of the Santa Rosa Plain, bounded by the low, rolling coastal hills to the west and the Sonoma Mountains to the east. Several creeks run into the City from the surrounding mountains and hillsides. These mountains and hills, along with the surrounding crop fields and pastures, provide a rural backdrop to the City.
In the 1950’s Cotati was the “Hub of Sonoma County” a close-knit community with its own water and sewer system and top-rated fire department. The drive for cityhood was inspired by its neighbor to the north, newly incorporated Rohnert Park. In order to maintain its character, Cotati rushed to gather signatures and draw boundaries. The city of Cotati was incorporated in 1963.
Cotati is one of only two towns in the U.S. with a hexagonal layout. The fire department, and La Plaza Park are in the center of the hexagon. Constantly rated as one of the best places to live, Cotati has a diverse community, good schools, and a variety of local businesses and activities.
Sonoma State University is just outside of Cotati’s city limit and has played a significant role in the City’s history since moving to its current location in 1966. Because of the youthful influence from Sonoma State, Cotati has a lively night life.
"Use an Accordion, Go to Cotati" is a motto for the Cotati Accordion Festival. Established in 1991, it is one of the most significant accordion festivals in the United States. The festival draws accordion aficionados from all over the world to La Plaza Park to participate in a full weekend of fun, food and music celebrating the beloved squeezebox. In 1997, a statue of festival cofounder Jim Boggio playing an accordion was erected in La Plaza Park.
In 1990, citizens voted for a fixed urban growth boundary and focused development within the City borders. The City then enhanced the downtown area with Priority Development Areas to encourage development in the Downtown Core and Cotati Depot (Santero Way Specific Plan).
In addition, the Sonoma Marin Area Rail Transit (SMART) light rail system began service in 2017, including the Cotati Station situated on the edge of downtown toward the Sonoma State University campus.
Since 2000, population density has increased 17.6% to 4,000 per square mile. Of the jurisdictions in Sonoma County, Cotati has the least amount of exclusionary zoning, only allowing single family dwellings, at just over 40%.
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Packet Pg. 427 Attachment: Exhibit B1 - Cotati Adoption Draft Housing Element (2023-03-20) (Housing Element CC Resolution) 7 Figure 1: City of Cotati Location within Sonoma County Source: Wikimedia Commons
1.9 CHANGING HOUSING NEEDS AND DEMOGRAPHICS
As Cotati ages and demographics change, different housing needs have arisen, and new programs are needed to meet changing demands. This section explores the characteristics and the housing needs of Cotati residents and helps to provide direction in updating the City’s Housing Element goals, policies, and programs. Comparisons between Cotati’s data and that of Sonoma County and the Association of Bay Area Governments (ABAG) are also covered in this section.
1.9.1 Population Characteristics and Trends
Cotati’s population increased 4.4% between 2010 and 2020, from 7,265 to 7,584. In comparison, Sonoma County’s population increased only 1% between 2010 and 2020, from 483,878 to 488,863. Cotati’s population growth rate of 17.1% over the past two decades is comparable to the surrounding ABAG region at 14.5%.
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Packet Pg. 428 Attachment: Exhibit B1 - Cotati Adoption Draft Housing Element (2023-03-20) (Housing Element CC Resolution) 8 Age Composition
Cotati’s population is generally younger than the region’s population. The share of the population under 18 years of age is 20.1%, which is slightly higher than the regional County share of 19.3%. Cotati's seniors (65 and above) make up 15.4% of the population, which is lower than the regional share of 20.7%.
Figure 2: Population by Age, 2000-2019
Source: American Community Survey, 2015-2019
Race and Ethnicity
The U.S. Census statistics include the race and ethnicity of a city's population. The most prevalent racial and ethnic categories are as shown in Table 1. The 2010 and 2020 population estimates show that Cotati is experiencing increased percentages of Hispanic and Latino and Native American residents, and decreases in White, Asian, and Black residents. Additional discussion of Cotati’s racial and ethnic composition is included in Section 4.
Table 1: Comparative Trends in Racial and Ethnic Composition, 2010-2020 Cotati Sonoma County California
2010 2020 2010 2020 2010 2020
Hispanic or Latino 17.3% 22.3% 24.9% 27.3% 37.6% 39.4%
White (Non-Hispanic)
alone 72.5% 70.2% 66.1% 58.5% 40.1% 34.7%
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Packet Pg. 429 Attachment: Exhibit B1 - Cotati Adoption Draft Housing Element (2023-03-20) (Housing Element CC Resolution) 9 Black or African American
alone 1.7% 1.1% 1.4% 2.1% 5.8% 5.4%
Native American alone 1.0% 2.2% 0.7% 2.2% 0.4% 0.4%
Asian alone 3.9% 2.4% 3.7% 4.6% 12.8% 15.1%
Native Hawaiian or Other
Pacific Islander alone 0.4% 0.3% 0.3% 0.4% 0.3% 0.3%
Some other race alone 5.9% N/A 0.2% 0.6% 0.2% 0.6%
Two or More Races 5.5% 6.3% 2.7% 4.0% 2.6% 4.1%
Source: U.S. Decennial Census 2010, 2020
Employment and Income
According to the 2019 American Community Survey, the City of Cotati has 4,060 residents in the workforce. The industries with the highest percentage of employees are Health & Educational Services with 1,132 employees (28% of total), followed by Financial & Professional Services and Manufacturing, Wholesale, & Transportation (both 18% of total).
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Packet Pg. 430 Attachment: Exhibit B1 - Cotati Adoption Draft Housing Element (2023-03-20) (Housing Element CC Resolution) 10 Figure 3: Resident Employment by Industry
Source: American Community Survey, 2015-2019
1.9.2 Household Incomes and Housing Affordability
Cotati’s median household income was $86,982 in 2019, according to the American Community Survey. This is slightly higher than the County median household income of $86,173. Despite that, there are a considerable number of households (1,042, or 36.7%) with incomes at the “lower” level (80% of AMI or less). The distribution of income is shown in Figure
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Packet Pg. 431 Attachment: Exhibit B1 - Cotati Adoption Draft Housing Element (2023-03-20) (Housing Element CC Resolution) 11 Figure 4: Household Income Level by Household Size
Source: U.S. Dept. Housing & Urban Development, Comprehensive Housing Affordability Strategy, 2017 When housing prices are very high, many households must spend a larger share of their income on housing. Households are considered housing cost-burdened when their total housing costs exceed 30% of their gross monthly income, and to be severely cost-burdened when their total housing costs exceed 50% of their gross monthly income. Households with very low and extremely low incomes are disproportionately burdened by housing cost.
Figure 5 below shows the number of cost-burdened and extremely cost burdened households by income level. While Cotati had a higher median household income than the County in 2017, there were 1,113 households overpaying for housing, or approximately 39% of households.
Very low-income households in Cotati faced the direst need, with over 80% cost burdened. 1,910 55
1,328
163
2,954 220
1,740
190
6,884 404
0%
10%
20%
30%
40%
50%
60%
70%
80%
90%
100%
All other household types Large Families of 5+ Persons Percent of Households 0%-30% of AMI 31%-50% of AMI
51%-80% of AMI 81%-100% of AMI
Greater than 100% of AMI
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Packet Pg. 432 Attachment: Exhibit B1 - Cotati Adoption Draft Housing Element (2023-03-20) (Housing Element CC Resolution) 12 Figure 5: Cost Burden by Income Level
Source: U.S. Dept. Housing & Urban Development, Comprehensive Housing Affordability Strategy, 2017
1.9.3 Special Needs Populations
Homeless
The Sonoma County Community Development Commission conducts annual point-in-time surveys of homeless populations. In 2022, 85 people were reportedly experiencing homelessness in Cotati, an increase from 37 people counted in 2020, according to the 2022 Sonoma County Homeless Census Comprehensive Report. Six people were sheltered, and 79 were unsheltered. Stakeholder input indicates that the majority of those unsheltered sleep in cars in the industrial section of Cotati, and that the methodology of the report may include some individuals outside of City limits due to the arrangement of Census tracts. Services for homeless individuals are available in Cotati, and the primary homeless services providers are North House and A Step Up, two group homes providing a total of 19 transitional housing beds for people experiencing homelessness, addiction, and behavioral health issues. Additionally, the County of Sonoma acquired a house on Arthur Street in 2020, which it owns and operates as transitional housing.
Disabled
People with disabilities experience disproportionate rates of poverty and are the most likely population to experience homelessness, cost burden or inability to afford housing. Studies
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Packet Pg. 433 Attachment: Exhibit B1 - Cotati Adoption Draft Housing Element (2023-03-20) (Housing Element CC Resolution) 13 show that persons with disabilities are more likely to experience discrimination when seeking housing compared to other protected classes. In California, 54% of the discrimination complaints received by the U.S. Department of Housing and Urban Development were related to disability status.
Census data from the American Community Survey 2015-2019 indicate that 10.3% of Cotati residents are disabled: 5.61% of adults have a cognitive disability, 4.02% have an independent living disability, 1.88% have a self-care disability, 4.98% have an ambulatory disability, 1.25% have a vision disability, 5.61% with a cognitive disability and 2.74% with a hearing disability.
These numbers are not exclusive, as some residents have more than one type of disability.
The most commonly occurring disabilities among seniors 65 and older were ambulatory (25.6%) and independent living (15.6%). These needs can be addressed through housing strategies that include universal design in new single-family construction (e.g., an accessible ground floor bedroom and bathroom).
Figure 6: Disability by Type
Source: American Community Survey, 2015-2019
Elderly
Elderly persons often have fixed incomes and may have additional special needs related to access and care that may require physical improvements to their homes such as ramps, handrails, lower cupboards and counters, creation of a downstairs bedroom, or other modifications to enable them to remain in their homes. They may also need assistance in the form of a part-time or live-in caretaker.
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Packet Pg. 434 Attachment: Exhibit B1 - Cotati Adoption Draft Housing Element (2023-03-20) (Housing Element CC Resolution) 14 According to the American Community Survey 2015-2019, about 13.1% of Cotati’s population is aged 65 and above, lower than the County share of 20.7%. However, 9.9% of the population is in the 55-64 age group, which is projected to increase the population of elderly residents by the end of the Housing Element period.
Large Households
Household size can be influenced by a lack of affordable housing options, an increase or decrease in family formations, families leaving an area, and cultural tradition of living with family members reaching retirement age.
In Cotati, the average household size of 2.72 is larger than the County (2.58). In Cotati, the most common household size is 3-4 people (32.8%), followed by 2-person (27.6%) and 1-person (27.4%) households, as seen in Figure 7. Households with five or more people make up 12.2% of the households. Compared to the Association of Bay Area Governments (ABAG) region, Cotati has a similar share of single-person households (27.4% compared to 25% regionally) and 5+ person households (12% vs. 11%).
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Packet Pg. 435 Attachment: Exhibit B1 - Cotati Adoption Draft Housing Element (2023-03-20) (Housing Element CC Resolution) 15 Figure 7: Households by Household Size
Source: American Community Survey, 2015-2019
Female-Headed Households
Single parent households, particularly households headed by women, often have lowerincomes and higher living expenses, often making the search for affordable, decent and safe housing more difficult. In addition to difficulties faced by these households in finding and maintaining affordable housing, these households also typically have additional special needs relating to access to day care/childcare, health care and other supportive services.
State law requires an analysis of female-headed households to ensure adequate childcare and job training resources are provided. Of Cotati’s 2,758 total households, 14.3% are femaleheaded; of those, 50.3% had children at home. Of all female-headed households, 17.5% are below the poverty level.
Farmworkers
Farmworkers play a key role in the operation and delivery of the state’s food system. Despite this, farmworkers face a number of economic disadvantages compared to the national population as a whole. Farmworkers tend to have low incomes, higher risk of living in poverty, and limited access to safe, healthy, and affordable housing choices. In 2012, 75% of farmworkers worked alongside or lived with family members according to HCD.
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Packet Pg. 436 Attachment: Exhibit B1 - Cotati Adoption Draft Housing Element (2023-03-20) (Housing Element CC Resolution) 16 The 2015-2019 ACS identified 153 Cotati residents employed in farming, fishing, and forestry occupations; this represents 3.8% of the Cotati workforce.
1.10 CHARACTERISTICS OF HOUSING STOCK
Type
Cotati’s housing stock consists primarily of single-family units (64.7%), compared to 57% for the greater Bay Area region. As shown in Figure 8, in comparison to the region, the City has a smaller proportion of multifamily units and a similar proportion of mobile homes. However, the share of single-family zoning in Cotati is the lowest among incorporated jurisdictions in Sonoma County according to Generation Housing’s 2022 report, State of Housing in Sonoma County.
Figure 8: Housing Type Trends
Source: California Department of Finance, E-5
Tenure
Housing security can depend heavily on housing tenure (i.e., whether homes are owned or rented). Cotati has the same rate of owner-occupied homes as the ABAG region at 56%. The City’s housing stock consists of 2,758 occupied units, with 1,563 owner-occupied and 1,195 renter-occupied units.
The high cost of housing in the San Francisco Bay Area has made homeownership difficult for younger buyers and seniors on fixed incomes, as indicated in Figure 9 below. Most Cotati
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Packet Pg. 437 Attachment: Exhibit B1 - Cotati Adoption Draft Housing Element (2023-03-20) (Housing Element CC Resolution) 17 households earning below 100% AMI are renters, and the majority of households earning above 100% AMI own their homes. This is consistent with trends found across the County and the larger ABAG region.
Figure 9: Housing Tenure by Age
Source: American Community Survey, 2015-2019
Age and Condition
The age of Cotati’s housing stock is consistent with trends of the greater Bay Area region. While some homes date back to the early twentieth century, most of the housing stock was built during the housing booms of the 1960s to 1990s.
Substandard housing issues are of limited concern in Cotati, with only 1.2% of owned units and
0.8% of rented units with a deficient kitchen, and 1.2% of owned units and no reported rentals with plumbing issues. However, with over 1,000 units reaching 50 years of age during the next 8 years, rehabilitation needs will likely increase during this planning period.
The City’s Code Enforcement Division estimates that there are 10 single-family homes in need of rehabilitation over the planning period, and zero in need of demolition. These properties are primarily occupied by seniors and people with disabilities who may need assistance to bring residences up to code. The City’s multifamily housing stock is generally well-tended, and no units in need of rehabilitation or demolition within the planning period were identified.
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Packet Pg. 438 Attachment: Exhibit B1 - Cotati Adoption Draft Housing Element (2023-03-20) (Housing Element CC Resolution) 18 Figure 10: Housing Units by Year Structure Built
Source: American Community Survey, 2015-2019
Overcrowding
The ACS definition of overcrowding is more than 1.0 occupants per room, where the number of rooms includes all except kitchens, bathrooms, and hallways. Severe overcrowding is defined as more than 1.5 occupants per room. By these definitions, there are 195 overcrowded households and 37 severely overcrowded households in Cotati.
The rate of overcrowding in Cotati (8%) is higher than the County (5%) and ABAG region (7%).
As in other cities, rental units in Cotati are more likely to be overcrowded and severely overcrowded than owner-occupied units, with 17.8% of rental units experiencing overcrowding compared to 1.3% of owned homes. In addition to the high cost of housing, this may be partially attributed to off-campus residences of Sonoma State University students.
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Packet Pg. 439 Attachment: Exhibit B1 - Cotati Adoption Draft Housing Element (2023-03-20) (Housing Element CC Resolution) 19 Figure 11: Overcrowding Severity
Source: U.S. Dept. of Housing & Urban Development, Comprehensive Housing Affordability Strategy, 2017 Vacancy
Vacancy trends in housing are analyzed using a “vacancy rate” which establishes the relationship between housing supply and demand. For example, if the demand for housing is greater than the available supply, then the vacancy rate is low, and the price of housing will most likely increase. Additionally, the vacancy rate indicates whether the City has an adequate housing supply to provide choice and mobility. A “vacancy” occurs for several reasons; a home may be listed for sale or being prepared for a tenant. Homes can also be held for seasonal or occasional use by their owners. HUD standards indicate that a vacancy rate of 5% is sufficient to provide choice and mobility.
Cotati’s vacancy rate is 5%, with about 153 vacant units. A lower share (15%) of vacant units are for recreational, seasonal, or occasional use compared to the entirety of Sonoma County (48% of vacant units). This indicates that vacancy rates in Cotati are less influenced by the presence of short-term vacation rentals.
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Packet Pg. 440 Attachment: Exhibit B1 - Cotati Adoption Draft Housing Element (2023-03-20) (Housing Element CC Resolution) 20 Figure 12: Occupancy Status
Source: American Community Survey, 2015-2019
Prices
While Cotati’s median home price trends closely match those of the larger region, purchase prices are consistently lower than the region according to the 2001-2021 Zillow Home Value Index (Figure 13). In April 2022, the median home value in Cotati hit a new peak of $753,319.
Over the last 20 years, Cotati has ranged between 58% to 83% of ABAG regional median home values.
Despite steady increases in home prices in the past ten years, rents and wages have remained relatively consistent in the last decade; see Section 4.
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Packet Pg. 441 Attachment: Exhibit B1 - Cotati Adoption Draft Housing Element (2023-03-20) (Housing Element CC Resolution) 21 Figure 13: Median Home Values, 2001-2021
Source: Zillow Home Value Index (ZHVI), 2001-2021
Preservation of Assisted Units at Risk of Conversion
There are no deed-restricted affordable housing developments within the City with a high risk of conversion to market rate in the next ten years. Programs to assist in the preservation of atrisk housing are discussed in Section 2 and Section 4.
1.11 SUMMARY OF CONSTRAINTS
As discussed in Section 4, governmental and non-governmental constraints directly affect the production of housing in a City. Non-governmental constraints such as land costs and construction expenses can limit the development of affordable housing. Relevant nongovernmental constraints include availability of vacant land, the high cost of land and development, and community resistance.
Although financing is readily available for qualified homebuyers, home purchases may be difficult for lower and moderate-income buyers with limited down payments. Homebuyers using conventional financing may also be competing with all-cash offers for homes. These nongovernmental constraints affect the cost of development in Cotati and serve as barriers to housing production and affordability.
In addition to non-governmental constraints, policies and regulations at the Federal, State, and local levels can affect housing production. Local governmental constraints such as processing requirements for development applications, design and development standards, density
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Packet Pg. 442 Attachment: Exhibit B1 - Cotati Adoption Draft Housing Element (2023-03-20) (Housing Element CC Resolution) 22 limitations, fees and exactions, and uncertainty associated with obtaining permits can affect the price and availability of housing. Potential governmental constraints in Cotati are explored in Section 4.
1.12 SUMMARY OF FAIR HOUSING ANALYSIS
Assembly Bill 686 (Affirmatively Furthering Fair Housing, or AFFH) requires state and local agencies to take proactive measures to correct any housing inequalities related to race, national origin, color, ancestry, sex, marital status, disability, religion, or other protected characteristics. All Housing Elements due on or after January 1, 2021, must contain an Assessment of Fair Housing. Agencies must ensure that their laws and programs affirmatively further fair housing, and that they take no actions that counter those goals.
Under State law, Affirmatively Furthering Fair Housing, means “taking meaningful actions, in addition to combatting discrimination, that overcome patterns of segregation and foster inclusive communities free from barriers that restrict access to opportunity based on protected characteristics.” Agencies must include in their Housing Elements a program that promotes fair housing opportunities while identifying areas of racial/ethnic concentration across the socioeconomic spectrum. In the context of a community’s housing needs, AFFH is not just about the number of housing units needed, but also about where the units are located and who has access to them.
AB 686 enacts new requirements for the Assessment of Fair Housing; this assessment is contained in Section 4 along with a zoning history of Cotati and allowed housing types. Per HCD Guidance, the analysis assesses enforcement and outreach capacity, segregation and integration patterns, disparities in access to opportunity, disproportionate housing needs including displacement, and concentrated areas of poverty and affluence across racial/ethnic groups.
Data compiled in the Assessment of Fair Housing and Regional Fair Housing Analysis found high-priority challenges to fair housing and contributing factors to equal access to affordable housing in high opportunity areas in the City including:
Displacement of residents due to economic pressures (rent increases, priced out); Lack of affordable units appropriately sized for large families; Community opposition;
Lack of awareness of and funding for fair housing outreach and enforcement; Lack of public investment in neighborhoods, including services & amenities.
While it is not uncommon to find enclaves of persons with similar cultural background and values, it is necessary to analyze any area demonstrating racial or economic concentration to ensure that the community is not experiencing disparities in access to opportunities such as education, employment, and amenities. Economic, health and environmental metrics are all considered when determining a community or neighborhood’s resources level. The composite score typically used to describe the resource level includes indicators of relative poverty and affluence in three areas:
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Packet Pg. 443 Attachment: Exhibit B1 - Cotati Adoption Draft Housing Element (2023-03-20) (Housing Element CC Resolution) 23 Economic Score, including indicators such as poverty, employment, median home values, and adult education;
Education Score, including proficiency scores for math & English as well as high school graduation rates;
Environmental Score, including air pollution indicators, traffic density, drinking water contaminants, impaired water bodies, hazardous waste facilities, and pesticides.
An in-depth analysis including an Assessment of Fair Housing is included in Section 4. Section 2 includes specific policies, programs, and actions to be undertaken by the City to address these areas of concentration and to affirmatively further fair housing. Section 3 contains the housing sites location information and maps as part of the AB 686 requirement that jurisdictions identify sites throughout the community in a manner that is consistent with their duty to Affirmatively Further Fair Housing.
Ensuring Equitable Zoning Practices
Single-family zoning is exclusionary when it occurs to the exclusion of other types of residential uses. While Cotati has a high proportion (65%) of single-family homes, it coexists with multifamily zoning. AB 686 requires the City to adopt programs to overcome and reverse historic patterns of exclusion, and to identify locations for affordable housing through the AFFH lens.
The approach taken in the 2023 Housing Element to address past exclusionary zoning practices and to affirmatively further fair housing is two-fold. First, programs are included that amend the City code to allow for all types of housing, including the multifamily apartments and duplexes that have previously been less common in suburban cities such as Cotati;
Secondly, the location of potential housing sites to meet Cotati’s lower-income RHNA is considered through an equity lens, not only by choosing locations in areas throughout the city but also by including programs to promote the development of missing middle houses, duplexes, triplexes, ADUs, and affordable JADUs in the city’s single-family residential neighborhoods.
The Housing Element requires jurisdictions to zone for a variety of types of housing, and programs are included to allow staff-level approval of certain types of housing including low barrier navigation centers and permanent supportive housing in compliance with new state law.
Section 2 includes the specific policies and programs to reverse exclusionary zoning and to affirmatively further fair housing; Section 3 contains the housing sites location information and maps. Sites to be considered for higher-density housing are included within Moderate Opportunity Areas, currently the highest resource designation in Cotati.
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Packet Pg. 444 Attachment: Exhibit B1 - Cotati Adoption Draft Housing Element (2023-03-20) (Housing Element CC Resolution) 24 1.13 REGIONAL HOUSING NEEDS ALLOCATION
The Regional Housing Needs Allocation (RHNA) is a requirement of State housing law and is a determination of projected and existing housing needs for all jurisdictions in California. The Association of Bay Area Governments (ABAG) conducts the RHNA process every eight years.
Every jurisdiction must plan for its RHNA allocation in the Housing Element by ensuring enough sites with appropriate zoning to accommodate their RHNA. The goal is to ensure that local plans have enough appropriately zoned land to accommodate existing and projected housing needs for all income levels for the entire 8-year planning period. Jurisdictions are not expected to build the housing, but they must plan and zone for it.
The RHNA methodology applies several factors to further the objectives of State law and meet the goals of the Plan Bay Area 2050. After a RHNA total is calculated, a social equity adjustment is applied to determine the four income categories. The social equity adjustment is based on household income and access to resources. One of the five objectives of State housing law is to ensure that there is not an overconcentration of households by income group in comparison to the county or regional average. To ensure that the RHNA methodology does not overburden low-income jurisdictions with more low-income households, a social equity adjustment is applied during the Income Group process. Higher income jurisdictions are required to plan for fewer market rate units and more affordable units, while lower income jurisdictions plan for more market rate units and fewer affordable units.
Cotati’s RHNA for the period between January 2023 – January 2031 is 234 units, divided between income groups as shown in Table 2.
Table 2: Cotati Regional Housing Needs Allocation (RHNA), 2023-2031 Jurisdiction Very Low
Income
(<50% AMI)
Low Income
(50-80%
AMI)
Moderate
Income
(80-120% AMI)
Above
Moderate
Income
(>120% AMI)
Total
Cotati 60 34 39 101 234
Source: ABAG Draft Regional Housing Needs Allocation Plan: San Francisco Bay Area, 2023-2031 While the RHNA is assigned based on the four income categories above, the law also requires that communities plan for the needs of extremely low-income households, defined as those making less than 30% of the County AMI. The housing need for the extremely low-income group is generally considered to be one-half of the very low-income need. This Housing Element utilizes the statutory allowance of a 50/50 split as a framework for dividing the very low-income RHNA of 60 units in half by planning for 30 extremely low-income units and 30 very low-income units. Program actions are included to accommodate any shortfall.
Section 3 provides an analysis of the sites available to meet the City’s assigned RHNA, the Sites Inventory, and any constraints to development of the listed housing sites. Cotati’s entire RHNA can be accommodated on existing sites with appropriate zoning. Additionally, the City is committed to affirmatively furthering fair housing and will undertake a strategic rezoning of parcels within its highest resource area (Santero Way Specific Plan Area) to provide more
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Packet Pg. 445 Attachment: Exhibit B1 - Cotati Adoption Draft Housing Element (2023-03-20) (Housing Element CC Resolution) 25 opportunities for housing affordable to the local workforce within areas with higher access to opportunity. Section 3 provides an analysis of the RHNA surplus, the required sites information, and the housing sites inventory.
1.14 2015 COTATI HOUSING ELEMENT REVIEW
Cotati successfully implemented a variety of housing programs in its 2015 Housing Element.
An evaluation of the City’s progress toward achieving those programs, including an analysis of the differences between what was projected and what was achieved, provides useful data to determine any new or revised policies and programs for the 2023 Housing Element.
In the 2015-2023 Housing Element Update, the City planned for the expansion of the local housing supply for affordable and market-rate housing as well as maintenance and improvement of the existing housing stock. Implementation programs included:
Providing adequate sites at a range of densities to accommodate future housing needs;
Assisting in the development of adequate housing to meet the needs of extremely low, very low, and moderate-income households;
Conserving and improving the existing housing stock through Community Preservation rehabilitation loans and a handy worker program; Preserving the affordability of existing homes that were at risk of conversion to market-rate during the planning period;
Addressing and, where appropriate and legally possible, removing government constraints to the maintenance, improvement, and development of housing for all income levels; and
Promoting housing opportunities for all persons regardless of race, religion, sex, marital status, ancestry, national origin, color, familial status, or disability Progress Implementing Programs
The City has been successful in implementing most of the programs in its 2015 Housing Element. As indicated in Table 3, the City was largely successful in implementing its programs to support new construction, while quantified objectives pertaining to rehabilitation and preservation were unsuccessful. Programs were successful when utilized, and programs that were successful in the 5th Cycle have been amended and carried forward in the 2023 Housing Element. Changes include commitments to supplement direct efforts with robust public and stakeholder engagement to maximize program efficacy. Special needs housing is prioritized in the Housing Element, and effectiveness will be enhanced by programs to zone for a variety of housing types and affirmatively further fair housing. See Appendix A for a full list of the City’s implementation programs and their status.
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Packet Pg. 446 Attachment: Exhibit B1 - Cotati Adoption Draft Housing Element (2023-03-20) (Housing Element CC Resolution) 26 Table 3: Progress in Achieving 2015 Quantified Objectives by Income Income
Group
New
Construction
Projected/
Actual
Rehabilitation
Projected/
Actual
Preservation
Projected/
Actual
2015
Quantified
Objective
Total Units
Realized
2015-2022
Extremely
Low -
Very Low
30 / 11 6 / 0 37 / 0 36 11
Low 35 / 19 4 / 0 45 19
Moderate 15 / 24 25 / 0 -- 71 24
Above
Moderate 100 / 82 25 / 0 -- 152 82
Total 180 / 136 60 / 0 37 / 0 339 136
Lessons Learned
The City was able to meet a number of its objectives through successful programs, including those that preserved affordable units at risk of market-rate conversion, promoted the development of ADUs/JADUs, and allowed of streamlining of housing in the Neighborhood Urban (NU) Zone to support infill development. The City made progress through other programs that were partially achieved including programs supporting affordable housing development, as planned projects encountered difficulties and delays due to a lack of financing. Not all the programs were successful, as detailed in Appendix A.
The high cost of land and construction has made it a challenge for the City to reach all of its programs and quantified objectives. The market drives the cost of development and due to the high cost of construction and land in Cotati, it can be challenging for developers and investors to procure land, build units and then sell or lease them at an affordable rate. These non-governmental factors had the largest effect on the success of the City’s housing policies and programs.
Other factors that led to poor utilization of some of the programs included a lack of information about and promotion of some of the City’s available housing programs such as the utilization of Section 8 vouchers among landlords and residents. Without a focused effort to promote the availability and ease of application for these programs, few residents, property managers, and developers are made aware of them. Additional promotion will help the less successful, yet still applicable programs reach a wider audience and increase participation.
1.15 PROGRAM CHANGES IN 2023 HOUSING ELEMENT
The 2023 Housing Element update is not a comprehensive "new" Housing Element, but rather an update of the 2015 Housing Element. The focus of the update process has been to keep the programs that are working, adding new policies and programs where community needs have changed or where necessary to comply with new State laws. New or revised goals, objectives, policies, and programs are included to meet changing needs and to incorporate community and stakeholder input. Ongoing policies and programs that have been successful
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Packet Pg. 447 Attachment: Exhibit B1 - Cotati Adoption Draft Housing Element (2023-03-20) (Housing Element CC Resolution) 27 are continued in the Housing Element update; limited-term programs that have already been accomplished have not been carried forward.
Appendix A provides an evaluation of the programs from the 5th Cycle Housing Element and the City’s level of success in achieving them.
SECTION II: HOUSING STRATEGY
2.1 HOUSING STRATEGY
This Section contains the City’s Housing Strategy for the 2023-2031 Housing Element planning period. State law recognizes the vital role local governments play in the supply and affordability of housing. Each local government in California is required to adopt a comprehensive, longterm general plan for the physical development of the city or county. To ensure adequate provision for the housing needs of all economic segments of the community, the Housing Element must:
Identify the agencies and officials responsible for the implementation of the various actions and how consistency will be achieved with other general plan elements and community goals.
Identify adequate sites which will be made available through appropriate zoning and development standards and with the public services and facilities needed to meet the needs of all income levels. This shall include homeownership, rental housing, factorybuilt housing, mobile homes, emergency shelters, and transitional housing. Assist in the development of adequate housing to meet the needs of low- and moderate-income households.
Address and, where appropriate and legally possible, remove governmental constraints to the maintenance, improvement, and development of housing. Conserve and improve the condition of the existing affordable housing stock. Promote housing opportunities for all persons regardless of race, religion, sex, marital status, ancestry, national origin, or color.
The following goals, policies, and programs are designed to address the existing and projected housing needs of the City of Cotati. Each program has one or more individuals, bodies, or agencies responsible for its implementation, along with a potential or committed funding source, and a schedule for its implementation during the 2023-2031 planning period.
Programs implemented and not applicable for continuation since the last Housing Element in 2015 have been removed from this document. Unchanged policies and programs are continued as-is; new and amended programs are identified accordingly:
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Packet Pg. 448 Attachment: Exhibit B1 - Cotati Adoption Draft Housing Element (2023-03-20) (Housing Element CC Resolution) 28 Goal H-1 Resilient & Safe Housing
Conserve and improve the existing housing stock to provide adequate, safe, and decent housing for all Cotati residents
Goal H-2 Housing Production
Provide adequate sites and pursue funding to accommodate the housing needs of all economic segments of the community
Goal H-3 Affordable, Attainable, & Accessible Housing Expand affordable housing opportunities for lower income households and persons with special housing needs, including seniors, disabled persons, large households, and homeless persons and families
Goal H-4 Affirmatively Furthering Fair Housing
Promote housing opportunities for all persons regardless of race, gender, age, marital status, ancestry, national origin, color, or sexual orientation Goal H-5 Community Engagement
Ensure public participation in the development of the City’s housing policies, and ongoing collaboration with community stakeholders
For each goal, a set of policies and implementation programs is provided to assist the City in attaining the goal. Each implementation program contains the following information:
Methods to promote housing opportunities for all persons regardless of race, religion, sex, marital status, ancestry, national origin, or color. A concise statement of the specific City actions that will be taken to implement the program.
Funding source.
The City department or other agency responsible for implementation. Schedule for completion.
The expected results of each program are summarized as quantified objectives in Table 4.
Goal H-1: Resilient & Safe Housing
Conserve and Improve the Existing Housing Supply to Provide Adequate, Safe, and Decent Housing for all Cotati Residents
Policy H-1.1: Encourage housing rehabilitation and preservation to assist in the health, affordability, and vibrancy of neighborhoods. (Source: Previous Policy H 1.1) Policy H-1.2: Encourage the stabilization and affordability of neighborhoods by assisting with homeownership opportunities. (Source: Previous Policy H-1.2) Policy H-1.3: Seek all available funding, including CDBG, HOME, BEGIN, and CalHOME, to provide on-going housing rehabilitation and home ownership programs. (Source: New Policy, Previous Program 1-1)
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Packet Pg. 449 Attachment: Exhibit B1 - Cotati Adoption Draft Housing Element (2023-03-20) (Housing Element CC Resolution) 29 Policy H-1.4: Enforce conformance with local building codes to ensure that housing is safe and sanitary and to minimize hazards to public health and safety. (Source: Previous Policy H-1.3)
Policy H-1.5: Encourage proper maintenance of essential public services and facilities in residential neighborhoods. (Source: Previous Policy H-1.4).
Policy H-1.6 Encourage the preservation and maintenance of mobile home parks. (Source: Previous Policy H-1.7)
Policy H-1.7 Monitor units at-risk of conversion and facilitate conservation or replacement of any assisted housing units that are planned for conversion to market rate rents. (Source: Previous Policy H-1.8)
Policy H-1.8 Require all residential development that receives housing rehabilitation assistance to enter into a covenant, deed restriction, or other mechanism to ensure: 1) the long-term affordability of the housing units, and 2) if the units convert to market-rate, that the City is reimbursed for its financial assistance with the rehabilitation. (Source: Previous Policy H-1.9) Policy H-1.9: Encourage the development of accessory dwelling units in order to provide additional affordable and attainable market rate rental units in Cotati. (Source: Previous Policy H-1.10)
Policy H-1.10 Continue to expand energy and water efficiency in new and existing residential development to ensure sustainable practices and reduce longterm housing costs. (Source: Previous Policies H-5.1 & H-5.2) Policy H-1.11 Participate in local and regional programs that provide housing rehabilitation, weatherization, and home ownership assistance. (Source:
New Policy, Previous Program 1-1)
Policy H-1.12 Facilitate resident awareness of available housing rehabilitation and home ownership assistance programs by making information on the program available at City Hall and on the City’s website. (Source: New Policy, Previous Program 1-1)
Program 1-1 Housing Rehabilitation
(Source: Previous Program 1-1)
Improve neighborhoods and housing by providing opportunities for home ownership and housing rehabilitation through the following activities:
As funds become available, implement a Housing Rehabilitation Program which provides low interest loans for the rehabilitation of homes owned or occupied by extremely low, very low, low, and moderate income households with an emphasis on assisting extremely low and very low income households. Ensure that the
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Packet Pg. 450 Attachment: Exhibit B1 - Cotati Adoption Draft Housing Element (2023-03-20) (Housing Element CC Resolution) 30 housing rehabilitation program includes provisions for mobile homes and renovations to provide accessibility for disabled persons, to the extent that the funding source allows these types of improvements.
As funds become available, promote awareness of the housing rehabilitation program through contacting neighborhood groups in residential areas with aging housing stock. Outreach shall include program information as part of code enforcement efforts in cooperation with the Building Department. Provide annual funding for a regional or subregional shared planner or grant writer position to prepare funding applications for housing rehabilitation, as budget allows.
Responsibility: Community Development Department
Funding: CDBG, HOME, BEGIN, etc.
Timeframe: Seek funding annually; on-going, as funds become available; outreach conducted on an annual basis in the form of publicizing available funding opportunities in the City’s newsletter.
Geography: Citywide, prioritizing homes identified in need of rehabilitation Program 1-2: Home Ownership
(Source: Previous Program 1-1)
Improve neighborhoods and housing by providing opportunities for home ownership by implementing a Home Ownership Assistance Program which provides low interest loans to assist first-time low and moderate income homebuyers in purchasing a home. Responsibility: Community Development Department
Funding: CDBG, HOME, BEGIN, etc.
Timeframe: Seek funding annually; on-going, as funds become available; continue Home Ownership Assistance Program
through the City’s inclusionary housing program, and conduct outreach to housing developers on including ownership units on a project basis.
Geography: Citywide, low and moderate income households Program 1-3: Non-Profit and Agency Coordination – Existing Housing Needs (Source: Previous Program 1-2)
Continue working with and develop new relationships with local agencies, nonprofit housing providers, and local organizations. Participate in an annual discussion on Housing Fair between housing developers, decisionmakers, advocates, and other interested parties in partnership with the County, the subregion, and local organizations such as the Sonoma County Community Development Commission, Disability Access, and Legal Aid of Sonoma County. Responsibility: Community Development Department
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Packet Pg. 451 Attachment: Exhibit B1 - Cotati Adoption Draft Housing Element (2023-03-20) (Housing Element CC Resolution) 31 Funding: CDBG, HOME, BEGIN, etc.
Timeframe: On-going annual meetings and coordination with Sonoma County CDC; participate in Housing Fair annually, and report findings to City Council for direction and/or action.
Program 1-4: Capital Improvement Program
(Source: Previous Programs 1-3 & 2-5)
As part of the annual review of the Capital Improvement Program (CIP), determine priorities for capital improvement projects required to maintain the community's aging or nonexistent infrastructure, particularly located in Lower Resource Areas designated in California Opportunity Area Maps. Review of the CIP shall also include verification that areas needing improvement are scheduled for funding to address these needs at a specific time in the future.
Additionally, the Capital Improvement Program shall ensure that infrastructure improvements in Lower Resource Areas improve the circulation and connectivity of the urban fabric to grant all Cotati residents opportunity and mobility. This will be accomplished through improvements scheduled in the Downtown Specific Plan Area, South Sonoma Business Park, and West Cotati Gravenstein Commercial Corridor.
The City shall continue to prioritize lower-income housing development for water and sewer expansion, consistent with Government Code 65589.7 or its successor. Following adoption, provide the Housing Element Update to the City’s water and sewer providers (e.g., the water and sewer division of the Public Works Department).
Responsibility: Community Development and Public Works Departments Funding: General Fund and available funding for CIP projects Timeframe: Annually with CIP update
Geography: Citywide, emphasis in specific plan areas within the western side of the City designated as Low Resource by TCAC Resource Map including aforementioned specific plans and PDA areas;
adjacent to existing and planned affordable housing
developments
Program 1-5: Preservation of Affordable Housing
(Source: Previous Programs 1-5, 1-6, 1-7)
To facilitate the preservation of both deed-restricted and other existing affordable housing, and protect residents from displacement, the City will:
Maintain an updated inventory of affordable housing units, including rental and ownership units, that identifies the number of units by bedroom size and affordability level, funding/affordability source, and expiration date of affordability. Continue to monitor affordable housing developments with expiring deed restrictions, facilitate the acquisition of expiring properties, and conduct outreach to property owners.
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Packet Pg. 452 Attachment: Exhibit B1 - Cotati Adoption Draft Housing Element (2023-03-20) (Housing Element CC Resolution) 32 Monitor the status of publicly-assisted projects that may become “at risk” of losing affordable housing price restriction through personal contact by City staff with property owners and/or their representatives at least annually. When an affordable housing development is at-risk of converting, assist the owners in identifying resources, including available funding, for the continued provision of affordable units.
Monitor affordable housing developments at risk of converting to market-rate, and specify actions to take by the City within sufficient time prior to expiration of deedrestriction. Upon receipt of notice of a proposed conversion of assisted affordable housing, the City will contact qualified entities as identified by HCD and provided within the Housing Element, and encourage their involvement in the acquisition of the units. The City and partner organizations will work with property owners of at-risk units and provide them with education regarding tenant rights and conversion procedures. The City and partner organizations will also provide information regarding Section 8 rent subsidies through HUD (special vouchers for existing tenants in Section 8 projects), the Sonoma County Housing Authority, and other affordable housing opportunities in the region.
Responsibility: Community Development Department
Funding: City of Cotati Affordable Housing Fund, Sonoma County Community Development Commission and HCD
Mobilehome Park Resident Ownership Program
Timeframe: On-going; proactive outreach around preservation notice law on an as-applicable basis to both property owners and residents no less than three years before the expiration of deed-restrictions. Geography: Citywide
Program 1-6: Preservation of Mobile Home Parks
(Source: Previous Program 1-6)
To facilitate the preservation of mobile home parks and protect residents from displacement, the City shall:
Maintain an updated inventory of mobile home parks, that identifies the number of units by bedroom size.
Educate residents and park owners to facilitate resident purchase of mobile home parks with information on funding sources such as HCD’s Mobile home Park Rehabilitation and Resident Ownership Program (MPRROP). Coordinate with the Sonoma County Community Development Commission to support the preservation of mobile home parks.
Responsibility: Community Development Department
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Packet Pg. 453 Attachment: Exhibit B1 - Cotati Adoption Draft Housing Element (2023-03-20) (Housing Element CC Resolution) 33 Funding: City/HCD Mobile Home Park Resident Ownership Program Timeframe: Continue to support mobile home park residents and owners, and distribute information about the program to mobile home residents by October 2023 and apply for MPRROP Grant during the planning period, when funds are available and resident interest exists. The City shall conduct direct outreach to mobile home park residents at least twice per Housing Element planning cycle and provide MPRROP program information on the City’s website. Affordability information updated within 6 months of adoption of this Housing Element update; maintenance of inventory is on-going.
Geography: Existing mobile home parks, primarily along West Sierra Avenue Program 1-7: Essential Housing Bond Financing Program
(Source: New Program, addresses local and regional needs and priorities) In partnership with a Joint Powers Authority (JPA) and non-profit asset manager, seek to utilize tax exempt bonds to fund: (1) the acquisition of existing market-rate multi-family buildings and restrict future rents to be affordable to households that earn extremely low to moderate incomes, and/or (2) the construction of new deed-restricted affordable housing. In order for asset managers to access these types of bonds, Cities must join a Joint Powers Authority (JPA) and authorize the JPA to issue these bonds on behalf of the City. The asset manager then purchases the multi-family buildings or initiates new development, using only money from the bond financing, and sets the rents to be affordable to low to moderate income households.
Municipal ownership reduces or eliminates the property tax burden and reduces the financing interest costs due to the tax-exempt bond, reducing the carrying cost of the property and allowing the reduced rents to be realized.
Responsibility: Community Development Department
Funding: Housing Fund
Timeframe: Establish JPA structure or join existing JPA by December 2023 Geography: Citywide, existing and prior multifamily residential zones Program 1-8: Residential Building Decarbonization
(Source: Previous Program 5-1 – Energy Conservation and Efficiency) Promote energy efficiency and conservation in new and existing residential development through:
Continuing to adopt building and other codes that meet or exceed energy conservation and/or efficiency standards established by the California Energy Code.
As part of any General Plan or Specific Plan Update, ensure location of higher density residential housing near employment centers, high-quality transit and public services to discourage sprawl and conserve energy resources.
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Packet Pg. 454 Attachment: Exhibit B1 - Cotati Adoption Draft Housing Element (2023-03-20) (Housing Element CC Resolution) 34 Continuing to permit and encourage mixed uses and higher densities on in-fill and vacant sites in Priority Development Areas (PDAs) with public serving facilities, such as medical clinics, schools, and grocery stores, to discourage sprawl and encourage short vehicle trips and/or alternative forms of transportation. During preparation of specific plans and master plans, encourage location of higher density residential areas within walking distance of transit, employment-generating uses, schools, parks, community centers, and other amenities. Pursuing available grant programs to provide financial incentives for smart growth techniques and to provide property owners with low interest loans or grants to encourage weatherization improvements, solar/photovoltaic installations, electric vehicle charging, sustainable growth patterns, energy conservation, and energy efficiency.
Provide information on residential building decarbonization and energy conservation for public distribution on the City’s website, including photovoltaic solar systems, heat pumps, kitchen electrification, electric vehicle (EV) charging, weatherization, drought-resilient landscaping, rainwater storage, and residential “laundry-to-landscape" greywater systems.
Create a city-wide standard for deployment of electric vehicle charging, based on residential use types.
Provide clear and transparent guidance on permitting procedures for homeowners and developers interested in implementing residential building decarbonization. Responsibility: Community Development Department
Funding: General Fund and Grant Funding
Timeframe: On-going; information available by April 2023 and updated annually
Geography: Citywide, specific plan areas as amended/established Goal H-2: Housing Production
Provide Adequate Sites to Accommodate the Housing Needs of All Economic Segments of the Community
Policy H-2.1 Ensure that adequate land designated for residential and/or mixed-use development is available to accommodate the City’s fair share of ABAG’s Regional Housing Needs Allocation (RHNA) and monitor on an annual basis to ensure continual compliance with State law. (Source: Previous Policies H2.1 & 2.2) Policy H-2.2 Continue to require that residential development in the NU, NM, CG, and DSP zones meet the minimum density requirements identified in the Land Use Code, and report requests for reduced density on an annual basis. (Source: Previous Policy H-2.3)
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Packet Pg. 455 Attachment: Exhibit B1 - Cotati Adoption Draft Housing Element (2023-03-20) (Housing Element CC Resolution) 35 Policy H-2.3 While the City is able to accommodate its share of the regional housing need without rezoning during the current Housing Element period, to the extent necessary, the City will consider land use re-designation and promotion of existing innovations like the Cottage Housing Ordinance in order to accommodate development capacity that affirm all other goals of the City’s General Plan and maintain Cotati’s rural character. (Source:
Previous Policy H-2.4)
Policy H-2.4 Ensure that public infrastructure planning activities, including sewer, water, and drainage facilities, accommodate the City’s fair share of regional housing needs and that developments including lower income units are granted priority in accordance with Government Code Section 65589.7. (Source: Previous Policy H-2.5)
Policy H-2.5 Ensure that the City’s development requirements, including the standards established by the General Plan and Land Use Code, accommodate and provide for available housing sites that are appropriate for a range of income levels and housing types, including housing to accommodate special needs populations. (Source: Previous Policy H-2.6) Policy H-2.6 Encourage mixed use development, including residential and live/work uses in commercial and office areas where the viability of the nonresidential activities would not be adversely affected. (Source: Previous Policy H-2.7)
Policy H-2.7 Require housing developments to provide housing units at a range of affordability levels to assist in meeting the City’s housing needs as required by Chapter 17.31 of the Land Use Code. (Source: Previous Policy H-2.8) Policy H-2.8 Continue to address the impacts of large-scale commercial and office projects on housing needs through the affordable housing requirements established by Chapter 17.31 of the Land Use Code. Prioritize workforce housing developments and inclusionary units dedicated to lower and moderate-income workers. (Source: Previous Policy H-2.9) Policy H-2.9 Continue to facilitate, and encourage, the construction of accessory dwelling units pursuant to the City's Accessory Dwelling Unit Ordinance, Cottage Housing Ordinance, and pursuit of “affordable by design” missing middle housing such as junior accessory dwelling units (JADUs) and cohousing. (Source: Previous Policy H-2.10)
Policy H-2.10 Facilitate modular, factory-built housing units on permanent foundations in residential zoning districts and a variety of housing types. (Source:
Previous Policy H-2.11)
Policy H-2.11 Encourage housing development on existing infill sites in order to efficiently utilize existing infrastructure. (Source: Previous Policy H-2.12)
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Packet Pg. 456 Attachment: Exhibit B1 - Cotati Adoption Draft Housing Element (2023-03-20) (Housing Element CC Resolution) 36 Policy H-2.12 Assist in the development of affordable housing, particularly extremely low and very low income units, through the use of in-lieu affordable housing funds as well as CDBG and HOME funds, when available. (Source:
Previous Policy H-2.13)
Program 2-1: Adequate Housing Sites
(Source: Previous Program 2-1)
Continue to maintain an inventory of vacant and underdeveloped residentially designated land and, for sites appropriate for lower income and special needs development, identify the parcel number, parcel size, zoning designation, general plan designation, and allowed density with a density bonus for affordable units. Ensure that the inventory is available for public distribution at City Hall and on the City’s website. Update the inventory on an annual basis to:
Remove any parcels that have been developed and ensure that the remaining parcels are adequate to accommodate the City’s fair share of the Regional Housing Needs Allocation.
Identify additional high-density sites for lower income development if a short-fall of available sites to accommodate the City’s very low- and low-income allocation occurs. Note: The City currently has an excess of available parcels appropriate for very low- and low-income development.
The City shall create and maintain a list of additional sites with appropriate zoning that could be added to the City’s Sites Inventory if and when an analysis provided through the Annual Progress Report indicates that sufficient sites may not exist to accommodate the City’s remaining RHNA, by income level, for the planning period. To ensure sufficient residential capacity is maintained to accommodate the RHNA for each income category, staff will develop and implement a formal, ongoing (project-by-project) administrative evaluation procedure pursuant to Government Code Section 65863 within six months of adoption of the Housing Element. The evaluation procedure will track the number of extremely low-, very low-, low-, moderate-, and above moderate-income units constructed to calculate the remaining unmet RHNA. The APR will serve to document this evaluation and the evaluation procedure will also track the number of units built on the identified sites to determine the remaining site capacity, by income category, and will be updated as developments are approved. The Sites Inventory may be updated every year as the Annual Progress Report (APR) is completed, and the APR with the updated inventory will be available on the City’s website.
No project approval or other action that reduces the density or development capacity of a site shall be undertaken unless sufficient remaining sites are available (or additional adequate sites are identified) to meet the City’s RHNA obligation prior to approval of the development. Alternate sites shall be made available within 180 days of approval of the development, as required by Senate Bill 166. Identification of the replacement sites, and any necessary actions, to make the site(s) available, will be adopted prior to (or concurrent with) the approval of the development.
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Packet Pg. 457 Attachment: Exhibit B1 - Cotati Adoption Draft Housing Element (2023-03-20) (Housing Element CC Resolution) 37 Responsibility: Community Development Department
Funding: General Fund
Timeframe: On-going; maintain a dynamic inventory of Housing Element sites by reviewing by April of each year and amending the list as needed; establish administrative evaluation procedure within six months of Housing Element adoption; ensure adequate
alternative sites within 180 days of any project approval incurring net loss of Housing Elements sites capacity.
Geography: Citywide
Program 2-2: Streamlining Housing Development
(Source: Previous Program 2-6, amended to address stakeholder feedback and potential governmental constraints)
Stakeholders from the development community identified streamlining, fast tracking, and providing clear development standards and expectations as the primary mechanisms to reduce governmental constraints to residential development. In order to facilitate new residential development, the City shall implement the following actions:
Continue to provide and encourage an optional pre-application process to meet with representatives from relevant City departments before submitting a development application.
Continue to provide developers of residential projects opportunities to fast track the permitting process, with priority given to discretionary projects proposing affordable housing levels in excess of the minimum 15% inclusionary BMR housing units.
Join in regional collaboration efforts that would streamline housing efforts or increase staff capacity. Ensure the City has sufficient staff capacity to streamline development and implement Housing Element programs, including through the use of supplemental contract staffing.
Develop a written streamlined application process in accordance with SB 35 and SB 330, including the pre-application and the procedure. This process provides a streamlined ministerial approval process to qualified residential and mixed-use development projects. The written procedures and checklists shall be developed and made available at City Hall and on the City’s website. Eliminate the City’s growth management ordinance (GMO) in compliance with SB 330 (2019).
Expand existing Objective Design and Development Standards for SB 35 projects to apply to multi-family, single-family and mixed-use projects. Achieve compliance with new State Density Bonus provisions of AB 2345 and any other applicable changes to State law upon adoption of this Housing Element.
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Packet Pg. 458 Attachment: Exhibit B1 - Cotati Adoption Draft Housing Element (2023-03-20) (Housing Element CC Resolution) 38 Responsibility: Community Development Department
Funding: General Fund
Timeframe: Ongoing, as projects are proposed; 2024 for City streamlining products and compliance with State law; proactive outreach conducted to housing developers with local and regional presence upon alteration and/or adoption of streamlined application process(es).
Geography: Citywide
Program 2-3: Accessory Dwelling Units (ADUs)
(Source: Previous Program 2-3)
Incentivize and promote the development of accessory dwelling units (ADUs) and junior accessory dwelling units (JADUs) by providing technical assistance and resources for their development and rental through the following actions:
Maintain ADU webpage with accessible information, a simple application, and contact information for questions about and assistance with accessory dwelling units.
Partner with regional organizations that provide technical assistance, including site evaluations, for the development of ADUs and JADUs, and landlord/tenant support, such as the Napa Sonoma ADU Center and Homes for Sonoma. Share resources provided by these organizations, including webinars and technical assistance programs, through the City webpage, newsletter, and social media. Facilitate the development of JADUs by developing promotional materials specific to JADUs and their funding and making these available on the City’s ADU webpage.
In partnership with regional organizations, promote and publicize new allowances for ADUs and JADUs to the public, including place-based promotion for locations with higher income eligibility limits for the CalHFA ADU grant program Reduce penalties for existing unpermitted units and establish a process to legitimize such units. Promote and publicize this program through City website and social media to encourage people with unpermitted units to bring these homes up to code.
Annually report out on the City’s successes in the production of ADUs and JADUs with the City’s APR.
Review ADU production two years into the planning period and compare with Housing Element projections. If actual production is below the projected level, and the City is not meeting its RHNA targets proportional to the duration of the planning period, review options for providing a small grant program to assist eligible residents with costs associated with permit processing or implement other costreducing measures to increase ADU development as the budget allows. Such a
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Packet Pg. 459 Attachment: Exhibit B1 - Cotati Adoption Draft Housing Element (2023-03-20) (Housing Element CC Resolution) 39 grant program shall prioritize ADUs affordable by design to lower and moderateincome residents, as funding allows. Responsibility: Community Development Department
Funding: General Fund
Timeframe: 2024; as specified for specific follow up actions including review of ADU/JADU production and affordability every two years with programmatic actions to accommodate the shortfall within six months of issue identification (i.e. replacement sites procedure identified in Program 2-1, and in a small grant program); establish process for legitimizing unpermitted ADUs by 2024; report on ADU/JADU production by April of each year; and proactive outreach actions including ongoing maintenance of existing ADU webpage, annual updates from nonprofit partners provided in the City’s newsletter, and specific outreach conducted to residents/owners of unpermitted ADUs within three months of the Community Development Department gaining knowledge of such dwellings.
Geography: Citywide
Program 2-4: Cottage Housing
(Source: New Program)
Continue to promote the Cottage Housing Ordinance established in the 5th Housing Element Cycle to incentivize smaller units and increase the supply of missing middle housing including multiplexes, courtyard cottages, and other such housing types deemed “affordable by design” and allowable under the Cottage Housing Ordinance. The City shall:
Review the success of the Cottage Housing Ordinance on an annual basis and report unit counts as part of the APR.
Assess programmatic constraints with outreach to developers utilizing the ordinance no less than twice per Housing Element planning period. Investigate a supplemental ordinance utilizing SB 10 framework in order to streamline existing provisions of the Cottage Housing Ordinance and expand upon those provisions as deemed appropriate by the City Council. Responsibility: Community Development Department
Funding: General Fund
Timeframe: Annual reporting in the APR; City Council to review SB 10 ordinance by December 2025
Geography: Applicable zones as identified by Cottage Housing Ordinance and Council findings
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Packet Pg. 460 Attachment: Exhibit B1 - Cotati Adoption Draft Housing Element (2023-03-20) (Housing Element CC Resolution) 40 Program 2-5: Continuum of Care and Crisis Response
(Source: Previous Program 2-4)
The City will work through the Continuum of Care and County to support funding for the provision of emergency shelters, transitional housing, and supportive housing to provide housing for persons experiencing and at-risk of homelessness. The City shall continue participation in the mental health crisis response (SAFE) Program, or a similar program, to defer police calls to an alternative response from mental health professionals. Responsibility: Community Development Department, Police Department Funding: General Fund
Timeframe: Ongoing
Geography: Citywide
Program 2-6: Santero Way Rezoning to Affirmatively Further Fair Housing (Source: New Program, addresses identified housing needs and fair housing) In order to increase residential development in Moderate Resource areas and near amenities, the City will rezone sites within the Santero Way Specific Plan Area to increase residential capacity through Transit-Oriented Communities (TOC) or a similar zone to allow more opportunities for residential development at or above the City’s default density. (Note: any prospective rezoning under this program is independent of the Housing Element’s site identification for accommodation of the 6th Cycle RHNA). Responsibility: Community Development Department
Funding: Regional Early Access Planning (REAP) Grants and General Fund Timeframe: Rezoning completed by January 31, 2026
Geography: Santero Way Specific Plan Area
Program 2-7: Support Development of Proposed Projects
(Source: New Program, addresses housing needs and RHNA) In order to ensure pending and approved projects will be available for occupancy within the planning period, the City will proactively support the processing, approval, and development of these projects (See Table 8). Specifically, the City will provide automatic fee subsidies and/or in-kind services valued atup to $25,000 for 100% affordable housing developments that comply with the City’s adopted development standards, offer automatic fee deferrals until occupancy for all residential units, streamline permit processing by automatically moving these projects to the front of the queue, and proactively approve requests for extensions of approved entitlements on these sites as permitted by law. Additionally, the City will rezone parcels for the “Cotati Village” project (APNs: 144-050-009 & 046-286-021) to remove the unused PD designation and facilitate the proposed project on this site. Responsibility: Community Development Department
Funding: General Fund
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Packet Pg. 461 Attachment: Exhibit B1 - Cotati Adoption Draft Housing Element (2023-03-20) (Housing Element CC Resolution) 41 Timeframe: Support development on pipeline projects beginning in 2023, continuing throughout the planning period
Rezone Cotati Village site by December 2023
Geography: Citywide; rezoning for Cotati Village
Goal H-3: Affordable, Attainable & Accessible Housing
Expand Affordable Housing Opportunities for Lower Income Households and Persons with Special Housing Needs, including Seniors, Disabled Persons, Developmentally Disabled Persons, and Homeless Persons and Families
Policy H-3-1: Ensure that the City’s development standards encourage development of a range of housing types, including multifamily, mixed use, high density residential, accessory dwelling units, cottage housing units, and singlefamily units; implement objective design and development standards in triannual building code review; and incentivize production of lower income housing. (Source: Previous Policy H-3.1)
Policy H-3-2: Provide incentives for discretionary affordable housing development that address community priorities, including density bonuses, expedited processing, relaxation in development standards through the use of concessions and incentives, and either reduction, delay, or waiver of fees when financially feasible. (Source: Previous Policy H-3.2) Policy H-3-3: Continue to provide density bonuses to eligible projects as required by Government Code Section 65915, including projects that meet the minimum amount of total units affordable to extremely low, very low and low income households or provide units restricted to occupancy for senior households. (Source: Previous Policy H-3.3)
Policy H-3-4: Seek and utilize available County, State and Federal programs and other funding sources that provide housing opportunities for extremely low, very low, low, and moderate income and special needs households. (Source:
Previous Policy H-3.6)
Policy H-3-5: Encourage housing for large and intergenerational families, including through the promotion of accessory dwelling units. (Source: Previous Policy H-3.7)
Policy H-3-6: Continue to facilitate accessible universal design in new housing development and eliminate further barriers to safe and accessible housing for people with disabilities. (Source: Previous Policy H-3.8) Policy H-3-7: Coordinate with regional and local service groups to facilitate linkages between at-risk individuals and families, and organizations that provide
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Packet Pg. 462 Attachment: Exhibit B1 - Cotati Adoption Draft Housing Element (2023-03-20) (Housing Element CC Resolution) 42 support services, such as rapid re-housing programs, house share programs, and services for the homeless. (Source: Previous Policy H-3.9) Program 3-1: Zoning for a Variety of Housing Types
(Source: Previous Program 3-1, Addresses Government Code 65583 and 65583.2) As part of development project review and processing, provide incentives for affordable housing that addresses communities priorities, including housing affordable to extremely low income households, and special needs housing, including: density bonuses, expedited processing, relaxation in development standards (e.g., reduced minimum lot sizes or setbacks, increased height limitations, reduced open-space requirements, reduced parking requirements), and either reduction, delay, subsidy or waiver of fees when financially feasible, and fast-tracked applications. Incentives shall include those identified above and by the Land Use Code and this Housing Element.
The City will review all City Zoning Codes and plans to determine if changes are needed to comply with State laws related to transitional housing, supportive housing, group homes, Low Barrier Navigation Centers, and Accessory Dwelling Units.
City staff will bring forward Municipal Code amendments to address recent changes to State law including, but not limited to the following:
Allow Permanent Supportive housing, as defined in Government Code Section 65650, to be a by-right use in all zones where multifamily and mixed-uses are permitted. (AB 2162)
Allow Low Barrier Navigation Centers to be a by-right use in zones where multifamily and mixed-uses are permitted, including the nonresidential zones where multifamily is permitted. (Government Code 65660)
Allow employee housing consisting of no more than 36 beds in group quarters (or 12 units or less) designed for use by a single family or household to be treated as an agricultural use, as required by CA Health and Safety Code Section and 17021.6. Allow the development of JADUs within all single-family dwellings, including those in the NM and NU zones, and ensure all ADU/JADU requirements are compliant with State law.
Allow Residential Care Facilities for 7 or more clients as a permitted use in residential zones, subject only to clear, transparent, objective standards. Amend Density Bonus ordinance for consistency with Government Code 65915, as amended by AB 2345, AB 2334, and any other applicable changes to State Density Bonus Law, including updated parking and height standards. Amend the City’s Zoning Code to permit manufactured homes in the same manner, in the same zones, and only subject to the same requirements as other single-family residential uses.
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Packet Pg. 463 Attachment: Exhibit B1 - Cotati Adoption Draft Housing Element (2023-03-20) (Housing Element CC Resolution) 43 Amend the City’s Zoning Code to use the maximum parking requirements in Government Code Section 65915 for all multifamily projects without the need for any developer request.
Amend parking requirements and management standards for emergency shelters pursuant to State law, including AB 139.
The City will complete amendments to Specific Plans to ensure compliance with State laws related to transitional housing, supportive housing, group homes, Low Barrier Navigation Centers, and Accessory Dwelling Units. The City will allow developments by right of at least 20 units per acre pursuant to Government Code section 65583.2(i) when 20 percent or more of the units are affordable to lower-income households on sites identified to accommodate the lower income RHNA that was previously identified in past Housing Elements. Responsibility: Community Development Department
Funding: General Fund
Timeframe: Land Use Code revisions adopted in 2023; amend remaining plans regulating land use by June 2024; complete required rezonings by January 2026
Geography: Applicable zones citywide
Program 3-2: Funding for Affordable and Special Needs Housing (Source: Previous Program 3-3)
Continue to seek available funding for lower income and special needs housing to provide affordable housing and special needs housing that addresses the City’s priorities. Funding for housing shall include the following actions:
Support applicants of discretionary projects for County, State, Federal, or other funding applications for affordable (extremely low, very low, and low income) and special needs (seniors, homeless, at-risk of homelessness, large households, disabled persons, developmentally disabled persons, female-headed households, agricultural workers etc.) housing programs, including the Affordable Housing Innovation Program funds, BEGIN, CalHome, Emergency Housing and Assistance Program Capital Development, Housing Related Parks Program, Low Income Housing Tax Credits Multifamily Housing Program – General and Supportive Housing Components, Predevelopment Loan Program, and Transit-Oriented Development Housing Program. Continue to prioritize support of applications for discretionary projects that provide a significant percentage of units to serve the City’s extremely low income, very low income, transitional/supportive, senior, or large family housing needs.
Continue the Housing Fund, with contributions collected from private and public sources to implement and/or supplement the City's housing programs. Use the
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Packet Pg. 464 Attachment: Exhibit B1 - Cotati Adoption Draft Housing Element (2023-03-20) (Housing Element CC Resolution) 44 Housing Fund to make housing available to very low to moderate-income Cotati residents, with an emphasis on very low and low income units for individuals and large families, affordable senior housing, and transitional/supportive housing. Responsibility: Community Development Department, Sonoma County Community Development Commission (CDC)
Funding: Housing Fund and/or various County, State, Federal or other funding sources
Timeframe: On-going, with annual application for County CDBG and HOME Funds and other state and federal funds, when appropriate and available; proactively conduct outreach to developers of projects within the City on a project basis, and outreach to at least three regional developers actively building units under the prioritized criteria.
Geography: Citywide
Program 3-3: Maintain Adequate Staff
(Source: Previous Program 3-6)
Continue to maintain adequate staff in the Community Development Department to process and review housing development applications in a timely manner and to implement the housing programs contained in this Element, through the following actions:
Coordinate with ABAG/MTC, the Sonoma County Community Development Commission, or other regional partners to supply contract planners and supplemental staff services as needed to facilitate the production, protection, monitoring, and preservation of housing in the City.
Formalize the role of Housing Administrator or Coordinator as a duty of in-house staff and/or a third-party administrator, as funding allows. Augment staff capacity with consultants as deemed necessary to execute City Housing goals.
Responsibility: Community Development Department
Funding: General Fund and any available grant funds for housing programs
Timeframe: On-going
Geography: Citywide
Program 3-4: Housing Choice Vouchers
(Source: Previous Program 3-7 – Tax-Exempt Financing)
The Section 8 Housing Choice Voucher Program is a federal subsidy program that helps families afford market-rate, private rental housing. Furthermore, landlords housing Section 8 tenants benefit from federally guaranteed rental income. Under State law (SB 329 and SB 222),
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Packet Pg. 465 Attachment: Exhibit B1 - Cotati Adoption Draft Housing Element (2023-03-20) (Housing Element CC Resolution) 45 landlords in California are legally required to accept rental applications from applicants using Section 8 and VASH vouchers and other forms of rental assistance.
The City shall continue to require developers utilizing tax-exempt financing to include language in agreements with the City permitting persons and households eligible for HUD Section 8 rental assistance or Housing Voucher Folders to apply for below-market-rate units provided in the development.
The City shall provide information on the City’s website regarding the Section 8 Housing Choice Voucher Program, including income eligibility, landlord resources, and a link to the Section 8 application hosted by the Sonoma County Community Development Commission.
The City shall monitor the status of the Section 8 waiting list on a quarterly basis and issue a citywide notification via the City’s mailing list upon periodic opening of the waiting list. Responsibility: Community Development Department
Funding: General Fund and any available grant funds for housing programs
Timeframe: On-going; quarterly monitoring
Geography: Citywide
Program 3-5: Review Processing Fees
(Source: Previous Program 3-8)
Pursue use of Housing Fund dollars to subsidize the development impact fees of extremely low, very low, and low-income units, where the City fell short of 5th Cycle RHNA targets.
Ensure compliance with SB 330 (Housing Accountability Act), and adherence to streamlining deadlines, thereby reducing the overall cost of housing developments by mitigating unnecessary delays.
Ensure compliance with AB 602, as detailed in Program 6-4.
Conduct comprehensive review of processing fees and procedures to identify potential constraints to housing development.
Responsibility: Community Development Department
Funding: General Fund, Housing Fund, and any available grant funds for housing programs
Timeframe: Ensure compliance with SB 330 and AB 602 during fiscal year 2022/23, prior to June 30, 2023; conduct comprehensive review of processing fees by December 2025, and complete beneficial revisions to City fees identified in the study by June 2026. Geography: Citywide
Program 3-6: Prohousing Designation
(Source: New Program)
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Packet Pg. 466 Attachment: Exhibit B1 - Cotati Adoption Draft Housing Element (2023-03-20) (Housing Element CC Resolution) 46 Through addressing constraints to development and fair housing opportunity, the City will investigate the local feasibility to receive the Prohousing Designation from the California Department of Housing and Community Development. Receiving this designation will provide the City an advantage in applications for competitive funding sources, including the Infill Infrastructure Grant and funding from the Affordable Housing and Sustainable Communities Program.
The City will review its implemented policies and programs within one year of Housing Element adoption to determine its eligibility for the Prohousing Designation Program. If eligible, the City will apply to receive the Prohousing Designation by 2025. Responsibility: Community Development Department
Funding: General Fund and any available grant funds for housing programs
Timeframe: 2025
Geography: Citywide
Goal H-4: Affirmatively Furthering Fair Housing
Promote Housing Opportunities for All Persons Regardless of Race, Gender, Age, Marital Status, Ancestry, National Origin, Color, or Sexual Orientation Policy H-4-1: The City will work to eliminate all unlawful discrimination in housing with respect to age, race, gender, sexual orientation, marital or familial status, ethnic background, disability, medical condition, or other arbitrary factors, so that all residents can obtain decent housing throughout the City. (Source:
Previous Policy H-4.11)
Program 4-1: Anti-Displacement Actions
(Source: New Program, Addresses AB 686)
Lower and moderate-income renters are at increased risk of displacement. The City shall take measures to reduce the risk of displacement through the City, especially in areas of increased investment and development, through the following actions:
Pursue grant opportunities to create a residential rehabilitation program for lower income residents. Work with the Community Development Commission to apply for HOME, CalHome, and CDBG funds, as well as promote Section 504 Home Repair Program loans and grants to provide housing rehabilitation loans and weatherization services for income-eligible households to improve living conditions.
Explore a Condominium Conversion ordinance to limit the loss of rental housing stock, as applicable.
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Packet Pg. 467 Attachment: Exhibit B1 - Cotati Adoption Draft Housing Element (2023-03-20) (Housing Element CC Resolution) 47 Continue to promote programs for housing stability and eviction prevention.
Prepare a directory of trusted community partners willing to promote these programs. Utilize these partnerships to share resources in a culturally sensitive manner and incorporate place-based outreach.
When implementing Program 1-6 to convert market-rate properties to deedrestricted affordable, prioritize developments subject to a higher likelihood of displacement.
The City will exercise preference in deed-restricted affordable housing units for Cotati residents, members of the Cotati workforce, families enrolled in the CotatiRohnert Park Unified School District, members of local tribes including the Federated Indians of Graton Rancheria, and employees of Sonoma State University.
This provision will be applied as allowed under State law and subject to the duty of public agencies to affirmatively further fair housing.
The City will require replacement housing units subject to the requirements of Government Code Section 65915(c)(3) when any new development occurs on a site in the Sites Inventory if that site meets any of the following conditions: a) currently has residential uses or within the past five years has had residential uses that have been vacated or demolished; and b) was subject to a recorded covenant, ordinance, or law that restricts rents to levels affordable to persons and families of low or very-low income; or c) subject to any form of rent or price control through a public entity’s valid exercise of its police power; or d) occupied by low or very-low income households. The City will conduct outreach to residents of 100% of nonvacant sites within the City’s Sites Inventory that may be replaced by new construction within 90 days of permit application on any given site(s). Responsibility: Community Development Department
Funding: General Fund and Grant Funding
Timeframe: On-going; pursue grant opportunities annually, as funds are available; present condominium conversion action items to Council by end of 2025; identify strategies for place-based outreach in partnership with stakeholders by end of 2025; prioritize developments with higher likelihood of displacement on an ongoing, project basis; establish local preference policy by end of 2024; outreach to residents of nonvacant sites at risk of displacement within 90 days of permit application.
Geography: Citywide, including local non-residents affiliated with the Cotati- Rohnert Park Unified School District, local tribal organizations, and Sonoma State University as described above
Program 4-2: Housing Discrimination Complaints
(Source: Previous Program 4-1)
The City shall take measures to distribute information regarding fair housing rights, programs, and complaint procedures through the following actions:
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Packet Pg. 468 Attachment: Exhibit B1 - Cotati Adoption Draft Housing Element (2023-03-20) (Housing Element CC Resolution) 48 Refer fair housing complaints to service providers including Legal Aid of Sonoma County and Fair Housing of Sonoma County, which provide free fair housing information and assistance to all residents of Sonoma County. Continue to address fair housing issues through participation, through the Urban County or other sources, in Fair Housing Sonoma County and Fair Housing of Marin (organizations that provide assistance for housing discrimination complaints and tenant/landlord mediation).
Responsibility: Community Development Director, overseeing Code Enforcement Division and Building Division
Funding: General Fund
Timeframe: On-going; check public counter weekly to ensure that fair housing brochures are available to the public; change
information that is available on an annual basis upon changes to fair housing law; City involvement in every case that comes forward, ensuring that grievances are addressed and all aspects of the law are enforced; civil matters referred to Legal Aid of Sonoma County.
Geography: Citywide
Program 4-3: Nondiscrimination & Fair Housing Information (Source: Previous Programs 4-2 & 4-3)
The City shall take measures to provide and publicize information regarding fair housing programs, housing rights, and complaint procedures, including the following actions:
Include nondiscrimination clauses in rental agreements and deed restrictions for housing constructed with City assistance.
Require bilingual (English/Spanish) availability of rental agreements in developments constructed with City assistance by 2025.
Continue to maintain an inventory of existing affordable rental housing and affordable ownership opportunities and programs on the City website. Continue to provide information regarding equal housing opportunity laws and the City's equal housing opportunities procedures to the public at City Hall, the Police Department and the City’s website. Include information about Fair Housing of Sonoma County to ensure residents with grievances can connect to the appropriate agencies and services.
Responsibility: Community Development Department
Funding: General Fund
Timeframe: On-going; bilingual (English/Spanish) availability of rental agreements in developments with City assistance by 2025;
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Packet Pg. 469 Attachment: Exhibit B1 - Cotati Adoption Draft Housing Element (2023-03-20) (Housing Element CC Resolution) 49 affordable housing webpage and equal housing information updated annually.
Geography: Citywide
Program 4-4: Reasonable Accommodation
(Source: Previous Program 3-4)
Continue to ensure that reasonable accommodation is provided for persons with disabilities, including developmental disabilities, through the following actions:
Ensure that requests for reasonable accommodation are over the counter, fast, and free. Conduct a biannual (every two year) review of the City’s regulations, procedures, and processes to ensure that reasonable accommodation is provided for disabled persons.
If barriers to reasonable accommodation are identified, undertake appropriate revisions to address the issue within six months, or prioritize as funding allows. Responsibility: Community Development Department
Funding: General Fund
Timeframe: Land Use Code revisions adopted concurrently with the Housing Element; biannual review conducted by April 1.
Geography: Citywide
Program 4-5: Limit Code Enforcement Activities
(Source: Previous Program 1-4 – Addresses AB 686)
Continue to prioritize residential code enforcement activities for situations that pose an immediate threat to public health and safety. Such activities do not include minor alterations made to residences without benefit of permit when such alterations are made to accommodate a special need or disability of the resident(s), or for interior alterations made to allow or honor the residents’ cultural needs or practices, unless those alterations pose an immediate threat to the safety of the residents or neighborhood. In instances of health and safety requiring significant repair, connect residents and property owners with rehabilitation programs and legal assistance. Ensure that Code Enforcement representatives receive training for cultural sensitivity and allow adequate capacity for services to be conducted. Responsibility: Community Development Department
Funding: General Fund
Timeframe: On-going
Geography: Citywide
Program 4-6: Culturally Appropriate Facilitation and Involvement (Source: New Program – Addresses AB 686)
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Packet Pg. 470 Attachment: Exhibit B1 - Cotati Adoption Draft Housing Element (2023-03-20) (Housing Element CC Resolution) 50 Facilitate the involvement of underrepresented residents, businesses, and organizations in all aspects of the planning process, utilizing culturally appropriate approaches to public participation and involvement.
Require affordable housing providers to conduct outreach to historically underrepresented populations, including people of color, when affordable housing programs are being marketed.
Responsibility: Community Development Department
Funding: General Fund
Timeframe: On-going
Geography: Citywide
Goal H-5: Community Engagement
Ensure Public Participation in the Development of the City’s Housing Policies Policy H-5-1: Encourage and facilitate public participation in the formulation and review of the City's housing and development policies. (Source: Previous Policy H-6.1)
Program 5-1: Annual Report
(Source: Previous Program 6-1)
Prepare an Annual Report to the City Council in the format approved by HCD which describes 1) implementation of Housing Element programs to date, 2) the amount and type of housing activity as related to the Housing Element’s goals, policies, and programs, 3) an updated summary of the City's housing needs, and 4) other housing information as described in these Goals. Submit this report to the Department of Housing and Community Development by April 1 of each year, and share via the City’s newsletter.
Responsibility: Community Development Department
Funding: General Fund
Timeframe: Provide annual report to City Council in the first quarter of each year and submit to HCD by April 1
Geography: Citywide
Program 5-2: Workshops and Public Hearings
(Source: Previous Program 6-2)
Facilitate workshops and public hearings to provide the public, housing developers, and service providers with an opportunity to review and discuss proposed changes to the City’s Housing Element. The City shall continue to hold informational presentations on evolving housing regulations and opportunities annually with the APR.
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Packet Pg. 471 Attachment: Exhibit B1 - Cotati Adoption Draft Housing Element (2023-03-20) (Housing Element CC Resolution) 51 Responsibility: Community Development Department
Funding: General Fund
Timeframe: On-going; public workshop on APR annually in March Geography: Citywide
Program 5-3: Stakeholder Engagement
(Source: Previous Program 3-2 – Planning for Affordable and Special Needs Housing) In addition to engaging the residents and workforce of Cotati, to engage stakeholders directly involved in housing, the City shall:
Continue to notify local and regional housing developers about the availability of public lands in compliance with the Surplus Lands Act.
Participate in housing stakeholder workshops or Housing Fairs that includes housing developers, property managers, community leaders, advocates, and special needs group stakeholders. These workshops are intended to identify potential housing projects, priorities, and funding opportunities. Pursue participation in events with active housing developers, community organizations, and neighboring jurisdictions such as Rohnert Park or other non-entitlement jurisdictions of the Sonoma County Community Development Commission as applicable.
Responsibility: Community Development Department
Funding: General Fund
Timeframe: On-going; surplus lands notification on an opportunity basis; participation in Housing Fairs on annual basis.
Geography: Citywide
Program 5-4: Accessible & Transparent Information
(Source: New, Addresses AB 602, SB 319)
The City will increase accessibility and transparency of housing development standards and opportunities and meet the new transparency and development fee requirements of AB 602 and SB 319 by implementing the following actions:
Post all required information about development standards and fees on the City’s website along with relevant information on zoning, development standards, and affordable housing-related ordinances.
Ensure compliance with AB 602 requirements for new development impact fee studies and publicizing resulting fees.
Create and publish a summary that identifies the sites on the City’s Sites Inventory and make the summary available online in map format. Provide site-specific development information and support whenever possible to provide a clear development process for interested housing developers.
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Packet Pg. 472 Attachment: Exhibit B1 - Cotati Adoption Draft Housing Element (2023-03-20) (Housing Element CC Resolution) 52 Responsibility: Community Development Department
Funding: General Fund
Timeframe: On-going on project basis; development standards (including AB 602 updates) on website by end of 2024; sites summary and map by end of 2024.
Geography: Citywide
2.2 QUANTIFIED OBJECTIVES
One of the requirements of State law (California Government Code Section 65583(b)) is that the Housing Element contain quantified objectives for the maintenance, preservation, improvement, and development of housing. The quantified objectives set a goal for Cotati to achieve based on needs, resources, and constraints. State law recognizes that the total housing needs identified by a community may exceed available resources and the community’s ability to satisfy this need. Under these circumstances the quantified objectives need not be, and are not intended to be, identical to the total housing needs.
The quantified objectives shown in Table 4 represent goals. They are estimates based on past experience, anticipated funding levels, and anticipated housing market conditions. The quantified objectives are not designed to be minimum requirements. Rather, they are based largely upon implementation programs that have measurable outcomes. However, the Housing Element contains several policies and implementation programs that reduce barriers and create opportunities for affordable housing. These policies and programs assist in meeting the City’s housing needs but are more qualitative in nature and are difficult to quantify.
Table 4: Summary of Quantified Objectives, City of Cotati, 2023-2031 Program Types Extremely
Low-Income
Very LowIncomeLow-Income ModerateIncomeAboveModerate Income
New Construction 20 19 19 26 98
Preservation of
Affordability
10 10 8 0 0
Rehabilitation 1 1 1 0 0
Conversion 0 0 0 0 0
ADUs/JADUs 12 12 12 4 40
Total 43 42 40 30 138
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Packet Pg. 473 Attachment: Exhibit B1 - Cotati Adoption Draft Housing Element (2023-03-20) (Housing Element CC Resolution) 53 SECTION III: HOUSING SITES
3.1 CONTEXT
Under Government Code Section 65583(a)(3), the City must identify suitable adequate sites with capacity to fulfill its fair share of regional housing needs, as determined by ABAG’s Regional Housing Needs Assessment (RHNA). These sites can include vacant sites zoned for residential use, vacant sites that allow residential development, and underutilized sites that are capable of being redeveloped to increase the number of residential units. These sites must have the realistic potential for new residential development within the Housing Element planning period. Additionally, jurisdictions may receive credit towards their RHNA for units in planned, approved, and pending residential projects, projected development of accessory dwelling units, and through other adequate alternatives described in Government Code Section 65583.1(c).
Cotati has a RHNA of 234 units, divided among the following income categories:
Table 5: Cotati Regional Housing Needs Allocation (RHNA), 2023-2031 Jurisdiction Very Low
Income
(<50% AMI)
Low Income
(50-80%
AMI)
Moderate
Income
(80-120% AMI)
Above
Moderate
Income
(>120% AMI)
Total
Cotati 60 34 39 101 234
Source: ABAG Draft Regional Housing Needs Allocation Plan: San Francisco Bay Area, 2023-2031 Cotati is meeting its RHNA through the following means:
Planned, approved, and pending projects projected to develop during the planning period;
Sites identified in the Sites Inventory, including sites on vacant and non-vacant land; Sites identified for rezoning under an Adequate Sites Program; Conversion of units from non-affordable to affordable under an Adequate Sites Program Alternative; and
ADU development projections.
Legislation passed since the last Housing Element update has added more stringent requirements for the Sites Inventory. Assembly Bill 1397 addresses standards for the adequacy of inventoried housing sites, including non-vacant sites and sites that were identified in previous Housing Elements. Senate Bill 166, the “No Net Loss” law, requires a jurisdiction to ensure a Housing Element Sites Inventory maintains capacity to accommodate the RHNA by income group throughout the entire Housing Element planning period. Because of this requirement, this sites inventory includes a 36% buffer for lower-income units and an 190% buffer for moderate-income units, uses realistic affordability and capacity assumptions, and relies on a variety of strategies to ensure the City addresses its housing needs. Additionally,
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Packet Pg. 474 Attachment: Exhibit B1 - Cotati Adoption Draft Housing Element (2023-03-20) (Housing Element CC Resolution) 54 programs are included within the Housing Element to ensure the City complies with new ‘No Net Loss’ requirements and maintains sufficient sites in inventory. Pursuant to Chapter 667, Statutes of 2019 (SB 6), the site inventory is also prepared using the standards and electronic forms adopted by HCD. The full site inventory can be found in Appendix D.
3.2 PROJECTED DEVELOPMENT AND RHNA CREDIT
As allowed by Government Code Section 65583.1 and 65583.2(a), Cotati is counting the projected development of Accessory Dwelling Units (ADUs) and the capacity of planned, approved, and pending residential projects towards their RHNA. After considering these sites, the City is projected to develop 721 units, sufficient units to surpass its entire RHNA allocation.
However, these units are not anticipated to meet the RHNA by income level, with an outstanding need for moderate- and lower-income units. Housing sites and adequate sites programs have been identified to meet the capacity for the remaining moderate- and lowerincome RHNA and to provide a buffer of unit capacity for No Net Loss considerations.
3.2.1 ADUs and JADUs
An Accessory Dwelling Unit (ADU) is a secondary dwelling unit located on residentially zoned property that has an existing single-family or multifamily residence. Due to their small square footage, ADUs can provide affordable housing options for family members, friends, students, the elderly, in-home health care providers, the disabled, and others. Junior ADUs (JADUs) are even smaller living units that can be built out of existing space in homes and garages. JADUs have independent cooking facilities and outside access, however they may share sanitation facilities within the primary home.
Jurisdictions may count the potential for ADU development as credits towards their RHNA, based on an analysis that includes recent development trends, local demand, available resources or incentives, and anticipated affordability. Analysis and discussion of local trends, demand, and affordability are contained within this section, and analysis and discussion of resources, incentives, constraints, and development standards for ADUs and JADUs are included within the Technical Background Report.
Recent California legislation has facilitated increased permitting and production of ADUs.
From 2018 to 2022, the City permitted an average of 4 ADUs annually, ranging from 2 to 8 permits per year. The City anticipates the upward trend in the development of ADUs and JADUs throughout the 6th Cycle will increase and is supporting that assumption with programs to facilitate and incentivize production.
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Packet Pg. 475 Attachment: Exhibit B1 - Cotati Adoption Draft Housing Element (2023-03-20) (Housing Element CC Resolution) 55 Table 6: ADU Permits Issued or Completed by Year in Cotati Year 2018 2019 2020 2021 2022 Total
ADU Permits 2 4 4 2 8 20
“Safe Harbor”
(RHNA Assumption)
Average of 4 ADUs permitted per year / 32 in planning cycle Projection with
Programs
(Quantified
Objective)
Average of 5 ADUs permitted per year / 40 in planning cycle Source: 2018-2021 Housing Element Annual Progress Reports; Community Development Department, 2022 City of Cotati Permit Data.
The Association of Bay Area Governments (ABAG) prepared a report and issued affordability recommendations for projecting ADU development based on a survey of local ADU rental costs. This data was used to generate the regional distribution of ADUs shown in Table 7. Cotati is using the affordability assumptions provided in this report to ensure the distribution of affordability reflects local development trends.
This distribution of affordability will be applied to a projection of 4 ADUs or JADUs built annually, for a total of 32 units over the planning period credited towards Cotati’s RHNA (Table 7). This increased projection will be supported by policies and programs to facilitate ADU development (Policy H-1.9, Program 2-3: Accessory Dwelling Units). The City will review ADU development two years into the planning period and implement further incentives if the City is not on track to meet its RHNA targets through its ADU projections. The City will also implement policies and programs to facilitate ADU development (Policy H-1.9, Program 2-3: Accessory Dwelling Units) and strive to meet a quantified objective of 5 ADUs per year.
Table 7: Assumed Affordability for 6th Cycle ADUs
VLI LI MI AMI Total
Regional Distribution of
ADUs by Income Level 30% 30% 30% 10% 100%
Projected ADUs by
Income Level for 6th
Cycle Projection Period
10 10 9 3 32
3.2.2 Planned, Approved, and Pending Projects
Jurisdictions may also count planned, approved, and pending residential units as credits towards their RHNA. These units can be counted based on affordability and unit count, provided it can be demonstrated that the units can be built within the planning period.
Affordability (income category) is based on the actual or projected sales prices, rent levels, or other mechanisms establishing affordability of the units within the project, including affordability requirements achieved through the City’s inclusionary housing program and/or project entitlement negotiations. A brief description of each project is provided below.
These projects are all expected to be completed during the planning period. Current growth control measures, discussed in Section 4.4.2 of the Technical Background Report, are not
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Packet Pg. 476 Attachment: Exhibit B1 - Cotati Adoption Draft Housing Element (2023-03-20) (Housing Element CC Resolution) 56 being enforced and will be removed under Program 2-2. Growth control measures will not affect the approval and development of these projects.
Table 8: Planned, Approved, and Pending Projects for RHNA Credit Project ELI VLI LI MI AMI Total Status Anticipated
Occupancy
Cotati
Station 0 8 3 8 79 98 Approved 2024
Cotati
Village 0 18 0 0 159 177 Under Review(SB330) 2025
East Cotati
Cottage
Housing
0 0 0 2 4 6 Approved 2024
La Plaza
View 0 0 45 11 0 56 Under Review 2025
Lasker Lane 0 0 0 0 6 6 Approved 2025
Pink Viking 0 1 2 3 30 36 Under Review 2025
Redwood
Row 4 5 8 8 145 170 Under Review(SB330) 2025
Red’s
Residential 4 10 0 0 112 126 Under Review (SB330) 2025
RHNA
Credit 8 42 58 32 535 675 -- --
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Packet Pg. 477 Attachment: Exhibit B1 - Cotati Adoption Draft Housing Element (2023-03-20) (Housing Element CC Resolution) 57 Figure 14: Location of Planned, Approved, and Pending Projects Cotati Station
Cotati Station is an upcoming residential development located within the Santero Way Specific Plan area (APNs 144-320-033, 034, 035, 036, and 144-480-022). The City approved a density bonus for a total of 98 residential units consisting of 79 market rate units and 19 below market rate units (8 moderate-income units, 3 low-income units, and 8 very low-income units) which will be made affordable through a deed restriction. Affordability agreements and fee deferral agreements were in place in 2022, and a building permit application is expected in 2023. There are no known barriers to development.
Cotati Village
Cotati Village is an upcoming 177-unit multifamily housing development located at the northeast corner of Highway 116 and Alder Lane (APNs: 144-050-009 & 046-286-021). The project will include 159 market rate units and 18 very low-income units. The lower-income units are provided through the City’s Inclusionary Ordinance and will be deed restricted. The applicant previously rezoned these sites to PD for a different prospective project at a lower density; the current Cotati Village Project does not make use of the PD zoning but instead is proposed under the original CG zoning. To facilitate the development of this project, the City is committed to rezoning to remove the unused PD designation (Program 2-7) and return it to
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Packet Pg. 478 Attachment: Exhibit B1 - Cotati Adoption Draft Housing Element (2023-03-20) (Housing Element CC Resolution) 58 its original CG designation to allow the current project at no cost to the developer. The applicant is finalizing design plans, and the hearing for this project is expected mid-2023.
East Cotati Cottage Housing
The East Cotati Cottage Housing project is a six-unit missing middle cottage housing development proposed at 902 East Cotati Avenue (APN: 144-302-030). This project was approved on February 21, 2023 and is among the first to utilize flexible zoning provisions of the City’s Cottage Housing Ordinance passed in 2021 and promoted through Program 2-4 of the Housing Element. The project includes four units between 1,000 and 1,300 sq.ft in size, assumed to be affordable to above moderate-income households, and two 500 sq.ft. ADUs, classified as moderate-income units based on the small unit size, supported by the analysis in Section 3.2.1. The building permit application is expected later in 2023, and there are no known barriers to development.
La Plaza View
La Plaza View is a 70-unit* multifamily housing development located on vacant land within the downtown hexagon on East Cotati Avenue between La Plaza and Charles Street (100 East Cotati Ave; APNs 144-274-002, 014, and 015). In July 2022, the City approved the project for 23 market rate units, 2 moderate-income units, 1 low-income unit, and 1 very low-income units.
The developer submitted a second application on March 1, 2022 under streamlined ministerial SB 35 approval provisions that allow greater building heights and density for projects containing at least 50% affordable units. The project will be 100% affordable with 56 lowerincome units and 14 moderate-income units, all of which will be deed restricted. Local tribal representation accepted AB 168 consultation which continues to be underway as of March 2023.
*Due to ongoing consideration of two development proposals, the City is assuming a realistic capacity of 80% of the larger project at proportional affordability levels of 80% low-income and 20% moderate-income.
Lasker Lane
Lasker Lane is a six-unit, market rate, single-family housing development approved at 65 Lasker Lane (APN 144-470-007). The project is fully entitled, and the City is working with the previous owner’s heir(s) to support construction of this vested project.
Pink Viking
Pink Viking is an upcoming 36-unit single-family housing development proposed at 8841 Old Redwood Highway (APN 046-223-018). The project will include 30 market rate units, 3 moderate-income units, 2 low-income units, and 1 very low-income unit. The moderate- and lower-income units are provided through the City’s Inclusionary Ordinance and will be deed restricted. This project is awaiting the finalization of environmental documentation, and the hearing is expected in Fall 2023. California Tiger Salamander mitigation is the only known
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Packet Pg. 479 Attachment: Exhibit B1 - Cotati Adoption Draft Housing Element (2023-03-20) (Housing Element CC Resolution) 59 barrier and is not expected to constrain development as the costs have already been considered by the developer (see further discussion in Section 3.8.4).
Redwood Row
Redwood Row is a proposed 170-unit mixed-use townhome development on a vacant 10.41- acre property located at the northwest corner of Redwood Drive and Gravenstein Highway adjacent to Lowe’s Home Improvement in the Commercial Gravenstein Corridor zoning district (APNs: 046-286-017, -18, -19, and -20 ). The moderate- and lower-income units are provided through the City’s Inclusionary Ordinance and will be deed restricted. This project is in review and awaiting environmental documentation, including California State Water Resources Control Board approval of mitigation measures. There are no other known barriers to development.
Red’s Residential
Red’s Residential is proposed as a mixed-use development consisting of 126 multi-family units spread across four residential buildings on a 5.3 acre site. The project proposes to provide 13 units affordable to very low-income individuals and families in order to qualify for a 50% density bonus. The City has approved a lot line adjustment to facilitate this development. The project is located at 7515 Alder Avenue within the Commercial Gravenstein Corridor (CG) zoning district (APNs: 144-040-011 and 144-040-021). The lower-income units will be deed restricted as required by density bonus law. The project was vested in March 2023. California Tiger Salamander mitigation is the only known barrier and is not expected to constrain development as the costs have already been considered by the developer (see further discussion in Section
3.8.4).
3.3 REALISTIC CAPACITY OF SITES ZONED FOR HOUSING
As shown in Table 9, the City has identified enough units through RHNA Credits (projected ADU development and pending, approved, or permitted projects) to meet its 6th Cycle RHNA for the above moderate-income category and for total units. To identify enough sites for its moderate- and lower-income RHNA, the City prepared an inventory of sites available and suitable for housing development. Information about these sites is included below.
Realistic development capacity for these sites is based on development standards and land use controls (see Section 4.4.2 of the Technical Background Report), access to infrastructure, necessary site improvements, other constraints, and recent development trends (see Table 11).
Residential development trends, detailed in Section 3.5, show that projects are typically developed at over 100% of maximum allowed capacity, using density bonuses or similar provisions. This analysis utilizes a lower realistic capacity factor of 85% to account for No Net Loss requirements. Realistic development capacity for nonvacant sites accounts for the likelihood of non-residential development.
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Packet Pg. 480 Attachment: Exhibit B1 - Cotati Adoption Draft Housing Element (2023-03-20) (Housing Element CC Resolution) 60 Figure 15: Location of Housing Opportunity Sites
Table 9: RHNA and Site Capacity
Lower
Income
Moderate
Income
Above
Moderate
Income
Total
RHNA Allocation 94 39 101 234
Pipeline 108 32 535 675
ADUs/JADUs 20 9 3 32
Housing Sites (Current Zoning) 30 39 36 105
Total Units 158 80 574 812
RHNA Surplus 64 41 473 578
Percent Buffer 68% 105% 468% 147%
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Packet Pg. 481 Attachment: Exhibit B1 - Cotati Adoption Draft Housing Element (2023-03-20) (Housing Element CC Resolution) 61 Table 10: Capacity of Sites Allowing Residential Development # Site Address/
Location APN Zone
Max
Density
(units/ac)
Acres Units Affordability
Vacant Sites
1 7734 Old
Redwood Hwy 144-080-022 NG 20 0.43 5 AMI, MI
Nonvacant Sites
2 150 St Joseph Way 144-170-009 NG 20 5.65 61 AMI, MI, LI 3 7457 Alder Ave 144-040-017 CG 15 1.98 39 AMI, MI 7455 Alder Ave 144-040-013 CG 15 1.89 Total 105
30 LI
39 MI
36 AMI
3.3.1 Vacant Sites
Site 1: 7734 Old Redwood Highway
Site 1 is a vacant 0.45-acre site within the Northern Gateway zone of the Downtown Specific Plan area, set back from the highway, with no ground floor requirements for retail or commercial development set by the Specific Plan. This area is regulated by a form-based code and does not have a maximum allowable density, but the City’s development standards allow for development at approximately 20 units per acre (further analysis in Section 4.4). This site has similar characteristics (parcel shape, size, proximity to downtown) as Example #2 on Table 11: Development Trends, which is developing above 25 units per acre, and similar land use controls as Example #4, which is developing at over 60 units per acre. The site is adjacent to both residential and commercial uses and is intended for mixed-use development.
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Packet Pg. 482 Attachment: Exhibit B1 - Cotati Adoption Draft Housing Element (2023-03-20) (Housing Element CC Resolution) 62 Capacity: (20 units/acre)(0.45 acres)(85% realistic capacity)(67% factor for likelihood of residential development) = 5.1 units, rounded down
RHNA Income Category: 3 moderate-income, 2 above moderate-income units Infrastructure: Parcel is served by water, sewer, and dry utilities. Prior Use: Parcel was used in the 4th and 5th Cycle Site Inventories. This site is not being used to accommodate the lower-income RHNA and is not subject to rezoning requirements.
3.3.2 Non-Vacant Sites
Site 2: 150 St. Joseph Way
This site is a 10.07 acre nonvacant parcel owned by the Catholic Church containing a church building, parking lot, and 5.65 acre of undeveloped land. The site is surrounded by residential and underutilized commercial areas. The site is within the Northern Gateway zone of the Downtown Specific Plan area, with no ground floor requirements for retail or commercial development. This site has similar characteristics (parcel size, proximity to downtown) to Examples #6, #7, and #8 on Table 11: Development Trends, which are developing at an average of 21 units per acre, and similar land use controls as Example #4, which is developing at over 60 units per acre.
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Packet Pg. 483 Attachment: Exhibit B1 - Cotati Adoption Draft Housing Element (2023-03-20) (Housing Element CC Resolution) 63 Capacity: (20 units/acre)(5.65 vacant acres)(85% realistic capacity)(67% factor for likelihood of residential development)= 61.1 units, rounded down RHNA Income Category: 30 low-income, 16 moderate-income, 15 above moderateincome units Infrastructure: Parcel is served by water, sewer, and dry utilities. Prior Use: Parcel was used in the 4th and 5th Cycle Site Inventories. Under Program 3-1, this site will allow for residential development at 20 units per acre for housing developments in which at least 20 percent of units are affordable to lower-income households.
Site 3: Alder Ave
This 3.87 acre site consists of two adjacent, developer-owned parcels. One parcel is underutilized, and the other is vacant. The site is near residential development and underutilized. This site has the same zoning as Examples #6, #7, and #8 on Table 11:
Development Trends, which are developing at an average of 21 units per acre, and similar characteristics (multiple parcels, site size) as Examples #4 and #5, which are developing at an average of over 50 units per acre.
Capacity: (15 units/acre)(3.87 acres)(85% realistic capacity)(80% factor for likelihood of residential development) =39.5 units, rounded down
RHNA Income Category: 20 moderate-income, 19 above moderate-income Units Infrastructure: Parcels are served by water, sewer, and dry utilities. Prior Use: Parcels were not used in a previous Site Inventory
3.3.3 Sites Suitability Analysis
Summary of Site Suitability
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Packet Pg. 484 Attachment: Exhibit B1 - Cotati Adoption Draft Housing Element (2023-03-20) (Housing Element CC Resolution) 64 The identified sites have realistic development potential and are suitable to count towards the City’s RHNA. Over 87% of the City’s lower-income RHNA is met through capacity of pipeline projects and ADU projections, with nonvacant sites used mainly to increase the City’s buffer of available sites. Available sites identified to meet the City’s lower-income RHNA have the necessary large sites analysis and will allow residential development at 20 units per acre.
Pending projects with identified lower-income capacity are likely to develop during the planning period, as discussed in Section 3.2.2, and the lower- and moderate-income units in those projects will be made affordable to the identified income groups through a deed restriction as required by the City’s Inclusionary Housing Ordinance and Density Bonus provisions or are assumed to be affordable to moderate-income units based on the Accessory Dwelling Unit analysis in Section 3.2.1. All identified sites have infrastructure access. Sites that have been used in previous planning periods that were identified to meet the City’s lowerincome RHNA are subject to a program to allow by-right development at 20 units per acre if 20% of the site’s units are affordable (Program 3-1). The City can accommodate over 50% of its lower-income RHNA with pipeline projects and ADU development.
Lower-Income Suitability Analysis
Sites 2 has been identified to meet the lower-income RHNA. Through implementation of Programs 3-1, this site will allow development at Cotati’s default density of 20 units/acre. This site has capacity to accommodate over 16 units.
Large Sites Analysis
While only 5.65 acres of the parcel are identified with development potential, Site 2 is located on a 10.07 acre parcel. Regionally, churches and other public institutions have expressed interest in selling excess vacant land to interested developers, and it is likely that this could happen on this site. This property owner has been approached by developers interested in developing a portion of their property. The City has current experience with development on a large site (Redwood Row, discussed in Section 3.2.2). The size of the parcel does not affect the suitability of the site to accommodate housing for lower-income households.
Nonvacant Sites Analysis
Sites 2 and 3 are nonvacant sites, identified as underutilized sites with development potential to meet the RHNA. Development potential was identified based on developer interest, developer trends, demand for residential compared to demand for current uses, any knowledge of existing contracts, improvement-to-land value, and other specific site conditions as follows:
Site 2: This site contains church facilities and parking lot, with over half of this site being undeveloped. The property owners, the Catholic Church, have expressed interest in residential development on this site, including in a meeting with City staff on January 18, 2023. There has been significant developer interest in the large vacant areas of the Northern Gateway zone, including this site, and owners of the adjacent parcel expressed interested in purchasing a portion of this site. Regionally, churches and other public institutions have expressed interest in selling excess vacant land to interested developers, and it is likely that this could happen on this site. There are no known contracts or leases that would prevent sale or development
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Packet Pg. 485 Attachment: Exhibit B1 - Cotati Adoption Draft Housing Element (2023-03-20) (Housing Element CC Resolution) 65 of the undeveloped half of the site. Additionally, recent legislation continues to facilitate the development of housing on lands owned by religious institutions, including the enacted AB 2244 (2022) mandating parking reductions on faith-based lands.
Site 3: This site includes two adjacent parcels, including one vacant parcel and one nonvacant parcel under the same ownership. The nonvacant site has a rural residential land use code, with no residential units shown on available data. The site appears to contain smaller old structures and automobile storage and has an improvement-to-land value of 0.17. Demand for residential development is higher than the demand for the current use and there are no known contracts or leases that would perpetuate the existing use. The site is adjacent to proposed, approved, and existing residential development.
Sites Allowing Non-Residential Uses
Sites identified with capacity to meet the RHNA that allow nonresidential and mixed-use developments are located in the Downtown Specific Plan area (Sites 1 and 2), and in the CG zone (Site 3). Based on development proposals over the last ten years, capacity factors have been applied to these sites to account for the likelihood of residential development compared to nonresidential development. Citywide, most sites allowing both residential uses and nonresidential uses have primarily received interest for residential development.
Within the Downtown Specific Plan Area, there have been 2 proposals for nonresidential development and 4 proposals for residential development over the last 10 years, so a capacity factor of 67% is applied to sites in these zones. Notably, purely residential development has not been a permitted use on these sites until the recent Downtown Specific Plan update, anticipated to be adopted Spring 2023, and through the implementation of Program 3-1. Once these changes are in place, it is anticipated that the proportion of residential proposals will increase.
Within the CG zone, there has been 1 proposal for nonresidential development and 4 proposals for residential development over the last 10 years, so a capacity factor of 80% is applied to sites in this zone.
Over 50% of the units to accommodate the very low and low-income housing need are identified within planned and approved projects.
Sites Used in Multiple Planning Periods
Sites 1 and 2 were used in multiple planning periods. Under Program 3-1, these sites will allow 100% residential development by right if 20% of units are affordable, allowing densities of at least 20 units per acre. This program will ensure that sites have realistic development potential within the planning period.
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Packet Pg. 486 Attachment: Exhibit B1 - Cotati Adoption Draft Housing Element (2023-03-20) (Housing Element CC Resolution) 66 3.4 PROGRAMS TO ASSIST IN THE DEVELOPMENT OF HOUSING Program 1-7: Essential Bond Financing Program
The City of Cotati, in partnership with local nonprofit Burbank Housing Development Corporation (Burbank), is pursuing use of an essential bond financing strategy for the development of affordable housing. In this model, the City joins a California Joint Powers Authority (JPA), authorizes the JPA to issue bonds on behalf of the City, and uses these funds for the construction of affordable housing. This is an innovative strategy that can help the City overcome financial constraints to housing development.
Program 2-1: Adequate Housing Sites
The City will continue to maintain an inventory of vacant and underdeveloped residentially designated land and, for sites appropriate for lower income and special needs development, identify the parcel number, parcel size, zoning designation, general plan designation, and allowed density with a density bonus for affordable units; ensure that the inventory is available for public distribution at City Hall and on the City’s website; and update the inventory on an annual basis.
Program 2-3: Accessory Dwelling Units
Accessory dwelling units (ADUs) are a priority for the development of housing in Cotati. The City will prioritize the availability of preapproved plans provided by the Napa Sonoma ADU Center, assist the efforts of the Napa Sonoma ADU Center and Homes for Sonoma, and provide penalty relief to ADU dwellers without the benefit of a permit to incentivize the development of ADUs and support for residents. The City will review the efficacy of these subprograms within two years and support further interventions to support both the ABAG-approved affordability assumptions and further ADU development in the community throughout the planning period.
Program 2-4: Cottage Housing
The City’s Cottage Housing Ordinance adopted in 2021 allows a doubling of density allowed in underlying zoning with Council approval of a Cottage Housing development plan. This requires the construction of smaller units that are affordable by design, and in return, provides more flexible requirements for housing development on smaller lots at a greater unit capacity.
Program 2-6: Santero Way Rezoning
The City is rezoning land within its Santero Way Specific Plan Area to increase the allowed residential capacity in Moderate Resource areas near transit. This program is not being used to meet the RHNA but will help the City meet its housing needs and address AFFH.
Program 2-7: Supporting Development on Inventory Sites
To support residential development to meet the RHNA, the City is committed to supporting ongoing development projects and to rezoning to increase residential capacity.
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Packet Pg. 487 Attachment: Exhibit B1 - Cotati Adoption Draft Housing Element (2023-03-20) (Housing Element CC Resolution) 67 Program 3-1: Sites Used in Multiple Planning Periods The City is relying on sites that have been used in the last two planning periods to meet its lower-income RHNA. In order to use these sites, the City will allow residential development by right at 20 units per acre when 20 percent or more of the units are affordable to lower income households. This program will apply to Sites 1 and 2.
Program 4-1: Anti-Displacement Actions
The City is relying on a nonvacant site that may have residential units to meet its RHNA. The City will require replacement housing units subject to the requirements of Government Code Section 65915(c)(3) when any new development occurs on a site in the Sites Inventory if that site meets any of the following conditions: a) currently has residential uses or within the past five years has had residential uses that have been vacated or demolished; and b) was subject to a recorded covenant, ordinance, or law that restricts rents to levels affordable to persons and families of low or very-low income; or c) subject to any form of rent or price control through a public entity’s valid exercise of its police power; or d) occupied by low or very-low income households. This program will address displacement risk on these sites.
3.5 DEVELOPMENT TRENDS AND REALISTIC CAPACITY
ANALYSIS
Realistic capacity assumptions have been calculated based on recent development, developer input, market trends, and local knowledge. Most recent residential projects in the City have developed at or above maximum allowable density, as shown in Table 11. The City also has examples of development on large and small sites, examples of mixed-use development, and development of affordable housing below the City’s default Density. The City is using a restrained realistic capacity factor of 85% to account for No Net Loss Requirements.
Table 11: Development Trends
#
Housing
Development APN Total Units Acres Zone
Max
Density
Density
Achieved
Percent
of Max
units/acre Density
Market Rate Housing with Affordable Units (All Projects 2018-2023) 1 Kessing Ranch
100 Valparaiso
(2018)
144-450-002 47 units:
2 VLI
2 LI
3 MI
40 AMI
9.6 NL 6 4.9 82%
2 Cottage
Housing
Project*
902 E. Cotati
Avenue
(Approved
2023)
144-302-030 6 units:
2 MI
4 AMI
0.23 NM 10 26.1 261%
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Packet Pg. 488 Attachment: Exhibit B1 - Cotati Adoption Draft Housing Element (2023-03-20) (Housing Element CC Resolution) 68 100% Affordable Housing (All Projects 2018-2023)
3 Jamie Lane
Unaddressed
Parcel
(2021)
144-301-012 5 units:
5 MI
0.63 NM 10 8 80%
4 La Plaza View*
100 East Cotati
Ave.
(Approved
2022)
144-274-002,
014 & 015
56 units:
45 LI,
11 MI
0.88 DSP
(LP)
N/A 63.6 N/A
Mixed Use Development with Affordable Units (All Projects 2018-2023) 5 Cotati Station*
Santero Way
(Approved
2022)
144-320-034
through -036
98 units:
8 VLI
3 LI
8 MI
79 AMI
2.41 SWSP N/A 40.7 N/A
6 Cotati Village*
NE Corner of
Hwy 116 &
Alder Lane
(Pending)
144-050-009 177
units:
18 VLI
159 AMI
7.19 CG 15 24.6 164%
7 Redwood Row*
Redwood Drive
and Gravenstein
Hwy
(Pending)
046-286-017,
-18, -19, and
-20
170
units:
4 ELI
4 VLI
8 LI
8 MI
145 AMI
10.4 1
CG 15 16.3 109%
8 Red's
Residential*
7515 Alder
Avenue
(Pending)
144-040-011 126
units:
4 ELI
10 VLI
112 AMI
5.62 CG 15 22.4 149%
Average 25.8 141%
*These projects are included in the discussion of Planned, Approved, and Pending projects in Section 3.2.2.
3.6 FAIR HOUSING CONSIDERATIONS
Housing sites identified to meet Cotati’s RHNA are distributed throughout the community in a manner that affirmatively furthers fair housing. Cotati contains Low and Moderate Resource areas. Of the 13 sites in inventory, 5 sites are in a Moderate Resource area (Figure 16), containing 17% of total unit capacity and 17% of lower-income unit capacity. A full analysis of inventory sites compared to components of the Fair Housing Assessment is included in the Technical Background Report, in Section 4.5.7.
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Packet Pg. 489 Attachment: Exhibit B1 - Cotati Adoption Draft Housing Element (2023-03-20) (Housing Element CC Resolution) 69 Figure 16: Housing Opportunity Sites by Opportunity Area Source: HCD/TCAC Opportunity Area Maps, 2022
3.6.1 Improved Conditions
Housing sites and pipeline projects are distributed throughout the City, with no concentration of sites for one income group. The sites will increase access to opportunity in and around the Downtown and near the train station and increase the stock of affordable housing.
3.6.2 Exacerbated Conditions
Sites on the Western side of the City are located in a Lower Resource area. Particularly, sites West of the freeway have less access to transportation and are further from amenities and resources. An infrastructure program is included to address this need (Program 1-4), and a rezoning program is included to add additional residential capacity in the City’s Moderate Resource area, near transit (Program 2-6).
3.7 INFRASTRUCTURE CONSIDERATIONS
The City has adequate infrastructure to accommodate the development of its RHNA, including water, sewer, and dry utilities. Infrastructure capacity is summarized below with a more detailed discussion of infrastructure included within the Technical Background Report.
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Packet Pg. 490 Attachment: Exhibit B1 - Cotati Adoption Draft Housing Element (2023-03-20) (Housing Element CC Resolution) 70 3.7.1 Water
Cotati’s main water supply comes from the Russian River surface water, and three groundwater wells located in Santa Rosa Plain Subbasin which are provided by Sonoma County Water Agency (SCWA) through two transmission pipelines. The City is entitled to receive up to 1,520 acre-feet per year under the water supply agreement with the SCWA. Cotati also obtains about 1/3 of its water supply from three municipal groundwater wells. While the City has historically used groundwater to supply more than half of its demands, its current water management strategy is to draw its primary water supply from the SCWA and utilize groundwater to supplement its needs during peak demand periods or periods of drought.
3.7.2 Sewer
The City of Cotati owns and operates the wastewater collection system and provides sanitary sewer service to approximately 1200 acres in and around City limits. Sewage and wastewater generated is transported to the Santa Rosa Subregional Wastewater Reclamation System for treatment at Laguna Treatment Plant. There is one sewer project identified in the Capital Improvement Program from Fiscal Year 2020/21 through FY 2024/25. The City completed a sewer project in 2020/21 on William and Olof Streets, and will continue construction on West Sierra Avenue in FY 2022/23. Methane capture and energy generation to offset energy usage occurs at the Santa Rosa Subregional Treatment Plant.
3.7.3 Other Utilities
Electricity: As of 2019, the City of Cotati uses 100% renewable electricity (Evergreen) provided by Sonoma Clean Power. The City opted into the local Community Choice Aggregation (Sonoma Clean Power), which automatically enrolled all residential and commercial customers into Clean Start (higher mix of local renewable electricity), unless the customer opts out into PG&E.
Solid Waste: The City of Cotati does not have any active or planned solid waste facilities.
Cotati is served by a franchise waste hauler (Recology), with solid waste disposed of at the Central Landfill in Sonoma County. Recycling and composting services are also included as part of the solid waste collection and processing system.
3.8 ENVIRONMENTAL CONSIDERATIONS
Sonoma County has developed a multijurisdictional hazard mitigation plan in partnership with local government to identify measures to reduce risk from natural hazards. The City of Cotati has its own local hazard mitigation plan, which was developed as an element of Sonoma County’s multijurisdictional plan.
According to hazard risk ranking, earthquakes and wildfires are categorized as high-risk hazards while floods, severe weather, and landslides are considered medium-risk hazards.
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Packet Pg. 491 Attachment: Exhibit B1 - Cotati Adoption Draft Housing Element (2023-03-20) (Housing Element CC Resolution) 71 3.8.1 Fire
There are 7 residential structures found in high relative hazard and 341 residential structures found in moderate relative hazard for wildfire. Wildland urban interface fires are prevalent in Sonoma County. No land within the City or inventory sites are within State-designated fire hazard severity zones. This is relatively minor in comparison to the region, and wildfire does not pose a substantial displacement risk in Cotati.
Figure 17: Fire Hazard Severity Zones
3.8.2 Seismic Hazards
Cotati has been exposed to earthquakes in the past and remains highly likely to be exposed in the future. The City is positioned southwest of the Rodgers Creek fault, a system with a 33% projected likelihood of a major earthquake (magnitude 6.7 or greater shaking) in the 30-year projection period. Seismic hazards mainly affect Site 3 but would not preclude development on this site. Cotati does not feature any known major fault lines running directly under City limits, unlike neighboring jurisdictions with faults including San Andreas and Rodgers Creek, and earthquakes do not pose a substantial displacement risk in Cotati.
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Packet Pg. 492 Attachment: Exhibit B1 - Cotati Adoption Draft Housing Element (2023-03-20) (Housing Element CC Resolution) 72 Figure 18: Earthquake Hazard Zones
Source: California Geological Survey, Earthquake Zones of Required Investigation Figure 19: Deep-Seated Landslide Susceptibility
Source: California Geologic Survey Data Viewer, CGS Map Sheet 58
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Packet Pg. 493 Attachment: Exhibit B1 - Cotati Adoption Draft Housing Element (2023-03-20) (Housing Element CC Resolution) 73 There are 63 residential structures identified in the high landslide exposure category and 301 residential structures in the moderate exposure category. The City’s Zoning Map concentrates development within portions of the urban core lacking hillsides and not susceptible to landslides.
3.8.3 Flood
The northeastern portion of Cotati is subject to flooding from the Laguna de Santa Rosa and Cotati Creek. Approximately 4.8 percent of the land within the city limits located within is subject to one percent of flooding in any given year and about 7.7 percent within the Urban Growth boundary are considered high flood hazards with the FEMA flood zone AE (a 100-year flooding scenario with base flood elevation determined). No sites are within the 100-year flood zone. The 500-year flood zone impacts sites 2 and 3 but does not preclude development on these sites.
Figure 20: Flood Hazard Zones
Source: FEMA, National Flood Hazard Layer, 2008
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Packet Pg. 494 Attachment: Exhibit B1 - Cotati Adoption Draft Housing Element (2023-03-20) (Housing Element CC Resolution) 74 The Downtown Specific Plan area is the only priority development area that has experienced localized flooding in the past, and no other areas are known to be susceptible to hazard risks.
Based on the 100-year scenario of flood risk assessment, 200 residential buildings may be exposed to flooding. Flood zones in Sonoma County have historically displaced communities directly along the Russian River and in other areas of the Russian River watershed with relatively minimal damage in Cotati. Flooding in Cotati does not pose a substantial displacement risk.
Among critical facilities, the City of Santa Rosa’s wastewater treatment plant (where Cotati wastewater is sent) has experienced significant flooding on several occasions and is likely to be exposed to flooding in the future.
3.8.4 Special Status Species
Some areas of Cotati are the native habitat of protected species, including the California tiger salamander (CTS). The Santa Rosa Plain Conservation Strategy (SRPCS) was published in 2005 and provides the biological framework for conservation of the CTS on the Santa Rosa Plain.
The designation of critical habitat, shown in Figure 21, was last revised in 2011 and does not include urbanized areas of Cotati, including the downtown and SMART Station area.1 Some inventory sites are located within the CTS range. Recent development and proposed projects within these areas demonstrate that CTS mitigation will not limit the ability to meet the RHNA using these sites.
1 Federal Register Volume 76, Issue 169, Endangered and Threatened Wildlife and Plants; Revised Designation of Critical Habitat for the Sonoma County Distinct Population Segment of California Tiger Salamander, 2011
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Packet Pg. 495 Attachment: Exhibit B1 - Cotati Adoption Draft Housing Element (2023-03-20) (Housing Element CC Resolution) 75 Figure 21: California Tiger Salamander Range
Source: California Department of Fish and Wildlife, California Tiger Salamander Range, 2020
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Packet Pg. 496 Attachment: Exhibit B1 - Cotati Adoption Draft Housing Element (2023-03-20) (Housing Element CC Resolution) 76 3.9 CONCLUSION
The City of Cotati is well positioned to successfully implement the policies, programs, and actions of this Housing Element. The 2023 Housing Element serves the housing needs of the next eight years for current and future residents and fulfills the statutory requirements of the State of California. The Housing Element demonstrates that the City has the housing sites and planned projects needed to address and surpass its Regional Housing Needs Allocation without the need to rezone sites. Moreover, the selected sites are integrated throughout the City with adequate distance from environmental hazards in consideration of existing and enhanced fair housing requirements. Programs have been identified to mitigate constraints to the production of housing, and to ensure that Cotati can continue to be an affordable and vibrant community for a wide variety of residents in the years to come.
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Packet Pg. 497 Attachment: Exhibit B1 - Cotati Adoption Draft Housing Element (2023-03-20) (Housing Element CC Resolution)
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Packet Pg. 498 Attachment: Attachment 1, Exhibit B2 - Cotati Adoption Draft Technical Background Report (Housing Element CC Resolution)
TABLE OF CONTENTS
4.1 INTRODUCTION.......................................................................... 1
4.2 HOUSING NEEDS DATA ............................................................... 1
4.2.1 Pre-Certified Housing Needs Dataset ..........................................1
4.2.2 Housing Needs Analysis ............................................................2 Housing Costs and Affordability......................................................2 Housing Affordability ....................................................................2 Senior Households........................................................................6 Persons with Disabilities, including Developmental Disabilities............8 Large Households....................................................................... 11 Farmworker Housing................................................................... 12 Female-Headed Households......................................................... 13 Homelessness............................................................................ 15
4.2.3 Zoning for a Variety of Housing Types ......................................17
4.3 LOCAL HOUSING PROGRAMS & RESOURCES ..............................25
4.3.1 Resources: Housing Assistance Programs..................................25 Federal Assistance Programs ....................................................... 25 State Assistance Programs .......................................................... 28 Local Assistance Programs........................................................... 30
4.3.2 Resources: Shelters, Transitional and Supportive Housing...........31
4.3.3 At-Risk Assisted Housing Developments....................................32
4.3.4 Planning and Zoning Incentives ...............................................32 Density Bonuses ........................................................................ 33 Affordable Housing ..................................................................... 33 Local Processing and Permit Fees ................................................. 33
4.4 HOUSING CONSTRAINTS ANALYSIS ..........................................35
4.4.1 Non-Governmental Constraints ................................................36 Vacant Land .............................................................................. 36 Land Costs ................................................................................ 36 Construction Costs ..................................................................... 36 Financing .................................................................................. 36 Development Trends................................................................... 37 Community Opposition................................................................ 38
4.4.2 Potential Governmental Constraints..........................................39 General Plan and Zoning Code ..................................................... 39 Density ..................................................................................... 42 Development Standards.............................................................. 43 Parking Requirements................................................................. 48 Growth Controls......................................................................... 49 Specific Plans............................................................................. 51 Streamlined & By-Right Development Applications ......................... 52
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Packet Pg. 499 Attachment: Attachment 1, Exhibit B2 - Cotati Adoption Draft Technical Background Report (Housing Element CC Resolution) Housing for People with Disabilities .............................................. 53 Building Codes and Enforcement .................................................. 53 Reasonable Accommodation ........................................................ 54 Development and Permitting Fees ................................................ 55 Local Processing and Permit Procedures ........................................ 57 Historic Preservation................................................................... 58
4.4.3 Environmental and Infrastructure Constraints ............................59 Environmental Constraints........................................................... 59 Infrastructure Constraints ........................................................... 67
4.5 Assessment of Fair Housing.......................................................68
4.5.1 Background and Summary of Fair Housing Issues ......................68 Housing Element Requirements.................................................... 69
4.5.2 Fair Housing Enforcement and Outreach Capacity.......................70 Compliance with Existing Fair Housing Laws & Regulations .............. 70 Fair Housing Services, Outreach, and Enforcement at a Local Level .. 73 Housing Enforcement and Outreach Capacity: Fair Housing Issues and Contributing Factors ................................................................... 75
4.5.3 Segregation and Integration Patterns and Trends.......................76 Race and Ethnicity...................................................................... 77 Persons with Disabilities.............................................................. 85 Familial Status ........................................................................... 87 Income ..................................................................................... 88 Poverty ..................................................................................... 94 Racially & Ethnically Concentrated Areas of Poverty (R/ECAP) and Affluence (RCAA) ....................................................................... 96 Integration and Segregation: Fair Housing Issues and Contributing Factors ..................................................................................... 97
4.5.4 Disparities in Access to Opportunities .......................................97 Resource Areas .......................................................................... 98 Education.................................................................................. 99 Access to Healthy Environment.................................................. 102 Transportation ......................................................................... 104 Economic Development and Job Access....................................... 109 Disparities in Access to Opportunity: Fair Housing Issues and Contributing Factors ................................................................. 113
4.5.5 Disproportionate Housing Needs, Including Displacement.......... 113 Cost Burden and Severe Cost Burden ......................................... 113 Overcrowding .......................................................................... 116 Substandard Housing................................................................ 118 Homelessness.......................................................................... 119 Displacement........................................................................... 119 Disproportionate Housing Needs and Displacement: Fair Housing Issues and Contributing Factors ........................................................... 122
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Packet Pg. 500 Attachment: Attachment 1, Exhibit B2 - Cotati Adoption Draft Technical Background Report (Housing Element CC Resolution)
4.5.6 Summary of Fair Housing Goals and Priorities Based on Identified Contributing Factors ..................................................................... 122
4.5.7 Housing Sites and AFFH Considerations .................................. 124 Segregation and Integration ...................................................... 126 Racially and Ethnically Concentrated Areas of Poverty................... 127 Disparities in Access to Opportunity............................................ 127 Disproportionate Housing Needs Including Displacement............... 127 TABLES
Table 1: Housing Cost Limits by Area Median Income Level................................ 3 Table 2: HCD Income Limits Sonoma County, 2022 .......................................... 3 Table 3: Sonoma County Median Hourly Wage by Occupation, 2020 .................... 4 Table 4: Cotati Household Income Level by Tenure ........................................... 4 Table 5: Cotati Cost Burden and Housing Problems by Tenure ............................ 5 Table 6: Senior Population by Age Group in Cotati ............................................ 7 Table 7: Senior Households by Age and Tenure in Cotati.................................... 7 Table 8: Senior Household Income Groups by Cost-Burden Levels in Cotati .......... 8 Table 9: Disability Type per Age Group in Cotati............................................... 9 Table 10: Household Size by Tenure............................................................. 11 Table 11: Large Households by Income Group ............................................... 12 Table 12: Household Size versus Bedroom Size by Tenure in Cotati................... 12 Table 13: Single Parent and Female-Headed (FH) Households in Cotati .............. 14 Table 14: Total Number of Homeless Persons in Cotati, by Shelter Status........... 15 Table 15: Residential Uses Allowed by Zoning District in Cotati ......................... 18 Table 16: Average Mortgage Interest Rates 2000 – 2022................................. 37 Table 17: Allowable Land Uses for Low Density and Neighborhood District Zones. 39 Table 18: Permit Requirements for Mixed Use Corridors, Downtown Specific Plan Districts, and Other Districts ....................................................................... 41 Table 19: City of Cotati Development Standards............................................. 44 Table 20: City of Cotati Parking Requirements ............................................... 48 Table 21: City of Cotati Permitting Fees ........................................................ 55 Table 22: Permitting Fees in Cotati and Comparable Local Jurisdictions .............. 56 Table 23: Timelines for Permit Procedures and Decision-Making Authority .......... 57 Table 24: Housing Resources for Cotati......................................................... 73 Table 25: Racial Isolation Index Values for Segregation within Cotati................. 82 Table 26: Racial Dissimilarity Index Values for Segregation within Cotati............ 82 Table 27: Theil’s H Index Values for Racial Segregation within Cotati................. 83 Table 28: Disability by Type, 2019 ............................................................... 85 Table 29: Disability Status by Race and Ethnicity, City of Cotati, 2015-2019 ....... 86 Table 30: Population by Income Group in Cotati and the Region........................ 90 Table 31: Income Group Isolation Index Values in Cotati (2010, 2015) and Average Bay Area Jurisdiction ................................................................................. 92
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Packet Pg. 501 Attachment: Attachment 1, Exhibit B2 - Cotati Adoption Draft Technical Background Report (Housing Element CC Resolution) Table 32: Income Group Dissimilarity Index Values for Segregation in Cotati ...... 92 Table 33: Poverty Status by Race in Cotati .................................................... 94 Table 34: Percent of Population Below Poverty Level for Whom Poverty Status is Determined in California, Sonoma County, and Cotati (2019) ........................... 96 Table 35: Cotati-Rohnert Park Unified District Student Demographics ...............101 Table 36: FDIC-Regulated Bank Branches by Sonoma County Municipality.........110 Table 37: Projected Change in Jobs and Employed Residents in Cotati between 2010 and 2040 ........................................................................................111 Table 38: Cost Burden Severity in Cotati, County, State .................................115 Table 39: Substandard Housing Issues ........................................................118 Table 40: Homeless Persons in Cotati by Shelter Status..................................119 Table 41: Prioritization of Contributing Factors ..............................................122 Table 42: Housing Sites and Segregation Indicators.......................................126 Table 43: Housing Sites and Access to Opportunity........................................127
FIGURES
Figure 1: Earthquake Zones of Required Investigation..................................... 61 Figure 2: Deep-Seated Landslide Susceptibility .............................................. 62 Figure 3: Earthquake Shaking Potential for California ...................................... 63 Figure 4: Flood Hazard Zones...................................................................... 64 Figure 5: Fire Hazard Severity Zones............................................................ 65 Figure 6: California Tiger Salamander Range ................................................. 66 Figure 7: Zoning Map of the City of Cotati ..................................................... 77 Figure 8: Population by Race in Cotati, 2000-2019.......................................... 78 Figure 9: Population by Race in Cotati, Sonoma County, and the Bay Area ......... 79 Figure 10: Racial Dot Map of Cotati .............................................................. 80 Figure 11: Racial Dot Map of Cotati and Surrounding Areas, 2020 ..................... 81 Figure 12: Levels of Segregation in Census Tracts within Sonoma County, 2018.. 84 Figure 13: Population with a Disability, Cotati ................................................ 86 Figure 14: Household Type in Cotati............................................................. 87 Figure 15: Percent of Children in Female-Headed Households ........................... 88 Figure 16: Percent of Children in Married-Couple Households............................ 88 Figure 17: Households by Household Income Level......................................... 89 Figure 18: Income Dot Map of Cotati, 2015 ................................................... 91 Figure 19: Map of Existing Affordable Rental Housing Projects in Cotati and Surrounding Area ...................................................................................... 93 Figure 20: Population by Poverty Status, 2019............................................... 95 Figure 21: Population by Poverty Status, 2014............................................... 95 Figure 22: Population Living in Resource Areas by Race in Cotati ...................... 97 Figure 23: TCAC Opportunity Maps (2022) – Composite Score.......................... 98 Figure 24: Population Living in Resource Areas by Race................................... 99 Figure 25: TCAC Opportunity Areas (2022) Education Score by Tract................100
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Packet Pg. 502 Attachment: Attachment 1, Exhibit B2 - Cotati Adoption Draft Technical Background Report (Housing Element CC Resolution) Figure 26: English Language Arts/Literacy Distribution – All Grades, 2018-2019.101 Figure 27: Mathematics Achievement Distribution – All Grades, 2018-2019 .......102 Figure 28: CalEnviroScreen 4.0 Percentiles by Census Tracts in Cotati ..............102 Figure 29: CalEnviroScreen 4.0 Percentiles by Census Tracts in the Region........103 Figure 30: Clean Environment Conditions in Cotati Compared to Other California Cities/Towns............................................................................................104 Figure 31: Sonoma-Marin Area Rail Transit (SMART) Service Corridor Map ........105 Figure 32: Sonoma County Transit System Map ............................................106 Figure 33: California Healthy Places Index: Transportation in Cotati .................108 Figure 34: Sonoma County Equity Priority Communities..................................109 Figure 35: TCAC Opportunity Areas (2021) Economic Scores in Cotati...............110 Figure 36: Inflow and Outflow of Workers in Cotati ........................................112 Figure 37: Ratio of All Jobs to Homes in Sonoma County Jurisdictions ...............113 Figure 38: Cost Burden by Tenure in Cotati, 2019..........................................114 Figure 39: Cost Burden by Income Level in Cotati..........................................115 Figure 40: Occupants Per Room for Households by Race and Ethnicity ..............117 Figure 41: Overcrowding Severity in Cotati, Sonoma County and the Bay Area...118 Figure 42: Urban Displacement Project Bay Area Model 2020 - Cotati ...............120 Figure 43: Urban Displacement Project Bay Area Model 2020 – North Bay Region .............................................................................................................121 Figure 44: Special Flood Hazard Areas (FEMA, 2020) in Cotati .........................122 Figure 45: Housing Sites and Resource Areas................................................125
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Packet Pg. 503 Attachment: Attachment 1, Exhibit B2 - Cotati Adoption Draft Technical Background Report (Housing Element CC Resolution) 1 Section IV: Technical Background Report
4.1 INTRODUCTION
This section of the Technical Background Report includes the required quantification and analysis of needs, identification, and analysis of the housing needs for special needs populations, and analysis of zoning for a variety of housing types. The Technical Background Report supplements the Housing Needs Data Report described below. Through the Housing Element, the City is planning to accommodate future population growth and address local housing needs.
Key information from this analysis is summarized in Section 1 of the Housing Element.
4.2 HOUSING NEEDS DATA
To meet all statutory requirements in Government Code § 65583(a) (1 and 2) related to quantification and analysis of existing housing needs, this Technical Background Report includes locally acquired information and data including areas of economic and ethnic segregation, special needs, local knowledge of the housing stock, local housing resources, and an analysis of housing constraints.
4.2.1 Pre-Certified Housing Needs Dataset
The Housing Needs Data Report provided by the Association of Bay Area Governments (ABAG) is included in Appendix A. This appendix contains a list of housing terms, regional housing needs allocation (RHNA) methodology, household characteristics, demographics of housing stock, and data on special needs populations. The data in this report was reviewed and pre-certified by the California Department of Housing and Community Development (HCD) in March 2021 and meets most of the requirements for quantification of existing and projected, including the following:
• Population, employment trends, and existing and projected housing needs for all income levels;
• Household characteristics, including level of payment compared to ability to pay, housing characteristics, including overcrowding (e.g., existing households, existing extremely low-income households, total, lower and extremely low-income households overpaying, overcrowded households); and;
• Special housing needs (e.g., number of persons with disabilities, number of persons with developmental disabilities, elderly households by tenure, large households by tenure, farmworkers, and female-headed households).
The remaining housing needs data requirements, including quantification of persons experiencing homelessness, estimation of the number of units in need of
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Packet Pg. 504 Attachment: Attachment 1, Exhibit B2 - Cotati Adoption Draft Technical Background Report (Housing Element CC Resolution) 2 rehabilitation and replacement, and projects at risk of converting to market-rate uses, are addressed within this Technical Background Report (Section 4). The section also contains other data related to local housing programs and resources, an analysis of housing constraints, and the assessment of fair housing.
4.2.2 Housing Needs Analysis
To meet all requirements of Government Code § 65583(a)(1)(2), this section includes data and analysis of the jurisdiction’s projected housing needs for special needs housing populations including the elderly, persons with disabilities (including developmental disabilities), large households, female-headed households, persons experiencing homeless and persons in need of emergency shelter, and agricultural workers. After identifying and analyzing these special housing needs, the City can provide resources and actions to accommodate and address diverse housing needs.
Housing Costs and Affordability
Housing affordability is a major consideration in providing suitable housing. The cost of housing itself is not a problem unless households in the area cannot find adequately sized units at an affordable price. Affordability is defined as paying 30% or less of gross monthly household income on housing costs, based on both State and Federal standards for households of lower income. The following section discusses current income levels and ability to pay for housing compared with housing costs. Since above moderate-income households do not generally have problems locating affordable units, affordable units are frequently defined as those reasonably priced for households that are very low- to moderate-income.
Housing cost is generally the single, greatest expense item for households. For owner-occupied households housing expenses consist of mortgage and interest payments, insurance, maintenance, and property taxes. For renter-occupied households housing expenses consist of rent and utilities. Higher-income households may choose to spend greater portions of their income on housing expenses and still have sufficient money left over for other expenses. However, many lower-income households must involuntarily spend a large share of their income on housing leaving them with less money for other expenses.
Housing Affordability
Table 1 shows the affordable housing cost guidelines established in Section 50052.5 and 50053 of the California Health and Safety Code. The guidelines are based on the median income calculated by the HCD income limits. As previously described, the generally accepted definition of housing affordability is for a household to pay no more than 30% of its gross annual income on housing. It should be noted that moderate-income households and above typically spend greater than 30% on household expenses; therefore, the threshold for overpayment is higher at approximately 35% of their income.
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Packet Pg. 505 Attachment: Attachment 1, Exhibit B2 - Cotati Adoption Draft Technical Background Report (Housing Element CC Resolution) 3 Table 1: Housing Cost Limits by Area Median Income Level Income Level Income Limit For Sale Rental
Extremely Low 0-30% AMI 30% of 30% of AMI 30% of 30% of AMI Very Low 31%-50% AMI 30% of 50% of AMI 30% of 50% of AMI Low 51%-80% AMI 30% of 70% of AMI 30% of 60% of AMI
Moderate 81%-120% AMI 35% of 110% of AMI 35% of 110% of AMI Source: HCD Income Limits, 2022.
HCD establishes household income limits to define households as extremely low-, very low-, low-, or moderate-income level. These income levels vary throughout the state and are based on the area median income of the region and adjusted based on the number of persons per household. The income limits for Sonoma County are shown on Table 2. A family of three with an annual income of $85,550 or less would be considered a low-income household:
Table 2: HCD Income Limits Sonoma County, 2022
Income Level
Persons Per Household
1 2 3 4 5 6
Extremely
Low (ELI) $25,000 $28,550 $32,100 $35,650 $38,550 $41,400 Very Low
Income (VLI) $41,600 $47,550 $53,500 $59,400 $64,200 $68,950 Low Income (LI) $66,550 $76,050 $85,550 $95,050 $102,700 $110,300 Median Income $78,950 $490,250 $101,500 $112,800 $121,800 $130,850 Moderate
Income $94,750 $108,300 $121,800 $135,350 $146,200 $157,000 Table 2 summarizes 2022 HCD-defined household income limits for extremely low, very low-, low-, and moderate-income households in Sonoma County (including Cotati) by the number of persons in the household and shows maximum affordable monthly rents and maximum affordable purchase prices for homes. Households earning the 2020 median income for a family of four in Cotati ($112,800) could afford to spend up to $33,840 a year, or $2,840 per month, on housing without being considered cost burdened.
Extremely low-income households have incomes at or below 30% of the area median income (AMI), adjusted for household size. In Sonoma County, the 2022 AMI for a four-person household is $112,800. A household of the same size with an annual income at or below $35,650 is considered extremely low-income (ELI). This income is equivalent to an hourly wage of $17.14, which may include farmworkers, cooks, and cashiers (Table 3). Additionally, many extremely low-income households are on fixed incomes with sources including disability benefits and social security.
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Packet Pg. 506 Attachment: Attachment 1, Exhibit B2 - Cotati Adoption Draft Technical Background Report (Housing Element CC Resolution) 4 Table 3: Sonoma County Median Hourly Wage by Occupation, 2020 Occupation Median Hourly Wage
Waiters and Waitresses $13.49
Cashiers $14.38
Retail Salesperson $16.07
Farmworkers and Laborers $15.94
Cooks, Restaurant $16.64
Sources: U.S. Bureau of Labor Statistics, Quarterly Census of Employment and Wages (QCEW), 2020 first quarter industry employment
There are an estimated 285 ELI households in Cotati, 10.1% of the City’s total households. This is a lower proportion than the larger Sonoma County, where 19.9% of households are extremely low-income. In Cotati, 12.3% of ELI households are homeowners, and 87.7% rent. In comparison, 56.3% of the City’s total households are homeowners and 43.7% rent.
Table 4: Cotati Household Income Level by Tenure
Income Level OwnerOccupied
RenterOccupied Total
0%-30% of AMI Extremely Low-Income (ELI) 35 250 285
31%-50% of AMI Very Low-Income (VLI) 159 180 339
51%-80% of AMI Low-Income (LI) 145 273 418
81%-100% of AMI 44 165 209
Greater than 100% of AMI 1,214 370 1,584
Total 1,597 1,238 2,835
Source: HUD, CHAS ACS Tabulation, 2013-2017 release
Extremely low-income households may be more likely to face housing problems and cost burden. Housing problems include a lack of complete kitchen facilities, lack of complete plumbing facilities, or overcrowding. Cost burden is the ratio of housing costs (rent or mortgage, utilities, taxes) to household income. HUD defines costburdened households as those whose monthly housing costs exceed 30% of monthly income, while severely cost-burdened households are those whose monthly housing costs exceed 50% of monthly income.
In Cotati, about 76% of extremely low-income renters experience housing problems, 78% are cost-burdened, and 58% are extremely cost-burdened, as shown in Table 5
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Packet Pg. 507 Attachment: Attachment 1, Exhibit B2 - Cotati Adoption Draft Technical Background Report (Housing Element CC Resolution) 5 below. ELI renters face greater housing problems and cost burden than ELI homeowners in Cotati.
Table 5: Cotati Cost Burden and Housing Problems by Tenure Total owners Total renters Total households
ELI Households 35 250 285
Any housing problem 25 190 215
Cost burden >30 % 19 195 214
Cost burden >50 % 15 145 160
VLI Households 159 180 339
Any housing problem 125 170 295
Cost burden > 30 % 125 165 290
Cost burden >50 % 45 100 145
LI Households 145 273 418
Any housing problems 30 265 295
Cost burden > 30 % 30 240 270
Cost burden >50 % 20 45 65
Source: HUD Consolidated Housing Affordability Strategy (CHAS), 2013-2017 ACS Many extremely low-income households seek rental housing and are likely to experience housing problems including cost burden, overcrowding, or substandard housing conditions. This can be exacerbated by stagnant wages and increasing cost of living that may result in the lack of adequate resources to meet basic daily needs.
ELI households may include multiple wage earners and typically include food service workers, full-time students, teachers, farmworkers, healthcare professionals, seniors, or adults with disabilities and special needs.
Housing types that can accommodate special needs populations include mobile homes, studios or one-bedroom units such as single-room occupancy units, and shared multi-bedroom homes.
Programs and Resources for Very and Extremely Low-Income Households Several existing and planned affordable housing complexes in Cotati include units that serve very low and extremely-low income households including:
• Charles Street Village, 47 affordable homes, Seniors, 2001 • Marvin Gardens, 37 affordable homes, Family, 1983
• Wilford Lane Apartments, 35 affordable homes, Special Needs, 2003 • Windwood Apartments, 28 affordable homes, Family, 1981
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Packet Pg. 508 Attachment: Attachment 1, Exhibit B2 - Cotati Adoption Draft Technical Background Report (Housing Element CC Resolution) 6 • Cotati Station, 8 very low-income rental units, approved in 2022 • Kessing Ranch, 2 very low-income, for sale units
• Three proposed projects will include very low-income units:
o Redwood Row, 9 very low-income units (170 total units) o Cotati Village, 18 very low-income units (177 total units) o Red’s Residential, 14 very low-income units (126 total units) Rooming houses, (Single Room Occupancies or SROs), are allowed under a use permit in the NU zone.
Within the 5th Housing Element planning cycle, 7 VLI units were permitted.
To address the remaining needs of extremely low-income households, the City is implementing the following policies and programs:
• Program 1-5: Preservation of Affordable Housing
• Program 2-6: Emergency Shelters, Transitional Housing, and Supportive Housing
• Program 3-2: Funding for Affordable and Special Needs Housing • Program 4-1: Anti-Displacement Actions
Senior Households
Households with individuals 65 years and older are considered senior households.
Seniors may experience challenges accessing or securing affordable housing while living on a fixed income. Increasing costs of living and healthcare can exacerbate existing issues related to disabilities, chronic health conditions, or reduced mobility.
Seniors who rent may be at greater risk of housing insecurity than homeowners and are more likely to be cost burdened.
Existing and Projected Needs of Senior Households
In 2019, 977 persons (13.1% of the City’s population) aged 65 years and older were recorded. The senior population increased by approximately 36.3% since 2013 whereas the City’s total population increased at a lesser rate of 2.1%. Table 6 identifies the senior population by age group and the associated percent change.
From 2013 to 2019, the 85 years and older age group significantly increased by 193%, and the 65 to 74 age group increased by 56.9%, and the 75 to 84 age group decreased by 16.8%.
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Packet Pg. 509 Attachment: Attachment 1, Exhibit B2 - Cotati Adoption Draft Technical Background Report (Housing Element CC Resolution) 7 Table 6: Senior Population by Age Group in Cotati
Age Group 2013 2019
Percent Change,
2013-2019*
Age 65-74 394 55.0% 618 63.3% +56.9%
Age 75-84 280 39.1% 233 23.8% -16.8%
Age 85+ 43 6.0% 126 12.9% +193%
Source: City of Cotati 5th cycle Housing Element; US Census Bureau, 2019*Note: (+) represents increases and (-) represents decreases in population size Senior households make up 22.3% of the total households in Cotati. Of the total senior households, 79.1% own their unit and 20.9% rent. Seniors who are 65-74 years make up about 70% of owner-occupied senior householders, as shown in Table 7 below. Since 2013, the number of owner-occupied senior householders has increased by 45.8% whereas renter-occupied senior householders have decreased by 16.2%. The increase in owner-occupied senior households is likely due to the aging in place of Cotati’s population.
Table 7: Senior Households by Age and Tenure in Cotati
Owner Renter
Number Percent Number Percent
Age 65-74 339 69.6 50 38.8
Age 75-84 86 17.7 64 49.6
Age 85+ 62 12.7 15 11.6
Total 487 100 129 100
Source: US Census ACS: 2019 5-Year estimates, Table B25007 In Cotati, 25.6% of seniors experience ambulatory difficulties followed by those with independent living difficulties (15.6%) and hearing difficulties (11.6%).
Half of the owner-occupied senior households earn above-moderate incomes and are less likely to experience cost burdens. Households that are not cost burdened pay 30% or less of their income on housing needs such as mortgage/rent, taxes, and utilities.
Low-income senior households who rent are most likely to experience severe cost burdens, paying more than half of their income towards housing expenses. Of total senior households who reported any cost burdens, 15% are severely cost burdened and may require assistance in rehabilitating their hoes to suit their changing needs such as handrails, ramps, flooring, etc. Rental subsidies also continue to be viable options for seniors to reduce housing costs and address their unique needs.
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Packet Pg. 510 Attachment: Attachment 1, Exhibit B2 - Cotati Adoption Draft Technical Background Report (Housing Element CC Resolution) 8 Table 8: Senior Household Income Groups by Cost-Burden Levels in Cotati Income group 0%-30% of Income
Used for Housing
30%-50% of
Income Used
for Housing
50%+ of
Income Used
for Housing
Total Percent
0%-30% of AMI 25 34 30 89 12.4
31%-50% of AMI 50 69 59 178 24.7
51%-80% of AMI 90 25 20 135 18.8
81%-100% of AMI 24 14 0 38 5.3
Greater than
100% of AMI 210 70 0 280 38.9
Total 399 212 109 720 100
Source: US HUD CHAS ACS Tabulation, 2013-2017 release
Programs and Resources for Senior Households
There are 47 units of senior housing and 15 beds of residential care and assisted living in Cotati:
• Charles Street Village (770 E. Cotati Avenue) – 47 units of lower-income senior housing
• Oaks of Hebron Sierra (405 W. Sierra Avenue) – 6 bed elderly residential care facility
• Sunset House (9408 Willow Ave) – 9 bed elderly assisted living facility To address the remaining needs of senior households, the City is implementing the following policies and programs:
• Program 2-4: Accessory Dwelling Units (ADUs)
• Program 3-2: Funding for Affordable and Special Needs Housing Persons with Disabilities, including Developmental Disabilities State law defines disability as a “physical or mental impairment that makes performance of a major life activity difficult” (CA Dept of Fair Employment and Housing, 2022). Physical and mental impairments can include chronic or episodic conditions such as HIV/AIDS, hepatitis, epilepsy, seizure disorder, multiple sclerosis, heart disease, and other similar conditions. Individuals with these conditions are protected under various State laws, such as the Prudence K. Poppink Act and Fair Employment and Housing Act. Individuals with mental, physical, or developmental disabilities need accessible, safe, and affordable housing close to medical care or supportive services. Individuals with disabilities typically live on fixed incomes, limiting their ability to pay for housing.
Housing Element law, as amended by SB 812 (2021) requires jurisdictions to evaluate special housing needs for individuals experiencing developmental disabilities. A
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Packet Pg. 511 Attachment: Attachment 1, Exhibit B2 - Cotati Adoption Draft Technical Background Report (Housing Element CC Resolution) 9 developmental disability is defined in the Lanternman Act as an impairment that “originates before an individual attains 18 years of age, continues or may continue indefinitely, and constitutes a substantial disability for that individual” and includes mental retardation, cerebral palsy, epilepsy, and autism.
Existing and Projected Needs of Persons with Disabilities In Cotati, 10% of the population (1,581 individuals) reported having a disability, including developmental disabilities. The proportion of disabled residents is lower than Sonoma County overall, and individuals with disabilities have decreased from 17% in 2013 (Source: 5th Cycle Housing Element). Among disability types, 5.6% experience cognitive difficulties, 5% experience ambulatory difficulties, and 4% experience independent living difficulties. Most youth with disabilities live at home with a parent or guardian.
Disabled renter households reported a higher incidence of housing problems, such as overcrowding, overpayment, or lacking full kitchen or plumbing facilities than nondisabled owner households.
Table 9: Disability Type per Age Group in Cotati
Disability Type Under 5*
years
5-17*
years
18-34
years
35-64
years
65-74
years
75+
years
Total
Hearing difficulty 0 0 0 91 45 68 204
Vision difficulty 0 0 0 42 23 28 93
Cognitive difficulty 8 168 149 46 47 417
Ambulatory difficulty 0 17 104 141 109 371
Self-care difficulty 0 28 52 12 48 140
Independent living
difficulty - - 69 79 60 92 300
Developmental
Disability 22 34 56
Source: US Census Bureau, S1810 Disability Characteristics, 2019: ACS 5-Year Estimates; California Department of Developmental Services, 2020
* The number of individuals experiencing cognitive, ambulatory, and self-care difficulties represent age groups 17 and younger.
Programs and Resources for Persons with Disabilities
In Cotati, there are 83 units of affordable housing that support disabled households:
• Charles Street Village (770 E. Cotati Avenue) – 47 units of lower income senior housing, including units accessible to senior disabled households. • Wilford Lane Village (160 Wilford Lane) – a 36-unit family apartment community, includes several units that were designed to accommodate disabled persons with special needs.
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Packet Pg. 512 Attachment: Attachment 1, Exhibit B2 - Cotati Adoption Draft Technical Background Report (Housing Element CC Resolution) 10 Based on 2019 ACS data, 10% of households in Cotati had a disabled member.
Applying this figure to the 6th Cycle RHNA, approximately 23.4 new households will have one or more disabled members through 2033, including at least. Based on 2019 ACS data, 4.0% of persons in Cotati have an independent living or self-care disability.
Applying this figure to the RHNA, approximately one with special housing needs that require a supported living environment.
Households with a disabled member will require a mixture of housing units with accessibility features, in‐home care, or group care housing facilities. Some of these households will have a member with developmental disability who may also have special housing needs. The North Bay Regional Center (NBRC) indicated that developmentally disabled persons may live with a family in a typical single family or multifamily home, but some developmentally disabled persons with more severe disabilities may have special housing needs that may include extended family homes, group homes, small and large residential care facilities, intermediate care, or skilled nursing facilities. Most of these persons will be low income and will need affordable housing such as extremely low/very low/low-income housing (both rental and ownership), Section 8/Housing Choice Vouchers, and single room occupancy units.
Regionally, the NBRC provides services and housing opportunities for individuals with disabilities in Sonoma County and provides in-home family support services for adults with disabilities to assist with daily needs and activities. Other local and regional resources and programs for individuals with disabilities include:
• North Bay Industries – located in Rohnert Park, provides supportive employment programs and affordable housing for adults with disabilities. • United Cerebral Palsy (UCP) of the North Bay – children and young adult education, integrated employment, and recreational activities. • First 5 Sonoma County – programs and resources for parents and children from prenatal stage to five years.
• Allied Integration Services – adult day programs including vocational training, skill-building, and behavioral management.
To address the remaining needs of households with disabilities, the City is implementing the following policies and programs:
• Program 3-2: Funding for Affordable and Special Needs Housing • Program 4-4: Reasonable Accommodation
• Policy H-3.6: Continue to facilitate accessible universal design in new housing development and eliminate further barriers to safe and accessible housing for people with disabilities
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Packet Pg. 513 Attachment: Attachment 1, Exhibit B2 - Cotati Adoption Draft Technical Background Report (Housing Element CC Resolution) 11 Large Households
Large households typically comprise of five or more persons residing together. This may include multiple generations and/or extensions of a family, multiple families, students, or other non-related household members. Large households serve a unique need in that householders may want to save money due to the high cost of living, share responsibilities for religious or cultural reasons, serve a member with disabilities, among other living arrangements including co-housing communities, intentional communities, group homes, employee housing, fraternities, sororities, and communes. While all housing units with three or more bedrooms can serve large households, some larger and multi-generational households may require more bedrooms to avoid overcrowding.
Existing and Projected Needs of Large Households
In Cotati, large families make up 12.2% of total households and have more than doubled in the 5th Housing Element Cycle. Tenure among large households is 48.5% owner-occupied and 51.5% renter-occupied units. More than half of larger families are at above-moderate income levels and roughly one third of larger families are at low to extremely low-income levels. Lower- and moderate-income large households may have difficulty accessing affordable rental housing.
Large families can have a difficult time finding housing units large enough to meet their needs. In Cotati, there appears to be an adequate amount of housing units available to provide units with enough bedrooms both for larger households that own their home and that rent. Table 10 identifies the number of large households by household size. While there appear to be adequate units in Cotati to accommodate all large owner and renter households, it does not mean that there is a match between housing units and large families. Consequently, a lack of units available to large households is cited as a contributing factor to fair housing issues.
Table 10: Household Size by Tenure
Household Size Owner-occupied
households
Renter-occupied
households
All households
1-person 449 308 757
2-person 448 312 760
3-person 292 237 529
4-person 211 165 376
5 or more-person 163 173 336
Total 1,563 1,195 2,758
Source: U.S. Census Bureau, ACS 5-Year estimates, Table B25009, 2019
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Packet Pg. 514 Attachment: Attachment 1, Exhibit B2 - Cotati Adoption Draft Technical Background Report (Housing Element CC Resolution) 12 Table 11: Large Households by Income Group
Income Group All other household types Larger families of 5+ people
Total
0%-30% AMI 264 10 274
31%-50% AMI 343 10 353
51%-80% AMI 379 45 424
81%-100% AMI 177 34 211
Greater than 100% AMI 1,450 139 1,589
Source: U.S. Department of Housing and Urban Development (HUD), Comprehensive Housing Affordability Strategy (CHAS) ACS tabulation, 2013-2017 release
Table 12: Household Size versus Bedroom Size by Tenure in Cotati Tenure
5 Person Households 6 Person or Larger Households
3 BDR
units Households Shortfall/ Excess 4+ BDR units Households Shortfall/ Excess Owner 649 138 511 415 25 390
Renter 438 102 336 129 71 58
Total 1,087 240 175 544 96 448
Source: U.S. Census Bureau, 2019 ACS 5-Year estimates, Tables B25009, S2504, DP04 Programs and Resources for Large Households
To address the remaining needs of large households, the City is implementing the following policies and programs:
• Program 2-4: Accessory Dwelling Units (ADUs)
• Program 3-2: Funding for Affordable and Special Needs Housing • Program 4-6: Culturally Appropriate Facilitation and Involvement Farmworker Housing
Statewide, farmworker housing is of unique concern and importance. Farmworkers are essential to the region’s economy and its food supply. According to the United States Department of Agriculture (USDA) 2017 Census of Agriculture, only 18% of Sonoma County’s farmworkers are migrant workers, with 82% of farmworkers considered settled and working farm(s) within 75 miles of their residences. Of the County’s 3,594 farms counted in 2017, 48% hired farm labor, 93% were considered family farms, and 44% of farms were smaller than 10 acres.
Existing and Projected Needs of Farmworkers
The 2019 ACS 5-Year Estimate identified approximately 153 Cotati residents employed in farming, fishing, and forestry occupations, representing 3.8% of the City workforce and 2.08% of Sonoma County farmworkers.
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Packet Pg. 515 Attachment: Attachment 1, Exhibit B2 - Cotati Adoption Draft Technical Background Report (Housing Element CC Resolution) 13 Per the Sonoma County Farmworker Health Survey 2013-2014, the “majority of farmworkers (88%) reported that Sonoma County was their permanent residence, and most (71%) farmworkers were living in the US with their families.” Farmworker families were estimated to spend between 30% and 54% of their annual income on housing. Two-thirds of farmworkers lived in overcrowded dwellings in Sonoma County, and farmworkers who lived with their families were the most likely to live in overcrowded conditions.
In 2021, the local newspaper printed a special report about low-wage earners living in Sonoma County, saying, “many are farmworkers… who live in cramped apartments with too many people, or sheds with only a chemical toilet, or tiny mobile homes with leaking roofs or backed-up sewage pipes...”1 Although the data does not indicate a specific need for farmworker housing among Cotati residents, this is a significant regional need.
Programs and Resources for Farmworkers
Various programs are available in the region to meet the needs of farmworkers. These include:
• California Rural Legal Assistance, provides legal aid with civil cases for lowincome people, farmworkers, and migrant communities • La Luz Center, provides rental assistance, tenant support, and access to food, counseling, education, and health resources to eligible residents To address the remaining needs of farmworkers, Cotati is implementing the following program(s):
• Program 3-1: Zoning for a Variety of Housing Types
• Program 3-2: Funding for Affordable and Special Needs Housing Female-Headed Households
Single parent households are households with children under the age of 18 at home and include both male and female‐headed households. These households generally have a higher ratio between their income and their living expenses (that is, living expenses take up a larger share of income than is generally the case in two‐parent households). Finding affordable, decent, and safe housing is often more difficult for single parent and female-headed households. Additionally, single parent and femaleheaded households have special needs involving access to daycare or childcare, health care and other supportive services.
Existing and Projected Needs of Female-Headed Households Forty-five percent of Cotati households are headed by a single people. There are 438 single-male heads of household (15.9%) and 811 single-female heads of household (29.4%). Table 13 identifies single-parent households by gender of the householder 1 Many live in squalid conditions to work in Sonoma County, Press Democrat, November 18, 2021
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Packet Pg. 516 Attachment: Attachment 1, Exhibit B2 - Cotati Adoption Draft Technical Background Report (Housing Element CC Resolution) 14 and presence of children. In Cotati, while 4.4% of families overall are under the poverty level, 57.5% of female-headed households are under the poverty level. Area Median Income (AMI) of 18% or less is considered poverty, as defined by the California Poverty Measure. As Cotati’s population and households grow, there will be a continued need for supportive services for single-parent households with children present.
Table 13: Single Parent and Female-Headed (FH) Households in Cotati Household type Number Percent of Total Households
Total households 2,758
Total FH households 811 29.4
FH householder w. children
under 18, no spouse
113 4.1
Male householder w. children
under 18, no spouse
16 0.6
FH households living alone 455 16.5
Total families under the poverty
level
120 4.4
FH households under the
poverty level, no spouse
No child
1 or 2 children
3 or 4 children
69 29
24 16
2.5 Source: US Census Tables B17012 & DP02 2019: ACS 5-Year estimates – acc. 6/1/22 Programs and Resources for Female-Headed Households
Female-headed households under the poverty level may need additional resources related to job training, childcare, and health care coverage. State and County programs are available to assist low-income families and single-parent families, including the following:
• SonomaWORKS provides temporary help for families with children who have little or no money. This may include housing, food, utilities payments, childcare or medical care, job training, legal services, and mental health services. • Medi-Cal and the County Medical Services Program provide health care coverage for eligible residents.
• CalFresh and WIC help eligible residents afford food and access information about nutrition and health.
For families at risk of homelessness, available resources include the following:
• 2-1-1 is a local hotline that provides information about a variety of services in Sonoma County, including housing, shelter, and food.
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Packet Pg. 517 Attachment: Attachment 1, Exhibit B2 - Cotati Adoption Draft Technical Background Report (Housing Element CC Resolution) 15 • SHARE Sonoma County is a local service provider that matches home-seekers who are either homeless or at-risk of homelessness with home-providers that have an extra room in their house.
To address the remaining needs of female-headed households, the City is implementing the following program:
• Program 4-3: Nondiscrimination & Fair Housing Information Homelessness
Homeless individuals and families have perhaps the most immediate housing need of any group. They also have one of the most difficult sets of housing needs and support services to meet, due to both the diversity and the complexity of factors that lead to homelessness. The Department of Housing and Urban Development defines homelessness as any “individual or family who lacks a fixed, regular, and adequate nighttime residence.” This also includes those at risk of being homeless, those fleeing domestic violence, those who have no other residence, and those who lack the resources to obtain permanent housing. In California, those who have reported experiencing chronic homelessness have increased by 20% between 2020 and 2021.2 Existing and Projected Needs of Persons Experiencing Homelessness According to the 2020 Point-in-Time Census, there was an estimated total of 37 homeless persons in Cotati, all of which were unsheltered. In Sonoma County, there are a total of 2,745 reported individuals experiencing homelessness, which represents a 7% decrease in homeless persons since 2019. The causes of homelessness are complex and often based on inter-related factors. In Sonoma County, the primary causes of homelessness, as reported by the 2020 Sonoma County Homeless Census Comprehensive Report, were lost job (22%), alcohol or drug use (16%), argument with family or friend (15%), and fire (10%). Obstacles to obtaining permanent housing, from highest reported to lowest reported, include unable to afford rent (70%), no job or not enough income (50%), no money for moving costs (31%), no housing availability (20%), and no transportation (17%).
Of those experiencing homelessness in the County, the majority (63%) are men and white. The number of homeless individuals who are sheltered in Sonoma County increased by 5% between 2019 to 2020. The amount of homeless youth (18-24) and seniors (61+) has increased since 2016.
According to the 2020 Sonoma County Homeless Census Comprehensive Report, the number of those who are homeless and unsheltered in Cotati increased dramatically between 2018 to 2019 (Table 14) but decreased since then.
Table 14: Total Number of Homeless Persons in Cotati, by Shelter Status 2018 2019 2020
2 2021 Annual Homeless Assessment Report (AHAR) to Congress
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Packet Pg. 518 Attachment: Attachment 1, Exhibit B2 - Cotati Adoption Draft Technical Background Report (Housing Element CC Resolution) 16 Unsheltered 1 44 37
Sheltered 0 0 0
Total 1 44 37
Source: 2020 Sonoma County Homeless Census Comprehensive Report Programs and Resources for Persons Experiencing Homelessness Emergency shelters are allowed by-right in the General Commercial District and the Public Facilities District of Cotati. Emergency shelters are allowed within the Downtown Specific Plan area, subject to the permit requirements and standards of the Downtown Specific Plan. North House on Old Redwood Highway in Cotati is a 8- unit transitional housing facility serving homeless and mentally disabled adults. “A Step Up – Cotati” is a 11-bed transitional home serving adults with addiction and behavioral health issues.
Cotati has two housing facilities operated by Community Support Network that serve populations that are homeless or at-risk of homelessness. • North House – 8050 Old Redwood Highway: Eight-bed residential Transitional Training Program for mentally ill, homeless adults. There is minimal supervision and services focus on helping clients assess their own skills and abilities relating to independent living stabilization. Clients can stay up to eight months.
• A Step Up – 420 East Cotati Avenue: Eleven-bed facility providing dual diagnosed adults (mental illness with alcohol and/or other drug issues) the opportunity to improve physical and emotional health and develop positive habits that can speed up their path to recovery and self-sufficiency. Clients can stay up to twelve months.
Cotati partners with the Committee on the Shelterless (COTS) shelter and housing programs, which provide emergency and transitional shelter and permanent housing for the homeless. Some of the programs include Integrity Housing, Permanent Supportive Housing (PSH), and the Rapid Rehousing (RRH) program.
A list of regional housing resources is provided for those experiencing homelessness at the Homeless Shelter Directory, including:
• Sonoma County Behavioral Health
• Community Support Network
• The SAY Dream Center For Youths
• The Living Room Day Shelter For Women
• The Rose - Women with Children Emergency Shelter
• Redwood Gospel Mission
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Packet Pg. 519 Attachment: Attachment 1, Exhibit B2 - Cotati Adoption Draft Technical Background Report (Housing Element CC Resolution) 17 • Catholic Charities Homeless Services Center
• Family Support Center
• Sloan House Women's Emergency Shelter
• Community Support Network Opportunity House
• InterFaith Shelter Network
To address the remaining needs of homeless individuals, the City is implementing the following policies and programs:
• Program 2-5: Continuum of Care and Crisis Response - Seek funding to support transitional and supportive housing.
• The City of Cotati has greatly expanded its relationship with local non-profit organizations and service providers, through participation with the CDC and separately to meet the various needs of the un-housed population. This has resulted in three units of transitional housing being purchased within the City, with management of these services being led by CDC staff. • Program 3-2: Planning for Affordable and Special Needs Housing – Develop a housing stakeholders group that includes affordable housing developers and special needs group stakeholders to discuss needs and priorities. • The City's Land Use Code requires 10% of all units in new subdivisions to be single story and universally accessible to allow for full conversions in the future if needed/wanted. The City's objective design guidelines also require multifamily housing projects to incorporate 10% of the units as accessible. • Program 3-3: Funding for Affordable and Special Needs Housing – Seek available funding for lower income and special needs housing. • Program 1-1: Housing Rehabilitation and Home Ownership • Over the 5th Cycle, the CDC applications for these funding sources has primarily focused on addressing homelessness and infrastructure deficiencies.
• Policy H-3-9: Coordinate with regional and local service groups to facilitate linkages between at-risk individuals and families, and organizations that provide support services.
4.2.3 Zoning for a Variety of Housing Types
This section provides an analysis of zoning and availability of sites for a variety of housing types pursuant to Government Code § 65583(a)(4), 65583(c)(1), and 65583.2(c). The City provides for a range of housing types within its Zoning Code, as demonstrated in Table 15 below, including single-family, multi-family, accessory dwelling units, mobile and manufactured homes, residential care facilities, emergency shelters, supportive housing, transitional housing, single-room occupancy living units, boarding/rooming houses and family daycare homes.
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Packet Pg. 520 Attachment: Attachment 1, Exhibit B2 - Cotati Adoption Draft Technical Background Report (Housing Element CC Resolution) 18 Additional information related to the permitting requirements, allowed densities, and development standards for each type of housing and zoning designation can be found in Section 4.4.2, Potential Governmental Constraints. Because Cotati is small town of mature neighborhoods it has limited availability of sites across all zoning districts discussed. State laws such as SB 478 (2021) promote the creation of “missing middle” housing such as live/work units, multiplexes, townhomes, bungalow courts, and other housing types by allowing more flexibility in size and shape of new, smallscale development (Terner Center, 2019).
This Housing Element includes a program for the City to allow an increased variety of housing types such as live-work studios. The City is actively processing and permitting projects that address the community’s housing needs, including many of the housing types analyzed here. Additionally, during 2022 the City is updating the Downtown and Transit Oriented Zoning to allow better allow for infill residential development.
Table 15: Residential Uses Allowed by Zoning District in Cotati Zoning Map
Symbol Name of Zoning District
General Plan Designation
Implemented
by Zoning District
Maximum density/dwelling units
to accommodate
RR Rural Residential Rural One unit per 1 or 1.5 acre
RVL Residential Very Low
Density
Low-Density Residential One unit per 0.5 to 0.66 acre
NL Neighborhood, Low
Density
Low-Medium Density
Residential
6 units per acre
NM Neighborhood, Medium
Density
Medium Density Residential 10 units per acre
NU Neighborhood, Urban High-Density Residential 15 units per acre Mixed Use Corridor and Downtown Zones
CE Commercial, East Cotati
Ave. Corridor
Office, General Commercial 15 units per acre
CD Downtown Commercial General Commercial, La
Plaza Specific Plan
15 units per acre
CA Commerce Avenue Downtown Specific Plan3 61 dwellings NG Northern Gateway Downtown Specific Plan 229 dwellings HC Historic Core Downtown Specific Plan 71 dwellings
LP La Plaza Downtown Specific Plan 89 dwellings
Special Purpose and Overlay Zones
3 Downtown Specific Plan area has no density limits. The plan establishes a maximum number of residential units that can be developed within the zones of the Specific Plan area.
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Packet Pg. 521 Attachment: Attachment 1, Exhibit B2 - Cotati Adoption Draft Technical Background Report (Housing Element CC Resolution) 19 Zoning Map
Symbol Name of Zoning District
General Plan Designation
Implemented
by Zoning District
Maximum density/dwelling units
to accommodate
CP Coordinated Planning
Overlay
All
MHP Mobile Home Park
Overlay
All Residential determined by the primary
zone of the affected site
PF Public Facility Public Facilities
SPSW Specific Plan, Santero
Way
All No maximum
SPD Specific Plan, Downtown General Commercial,
Residential, Parks
No maximum
Source: https://www.codepublishing.com/CA/Cotati/html/Cotati17/Cotati1720.html Single- and Multifamily Rental Housing
Single- and multifamily housing types include detached and attached single-family homes, duplexes, triplexes, townhomes, condominiums, and rental apartments.
Single-family dwellings are permitted in the RR, RVL, and NL zones, and in the NM and NU zones with a use permit. Multifamily housing of 5-9 units is allowed with a use permit in the NM and NU zones. Multifamily housing with 10 or more units is permitted in SPSW zone and is permitted with a use permit in the NU zone.
Residential components of mixed-use projects are a permitted use in the CE, CG, CD, HC, LP, NG, CA, and SPSW zones. Zones allowing multifamily housing are generally adjacent to medium and low density residential areas, with many areas near major thoroughfares or the train station.
According to the 2020 ACS 5-year estimates, there are 2917 housing units in Cotati. Single-family detached and attached account for most Cotati housing stock, consisting of 55.3% (1613 units) and 13.1% (382 units) respectively. Duplexes, triplexes, and fourplexes comprise 5.7% (166 units) and multi-family complexes with five or more units comprise 19.9% (580 units) of the housing stock.
Housing for Agricultural Employees
According to the 2020 ACS 5-year estimate, 3% of Cotati’s residents (124 people) were employed in the agriculture, forestry, fishing/hunting, and mining industries.
There is no farmworker data specific to the City, but there are agricultural lands that would require farmworker employment within the City limits. While there is a significant amount of agricultural production in Sonoma County and demand for farmworker housing in the unincorporated areas of the county as well as communities with agricultural land, there are no parcels in Cotati currently designated for agricultural use. Agricultural uses, such as crop production, horticulture, vineyard, and orchard use may be allowed in the Rural Residential zone subject to the issuance of a use permit.
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Packet Pg. 522 Attachment: Attachment 1, Exhibit B2 - Cotati Adoption Draft Technical Background Report (Housing Element CC Resolution) 20 Cotati’s Zoning Code allows employee housing that accommodates up to six employees, considered as a single-family use and subject to the same standards and permit requirements as a single-family residence in all zones that allow single-family uses, and is compliant with CA Health and Safety Code Section 17021.5. Under Program 3-1 (Zoning for a Variety of Housing Types), the City will amend its Code to allow housing consisting of no more than 36 beds in group quarters (or 12 units or less) designed for use by a single family or household to be treated as an agricultural use, as required by CA Health and Safety Code Sections 17021.6.
Emergency Shelters and Low Barrier Navigation Centers
According to the Health and Safety Code, emergency shelters are housing with minimal supportive services for homeless persons that are limited to occupancy of six months or less by a homeless person. Local agencies are required to identify a zone where emergency shelters are allowed as permitted use without a conditional use or another discretionary permit. Emergency shelters are allowed in the Downtown Commercial (CD) District and the Public Facilities (PF) District of Cotati. The City also allows establishment of emergency shelters in the Downtown Specific Plan area, subject to the permit requirements and standards of the Downtown Specific Plan.
Sites zoned PF are scattered throughout the City, with CD and Downtown Specific Plan areas located near the center of the City, with better access to transit and amenities. These sites have sufficient capacity to meet the need for emergency shelter, as shown in Table 16. In addition to these vacant sites, there is potential for reuse and redevelopment of existing buildings as emergency shelters.
Table 16: Sites with Capacity for Emergency Shelter
APN Zoning District Acres Current Use
144-261-003 CD 0.15 Vacant
144-274-007 CD 0.17 Vacant
Total 0.32
Calculated using the standards of AB 2339 (2022): 37 people in need of emergency shelter x 200 sq.ft per person = minimum of 0.17 acres needed
Under State law, the City may apply certain written objective development and management standards for homeless shelters. Cotati’s Zoning Code includes the following standards for homeless shelters:
• Occupancy. The maximum number of beds or persons permitted to be served nightly by an emergency shelter, or any combination of emergency shelters in the city, shall not exceed twenty persons.
• Length of Stay. Occupancy for an individual in an emergency shelter is limited to no more than six months. The operator of the emergency shelter shall maintain adequate documentation to demonstrate compliance with this provision.
• Location. No emergency shelter shall be located within three hundred feet of another emergency or homeless shelter.
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Packet Pg. 523 Attachment: Attachment 1, Exhibit B2 - Cotati Adoption Draft Technical Background Report (Housing Element CC Resolution) 21 • Management Plan. Prior to the director’s decision, the operator of the emergency shelter must submit to the community development department a written management plan. As a minimum, the management plan shall include and address the following:
o Procedures for staff training to meet the needs of the shelter residents, and have processes to address the following topics:
client intake, confidentiality, health and safety training, mental health, and substance abuse treatment and referrals;
o Operational rules and standards of conduct for residents, including policies prohibiting the use or possession of controlled substances by residents, rules concerning the use or possession of alcohol, curfew, prohibition of loitering, and any other provisions necessary to ensure compatibility with surrounding uses;
o Policies and procedures for eviction from the facility for violation of rules and standards of conduct;
o A detailed safety and security plan to protect shelter residents and surrounding uses;
o A process for resident screening and identification;
o Provisions for on-site or partnerships with off-site organizations to provide job training, counseling, and treatment programs for the residents;
o Services to assist residents with obtaining permanent shelter and income;
o If applicable, timing and placement of outdoor activities; o Location within the facility for temporary storage of residents’ personal belongings;
o Provisions for continuous on-site supervision during hours of operation. Specifically, there shall be a minimum of one staff person per eight clients during daytime hours, seven a.m. to nine p.m., and a minimum of two staff people at the facility during nighttime hours, nine p.m. to seven a.m.;
o If applicable, procedures for ensuring safety and security of women and children within the facility;
o The exterior of the building must be kept in a good state of repair and the exterior finish and landscaping must be kept clean and well maintained. Each site shall be kept in a neat and orderly manner, free of weeds, loose trash, debris and other litter, including but not limited to shopping carts;
o Organized outdoor activities on the site may only be conducted between the hours of eight a.m. and nine p.m.;
o Employees, partners, directors, officers, managers and similar persons shall be screened prior to occupancy to confirm that they
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Packet Pg. 524 Attachment: Attachment 1, Exhibit B2 - Cotati Adoption Draft Technical Background Report (Housing Element CC Resolution) 22 have no history of a previously failed emergency shelter (or similar facility) due to the fault of the operator, and have not been convicted of any of the following offenses within the prior five years:
A crime requiring registration under Penal Code Section 290; A violation of Penal Code Sections 311.2 or 311.4 through 311.7;
A violation of Penal Code Sections 313.1 through 313.5; A violation of Penal Code Section 647(a), (b), or (d); A violation of Penal Code Section 315, 316, or 318;
A felony crime involving the use of force or violence on another; or
The maintenance of a nuisance in connection with the same or similar business operation.
o The management of the emergency shelter shall effectuate a background investigation on all employees to the satisfaction of the chief of police.
• Common Facilities and Services. An emergency shelter may include the following facilities and services as ancillary to the emergency shelter use:
o Commercial kitchen facilities;
o Dining area;
o Laundry room;
o Recreation or meeting room;
o Outdoor recreational spaces; provided, that the space is located within a building interior courtyard or is enclosed by a building, solid fence, or wall or some combination thereof to secure the space and ensure that it is not accessible to the general public; o Animal boarding for current residents of the facility only; and o Child care facilities for current residents of the facility only. • Client Intake Areas. An enclosed intake area shall be provided within the emergency shelter building. The intake area shall be a minimum of one hundred square feet in size, located entirely within the building. The intake hours shall be posted clearly on the doors to the emergency shelter. Clients shall be allowed to wait in an interior or exterior waiting area that shall not exceed one hundred fifty square feet. Clients shall not loiter nor form a queue outside of the exterior waiting area. • Parking. Each emergency shelter shall have a minimum of two off-street parking spaces plus the greater of either: (a) one additional off-street parking space for each ten beds, or fraction thereof, or (b) one additional parking space per employee.
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Packet Pg. 525 Attachment: Attachment 1, Exhibit B2 - Cotati Adoption Draft Technical Background Report (Housing Element CC Resolution) 23 • Lighting. Exterior lighting shall be located along all pedestrian pathways, parking lots, entrances and exits, common outdoor areas, and at the front of the building. All lighting shall be maintained in good operating condition and shall be fully shielded.
• On-Site Security. Security measures shall be reviewed and approved by the chief of police prior to commencement of operations on the site and shall be sufficient to protect clients and neighbors. On-site security shall be provided during the hours when the emergency shelter is in operation and at all times when clients are present on site. In the event that five or more calls for police services have been received over a thirty-day period by the police department, the facility shall be required to provide additional on-site security staff to the satisfaction of the chief of police and the community development director.
• City, County and State Requirements. An emergency shelter shall obtain and maintain in good standing all required licenses, permits, and approvals from the city, county, and state agencies or departments and demonstrate compliance with applicable building and fire codes. An emergency shelter shall comply with all county and state health and safety requirements for food, medical, and other supportive services provided on site.
These development standards are consistent with State requirements set by SB 2 and encourage and facilitate the development of emergency shelters. The management standards for emergency shelters may be in excess of those allowed by State law, parking standards for emergency shelters have not been updated for compliance with AB 139, and Cotati’s Zoning Code does not currently provide allowances for low barrier navigation centers. Under Program 3-1 (Zoning for a Variety of Housing Types), the City will allow Low Barrier Navigation Centers to be a by-right use in zones where multifamily and mixed-uses are permitted, including the nonresidential zones where multifamily is permitted, and amend parking requirements and management standards for emergency shelters pursuant to State law, including AB 139. Additionally, Program 2-5 (Continuum of Care and Crisis Response) is included in Section 2 to address and expand resources available in Cotati.
Transitional and Supportive Housing
Transitional and supportive housing projects are allowed in all districts where residential uses are allowed. Transitional and supportive housing are considered residential uses and are only subject to standards that apply to other residential dwellings of the same type in the same zone, in compliance with state law.
Program 3-1 (Zoning for a Variety of Housing Types) will ensure that the City is in compliance with state laws to allow permanent supportive housing by right in all zones where multifamily and mixed-uses are permitted.
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Packet Pg. 526 Attachment: Attachment 1, Exhibit B2 - Cotati Adoption Draft Technical Background Report (Housing Element CC Resolution) 24 Single Room Occupancy (SRO) Housing
Single Room Occupancy facilities (SROs) is a type of housing that can serve extremely low-income households. It includes housing with shared facilities, such as living or dining areas, with private sleeping areas. Rent is much lower than those associated with typical apartment complexes. The City’s NU zone allows for rooming houses with a Use Permit. While SRO facilities are not specified in the zoning code, the City has allowed the by-right conversion of an existing motor lodge to long-term occupancy.
Program 3-1 (Zoning for a Variety of Housing Types) will ensure that the City is in compliance with the most recent state laws for allowable residential land uses.
Manufactured Homes
Manufactured homes on permanent foundations are allowed on lots zoned for singlefamily dwellings, except for those abutting a designated historical landmark site (CMC Chapter 15.24). Manufactured homes are allowed in RR, R1, and R2 zones in the same manner as a stick-built single-family home and must be certified under the National Mobile Home Construction and Safety Standards Act of 1974. Program 3-1 (Zoning for a Variety of Housing Types) will bring the City into compliance with the requirements of Government Code § 65852.3 to permit manufactured homes in the same manner, in the same zones, and only subject to the same requirements as other single-family residential uses.
Mobile Home Parks
Mobile home parks (MHP) are described as “any area or tract of land where one or more spaces are rented or leased or held out for rent or lease to accommodate mobile homes, manufactured homes or travel trailers used for human habitation for 30 days or longer.” Mobile homes account for 4.1% (119 units) of the City’s housing stock. The Mobile Home Park (MHP) zoning district is a type of Special Purpose and Overlay Zones district in which mobile homes are the only allowable land use type.
Accessory Dwelling Units (ADUs)
An ADU is a self-contained home that is smaller than the main house and legally part of the same property. Residential properties are eligible to construct an Accessory Dwelling Unit (ADU) which can be an interior or garage conversion, detached standalone ADUs, ADUs attached to the primary residence, and ADUs constructed above garages type. Additionally, every single-family residential property is also eligible to construct a Junior ADU (JADU), with the exception of NM and NU zones; Program 3- 1 is included to amend the Zoning Code to allow JADUs in these zones. The maximum size of JADUs is 500 square feet.
To support the development of ADUs, the City has formed partnerships with the following community-based non-profit organizations:
• Napa Sonoma ADU Center provides resources to homeowners considering construction of an ADU or JADU.
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Packet Pg. 527 Attachment: Attachment 1, Exhibit B2 - Cotati Adoption Draft Technical Background Report (Housing Element CC Resolution) 25 • Homes for Sonoma, a nonprofit developer, was founded to create affordable housing options in a safe environment and support a sustainable community.
The organization aims to address the housing crisis in Sonoma County and across the state with scalable solutions, especially by promoting ADUs.
The City issued an average of 3 annual permits for ADUs between 2018 and 2021.
4.3 LOCAL HOUSING PROGRAMS & RESOURCES
4.3.1 Resources: Housing Assistance Programs
The following programs include Federal-, State-, and locally run programs providing funding for construction, rehabilitation, or rental assistance for very low-, low-, and moderate-income households. This section describes programs utilized by the City and those that may be locally available and potentially applicable within the jurisdiction.
Federal Assistance Programs
The Community Development Block Grant (CDBG) Program funds a wide variety of local housing and community development projects that improve the quality of living for lower-income residents whose incomes are less than 80% of the Area Median Incomes as established by the U.S. Department of Housing and Urban Development (HUD).
Sonoma County receives approximately $1.8 million annually in CDBG funds. The program is administered by the Community Development Commission, and the Sonoma County Board of Supervisors makes the final decision regarding how the funds are distributed locally. The City of Cotati is a part of the urban county group of non-entitlement jurisdictions with funds administered by the Sonoma County Community Development Commission. The Cities & Towns Advisory Committee administers CDBG funding to participating cities. The City can apply directly to the Sonoma County Community Development Commission to obtain CDBG funds for designated projects; however, the City is not guaranteed any minimum allocation.
CDBG funds can be used for activities that meet one of the following National Objectives:
• Benefits low- and moderate- income persons;
• Aids in the prevention or elimination of blight; and
• Meets a need from having a particular urgency (e.g. disasters) Examples of such activities include the following:
• Housing rehabilitation
• Community and Senior Centers
• Acquisition of real property for affordable housing
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Packet Pg. 528 Attachment: Attachment 1, Exhibit B2 - Cotati Adoption Draft Technical Background Report (Housing Element CC Resolution) 26 • Infrastructure improvements
• Public services
• Accessibility modifications
• Permanent supportive housing for people experiencing homelessness • Homeless Shelters
Home Investment Partnerships (HOME) grants are provided by HUD to fund a wide variety of projects that implement local housing strategies and create affordable housing for low-income households including building, buying, rehabilitating affordable housing, or providing direct rental assistance (Source: HUD). The County receives approximately $650,000 in HOME funds annually. The City or nonprofit developers can apply to Sonoma CDC to obtain HOME funds, which are used on a competitive basis. The City can work with affordable housing developers to support applications for these funds that can be used for all aspects of affordable housing development (Source: SCHA).
Housing Choice Voucher Section 8 (HCV Program) is a major federal program for assisting very low-income families, the elderly, and the disabled to afford decent, safe, and sanitary housing in the private market.
To become a participant of the HCV Program, individuals and families must sign up on the Waiting List with the Sonoma County Housing Authority This is a list of people who are waiting to receive rental assistance. Names can only be added to the Waiting List when the list is open, which is approximately every three to five years. While the list is open, 750 applications are randomly selected and assigned a place in line. Once a name reaches the top of the Waiting List, the applicant is interviewed to determine whether they are eligible for the program. Most recently, the Sonoma County HCV Program Waiting List was opened to receive applications from October 1, 2021 – November 1, 2021.
If selected, participants may choose any housing that meets the Housing Quality Standards of the program. The Sonoma County Housing Authority (SCHA) pays a housing subsidy directly to the landlord, and the participant pays the difference between the actual rent charged and the amount subsidized by the program. The tenant's share of rent and utilities is generally between 30 to 40% of their monthly income (Source: SCHA).
Project-Based Voucher Program is administered by the Sonoma County Housing Authority (SCHA) and is administered like the HCV program, except the voucher is tied to an individual unit, rather than “owned” by the person. Project-based vouchers are an important tool to ensure long-term financial stability of projects serving lowerincome persons, especially extremely low-income households. In recent years, SCHA has awarded new project-based vouchers, with priority given to projects with setaside units for people experiencing homelessness.
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Packet Pg. 529 Attachment: Attachment 1, Exhibit B2 - Cotati Adoption Draft Technical Background Report (Housing Element CC Resolution) 27 The Emergency Shelter Grant (ESG) Program administered by Sonoma County CDC which provides HUD funds to rehabilitate and operate emergency shelters and transitional shelters, provide essential social services, provide permanent housing solutions, and prevent homelessness (Source: SCHA).
The Federal Home Loan Bank System facilitates Affordable Housing Programs (AHP) which subsidize the interest rates for affordable housing. The San Francisco Home Loan Bank District provides local services within California. AHP grants are awarded annually through a competitive application process to Bank members working in partnership with housing developers and community organizations.
Basic eligibility requirements include having at least 20% of units in rental housing reserved for very low-income households and any owner-occupied housing must serve lower income households (Source: Federal Home Loan Bank of San Francisco).
HUD Section 811/202 Programs provide critical affordable housing to elderly and persons who experience disabilities. The Section 202 program funds development and operation of affordable housing for very low-income elderly households. The Section 811 program provides non-profits with funding to develop and operate supportive housing for disabled very- and extremely-low-income persons (Source:
HUD).
Low-Income Housing Preservation and Residential Home Ownership Act (LIHPRHA) requires that all eligible HUD Section 236 and Section 211(d) projects which are “at-risk” of conversion to market-rate rental housing through the mortgage prepayment option be subject to LIHPRHA incentives. The incentives include HUD subsidies which guarantee owners an eight percent annual return on equity. Owners must file a Plan of Action to obtain incentives or offer the project for sale to a) nonprofit organizations, b) tenants, or c) public bodies.
Low Income Housing Tax Credits (LIHTC) provide State and Local LIHTCallocating agencies the equivalent of approximately $8 billion in annual budget authority to issue tax credits based on population for the acquisition, rehabilitation, or new construction of rental housing targeted to lower-income households.
National Housing Trust Fund (NHTF) is a federal program administered in California by HCD whereby funds can be used to increase and preserve the supply of affordable housing, with an emphasis on permanent housing for extremely lowincome households. Previously, NHTF funding was allocated through the Housing for a Healthy California Program. Beginning in Fiscal Year 2022, the NHTF will be aligned with federal regulations. HCD is currently in the process of developing guidelines for the 2022 allocation of NHTF funds.
Off-Farm Labor Housing Direct Loans & Grants is a federal program administered by the US Department of Agriculture Rural Development. This program provides affordable financing to develop housing for year-round and migrant or seasonal domestic farm laborers. Housing construction may be in urban or rural areas, if there is a demonstrated need for farmworkers nearby. The rental housing is
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Packet Pg. 530 Attachment: Attachment 1, Exhibit B2 - Cotati Adoption Draft Technical Background Report (Housing Element CC Resolution) 28 for very low- to moderate-income ($5,500 above low-income limit) farmworkers and their families (Source: USDA RD).
State Assistance Programs
Affordable Housing and Sustainable Communities Program (AHSC) is administered by the Strategic Growth Council and implemented by the Department of Housing and Community Development (HCD). The AHSC Program funds land-use, housing, transportation, and land preservation projects to support infill and compact development that reduce greenhouse gas emissions. The AHSC provides grants and/or loans that benefit disadvantaged communities through increasing accessibility of affordable housing, employment centers, and key destinations via low-carbon transportation. Eligible applicants for the AHSC program include localities, public housing authorities, and redevelopment successor agencies among others.
CalHome Program is administered by HCD and provides grants to local public agencies and nonprofit developers to assist individual first-time homebuyers through deferred-payment loans for down payment assistance and home rehabilitation, including manufactured homes not on permanent foundations, acquisition and rehabilitation, homebuyer counseling, self-help mortgage assistance, or technical assistance for self-help homeownership. The CalHome Program also provides financial assistance for development of multiple-unit ownership projects (Source: HCD).
California Emergency Solutions and Housing (CESH) Program is administered by HCD and provides grants to fund a variety of activities to assist persons experiencing or at risk of homelessness. Local governments, non-profit organizations, or designated unified funding agencies can apply for funding to use for housing relocation and stabilization services, operating subsidies for permanent housing, flexible housing subsidy funds, operating support for emergency housing interventions, and systems support for homelessness services and housing delivery systems.
California Housing Accelerator Program is a new HCD program and intends to reduce the backlog of shovel-ready housing projects that have been stuck in financial limbo. Projects which have been funded under other HCD programs and have not been able to access low-income housing tax credits are eligible for the program.
Applications for funding assistance must go through a selective process, giving priority to Tier I “Multifamily Project Tracker” projects, and once selected is provided a forgivable loan. The program is funded by the Coronavirus State Fiscal Recovery Fund established by the federal American Rescue Plan of 2021.
California Housing Finance Agency (CalHFA) operates several programs to help reduce the cost of housing. These programs, funded through the sale of taxable and tax-exempt bonds, provide permanent financing of affordable housing developments, financing for homebuyers, hardship assistance, resources to increase homeownership for Black residents, and grants for the pre-development costs associated with the construction of Accessory Dwelling Units.
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Packet Pg. 531 Attachment: Attachment 1, Exhibit B2 - Cotati Adoption Draft Technical Background Report (Housing Element CC Resolution) 29 Community Placement Plan (CPP) and Community Resource Development Plan (CRDP) Funds. In collaboration with the regional center, the California Department of Developmental Services uses CPP and CRDP funds to develop safe, affordable, and sustainable homes as a residential option for individuals with intellectual and developmental disabilities.
Golden State Acquisition Fund (GSAF) provides funding seeded by HCD’s Affordable Housing Innovation Fund to preserve and expand quality affordable and senior housing. Combined with matching funds, GSAF makes up to five-year loans to developers for the acquisition or preservation of affordable housing. Terms for funding include development parameters that require projects to designate units to lower income households. Nonprofit and for-profit developers, cities, counties, and other public agencies within California are all eligible for GSAF financing.
Homekey is administered by HCD and provides grants to local entities to acquire and rehabilitate a variety of housing types to sustain and expand housing for people experiencing homelessness or are at risk of experiencing homelessness and provides additional funding for wrap-around supportive services.
Infill Infrastructure Grant Program (IIG) promotes infill development by providing financial assistance for infrastructure improvements necessary for specific residential or mixed-use infill development projects or areas. Criteria for funding include affordability, density, and access to transit. Eligible applicants for the IGG Program include nonprofit and for-profit developers of qualifying infill projects and localities with jurisdiction over qualifying infill areas among others.
Joe Serna, Jr. Farmworker Housing Grant (FWHG) Program is administered by HCD and finances the new construction, rehabilitation, and acquisition of owneroccupied and rental units for agricultural workers, with a priority for lower income households. Eligible applicants include local government agencies, nonprofit corporations, and cooperative housing corporations among others.
Local Early Action Planning (LEAP) Grants is administered by HCD and provides over-the-counter grants complemented with technical assistance to local governments for the preparation and adoption of planning documents, and process improvements that accelerate housing production and facilitate compliance to implement the sixth-cycle Regional Housing Needs Assessment.
Local Housing Trust Fund (LHTF) Program is funded through HCD and provides matching funds to local and regional housing trust funds dedicated to the creation, rehabilitation, or preservation of affordable housing, transitional housing, and emergency shelters. Funds are also used to provide down payment assistance for first-time homebuyers and is restricted for units with at least 55 years of affordability for households earning less than sixty percent AMI.
Mobile Home Park Rehabilitation and Resident Ownership Program (MPRROP) is administered by HCD and is used to finance the preservation of affordable mobile home parks by conversion to ownership or control by resident
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Packet Pg. 532 Attachment: Attachment 1, Exhibit B2 - Cotati Adoption Draft Technical Background Report (Housing Element CC Resolution) 30 organizations, nonprofit housing sponsors, or local public entities. Eligible applicants include mobile home park resident organizations, nonprofit entities, and local public agencies. Low-income residents of converted parks can apply for individual loans to the entity that has purchased the park.
Multifamily Housing Program (MHP) is administered by HCD and assists the new construction, rehabilitation, and preservation of permanent and transitional rental housing for lower income households. Eligible applicants must have successfully developed at least one affordable housing project.
Predevelopment Loan Program (PDLP) provides predevelopment capital to finance the predevelopment costs of projects to construct, rehabilitate, convert, or preserve assisted housing projects with priority given to developments which are rural, located in the public transit corridors, or which preserve and acquire existing government-assisted rental housing as risk of conversion to market rates. Eligible applicants include local government agencies among others.
Section 811 Project Rental Assistance offers long-term project-based rental assistance funding from the U.S. Department of Housing and Urban Development (HUD) through a collaborative partnership among the California Housing Finance Agency (CalHFA), Department of Health Care Services (DHCS), Department of Housing and Community Development (HCD), Department of Developmental Services (DDS) and California Tax Credit Allocation Committee (TCAC).
Supportive Housing Multifamily Housing Program (SHMHP) provides lowinterest loans to developers of permanent affordable rental housing that contain supportive housing units. SHMHP funds may be used for new construction or rehabilitation of a multifamily rental housing development, or conversion of a nonresidential structure to a multifamily rental housing development.
Veterans Housing and Homelessness Prevention (VHHP) Program is implemented by HCD and funds the acquisition, construction, rehabilitation, and preservation of affordable multifamily housing for veterans and their families to allow veterans to access and maintain housing stability. Eligible applicants include affordable housing developers who are partnered with appropriate service providers.
Local Assistance Programs
Housing Land Trust of Sonoma County (HLT) is a private, non-profit corporation founded in February 2002, with a goal of making housing affordable and to provide home ownership and opportunities to low- and moderate-income families in Sonoma County. HLT uses the Community Land Trust model (CLT), a model in which the organization owns real estate in certain areas within the City and provides access to land and housing for the local community who have been forced out of the housing market. Through this model, low and moderate-income families can purchase homes on affordable terms and lease the land beneath the home for 99 years. Homeowners can sell their homes if they decide to move and get a fair return for their investment and at the same time benefit potential homebuyers by keeping the price affordable.
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Packet Pg. 533 Attachment: Attachment 1, Exhibit B2 - Cotati Adoption Draft Technical Background Report (Housing Element CC Resolution) 31 The City of Cotati in partnership with Housing Land Trust of Sonoma County and Renew Now Homes have currently listed the Jamie Lane and Kessing Ranch available for purchase by qualifying applicants.
Fair Housing of Sonoma County (FHOSC) is a non-profit agency that is a designated provider of fair housing and supplies land-tenant information and referral service to all residents of Sonoma County.
Legal Aid of Sonoma County's Homeless Advocacy Project (HOME) is a program that assists low-income tenants of Sonoma County with eviction defense, Section 8 issues, mobile home park issues, and habitability problems.
The County Fund for Housing (CFH) provides financial assistance to develop, preserve and accelerate the development pace of affordable housing in Sonoma County. The CFH resources are used to provide loans and grants to qualified developers, public entities, groups, and individuals to undertake activities which create, maintain, or expand the County’s affordable housing stock. CFH receives funds from multiple local sources, including, but not limited to County of Sonoma General Fund; County of Sonoma Reinvestment and Revitalization Funds; Developer In-Lieu Fees; Transient Occupancy Tax; and CFH loan processing fees, interest, and loan repayments.
4.3.2 Resources: Shelters, Transitional and Supportive Housing The City will continue to seek sources of funding, including Emergency Housing Assistance Program through the County, to support transitional housing, and supportive housing by interested developers/operators to provide housing for homeless persons and households at‐risk of homelessness.
The Sonoma County Community Development Commission (CDC) receives and administers federal block grant funds through the Consolidated Plan process that are used in the unincorporated County and participating cities to address the needs of lower income households, including the special needs and homeless populations.
Cotati is a participant in the Urban County Consolidated Plan process and block grant programs. The CDC funds a variety of programs and shelters County-wide to address homelessness that provide short-term emergency housing assistance as well as longterm programs to transition from homelessness. These programs include Shelter Plus Care, Committee on the Shelterless, Community Support Network, and the Catholic Charities Homeless Services Center.
There are emergency shelters serving as general homeless shelters or transitional housing opportunities that are available to Cotati’s homeless population. There are no homeless listings within the City limits but there are homeless shelters in Santa Rosa and Petaluma that provide help to Cotati’s homeless population.
In 2015, the City partnered with Catholic Charities to provide space and facilities for a pilot Safe Parking program. Additionally, the City operates a mental health crisis
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Packet Pg. 534 Attachment: Attachment 1, Exhibit B2 - Cotati Adoption Draft Technical Background Report (Housing Element CC Resolution) 32 responses team Specialized Assistance for Everyone (SAFE) in conjunction with the City of Rohnert Park.
The City continues to investigate other possible opportunities to partner and expand services. There are several state licensed neighborhood facilities in the City.
In 2019, the County CDC purchased a three-unit property within Cotati (8190, 8192, and 8194 Arthur Street) to provide supported transitional housing to residents.
A Step Up – Cotati is a live-in program providing an 11-bed home where residents can live for up to 3-12 months in a safe and supportive environment. The place allows them to improve their emotional and physical health, while learning positive coping skills on the path to recovery and independence.
4.3.3 At-Risk Assisted Housing Developments
Pursuant to Government Code § 65583, at-risk assisted housing developments refer to any existing multi-family, rental housing complexes which receive funding under public programs and are at risk of being converted from low-income housing to market rate housing within ten (10) years of the housing element planning period.
The conversions can occur due to termination and opting out of programs such as rental subsidies, mortgage repayment, expiration of restricted uses or direct loans.
The City of Cotati contains a total of 147 low-income units, none of which are at risk of being converted to market rate units within the planning cycle (ABAG, 2021).
Affordability restricts were renewed in December 2022. Affordability restrictions were renewed in December 2022 for 28 units of affordable housing that were recently atrisk.
4.3.4 Planning and Zoning Incentives
AB 2345 provides developers with density bonuses or other incentives in exchange for the provision of affordable housing units included within the development which meets certain requirements. As of January 2021, up to a 50% density bonus can be approved for housing projects consisting of a combination of affordable and Abovemoderate homes. The legislation also reduces specific thresholds for obtaining approvals and allowances from local jurisdictions, requires density bonus reporting, and reduces parking obligations for many projects qualifying for a density bonus. To qualify for the density bonus developments must include (a) at least eleven percent (15%) of the total units are for very low-income households, (b) at least twenty percent (24%) of the total units are for low-income households, or (c) at least forty percent (44%) of the total for-sale units are for moderate-income households. The density bonus applies to housing development of five or more dwelling units.
The City of Cotati requires developers to construct housing in which at least 15% of the total number of proposed units are for lower income households. The affordable units must be built on-site in developments with 10 or more units; smaller
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Packet Pg. 535 Attachment: Attachment 1, Exhibit B2 - Cotati Adoption Draft Technical Background Report (Housing Element CC Resolution) 33 developments can meet the affordable housing obligation by paying an in-lieu fee.
The density bonus is available to help to offset these costs when the units are provided on-site.
Density Bonuses
The City’s current density bonus provisions are as follows:
• General Density Bonus: The City grants at least a 20% increase in the number of dwelling units, up to a maximum of 35%.
• Bonus for Condominium or Planned Development Project: The City grants at least a 5% increase in the number of dwelling units, up to a maximum of 35%. • Density Bonus for Land Donation: An applicant is granted at least a 15% density bonus for the entire development when donating land to the City, up to a maximum of 35%.
• Senior Housing Density Bonus: The City shall grant a density bonus that is 20% of the number of senior housing units.
Program 3-1 (Zoning for A Variety of Housing Types) will bring the City into compliance with changes to the State’s Density Bonus Law.
Affordable Housing
The City of Cotati prioritizes access to healthy, safe, and affordable housing for all its residents. As part of this effort, the City formed a strategic partnership with several experienced housing service providers including the Housing Land Trust of Sonoma County (HLT) and the Sonoma County Community Development Commission (CDC) to develop and administer a variety of affordable housing programs.
The City’s Inclusionary Housing Policy requires all residential projects of 10 units or more to allocate 15% of the homes to families and individuals that are under either “Very-Low,” “Low” or "Moderate" Income level.
Local Processing and Permit Fees
Applicants need to obtain the building permit form either online or physical form and fill it out. Completed permit form is sent to the Community Development Department office by email or mail and then after the permit is received, it will be evaluated by the department and an applicant is provided the permit number and the amount due.
After paying the due amount, the applicant will receive the approved permit and scheduled inspections will be conducted.
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Packet Pg. 536 Attachment: Attachment 1, Exhibit B2 - Cotati Adoption Draft Technical Background Report (Housing Element CC Resolution) 34 SFD on
existing lot
SFD
w/subdivision Multifamily
600k SFRs
Subdivision 20 units
MF 50 units 350k
valuation
Entitlements
Administrative
Design Review Subdivision map Design review,
Final map
CEQA
(assumes
IS/MND)
CEQA (assumes
IS/MND)
Design review
Building permit Building permit Building
permit
Typical
processing
time
30-days 8-12 months 3-8 months
$1,993 $8,767 $7,333
Est. Fees per
project $16,070 6000
Entitlements $7,333 $2,184
6000
$2,184
subtotal per
unit $1,993 $2,018 $310
Impact Fees $59,599 $59,599 $50,552
Building
Permit
1%-2% of
construction
valuation
1%-2% of
construction
valuation
1%-2% of
construction
valuation
Total $61,592 $61,616 $50,863
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Packet Pg. 537 Attachment: Attachment 1, Exhibit B2 - Cotati Adoption Draft Technical Background Report (Housing Element CC Resolution) 35 Source: Master Fee Schedule 2021, City of Cotati
4.4 HOUSING CONSTRAINTS ANALYSIS
This section of the Housing Element examines the constraints that could hinder the City’s achievement of its housing objectives and the resources that are available to assist in the production, maintenance, and improvement of the City’s housing stock.
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Packet Pg. 538 Attachment: Attachment 1, Exhibit B2 - Cotati Adoption Draft Technical Background Report (Housing Element CC Resolution) 36 4.4.1 Non-Governmental Constraints
In compliance with Government Code § 65583(a)(6), the following section analyzes potential non-governmental constraints:
Vacant Land
There is remaining vacant land within available the City, including land in areas zoned for lower densities, higher densities, and mixed-use development, and a range of lot sizes. The availability of vacant land allows for the development of additional housing in the City without the need for redevelopment and does not pose a constraint.
Land Costs
The financial infeasibility, economic fluctuations, succession of post-2017 emergency situations, and lack of appropriately zoned land have contributed to the slow pace of house production in Sonoma County over the past few years. In addition, the COVID19 pandemic has put additional pressure on the local market and worsened the housing shortage. The market is still impacted by the 2017 Tubbs Fire and subsequent wildfires including the 2019 Kincaid Fire. The number of lots for sale has increased from 5088 in 2018 to 6563 in 2021. The land cost as a share of the property value at 35% in Sonoma County is lower relative to other California counties.
Land recently listed for sale in Cotati consists of lots smaller than an acre with access to utilities. The average price of vacant land in Cotati was $976,318 per acre as of August 2022, according to LoopNet. The lot with the highest cost per acre is located near the SMART station and has existing approved plans for multifamily development and the lot with the lowest cost per acre is located on the outskirts of town, primarily near other vacant lots and commercial uses. While land costs are high, they do not pose a significant constraint to the development of housing in Cotati.
Construction Costs
According to local stakeholders in the development community, hard costs for residential construction typically start around $400 per square foot. Construction costs vary based on the type of development. Construction costs for stacked flats start as low as $250 per square foot. Disruptions in supply chains have exacerbated construction costs and further constrained housing development. Stakeholders also expressed that the unpredictability of construction costs was a constraint to the development of housing, especially for projects relying on tax credits or similar affordable housing funding sources. The cost of construction affects the affordability of new housing and is a significant nongovernmental constraint to housing in Cotati.
Financing
Financing is one of the most crucial factors considered in the provision of adequate housing for all sectors of the population. The availability of finance is influenced by factors beyond the local government's control, such as bank and investor capital
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Packet Pg. 539 Attachment: Attachment 1, Exhibit B2 - Cotati Adoption Draft Technical Background Report (Housing Element CC Resolution) 37 levels, borrowers' creditworthiness, and investors' willingness to provide capital for real estate.
Lenders typically prefer a 20-percent down payment on a mortgage loan. Prospective buyers, who might be able to support an 80-percent loan, often do not have the financial resources to make the required down payment. Lenders will sometimes loan up to 90 percent of the asking price, but an applicant's credit is much more closely scrutinized, and monthly payments and monthly income requirements are significantly higher. Consequently, financing can pose a major obstacle for first-time or moderate-income homebuyers, even for those who might otherwise qualify for a standard loan.
There are three government-insured types of home loans. They are USDA loans, VA loans, and FHA loans. USDA loans are provided based on the rural Development rural area requirements. USDA loans have nine different multifamily housing programs that provide rental assistance for lower-income tenants and are geared toward financing projects related to the development, rehabilitation, and preservation of affordable homes for low-income, elderly, disabled people, and domestic farm laborers. FHA loans are provided by the Federal Housing Administration. This program is managed by the federal government’s Department of Housing and Urban Development (HUD). For Californians, there is the CalHFA and CalPlus under the FHA loan program.
Mortgage interest rate has fluctuated below 5% since 2010. The highest average rate recorded was 4.69% in 2010 and the lowest rate was 2.96 in 2021. The data shows a trend in average mortgage interest rates, in which every two years it adjusts to either surpass or fall below 4%, as shown in Table 17.
Table 17: Average Mortgage Interest Rates 2000 – 2022
Source: Freddie Mac, 30-year fixed mortgage rates and points. Retrieved from https://www.freddiemac.com/pmms/pmms30
Development Trends
The La Plaza View Mixed-Use development is an entitled mixed-use project in downtown Cotati. It is located on the vacant parcels along East Cotati Avenue between Charles Street and La Plaza. The proposed project has two three-story
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Packet Pg. 540 Attachment: Attachment 1, Exhibit B2 - Cotati Adoption Draft Technical Background Report (Housing Element CC Resolution) 38 buildings and includes 27-29 residential units. A separate density bonus project under ministerial consideration utilizing Senate Bill 35 (SB 35) streamlining provisions, has also been proposed on this site.
Cotati Village is part of the larger Cotati commons project, previously known as South Sonoma Business Park. This proposed project was originally envisioned in 2002 to develop 35-acres of land with 15-acres allotted to retail, offices, and corporate facilities. After conducting an environmental impact study, the City proposed an alternative project and adopted “The Orchard Plan Alternative” in May 2001, which includes 13.36-acres of mixed and retail use, and 50 residential units. Subsequently, in 2021, a horizontal mixed-use project proposing 7,000 square feet of commercial space and approximately 170 multi-family apartment projects was submitted and is under review by City staff.
The Kessing Ranch Subdivision is a new single-family development located at the corner of Old Redwood Highway and Valparaiso Avenue. The project has 7 units for sale affordable homes out of the 42 units available. Construction was completed in 2022 with all units being occupied.
Cotati Station is a 98-unit multifamily apartment project in the Santero Way Specific Plan area, adjacent to the SMART rail station in Cotati. This project benefited from a 100% density bonus granted by the Cotati City Council and is anticipated to break ground in late 2022.
While multifamily housing units comprised only 31% of Cotati’s housing units at the end of 2017, recently approved and constructed projects will increase this proportion significantly.
State law allows single-family homes to build at least one accessory dwelling unit (ADU) and one junior accessory dwelling unit. In compliance with the state law, Cotati Municipal code Chapter 17.42.170 articulate ADU and JADU procedures and development standards. Additionally, the City’s Cottage Housing Ordinance allows missing middle housing types on most residential lots in the City, and grants increased density for qualifying projects. These ordinances play a significant role in addressing the growing housing shortage and promotes individual homeowners to contribute to increasing the housing supply in the City over the coming years.
Community Opposition
Residents of Cotati have at times expressed concern about housing developments that would change the “community character” or appearance of their neighborhoods, especially in single-family areas. However, when these concerns have been addressed, they have generally resulted in a better project and have not stopped the development of housing projects in Cotati. Community members appear to be generally supportive of affordable housing, mixed-use development, senior housing, and transit-oriented development. Although this has not happened in recent memory, community opposition within the California Environmental Quality Act (CEQA) review process can pose a constraint to development. The CEQA process does add time,
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Packet Pg. 541 Attachment: Attachment 1, Exhibit B2 - Cotati Adoption Draft Technical Background Report (Housing Element CC Resolution) 39 uncertainty and cost to the approval and construction of housing development.
Programs xx and xx will remove discretionary review procedures where appropriate, reducing the opportunities for community opposition to serve as a constraint to housing development while affirmatively further fair housing choice.
4.4.2 Potential Governmental Constraints
Governmental constraints are policies, standards, requirements, or actions imposed by the various levels of government upon land and housing ownership and development. Although federal and state agencies play a role in the imposition of governmental constraints, these agencies are beyond the influence of local government and are therefore not addressed in this document.
General Plan and Zoning Code
Each jurisdiction in California must prepare a comprehensive, long-term General Plan to guide its future. The Land Use Element of the General Plan establishes the basic land uses and density of development within each jurisdiction. Under state law, the General Plan elements must be internally consistent, and each jurisdiction’s zoning must be consistent with its General Plan. Thus, the Land Use Element must provide suitable locations and densities to implement the policies of the Housing Element.
The City of Cotati’s General Plan was updated in 2015 to guide development for the next 20 years. The City’s land use regulations are codified in Chapter 17.22 of the Cotati Municipal Code and include allowable land uses and planning permit requirements for residential, commercial, mixed use, specific plan, and other district areas. The various district zones allow for a variety of housing including multi-family housing up to 100 units, residential care facilities, mobile/ manufactured homes, live/work units, emergency shelters, and ADUs, as shown in Table 18 and Table 19 below. Minimum and maximum densities are described within each zoning district.
Table 18: Allowable Land Uses for Low Density and Neighborhood District Zones
Housing Type RR RVL NL NM NU OSC
Minimum Density Permitted
(units per acre)
N.A. N.A. 4* 8* 12* Max. 1
caretaker
unit
Maximum Density
Permitted (units per acre)
1 2 6 10 15 Max. 1
caretaker
unit
Single-Family Dwelling P P P UP** UP** -
Accessory Dwelling Units P P P P P -
Junior Accessory Dwelling
Units
P P P - - -
Multifamily housing, 2 units - - UP P P -
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Packet Pg. 542 Attachment: Attachment 1, Exhibit B2 - Cotati Adoption Draft Technical Background Report (Housing Element CC Resolution) 40 Multifamily housing, 3 or 4
units
--- UPP-
Multifamily housing, 5 to 9
units
--- UP UP-
Multifamily housing, 10 or
more units
---- UP-
Multifamily housing, up to
100 units with 25%
----P-
Residential care facility for
the elderly (RCFE)
UP UP UP UP UP-
Residential care, 11 or
more clients
UP UP UP UP UP-
Residential care, 6 or fewer
clients, in a single-family
dwelling
PPPPP-
Residential care, 7 to 10
clients
UP UP UP UP UP-
Residential component of a
mixed-use project
-- UP UP UP-
Residential accessory use
or structure
PPPPP-
Caretaker quarters----- UP
Cottage housing--SSS-
Mobile Home Park UP UP UP UP UP-
Mobile/Manufactured HomePPPPP-
Rooming or boarding house---- UP-
Organizational house
1 ---- UP
-
Source: City of Cotati Municipal Code Chapter 17.22, 2022 RR = Rural Residential
RVL = Residential, Very Low Density
NL = Neighborhood - Low Density
NM = Neighborhood – Medium Density
NU = Neighborhood – Urban
OSC = Open Space, Conservation
OSR = Open Space, Recreation
P = Permitted Use, Zoning Clearance required
UP = Use Permit required
S = Permit requirement set by Specific Use Regulations - = Use not allowed
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Packet Pg. 543 Attachment: Attachment 1, Exhibit B2 - Cotati Adoption Draft Technical Background Report (Housing Element CC Resolution) 41 * = No residential subdivision, or residential development project with multiple units on a single parcel (including the residential component of a mixed use project) will be approved at less than the minimum density; except that in the CE, CG, and CD zoning districts, the review authority may reduce the minimum density for a mixed use project where it determines that the minimum density is not feasible due to constraints on the parcel, including topography, easements, and access. ** = Use permit approval shall require that the review authority first find that the location of a proposed single-family dwelling on a parcel that may be further subdivided will not preclude future subdivision and development in compliance with the General Plan.
1 “Organizational house” means a residential lodging facility operated by a membership organization for its members and not open to the general public. Includes fraternity and sorority houses, student dormitories, convents, monasteries, and religious residential retreats.
Table 19: Permit Requirements for Mixed Use Corridors, Downtown Specific Plan Districts, and Other Districts
Housing Type CE CG CD CI IG PF HC LP NG CA
Minimum Density
Permitted (units per
acre)
12* 12* 12* N.A. N.A. N.A.
Subject to Downtown
Specific Plan – See Table
21 Maximum Density
Permitted (units per
acre)
15 15 15 15 N.A. N.A.
Accessory Dwelling
Unit
P P P - - - P P P P
Residential care
facility for the
elderly (RCFE)
UP MUP - - - UP - UP UP UP
Residential care, 7
or more clients
UP - - - - UP - UP - -
Residential
component of a
mixed-use project
P P P - - - P P P P
Emergency/transitio
nal shelter**
- - S - - S S S S S
Live/work unit UP UP - UP UP - P P P P
Home occupation P P P - - - P P P P
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Packet Pg. 544 Attachment: Attachment 1, Exhibit B2 - Cotati Adoption Draft Technical Background Report (Housing Element CC Resolution) 42 Source: City of Cotati Municipal Code Chapter 17.22, 2022 CE = East Cotati Avenue Corridor
CG = Gravenstein Highway Corridor
CD = Downtown Commercial
CI = Commercial/Industrial District
IG = General Industrial District
PF = Public Facility District
Downtown Specific Plan
HC = Historic Core
LP = La Plaza
NG = Northern Gateway
CA = Commerce Avenue
SUR = Specific Use Regulations P = Permitted
Use, Zoning Clearance required
MUP = Minor Use Permit required
UP = Use Permit required
S = Permit requirement set by Specific Use
Regulations
- = Use not allowed
* = No residential subdivision, or residential development project with multiple units on a single parcel (including the residential component of a mixed use project) will be approved at less than the minimum density; except that in the CE, CG, and CD zoning districts, the review authority may reduce the minimum density for a mixed use project where it determines that the minimum density is not feasible due to constraints on the parcel, including topography, easements, and access. ** = Emergency shelters are allowed by right; Specific Use Regulations relate to management standards and other use standards discussed in Section 4.2.3.
Density
According to the City’s General Plan, higher density is intended to concentrate in central locations and decreases as one goes further from the City core towards the urban growth boundary (UGB) and sphere of influence (SOI). This is reflected in Chapter 17.22 of the City’s Municipal Code as density limits typically range from four (4) units per acre in NL (Neighborhood – Low Density) zones to fifteen (15) units per acre in NU (Neighborhood Urban), CE (East Cotati Avenue Corridor), CG (Gravenstein Highway Corridor), CD (Downtown Commercial), and CI (Commercial/Industrial District) zones. There are no acreage-based residential density limits for certain mixed-use corridors, including the Downtown Specific Plan and other overlay districts, as shown above. Density limits for these zones are subject to the provisions of their respective plans and supporting CEQA analysis.
The Downtown Cotati Specific Plan describes five main district zones, four of which allow residential and mixed uses. The Specific Plan encourages high density residential development based on development standards such as maximum allowable dwelling units, maximum building height, and FARs. For example, HC (Historical Core) district allows a maximum of 71 dwellings, 35-ft. maximum height, and FAR of 2.15.
Cotati’s live/work unit provisions allow for the re-use of existing structures subsequent to an environmental assessment (CMC 17.42.090), essentially allowing adaptive reuse for workforce housing. Live/work units are allowed a maximum density of 15 units per acre and are not applicable to affordable housing requirements
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Packet Pg. 545 Attachment: Attachment 1, Exhibit B2 - Cotati Adoption Draft Technical Background Report (Housing Element CC Resolution) 43 and incentives. This provision limits allowable units based on acreage rather than maximizing units based on the building envelope.
Development Standards
Zoning regulations establish certain development standards that implement the goals, policies and programs of the land use element as described in the City’s General Plan. Specific development standards include allowable lot coverage, minimum lot area, setback requirements, building height, and street-side building distances. Table 20 below illustrates development standards for residential and commercial zoning districts.
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Packet Pg. 546 Attachment: Attachment 1, Exhibit B2 - Cotati Adoption Draft Technical Background Report (Housing Element CC Resolution) 44 Table 20: City of Cotati Development Standards
Zoning
District
Minimum
Lot Size
(Sq. Ft.)
Minimum
Lot Width
(Feet)
Maximum Building
Height (Feet)
Minimum Front Yard
Setback (Feet)
Minimum Side Yard Setback
(Feet)
Minimum Rear
Yard Setback
(Feet)
Maximum Lot
Coverage (Percent)
Primary Accessory Interior Street Side
R
E
S
I
D
E
N
T
I
A
L
RR
65,340 for
RR-1.5 zone
43,560 for
RR-1.0 zone
100
100
28 121 25 10 20 20
30% on a 0.5-acre
parcel; reduced by 10%
for each additional 0.5
acre to a minimum of
10%
RVL
28,750 for
RVL-0.66
zone
21,780 for
RVL-0.5 zone
100
100
28 12 25 10 20 20 Same as RR
NL 6000 60 28 12 20 7 ft. (one side)
5 ft. (the other side) 10 20 40%
NM 5000 50 28 12 20
5 ft.; 10 ft. for
multifamily
structures; none
required for
rowhouse units
10 20 50%
NU 3500 45
28 ft.; 35 ft.
with use
permit
12 15
10 ft. for 1-story
building walls; 15 ft.
for 2-story building
walls; none required
for rowhouse units
15 15 60%
OSC
Determined
via
subdivision
review
N.A 35
25 for parcels
≤1 acre
28 for parcels
>1 acre
30 20 30 30 5%
C
O
M
CE 6000 60
35 ft.; 45 ft. with use
permit; or 45 ft. in
compliance with
Section 17.30.040(D)2
10 ft. for street side3
10 ft. abutting a
residential zone,
none required
otherwise
Varies4
20 ft. abutting a
residential zone, 10
ft. required
otherwise
80%
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Packet Pg. 547 Attachment: Attachment 1, Exhibit B2 - Cotati Adoption Draft Technical Background Report (Housing 45 M
E
R
C
I
A
L
CG 10,000 100
35 ft.; 50 ft. with use
permit; or 45 ft. in
compliance with
Section 17.30.040(D)
0 ft.; except that the
build-to-line along the
Gravenstein frontage
shall be 30 ft. from the
highway right-of-way
10 ft. abutting a
residential zone,
none required
otherwise
Varies4
20 ft. abutting a
residential zone;
10 ft. required
otherwise
80%
CD 2000 20
35 ft.; 50 ft. with use
permit; or 45 ft. in
compliance with
Section 17.30.040(D)
0 ft.; 15 ft. on Arthur,
Charles, Henry, and
William Streets, and
East Cotati Avenue, in
compliance with the La
Plaza Specific Plan
10 ft. abutting a
residential zone,
none required
otherwise
Varies4 10 ft. 100%
CI 10000 100 40 ft. 20
20 ft. abutting a
residential zone,
none required
otherwise
20 30 80%
IG 10000 100
20 ft. if located within 50
ft. of a residential zone,
40 ft. elsewhere
20 0 20 30 80%
Source: City of Cotati Municipal Code Title 17, 2022
1 Greater height allowed for accessory structures where authorized by minor use permit (17.42.160). 2 Mixed Use structures in CE, CG, and CD zones may exceed maximum height limit to three (3) and forty-five (45) feet if the upper stories are residentially exclusive with a minimum 50% reserved as affordable to lower and moderate-income households. 3 Build-to-Lines require that buildings have at least 80% of the street-facing façade abutting the build-to-line (required location of new structures). The Buildto-Line may be waived for projects with more than one building where the frontage is occupied with more than one building (17.30.020). 4 Street side of a corner parcel is measured from whichever of the following points results in the greatest setback from an existing or future roadway: 1) The nearest point on the side property line bounding the street; 2) edge of an easement for a private road; 3) inside edge of the sidewalk; or 4) boundary of a planned future right-of-way (17.30.020).
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Packet Pg. 548 Attachment: Attachment 1, Exhibit B2 - Cotati Adoption Draft Technical Background Report (Housing 46 Residential development standards for the City’s Specific Plan areas are shown in Table 21 and Table 22. These areas are regulated by Form Based Codes, with no density limits. Realistic densities for these zones are based on land use controls and are listed in the following tables.
Table 21: Development Standards in Downtown Cotati Specific Plan Area Zone Setbacks Parking Height Realistic
Density
HC Front: 0’-5’
Side Street: 0’-5’
Sideyard: 0’ or 5’
Rear: 20’
Alley: 2’
1.5 spaces/unit
35’ 25-30
units/acre*
LP Front: 0’-8’
Side Street: 0’-12’
Sideyard: 0’ or 10’
Rear: 20’
Alley: 2’
2 spaces/ unit 35’ 20-30
units/acre*
NG Front: 0’-10’
Side Street: 0’-12’
Sideyard: 0’ or 10’
Rear: 10’
Alley: 2’
2 spaces/ unit 50’ 25-35
units/acre*
CA Front: 0’
Side Street: 0’
Sideyard: 0’
Rear: 15’
Alley: 2’
2 spaces/ unit 35’ 25-30
units/acre*
*Based on La Plaza View; See Table 11 of Housing Element Section 3.
Table 22: Development Standards for Santero Way Specific Plan Use Type Setbacks Height Max Lot
Coverage
Realistic
Density
SingleFamilyFront: 8’-12’
Rear: 4’
Side: 9’-14’ from street ROW
5’ from lot line
10’ from Specific Plan property
line for the first floor and
increased by 5’ for each additional
story
35’
2.5 stories
50% 6-12
units/acre
Duplex Front: 8’-12’
Rear: 4’
Side: 9’-14’ from street ROW
5’ from adjacent lot line
35’
2.5 stories
60% 12-15
units/acre
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Packet Pg. 549 Attachment: Attachment 1, Exhibit B2 - Cotati Adoption Draft Technical Background Report (Housing Element CC Resolution) 47 0 built-to line at continuous unit
lot line
10’ from Specific Plan property
line for the first floor and
increased by 5’ for each additional
story
Townhome Front: 8’-12’
Rear: 4’
Side: 9’-14’ from street ROW
5’ from adjacent lot line
0 built-to line at continuous unit
lot line
10’ from Specific Plan property
line for the first floor and
increased by 5’ for each additional
story
35’
2.5 stories
70% 18-20
units/acre*
Live/Work Front: ’-12’
Rear: 4’
Side: 9’-14’ from street ROW
5’ from adjacent lot line
0 built-to line at continuous unit
lot line
10’ from Specific Plan property
line for the first floor and
increased by 5’ for each additional
story
35’
2.5 stories
70% 20-25
units/acre*
* Based on existing projects
The City’s development standards are generally conducive to increased building density for residential development. Mixed use structures in commercial areas are allowed height increases if affordable units are provided and are allowed to build to the front and side yard setbacks to maximize buildable parcel space.
The Downtown Specific Plan contains urban development standards that are unique to the four districts including building placement, height, types and façades.
Development standards are similar to the City’s standards for CE, CG, and CD zones.
For example, 0’ front setbacks and 35 feet in height (50 feet for the NG district) are allowed.
While the City’s standards allow for increased building density for residential development, the City’s code includes design standards for streetscapes (trees, façade, setbacks) to allow for sunshine, airflow, and space that promotes public health and safety (Chap. 17.26). The City established unique and place-based setback standards such as the build-to-line requirements to maintain a cohesive streetscape. The setbacks for proposed buildings in the Specific Plan will effectively shape the public space of streets, enhancing the comfort and convenience of residents and pedestrians. The City’s development standards promote building mass
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Packet Pg. 550 Attachment: Attachment 1, Exhibit B2 - Cotati Adoption Draft Technical Background Report (Housing Element CC Resolution) 48 that accommodates residential units and do not serve as a constraint to housing development.
Parking Requirements
Sufficient parking for vehicles is a necessity for most Sonoma County residents.
However, if parking requirements are excessive, they can reduce the feasibility of developing new housing at the densities necessary to provide affordable housing. The City’s Municipal Code establishes off-street residential parking standards, as summarized in Table 23.
Sites with multiple tenants have aggregated parking standards for each separate use.
Multi-tenant centers can share parking requirements with adjacent non-residential use centers. More residential parking can be provided, but projects are encouraged to not “overpark” by supplying more parking than is necessary.
Parking reductions of up to 15% are available provided that the applicant/ property owner provides sufficient evidence that justifies the request (17.36.080). Other allowable reductions include a waiver of covered parking for affordable units.
Additionally, residential portions of horizontal mixed-use development may provide parking equivalent to multifamily dwellings with no guest spaces. The same applies to vertical mixed use, but a 30% reduction in spaces is allowed in these cases.
The parking requirements are consistent with those of other suburban communities in the North Bay. The City’s parking reductions and shared parking allocations allow flexibility in modifying parking requirements, especially in mixed-use areas with high density. Overall, the City’s parking requirements do not pose a significant or unique constraint to housing production. A revision to the Municipal Code is included in Program 3-1 (Zoning for A Variety of Housing Types) to implement the Government Code §65915 required parking maximums for all multifamily projects without need for a special request. This will further reduce the potential for parking requirements to pose a constraint on new housing development.
Table 23: City of Cotati Parking Requirements
Type of
Residential Use Required Parking Additional Comments
Accessory
Dwelling Unit
(ADU)/ Junior
ADU
1 space per unit On-site parking not required per Section
17.42.170.
Condominium
dwelling units
2 covered spaces within a
garage or carport for each
unit
Guest parking 1 space per four (4) units
Live/work units 2 spaces per unit
Individual
mobilehomes 2 spaces for each unit at least 1 within a garage or carport
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Packet Pg. 551 Attachment: Attachment 1, Exhibit B2 - Cotati Adoption Draft Technical Background Report (Housing Element CC Resolution) 49 Mobilehome
parks
2 spaces for each
mobilehome
plus 1 additional space for each 4
mobilehomes shall be provided for guest
parking throughout the park
Multifamily
Residential
(MFR): Studio
units and onebedroom units
2 spaces per unit at least 1 within a garage or carport MFR: Two- and
three-bedroom
units
2 spaces per unit at least 1 within a garage or carport MFR: Fourbedroom units
and above
2 spaces per unit
or less as required by the review authority.
At least 1 space shall be within a garage or
carport
MFR: Guest
parking
1 space for each four (4)
units
Organizational
house 1 space for each bedroom
Residential Care
Home (RCH): Six
or fewer clients
2 covered spaces within a
garage or carport.
RCH: Seven or
more clients 1 space for each 2 beds 1 space for each 4 beds for guests and employees Residential
development
with density
bonus
1 space per studio to 1-
bedroom
2 spaces per 2-3 bedrooms
2.5 spaces per 4+ bedrooms
Rooming or
boarding houses
1 covered or uncovered
space for each bedroom
Senior housing
projects
1 space for each two (2)
units, with half the spaces
covered
1 guest parking space for each 10 units.
Reduced parking may be provided
Single-family
dwellings
2 covered spaces within a
garage or carport
Source: City of Cotati Municipal Code Ch. 17.36, 2022
Growth Controls
Growth controls are typically established through urban growth boundaries (UGBs) which allow local governments to manage the urbanization of undeveloped land, and growth management ordinances (GMOs) which set a cap on the annual number of units produced. A phased approach to growth controls can effectively conserve open space while balancing housing needs. However, low allocations and excessive limitations can constrain development that prevents jurisdictions from producing their fair share of housing. Every incorporated jurisdiction in Sonoma County has
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Packet Pg. 552 Attachment: Attachment 1, Exhibit B2 - Cotati Adoption Draft Technical Background Report (Housing Element CC Resolution) 50 enacted UGBs that are accompanied by countywide community separators for open space, but many GMOs have been invalidated by recent legislation.
Urban Growth Boundary (UGB)
The City adopted a UGB on November 1998 by a voter-approved measure further described in Policy LU 1.8 of the General Plan. A supermajority (69.5%) of residents voted in favor of Measure Q (2016) to extend the UGB for another 20 years.
The City’s General Plan established criteria to allow amendment of the UGB under a majority vote, as described below:
- No more than 10 acres of land shall be incorporated into the UGB to accommodate residential uses;
- Does not result in unconstitutional taking of private property; - Development of a public park, public school, public facility, public open space or other projects are necessary to promote public health, safety, and welfare; - Exempt projects with vested rights.
The City Council must make supportive findings that demonstrate the need for expanding the existing UGB.
Growth Management Ordinance (GMO)
Growth management provisions are codified in Chapter 17.52 of the City’s Municipal Code and describe allocation measures, procedures, and monitoring of unit allocations.
Under Cotati’s existing growth management program, a maximum of one hundred (100) units are allocated annually, at least twenty-five (25) of which must be exclusively available for low and very low-income households and ten (10) of which are reserved for detached single-family dwellings on individual parcels. Units which were not allocated may be carried into the subsequent years where adequate water and sewer infrastructure capacities are available. The 100-unit annual allocation limit has never been reached in Cotati.
A growth management allocation is required for all non-exempt residential development prior to building permit issuance. Remodels, additions to existing residences, and ADUs/JADUs are exempt from allocation requirements. Additionally, any dwelling units provided in compliance with a Specific Plan may be exempted at the discretion of the City Council (CMC 17.52.020).
Unused allocations may be rolled over for up to three years, for a total of 300 units.
With a maximum of 1110 allowable units in the 6th Cycle, the growth management controls do not appear to pose a constraint and prevent the City from fulfilling its RHNA of 234 units. However, the provisions of SB 330 (2019) likely restrict use of the City’s existing growth management program because it was not voter-approved prior to 2005. Program 2-2 (Streamlining Housing Development) is included in this
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Packet Pg. 553 Attachment: Attachment 1, Exhibit B2 - Cotati Adoption Draft Technical Background Report (Housing Element CC Resolution) 51 Housing Element to bring the City into compliance with current statute. The City does not actively administer or monitor its growth management program; as such, it does not serve as a constraint to development.
Specific Plans
Specific Plans contain place-based development standards and a policy framework that implements the goals and policies of the City’s General Plan per Gov. Code § 65450-65457. Specific plans allow for expedited review of development projects that are consistent with adopted Specific Plans. However, Specific Plans could also pose a constraint to housing production if the standards are too strict or require additional reviews that lengthen the permit approval process.
The City’s Specific Plan provisions are codified in Chapter 17.28 of the Cotati Municipal Code. Special plans in Cotati are listed below:
• Downtown Cotati Specific Plan: A 59.5-acre planned development with 450 maximum residential units, 418,000 sq. ft. of non-residential space, and designated open space at La Plaza Park. The plan contains five distinct districts: historic core (HC), La Plaza (LP), Northern Gateway (NG), Commerce Avenue (CA), and Parks (P). A variety of housing is encouraged including…courtyard housing (retail/commercial first floor and residential flats or townhouses above), duplex/ triplex/ quadplex, and rowhouses. The plan utilizes use standards (setbacks, parking requirements, maximum dwellings, max. non-residential sq. ft., max. bldg. height, FAR) that are unique to each district to regulate development intensity and spatial form of the urban fabric.
Maximum height limits average 35 feet, parking requirements range from 1.5- 2 spaces per residential unit, and lots require a 10-20-foot rear yard setback to an alleyway with 0-foot front yard setback to enhance pedestrian-scale environments. The NG District allows a maximum height of 50 feet with step back features on upper floors to minimize massing while emphasizing mixed core development. This includes first floor commercial and primary residential uses above. The plan was adopted on August 26, 2009.
• Santero Way Specific Plan: A 22.45-acre area proposing 198 residential units, 230,000 sq. ft. of commercial space, and 9,000-20,000 sq. ft. of retail space. There are nine (9) property owners for the varying land use districts:
retail mixed-use, office mixed-use, public park and plaza, residential, and selfstorage overlay. The Specific Plan encourages a variety of housing types and describes each housing type’s development standards per land use district. For example, SFRs, duplexes, townhomes and live/work units are allowed a 0-feet contiguous lot-line side yard setback while meeting building codes to allow for increased density. The plan encourages courtyards that cluster residences among a shared open space concept that also allows for increased density. Cohousing is allowed under a conditional use permit. Additionally, 15% of units within each district must remain affordable per the City’s inclusionary housing ordinance. The plan was adopted and amended in August 2001.
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Packet Pg. 554 Attachment: Attachment 1, Exhibit B2 - Cotati Adoption Draft Technical Background Report (Housing Element CC Resolution) 52 Cotati’s Specific Plans aim to provide a variety of housing types in mixed use districts while maintaining a pedestrian-scale environment. The plans encourage walkability while planning for automobile-oriented development such as the CA district in the Downtown Specific Plan. While the Specific Plan development standards allow for increased density, parking requirements have the potential to reduce achievable densities. Program 2-2 (Streamlining Housing Development) is proposed to address this potential constraint.
Streamlined & By-Right Development Applications
Pursuant to Government Code § 65913.4, the City of Cotati processes affordable housing projects through the Affordable Housing SB 35 Project Supplemental Application, which is submitted concurrently with the Master Plan Project Application.
This application process allows any proposed housing projects that provide on-site affordable units for households making less than 80% AMI to be eligible for permit streamlining, given that the project meets certain criteria. The streamline approval process allows ministerial review and omits CEQA analysis requirement along with CUPs or other discretionary entitlements. The criteria include:
• Consultation with Native American tribes by submitting a notice of intent; • Stated number and type of units of at least two residential units or more and minimum and maximum density ranges, including any applicable density bonus;
• Affordability of units to be incorporated utilizing City’s Municipal Code provision of a) at least 10% total units for households making less than 80% AMI if more than 10 units proposed, or b) at least 20% total units for households making less than 120% AMI, and should be deed restricted to maintain affordability period;
• Conforms with General Plan and zoning districts as an allowable use; • Perimeter of the site is surrounded by at least 75% urban development including, but not limited to, residential, commercial, public institutional, transit corridor or transportation passenger facility, or retail use; • Not located on farmland, wetlands, fire severity areas, hazard waste sites, delineated earthquake fault zones, FEMA-designated floodway or flood hazard area, conservation lands, protected species habitat areas, and demolition of historic structures or existing residential uses;
• Not involving subdivisions unless under provisions of the Subdivision Map Act.
If the project complies with existing zoning and objective design standards, the property owner may volunteer to streamline their project through the SB 35 permit approval process upon provision of 50% affordable units. Program 2-2 (Streamlining Housing Development) establishes a clear process for developers wishing to utilize streamlining provisions in accordance with the City’s zoning.
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Packet Pg. 555 Attachment: Attachment 1, Exhibit B2 - Cotati Adoption Draft Technical Background Report (Housing Element CC Resolution) 53 Housing for People with Disabilities
Persons with special needs, such as the elderly and those with disabilities, must have access to housing. Community care facilities provide a supportive housing environment to persons with special needs in a group environment. The City allows these facilities in the following zones:
• Residential Care Home: Residence for up to six persons allowed within existing structures in all residential zones with no administrative review. New construction requires the same administrative permit as a single-family residence.
• Residential Care: Residential facility for elderly/disabled persons with meals, housekeeping and activities for seven or more clients allowed in RR, RVL, NL, NM, NU, CE and PF with a CUP. Areas with appropriate access to amenities and services are the most suitable for residential community care facilities. Most of these areas are located within allowed zones. These facilities require a CUP as allowed by law to ensure land use compatibility and protect public health and safety. Residential care facilities are only subject to development standards for other residential developments of the same type in the same zone.
Under Program 3-1, the City will allow Residential Care Facilities for 7 or more clients with disabilities as a permitted use in residential zones, subject only to clear, transparent, objective standards. This program will facilitate approval certainty of this housing type.
• Residential Care Facility for the Elderly: Convalescent homes for elderly, disabled, and ailing persons allowed in CG with an MUP; in CE, PF, RR, RVL, NL, NM and NU with a CUP.
In the Cotati Zoning Code, “Family” is defined as an individual, or two or more persons related by blood, marriage, or adoption, or a group of unrelated persons who live together in a dwelling unit as an independent housekeeping unit, which may include use of common cooking facilities or shared household responsibilities.
This definition is broad and inclusive and does not pose any constraints to housing for people with disabilities.
Building Codes and Enforcement
Americans with Disabilities Act (ADA) provisions include requirements for a minimum percentage of units in new multi-family developments to be fully accessible to the physically disabled and another percentage to be “adaptable” to being accessible to the physically disabled. Development of fully accessible and/or adaptable units may also increase the overall project costs. Enforcement of ADA requirements is not at the discretion of the City but is mandated under federal law. The provisions of the ADA applicable to residential uses would apply only to multi-family developments and any residential components of a live-work project in a Commercial Zone.
Compliance with building codes and the ADA may increase the cost of housing production. However, these regulations provide minimum standards that must be followed to ensure the development of safe and accessible housing. Therefore, the
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Packet Pg. 556 Attachment: Attachment 1, Exhibit B2 - Cotati Adoption Draft Technical Background Report (Housing Element CC Resolution) 54 local enforcement of these codes does not significantly constrain the development of housing.
Cotati enforces the 2023 California Building Code, and CalGreen Tier 1 is the most applicable local amendment. The enforcement of the 2023 Building Code and CalGreen Tier 1 amendment have not been identified as having any impact on housing supply and affordability in Cotati. These standards are consistent across most North Bay communities and allow the future cost of home ownership/occupancy to be reduced through lower utility bills (electricity, gas and water), and resulting in a reduced long-term cost of living.
Reasonable Accommodation
Under the ADA, cities must reasonably modify policies when necessary to avoid discrimination because of disability, unless they can show that the modifications “would fundamentally alter the nature of the service, program or activity.” (28 Code of Federal Regulations 35.130(b)(7).) In general, the law states that local agencies retain their ability to regulate land uses and to apply neutral, non-discriminatory regulations, but are required to make accommodations to allow persons with disabilities an equal opportunity to use and enjoy housing in the community.
The City of Cotati adopted its reasonable accommodation ordinance in Section 17.68, Reasonable Accommodations for Persons with Disabilities, of the City of Cotati Municipal Code. The Federal Fair Housing Amendments Act of 1988 and the California Fair Employment and Housing Act implement part of the City’s General Plan Housing Element and provides a procedure for individuals with disabilities to request reasonable accommodation. The Reasonable Accommodation Ordinance states that that an individual(s) with disabilities have an equal opportunity to use and enjoy housing by allowing accommodation(s) with respect to certain City regulations, policies, procedures, and standards. The ordinance is enforced, if said accommodation(s) are both reasonable and necessary to provide such equal opportunity without compromising the City commitment to protecting community character and environmental quality. The City does provide reasonable accommodation for various scenarios, including but not limited to allowances for a wheelchair ramp in a required setback; an increase in building height to permit an elevator installation; or providing an applicant with additional time to submit material, if deemed reasonable under the Acts.
Requests for reasonable accommodation are subject to an administrative permit and are approved within 30 days. There is no fee to request reasonable accommodation.
Upon review of an application, the Director of Community Development will grant the request based on the following findings:
• That the requested accommodation is intended to be used by an individual with a disability who resides or will reside on the property; • That the requested accommodation is necessary to afford an individual with a disability equal opportunity to use and enjoy a residential use;
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Packet Pg. 557 Attachment: Attachment 1, Exhibit B2 - Cotati Adoption Draft Technical Background Report (Housing Element CC Resolution) 55 • The requested accommodation will not impose an undue financial or administrative burden on the City; and
• That the requested accommodation will not require a fundamental alteration in the nature of the land use and zoning.
The reasonable accommodations process is free, ministerial, and fast. It does not pose a constraint.
Development and Permitting Fees
Various permitting fees for housing development, as shown in Table 24, are charged by the agencies within the City of Cotati to cover the cost of processing, evaluating, and ensuring compliance. Per Government Code § 66020, the City is legally required to set permit and development fees in amounts that do not exceed and are equal to the cost of providing services associated with these fees. These fees are established at the time of imposition or project approval. The City’s fee schedule notes that some permit application fees are charged on a fixed fee basis, and some charged as a deposit based on the over-all costs incurred during the permit process, which is further discussed in the Local Processing and Permit Procedures section below.
Permit fees will vary based on the project’s scope of work, location, and discretionary fees required to entitle the project. Planning and engineering fees may vary significantly per project and thus are charged on a full-cost recovery basis after an initial deposit while most building permit fees will remain relatively similar. Other discretionary fees such as in-lieu costs for affordable housing or parking, affordable rental housing linkage, traffic impact, and development impact. After-the-fact permitting fees are two times the building permit fee. Permit types that are not listed usually incur an hourly cost of staff time.
Table 25 compares selected permitting fees from Cotati with jurisdictions of similar populations within Sonoma County. While there is significant variation between different types of permits in different jurisdictions, the fees required by the City of Cotati are generally within the range of fees required by comparable jurisdictions and therefore are not likely to pose a unique or significant constraint to housing development. Fees increase annually based on the San Francisco Bay Area Construction Cost Index, or similar consumer price index to account for inflation and are typical across other jurisdictions.
Table 24: City of Cotati Permitting Fees
Item/Permit Type Fee
Administrative Permit $ 183 hourly
Annexation $ 7,684 initial deposit
Appeals $ 500
Conditional Use Permit
Design Review
Administrative
Preliminary
$ 1,993
$ 6,000 initial deposit
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Packet Pg. 558 Attachment: Attachment 1, Exhibit B2 - Cotati Adoption Draft Technical Background Report (Housing Element CC Resolution) 56 Final $ 2,184 initial deposit
Development Agreement
Environmental Review
CEQA exemption
Initial Study/ Mitigated Negative Declaration /
Negative Declaration
Initial Study/ Environmental Impact Report
$ 183 hourly
$ 7,333 initial deposit to City staff + actual
consultant costs and fees
$ 7,333 initial deposit to City staff + actual
consultant costs and fees
General Plan Amendment $ 16,070 initial deposit
Hillside Development Permits $ 2,184 initial deposit
Limited Term Permits $ 1,000 initial deposit
Pre-Application Reviews
Single-family homes (owner occupied)
Formal conceptual plan review or preliminary
(with written comments)
Determined by staff – actual cost
$ 2,406
Subdivisions
Parcel Map
Tentative Subdivision Map
$ 8,737 initial deposit
$ 16,070 initial deposit
Time Extension $ 4,583 initial deposit
Tree Removal
Initial five (5) trees
≥ 6 trees
City Staff Review
$ 50 each
$ 92 each
$ 733
Use Permit
Minor Use
Modification to previously approved Use
Permit
Major Use Permit
$ 1,818
$ 3,284
$ 4,396
Variance
Minor
Major
$ 1,467
$ 3,667 initial deposit
Zoning Code/ Zoning Map/ PUD Amendment $ 11,000 initial deposit Plan Check of Building Plans/ Permits $ 183 hourly
Source: City of Cotati Master Fee Schedule, September 2022 Table 25: Permitting Fees in Cotati and Comparable Local Jurisdictions City Administrative
Permit
Conditional Use
Permit
Residential Design
Review
Development
Agreement
Cotati $350 (inspection of
modification of
service)
$1,818-$4,369 $183-$6,000 Actual Cost
Sebastopol $454 $1,500 – $3,000 $347 – $4,000 $15,000
Cloverdale $630 $3,070 $4,430 $5,910
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Packet Pg. 559 Attachment: Attachment 1, Exhibit B2 - Cotati Adoption Draft Technical Background Report (Housing Element CC Resolution) 57 Rohnert
Park
$803 $ 2,731 $1,638 residential
remodel
$2,731 new
residence
Actual cost of time
& materials
charged against
an Initial Deposit
as determined by
staff
Source(s): Cotati Master Fee Schedule, 2022; City of Rohnert Park Development Services – Planning Schedule of Fees and Charges, 2022; Cloverdale Master Fee Schedule, 2022; Sebastopol Master Fee Schedule, 2020.
Local Processing and Permit Procedures
Clear regulatory frameworks and straight-forward procedures for obtaining planning and building permits provide developers with consistency and realistic expectations that can significantly decrease expenses incurred during development that may otherwise delay project construction. Projects that must go through unclear and multi-layered permitting authorities can incur increasing project development costs, which ultimately is reflected in the amount of viably affordable units. Administrative processing of planning and building permits allows jurisdictions to apply the local municipal code and zoning ordinances that organize varying land uses within City boundaries.