EAST PALO ALTO
CITY COUNCIL
STAFF REPORT
DATE: July 19, 2022
TO: Honorable Mayor and Members of the City Council
VIA: Patrick Heisinger, Interim City Manager
BY: Rachel Horst, Housing and Economic Development Manager Karen Camacho, Housing Project Manager
SUBJECT: Update on the Draft Housing Element
Recommendation
Receive the report, provide feedback on the Draft Housing Element, and authorize release of the document for a 30-day public review period.
Alignment with City Council Strategic Plan
This recommendation is primarily aligned with:
Priority No. 6: Create a Healthy and Safe Community
Background
Housing Element
Since 1969, California has required all local governments to plan to meet the housing needs of everyone in the community. This requirement is met by adopting a Housing Element as part of the General Plan, also required by the state. The General Plan serves as the blueprint for how the city will grow and develop and includes at least eight mandated elements: land use, transportation, conservation, noise, open space, safety, environmental justice, and housing.
California’s Housing Element Law acknowledges that, for the private market to provide adequate housing statewide, local governments must adopt plans and regulatory systems that provide opportunities for (and do not unduly constrain) housing development.
Every eight years the City is required by State law to update its Housing Element. This includes planning to meet existing and projected housing needs, including our share of the Regional Housing Needs Allocation (“RHNA”).
Housing Element Update Process
Staff has provided updates to the City Council and Planning Commission and sought feedback on the Housing Element on the following dates:
City Council Feedback on the Housing Element
May 10, 2021 Brief Informational update to Planning Commission on Housing Element
March 14, 2022 Update to Planning Commission on 2021 Housing Element and General Plan Annual Progress Report1
March 15, 2022 City Council Authorization to Submit 2021 Housing Element Annual Progress Report, 2021 General Plan Annual Progress Report, and Housing Successor Agency Report to State Agencies2 April 26, 2022 Joint Study Session with Planning Commission and City Council3 July 11, 2022 Planning Commission Housing Element Drafting Update July 19, 2022 City Council Housing Element Drafting Update Staff has also sought public feedback via meetings on the following dates:
Public Feedback on the Housing Element
March –
December 2021
Let's Talk Housing! 4-part webinar series in San Mateo County June 2, 2021 Community Meeting about Outreach Strategies July 19, 2021 Community Meeting #1 (virtual; in English & Spanish)4 February 24,
2022
Community Meeting #2 (virtual; in English & Spanish)5
May 2, 2022 Equity Advisory Group Meeting
May 5, 2022 Community Meeting #3 (in-person and virtual; in English, Spanish & Tongan)6
June 8, 2022 &
June 15, 2022
Intercept Surveys at East Palo Alto Community Farmer’s Market February 24,
2022 – July
2022
Online Surveys (Jamboard Survey and Policies & Programs Survey)
May 25, 2022 –
July 2022
Balancing Act Online Survey
Housing Element Drafting and Current Status
Staff is currently drafting the Housing Element update in anticipation of releasing a draft for 1 March 14, 2022 Planning Commission Meeting:
http://eastpaloalto.iqm2.com/Citizens/SplitView.aspx?Mode=Video&MeetingID=1482&MinutesID=1517&FileFormat=doc&Format=Mi nutes&MediaFileFormat=mpeg4
2 March 15, 2022 City Council Meeting:
http://eastpaloalto.iqm2.com/Citizens/SplitView.aspx?Mode=Video&MeetingID=1804&MinutesID=1518&FileFormat=pdf&Format=Mi nutes&MediaFileFormat=mpeg4
3 April 26, 2022 Joint City Council and Planning Commission Study Session:
http://eastpaloalto.iqm2.com/Citizens/SplitView.aspx?Mode=Video&MeetingID=1808&MinutesID=1529&Format=Minutes&MediaFile Format=mpeg4
4 July 19, 2021 Community Meeting: https://www.youtube.com/watch?v=KI7o9ejCmIo 5 February 24, 2022 Community Meeting: https://vimeo.com/681972749 (English); https://vimeo.com/681972604 (Spanish) 6 May 5, 2022 Community Meeting: https://vimeo.com/711354897 public review in August. HCD requires a 30-day public review period, followed by submittal to HCD, after which the agency has 90 days to return comments to the City. Staff will incorporate HCD’s comments into a final draft and bring this draft to the Planning Commission in a public hearing forum, followed by a public hearing at the City Council by December 2022. A rough timeline is shown below:
Timeframe Activity
Early 2020 Staff began preparation for Housing Element: biweekly 21 Elements meetings, review of current Housing Element, review of new Housing Element laws, etc.
Spring 2021 Staff began analysis with 21 Elements: review of “sites strategies,” planning for community meetings, applications for funding and T.A.
June 2021 –
June 2022
Community Outreach to inform drafting
July-August
2022
Draft chapters of Housing Element (30-day public review period following release of full draft, minimum of 10 days for public comment incorporation)
July 11, 2022 Planning Commission review and input on some chapter drafts July 19, 2022 City Council review and input on some chapter drafts August 2022 Full Housing Element draft released for public review (30-day public review period, followed by 10-day period to incorporate comments) September
2022
(Upon conclusion of public review period) Submit to Department of Housing & Community Development for review
November
2022
Planning Commission Public Hearing
December
2022
City Council adopt Housing Element
January
2023
Housing Elements due to HCD (required by statue)
January
2026
Re-zoning to accommodate the RHNA (on sites identified in the Sites Inventory) completed
The Housing Element consists of the following main sections, or chapters. Please note, these are the main components of the document; some shorter, “miscellaneous” sections are not included here but will be in the final Housing Element.
1. Introduction and Background of East Palo Alto
2. Overview of Housing Element Public Participation/Community Engagement
3. Review of Prior Housing Element
4. Housing Needs Assessment and Analysis of Housing Needs for Special Populations
5. Housing Supply and Review of Affordable Housing At-Risk of Conversion to MarketRate
6. Affirmatively Furthering Fair Housing Assessment and Action Plan
7. Analysis of Actual and Potential Governmental and Non-Governmental Constraints
8. Existing Housing Resources and Programs
9. Analysis of Zoning and Availability of Sites for a Variety of Housing Types
10.Sites Inventory and Analysis
11.Goals, Policies, and Programs
The purpose of this staff report is to share an update on Housing Element drafting progress, with a focus on findings and highlights of the bolded chapters above (2, 4, 6, 10, and all).
Significant portions of these drafts have been completed and, for the purposes of discussion, are provided for reference in Attachments 1, 2, 3, 4, and 5. Staff continues to draft additional sections for each of these chapters, including additional background, charts, and maps, in the weeks leading up to the public review period.
Staff presented an earlier version of this report to the Planning Commission on July 11, 2022.
To highlight key findings and provide further background on each of these sections, the staff report is broken down into four corresponding sections:
• Section I Overview of Housing Element Public Participation • Section II Housing Needs Assessment and Analysis of Housing Needs for Special Populations
• Section III Affirmatively Furthering Fair Housing Assessment and Action Plan • Section IV Sites Inventory and Analysis
• Section V Policies & Programs
Analysis
SECTION I: Overview of Housing Element Public Participation/Community Engagement Outreach Strategies
The Housing Element must reflect the vision of its residents, and to accomplish this, the City of East Palo Alto developed a broad and diverse outreach plan designed to reach as many community members who live and work in the city as possible. Given the inability to hold inperson events due to the COVID-19 pandemic, staff developed different community outreach and engagement strategies, including virtual meetings, digital tools, and safe in-person interactions once the shelter-in-place order lifted. Attachment 1 summarizes the outreach activities. These include:
• Website and social media updates
• City Mailer
• Email Alerts & City Newsletters
• Virtual community meetings
• Virtual Planning Commission and City Council public meetings • Hybrid (virtual & in-person) community meeting
• Online surveys (via Jamboard, Google Forms, and Balancing Act webpage) • Intercept surveys at the East Palo Alto Community Farmer’s Market • Flyer distribution
Policies and Programs Community Engagement
At the joint study session on April 26, 2022, the City Council and Planning Commission received an update on the community engagement on Housing Element policies and programs. Since then, staff hosted a public community meeting on May 5, 2022, through a hybrid in-person and virtual forum. This meeting included an online Housing Element survey.7 Staff received 45 survey submissions assessing the City’s performance on key policy and program areas. Attachment 1 provides an overview of the survey results.
In summary, the main areas where the City can improve based on survey results include:
a. Increasing homeownership opportunities for income-qualified households (focused on existing residents and workers in East Palo Alto).
b. Improving housing and neighborhood conditions.
c. Balancing development that link housing to jobs.
Sites Inventory Community Engagement
Residents also provided input on the potential sites inventory through the Balancing Act webpage,8 a simulation tool that helps residents visualize and identify where new housing development could be prioritized in the City, and the preferred density (measured by number of dwelling units per acre of land) of new housing development.
The City of East Palo Alto received the second-highest engagement compared to other California cities participating in this simulation tool, with 12 respondents total. Our extensive outreach via the City’s website, City newsletters, direct email communications, social media, and in-person flyer distribution helped us receive 196 page views for a total of 20 hours of site use; despite these efforts, the response rate was only 6%. This outcome illustrates the challenges of engaging residents through tools that require tech-savviness.
The following table summarizes the Balancing Act survey results:
East Palo Alto Balancing Act Sites Inventory Survey Results Respondents
Choosing
“Higher
Density”
Respondents
Choosing
“Lower
Density”
Respondents
Choosing
“No housing”
Average
Unit Count
Selected
1a - RBD Zoned for
Housing 75% 25% 0% 592
1b - RBD Zoned for
Housing 50% 50% 0% 127
2 - Four Corners 67% 25% 8% 397
3 - South of Weeks 42% 25% 25% 80
4 - EPA Waterfront 25% 33% 42% 152
5 - Harvest Affordable
Housing Proposal 42% 0% 17% 73
6A - Pulgas East Site 1 42% 17% 42% 57
7 Housing Element Update Survey:
https://docs.google.com/forms/d/e/1FAIpQLScT5ZIkH1lLYaDItYNhw4rOqyrZxKi0PkUGF7WkB0fb0d1frg/viewform (English) and
https://docs.google.com/forms/d/e/1FAIpQLSczDXPzp5XjAhgCWJSr_D0nbKGBXzGfHiM87UptVB5ASbpL2A/viewfor m (Spanish); Jamboard Survey: https://jamboard.google.com/d/1- Wre_PIgoPBYurKEKY_rxKrzfF121jziT2VuYkcE2uE/viewer.
8 East Palo Alto Balancing Act: https://eastpaloalto.abalancingact.com/EPA-balancing-act 6B - Pulgas East Site 2 42% 17% 42% 53
6C - Pulgas East Site 3 58% 25% 17% 123
7 - City of East Palo
Alto 50% 8% 42% 13
8 - San Mateo County
Government Center 17% 17% 67% 39
9 - Ravenswood School
District 42% 25% 33% 104
A - Weeks Street 50% 33% 17% 37
B - University Avenue 83% 0% 17% 11
C - Schembri Lane 33% 42% 25% 7
D - Runnymede Street 33% 33% 33% 6
E - Green Street 1 33% 42% 25% 6
F - Green Street 2 33% 42% 25% 4
G - Donohoe Street 50% 25% 25% 7
H - East Bayshore 58% 17% 25% 8
Overall, the Balancing Act survey results demonstrate there is more appetite for housing. Most residents supported higher density housing on the Ravenswood/Four Corners Specific Area Plan sites. A majority (50% or more) also supported higher density on the following sites:
a. Pulgas Street East Site 3 (APN 63240310)
b. East Bayshore site (807 E. Bayshore)
c. Weeks Street site (851 Weeks St.)
d. Donohoe Street site (801 Donohoe St.)
e. City of East Palo Alto site (2277 University Avenue) An overwhelming majority supported higher density along University Avenue, and a large majority (67%) did not support housing on the San Mateo County Government Center site at 2415 University Ave., where City Hall is currently located.
Staff also spoke with 30 East Palo Alto residents in-person at East Palo Alto Community Farmer’s Markets and received further input on housing density and future housing development. Of the 30 residents staff engaged with, 53% indicated they wanted to see higher-density housing, 20% indicated they wanted to see lower-density housing, and 24% indicated they would visit the City website to learn more. Residents also expressed their thoughts and opinions on the proposed sites inventory, and common input included the need for more affordable housing, ensuring there is a jobs-housing balance, ensuring new jobs do not create displacement pressures on current residents, creating new units that have better habitability, and ensuring there is enough parking.
Key Takeaways from Community Engagement
The key takeaways emerging through the outreach process are detailed in Attachment 1 and summarized below:
a. Housing is personal.
b. The price of housing is a major concern.
c. More housing is needed.
d. More homeownership opportunities are needed.
e. Improved housing and neighborhood conditions are needed. f. Single-family neighborhoods are polarizing.
g. Affordable housing is a top concern.
h. The process is too complicated.
i. Better information resources needed.
j. Issues are connected. These include housing, transportation, climate change, employment and education.
k. Equity is on people’s minds.
l. Anti-displacement is important.
m. Environmentally sustainable development is needed.
n. Regional work matters but there’s more to figure out. o. Diversity in participation was a challenge.
This preliminary input informed the following policies and programs that staff is incorporating into the draft Policies & Programs chapter:
a. Reduced constraints and enhanced incentives for housing development. b. Overlay for non-profit-owned properties of a certain size that commit to building 100% affordable housing
c. Further City streamlining for SB 9 projects
d. Encouraging ADU production to address “missing middle” problem. e. Temporary Use permit for temporary housing for unhoused individuals f. Requiring minimum residential density on sites inventory/housing opportunity sites in RBD
g. Waiving fees for affordable projects
h. Reduced parking for affordable projects
Based on community input, many residents expressed that they would like to see greater density and more sites for affordable housing in the Sites Inventory analysis, which will be further discussed in this report.
Feedback from the Public, Planning Commission, and City Council At the joint study session on April 26, 2022, the City Council and Planning Commission received an update on the community engagement on Housing Element policies and programs.
The City Council, Planning Commission, and members of the public may provide further input on the outreach strategies implemented and guidance on future outreach, as well as input on the findings derived from the community outreach process. Public engagement is an ongoing process, and members of the public will be able to continue to provide input at these Planning Commission and City Council meetings, as well as during the 30-day public review period of the Housing Element Update draft before final submittal to HCD by the end of December.
SECTION II: HOUSING NEEDS ASSESSMENT AND ANALYSIS OF HOUSING NEEDS FOR
SPECIAL POPULATIONS
The Housing Needs Assessment consists primarily of data provided by ABAG/MTC in preparation for the Housing Element. Each jurisdiction received a “data packet” prepared to specifically address each of the statutorily required data points.9 The draft East Palo Alto Housing Needs Assessment can be found in Attachment 2. These data help to more robustly describe the state of housing in East Palo Alto and to provide a basis for planning for development over this eight-year planning period.
Several highlights from this extensive data compilation have been incorporated into the community meetings and outreach referenced above. These include:
Demographic Shifts
The majority of East Palo Alto is made up of people of color, including 66.1% Latinx, 10.9% African-American, and 9.6% Asian, while approximately 10% of the population is White. This is a far larger proportion of people of color, particularly Latinx and African-American, than the rest of San Mateo County.
Since 2000, the percentage of residents in East Palo Alto identifying as White has increased, and the percentage of residents of all other races and ethnicities has decreased, by 3.4 percentage points. The largest absolute increase in residents identified as Latinx, while the largest absolute decrease in residents identified as African-American.
Displacement Risk
64.7% of households in East Palo Alto live in neighborhoods that are “susceptible to or experiencing displacement.” Additional data illustrate some of the factors contributing to displacement risk:
• The City’s housing stock consists of 54.1% single family detached, 4.1% single family attached, 3.4% small multiple-family (2-4 units), and 36.6% medium or large multiplefamily (5+ units). The City has a higher proportion of single-family home renters relative to the rest of the County, and a higher proportion of renters overall– 60% in East Palo Alto versus 40% countywide. In addition, while single-family renters benefit from just cause eviction, they are not protected from high rent increases that is one of the major contributing factors to displacement, meaning that many renter households are without most rental/tenant protections.
• One quarter (25%) of households in East Palo Alto are severely cost-burdened, meaning they spend more than 50% of their income on housing costs, and 28.8% of households spend 30%-50% of their income on rent.
• 25.5% of households in East Palo Alto make less than 30% of AMI, which is considered extremely low-income (“ELI”), compared to 14% countywide. Only 17.4% make more than 100% of the AMI, compared to 49% countywide. These percentages align with tenure: the largest proportion of renters is ELI, while the largest proportion of homeowners earns more than 100% AMI.
• 8.6% of very low-income households (below 50% AMI) experience severe overcrowding, defined as units with more than 1.5 persons per room. 9 The full list of statutorily required data can be found on page 3 of this Housing Element Checklist by HCD: Housing Element Completeness Checklist (21elements.com)
Dramatic Shifts in Housing Market
The reported vacancy rate is 7.4% (for all housing unit types).
The estimated “typical home value” was $936,680 in December 2020, compared to $1,418,330 in San Mateo County. This represents an increase of 151% since 2001 – higher than in the rest of the County and the rest of the Bay Area. Similarly, since 2009, the median rent has increased by 65.7% in East Palo Alto, from $1,210 to $1,630 per month – a much higher increase than in San Mateo County or the Bay Area.
27.5% of East Palo Alto households are larger households with five or more people- illustrating the demand for larger units (3 or more bedrooms).
Special Needs Populations
6.4% of residents in East Palo Alto have a disability, and the most common living arrangement for individuals with disabilities in East Palo Alto is the home of parent /family /guardian. Please note that staff is working with Housing Choices, a Bay Area nonprofit serving individuals with developmental and other disabilities, to obtain more data on this population in East Palo Alto.
The number of students in East Palo Alto experiencing homelessness in 2019-20 (514) represented 43.9% of the San Mateo County total.
This does not represent an exhaustive list of data or conclusions that may be drawn from them. For a full description, see Attachment 2.
SECTION III: Affirmatively Furthering Fair Housing Assessment and Action Plan The State of California and the U.S. Department of Housing and Urban Development (HUD) require that all public agencies affirmatively further fair housing (AFFH) or take meaningful actions to overcome disparities in housing needs and access to opportunity, combat segregation and foster integrated and inclusive communities.
The Housing Element must incorporate an analysis of fair housing outreach and capacity, integration and segregation, access to opportunity, disparate housing needs, and current fair housing practices. While the AFFH chapter provides an analysis in detail (see Attachment 3), AFFH considerations are incorporated throughout all the Housing Element chapters.
Identifying AFFH Issues
A County-wide AFFH survey was administered to capture residents’ needs regarding affirmatively furthering fair housing, and found the following housing challenges (based on responses from 53 East Palo Alto residents):
a. About 41% of respondents indicated they would like to move but can’t afford anything that is available.
b. About 35% of respondents said their house or apartment is too small for their family. c. About 20% of respondents said they are often late on rent payments and 16% indicated they can’t keep up with utilities.
d. 40% of respondents indicated their neighborhood does not have good sidewalks, walking areas, and/or lighting, and 25% indicated schools in their neighborhood are poor quality.
e. 32% of respondents said they have experienced displacement in the past five years, common reasons for displacement included:
i. Rent increased more than I could pay; and
ii. Landlord wanted to rent to someone else.
f. 29% of respondents indicated they had been discriminated against when looking for housing.
The AFFH Appendix of Attachment 3 compares survey responses with other jurisdictions in San Mateo County, allowing for a comparative analysis. These survey results align with what staff heard in past community engagement activities.
Fair Housing Issues and Possible Contributing Factors
The County-wide AFFH survey helped identify a few key fair housing issues in East Palo Alto.
These key fair housing issues include:
• Cost burden for Hispanic/Latinx and Black/African American households • Entire City is considered vulnerable to displacement
• Lack of sidewalks, good street lighting and walkability in some neighborhoods • High rates of fair housing discrimination
• Applicants for mortgage face high rates of denial, highest for Black/African American and Hispanic/Latinx applicants
• Higher portion of children than rest of county attending lower-performing schools An analysis of the city’s history of segregation and discrimination helps answer what may be some contributing factors to these fair housing issues. Possible contributing factors include:
• Decades of discrimination in employment, education, and housing markets • Race-blind policies still generate disparate outcomes • Migration to East Palo Alto due to relatively more affordable rents and home prices; neighborhoods with highest performing schools have high housing prices, pushing families into areas with schools that have fewer resources • Low-income residents seeking affordable housing more likely to work low wage jobs that do not support cost of living, resulting in cost burden and overcrowding • K-12 achievement gaps impacting future employment opportunities • Historically low private sector investment
Recommendations to Address Fair Housing Issues
The Housing Elements encourages examining specific policies and programs that may help address systemic challenges to furthering fair housing. The “Housing-specific policies enacted locally” section of Attachment 3 identifies the following policy and program ideas, which may be incorporated into the Policies & Programs chapter:
• Anti-Displacement Plan
• Rental registry
• Homebuyer assistance program
• Mortgage and rental assistance (beyond pandemic)
• Foreclosure assistance
• Living wage employment ordinances
• Housing counseling
• Acquisition and unsubsidized properties with affordable rents • Construction of 2-3 bedroom affordable housing units for larger families • Engaging the school district to address performance gaps; • Exploring establishment of cooperatives/community ownership of housing; • Seeking funding from the private sector to add neighborhood improvements communities that have the greatest needs; and
• Establishing a land banking program (with that funding). • Standardized review metrics of housing developments
Some of these policies and programs overlap with those discussed at the April 26, 2022 study session on the Housing Element. Those which were not discussed are still under consideration by staff and may be incorporated into the Goals, Policies, and Programs Chapter of the Draft Housing Element for public review.
SECTION IV: SITES INVENTORY AND ANALYSIS
Purpose of the Sites Inventory
For the Sites Inventory, HCD requires a site-by-site analysis of parcels in the City where housing development is expected to occur over the eight-year planning period. Using an HCDprovided form, jurisdictions must provide information about each site to illustrate the key assumptions used to calculate the estimated number of units. The total number of units, by income category, from the sites in the Sites Inventory must meet or exceed the City’s RHNA.
Staff has assembled a list of potential sites for the Sites Inventory; this list largely reflects what was provided in the April 26 Study Session on the Housing Element, with additional analysis.
This list may be found in Attachment 4.
According to HCD guidance for choosing suitable sites to accommodate the RHNA, lowerincome housing is best accommodated on sites larger than 0.5 acres or smaller than 10 acres and zoned for a minimum 30 dwelling units per acre density.10 Nonvacant sites should not exceed 50% of all sites in the Sites Inventory.
For reference, zoning designations that allow for a minimum of 30 du/acre include:
Zoning Min/Max Du/Acre
Residential High Density 3 22 to 43
Residential High Density 5 22 to 43
Mixed Use Corridor 1 22 to 65
Mixed use Corridor 2 22 to 65
Mixed Use High 43 to 86
Residential Urban High Density 43 to 86
Bay Rd. Central 0 to 50*
4 Corners 0 to 60*
10 This is the “default density” for lower-income housing for San Mateo and other metropolitan jurisdictions, according to HCD:
https://www.hcd.ca.gov/analysis-of-sites-and-zoning
*No minimum specified, but density may be sufficiently high to support assumption of lowerincome development on the site.
Not all sites in the draft Sites Inventory fall within the 0.5-to-10 acre limits. This will require additional justification in the Sites Inventory Analysis, though the sites may be used to account for Above-Moderate (market-rate) units only. There are currently 6 sites smaller than 0.5 acres and 1 site larger than 10 acres on the list. Well over half of the sites are vacant, with some key redevelopment sites.
In Attachment 4 each site is detailed in a chart that contains the following, based on HCD requirements:
Entry Description
APN Assessor’s Parcel Number
Size HCD considers the appropriate size range for lower-income housing to be sites that can support 50 to 150 units, or between .5 acres and 10 acres. Smaller or larger sites can be considered for market-rate housing.
General Plan land use
designation
As identified in General Plan.
Zoning designation Existing zoning, e.g., RMD-1, in General Plan and Specific Plan, if applicable
Allowable density
(minimum and maximum)
Density, or dwelling units per acre (“du/acre”)
Development capacity Estimate the number of units likely to be built on the site.
Jurisdictions must justify these estimates and state their assumptions in the narrative section of the Housing Element.
See “capacity adjustment” below.
RHNA affordability levels Indicate which levels of affordability will be served by the site (lower-income, moderate, above-moderate). For lowerincome RHNA, default density of the site must be a minimum of 30 du/acre. HCD encourages jurisdictions to choose sites near transit, high-performing schools, jobs, amenities (e.g. parks, grocery stores, healthcare), with good infrastructure and no environmental mitigation needed.
Existing use If site is nonvacant, describe what is currently on the site.
Publicly owned Any sites owned by City, County or federal government.
Site status Indicate whether the site is available or whether there is a pending project on it.
Infrastructure availability Address whether there are sufficient water, sewer, and dry utilities available and accessible to support housing
Development. If not, include a program in the Housing
Element that ensures access and availability to
infrastructure to accommodate development within the
planning period.
Environmental constraints To the extent the information is available, provide a general description of any known environmental or other features (e.g., presence of floodplains, protected wetlands, oak tree preserves, very high fire hazard severity zones) that have the potential to impact the development viability of the identified sites.
Included in prior Housing
Element(s)
If the site was used in a prior sites inventory, the jurisdiction must demonstrate why it is likely that the parcel will develop in the next RHNA cycle.
Overview of Types of Sites in the Sites Inventory
The number of estimated units total over the eight-year planning period from all sites included in the Sites Inventory, also referred to as “Housing Opportunity Sites” and shown in Attachment 4, is summarized below:
Total Units from Sites Inventory Sites vs. RHNA 6
VLI LI MOD Above-Mod Total
Housing
Opportunity
Sites
472 206 34 1011 1723
RHNA 6 165 95 159 410 829
Difference 231 103 -125 580 830
Percentage
difference 186% over 117% over 79% under 147% over 108% over *Totals do not include ADUs.
As discussed in prior staff reports, the East Palo Alto Sites Inventory contains many “pipeline units,” or units in projects that have been entitled or received SB 35 Zoning Clearance, and that are expected to apply for a building permit or begin construction later in 2022 or in subsequent years. All such units can be counted towards the next RHNA cycle, as was shown in Attachment 2 to the April 26 Study Session staff report. Taking these unit counts into account, the City can meet or slightly exceed the RHNA in nearly every category, except for Moderate-Income units.
For other sites in the Sites Inventory, there is an active development application with a high level of confidence they will lead to construction of units within the eight-year Housing Element cycle (2023-2031)-- or there is significant developer interest and potential feasibility, but the ability to develop residential units relies on a re-zoning of the parcel. For these reasons, in calculating the realistic capacity of the sites, staff relied in many cases on the development proposal or preapplication. If staff estimated the number of units using a different methodology, this is indicated in Attachment 4.
21 Elements, the technical assistance provider for Housing Elements in San Mateo County, recommends a “buffer” of 30% for lower-income units. As the chart above shows, the City’s Sites Inventory unit totals exceed the VLI, LI, and Above-Mod RHNA by more than twice the amount required, while MOD units fall short by 79%. Staff is working with HCD to determine how to accommodate more MOD units from the RHNA through methodological adjustments or other means.
The Sites Inventory shown in Attachment 4 is broken down into the following types of sites, each with its own description:
Entitled or Ministerially-Approved Projects
Site Size Zoned
Density
Assumed
Density
VLI LI MOD AboveModTotal
965 Weeks
2.52 22 to 43
or 40 54 42 93 1 136
1804 Bay Rd.
.99 22 to 65
or 50 75 10 65 75
2331 University .89 22 to 65 37 4 3 26 33
1201 Runnymede
.932
22 to 43
or 40 34 3 3 26 32
760 Weeks .52 12 to 22 19 1 1 8 10
120-126 Maple
Lane
.177
(total) 12 to 15 15 4 4
APN 063265300
Runnymede/Clarke .156 12 to 15 12 1 2 3
Here and in all subsequent charts, “Zoned Density” refers to the density permitted for that zoning type; “Assumed Density” is the density of the proposed project and/or the density used to calculate the number of units in each income category. It is provided in dwelling units per acre. Some contain two zoned densities: one from the General Plan and one from the Ravenswood/4 Corners Specific Plan.
Projects Not Approved, but High Probability of Development This additional “pipeline” category includes sites with a minimum 30 du/acre and size between
0.5 and 10 acres, which can support lower-income housing, in addition to some lower-density or smaller infill sites with an active Planning application. Multiple sites zoned RMD-2, with allowable density between 12-22 du/acre, have seen development interest. Where the developer has agreed to meet the requirements of the City’s inclusionary housing ordinance, this results in a small number of affordable units in the project.
Site Size
(acres)
Zoned
Density
Assumed
Density
VLI LI MOD AboveModTotal
Woodland Park
Euclid
Improvements11 3.9
22 to 43
or
43 to 86 155 444 444
Four Corners 6.02 43 to 86 30 36 144 180
11 Woodland Park is proposing to provide between 75 and 89 inclusionary units off-site (an in-lieu fee will be paid for the difference if not all 89 are built off-site), which will be deed-restricted to 35-60% AMI. The project will demolish and rebuilding 160 rent-controlled units as a part of the new development, which remain restricted to the Annual General Adjustment (AGA) each year or revert to market-rate if these units are or become vacant upon the completion of the new development. In this chart, only the net-new, market-rate units are counted.
or
up to 40
717 Donahoe .66 12 to 22 21 1 1 12 14
990 Garden 1.32 up to 12 6 2 6 8
2340 Cooley .26 12 to 22 31 1 7 8
Projects with Lower Probability of Development, But Development Interest This category consists largely of very low-density, above-moderate developments with single family-home or townhome subdivisions and some smaller sites (less than 0.5 acres). It contains one site suitable for lower-income housing.
Site Size
(acres)
Zoned
Density
Assumed
Density
VLI LI MOD AboveModTotal
547
Runnymede
.45 12 to 22 15 7 7
1062
Runnymede
.92 up to 12 6 6 6
812 Green .89 up to 12 6 5 5
842 Green .59 up to 12 6 4 4
801
Donahoe
.45 12 to 22 6 5 5
755
Schembri
1.435 12 to 15 4 17 17
807 E.
Bayshore
.55 up to 22 15 12 12
Lincoln St.
(APN
063186270)
.254 up to 12 8 1 2 3
851 Weeks .65 22 to 43
or up to
40 40 16 10 26
Publicly-Owned Sites with Potential for Development or Redevelopment These sites include a City-owned site, the Senior Center, County-owned Government Center, and a site owned by the Ravenswood Elementary School District.
Site Size Zoned
Density
Assumed
Density
VLI LI MOD AboveModTotal
2277
University
.36 up to
60 30 19 1 20
560 Bell .736 n/a 30 14 8 22
2415
University
2.045 22 to
65 or
up to
50 55 60 1 61
Bay Rd.
(APN
063090080)
n/a 30 26 26 26 78
Nonresidential Zoning, but Residential Development Application (RBD) These sites are in the Ravenswood/4 Corners Specific Plan Area and reliant on the rezoning process that will occur starting in Fall 2022.
Site Size Zoned
Density
Assumed
Density
VLI LI MOD AboveModTotal
EPA
Waterfront
29.6 (9
usable)
n/a 29 52 208 260
1103 Weeks
St. (Harvest
offsite)
1.6 n/a 59 95 95
Weeks St
(APN
063271490)
2.7 n/a 30 51 30 81
Sites with (Re)development Potential in Ravenswood Business District These sites are located in the RBD area and are zoned for relatively dense housing.
Site Size Zoned
Density
Assumed
Density
VLI LI MOD AboveModTotal
791
Weeks
.89 22 to 43
or up to
40 30 22 12 34
1923 Bay
Rd.
.99 22 to 65
or
up to 50
40 25 15 40
Accessory Dwelling Units
This category includes projected ADUs and JADUs for the eight-year planning period. These units may be counted towards the RHNA; numbers based on past production.
Since 2019, the City has issued an average of 15.6 ADU permits per year.12 Based on the annual average since 2019,13 the City would project 125 ADUs being permitted over the eightyear planning period. Using ABAG’s survey data to distribute the projected units by income category produces the following estimates:
ADU Estimates for RHNA 6 Period
Income Category Percentage Total
Very low 30% 38
Low 30% 37
Moderate 30% 37
Above moderate 10% 13
12 The number of ADUs per year since 2019: 8 in 2019, 10 in 2020, 29 in 2021. 13 Most cities base their determination of annual ADU permits by averaging the building permits approved each year since 2019, when state law made it easier to construct the units.
Affirmatively Furthering Fair Housing Considerations for Sites Inventory The Sites Inventory must demonstrate that the sites chosen are not concentrated in one area of a jurisdiction, especially when a jurisdiction has sites of varying “opportunity” levels, as based on the TCAC Opportunity Map.14 Furthermore, the Sites Inventory should limit the number of lower-income housing sites in areas deemed Racially/Ethnically Concentrated Areas of Poverty (“R/ECAPs”).15
As the maps provided in the Affirmatively Furthering Fair Housing overview demonstrate, East Palo Alto does not have high variation in terms of “opportunity” areas, nor does it contain R/ECAPs. However, in 2019, three Census tracts deemed “edge R/ECAPs” existed in East Palo Alto—which means they are majority people of color and have a poverty rate two times higher than the countywide Census tract average. Given the overall data on housing needs, location of housing sites is less of a concern within the City than within the region in which East Palo Alto is situated.
The selection of sites in the Sites Inventory reflects different areas of the City, with an emphasis on larger parcels in the Ravenswood/4 Corners Specific Plan Area (“RBD”). The Sites Inventory also reflects denser housing development not concentrated on the Westside, where most of the City’s rental housing stock is located, with the exception of Woodland Park.
Staff does not find that the selection of sites in the Sites Inventory would contribute further to the trends identified in the Affirmatively Furthering Fair Housing assessment.
Addressing Infrastructural and Other Factors Affecting the Sites Inventory Constraints of any kind, whether non-governmental or governmental, must be addressed in the Housing Element wherever relevant to the production of housing. At a minimum, jurisdictions must list these constraints in the Analysis of Governmental and Non-Governmental Constraints to Housing chapter of the Housing Element and describe the ways that the jurisdiction is working to reduce or eliminate them. In addition, where infrastructure limitations are known impediments to the development of individual Housing Opportunity Sites, the jurisdiction must also address them in the Sites Inventory and Analysis.
Staff continues to collect key data and draft the Analysis of Governmental and NonGovernmental Constraints to Housing, a chapter that is not a focus of tonight’s discussion on the Housing Element. However, staff finds that information pertaining to infrastructure is directly relevant to the discussion of individual sites and is therefore including a brief overview of water and sewer availability as well as fee processing and permit times for contextual purposes in this staff report.
Water and Sewer Infrastructure Availability
In addition to requiring jurisdictions to analyze each site for water and infrastructure availability, 14 TCAC opportunity map: https://belonging.berkeley.edu/2022-tcac-opportunity-map 15 According to the AFFH analysis provided, R/ECAPs “are meant to identify areas where residents may have historically faced discrimination and continue to be challenged by limited economic opportunity.” Racial Concentrated Areas of Affluence (“RCAAs ”), on the other hand, “are meant to identify areas of particular advantage and exclusion.” HCD and HUD’s definition of a Racially/Ethnically Concentrated Area of Poverty is: a census tract that has a non-White population of 50 percent or more (majorityminority people of color) AND a poverty rate of 40% or more; OR a census tract that has a non-White population of 50 percent or more (majority-people of color) AND the poverty rate is three times the average tract poverty rate for the County, whichever is lower. the Housing Element also should include a detailed description of existing or planned water, sewer, and other utilities supply citywide, past challenges related to infrastructure, and how the City has responded since the last Housing Element.
In East Palo Alto, one of the main impediments to the production of residential units has historically been lack of water supply, ultimately leading to a 2016 moratorium on all new development due to the water emergency. In July 2017, the City entered into an agreement with the City of Mountain View for $5 million to receive $1 million gallons of water per day, and in 2018, the City received .5 million gallons per day from Palo Alto, allowing the City to resume development. Since the end of the water moratorium, the City has seen a major increase in development proposals.
While the City’s securing of these permanent water transfers has improved the overall water supply, the City continues to face the challenge of water distribution and storage. However, the City has taken major steps to address these shortfalls over the last five years.
The City is currently working with EKI Environment & Water to draft an updated Water System Master Plan (“WSMP”), a draft of which is available online.16 The WSMP will identify costeffective strategies to upgrade the existing distribution system to meet the current and future water demand by providing a 20-year capital improvement program to help guide future capital expenditures in the City and a calibrated distribution system hydraulic model using the City’s geographical information system.
The City also has initiated and completed several key capital improvement projects aimed at improving water storage and distribution citywide:
• O’Brien Turnout Connection Upgrade Project - completed • Purdue Ave. 16-inch transmission main, which includes installation of a new turnout connection to the SFPUC (San Francisco Public Utilities Commission) system to feed the Ravenswood Business District – design complete
• Gloria Bay Well – completed
• Pad D Standby Well to secure an emergency source of potable water supplies in the event of an emergency interruption of supplies from the San Francisco Public Utilities Commission) – under construction
• University Ave and Cooley Ave 12-inch Water Transmission Main – design 100% complete and projected completion early 2023
• Water System Master Plan 2022 which will be used to create a water capital improvement program that includes both maintenance and expansion of the City system- underway
With these improvements in place, the City will be much better positioned to accommodate existing and future water demand and to ensure the health and safety of all residents.
As discussed in the April 26 Study Session staff report, many development projects have experienced delays due to the lack of a sewer connection from the East Palo Alto Sanitary District (“EPASD”). If sewer issues with EPASD are not resolved, East Palo Alto will continue to fall behind on its RHNA. It will be essential to document in the Housing Element the process and outcomes of the San Mateo County Local Agency Formation Commission (“SMCLAFCo”) 16 See: Water System Master Plan 2022 | City of East Palo Alto (cityofepa.org) Municipal Service Review (“MSR”) and sphere of influence update, adopted by SMCLAFCo on June 15, 2022,17 and subsequent actions by EPASD addressed by City Council on June 21, 2022.18 A City Council study session to discuss next steps based on the SMCLAFCo recommendations is tentatively scheduled for the end of July.
Permitting Fees and Processing Times
East Palo Alto participated in the 21 Elements survey of jurisdictions’ fees and average processing times to inform the Governmental and Non-Governmental Constraints analysis in the Housing Element. While a much deeper analysis will be provided in the Governmental and Non-Governmental Constraints chapter, this comparison across 21 jurisdictions is helpful to understand how development may be affected by jurisdiction-specific costs and lengths of time required to begin construction.
The below chart shows a comparison of East Palo Alto’s responses with the other jurisdictions in San Mateo County (please note that some results may change as jurisdictions update their numbers). The responses were provided for single family homes, a prototypical 10-unit multiple-family building, and a prototypical 100-unit multiple-family building.
Total Fees (includes entitlement, building permits, and impact fees) per Unit Single Family Small Multiple-Unit Large Multiple-Unit
Atherton $15,941 No Data No Data
Brisbane $24,940 $11,678 No Data
Burlingame $69,425 $30,345 $23,229
Colma $6,760 $167,210 $16,795
Daly City $24,202 $32,558 $12,271
East Palo Alto $80,866 $30,812 $19,181
Foster City $67,886 $47,179 $11,288
Half Moon Bay $52,569 $16,974 No Data
Hillsborough $71,092 No Data No Data
Millbrae $97,756 $6,824 $55,186
Pacifica $33,725 $40,151 No Data
Portola Valley $52,923 No Data No Data
Redwood City $20,795 $18,537 $62,696
San Bruno $58,209 $72,148 $39,412
San Mateo $99,003 $133,658 $44,907
South San Francisco $81,366 $76,156 $32,471
Unincorporated San
Mateo $36,429 $27,978 $10,012
Woodside $70,957 $82,764 No Data
Source: 21 Elements Fee survey; East Palo Alto.
17See: East Palo Alto Sanitary District, City of East Palo Alto, West Bay Sanitary District - 2021-2022 | County of San Mateo, CA (smcgov.org)
18 See: Update and Next Steps following SMLAFCo Adoption of the Municipal Service Review for the City of East Palo Alto, East Palo Alto Sanitary District, and West Bay Sanitary District - City of East Palo Alto (iqm2.com) As is shown above, East Palo Alto’s fees for multiple-family units fall within the mid- to lower range, while the per-unit single family home fee is among the higher fees. This may be attributed to the City’s Inclusionary Housing In-Lieu Fee, a portion of which is required for a single-family development and are most easily calculated for this type; it is unclear if inclusionary fees were assumed in other jurisdictions. Please note that the fee survey did not include outside agencies’ fees, such as school districts, fire districts, or sanitary districts. 21 Elements then placed these costs into the context of total development costs for multiplefamily housing in the area, based on a report by Century Urban. Based on the estimated development costs, East Palo Alto’s fees comprise approximately 4% of those costs for all three development types. This is comparable to other jurisdictions.
The 21 Elements survey also included processing times for different levels of complexity.
Please note that there are some characteristics specific to each jurisdiction that may shorten or lengthen an average timeline. For example, in East Palo Alto, most projects are reviewed by the Planning Commission, so that “Discretionary By-Right” projects would still require some level of Planning Commission review. In addition, these processing times include both Planning and Building phases:
Permit Processing Times (in months)
ADU
Process
Ministerial
By-Right
Discretionary
By-Right
Discretionary
(Hearing
Officer if
Applicable)
Discretionary
(Planning
Commission)
Discretionary
(City Council)
Atherton 1 to 2 1 to 3 2 to 4 N/A 2 to 4 2 to 6
Brisbane 1 to 2 2 to 6 N/A N/A 4 to 12 6 to 14
Burlingame 1 to 2 2 to 3 2 to 3 N/A 3-4 standard
project; 12
major project
13 months
Colma 1 to 2 1 to 2 1 to 3 2 to 4 N/A 4 to 8
Daly City 1 to 2 2 to 4 N/A N/A 4 to 8 8 to 12
East Palo Alto 2 to 5 2 to 5 6 to 20 6 to 12 9 to 18 12 to 24 Foster City 1 to 2 1 to 2 1 to 2 3 to 6 6 to 12
Half Moon Bay 1 to 2 2 to 4 3 to 6 4 to 12 6 to 15
Hillsborough - - - - - -
Millbrae 0 to 2 3 to 6 1 to 3 3 to 8 3 to 8 4 to 9
Pacifica 1 to 2 2 to 3 4 to 5 5 to 6 5 to 6 7 to 8
Redwood City 2 to 3 3 to 4 N/A 8 to 10 12 to 18 18 to 24 San Bruno 2 3 to 6 N/A 3 to 6 9 to 24 9 to 24
San Mateo 4 to 8 1 to 2 4 to 7 N/A 9 to 12 9 to 13
South San
Francisco
1 1 2 to 3 2 to 3 3 to 6 6 to 9
Unincorporated
San Mateo
1 to 3 3 to 6 4 to 9 6 to 12 6 to 18 9 to 24
Woodside 1 to 2 1 to 2 N/A N/A 2 to 6 3 to 8
While staff responded to this survey as written, staff finds it is most appropriate to separate out the types of development processes into those specific to East Palo Alto.
The chart below shows average processing times for each:
Note: Assume 30 days for initial review and 30 days maximum upon resubmittal for Planning and 30 days initial review and 2 weeks maximum upon resubmittal for Engineering or Building.
Type Assumed Actions Length of Time
ADU/JADU Zoning Clearance and
Building review/inspection
1-2 months
Single Family Administrative Design
Review, Site Plan Review,
Building review/inspection
4-6 months
Moderate-Sized Multiplefamily Tentative Map Review,
Design Review, CEQA -
Categorical Exemption,
On/Offsite Improvements,
Building review/inspection
8-10 months for less
complex projects
12-18 months if Initial
Study required, consultant
team, etc.
Large Multiple-family Tentative Map Review,
Design Review, CEQA -
EIR, Zoning Change,
major grading, On/Offsite
Improvements, Building
review/inspection
18-24 months
There are several other typical actions not included in the “assumed actions” above that may affect a project’s timeline but are not directly related to staff processing of the application.
For example, Planning Commission approval is required for projects not subject to ministerial review (SB 35 projects, ADUs/JADUs) or single-family homes. Allotting time to each development on the Planning Commission agenda with a limited number of meetings and several developments in the queue can increase the amount of time a project requires to obtain Planning approval.
Similarly, the City’s community outreach policy,19 which was adopted in May 2019, requires developers to engage in different levels of outreach based on the size of their project. While community outreach is a necessary and desired component of the development process, it is incumbent upon the applicant to fulfill these requirements, and they must do so in a timely manner.
The above timeframes may still reflect unforeseen delays due to several additional factors, both internal and external. As with all jurisdictions processing unprecedented numbers of development applications, City staff has made strides towards processing of ADUs and other types of Zoning Clearance, such as SB 35 projects, but staff also continues to seek ways to improve processing of applications. Beyond processing times, it is necessary to acknowledge that outside agency review times and infrastructure demands, as discussed above, have placed delays on projects, in some cases by months to years. 19Please see: https://www.cityofepa.org/planning/page/community-outreach-policy SECTION V. POLICIES AND PROGRAMS
As referenced at the April 26 study session and discussed in the Outreach Summary and AFFH sections above, the Policies & Programs chapter of the Housing Element incorporates themes and findings from several sections of the Housing Element, including: input from the community through various channels of community outreach; analysis of fair housing issues; review of housing needs data; review of governmental and non-governmental constraints; and evaluation of the current Housing Element.
The goals, policies, and programs in this chapter are intended to respond to these findings and constitute the actions that the City will take over the coming eight years to address the City’s housing challenges and improve the overall state of housing in East Palo Alto. HCD places emphasis on “operationalizing” the policies and programs described in a jurisdiction’s Housing Element, meaning that they will be scrutinized for specificity and thoughtfulness regarding the timeline, staffing, and other resources needed to accomplish each one.
Staff continues to refine and properly format each of the policy suggestions discussed at length at the April 26 study session and further elaborated upon in community meetings. The table below summarizes staff recommendations and additional direction form City Councilmembers and Planning Commissioners on April 26:
Theme/Goal Policy or Program Idea
Environmental Justice/Affirmatively
Furthering Fair Housing
• Develop environmental “overlay” to avoid
building housing in at-risk areas
• Resolve issues with EPASD to improve
sanitary sewer infrastructure and reduce
processing delays
Incentives for affordable housing
development
• Affordable housing overlay zone – study
citywide and nonprofit-specific
• Minimum density on housing opportunity sites
• Fee waivers for affordable projects
• Reduced parking for affordable projects
Encouraging smaller-scale housing like
duplexes/triplexes and (market-rate)
ADUs
• Next phase of streamlining for ADUs
• Fee reductions or delay of payment of fees
• Outreach targeting smaller developers
ADUs as lower-income affordable
housing
• Formalized amnesty and legalization process
of unpermitted second units
• Public/private partnerships to fund
rehab/repairs
• Additional loan programs, like CalHome, to
build deed- restricted affordable ADUs
Promoting homeownership opportunities • Leverage all available federal funding support for downpayment and first-time homebuyer
assistance
• City first-time homeowner program or
strengthened partnership with HEART
• Advocate for these programs at regional level
Anti-displacement/Affirmatively Furthering
Fair Housing
• Jobs-housing linkage that links production of
commercial office space to affordable housing
production (especially in RBD)
• Strengthen housing replacement requirements
• Preservation/rehabilitation
Governmental Transparency • Improved website/communications on Housing issues
Conversion of Commercial or Retail to
Housing
• Study feasibility of Gateway 101 Shopping
Center retail to housing conversion
Special Needs Populations • Temporary Use Permit for temporary housing The following additional policy ideas originated from public feedback obtained through surveys and community meetings, in addition to staff additions from AFFH analysis and preliminary review of governmental and non-governmental constraints.
Theme/Goal Policy or Program Idea
Anti-Displacement • Exploring establishment of cooperatives and community ownership of housing
• Direct assistance for first and last month’s
rent/deposit assistance
• Opportunity to Purchase Act
• Commercial Linkage Fee update
• Anti-Displacement/Tenant Education Services
RFP
Encouraging ADUs • Preapproved ADU designs/plans
Safe and Healthy Housing • Strengthen monitoring/enforcement of habitability issues
• Formalized legalization process for
unpermitted units (and code enforcement
violations in general)
• Inventory of “at-risk” housing
• Preservation rehab of aging housing stock
• Providing childcare in affordable housing
Funds for Affordable Housing • Gross receipts tax ballot measure • Affordable Housing Fund plan
• Prohousing designation from HCD
Reducing development costs and
processing times
• Objective development and design standards
• Address issues with EPASD
Stewardship of affordable housing/BMR
portfolio
• RFP for future BMR Program management
• Rent registry
Development of public lands • Study feasibility of affordable housing at public sites in the sites inventory
Promote first-time homeownership and
support homeowners
• City-supported financial literacy program
• Foreclosure prevention/California Dream for All
Improved infrastructure to support
housing
• Water System Master Plan and other City
improvements
• Resolution with EPASD
Special Needs Populations • Longer-term solutions to RVs parked in public right of way
• Initiatives to address homelessness and
collaboration with County
Implementation of Housing Element
Workplan + other Housing work
• Participate in countywide shared housing staff
program
• Collaborate with Planning on key updates to
Development Code
The draft Policies and Programs can be found in Attachment 5.
Next Steps
Pending City Council direction, staff will release the Draft Housing Element for the 30-day public review period before end of August 2022 and submit the document, with revisions as needed to HCD for its 90-day review period in September 2022. Following receipt of HCD comments, a revised Draft Housing Element will be presented to the City Council for adoption by December 2022.
Fiscal Impact
None associated with this staff report.
Public Notice
The public was provided notice by making the agenda and report available on the City’s website and on a bulletin board located at City Hall: 2415 University Avenue, East Palo Alto.
Environmental
The action being considered at this time does not constitute a “Project” within the meaning of the California Environmental Quality Act (CEQA), pursuant to CEQA Guideline section 15378 (b)(5), in that it is a government administrative activity that will not result in direct or indirect changes in the environment.
Adoption of the final Housing Element at the end of 2022 will require CEQA clearance.
Attachments
1. Draft Outreach Summary Chapter
2. Draft Housing Needs Data Report
3. Draft Fair Housing Assessment
4. Draft Sites Inventory Chapter
5. Draft Policies and Programs