East Palo Alto City Council
February 21, 2023

2023-2031 Housing Element
City of East Palo Alto
Draft Revised
February 2023
City of East Palo Alto Housing Element

ACKNOWLEDGEMENTS
Mayor and City Council
Lisa Gauthier, Mayor
Antonio López, Vice Mayor
Ruben Abrica, Council Member
Carlos Romero, Council Member
Martha Barragan, Council Member
Regina Wallace-Jones, Former Council Member & Mayor
Planning Commission
Michael Mashack, Chair
Robert Sherrard
Robert Allen Fisk
Javanni Brown-Austin
Juan Méndez
Iliana Nicholas
Q. Smith
Ofelia Bello, Former Chair
East Palo Alto City Staff
Other
21 Elements
Raimi + Associates
Audrey Chau, UC Berkeley Equitable Housing Elements Graduate Student Summer Fellow Benjamin Toney, Partnership for the Bay’s Future Policy Fellow

TABLE OF CONTENTS
1 INTRODUCTION

1.1 ROLE OF HOUSING ELEMENT

1.2 DATA SOURCES

1.3 OUTREACH AND PUBLIC PARTICIPATION PROCESS

1.4 HOW WE INCORPORATED WHAT WE HEARD INTO THE PLAN

1.5 CONSISTENCY TO OTHER CITY PLANS
2 HOUSING NEEDS ASSESSMENT

2.1 POPULATION SIZE

2.2 DEMOGRAPHIC SHIFTS

2.3 LANGUAGE

2.4 AGE

2.5 INCOME

2.6 DISPLACEMENT RISK

2.7 DRAMATIC SHIFTS IN HOUSING MARKET

2.8 EMPLOYMENT, JOBS-TO-HOUSING RATIO, AND JOBS-HOUSING FIT

2.9 UNEMPLOYMENT

2.10 “HIGH” VERSUS “LOW”-RESOURCE NEIGHBORHOODS

2.11 SPECIAL NEEDS POPULATIONS

2.12 AFFORDABLE HOUSING UNITS AT-RISK OF CONVERSION TO MARKET RATE

2.13 EAST PALO ALTO HOUSING NEEDS DATA PACKET

2.14 SAN MATEO COUNTY HOUSING NEEDS
3 HOUSING CONSTRAINTS

3.1 GOVERNMENTAL CONSTRAINTS

3.2 INFRASTRUCTURE CONSTRAINTS

3.3 NON-GOVERNMENTAL CONSTRAINTS
4 AFFIRMATIVELY FURTHERING FAIR HOUSING – AN ASSESSMENT OF FAIR HOUSING WHAT IS AFFH?
SECTION I. FAIR HOUSING ENFORCEMENT AND OUTREACH CAPACITY SECTION II. INTEGRATION AND SEGREGATION
SECTION III. ACCESS TO OPPORTUNITY
SECTION IV. DISPARATE HOUSING NEEDS
5 SITES INVENTORY ANALYSIS

5.1 OVERVIEW OF TYPES OF SITES IN THE SITES INVENTORY

5.2 ENTITLED OR APPROVED PROJECTS

5.3 PROJECTS NOT APPROVED, BUT HIGH PROBABILITY OF DEVELOPMENT

5.4 PROJECTS WITH DEVELOPMENT INTEREST

5.5 PUBLICLY OWNED SITES WITH POTENTIAL FOR DEVELOPMENT OR REDEVELOPMENT

5.6 SITES WITH NONRESIDENTIAL ZONING, BUT RESIDENTIAL DEVELOPMENT APPLICATION IN RAVENSWOOD BUSINESS DISTRICT

5.7 SITES WITH (RE)DEVELOPMENT POTENTIAL IN RAVENSWOOD BUSINESS DISTRICT

5.8 ACCESSORY DWELLING UNITS (ADUS)

5.9 AFFIRMATIVELY FURTHERING FAIR HOUSING CONSIDERATIONS FOR SITES INVENTORY

5.10 SITES INVENTORY PROXIMITY TO AREAS
6 POLICIES AND PROGRAMS

6.1 STRUCTURE OF RHNA 6 HOUSING ELEMENT WORKPLAN AND GUIDING PRINCIPLES

6.2 AFFIRMATIVELY FURTHERING FAIR HOUSING CONSIDERATIONS FOR POLICIES AND PROGRAMS

6.3 GOALS, POLICIES AND PROGRAMS SUMMARY

6.4 IMPLEMENTATION PLAN
7 REVIEW OF PRIOR HOUSING ELEMENT

7.1 ACCOMPLISHMENTS OF RHNA 5 HOUSING ELEMENT PERIOD

7.2 HOUSING ELEMENT PROGRESS

7.3 PROGRESS TOWARDS LOWER-INCOME RHNA 5 TARGETS

7.4 ONGOING CHALLENGES TO MEETING THE CITY’S HOUSING NEEDS

APPENDICES

APPENDIX A PUBLIC OUTREACH AND PARTICIPATION

APPENDIX B HOUSING NEEDS DATA

APPENDIX C AFFIRMATIVELY FURTHERING FAIR HOUSING

APPENDIX D SITES INVENTORY
APPENDIX E RHNA 5 HOUSING WORKPLAN PROGRESS
Chapter 1 – Page 1
1 INTRODUCTION
Housing is a basic human necessity and the need for housing is shared by all residents. People want living spaces where they feel a sense of dignity, where they can express their individuality, and wherethey can be comfortable and healthy. Safe, well-maintained housing is a basic need that transcends age, race, income, and marital status. As such, the City of East Palo Alto encourages a diversity of housing types, costs, and locations to serve the variety of needs and wants of local residents.

1.1 ROLE OF HOUSING ELEMENT
The California State 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 the pursuit of this goal, the Legislature has mandated that all cities and counties prepare a Housing Element as part of the comprehensive General Plan. Section 65583 of the Government Code sets forth the specific components to be contained in a Housing Element. State law further requires Housing Elements be updated at least every eight years to reflect the changing housing needs of a community. As East Palo Alto’s Housing Element was last updated in 2015, this Update is for the planning period of 2023-2031.

The Housing Element Update consists of the following major components:
• Overview of the public participation and outreach process (Chapter 1) • Analysis of East Palo Alto’s demographic profile, housing characteristics, units at risk of conversion to market rate, and existing and future housing needs (Chapter 2). • Review of potential market, governmental, and environmental constraints to housing development(Chapter 3).
• Affirmatively furthering fair housing assessment (Chapter 4) • Evaluation of the land, financial, and organizational resources available to addressthe identified housing needs (Chapter 5).
• Housing plan to address the identified housing needs, including a statement of goals, policies, and actions (Chapter 6).
• Review of the progress and challenges in the prior Housing Element (Chapter 7)

1.2 DATA SOURCES
Various sources of information contribute to the Housing Element, including the American Community Survey (ACS) from the U.S. Census Bureau that provides the basis for population and household characteristics. In addition, several data sources were used to supplement the survey include economic and demographic Chapter 1 – Page 2
projections by the Association of Bay Area Governments (ABAG) and population estimates by the California Department of Finance (DOF).

Housing market information is based on City surveys and property tax assessor's files, such as home sales, rents, and vacancies.

Public and non-profit agencies input on data regarding special needs groups and the services available to them or gaps in the service delivery system.

1.3 OUTREACH AND PUBLIC PARTICIPATION PROCESS
East Palo Alto has a long history of extensive community involvement, and the 2023–2031 City of East Palo Alto Housing Element is no exception. It was developed with the collaborative efforts of residents and elected/appointed officials. Several opportunities for input on the Housing Element were provided through various forums as discussed below.
21 ELEMENTS COLLABORATIVE OUTREACH
East Palo Alto partnered with other San Mateo County jurisdictions for a first-of-its-kind countywide outreach effort, through an award-winning collaboration called 21 Elements. 21 Elements facilitated several panel presentations and discussion with advocates representing people with special needs, affordable housing developers and advocates, and funders. The panelists discussed their perspective on the unique housing needs of San Mateo County, and provided some policy suggestions.

HOUSING ELEMENT SPECIFIC OUTREACH
To accomplish the City’s goal of developing a Housing Element that reflects the vision of the people who make it special, the City of East Palo Alto developed a broad and diverse outreach plan designed to reach as many community members who live and work here as possible. A summary of public participation and community outreach activities and key takeaways are included here.

The City’s outreach goals were as follows:
• Reduce barriers to access to ensure a robust community participation process that is representative of the full range of demographics, perspectives, and experiences in East Palo Alto • Build a level of transparency in the update process to ensure successful support and implementation after adoption
Chapter 1 – Page 3
• Raise awareness among residents of the importance of the Housing Element update on shaping the future of our community
Given the inability to hold in-person events due to the COVID-19 pandemic, the City developed different community outreach and engagement strategies, including virtual meetings, digital tools, and safe in-person interactions to ensure that community members who do not have access to technology were still able to participate and provide their input. The City also proactively engaged residents for whom English is not spoken at home, families that would need childcare in order to participate and engage in conversations, and renters living in multi-family and in single-family housing with little access to public transportation.

For many years, the community has participated and engaged in conversations about affordable housing, tenant rights, displacement and fair housing. In addition to conversations focused on the Housing Element, the City’s efforts to establish sustainable funding sources for affordable housing production and homelessness prevention, to discuss the Ravenswood Business District/Four Corners Specific Area Plan, develop an affordable housing workplan, among many other initiatives, have provided opportunities for many additional collaborative outreach activities.

For other outreach work, we partnered with 21 Elements. Specific activities are summarized below:

Social Media and Printed Mailing. The City of East Palo Alto launched a Housing Element Update webpage, and conducted extensive social media outreach beginning March 2021. Physical mailers were sent City-wide in April 2022.

We also participated in and helped shape the Let’s Talk Housing initiative. City staff and consultants developed a countywide website available in five languages, a City webpage detailing our timeline, engagement activities, and resources that also linked to our City website, videos about the process in several languages, and a social media presence. As of February 2022, the website had been visited more than 17,000 times, with more than 20% from mobile devices.

Email Alerts. We sent alerts and updates via the City’s City-wide weekly newsletter and created a Housing Element Update mailing list where residents interested in the Housing Element process received updates on upcoming community meetings or ways to participate in the Housing Element Update.

Community Meetings: The City organized three public Housing Element community meetings and presented at 9 public commission/council meetings. These include:
o Planning Commission Informational Update 05/10/21 (virtual) o Community Meeting about Outreach Strategies 06/02/21 (virtual) Chapter 1 – Page 4
o Community Meeting #1 07/19/21 (virtual)
o Community Meeting #2 02/24/22 (virtual)
o Planning Commission Meeting 03/14/22 (virtual)
o City Council Meeting 03/15/22 (virtual)
o Planning Commission and City Council Joint Study Session 04/26/22 (virtual) o Community Meeting #3 05/05/22 (hybrid meeting in-person and virtual) o Planning Commission Meeting 07/11/22 (virtual)
o City Council Meeting 07/19/22 (virtual)
o Planning Commission Meeting 01/23/23 (virtual)
o Planning Commission Hearing 02/09/23 (virtual)
o City Council Hearing 02/21/23 (hybrid)
The City also participated in several meetings and webinars in partnership with 21 Elements, including:
▪ Let’s Talk Housing - Introduction to the Housing Element – A housing element overview with breakout discussion rooms that was part of a series of introductory meetings attended by one community member and two East Palo Alto stakeholders and over 1,000 community members countywide.
o 03/25/21 (Joint with Millbrae, Burlingame, Hillsborough and San Mateo); continued on 05/06/21 due to technological issues
o 07/26/21 (Virtual countywide meeting about the Housing Element update in Spanish) ▪ All About RHNA webinar – An in-depth dive into sites methodology. (4/23/21 - countywide) ▪ Stakeholder Listening Sessions – Four virtual meetings where jurisdictions could listen to and interact with stakeholder groups arranged by topic. More than 30 groups participated. o Fair Housing 09/27/21
o Housing Advocates 10/18/21
o Builders 10/01/21
o Service Providers 11/15/21
▪ Creating an Affordable Future webinars – A four-part series to help educate community members about local housing issues.
▪ Equity Focus Group Presentation – The City also conducted a virtual focus group presentation with the San Mateo County Equity Advisory Group on 05/02/22 to ensure outreach was set up to meet people where they were at as much as possible.

Surveys: City staff conducted three online surveys, an in-person intercept survey at pop-up Farmer’s Markets, and a Balancing Act survey with sites inventory-specific questions. These efforts included:
o Online Surveys 02/24/22 to 07/15/22
o Balancing Act Survey 05/25/22 to 07/15/22
o Intercept Survey at East Palo Alto Farmer’s Market 06/08/22 o Intercept Survey at East Palo Alto Farmer’s Market 06/15/22 Chapter 1 – Page 5

WHAT WE ACCOMPLISHED
It is more important than ever to include as many voices as possible in the Housing Element. Housing Elements at their best can provide an opportunity for everyone to add their voice to the conversation. However, many people are too often left out of the process. Renters, workers, young families, youth, people of color, immigrants, refugees, non-English speakers, and people with disabilities are often unable to participate in outreach activities when scheduled, don’t know how to get involved, or don’t trust the process. Our goal was to change that. Specifically, we:
▪ Ensured foreign language translation and interpretation was included in our meetings and materials1
▪ Designed a website that was mobile friendly, with accessibility features and available in multiple languages. (Lower income residents, young adults and people of color are more likely to use their phones)
▪ Formed an Equity Advisory Group consisting of 18 organizations across San Mateo County that provided feedback on outreach and materials, and shared information about the Housing Element Update and how to participate in the process with the communities they serve ▪ Held meetings in partnership with community organizations (including an Introductory meeting in Spanish with English interpretation focusing on community outreach strategies) ▪ Developed an Affirmatively Furthering Fair Housing survey The following is more a detailed description of the City’s engagement efforts to hear from as many community members as possible. Appendices C and E provide more details.

1. Website and Social Media
As a starting point for accomplishing extensive outreach, the City of East Palo Alto developed a clear online presence with all the information needed to understand the update process and know how to participate. • City of East Palo Alto Website and Social Media
The City launched a Housing Element Update webpage on its City website in March 2021, where community members can find the latest updates on the Housing Element Update and a list of upcoming community meetings. The City webpage also provides links to previous commission/council reports and recordings to community meetings and public meetings. The City 1 The City provided translation of materials and interpretation of public meetings in Spanish. The City is currently working on a language access plan to identify additional translation and interpretation needs in the community.

This may include translation and interpretation to Tongan and Samoan, which are the next most spoken languages in the City. According to the 2019 American Community Survey 5-Year Estimates, approximately 8.3% of East Palo Alto households speak Asian and Pacific Island languages, and 11.7% of East Palo Alto households who speak Asian and Pacific Island languages are limited English speaking households.

Chapter 1 – Page 6
also provided updates and invitations to community meetings on social media. All outreach communications were conducted in English and Spanish. Appendix A1 provides an overview of the webpage outreach performance and Appendix A2 provides an overview of the social media outreach performance.
• Let’s Talk Housing Website and East Palo Alto Webpage To reach a broader audience and supplement the City webpage, we launched the Let’s Talk Housing website with 21 Elements in March 2021. Our goal was to clearly explain what a housing element is, why it matters, and how to get involved. It was made available in Arabic, Chinese, English, Spanish and Tagalog, designed to be responsive on all types of devices and included accessibility features. As part of this effort, we also developed an East Palo Alto webpage with our timeline, engagement activities like surveys and housing balancing exercises, and resources that also linked to our City website. As of January 2022, the Let’s Talk Housing website has been viewed more than 17,000 times, with more than 20 percent occurring from mobile devices. Let’s Talk Housing Facebook, Instagram, Twitter and YouTube accounts were also created and maintained to keep people informed about upcoming or past event.
• Informational Videos on the Housing Element Update
After completing a series of introductory Meetings to the Housing Element Update (see below), we supported 21 Elements in developing shorter 4-minute snippets to ensure information was more accessible and less onerous than watching an hour-long meeting. Two videos were produced–What is a Housing Element and How it Works and Countywide Trends and Why Housing Elements Matter– in Arabic, Chinese, English, Spanish, and Tagalog. They were made available on the Let’s Talk Housing YouTube channel and website and shared on social media.

2. Email Alerts
The City sent updates about the Housing Element process via the City’s City-wide weekly newsletter, which updates residents on any upcoming City meetings and programs. The City also created a Housing Element Update mailing list to provide updates. Appendix A3 provides an overview of these email alerts.

3. Public Meetings and Hearings
The City of East Palo Alto held and participated in a variety of virtual and in-person meetings to inform the public about the Housing Element and hear what matters to the community. • Countywide Introductory Meeting to the Housing Element Update The City of East Palo Alto helped develop and facilitate a 90-minute virtual countywide meeting about the Housing Element update. Held on March 30, 2021, and continued May 6, 2021, due to technological issues, the meeting provided community members with an introduction to the Housing Chapter 1 – Page 7
Element update, why it matters, information on the Let’s Talk Housing outreach effort, and countywide trends. The City of East Palo Alto staff then facilitated a breakout room discussion with community members on housing needs, concerns, and opportunities, and answered any questions. A poll was given during the meeting, to identify who was joining us and more importantly who was missing from the conversation, including if they rent or own, who they live with, their age, and ethnicity. Time for questions was allotted throughout, and meeting surveys were provided to all participants after the meeting along with all discussed resources and links. Appendix A5 summarizes this countywide meeting.

In total six introductory meetings were held across the county between March and May 2021, and 1,024 registered for the series. Of those who registered, the majority identified as White (66%) or Asian (15%) and were 50 years or older; nearly half were 50 to 69 years old and almost a fifth were over 70. Almost half had lived over 21 years in their homes and three-fourths owned their homes. One East Palo Alto resident and fourteen other stakeholders participated in the East Palo Alto breakout group. A meeting summary can be found in Appendix A4.

On July 26th, the City of East Palo Alto joined a virtual countywide meeting about the Housing Element update in Spanish, hosted by El Comité, a trusted community organization. English interpretation was provided for non-Spanish speaking staff to participate in the conversation. In total, 57 people participated. A recording of this meeting was made available after and can be viewed here. • All About RHNA Webinar
The City of East Palo Alto joined a webinar with 21 Elements in April 2021 to provide information and answer community questions about the Regional Housing Needs Allocation (RHNA) process. 264 people registered and 80 questions were answered over three hours. The recording of this meeting and the FAQ can be found here.
• Community Meetings
▪ Outreach Strategies Community Meeting: The City conducted a community meeting virtually on June 2, 2021, that focused on outreach strategies. ▪ Housing Element Update Community Meeting #1: The City conducted its first City-specific community meeting virtually on July 19, 2021, which provided introductory information on the Housing Element Update and sought community input. Spanish interpretation was available. A recording of this meeting was made available after and can be viewed here. ▪ Housing Element Update Community Meeting #2: The City conducted a second community meeting virtually on February 24, 2022, which provided introductory information and sought input on RHNA, policies and programs, and environmental constraints. Spanish interpretation was available. A recording of this meeting was made available after and can be viewed here in English and here in Spanish.

Chapter 1 – Page 8
▪ Housing Element Update Community Meeting #3: The City conducted a third community meeting and first hybrid meeting (held both in-person and virtually) on May 5, 2022. Spanish and Tongan interpretation were available both in-person and on Zoom. The meeting also had childcare, free food, and a free shuttle bus. The meeting provided introductory information and sought input on policies and programs and sites inventory. A recording of this meeting was made available after and can be viewed in both English and Spanish here. Due to technological issues, we were unable to record the Tongan interpretation. • Public Meetings and Hearings
o May 10, 2021, Brief Informational Update on the Housing Element to the Planning Commission
o March 14, 2022, Update on 2021 Housing Element and General Plan Annual Progress Report
o 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 Agencies
o April 26, 2022, Joint study session with Planning Commission and City Council o July 11, 2022, Planning Commission update
o July 19, 2022, City Council update
o January 23, 2023 Planning Commission meeting
o February 9, 2023 Planning Commission hearing
o February 21, 2023 City Council hearing
• Stakeholder Listening Session Series
The City of East Palo Alto joined 21 Elements for a facilitated series of listening sessions held between September and November 2021 to hear from various stakeholders who operate countywide or across multiple jurisdictions. The four sessions convened more than 30 groups including fair housing organizations, housing advocates, builders/developers (affordable and market-rate), and service providers, to provide observations on housing needs and input for policy consideration.

Summaries for each session can be found here. Key themes and stakeholder groups included:
▪ Fair Housing: Concern for the end of the eviction moratorium, the importance of transitoriented affordable housing and anti-displacement policies, and the need for education around accessibility regulations and tenant protections. 8 stakeholder groups provided this feedback, including the following:
o Center for Independence www.cidsanmateo.org
o Community Legal Services of East Palo Alto (CLSEPA) www.clsepa.org Chapter 1 – Page 9
o Housing Equality Law Project www.housingequality.org
o Legal Aid for San Mateo County www.legalaidsmc.org
o Project Sentinel www.housing.org
o Housing Choices www.housingchoices.org
o Public Interest Law Project www.pilpca.org
o Root Policy Research www.rootpolicy.com
▪ Housing Advocates: Concern for rent increases and the need for ongoing outreach to underserved and diverse communities, workforce housing, deeply affordable and dense infill, and tenant protections for the most vulnerable. 6 stakeholder groups provided this feedback, including the following:
o Housing Leadership Council www.hlcsmc.org
o Faith in Action www.faithinactionba.org
o Greenbelt Alliance www.greenbelt.org
o San Mateo County Central Labor Council www.sanmateolaborcouncil.org o Peninsula for Everyone www.peninsulaforeveryone.org
o San Mateo County Association of Realtors www.samcar.org ▪ Builders and Developers: Local funding, tax credit availability, and concern that appropriate sites limit affordable housing while sites, construction costs, and City processes limit marketrate housing. 12 stakeholder groups provided this feedback, including the following:
o Affirmed Housing (Affordable) www.affirmedhousing.com o BRIDGE Housing (Affordable) www.bridgehousing.com
o The Core Companies (Affordable, Market Rate) www.thecorecompanies.com o Eden Housing (Affordable) www.edenhousing.org
o Greystar (Market Rate) www.greystar.com
o Habitat for Humanity (Affordable) www.habitatsf.org
o HIP Housing (Affordable) www.hiphousing.org
o Mercy Housing (Affordable) www.mercyhousing.org
o MidPen Housing (Affordable) www.midpen-housing.org
o Sand Hill Property Company (Affordable, Market Rate) www.shpco.com o Sares | Regis (Market Rate) www.srgnc.com
o Summerhill Apartment Communities (Market Rate) www.shapartments.com ▪ Service Providers: More affordable housing and vouchers or subsidies for market-rate housing are needed, along with on-site services and housing near transit, and jurisdictions should work with providers and people experiencing issues before creating programs. 10 stakeholder groups provided this feedback, including the following:

Chapter 1 – Page 10
o Abode Services www.adobeservices.org
o Daly City Partnership www.dcpartnership.org
o El Concilio www.elconcilio.org
o HIP Housing www.hiphousing.org
o LifeMoves www.lifemoves.org
o Mental Health Association of San Mateo County www.mhasmc.org o National Alliance on Mental Illness www.namisanmateo.org o Ombudsman of San Mateo County www.ossmc.org
o Samaritan House San Mateo www.samaritanhousesanmateo.org o Youth Leadership Institute www.yil.org
• Creating an Affordable Future Webinar Series
The City of East Palo Alto and 21 Elements offered a 4-part countywide webinar series in the fall of 2021 to help educate community members about local housing issues. The sessions were advertised and offered in Cantonese, Mandarin and Spanish, though participation in non-English channels was limited. All meetings and materials can be found here. The following topics, and how each intersects with regional housing challenges and opportunities, were explored:
▪ Why Affordability Matters: Why housing affordability matters to public health, community fabric and to county residents, families, workers and employers. ▪ Housing and Racial Equity: Why and how our communities have become segregated by race, why it is a problem and how it has become embedded in our policies and systems. ▪ Housing in a Climate of Change: What is the connection between housing policy and climate change and a walk through the Housing & Climate Readiness Toolkit. ▪ Putting it All Together for a Better Future: How design and planning for much-needed new infill housing can be an opportunity to address existing challenges in our communities.

The series included speaker presentations, audience Q&A, breakout sessions for connection, and debrief discussions. Participants were eager to discuss and learn more about housing challenges in their community. They asked questions and commented in the chat and shared their thoughts in a postevent survey. Overall, comments were mostly positive and in favor of more housing, though some were focused on the need for new affordable housing. There was a lot of interest in seeing more housing built (especially housing that is affordable), concern about change or impact to schools, parking, and quality of life, and personal struggles with finding housing that is affordable and accessible shared. Some participants wanted more in-depth education and discussion of next steps, while others had more basic questions they wanted answered.

Chapter 1 – Page 11
In total, 754 registered for the series. Of those who shared, the majority identified as White (55%) or Asian (24%) and ranged between 30 and 70 years old. Over half have lived in the county for over 21 years and nearly two-thirds owned their homes. For more information, see the Summary here.

4. Other Outreach Activities
The City of East Palo Alto set out to collect as much feedback as possible from the community, from their general concerns and ideas to where new housing could go. It was also important to us to consider community outreach best practices and consult and partner with organizations working in the community, to ensure we were reaching as many people as possible and doing so thoughtfully. Appendix A6 provides an overview of the survey results.
• Jamboard Survey
An online whiteboard where community members can provide their input on what types of housing they want to see, what locations/sites they want to see explored, what environmental issues bring them the most concern, and what environmental considerations should we have when zoning for new housing. See the survey here.
• Policies and Programs Survey
A survey to hear residents’ thoughts on how we are doing with our housing policies and programs, which policies we should keep, and which new policies we should consider prioritizing for the next 8 years. See the survey in English here and in Spanish here.
• East Palo Alto Balancing Act Survey
The Balancing Act is a housing simulation tool where residents may provide their input on the location of potential housing sites to be included in the 2023-2031 Housing Element. This simulation tool is a great way for residents to explore the location of housing sites and the number of potential housing units on those identified sites. See the Balancing Act page here. • Intercept Survey
Intercept surveys on housing inventory and density were also conducted at two of the East Palo Alto Farmer’s Markets. This in-person survey helped reach Spanish-speaking residents and lower-income residents who may not necessarily be active in public meetings. • Equity Advisory Group
In alignment with community outreach best practices, it was important to include the guidance of and foster partnerships with community organizations to help ensure everyone’s voices were heard during the Housing Element update. In response, an Equity Advisory Group (EAG) was formed consisting of 15 organizations or leaders across the county that are advancing equity and affordable housing. A stipend of Chapter 1 – Page 12
$1,500 was originally provided for meeting four to five times over 12 months to advise on Housing Element outreach and helping get the word out to the communities they work with.

After meeting twice in 2021, it was decided the best use of the EAG moving forward would be to provide more focused support in 2022 based on jurisdiction need and organization expertise. To date, EAG members have facilitated and hosted community meetings in partnership with 21 Elements, collected community housing stories to put a face to housing needs, advised on messaging, and amplified events and activities to their communities. The EAG continue to work collaboratively with jurisdictions and deepen partnerships, as well as connect community members to the Housing Element Update process. All participating organizations are featured on the Let’s Talk Housing website and include the following:
o Ayudando Lations A Soñar (ALAS) www.alasdreams.com
o Community Legal Services www.clsepa.org
o El Comité de Vecinos del Lado Oeste (El Comité)
www.tenantstogether.org/resources/el-comité-de-vecinos-del-lado-oeste-east-palo-alto o East Palo Alto Community Alliance and Neighborhood Development Organization (EPA CAN DO) www.epacando.org
o Faith in Action www.faithinaction.org/federation/faith-in-action-bay-area/ o Housing Choices www.housingchoices.org
o Housing Leadership Council www.hlcsmc.org
o Menlo Together www.menlotogether.org
o Nuestra Casa www.nuestracasa.org
o One San Mateo www.onesanmateo.org
o Peninsula for Everyone www.peninsulaforeveryone.org
o Puente de la Costa Sur www.mypuente.org
o San Mateo County Health www.gethealthysmc.org
o Youth Leadership Institute www.yli.org/region/san-mateo o Youth United for Community Action www.youthunited.net • Affirmatively Furthering Fair Housing Survey
A Fair Housing Assessment was conducted for all San Mateo County jurisdictions and had a statistically significant number of East Palo Alto residents participate (53 East Palo Alto residents total). Some primary findings in the Fair Housing Assessment include:
▪ Hispanic/Latinx & Black/African American households have a high-cost burden ▪ The entire city is considered vulnerable to displacement. ▪ There is a lack of sidewalks, good street lighting and walkability in some neighborhoods ▪ East Palo Alto has high rates of fair housing discrimination Chapter 1 – Page 13
▪ Applicants for mortgage face high rates of denial, highest for Black/African American and Hispanic/Latinx applicants
▪ East Palo Alto has a higher portion of children than county going to lower-performing schools The Affirmatively Furthering Fair Housing Chapter provides an overview of the survey results. In addition, Appendix A7 shows the Equity Advisory Group’s recommendations as a minimum to Affirmatively Furthering Fair Housing.
• Public Review Period
The City released the draft Housing Element for the 30-day public review period from August 29, 2022 to October 3, 2022. During this time, the City received comment letters from 18 individuals. Common themes in the comments submitted include:
▪ Language Access: Need for Spanish and Tongan translation, as well as easier to understand language and broken-down abbreviations.
▪ Process Timelines: Need for development streamlining and shorter process timelines. ▪ ADU Streamlining: Need for ADU incentives and streamlining. ▪ Water Infrastructure: Need for water infrastructure in new development sites. ▪ Housing affordability: Need to target development of lower-income housing. ▪ Homeownership opportunities: Need for affordable homeownership programs.

Appendix A8 provides an overview of comments submitted during this public review periods. Table A8.A in Appendix A8.A summarizes comments and City responses to the public comments submitted between August-October 2022.

On January 17, 2023, the City released a second revised draft of the Housing Element, and on February 6, 2023, the City released a third revised draft of the Housing Element for a 7-day public review period.

Table A8.B in Appendix A8 summarizes City responses to the public comments submitted between January – February 2023.

1.4 HOW WE INCORPORATED WHAT WE HEARD INTO THE PLAN
Comments from community workshops and correspondence received during the update process have helped to identify housing needs and issues of concern in the community and possible strategies for the City to pursue in addressing housing needs. Feedback and insights from people who face the greatest barriers to participation, including tenants, non-English speakers, and lower-income residents helped to highlight new policy opportunities and ways to strengthen and improve existing policies. There was an Chapter 1 – Page 14
overarching need and appetite for more housing affordability and availability. In addition, themes such as investing in infrastructure and anti-displacement measures and addressing climate change helped inform policies in the Housing Element Update.

KEY TAKEAWAYS
Below is a summary of key takeaways that emerged throughout the outreach process. • Need for affordable rents – The community is very concerned about promoting more affordable housing, particularly in light of rapid increases in prices in East Palo Alto. They want the Rent Stabilization and renter protection ordinances protected. • More housing overall is needed: Generally, people believe we need more housing, particularly affordable housing. However, there are diverging views on how to accomplish this, where housing should go, and what it should look like.
• Housing protection, preservation, and production are top priorities: The community is very concerned about addressing the rapid displacement in East Palo Alto. They want tenant rent relief and protections, housing preservation and housing production. They also felt that developers should be eligible for incentives and opportunities that make them more competitive. • Overcrowding is an issue: Because prices are so high, many residents are forced to share apartments. This causes overcrowding and associated problems. • Need for improved living conditions: Many residents had concerns about the condition of their apartments. They feel they are not being maintained at an acceptable level. • The price of housing is a major concern: Many voiced concerns about the high cost to rent or buy a home today, either for themselves, friends, or family. It is an issue that touches a lot of lives. • Housing is personal: People often have differing views on housing because it is a very personal issue tied to feelings of safety, belonging and identify. Often the comments reflected people’s current housing situation. Those with safe, stable housing that they can afford were more concerned with street and infrastructure conditions, and the value of homes. Those without were more interested in bolder policies that support tenants and more housing generally. Many people shared meaningful stories of being priced out of their communities or of their children not being able to live in the community where they grew up. Click here for a sample story.

Chapter 1 – Page 15
• Single-family neighborhoods are polarizing: While some people voiced their interest in upzoning single-family neighborhoods or eliminating them altogether, other homeowners want to protect them and in turn, the investment they have made.
• The process is too complicated: There was significant concern that the development process was too slow and there was too much uncertainty.
• Better information resources: People wanted to know how to find affordable housing in their communities and navigate the process of applying for it. • Issues are connected: Transportation, climate change, access to living wage jobs and education opportunities are all tied to housing and quality of life. These issues are not siloed in people’s lives and there is a desire to address them in interconnected ways. • Equity is on people’s minds: People want to talk about housing inequities and, even more so, discuss how to solve them. There was interest in ways to create new opportunities for housing and asset building for all that also address past exclusions. • Regional input matters but there’s more to figure out: It was valuable to build a broader sense of community and share resources at the countywide level. However, it was challenging to engage nonresident community members on jurisdiction-specific input. • Diversity in participation was a challenge: Despite partnering with organizations to engage with the hardest to reach communities and providing multilingual outreach, achieving diversity in participation was challenging. In the wake of Covid-19, organizations already operating on limited resources were focused on supporting immediate needs, while the added stresses of life coupled with the digital divide added additional barriers for many.
• Governmental constraints create challenges. Water and sewer infrastructure constraints have historically been a barrier for development In addition, City policies and programs that affirmatively further fair housing help address displacement and gentrification, but create additional costs to developers.

INCORPORATION INTO THE HOUSING ELEMENT
The following is a summary list of topics that were added or improved as a result of that community and stakeholder feedback.
• Theme: Environmental Constraints
o Use environmental “overlay” to avoid housing in at-risk areas Chapter 1 – Page 16
o Resolve issues with the East Palo Alto Sanitary District (EPASD) to improve sanitary sewer infrastructure
• Theme: Incentives for affordable housing development
o Implementation of state affordable housing overlay incentives • Theme: Encouraging smaller-scale, “missing middle” housing like duplexes/triplexes and (marketrate) ADUs o Streamlining
o Fee reductions
o Outreach targeting smaller developers
• Theme: ADUs as lower-income affordable housing
o Amnesty and legalization of unpermitted second units
o Public/private partnerships to fund rehab/repairs
o Additional loan programs to build deed restricted affordable ADUs • Theme: Promote homeownership opportunities
o Leverage all available federal funding support for down payment and first-time homebuyer assistance
o Advocate for these programs at regional level
• Theme: Need for anti-displacement
o Jobs-housing linkage that links production of commercial office space to affordable housing production
o Strengthen housing replacement requirements
o Preservation/rehabilitation
o Exploring establishment of cooperatives/community ownership of housing • Theme: Need for infrastructure improvements
o 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 The following is an overview of the rationale behind some of the policies and programs recommended.

Policy or Program Rationale
Overlay for nonprofit-owned
properties of a certain size that
commit to building 100%
affordable housing
Some nonprofit property owners, such as faith communities, own sufficiently large (and “underutilized”) parcels to build affordable housing and have interest in serving community need. With an overlay, the City may reduce costs by allowing projects of a certain scale. Exploration of an affordable housing overlay zone has been removed given the City is committed to implementing state affordable housing incentives and state legislation that facilitates the approval of residential projects.

Chapter 1 – Page 17
City-level streamlining for SB 9
projects
SB 9 facilitates multiple units on parcels zoned single family.

Duplexes, triplexes, and ADUs can help to add “missing middle” units to the housing stock.

Encouraging ADU production  ADUs address the “missing middle” problem and allow for additional units on a variety of parcels. The City has made ADUs a priority since 2018 and may wish to update this strategy as a Housing Element “program” to support the City’s development project of
ADU production over the next 8 years.

Temporary Use Permit for temporary
housing for unhoused individuals
City Council directed staff to develop a “Master Temporary Use Permit (TUP)” process as described in the April 5, 2022, staff report.

Facilitating temporary housing for unhoused individuals helps to address the needs of special populations, as required in the Housing Element.

Requiring minimum residential
density on Sites Inventory/Housing
Opportunity sites in the Ravenswood
Business District
Different uses are allowed in the Ravenswood Business District (RBD). Allowing residential as one of multiple uses, e.g., office or R&D, does not guarantee that affordable housing units will be built on a parcel.  Therefore, minimum residential density requirements on Sites Inventory/Housing Opportunity sites are needed to encourage development of housing in the RBD, especially affordable housing opportunities (such as density bonus law) that typically align with higher density requirements and make it cheaper to build more units.

Waiving fees for affordable projects  Analysis by 21 Elements partner firm EcoNorthwest found that waiving some fees for affordable projects would increase market feasibility for affordable units citywide, in many cases more than upzoning certain parcels
Reduced parking for affordable
projects
Analysis by 21 Elements partner firm EcoNorthwest found that reducing parking requirements for affordable projects would increase market feasibility for affordable units citywide, in many cases more than upzoning certain parcels.

1.5 CONSISTENCY TO OTHER CITY PLANS
The Housing Element update is a required Element of the City of East Palo Alto General Plan, which was updated in 2016. The changes proposed by this Housing Element update were reviewed against the General Plan, Vista 2035, and found to be consistent. Additionally, while the Housing Element is not currently consistent with the Ravenswood Business District/Four Corners transit-oriented development Specific Plan (RBD), this plan is also undergoing a targeted update by December 2023. The proposed housing sites, policies and programs, and any other aspects of the Housing Element update that are related to the RBD —including the rezoning program planned for 2023—will be consistent with the final updated Specific Plan.

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Chapter 2 – Page 1
2 HOUSING NEEDS ASSESSMENT
The Housing Needs Assessment consists primarily of data provided by the Association of Bay Area Governments/Metropolitan Transportation Commission in partnership with 21 Elements in preparation for the Housing Element. Each jurisdiction received a “data packet” prepared to specifically address each of the statutorily required data points. These data help to describe the state of housing in East Palo Alto and to provide a basis for planning for development over this eight-year planning period. The City supplemented these data with research and analysis provided by Esri Business Analyst in a 2020 housing needs report.

Several highlights from this extensive data compilation have been incorporated into the community meetings and outreach referenced in other sections of this Housing Element and have directly informed the Policies & Programs section. These include:

2.1 POPULATION SIZE
East Palo Alto’s population has been growing, but less than the Bay Area region overall with 4.4% growth in the City from 2000 to 2020, compared to 9% for the county and 15% for the Bay Area. This increase throughout the region is mostly due to natural growth (births minus deaths) and our strong economy drawing new residents to the region.

2.2 DEMOGRAPHIC SHIFTS
The majority of East Palo Alto is made up of people of color, including Latinx (60% vs. 24% in the county), Black/African American (11% vs. 3% in the county), and Asian and Pacific Islander (6% vs. 1% in the county), while a smaller share of the population is non-Hispanic White (14 percent vs. 37% in the county). 2 This is a far
larger proportion of people of color, particularly Latinx, African American, and Pacific Islander, than the rest of San Mateo County.

Since 2000, the percentage of residents in East Palo Alto identifying as non-Hispanic 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 Black/African American. The figure below shows the snapshot of race and ethnicity in East Palo Alto and San Mateo County in 2020.
2 U.S. Census, 2022.

Chapter 2 – Page 2
Sources: Esri Business Analyst, 2019; U.S. Census Bureau, 203-2017 American Community Survey; BAE Urban Economics, 2019.

These racial and ethnic demographic composition throughout the City is similar to that of the neighboring Bell Haven neighborhood of Menlo Park, and starkly different from the neighboring city of Palo Alto and the rest of Menlo Park. These similarities and differences may be attribable to the history of redlining and segregation in the region, where the Bell Haven neighborhood in Menlo Park and East Palo Alto, as well as other neighborhoods east of Highway 101 and unincorporated areas in the county (e.g. North Fair Oaks) experienced segregation, redlining, predatory lending, and resource deprivation.

Due to this history, racial and ethnic minatory populations generally have higher rates of poverty and lower household incomes compared to non-Hispanic White populations in East Palo Alto and the region. Cities like Redwood City, San Mateo, San Bruno, South San Francisco, and Daly City are ethnically diverse and have block group concentrations that are greater than 60 percent non-White populations. East Palo Alto differs drastically to its neighboring cities (Menlo Park, Palo Alto, and Atherton), which are predominately White majority tracts.

The following maps show the spatial distribution of different racial/ethnic groups as reported to the U.S.

Census.

Chapter 2 – Page 3
Hispanic/Latinx Population (2020)
Source: ACS Table B03002, 2016-2020 5-Year Estimate.

The City of East Palo Alto is currently a majority Hispanic/Latinx community. A high concentration of Hispanic/Latinx residents live on the Westside (west of Highway 101) in multi-family dwellings, and in specific single-family home neighborhoods in the eastside of the City. The surrounding Belle Haven neighborhood in Menlo Park has a similar concentration, while the surrounding Palo Alto neighborhood has a fewer than 20% Hispanic/Latinx population.

Chapter 2 – Page 4
Black/African American Population (2020)
Source: ACS Table B03002, 2016-2020 5-Year Estimate.

East Palo Alto used to be a predominately Black/African American community, but due to gentrification and displacement pressures, only a few Black/African American residents now live primarily in single family home neighborhoods throughout the City (on the eastside of Highway 101), and fewer live in multi-family neighborhoods on the westside of Highway 101. The surrounding neighborhoods in Menlo Park and Palo Alto experience more low concentrations.

Chapter 2 – Page 5
Pacific Islander/Native Hawaiian Population (2020)
Source: ACS Table B03002, 2016-2020 5-Year Estimate.

The City has the largest share of Pacific Islander/Native Hawaiian population in San Mateo County. A large portion of Pacific Islander/Native Hawaiian residents live in single-family home neighborhoods throughout the northeast side of Highway 101. The surrounding Belle Haven neighborhood in Menlo Park has a similar concentration, while the surrounding Palo Alto neighborhood has a lower concentration except for one parcel.

Chapter 2 – Page 6
American Indian/Alaska Native Population (2020)
Source: ACS Table B03002, 2016-2020 5-Year Estimate.

The City has a small share of the American Indian/Alaska Native population concentrated in a mixed multifamily home and single-family home neighborhood in the northern part of the City, south of Bay Road.

Surrounding neighborhoods in Menlo Park and Palo Alto have similar low concentrations.

Chapter 2 – Page 7
Asian Population (2020)
Source: ACS Table B03002, 2016-2020 5-Year Estimate.

The City has a concentrated share of the Asian population in its mobile home park neighborhood (Palo Mobile Estates recently underwent condominium conversion), and a smaller share in surrounding newer single-family home neighborhoods (built in the early 2000’s). Surrounding neighborhoods in Menlo Park and Palo Alto have higher concentrations.

Chapter 2 – Page 8
White Population (2020)
Source: ACS Table B03002, 2016-2020 5-Year Estimate.

East Palo Alto has a smaller share of the White population than in the region. A larger portion of White residents live in the newer single-family home and townhome neighborhoods on the southeast side of Highway 101.

Chapter 2 – Page 9
Mixed Race/Other Race Population (2020)
Source: ACS Table B03002, 2016-2020 5-Year Estimate.

A higher concentration of Mixed-Race or Other Race population lives in the Palo Mobile Estates mobile home park of East Palo Alto (which recently underwent condominium conversion). Surrounding neighborhoods in Menlo Park and Palo Alto have low to medium concentrations.

Chapter 2 – Page 10

2.3 LANGUAGE
Language access can play a major role in determining who can participate in the City’s housing policy and development decision-making process. Over two thirds of East Palo Alto’s population speak a language other than English at home.

The language most spoken other than English is Spanish, with over 51.5% of households who speak Spanish and 19.2% of households who speak Spanish with limited English.

East Palo Alto has a large Tongan and Samoan population compared to the region, and the next most spoken languages are Tongan, Samoan, or some other Asian or Pacific Islander language. According to the 2019 American Community Survey 5-Year Estimates, an estimated 8.3% of East Palo Alto households speak Asian and Pacific Island languages, and 11.7% of East Palo Alto households who speak Asian and Pacific Island languages are limited English speaking households.

About 5.8% of East Palo Alto households speak Other Indo-European languages, and 3.6% who speak Other Indo-European languages are limited English-speaking households.

These language breakdowns are similar to the neighboring Bell Haven neighborhood of Menlo Park, and starkly different from the neighboring city of Palo Alto. These similarities and differences may be attribable to the history of redlining and segregation in these neighboring cities.

The following maps show the distribution in East Palo Alto by language groups and limited English households. [Intentionally Left Blank]
Chapter 2 – Page 11
Spanish Speaking Households (2019) Spanish Speaking Households with Limited English (2019) Source: ACS Table S1602, 2015-2019 5-Year Estimate.

Most East Palo Alto census block groups have over 40% of Spanish-speaking households, with two block groups that have over 65% of the households speaking Spanish and two census blocks that have over 20% of the households speaking Spanish with limited English.

Chapter 2 – Page 12
Asian or Pacific Island-Speaking Households (2019) Asian or Pacific Island-Speaking Households with Limited English (2019) Source: ACS Table S1602, 2015-2019 5-Year Estimate.

Three East Palo Alto census block groups have between 1.5% and 10% of the households speaking Tongan, Samoan or some other Asian or Pacific Islander language with limited English.

Chapter 2 – Page 13
Other Indo-European-Speaking Households (2019) Other Indo-European-Speaking Households with Limited English (2019) Source: ACS Table S1602, 2015-2019 5-Year Estimate.

Two East Palo Alto census block groups have between 0.7% and 2% of households speaking Other IndoEuropean languages with limited English.

Chapter 2 – Page 14

2.4 AGE
East Palo Alto is a relatively “young” City, especially in comparison to surrounding cities, with 28.3% of the population under age 18 and 49% of the population under age of 40. This includes many families with children, illustrating the need for more affordable housing opportunities for both families and for adult children who are still living at home or are returning home.

The figure below shows a snapshot of East Palo Alto and San Mateo County median age in 2020.

Sources: Esri Business Analyst, 2019; U.S. Census Bureau, 203-2017 American Community Survey; BAE Urban Economics, 2019.

The following maps show the distribution in East Palo Alto by age groups and households with children. The age breakdown on the side east of Highway 101 in East Palo Alto is comparable to the neighboring Menlo Park and Palo Alto neighborhoods. However, there is a stark difference in age breakdown on the west side of Highway 101 in East Palo Alto compared to the rest of the City and neighboring Menlo Park and Palo Alto.

This may be primarily attributed to the housing stock tenure and density (i.e. majority of rental multi-family housing being located on the west of Highway 101), housing affordability (i.e. majority of rent stabilized units being located on the west of Highway 101), household incomes, and overcrowding, all of which are characteristics that differentiate the west of Highway 101 from the rest of the City and neighboring cities. [Intentionally Left Blank]
Chapter 2 – Page 15
Population Under 5 (2019)
Source: ACS Table B01001, 2015-2019 5-Year Estimate.

The block groups in the Westside, west of Highway 101, have the highest percentage of young children. This is also where a majority of rental housing is located. Between 10% and 20% of the people living in the Westside are below the age of five. There may also be correlation between number of young children in the Westside with low median household income and overcrowding.

Chapter 2 – Page 16
Population Under 18 (2019)
Source: ACS Table B01001, 2015-2019 5-Year Estimate.

The distribution of children under the age of 18 in East Palo Alto is similar to that of neighboring cities of Menlo Park and Palo Alto. A concentration of children under the age of 18 live on the Westside (west of Highway 101), in multi-family housing. Fewer children under 18 live in the single-family residential Gardens neighborhood in the southeast of East Palo Alto.

Chapter 2 – Page 17
Population Age 18-24 (2019)
Source: ACS Table B01001, 2015-2019 5-Year Estimate.

East Palo Alto has a larger share of young adults between the ages of 18 and 24 compared to its neighboring cities of Menlo Park and Palo Alto. Two specific neighborhoods that have a larger share of multi-family housing (located west of Highway 101 and East of Highway 101) have a concentration greater than 20%.

Chapter 2 – Page 18
Population Age 65 and Up (2019)
Source: ACS Table B01001, 2015-2019 5-Year Estimate
East Palo Alto has fewer seniors ages 65 and up compared to neighboring cities of Menlo Park and Palo Alto.

The majority of residents over the age of 65 live in single family home neighborhoods on the eastside (East of Highway 101), as well as near the University Avenue corridor where the City has a senior affordable housing development.

Chapter 2 – Page 19
Households with Children (2019)
Source: ACS Table B1005, 2015-2019 5-Year Estimate.

East Palo Alto has a higher share of children compared to the region. A high concentration of households with children resides in multi-family housing on the Westside (west of Highway 101) and in a single-family home neighborhood on the eastside (northeast and east of the City).

Chapter 2 – Page 20

2.5 INCOME
East Palo Alto has a higher percentage of lower income households than the rest of the county and region, with 72% of households earning less than 80% of the Area Median Income (AMI) compared to 40% of households in San Mateo County and 39% of households in the Bay Area as a whole.

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.

Poverty Rate
The groups with the highest poverty rates in East Palo Alto are American Indian/Alaska Native residents (22% poverty rate), multi-racial residents (14% poverty rate), Latinx residents (14% poverty rate) and Asian/Pacific Islander residents (14% poverty rate). Non-Hispanic White residents have the lowest poverty rate (7.5%).2 The figure below is a snapshot of the East Palo Alto and San Mateo County populations below 200 percent of the federal poverty level in 2020.

Sources: Esri Business Analyst, 2019; U.S. Census Bureau, 203-2017 American Community Survey; BAE Urban Economics, 2019.

Poverty is directly tied to the risk of housing insecurity and displacement and its disproportionate impact on households of color, discussed below and at length in the Affirmatively Furthering Fair Housing section of the Housing Element.

Chapter 2 – Page 21
Median Household Income Snapshot
The figure below is a snapshot of median household income in East Palo Alto and San Mateo County in 2020.

Sources: Esri Business Analyst, 2019; U.S. Census Bureau, 203-2017 American Community Survey; BAE Urban Economics, 2019.

The following map shows Median Income in East Palo Alto, based on 2019 Census data, against sites in the Housing Element Sites Inventory:
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Chapter 2 – Page 22
Median Household Income (2019)
Source: ACS Table B19013, 2015-2019 5-Year Estimate.

Most Census Block Groups in the City’s Westside, west of Highway 101, have a median household income less than $54,800, which is considered Extremely Low for a household of four people in San Mateo County.

Chapter 2 – Page 23
Some of the Block Groups in single family zoned areas have higher median income in comparison to other parts of East Palo Alto.

However, median incomes in these single-family zoned areas are not comparable to the $179,500 or greater median household incomes of Block Groups in neighbor cities Palo Alto and Menlo Park.

This contrast in income across jurisdictions implies that East Palo Alto’s housing affordability is affected by surrounding jurisdictions and regional economic forces. This should impact local and regional housing policies. The Ravenswood Business District (RBD) has a median household income of $54,8000 -$91,350, which is considered Very Low Income for a household for four people in San Mateo Count. Future development of the RBD should consider how to mitigate risk of gentrification and displacement of current residents.

The following Median Household Income (2019) map provides different ranges in incomes to identify differences between neighborhoods in the City.
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Chapter 2 – Page 24
Median Household Income (2019)
Source: ACS Table B19013, 2015-2019 5-Year Estimate.

While this map shows variation in median household income across the different neighborhoods in East Palo Alto, all block groups except one have a median household income that is Low Income, Very Low Income, or Extremely Low Income for a household of four people in San Mateo County.

Chapter 2 – Page 25

2.6 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:
• Type of Housing by Tenure. Unlike San Mateo County, East Palo Alto is a majority-renter city.

Renter households comprise 60 percent of East Palo Alto households, compared to just under 41 percent countywide. The table below shows that in 2020, the renter population in East Palo Alto was 56 percent, compared to just under 41 percent countywide. East Palo Alto saw a 1.0 percent decline in renter-occupied units between 2010 and 2020, while the overall number of occupied housing units increased by just over one percent. Meanwhile, the number of owner-occupied units increased by four percent, which is above and beyond the overall household growth rate.

These trends could indicate a loss of rental units in East Palo Alto as single-family rental units have shifted from the rental market and are now owner-occupied.

Tenure of Occupied Housing Units, 2010-2020
Note: Totals may not match totals in other tables due to independent rounding.

Sources: Esri Business Analyst; BAE, 2019.

Single-family units comprise a significant share of the rental housing supply in East Palo Alto.

Approximately 38 percent of renter households in East Palo Alto live in single family units compared to approximately 30 percent of renter households countywide. However, most renter households live in multifamily units in both geographies.

Chapter 2 – Page 26
Type of Housing by Tenure, 2015-2019
Note:
(a) Includes boats, RVs, vans, or any other non-traditional residences.

Sources: U.S. Census Bureau, American Community Survey, 2015-2019 Five-Year Sample Data, Table B25032; BAE, 2021.

Further broken down, 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 multiple-family (5+ units). 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, as well as owner move-in, which is a common mechanism for evictions. Many single-family renter households have far fewer rental/tenant protections than renter households living in multi-family apartments.
• Cost Burden. East Palo Alto has high proportions of cost-burdened and severely cost-burdened households. According to the U.S. Department of Housing and Urban Development, costburdened households are those that spend more than 30 percent of their gross household incomes on housing costs. Those who spend more than 50 percent of their gross household incomes on housing costs are considered severely cost-burdened. According to ACS data collected between 2015-2019, 25 percent of households in East Palo Alto were severely cost-burdened, and 29 percent of households were cost burdened. According to ACS data collected between 2013 and 2017,3 53 percent of all East Palo Alto households were cost-burdened, including 59 percent of renter households and 42 percent of owner households. By comparison, 36 percent of county households were cost burdened, including 46 percent of renter households and 30 percent of owner households. As shown in the figure below, rates of cost burdened and severely cost burdened households are particularly high among lower income groups. For example, almost 80 percent of extremely low-income and very low-income renter households in East Palo Alto have a high housing cost burden.
3 3 At the time the figure below was created, the most recent data were from 2013 and 2017.

Chapter 2 – Page 27
East Palo Alto Cost-Burdened Households by Tenure, 2013-2017 Note: HUD-defined income categories are based on the HUD Area Median Family Income (HAMFI).

Sources: U.S. Department of Housing and Urban Development, 2013-2017 Comprehensive Housing Affordability Strategy (CHAS) data; BAE, 2021.

Chapter 2 – Page 28
• Overcrowding. The U.S. Census defines moderately overcrowded housing units as those that are occupied by more than one person per room but fewer than 1.5 persons per room, and severely overcrowded units as those that are occupied by more than 1.5 persons per room. As shown in the table below, five-year American Community Survey (ACS) data collected between 2015 and 2019 suggests that 26 percent of all East Palo Alto households are either moderately or severely overcrowded. Overcrowding is more prevalent among East Palo Alto’s renter households, 36 percent of which are moderately or severely overcrowded. Despite containing less than three percent of the County’s occupied housing stock, East Palo Alto accounts for approximately 19 percent of the moderately or severely overcrowded units in San Mateo County.

Housing Unit Overcrowding, 2015-2019
Notes:
(a) The American Community Survey defines a moderately overcrowded unit as being occupied by more than one but fewer than 1.5 persons per room.
(b) The American Community Survey defines a severely overcrowded unit as being occupied by more than 1.5 persons per room.

Sources: U.S. Census Bureau, American Community Survey, 2015-2019 Five-Year Sample Data, Table B25014; BAE, 2021.
• 8.6% of very low-income households (below 50% AMI) experience severe overcrowding.

The following maps show the areas of the City with the highest concentrations of renters, cost-burdened households and overcrowded households:

Chapter 2 – Page 29
Renter-Occupied Households (2019)
Source: ACS Table B25003, 2015-2019 5-Year Estimate.

A majority of East Palo Alto’s renters live on the Westside (west of Highway 101) and in single family neighborhoods throughout the City, near major transit hubs along University Avenue and Bay Road.

Compared to neighboring jurisdictions, except Redwood City, East Palo Alto appears more accommodating to renters with housing vouchers and is providing more subsidized affordable housing. The City continues to promote affordable housing through its Inclusionary Housing Ordinance and affordable housing funding.

Chapter 2 – Page 30
Cost Burdened Households (2019)
Source: ACS Table B25091, 2015-2019 5-Year Estimate.

Cost Burdened Households is defined as gross rent of 30% or more of household income for renter-occupied households or selected monthly owner costs of 30% or more of household income for owner occupied households. A majority of block groups in East Palo Alto are greater than 45% cost burdened, with many areas that are greater than 60% cost burdened. In contrast, neighboring areas in Menlo Park and Palo Alto have less cost burdened households. This can be a result of many factors including low incomes, low wages, low amounts of jobs overall, and increasing home prices due to the increase of tech companies in the region.

Policies focused on rental assistance as well as on homeowners are needed.

Chapter 2 – Page 31
Overcrowded Households (2019)
Source: ACS Table B25014, 2015-2019 5-Year Estimate.

Overcrowded Households is defined as more than 1.00 occupants per room. Many East Palo Alto households experience overcrowding, especially in contrast to neighboring areas in Palo Alto and Menlo Park. More housing is needed to decrease overcrowding.

Chapter 2 – Page 32

2.7 DRAMATIC SHIFTS IN HOUSING MARKET
The following is data showing shifts in the East Palo Alto Housing Market, primarily taken from a 2021 Housing Needs and Displacement Report by BAE Urban Economics.

Vacancy Rate. The reported vacancy rate is 7.4% (for all housing unit types). Data from CoStar4 demonstrates that East Palo Alto tends to have a slightly higher vacancy rate than San Mateo County overall, though vacancy rates in both the city and county remained relatively low over the past decade until early 2020, when California began to enact restrictions in response to the COVID-19 pandemic. The Figure below shows that between the fourth quarter of 2019 and the first quarter of 2021, the multifamily rental vacancy rate in East Palo Alto increased from 6.9 percent to 12.2, while the multifamily rental vacancy rate in San Mateo County overall increased from 5.4 percent to 10.0 percent. Although vacancy rates seem to have stabilized somewhat during 2021, these data indicate that some East Palo Alto renters may have been displaced due to the economic impacts of the COVID-19 pandemic. Housing analysts typically cite a five percent rental vacancy rate as a rate that indicates healthy market demand while providing enough vacant units to allow for normal movement of tenants between units within the rental market. Given that vacancy rates are currently well over five percent, these data may indicate potential for existing vacant units to absorb some of the existing and future housing demand.
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44 CoStar is a private data vendor that develops comprehensive commercial and residential real estate research and data through their independent research organization. CoStar gathers market information through extensive data mining of land registry and tax assessor’s information and real estate broker surveys. CoStar’s market real estate information is also derived from a variety of real estate data platforms such as LoopNet, Apartments.com, BizBuySell, Lands of America, and STR.

Chapter 2 – Page 33
Multifamily Rental Vacancy Rate, East Palo Alto and San Mateo County, 2010-2019 Note: Data reflect units in market rate multifamily complexes with 5 units or more. QTD 2021 data reflect data as of late March 2021.

Sources: Costar; BAE, 2021.

Housing Unit Turnover. ACS data suggest that 14 percent of rental units and five percent of owner-occupied units in East Palo Alto turn over per year on average during recent years. The figure below shows, by household tenure, the percentage of the population that moved based on ACS data collected between 2015 and 2019. These data do not provide a direct indication of unit turnover, in part because the data are based on householder responses collected over a defined time period and capture net absorption of any new units added to the inventory in addition to re-tenanting of existing units. Nonetheless, these data provide a general indication of the number of units that are vacated and re-tenanted each year. Based on these estimates, approximately 530 rental units in East Palo Alto and 170 owner-occupied units in East Palo Alto turned over each year during the period covered by these data.

Chapter 2 – Page 34
Residents that Moved in the Past Year, 2015-2019
Note: (a) Universe is population one-year-old or older in households. Geographic mobility status and movement date/origin based on householder response at time of survey.

Sources: U.S. Census Bureau, 2013-2017 American Community Survey, Table B07013; BAE, 2019.

Home Sales Trends. Although the median home sale price in East Palo Alto has remained considerably lower than the Countywide median home sale price, the City has experienced dramatic recent increases in home sale prices, far outpacing the rate of home sale price increases in the County overall. The figure below shows annual median sale prices for homes sold in East Palo Alto and San Mateo County between February 2012 and January 2021. In February 2012, the median sale price of homes sold in East Palo Alto was $262,500, approximately half of the median in San Mateo County. By January 2021, the median home sale price in East Palo Alto was $947,500, up 261 percent from the February 2012 median and equal to 70 percent of the February 2021 median for San Mateo County. Between 2012 and 2021, the annual median home sale price in East Palo Alto generally increased in tandem with countywide increases. The median sale price in San Mateo County as of January 2021 was approximately $1.4 million, up 161 percent since February 2012.

Chapter 2 – Page 35
Median Home Sale Price Trends, 2012-2021
Sources: Redfin Data Center; BAE, 2021.

Rental Market Trends. Residential rents in East Palo Alto tend to be slightly lower than average for San Mateo County, though increases in rents in East Palo Alto generally keep pace with rent increases in the County overall. CoStar tracks 27 market-rate multifamily rental properties in East Palo Alto with five units or more, with a total of 2,258 units. Among these units, the average asking rent was $2,802 per month as of the first quarter of 2021, as shown in the figure below Although East Palo Alto has historically offered slightly more affordable rental options within the high-cost San Mateo County housing market, since the third quarter of 2021 the average rent among these units has been slightly higher than the average countywide asking rent for multifamily rental properties with five units or more. The data indicate that rental rates in East Palo Alto increase in tandem with rent increases in the wider regional housing market, making the rental market in the City more expensive over time as housing costs increase throughout the region.

Market-rate rents in East Palo Alto have been substantially more stable during the COVID-19 pandemic than rents countywide; as of March 2021, the average multifamily asking rent in East Palo Alto was one percent lower than in the first quarter of 2020, while the countywide average multifamily asking rent had decreased Chapter 2 – Page 36
by approximately nine percent. This may be partly due to the City’s Eviction Moratorium, which was adopted ahead of the County and in effect until after County eviction moratorium expiration, and active efforts from local nonprofit organization (including the organization from the Measure O Anti-Displacement contract), who stepped in and provided outreach for rental assistance.

Average Asking Rents, Q1 2010 – Q1 2021
Note: (a) Data reflect units in market rate multifamily complexes with 5 units or more.

Sources: CoStar, 2021; BAE, 2021.

East Palo Alto’s residential rental inventory includes approximately 2,700 units that are subject to the City’s Rent Stabilization Ordinance, which tend to have rental rates that are lower than the Citywide average. This total includes over 2,500 multifamily rental units and approximately 150 mobile home spaces that are covered by rent stabilization. In 1984, residents approved the City’s first rent stabilization ordinance, which limited annual rent increases for units built before that date. However, since 1999, landlords have been allowed to charge market-rate rents every time a unit is vacated and leased to a new tenant.5 Housing Affordability. Current market-rate housing costs in East Palo Alto exceed the affordability threshold for most lower- and moderate-income households. The tables below show the affordable single-family home and condominium sale price for households at various sizes and income levels and compares these affordable 55 Vacancy decontrol was mandated after the State legislature passed the Costa-Hawkins Rental Act in 1995, which allows rent to increase to market rates after a qualifying vacancy occurs and reinstates rent control for a new tenant. Costa-Hawkins went into effect in 1999.

Chapter 2 – Page 37
sale prices to current home sale prices in East Palo Alto.6 As shown, the median single-family home sale price in East Palo Alto is higher than the sale price that would be affordable to extremely low-income, very lowincome, low-income, and moderate-income households. The median condominium sale price in East Palo Alto is potentially affordable to some larger low-income and moderate-income households. However, it should be noted that the median condominium sale price in East Palo Alto fluctuates significantly between months and is often substantially higher than the January 2021 median of $628,000 that was used to inform the calculations shown in below. Moreover, there is a limited inventory of condominium units in East Palo Alto, and many may be too small for larger households, making this option unavailable for many households.

Affordable Single-Family Home Sale Price, East Palo Alto, 2021 Notes: (a) Based on California Department of Housing and Community Development income limits for 2020. (b) Based on a tabulation of how much housing a household could afford with 35% of its gross monthly income given premium and interest, homeowner's insurance, property taxes, and other payments. (c) Per Redfin Data Center, the median sale price for a single-family home sold in East Palo Alto in January 2021 was $1,005,000.

Sources: Redfin Data Center, 2021; California Department of Housing and Community Development, 2020; Federal Housing Administration, 2020; Freddie Mac, 2020; California Department of Insurance; San Mateo County Controller's Office, 2019-2020; BAE, 2021.
6 Affordable condominium sale prices are lower than affordable single-family home sale prices for households at a given income level because condominium owners are required to pay homeowner’s association fees, which reduce the monthly income available for mortgage payments.

Chapter 2 – Page 38
Affordable Condominium Sale Price, East Palo Alto, 2021 Notes: (a) Based on California Department of Housing and Community Development income limits for 2020. (b) Based on a tabulation of how much housing a household could afford with 35% of its gross monthly income given premium and interest, homeowner's insurance, property taxes, and other payments. (c) Per Redfin Data Center, the median sale price for a condominium sold in East Palo Alto in January 2021 was $628,000.

Sources: Redfin Data Center, 2021; California Department of Housing and Community Development, 2020; Federal Housing Administration, 2020; Freddie Mac, 2020; California Department of Insurance; San Mateo County Controller's Office, 2019-2020; BAE, 2021.

Market-rate rental units in East Palo Alto are similarly unaffordable to most households with moderate or below-moderate incomes. As shown in the table below, current average market-rate asking rents for units in multifamily rental properties exceed the affordability threshold for extremely low-income and very lowincome households for all household sizes shown, as well as for larger low-income and moderate-income households. However, it should be noted that the income levels shown in Table 6 are based on countywide Chapter 2 – Page 39
income thresholds set by the State. As shown in Figure 1, the median annual income among East Palo Alto residents ($72,208) is substantially lower than the countywide income limits for low-income households.

Affordable Rent, East Palo Alto, 2021
Notes: (a) Data reflect average asking rates of units in multifamily properties of five units or more in East Palo Alto as of late March 2021. (b) Housing Authority of the County of San Mateo allowances for tenantfurnished utilities and other services for a multifamily unit that uses gas cooking, heating, and water heating, as well as electricity for lights and appliances. The allowance is based on the number of bedrooms in the unit and a household is assumed to have one bedroom fewer than the number of people in the household. (c) Based on California Department of Housing and Community Development income limits for 2020. (d) These figures are 30% of gross monthly household income, the maximum amount that a household can spend on housing expenses without being considered cost-burdened.

Sources: California Department of Housing and Community Development, 2020; CoStar Group, 2021; BAE, 2021.

Chapter 2 – Page 40

2.8 EMPLOYMENT, JOBS-TO-HOUSING RATIO, AND JOBS-HOUSING FIT
Generally, having a similar number of jobs and employed residents produces more benefits for a community, such as reducing traffic and climate impacts, and allowing people who work in the community to also live there. In contract to San Mateo County, East Palo Alto has more housing units than jobs. San Mateo County is jobs-rich, meaning it has more jobs than employed residents. In contrast, East Palo Alto has a very low jobsto-housing ratio. There are 15,101 employed residents and 5,225 jobs in East Palo Alto, resulting in a jobs-toresident-workers ratio of 0.35. Between 2002 and 2018, the number of jobs in East Palo Alto increased by 47%. However, this increase does not show the types of jobs that were added (i.e., with higher or lower wages, and in what sectors) or the absolute number that were added, indicating that jobs-housing fit and the jobs-tohousing ratio remain a challenge to residents accessing high-cost housing in East Palo Alto.

As shown in the table below, the California Department of Finance estimated that there were 7,917 housing units in East Palo Alto as of 2020. Esri estimated that there were 5,104 jobs in East Palo Alto as of 2020.

Based on these figures, East Palo Alto has an estimated employment-to-housing unit ratio of approximately

0.64, essentially the inverse of the countywide ratio.

Employment and Housing Unit Growth, 2010-2019
Chapter 2 – Page 41
Notes: (a) Employment data are sourced from Bureau of Labor Statistics, Quarterly Census of Employment and Wages. (b) Housing unit counts are sourced from CA Dept. of Finance, E-5.

Sources: Bureau of Labor Statistics, Quarterly Census of Employment and Wages; California Department of Finance, E-5 Population and Housing Estimates, 2020; BAE, 2021.

The table below shows projected population, household, and employment growth in East Palo Alto, Menlo Park, and San Mateo County through 2040, according to projections prepared by the Association of Bay Area Governments (ABAG) and the Metropolitan Transportation Commission (MTC). As shown, ABAG and MTC estimate that East Palo Alto will gain 5,420 residents, 1,065 households, and 845 jobs between 2020 and 2040, bringing the City’s employment to household ratio from 0.76 to 0.77. During the same period, Menlo Park is projected to gain 2,290 households and 6,065 jobs, increasing the employment to household ratio in Menlo Park from 2.37 to 2.40. ABAG and MTC project that San Mateo County will gain 33,695 households and 72,750 jobs overall between 2020 and 2040, increasing the Countywide employment to household ratio from

1.40 to 1.48.

Projected Population, Household, and Employment Growth, 2020-2040 Sources: Association of Bay Area Governments/Metropolitan Transportation Commission, Plan Bay Area 2040 Projections; BAE 2021.

2.9 UNEMPLOYMENT
Jurisdictions throughout the region experienced a sharp rise in unemployment in 2020 due to impacts related to the COVID-19 pandemic, though with a general improvement and recovery in the later months of 2020. As of January 2021, East Palo Alto’s unemployment rate was 8.6%, which was slightly higher than the regional unemployment rate of 6.6% but much lower than its pandemic-related high rate of 13.1% in April 2020. East Palo Alto’s pre-pandemic unemployment rate was 2.9% (January 2020). Based on reporting from City partners Chapter 2 – Page 42
who assist East Palo Alto residents with applying for state emergency COVID-19 relief funds, the impact of COVID-19-related unemployment continues to affect households’ ability to cover both current and past accumulated housing costs.

2.10 “HIGH” VERSUS “LOW”-RESOURCE NEIGHBORHOODS
Some neighborhoods are identified as “Highest Resource” or “High Resource” by the State of California based on a range of indicators such as access to quality schools, proximity to jobs and economic opportunities, low pollution levels, and other factors. However, neighborhoods don’t always receive an equitable share of these community resources and may be designated as “Low Resource” if they lack these amenities. All East Palo Alto residents live in neighborhoods identified as “Low Resource”, meaning there are no “High Resource” neighborhoods in East Palo Alto. This lack of high-resource neighborhoods and its implications are further discussed in the Affirmatively Furthering Fair Housing section.

2.11 SPECIAL NEEDS POPULATIONS
Individuals with disabilities: Some population groups may have special housing needs such as mobility and accessibility barriers. 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.

Individuals with development disabilities: East Palo Alto is home to 313 people with developmental disabilities. This represents an 82% increase from the 172 people with developmental disabilities reported in the 2015-2023 Housing Element, much faster than the 6% increase in the County’s total population of people with developmental disabilities over the same time period.5 86% of adults continuing to live in the family home, a larger share than the County, likely due to the lack of any licensed care facility in the East Palo Alto.

Individuals with developmental disabilities who do not live in a licensed care facility or who cannot live with family need affordable housing options with supportive services. The current lack of affordable housing with services, combined with the need for transit access and access to amenities, has led to a growing population of individuals with developmental disabilities in East Palo Alto that is at higher risk of displacement than other groups.

Female-headed households: Approximately 21% of households are female-headed families, which are often at greater risk of housing insecurity, or being at risk of losing their home.

The following map shows the distribution of female-headed households in the City.

Chapter 2 – Page 43
Map 2.11.A Female Headed Households (2019)
Source: ACS Table B11001, 2015-2019 5-Year Estimate.

Note that female-headed households include family households with a female householder and no spouse present. A higher concentration of female-headed household resides in multi-family housing zones on the Westside (west of Highway 101) and on the eastside (east of Highway 101). A smaller portion reside in single family neighborhoods.

Chapter 2 – Page 44
Individuals experiencing homelessness:

The population of homeless individuals in the City of East Palo Alto also experiences major barriers to both temporary and permanent housing. This population includes a high number of school-age children: the number of students in East Palo Alto experiencing homelessness in 2019-20 (514) represented 43.9% of the San Mateo County total.

Larger households:

27.5% of East Palo Alto households are larger households with five or more people.

2.12 AFFORDABLE HOUSING UNITS AT-RISK OF CONVERSION TO

MARKET RATE
Jurisdictions are required to report in their Housing Element on any affordable units at-risk of conversion to market-rate over the eight-year Housing Element period (Government Code section 65583, subdivision (a)(9)).

Conversion to market-rate can result from:
a) expiration of funding-related affordability restrictions; b) foreclosure of BMR units
c) turnover of rent-stabilized units; or
d) habitability and maintenance issues that require code enforcement or legal action. [Intentionally Left Blank]
Chapter 2 – Page 45

2.12.1 Existing Affordable Housing
As shown in the table below, the City of
East Palo Alto currently has over 10
deed-restricted affordable housing
developments, 53 below market-rate
(BMR) ownership units, and 2,500 rentstabilized units (see map of rent stabilized inventory). Most affordable
rental housing developments received
some form of City assistance and are
subject to affordability restrictions
imposed by the City and other funding
entities. The City’s ownership BMR
units are the result of the former
Redevelopment Agency’s assistance or
market-rate developer obligations to
create affordable units under an
Inclusionary Housing or other program.

Units in the rent-stabilized portfolio are
subject to the 2010 Rent Stabilization
and Just Cause for Eviction Ordinance.

Map 2.12.1: East Palo Alto Rent Stabilized Units Inventory Chapter 2 – Page 46
Table 2.12.1: Existing Housing Units in East Palo Alto
Project Name Address Owner Tenure Type Risk
Level
Affordability
End Year
Government
Assistance Affordable RSO Market
Rate Total
Courtyard at Bay
Rd. 1730 Bay Rd N/A Rental Deedrestricted Low 2060 LIHTC 76 76 Nugent Square** 2361 University
Ave
Eden
Housing Rental Deedrestricted Low 2078 LIHTC 32 32
Serenity Senior 2358 University
Ave
MidPen
Housing Rental Deedrestricted Low 2069 LIHTC 40 1 41
Light Tree 1805 E Bayshore
Rd
Eden
Housing Rental Deedrestricted Low 2074 LIHTC, HUD, HCD 182 3 185 Peninsula Park* 1977 Tate Street BRIDGE
Housing Rental Deedrestricted Low 2053 LIHTC 65 64 129 Bay Oaks 2400 Gloria Way MidPen
Housing Rental Deedrestricted Low 2075 LIHTC 37 1 38
Clarke Ave. 2397 Clarke Ave. EPA CAN
DO Rental Deedrestricted Low - 15 15
Woodlands
Newell
1761 Woodland
Ave
MidPen
Housing Rental Deedrestricted Low 2068 LIHTC 47 2 49
Runnymede
Gardens 2301 Cooley Ave MidPen Housing Rental Deedrestricted Low 2055 LIHTC; HUD; CalHFA 77 1 78 BMR Units - - For-Sale Deedrestricted Low - - 53 53
Woodland Park
Rent Stabilized
Units
-
Sandhill
Property Co. Rental Rent Stabilized N/A Upon Vacancy*** - 1,838 1,838 All Other Rent
Stabilized Units - - Rental Rent Stabilized N/A Upon Vacancy*** - 709 709 All Other
Housing Units - -
Rental &
For-Sale
Market
Rate N/A N/A - 4,740 4,740
Units 624 2547 4812 7983
Percentage 8% 32% 60% 100%
*NOTE: Peninsula Park – many units marked “market-rate” are currently rented by Section 8 households. **Long-term affordability covenants for Nugent Square got extended in 2022 resyndication. Project received $7 million for necessary repairs and renovations. ***Due to Costa Hawkins and vacancy decontrol.

Chapter 2 – Page 47

2.12.2 At-Risk Affordable Housing Analysis

2.12.2.A Expiring Contracts According to the California Housing Partnership Corporation and the City of East Palo Alto, there are no affordable rental units with affordability contracts expiring. The earliest expiration date for the affordability contracts is in the year 2053 so the lost of at-risk units during the 6th cycle Housing Element is minimal. However, these projects may benefit from housing rehabilitation assistance to ensure that these projects are properly maintained during the affordability term.

Deed-restricted units in East Palo Alto have a low risk level of conversion to market-rate. Table below lists the deed-restricted affordable housing developments in the City and their risk level of conversion to market rate.

Table 2.12.2.A: Deed-Restricted Units by Risk Level
Name Address Affordable
Units
Total
Units
Funding Program Estimated
Affordability
End Year
Risk Level
Light Tree 1805 East Bayshore Road 56 57 LIHTC; HUD; CalHFA 2074 Low Runnymede Gardens 2301 Cooley Avenue 77 78 LIHTC; HUD; CalHFA 2055 Low Peninsula Park Apartments 1977 Tate Street 65 129 LIHTC 2053 Low Nugent Square 2361 University Avenue 31 32 LIHTC 2078 Low Light Tree Two 1805 East Bayshore Road 126 128 LIHTC; HUD; HCD 2074 Low Gloria Way Community
Housing
2400 Gloria Way 37 38 LIHTC 2050 Low
Woodlands Newell (Site A) 1761 Woodland Ave. 47 49 LIHTC 2068 Low University Avenue Senior
Housing
2358 University Avenue 40 41 LIHTC 2069 Low
The Courtyard at Bay Road 1730 Bay Road 76 77 LIHTC 2060 Low Wisteria House 211 Wisteria Avenue 4 4 HCD 2041 Low
Source: California Housing Partnership’s Preservation Database, 21 Elements.

Chapter 2 – Page 48

2.12.2.B BMR ownership units are an important source of Moderate-Income housing, or housing affordable to households at 81-120% of the Area Median Income. These units may be at risk of being “lost” from the BMR program due to noncompliance, foreclosure, or other means. Prior to the release of a Request for Proposals (RFP) to identify a qualified organization to administer the City’s BMR Program in 2018, due to low staffing levels, units in the BMR Program were not under consistent monitoring, and actions such as refinances, loan subordinations, re-sales were difficult and inefficient for the City to facilitate.

Of the 74 BMR files that EPACANDO verified to be within the City’s BMR portfolio, 4 were lost to foreclosure, 3 were sold in violation of the resale restriction agreement, and 14 reverted to market-rate as a result of the expiration of a five-year affordability term. With a BMR contractor in place conducting annual monitoring, overseeing transactions, and maintaining regular contact with BMR homeowners, these 53 units are at very low risk of “exiting” the program.

2.12.2.C Rent-stabilized units revert to market-rate when the occupant vacates, with rental increases limited to the Annual General Adjustment adopted by the City’s Rent Board each year thereafter. Referred to as “vacancy decontrol,” the reversion to market-rate occurs more frequently with higher turnover, making many units in the rent-stabilized portfolio unattainable for lower-income households. Each year, approximately 300- 400 rent stabilized units (12-16%) become vacant and return to market-rate. Due to this turnover, the City often cannot count all rent stabilized units as affordable rental units.

The following maps overlay rent stabilized units over median household incomes and overcrowded households, two factors that may contribute to turnover.

Chapter 2 – Page 49

2.12.2.C.1 Rent Stabilized Units Inventory and Overcrowded Households 2.12.2.C.2 Rent Stabilized Units Inventory Median Household Incomes Chapter 2 – Page 50

2.12.2.D Habitability and maintenance issues that require code enforcement or legal action can also increase risk of conversion to market-rate and displacement. Usually these units can be considered “substandard households” because they may be missing basic services and amenities.

The City tracks substandard housing through complaints filed with the Rent Stabilization Program, which typically are filed by households both in rent stabilized and non-rent stabilized units, and through code enforcement cases submitted to Building/Code Enforcement. Between 2016 and 2022, the City had substandard housing code enforcement cases open at ten different locations, nine of which were in single-family home neighborhoods and one of which was in a multi-family home neighborhood. The cases included: sheds housing people, unsafe electrical and gas, junk and debris, dilapidated housing, and other items that were deemed “substandard housing.” Between 2015 and 2022, the City had substandard housing petitions/complaints at 36 different locations, the majority of which were located in the West of Highway 101, where a majority of rent stabilized units remain. Rent Stabilization Program petitions/complaints also came from buildings along Bay Road, where a bigger portion of large multi-family apartments are located, and in smaller 2–4-unit buildings located in single-family home neighborhoods on the East side of Highway 101. These petitions/complaints filed were primarily for habitability or maintenance problems, as well as service reductions.

Map 2.12.2.D.1 maps sites that have recorded substandard housing complaints, by frequency level.

Map 2.12.2.D.2 maps these substandard housing site by density, to identify whether complaints arise more frequently in multi-family neighborhoods compared to single-family neighborhoods.

Map 2.12.2.D.3 maps these substandard housing sites by income, to see where these complaints may be located near concentrations of poverty.

Map 2.12.2.D.1 Substandard Housing Frequency
Chapter 2 – Page 51
Map 2.12.2.D.2 Substandard Housing (and Density)
Chapter 2 – Page 52
Map 2.12.2.D.3 Substandard Housing (and Income)
Chapter 2 – Page 53

2.12.3 Entities Qualified to Preserve At-Risk Units
There are several organizations in the region that have the capacity to own and manage affordable rental projects. There organizations include affordable housing developers such as Eden Housing, MidPen Housing, BRIDGE Housing, Mercy Housing, and others. The City can also directly purchase at-risk units, although the management, processing, and maintenance of these units can pose a funding challenge.

Since 2020, the City has researched various preservation models as part of the San Francisco Foundation’s Partnership for the Bay’s Future Policy Grants (the City started with the 2020-2022 Challenge Grant and continues to do so with the 2022-2024 Breakthrough Grant). Other East Palo Alto community-based entities such as East Palo Alto Community Alliance & Neighborhood Development Organization (EPACANDO) and Preserving Affordable Housing Long-Term, Inc. (PAHALI) community land trust have expressed interest in acquiring and preserving at-risk properties, to create community empowerment and maintain community control. The City currently has a contract with EPACANDO and PAHALI to preserve affordable spaces at the Palo Mobile Estates mobile home park by supporting residents in purchasing their lots. The park underwent conversion to a resident-owned park in 2021.

2.12.4 Preservation Costs
According to Enterprise Community Partners, Inc. (Enterprise), acquisition-rehab can be a direct antidisplacement strategy that advances racial and economic equity, a fast and cost-effective strategy, a flexible strategy that expands housing choices, and a long-term, environmentally sustainable strategy.

There are different types of affordable housing models for acquisition-rehab projects, including: affordable rental (deed-restricted) housing models where the nonprofit acquires and retains ownership of the land and property, and the rental units are held affordable; Limited Equity Housing Cooperatives (LEHC) models, where the residents form an entity that acquires the property and residents purchase and own shares in the LEHC at an affordable price, entitling them to reside in their unit and build some equity; and Community Land Trust (CLT) models, whereby the CLT acquires the land and property, but the property may be sold and owned by the residents at an affordable price, or retained and operated as a rental.

Between 2015-2019, the per-unit cost of completed acquisition-rehab projects in San Mateo County averaged $433,203 total per unit (75% of which was the purchase price, and the rest included rehab costs, financing costs, soft costs, developer fees, among other costs). Of that total, the per-unit subsidy averaged nearly $224,000.

The table below compares new affordable housing production per-unit cost and preservation per-unit cost to illustrate the magnitude of funding needed in production projects compared to preservation projects.6 Chapter 2 – Page 54
Table 2.12.4: San Mateo County Acquisition-Rehab
and New Construction Per-Unit Cost Comparison (Enterprise 2020 Report) New Affordable Housing Production
Per-Unit Cost
Occupied Acquisition-Rehab
Per-Unit Cost (Study Sample)
2016 2017 2018 2016-2018
Average
Average Compared to
New Production
$479,262 $665,831 $729,458 $627,681 $433,203 69%

2.12.5 Potential Funding Sources to Preserve Affordable Housing Financing for housing preservation will come from a combination of private and public funding, including local, regional and state subsidies, loans from banks and lending institutions like credit unions and Community Development Finance Institutions (CDFIs), and the private capital of tenants (if applicable).

A table of potential funding sources for Affordable Housing Preservation is featured below.

Table 2.12.5: Funding Sources for Affordable Housing Preservation Funding Source Funding Type Eligible Uses
Max
Assistance
Golden State Acquisition Fund Below market debt Acquisition $13,950,000 Foreclosure Intervention Housing Preservation
Program Grants, debt
Predevelopment, acquisition, rehabilitation, temporary
relocation. An operating subsidy is available for projects serving households making 50% AMI and below.
$450,000 -
$550,000
per unit
Project Homekey Grants
Acquisition, rehabilitation, of eligible dwelling types and operating support Varies
HOME Investment Partnerships Program Varies Acquisition, rehabilitation Varies Community Development Block Grant (CDBG) Grant Acquisition, rehabilitation Varies Bay Area Preservation Pilot Below market debt Acquisition, rehabilitation Varies Affordable Housing Fund Below market debt Predevelopment, acquisition, rehabilitation $100,000
per unit
Community Housing Fund Below market debt
Variety of loan products from predevelopment through
permanent financing $15,000,000
Supportive and Transitional Housing Varies
Acquisition, Predevelopment, Construction, MiniPermanent $6,000,000 Affordability Preservation and Production Varies Acquisition, Predevelopment, Construction, Rehabilitation $6,000,000 Workforce Housing Varies Acquisition, Predevelopment, Construction $7,500,000 Chapter 2 – Page 55
Enterprise-Level Line of Credit Varies
Revolving Line of credit for acquisition, predevelopment, working capital allowed with acquisition or predevelopment $6,000,000 Kaiser Housing for Health Fund Equity Varies by project Varies Bay Area Transit-Oriented Affordable Housing
(TOAH) Fund: Predevelopment Loan Below market debt Predevelopment costs for acquisition of Eligible Properties $750,000 Bay Area Transit-Oriented Affordable Housing
(TOAH) Fund: Acquisition Loan Below market debt Acquisition $10,000,000 The Catalyst Fund Below market debt Acquisition, Predevelopment, Permanent Financing Varies

2.12.5.A City Funding Sources
The City of East Palo Alto has a recent history of residents supporting local tax measures to provide revenues for affordable housing construction and related programs, although the sources for the tax payments are borne by property owners of large office buildings and multi-family rental properties.

Measure O:

In November 2016, residents voted to enact Measure O or the East Palo Alto Residential Rental Business License Tax Measure. Measure O is a one- and one-half cent tax on the gross receipts of owners who lease five or more residential rental units in East Palo Alto. The Business License Tax cannot be passed on to tenants and does not apply to new housing units during the first 10 years after a certificate of occupancy is issued. Nonprofit operators of affordable housing, Section 8 units, or below market rate units with deed restrictions are exempt from the tax. While Measure O funds can use for general government purposes, fund can be used to directly benefit Housing Element goals, policies, and programs. Highlighted uses included increasing affordable housing, protecting local residents from displacement and homelessness, and funding affordable housing programs. Funds have been used to provide initial start-up and operating funds for the City’s Pilot Recreational Vehicle (RV) Safe Parking Program in 2019 for unhoused residents. The City has also authorized allocating funds to several non-profit organizations to provide anti-displacement fair housing services, legal consultation, case management and referrals, information resources, community workshops on tenant/landlord laws, and community outreach and advocacy efforts. Three non-profit community organizations have been providing these services: Community Legal Services in East Palo Alto (CLSEPA), Nuestra Casa, and Youth United for Community Action (YUCA).

Measure HH:

In November 2018, East Palo Alto residents voted to enact Measure HH, a parcel tax on commercial office space of 25,000 square feet or more at the rate of $2.50 per square foot, which is estimated to raise $1,675,000 annually that may be used for several purposes: 1) maintenance of affordable and supportive housing programs, with an emphasis on creating net new housing (minimum of 35% of the funds must be used for this purpose); and 2) creation and maintenance of programs that facilitate access to job opportunities for East Palo Alto residents in Chapter 2 – Page 56
the science, technology, engineering, and mathematics (STEM) sectors and building trades sector; and 3) strengthen the City’s First Source Hiring (FSH) Program.

Since passage of Measure HH, the City has authorized approximately $1 million in assistance for a 100% affordable housing project (965 Weeks) that will consist of 136 low-income units serving households with average 45% area median income (AMI). The project is entitled and currently in the building permit review stage.

The City has also established a Pilot Workforce Development Program using Measure HH funds. To conceptualize the program, the City sought a consultant experienced in workforce development to identify strategies to maximize the effectiveness and impact of Measure HH funding. In October 2020, the City Council retained Brightline Defense Project (“Brightline”) to analyze and provide recommendations for implementing a workforce development program. Brightline conducted considerable public outreach and discussions with the community and employers on the appropriate allocation of Measure HH funds to provide “upward mobility” for East Palo Alto residents through training for sustainable jobs in reliable employment fields. Brightline’s concluded that the primary factors that are impeding upward mobility for East Palo Alto residents are: 1) lack of education and job training in the two targeted fields; 2) lack of financial resources for training; 3) the need to continue earning an income while in training; 4) lack of professional support and career guidance; and 5) the difficulty in accessing employment networks in the STEM and building trades fields, particularly for persons of color.

In November 2022, City Council authorized $775,215 from the Measure HH Fund to fund an 18-month Pilot Workforce Development Program. The program is intended to address the disparity between the region’s robust innovation and technology economy and the inability of East Palo Alto residents to benefit from the region’s economic prosperity. The pilot program’s goals are to offer participants a training program and, after completing training, to support and assist participants in finding a sustainable job that can achieve a living wage within 36 months after completion of training. Three non-profit community organization have been awarded funds to offer an innovative mix of STEM and building trades training programs: JobTrain, StreetCode Academy, and Live In Peace. The program will begin in 2023 and is only available to East Palo Alto residents with the Live In Peace program targeted for high school students and recent graduates. It is expected that the program will continue to be funded after the pilot period. The program also has an anti-displacement objective; with residents able to gain living wage jobs, it would increase their ability to remain in the community.

Measures V and L:

In November 2020, City Council placed Measure V on the ballot to help fund affordable housing development, acquisition and rehabilitation. Measure V was projected to provide approximately $390,000 per year, with an additional amount upon recovery from the COVID-19 pandemic. While it was unsuccessful in passing by a two percent margin, a similar ballot measure, Measure L, was subsequently approved by East Palo Alto voters in November 2022 to support housing affordability and to prevent displacement. Similar to Measure O, Measure L assesses a business tax on rental property but also applies to smaller properties with less than five rental units.

The measure is projected to generate up to $2 million annually to fund affordable housing programs in the City.

Chapter 2 – Page 57
In addition to the above tax revenue, City Council may choose to use existing General Funds for affordable housing production and preservation efforts. The Council has also earmarked a portion of the City’s Transient Occupancy Tax (TOT) for housing programs.

2.12.5.B Regional Funding Sources
Regional funding sources include the Metropolitan Transportation Commission (MTC)’s Bay Area Preservation Pilot (BAPP), a $49 million program launched in 2018 to provide flexible, relatively low-cost loans for up to 10 years to mission-driven developers and community-based organizations seeking to acquire, and preserve existing, unsubsidized affordable multi-family properties located in areas with high-frequency transit service. The Bay Area Transit-Oriented Affordable Housing Fund (TOAH), a $50 million public-private financing resource providing seven-year loan products at favorable interest rates and loan to value ratios (LTV), is aimed at supporting nonprofit and for-profit developers to help finance the purchase or improvement of properties near transit.7 TOAH is sponsored by a collaborative public-private partnership with the MTC and the Great Communities Collaborative. The Regional Early Access Planning (REAP 2.0) Grants administered by ABAG/MTC include a $15 million set aside for Affordable Housing Preservation, funding a maximum of $250,000 per door. A regional housing funding initiative proponed by the Bay Area Housing Finance Agency (BAHFA) expects to distribute at least $10 Billion after 2024, of which 15% of funds are prioritized for Affordable Housing Preservation across the 9-county region. BAHFA was established by California State Legislature Assembly Bill 1487 (2019, Chiu) to support the production and preservation of affordable housing by placing new revenue options on the ballot. BAFHA has the potential to raise hundreds of millions of dollars to help address affordable housing in the Bay Area.

2.12.5.C State Funding Sources
The state allocated $300 million for the preservation of existing affordable homes in the 2021-2022 California budget, creating a new Affordable Housing Preservation Program at the Department of Housing and Community Development (HCD).8 With the expansion of HCD programs and increasing awareness about the importance of housing preservation, the state is anticipated to allocate more funds towards housing preservation.

The Foreclosure Intervention Housing Preservation Program (FIHPP) is a statewide Affordable Housing Preservation fund of $500 Million dedicated to properties undergoing or at risk of foreclosure. These funds can be used both for single family and multifamily properties for acquisition, rehabilitation, and a host of other cost coverages.

2.12.5.D Private Funding Sources, Funding Initiatives and Lending Institutions 7 https://mtc.ca.gov/funding/investment-strategies-commitments/housing-solutions/transit-oriented-affordable-housing-fundtoah 8 https://calhsng.org/2021-2022-california-budget-update/ Chapter 2 – Page 58
Other potential funding sources include, but are not limited to: public-private partnerships. In particular Community Development Financial Institutions (CDFIs) that provide flexible financing for affordable housing developments for use for predevelopment, acquisition, construction rehabilitation, and bridge funding. These private sector financial institutions have community development as their primary mission and can receive funding from other private sector sources such as individuals, corporations, religious institutions, and provide lending services. Locally, groups such as Housing Trust Silicon Valley, Enterprise Community Partners (Enterprise), and the Local Initiatives Support Corporation (LISC) provide lending products designed to help developers get projects financed. The following are a few examples:
• The Housing for Health Fund (HFHF), a collaboration among Enterprise, Kaiser Permanente, and JP Morgan Chase, provides $85 million to promote health and the preservation of affordable housing. 9 • Enterprise’s Equitable Path Forward Fund is a five-year, $3.5 billion nationwide initiative to counter racial inequities rooted in housing, and focuses on supporting Black, Indigenous, and People of Color and housing providers who create and preserve affordable homes.10 • The Partnership for the Bay’s Future Bay’s Future Fund (BFF) and Community Housing Fund (CHF), a $500 million initiative to bridge funding gaps throughout the region’s rental housing market and address critical housing needs. The funds are managed by LISC and originated by the San Francisco Foundation, Bay Area LISC, the Corporation for Supportive Housing (CSH), Capital Impact Partners, and other public-private partners.11
Private companies in the Bay Area have also begun to provide financing for affordable housing developments. Recent investments include The Catalyst Fund, a partnership among Facebook, the City of East Palo Alto, the City of Menlo Park, and Envision Transform Build East Palo Alto (ETB-EPA). ETBEPA is a coalition of community groups in East Palo Alto that challenged Facebook to commit to furthering shared goals of enhancing equity, opportunity and access in the Silicon Valley, resulting in a community compact.12 The $18.5 million fund was created to provide financing for affordable housing developments within a 15-mile radius of Meta (formerly Facebook)’s Menlo Park campus, and is managed by LISC Bay Area and Housing Trust Silicon Valley. Based on the agreement, $10 million of the fund must be invested in permanently affordable housing in East Palo Alto; the remainder could be invested in affordable housing and preservation projects in San Mateo County or Santa Clara County within a 15-mile radius of Meta’s Menlo Park campus. To date, four affordable housing projects in San Mateo County have received funding awards through The Catalyst Fund, two of which are in East Palo Alto (Light Tree and 965 Weeks). 9 https://www.enterprisecommunity.org/news-releases/2020-03_housing-health-fund-makes-48-million-oakland-investment 10 https://www.enterprisecommunity.org/impact-areas/racial-equity/equitable-path-forward. 11 https://www.lisc.org/bay-area/what-we-do/affordable-housing/partnership-bays-future/ 12 Community Groups that signed the Community Compact included El Comité de Vecinos del Lado Oeste, East Palo Alto; Youth United for Community Action; Faith in Action Bay Area; and Community Legal Services in East Palo Alto.

Chapter 2 – Page 59
• LightTree Apartments is a major project sponsored by two experienced, mission-driven organizations – Eden Housing and East Palo Alto Community and Neighborhood Development Organization (EPACANDO). The $97 million project is both preserving/renovating 94 existing units and adding 91 new apartments affordable to extremely low-income and very low-income residents, and sets aside as many as 41 units for households with special needs: formerly homeless residents, youth aging out of foster care and households with a family member who has a disability. Light Tree is also the first allelectric affordable housing development in San Mateo County. The Catalyst Fund is providing a $4 million predevelopment loan to seed the project’s complex mix of public and private financing and support early planning efforts. The loan carries an almost unheard-of term of 57 years- illustrating the kind of flexible, affordable capital that is so vita for affordable housing efforts. • 965 Weeks is a development project sponsored by MidPen Housing and EPACANDO that will build 136 extremely low-income and low-income affordable housing units, ranging from studios to fourbedroom apartments, on a city-owned parcel. It will provide services to residents including a financial literacy program, a vocational development center, afterschool/summer programs and leadership development for youth, and functional assessment and cognitive/behavioral modification for people with special needs. The $1 million predevelopment loan from The Catalyst Fund will convert to a 57- year permanent loan after construction, providing flexible, affordable capital that is critical but hard to find. The Catalyst Fund has also committed to an additional $4.365 million permanent loan request for 965 Weeks.

Additional private lending sources can include credit unions, cooperative banks, and other banks willing to work with resale-restricted properties, LEHCs and CLTs. 13 2.13 EAST PALO ALTO HOUSING NEEDS DATA PACKET
The Housing Needs Data Packet (Appendix B1) provided by ABAG/MTC and 21 Elements outlines more extensively the City’s housing needs.

2.14 SAN MATEO COUNTY HOUSING NEEDS
Appendix B2 summarizes of housing needs in San Mateo County as a whole. 13https://www.lisc.org/media/filer_public/f0/e0/f0e07be0-1ca5-4720-b78c3a0d7a0181dd/022519_white_paper_community_land_trusts.pdf; https://groundedsolutions.org/tools-for-success/resourcelibrary/mortgage-financing-options. [Intentionally Left Blank]
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Chapter 3 - Page 1
3 HOUSING CONSTRAINTS
To facilitate the development, maintenance, and improvement of housing (especially affordable housing), the Housing Element must assess the potential constraints imposed by both City regulations and policies (i.e., “governmental constraints”), and by factors outside of City influence, such as market conditions (i.e., “nongovernmental constraints”). This assessment must address housing for all income levels, including housing for persons with disabilities.

Therefore, this Element analyzes the potential impacts of governmental regulations and policies on housing, including land use controls, fees and exactions, building codes, processing and permitprocedures, codes and enforcement, and on/off-site improvement standards. Likewise, it also assesses nongovernmental or potential market impacts, including land costs, construction costs, and the availability of financing. The findings of the analysis are outlined below. For any constraints to housing found within this section (via regulatory and/or market conditions), a program has been included in the Policies and Programs to address and mitigate the constraint

3.1 GOVERNMENTAL CONSTRAINTS
Governmental policies and regulations can result in both positive and negative effects on the availability affordability of housing. While government policies and regulations are intended to meet legitimate public purposes and further the public good, it is possible that they indirectly constrain the availability and affordability of housing to meet the community’s future needs.

The City complies with state transparency requirements. The City’s General Plan, Development Code, Inclusionary Housing Ordinance, other land use policy plans and regulations, and active project applications are available on the City’s website. Additionally, the City has available on the website a number of informational flyers and resources that describe the City’s zoning and development standards, project application procedures, and housing programs and services. In addition to complying with transparency requirements, project applicants are strongly encouraged to seek community input before presenting their project to the Planning Commission and City Council.

This section describes City policies and regulations that could potentially constrain the City’s ability to achieve its housing objectives. Each Housing Element must contain an “analysis of potential and actual governmental constraints upon the maintenance, improvement, or development of housing for all income levels, including land use controls, building codes and their enforcement, site improvements, fees and other exactions required of developers, and local processing and permit procedures” (Government Code Section 65583(a)). All Planning.

Building, Housing, and Public Works related requirements, including zoning, development standards, Chapter 3 - Page 2
inclusionary requirements, and impact fees, to name a few, are posted online on the City’s website, www.cityofepa.org.

This section addresses every aspect of the residential development process: the regulations currently in place, the responsible City Departments and Divisions, and the role of the City Council and Planning Commission, developers, and the general public. This is followed by analysis of the potential of any of these to constrain residential development, and how this may be mitigated.

The governmental constraints analysisfocuses on factorsthe City can control and does not include State, federal, or other governmental policies or regulationsthat East Palo Alto cannot affect or modify. These City policies and regulations typically affect the City’s ability to meet future housing needs and secure adequate funding for the construction of affordable housing.

3.1.1 General Plan Residential Uses and Zoning Controls in East Palo Alto The City adopted Vista 2035, its General Plan, in October 2016, following the adoption of the RHNA 5 Housing Element. As described in the Land Use Element, residential uses are now permitted within eight General Plan designations. Each of these is described in Table 1 below alongside the zoning area that corresponds to it.

In addition to the below General Plan land uses, the Ravenswood/4 Corners Specific Plan, which was adopted in 2013 and established City’s only Priority Development Area,14 permits residential in three zoning areas: 4 Corners, Bay Road Central, and Urban Residential.
14 A Priority Development Area is an ABAG/MTC-designated area near public transit planned for new homes, jobs and community amenities. Ravenswood/4 Corners Specific Plan Area is a Connected Community PDA, meaning that it offers basic transit services, and the City has committed to policies that increase mobility options and reduce automobile travel.

Table 3.1.1.A: General Plan Land Use Designations and Related Zoning General Plan Land Use Designation Density
(du/acre) Related Zoning Density (du/acre)
Low Density Residential 12 R-LD 0-12
Medium Density Residential 12.1-22 R-MD 1/RM-D 2 12 to 15/12- 22 High Density Residential 22.1-43 R-HD 3/R-HD 5 22-43 Urban Residential 43.1-86 R-UHD 43-86
Mixed Use Corridor up to 65 MUC 1/MUC 2 22-65
Mixed Use Low up to 22 MUL 0-22
Mixed Use High up to 86 MUH 43-86
Neighborhood Commercial up to 22 CN 0-22
Chapter 3 - Page 3
The above zoning designations are found in Chapter 18 of the East Palo Alto Municipal Code (Development Code). The Development Code describes in detail the development standards for each zone, including minimum and maximum density, parcel area and width, lot coverage, floor area ratio (“FAR”), height, open space, setbacks, and parking.

The zoning standards for residential and mixed-use zones are summarized in the table below.

Table 3.1.1.B: Zoning Standards for Residential Zones
Zoning Min/Max
Dwelling
Unit/Acre
Min
Parcel
Area
Lot
Coverage
Height
(feet)
Open Space
(square
feet)*
Floor
Area
Ratio
(FAR)
Setback
(ft)
Parking
(spaces)
R-LD 0 to 12 5,000s.f.
50f wide
.5 26 750 .55 front 10
rear 10
side 5
1 for 1
bdrm; 2 for
2-4 bdrm;
3 for 5-6
bdrm
R-MD 1 12 to 15 5,000s.f.
50f wide
.6 30 250 common
1-200 private
.65 front 20
rear 20
side 10
1 for 1
bdrm; 2 for
2-4 bdrm;
3 for 5-6
bdrm
R-MD 2 12 to 22 5,000s.f.
50f wide
.6 36 250
common
1-200 private
.65 front 20
rear 20
side 10
1 for 1
bdrm; 2 for
2-4 bdrm;
3 for 5-6
bdrm 1
R-HD 3 22 to 43 12,000s.f.
50f wide
.7 36 100 common
50-100
private
.7 front 15
rear 20
side 10
1 for 1
bdrm; 2 for
2-4 bdrm;
3 for 5-6
bdrm
R-HD 5 22 to 43 12,000s.f.
50f wide
.7 60 100
Common
.7 front 15
rear 20
1 for 1
bdrm; 2 for
Ravenswood/4 Corners Specific Plan Zoning
Ravenswood/4 Corners Specific Plan Density
(du/acre) Related Zoning Density (du/acre)
4 Corners up to 60 n/a n/a
Bay Road Central up to 50 n/a n/a
Urban Residential up to 40 n/a n/a
Chapter 3
- Page4
50-100
private
side 102-4 bdrm;
3 for 5-6
bdrm
MUL 0 to 22 12,000.s.f
100f wide
1 361 front 0
rear 5
side 5
1 for 1
bdrm; 2 for 2-4 bdrm;
3 for 5-6
bdrm
MUC 1 22 to 65 12,000.s.f
100f wide
1 60 1.25 front 0
rear 5
side 5
1 for 1
bdrm; 2 for 2-4 bdrm;
3 for 5-6
bdrm
MUC 2 22 to 65 12,000.s.f
100f wide
1 60 1.25 front 0
rear 5
side 5
1 for 1
bdrm; 2 for 2-4 bdrm;
3 for 5-6
bdrm
MUH 43 to 86 12,000.s.f
100f wide
1 8 stories or
100’,
whichever
is greater

2.5 front 0
rear 5
side 5
1 for 1
bdrm; 2 for 2-4 bdrm;
3 for 5-6
bdrm
R-UHD 43 to 86 12,000s.f.
50f wide
.7 7 stories or
75’,
whichever
is greater
50 common
50 private
None front 20
rear 20
side 10
1 for 1
bdrm; 2 for 2-4 bdrm;
3 for 5-6
bdrm 1
UR 0 to 40 n/a1 60 n/a1 front 5
rear 20
side 5
1 for 1
bdrm; 2 for 2-4 bdrm;
3 for 5-6
bdrm
BRC 0 to 50 n/a1 5 stories
above
grade
n/a 2.0 for
non-
residential
area
front 6
rear 30
side 10
1 for 1
bdrm; 2 for 2-4 bdrm;
3 for 5-6
bdrm
Chapter 3 - Page 5
4 Corners 0 to 60 n/a 1 6 stories
above
grade
n/a 1.5 front 6
rear 30
side 10
1 for 1
bdrm; 2 for
2-4 bdrm;
3 for 5-6
bdrm
* Per dwelling unit

3.1.2 Type of Residential Development Permitted in Each Zone – Zoning for a Variety of Housing Types
The table below shows which residential or mixed-use zones allow for different types of residential development.

Table 3.1.2.A: Types of Residential Development Permitted in the City’s Residential and Mixed-Use Zones Type Single
Family*
Duplex Triplex QuadplexMulti
(5+)
Mobile
Home
SRO Assist.

Living*
Supportive
Housing
Transitional
Housing
R-LD
R-MD
R-UHD
MUC
MUL
MUH
UR
BRC
4 Corners
Yes
Yes
Yes
No
No
No
Yes
No
No
No
Yes
Yes
Yes
Yes
Yes
Yes
No
No
No
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
No
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
No
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
No
No
No
No
No
No
No
No
No
Yes
Yes
Yes
No
No
No
No
No
No
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
*Detached and attached single family dwellings.
*Requires Administrative Use Permit for 7 or more occupants.

3.1.3 Supportive, Transitional, and Emergency Housing Uses As shown in Table 3.1.2.A above, Supportive and Transitional Housing are permitted uses within all residential zones in the City.

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). Emergency Shelters are permitted by-right in the City’s Industrial Transition zone, which is located in the Ravenswood/4 Corners Specific Plan Area.

Chapter 3 - Page 6
This is compliant with Government Code Sections 65583(a)(4) and (5), which specify that local governments must identify at least one zone where emergency shelters are permitted by-right and that transitional housing and supportive housing must be considered a residential use subject to the same restrictions as other multifamily dwellings in the same zone. Emergency Shelters will only be subject to the written, objective standards outlined in CA Government Code Section 65583(A)(4)(B) as required by law.

The City has one Low-Barrier Navigation Center (LBNC), a shelter operated by Project WeHOPE at 1836-54 Bay Rd. Consistent with Assembly Bill (AB) 101, a LBNC is a use by right in areas zoned for mixed use and nonresidential zones permitting multifamily uses. A LBNC is defined as a Housing First, low barrier, temporary, service-enriched shelter focused on helping homeless individuals and families to quickly obtain permanent housing. Low barrier includes best practices to reduce barriers to entry, such as allowing partners, pets, storage of personal items, and privacy (Gov. Code, § 65660).

As indicated above, East Palo Alto’s Development Code recognizes a range of housing types as permitted in a variety of zoning districts. In addition to other forms of supportive housing, single room occupancy units (SROs) are also permitted uses in all residential zoning districts. This allows the City to provide for a variety of housing types for a wide range of residents.

The Housing Element includes programs (see Chapter 6, Goal 10) to update the City’s Development Code to comply with current state law regarding permanent supportive housing and emergency shelters.

3.1.4 Housing for People with Disabilities
Housing Element law requires jurisdictions to analyze potential governmental constraints to the development, improvement, and maintenance of housing for people with disabilities.

Residential Care Facilities
As shown in Table 3.1.C, residential care facilities for six or fewer persons are permitted by-right in all residential zones in East Palo Alto. For seven or more individuals, a conditional use permit is required.

Residential care facilities for seven or more individuals are subject to the requirements of the base residential zone where the facility is located, in addition to the following standards:

1. Applicable requirements of the California Building, Housing, and Fire Codes are met;

2. No sign which calls attention to the fact that the property is a residential care facility is posted;

3. Is not located within 500 feet of the boundaries of a parcel with a residential care facility (whether licensed or unlicensed), with six or fewer residents; and Chapter 3 - Page 7

4. Is not located within 750 feet of the boundaries of a parcel with another residential care facility with seven or more individuals.

The Housing Element includes a program (see Chapter 6, Goal 10) to update the City’s Development Code to comply with current state law regarding residential care facilities.

Definition of Family
The definition of family in the Development Code of the City of East Palo Alto is: One or more persons occupying a premises and living as a single nonprofit housekeeping unit as distinguished from persons occupying a club, fraternity, hotel, or sorority house. A family shall be deemed to include necessary servants.

This definition encompasses different living arrangements, including individuals with disabilities that may live with a caregiver or adults living in a group setting.

The Housing Element includes programs (see Chapter 6, Goal 10) to clarify in the City’s Development Code that the definition of a housekeeping unit can include unrelated individuals living together as a single household.

Reasonable Accommodations
Chapters 14.10 of the East Palo Alto Municipal Code and Chapter 18.98 of the East Palo Alto Development Code lays out the process for “Reasonable Accommodations” for individuals with disabilities, which are described as an adjustment to physical design standards to accommodate the placement of wheelchair ramps or other exterior modifications to a dwelling in response to the needs of a disabled resident. A request for Reasonable Accommodation may be made to the City to modify zoning or other land use regulations or policies that act as a barrier to accessing fair housing. Requests for Reasonable Accommodations are reviewed at the staff level. The City also have adopted an ADA Compliance Plan for public accessibility improvements.

Housing for Adults with Developmental Disabilities
With the increase in adults with developmental disabilities across San Mateo County and in East Palo Alto since the prior Housing Element, the lack of an existing licensed care facility in East Palo Alto for adults with developmental disabilities may pose a barrier to living independently in affordable housing or put individuals with developmental disabilities at risk of displacement. The Policies & Programs section attempts to address some of these barriers as part of Goal 7, Create more housing opportunities for special needs households, including large households, people at risk of or experiencing homelessness, and individuals with disabilities.

The lack of sufficient extremely low income and very low income units that are suitable for persons with disabilities presents a further challenge for individuals seeking independent living accommodations, which often requires units with affordable rents.

Chapter 3 - Page 8

3.1.5 Permit Types and Levels of Review
The “level of review” and total processing time required for different types of residential developments will vary based on the permit types associated with each development. Table 3.1.D summarizes the typical types of permits required for residential projects. Table 3.1.G presented later in this chapter describes average processing times for typical single-family and multi-family projects. Subdivisions and larger multi-family projects typically requiring a public hearing and Planning Commission action or recommendation. Single-family homes, duplexes, and quadplexes can typically be approved at an administrative or staff level. Review times can be longer for complex projects that require City Council approvals, such as projects requiring a legislative action (General Plan or zoning change), projects with a development agreement, projects that require a relocation plan, projects seeking alternative compliance with the City’s inclusionary housing ordinance, controversial projects that are appealed to the City Council, and if a project is revised several times during the development review period. Projects that require an EIR or Mitigated Negative Declaration also require additional processing time to comply with the California Environmental Quality Act. Alternatively, qualifying SB9, SB35, and SB330 projects can experience a more facilitated development review process as prescribed by state law. [Intentionally Left Blank]
Chapter 3 - Page 9
Table 3.1.5.A: Permit Types and Levels of Review
Permit Type Description Review Time (approx.)
Planning Administrative/Staff Level
Zoning Clearance Review to determine compliance with
Development Code and clear for Building
review
2-4 weeks
Administrative Use Permit Permit for an allowable use; review to ensure specific use is compatible with other existing
or surrounding uses
1-2 months
Temporary Use Permit Review to permit specific limited-term uses 45 days to 3 months Lot split/line adjustment/merger Creation of multiple lots or a single lot 2-4 months Reasonable accommodations Permit to make modifications to residential properties to accommodate people with
disabilities
Planning Public Hearing/Planning Commission Action
Design Review Review of projects for compliance with
provisions of Development Code and
architectural design guidelines
2-3 months
Tentative Map Review of map required when subdividing a parcel
3-4 months
Condominium Subdivision* Review of subdivision for creation of condominiums
3-4 months
Building Permit Review
Building Plan Review Review plans to determine compliance with Building Code.
30 days
Planning Review Resubmittal Re-check of building plans 2 weeks *Requires City Council approval
Chapter 3 - Page 10

3.1.6 General Plan Findings for Residential Projects
Review and approval of a residential project are based upon findings of consistency with the General Plan.

These findings are provided below.

For Subdivision Tentative Map (18.52.060 of the East Palo Alto Municipal Code):

A. The proposed map, subdivision design, and improvements are consistent with the General Plan, any applicable specific plan, and this Article.

B. The site is physically suitable for the type and proposed density of development.

C. The design of the subdivision and the proposed improvements are not likely to cause substantial environmental damage or substantially and avoidably injure fish or wildlife or their habitat.

D. The design of the subdivision or type of improvements is not likely to cause serious public health or safety problems.

E. The discharge of sewage from the proposed subdivision into the community sewer system will not result in violation of existing requirements specified by the California Regional Water Quality Control Board.

F. The design of the subdivision provides, to the extent feasible, passive, or natural heating and cooling opportunities.

G. The proposed subdivision, its design, density, and type of development and improvements conform to the regulations of the Development Code and the regulations of any public agency having jurisdiction by law.

For Site Plan and Design Review (18.86.050 of the East Palo Alto Municipal Code):

A. The proposed development is consistent with the General Plan and any application specific plan and is in compliance with all applicable provisions of the Development Code and all other City ordinances and regulations.

B. The proposed development is to be constructed on a suitable site, adequate in shape, size, topography, and other circumstances to accommodate the proposed development.

C. The proposed development complies with the applicable standards of review.

D. The proposed development is designed and arranged to provide adequate consideration to ensure the public health, safety, and general welfare, and to prevent adverse effects on neighboring property.

Chapter 3 - Page 11

3.1.7 Ministerial Processes and Compliance with Other State Mandates The City has adapted to changes in state law over the last eight years, incorporating state-mandated ministerial review into Planning review processes for eligible projects and creating forms for applicants to streamline review.

SB 35 Projects. East Palo Alto is subject to the SB 35 Streamlined Ministerial Review Process for projects with a minimum of 10% of units affordable to lower-income households. The Planning Division developed an application checklist and conformance letter for these projects to allow for the City to process the application within the time periods required by state law. As of the date of publication, the City has successfully processed two SB 35 applications, which will enable them to apply for building permits.

SB 9 Projects. The Planning Division developed an SB 9 checklist for developers to efficiently determine compliance with the new state law. As of the date of publication, the City has successfully completed reviews for four preliminary SB 9 applications, which will enable them to proceed to apply for building permits.

Accessory Dwelling Units. ADUs and JADUs are processed initially through a Zoning Clearance process to confirm development standards are met. Applicants fill out the Zoning Clearance form as part of their application and can be efficiently cleared for Building review and inspection if they meet all development standards.

Low-Barrier Navigation Centers (AB 101). Pursuant to state law, Low-Barrier Navigation Centers (or “LBNCs”) are a use by-right in areas zoned for mixed use and nonresidential zones permitting multifamily uses if it meets specified requirements. The single LBNC in East Palo Alto, located at 1836 Bay Rd., is an example of this type of use.

SB 330. The City is compliant with SB 330, also known as the Housing Crisis Act, by allowing for applicants to submit a “preliminary application” for a residential development; limiting the number of hearings associated with a single project, as provided by the law; processing applications within the timeframes provided by the law; only applying the standards permitted by the law; and adhering to the prohibition of demolition or housing and/or requiring replacement units (when applicable).

Housing Accountability Act. The City complies with the Housing Accountability Act (Government Code section 65589.5) in its review of each residential development, and City staff is well-versed in the limitations of local government to deny, reduce the density of, or make infeasible residential developments on any basis except for non-compliance with objective local development standards. The City has committed resources to refining its objective development and design standards to further streamline approval of residential developments and provide clarity to the City’s decision-making bodies, including the Planning Commission and City Council, in addition to the general public.

Chapter 3 - Page 12
State Density Bonus law. The City applies state Density Bonus law in reviewing projects that request additional density, concessions, or waivers pursuant to Government Code Sections 65915 – 65918. Applicants are required to submit a letter to the City with their Density Bonus request. Housing staff works closely with planning staff to implement the local ordinance that implements the state law. The City has processed several applications with a Density Bonus, including 100% affordable housing projects and projects with an inclusionary obligation, and executed multiple Density Bonus agreements.

3.1.8 Inclusionary Housing
On November 19, 2019, the East Palo Alto City Council adopted Ordinance No. 425, the Inclusionary Housing Ordinance (IHO), adding Chapter 18.37 to the City of East Palo Alto Development Code. All residential development projects that create new dwelling units are subject to the IHO. The Inclusionary Housing Plan for a residential development must be submitted concurrently to the Housing Division with the Planning application and is considered in the first round of application review.

For projects with fewer than 5 units, the inclusionary obligation is either payment of a proportional percentage of an in-lieu fee or providing one inclusionary unit on-site. Projects with 5 or more units are required to provide 20% of the total number of units on-site at affordability levels ranging from 35% of the Area Median Income (AMI) to 120% AMI, depending on whether the development is rental or for-sale. Developers may propose an alternative compliance option to the inclusionary requirement, which requires approval by the City Council. The table below provides a breakdown of inclusionary housing requirements and compliance options, available on the City’s Housing webpage. The IHO’s in-lieu fees are updated annually and incentivize developers to build the affordable housing units, rather than pay the fees.

Since the IHO’s effective date, several residential development projects with inclusionary units have been successfully entitled or cleared for Building permit review. Smaller development projects, such as those with two units or single-family dwellings with ADUs, have provided deed-restricted affordable ADUs as an alternative compliance option to the fee payment requirement.

The City Council adopted the Inclusionary Housing Ordinance in 2018 in response to community input requesting that residents in East Palo Alto who work in maintenance, food service, and administrative jobs, with a median income nearly half of the average median income of the County, also have an opportunity to live in East Palo Alto. The community was seeing exponential increases in housing costs due to the increase in tech industry jobs and the proximity of tech companies (primarily Meta, formerly known as Facebook, in Menlo Park and Amazon in East Palo Alto), and requested the City Council to pass a policy that would ensure new housing developments included housing units affordable to lower income households.

Chapter 3 - Page 13
Table 3.1.8.A City of East Palo Alto Inclusionary Housing Compliance Options Ownership/For-Sale Residential Developments

COMPLIANCE OPTIONS OBLIGATION REQUIREMENT
On-Site 20% 10% of units at Median Income
10% of units at Moderate Income
Off-Site 25% 13% of units at Median Income
requires City Council approval 12% of units at Moderate Income In-Lieu Fee 25% $190,000 per inclusionary unit (FY22-23) requires City Council approval
Rental Residential Developments

COMPLIANCE OPTIONS OBLIGATION REQUIREMENT
On-Site 20% 5% of units at 35% AMI
10% of units at 50% AMI
5% of units at 60% AMI
Off-Site 25% 7% of units at 35% AMI
requires City Council approval 12% of units at 50% AMI
6% of units at 60% AMI
In-Lieu Fee 25% $259,000 per inclusionary unit (FY22-23) requires City Council approval
Source: City of East Palo Alto Inclusionary Housing webpage, available at www.cityofepa.org/housing The table below is an inclusionary housing policy comparison across San Mateo County. As shown, East Palo Alto’s IHO fits within the typical 15-20% inclusionary requirement range for both for-sale and for rent housing developments.

The IHO has provided the City with tools that help meet the City’s regional housing needs allocation (RHNA) goal for constructing lower-income units, and affirmatively furthers fair housing by promoting integration of lower-income households with higher-income households. However, residential developers have identified the City’s IHO as a major constraint that impacts the financial feasibility of their projects due to the inclusionary housing level and the affordability levels. This may be further exacerbated by market conditions outside of the City’s control. As a result, the IHO allows developers to propose Alternative Compliance Options if developing units on-site is not feasible, and encouragers developers to build the affordable housing units rather than pay the in-lieu fees.

Chapter 3 - Page 14
Table 3.1.8.B Local Jurisdictions in San Mateo County with Affordable Housing Policies and Fees Source: Housing Leadership Council of San Mateo County, Building on Success: How San Mateo County can Meet the Need for Affordable Homes, Table 5, https://hlcsmc.org/data/.

Chapter 3 - Page 15

3.1.9 City Local Tax Measures
As discussed in Section 2.12, Potential Funding Sources to Preserve Affordable Housing, the City has committed to establishing an on-going local funding source for affordable housing production and preservation, fair housing programs, anti-displacement services, and workforce development programs through several voter-approved tax measures: Measures O, HH, and most recently Measure L. As opposed to impact fees that are one-time fees that are due at building permit issuance, the tax measures are annually taxes that are assessed and paid annually by property owners. Measures O and L are a business tax on rental property, while Measure HH is a parcel tax that applies only to large office development over 25,000 square feet. The Measures O and L business taxes affect the financial feasibility of projects so can be considered an impediment to residential development. However, these measures are also important tools for providing on-going financial resources to achieve many of the housing and fair housing programs in the City’s Housing Element.

3.1.10 Accessory Dwelling Units
The City adopted Ordinance No. 08-2020 on November 17, 2020, updating the City’s Development Code to reflect recent changes in state law. Applicants for ADUs and JADUs submit a Zoning Clearance application, available on the City’s Planning website, to confirm that all development standards are met. Once cleared by the Planning Division, the applicant may proceed to apply for a Building permit.

As a ministerial action, the Zoning Clearance process has significantly reduced processing times for ADUs and JADUs, with turnaround time on complete applications within a few days to a week. The majority of processing time is required for the Building permit phase, and can vary significantly depending on the project, the number and length of time between resubmittals, and the time required to obtain approvals from outside agencies such as Menlo Park Fire Protection District and East Palo Alto Sanitary District.

The number of ADU applications has also increased significantly since the start of 2020, with 30 Building permits issued in 2021 versus 13 in 2020.

3.1.11 Public Works and Engineering Review
The Public Works and Engineering Division reviews all residential development applications in the Design Review phase and following Planning entitlements. Engineering issues permits for on- and off-site improvements and grading, calculates City impact fees, and reviews tentative maps prior to Building Division review. This includes the subdivision improvement agreement, which lays out the public improvements, installation of utilities, grading, and drainage will be completed on the property.

Several City requirements for providing on- and off-site improvements apply to housing development, such as:

Chapter 3 - Page 16
• Green infrastructure
• On-site Low Impact Development (LID) improvements
• Street right-of-way dedications
• Street frontage improvement (e.g., curb, gutter, sidewalks and streetlights) • Water line improvement, including the water main installation along the property frontage and lateral service line with meter boxes and fire hydrants
• Sanitary sewer main installation along property frontage and lateral service lines; each parcel must be served by sanitary sewer or an individual sewage disposal system • Storm water drainage lines along property line street frontage • Street trees
• Regulated street widths for public urban residential roads, varying from 18 feet for a residential one-way loop to 40 feet for a residential collector
• Water, provided through a connection to a water supply system or through establishing a new water system; if neither is feasible, the Planning Director may allow the subdivider to provide water through an on-site well.

3.1.12 Building Division Review
The Building Division of the City of East Palo Alto enforces the Residential Building Code for the City of East Palo Alto, which is found in Chapter 15 of the East Palo Alto Municipal Code. This Chapter adopts the most recent California Residential Building Code (California Code of Regulations, Title 24) by reference. A Building permit is required prior to beginning any construction, reconstruction, addition, conversion, or alteration covered under the adopted California Codes.

The Building Division ensures that all new dwelling units meet all of the latest construction and safety standards. The division enforces building, plumbing, mechanical, electrical installations, accessibility, and energy compliance.

Chapter 3 - Page 17
REACH Codes
Since the adoption of the RHNA 5 Housing Element, the City has adopted stricter standards to reduce carbon emissions, known as the Building Electrification and Electric Vehicle Infrastructure REACH Codes Ordinance.

This Ordinance (07-2020), adopted in October 2020, amends East Palo Alto Municipal Code Chapter 15 to include REACH Codes that apply to California Energy Code and Green Building Code. The East Palo Alto Reach Codes were approved by the California Energy Commission on December 9th, 2020, and took effect on January 1st, 2021, on all new submissions for new construction. Learn about the REACH Code updates here.

The REACH Code requirements in effect as of 2022 are summarized in the table below. Note that effective 2023, the reach codes will be updated to reflect all-electric requirements and additional updates.

Chapter 3 - Page 18
Table 3.1.12.A: Summary of Reach Code Requirements (Prior to 2023) Building Type Building Electrification Solar EV Infrastructure Single Family Homes
and Townhouses
with Private Garages
All electric;
• Exception for Accessory
Dwelling Units (ADUs)
• Exception for 100% affordable
housing
N/A – Solar
already
required by
the
Residential
Code.
• One Level 2 (dryer plug/220 volt) + One Level 1
(110 volt)
• Single space garages to have one Level 2 charging.
• Exception for ADUs.
• Exception allowed if utility infrastructure
installation cost exceeds $400/dwelling for tax
credit-financed affordable housing.

Multi-Family All electric;
• Exception if demonstrated to be
infeasible.
• Exception for domestic water
heating projects granted
entitlements, with electrical prewiring.
• Exception for existing buildings
with physical constraints.
• Exception for 100% affordable
housing
15% of roof
area
Exceptions
for buildings
with limited
solar access
or vegetative
roofs.
• 10% of units with Level 2 charging: 90% of units
with Level 1 charging.
• Outlets may be shared between parking spaces.
• Local management software allowed.
• Exception allowed if utility infrastructure
installation cost exceeds.
• $4,500/dwelling for market rate, $400/dwelling for
tax credit financed affordable housing.
• Exception for projects granted entitlements.

Commercial All electric;
• Exception for restaurants,
cafeterias, with pre-wiring.
• Exception for emergency
operation centers, with prewiring.
• Exceptions for Life Science
buildings, with pre-wiring.
• Exception for existing buildings
with physical constraints.
15% of roof
area
Exceptions
for buildings
with limited
solar access
or vegetative
roof.

Office:
• 10 or more parking spaces – 10% of parking spaces with Level 2 charging;
• Additional 10% with Level 1 ready;
• Additional 30% EV capable.
• Exception for mechanical parking systems and locations without commercial power supply.

Other Nonresidential
Buildings (nonoffice)
Same as commercial Same as
commercial
• 10 or more parking spaces – 6% Level 2 Charging
Station
• Additional 5% Level 1 ready
Chapter 3 - Page 19

3.1.13 Total Processing Times for Residential Projects
The development review and permit process allow the City to ensure that residential development is accomplished in an orderly manner and complies with adopted building standards. This process can potentially act as a constraint to development if the associated time delays or costs place an undue burden on the developer.

As outlined above typical process varies depending on whether the process is administrative or discretionary; the main difference is the addition of a review and decision by the Planning Commission and/or City Council.

If an applicant is submitting an application for an ADU, an SB 35 project, an SB 9 project, or other statemandated ministerial review, the process is administrative. City staff reviews the application, works with the applicant to address comments, and approves the application if the comments are addressed.

East Palo Alto requires developers to obtain a series of approvals, or entitlements, before constructing any new development in the City, in order to ensure that new development is consistent with the City standards of design, health and safety. The entitlement process can be lengthy depending on the environmental analysis required for the project and requires payment of Planning Division permit and Engineering and Building Division plan check and permit fees.

Applicable submittal requirements for all application types are outlined in the Zoning Ordinance and in the Planning Department “Submittal Checklist” handouts. All applications, submittal requirements, and fee information are available on the City’s website, in each division’s page: Planning, Engineering, Building and Housing. The City’s practice is to request that the Planning Commission review all development applications as a whole (for example, an application for a rezoning is typically taken to the Commission along with a subdivision, design review and other entitlements). The Planning Commission typically meets twice each month, and projects subject to a CEQA categorical or statutory exemption typically do not delay the project further.

The table below shows average total processing times for “typical” residential projects:
[Intentionally Left Blank]
Chapter 3 - Page 20

3.1.13.A: Average Processing Times for “Typical” Residential Projects Type Assumed Actions Planning Approval Body Length of Time for Planning Approval
Building
Approval Body
Length of Time for
Building Approval
ADU/JADU Zoning Clearance and Building
review/inspection
Administrative (Ministerial) 1-2 months Administerial 30 days first review; 2 weeks resubmittals
Single Family
(1 unit)
Administrative Design Review,
Site Plan Review, Building
review/inspection
Administrative 3-6 months Administerial 30 days first review; 2 weeks resubmittals
Moderate-Sized
Multiple-Family
(2-4 units)
Tentative Map Review, Design
Review, CEQA – Categorical
Exemption, On/Offsite
Improvements, Building
review/inspection
Administrative or Planning
Commission
3-6 months for less complex
projects
6-12 months if Initial Study
required, consultant team, etc.

Administerial 30 days first review; 2
weeks resubmittals
Large MultipleFamily Tentative Map Review, Design
Review, CEQA – EIR, Zoning
Change, major grading,
On/Offsite Improvements,
Building review/inspection
Planning Commission (City
Council if Zoning or General
Plan Amendment proposed)
12-24 months Administerial 30 days first review; 2
weeks resubmittals
Note: For planning processing, assume 30 days for initial review, 30 days upon resubmittal for Planning and 30 days initial review and 2 weeks maximum upon resubmittal for Engineering or Building.

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 midsize to large projects not subject to ministerial review (SB 35 projects, ADUs/JADUs); single-family homes are reviewed administratively. 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,2 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 continue to seek ways to improve processing of applications. So far, the City has approved one multifamily housing project with a comprehensive tenant relocation plan, inclusionary housing obligation, and Chapter 3 - Page 21
General Plan and zoning changes that took more months than provided. 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.

3.1.14 Cumulative Impact of Development Standards on Development of Housing Taking into account the above development standards and required review processes for different types of residential projects, there is clearly a relationship between the project’s requirements and the length of processing time. More complex projects require multiple levels of review—some relating to the City’s Development Code, and others relating to outside agencies, the need for environmental review, or the completeness of a development application – and so require additional time for approval.

The City has committed to updating the Development Code to further clarify and streamline residential development review, including through the adoption of objective development and design standards. These can be found in the Policies & Programs section under Goal 1 – Create more housing opportunities, and more housing that is affordable to East Palo Alto residents, and they are intended to remove barriers to housing development that are within the City’s control while balancing the need for robust community input and adhering to the goals of the General Plan.

During the period of high development activity from 2019 to the present, smaller projects have also seen lengthier processing times than usual due to limitations on staffing and other resources. However, staff experience with processing of ADUs and other ministerial review processes continues to lead to improvements in this area. The Policies & Programs section addresses further activities that City staff commit to completing over the coming eight-year period, under Goal 1 – Create more housing opportunities, and more housing that is affordable to East Palo Alto residents. The City also added a goal to increase staffing capacity to help shorten processing times.

3.1.15 Permitting Fees and Impact Fees
The City charges processing fees for each type of development permit and fees to mitigate the impacts of development on the City’s infrastructure. These fees are posted on the City’s website in compliance with the requirements of Gov. Code 65940.1 sudv. (a)(1)(A)). High planning and site development fees can impact property owners’ ability to make improvements or repairs. However, line item fees related to processing, inspections and installation services are limited by California law to the cost to the agencies performing these services. City zoning, through State Density Bonus Law and the Affordable Housing Overlay zoning, provide various incentives for affordable housing as a way to reduce project costs and address actual and potential constraints that fees and exactions may impose.

Chapter 3 - Page 22
The fees for the City of East Palo Alto are summarized below in Tables 3.1.15.A and 3.1.15.B for three typical developments: (1) a 2,000 square-foot single-family unit on a .11 acre lot; (2) a 15,000 square-foot, 10-unit forrent multi-family on an 0.7 acre lot; (3) an 80,000 square-foot, 100-unit for-rent multi-family project (with 800 square feet per unit) on a 2.5 acre lot; and (4) a 750 square foot detached accessory dwelling unit.

Tables 3.1.15.A and 3.1.15.B Hypothetical Residential Projects for Calculating City Permit and Development Impact Fees
Project Number of
Units
Average
Dwelling Size
(sq. ft.)
Total
Livable Sq
Ft
Assumed Density
(units/acre)
Site Size
(acres)
Value
Single-family
Home
1 2,000 2,000 n/a 0.11
(5,000 sq.
ft.)
$900,000 or
greater*
Townhouse
Project
10 1,500 15,000 14 0.7 $5M ($500K
per unit)
Multi-family
Project
100 800 80,000 40 2.5
ADU Unit 1 750 750 n/a n/a $195,000
*Valuation for Building may differ based on International Building Code costs used.

Table 3.1.15.A City Permit and Development Impact Fees by Project Type Fee Single-Family 10-Unit MultiFamily100-Unit
Multi-Family
Accessory
Dwelling Unit
(Detached 750 sq
ft+ = charge)
Agency Paid
To
Comments
Planning
Design Review 4313 13862 13862 n/a City of East
Palo Alto
n/a
Environmental Review n/a 7701 24643 n/a City of East
Palo Alto
n/a
Zoning Clearance
(Administrative Review)
n/a n/a n/a 618 City of East
Palo Alto
n/a
Zone Change (if needed) n/a 20023 20023 n/a City of East Palo Alto
n/a
Chapter 3 - Page 23
General Plan Amendment (if
needed)
n/a 20023 20023 n/a City of East
Palo Alto
n/a
Tentative Map (4 lots or less) (if
proposed)
n/a n/a n/a n/a City of East
Palo Alto
n/a
Tentative map (5-25 lots) (if
proposed)
n/a 21563 n/a n/a City of East
Palo Alto
n/a
Tentative map (>25 lots) (if
proposed)
n/a n/a 41893 n/a City of East
Palo Alto
n/a
Building
Building Permit Processing Fee $303 $303 $303 $303 City of East Palo Alto
Flat fee of $303
Building Plan Check Fee $1,818 $22,974.69 $46723.25 $1,251.39 City of East Palo Alto
Valuation determined
using International
Building Code.
$150.87/sq ft for one and
two-family residential
(ADU included)
$139.06/sq ft for multiple
family
Building Permit/Inspection $2722 $35,546.19 $99,276.45 $1,499.02 City of East Palo Alto
Valuation determined
using International
Building Code.
$150.87/sq ft for one and
two-family residential
(ADU included)
$139.06/sq ft for multiple
family
Building State Fees – State CA
Green Building Fee
$13 $142 $445 $6 California
Building
Standards
Commission
$1 for permits with
valuations up to $25,000.

Additional $1 for each
additional $25,000.

Building State Fees – State
Strong Motion Fee
$39 $980.70 $1,446.224 $14.63 California
Department of
Conservation
Valuation amount in

0.00013=fee amount;
minimum fee of $0.50 for
any valuation up to
$3,850
Engineering/Public Works
Chapter 3 - Page 24
Grading Plan Review $2,678
Assuming < 50
Cubic Yards
$5,357
Assuming
101 -
500 Cubic
Yards
$16,070
Assuming
>501 Cubic
Yards
Typically, no
grading permit
needed
City of East
Palo Alto
The grading plan review
charge is dependent on
the cubic yards (cut +fill)
total, so these numbers
are estimates
Grading Inspection $2,678
Assuming < 50
Cubic Yards
$16,070
Assuming
101 -
500 Cubic
Yards
$21,377
Assuming
>500 Cubic
Yards
Typically, no
grading permit
needed
City of East
Palo Alto
The grading plan review
charge is dependent on
the cubic yards (cut +fill)
total, so these numbers
are estimates
Impact Fees
Impact Fees - Parks & Trails $4,715 $3,248 x 10 $3,248 x 100 $1,886 City of East Palo Alto
Impact Fees - Public Facilities $8,268 $5,696 x 10 $5,696 x 100 $3,307 City of East Palo Alto
Impact Fees - Storm Drainage
(Inside RBD)
$5,521 $96,620 $345,070 $2,208 City of East
Palo Alto
Impact Fees - Storm
Drainage (Outside RBD)
$3,194 $79,851
Per Impervious
acre
$79,851
Per Impervious
acre
$1,278 City of East
Palo Alto
Impact Fees - Transportation $2,690 $2,025 x 10 $2,025 x 100 $1,076 City of East Palo Alto
Impact Fees - Water Capacity $9,293 $5,720 x 10 $5,720 x 100 $5,720 City of East Palo Alto
Other
Sewer East Palo Alto:
$6,060
(connection fee) +
$1,400 (plan check
fee, sewer service
charge, permit
application fee)
East Palo Alto:
$6,060
(connection
fee) +
$1,400 (plan
check fee,
sewer service
charge,
East Palo Alto:
$6,060
(connection
fee) +
$1,400 (plan
check fee,
sewer service
charge,
Connection fees
are charged
proportionate to
the burden of the
ADU compared to
the primary
dwelling.

East Palo Alto
Sanitary
District
Cost varies
depending on
Sanitary District.

Cost varies
depending on
Sanitary District.

Charges for Fair
Chapter 3 - Page 25
Comparison:

West Bay Sanitary
District: $8,501
(connection fee)
Fair Oaks: $6,153
(connection fee) +
$380 (development
fee)
permit
application fee)
Comparison:

West Bay
Sanitary
District: $8,501
(connection
fee)
Fair Oaks:
$24,612
(connection
fee) +
$380
(development
permit
application fee)
Comparison:

West Bay
Sanitary
District: $8,501
(connection
fee)
Fair Oaks:
$24,612
(connection
fee) +
$380
(development
East Palo Alto Oaks assumes 1” for
single family and 2”
for multifamily.

School Ravenswood
School District
$4.08 per sq ft (effective
July 2022) - same across
Belmont, Las Lomitas,
Menlo Park, Portola
Valley, Ravenswood,
Redwood City, San
Carlos, and Woodside
Fire $427 $427 $427 $427 Menlo Fire
Protection
District
Includes site review and
assumes one resubmittal
Chapter 3 - Page 26
Table 3.1.15.B summarizes the types of fees that are typically required for common residential development types:

Table 3.1.15.B: Fees by Residential Development Types (FY 2022-2023) Single Family Home Residential
Planning – Entitlements
(~$4,313)
Building – Construction
** (~$4,895)
Impact Fees
(~$33,681)
Other Agency Fees
• Administrative Design
Review
• Engineering Design Review
support
• Building Design Review
support *
• Processing
• Plan Check
• Building Inspection
• Engineering Offsite Improvements
• Engineering Review of Building Permit
• Address Assignment (per unit)
See table below • Menlo Park Fire Protection District ($427) • Sequoia Union High School District ($4.08
per sq ft)
• East Palo Alto Sanitary District (~$7,460)
10-Unit Multifamily Development
Planning – Entitlements
(~$13,862)
Building – Construction
(~$59,947)
Impact Fees
(~$525,621)
Other Agency Fees
• Planning Application Fees
• Engineering Review
• Building Design Review*
• CEQA
• Engineering Grading Permit
• Engineering Review of Building Permit
Multi-Family
• Building Processing Fee
• Building Plan Check
• Building Inspection
• Final Map
See table below • Menlo Park Fire Protection District ($427) • Sequoia Union High School
District ($4.08 per sq ft)
• East Palo Alto Sanitary District (~$7,460)
100-Unit Multifamily Development
Planning – Entitlements
(~$13,862)15
Building – Construction
(~$148,194)
Impact Fees
(~ $2,093,821)
Other Agency Fees
• Planning Application Fees
• Engineering Design
Review
• Building Design Review*
• CEQA
• Engineering Grading Permit
• Engineering Review of Building Permit
Multi-Family
• Building Processing Fee
• Building Plan Check
• Building Inspection
• Final Map
See table below • Menlo Park Fire Protection District ($427) • Sequoia Union High School
District ($4.08 per sq ft)
• East Palo Alto Sanitary District (~$7,460)
Notes:* A Planning permit (Building Design Review) is not required when SB 9 or SB 35 is applied. ** Based on typical square footage.
15 Fee is assuming there is no Zoning or General Plan update.

Chapter 3 - Page 27
Permitting Fees
Planning and application fees offset the costs the City incurs in the development review process. All current planning and permit fees as adopted by City Council are included in the Master Fee Schedule, available at:
https://www.cityofepa.org/finance/page/comprehensive-fee-schedule and in the tables below.

Outside Agency Fees
Development review and impact fees are collected by agencies separate from the City and must be paid prior to issuance of a Building permit. These include school district fees, fire district fees, and sanitary district fees.

Sequoia Union High School District, Menlo Park Fire Protection District, and East Palo Alto Sanitary District are responsible for these fees and applicants are required to contact each agency for a fee estimate for their project.

Sanitary District Fees
The East Palo Alto Sanitary District (EPASD) is in the process of updating its fees, so current fees vary greatly by project. According to the 2019 EPASD Fee Schedule, connection fees are $6,060.16 There is an additional cost of $1,400 for the plan check fee, sewer service charge, and permit application fee. Neighboring West Bay Sanitary District charges a connection fee of $8,501,17 and Fair Oaks Sewer Maintenance District charges a connection fee of $6153 and an additional development fee of $380.18 Based on these fees, EPASD’s 2019 fees are comparable to other sewer districts’ fees.

Development Impact Fees
The City collects development impact fees to fund capital infrastructure project or public facilities costs attributable to development impacts. Development impact fees are typically due at the time of building permit issuance. The legal requirements for enactment of an impact fee program are set forth in Government Code Sections §66000 – 66025 (the “Mitigation Fee Act”), also commonly referred to as AB 1600.

In July 2020, the City Council adopted Resolution No. 108-2020, the first major revision of the City’s Comprehensive Fee Schedule, effective September 20, 2020. Development impact fees are studied and adopted separately from user and regulatory fees and are generally amended annually by the change in the Construction Cost Index, or CCI, published by Engineering News Record. Since 2020, the City’s development impact fees have risen annually by this amount. Most recently, in FY 2022-23, development impact fees increased by 8.9%, 16 https://www.epasd.com/home/showpublisheddocument/3232/636930162743300000 17 https://westbaysanitary.org/wp-content/uploads/2021/07/CODE-OF-GENERAL-REGULATIONS-revised-07-01-2021.pdf#page=49 18 https://www.fowd.com/rates-fees
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in accordance with CCI. The authorizing Municipal Code section and resolution adopting each fee is summarized in the table below:

Table 3.1.15.C: Authorizing Municipal Code and Resolutions by Fee Type Fee Type Authorizing
Municipal Code
Authorizing Fee Setting
and Annual Increase
Parks & Trails

13.28.040 Reso – 5093 &
MC – 13 .28.100
Public Facilities
Storm Drainage:

Inside Ravenswood Business District
Outside Ravenswood Business District
Transportation
Water Capacity 13.24.100 Reso – 5004
Affordable Housing Commercial Linkage 18.40.010 Reso – 118-2020 Projects Subject to Impact Fees
The table below shows the types of development projects that are subject to each of the development impact fees, and the amount in FY 2022-23: It should be noted that state law exempts development impact fees for Accessory Dwelling Units (ADUs) less than 750 square feet in size and the City does not impose impact fees on attached ADUs, so the ADU fees listed below only apply to detached ADUs exceeding 750 square feet.

Additionally, ADUs fees are set based on a proportion of the fees charged for new single-family dwellings.

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Table 3.1.15.D: Development Impact Fees
Fee Type How It Is Charged Development Type Amount
Commercial Linkage Per Square Feet (sq ft) Office/Medical/R&D above 10,000 sq ft $12.81 Parks & Trails Per dwelling unit Detached ADU
Single Family
Multifamily
$1,885.61
$4,714.61
$3,247.64
Public Facilities Per dwelling unit Detached ADU
Single Family
Multifamily
$3,306.96
$8,267.96
$5,695.63
Storm Drainage Per dwelling unit – single
family and ADU
Detached ADU in RBD*
Single Family in RBD
$2,208.45
$5,521.10
Detached ADU outside RBD
Single Family outside RBD
$1,277.61
$3,194.03
Per impervious acre – all
other land uses
In RBD $138,027.50
Outside RBD $79,850.62
Transportation Per dwelling unit Detached ADU
Single Family
Multifamily
$1,075.70
$2,689.83
$2,024.79
Water Capacity Per dwelling unit Detached ADU
Single Family
Multifamily
$5,719.58
$9,293.47
$5,719,58
*Ravenswood Business District/4 Corners Specific Plan Area The current Development Impact Fees can be found in the City’s Master/Comprehensive Fee Schedule, which is published online on the City website: https://www.cityofepa.org/finance/page/comprehensive-fee-schedule Fee Comparisons across Jurisdictions in San Mateo County The table below shows a comparison of East Palo Alto’s responses with the other jurisdictions in San Mateo County to a survey conducted by 21 Elements in preparation for the Housing Element. The responses were provided for single family homes, a prototypical 10-unit multiple-family building, and a prototypical 100-unit multiple-family building.

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Table 3.1.15.E: Fee Comparison Across Jurisdictions in San Mateo County Jurisdiction Single Family Small Multiple-Unit Large Multiple-Unit Atherton $15,941  No Data  No Data
Brisbane $24,940  $11,678  No Data
Half Moon Bay $52,569  $16,974  No Data
Hillsborough $71,092  No Data  No Data
Pacifica $33,725  $40,151  No Data
Portola Valley $52,923  No Data  No Data
Woodside $70,957  $82,764  No Data
Redwood City $20,795  $18,537  $62,696
Millbrae $97,756  $6,824  $55,186
San Mateo $99,003  $133,658  $44,907
San Bruno $58,209  $72,148  $39,412
South San Francisco $81,366  $76,156  $32,471
Burlingame $69,425  $30,345  $23,229
East Palo Alto  $80,866 $30,812 $19,181
Colma $6,760  $167,210  $16,795
Daly City $24,202  $32,558  $12,271
Foster City $67,886  $47,179  $11,288
Unincorporated San
Mateo County
$36,429  $27,978  $10,012
Source: 21 Elements Fee survey; East Palo Alto. (Note that this survey was conducted in 2021 and contains fees from FY 2021-22).

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 placed these costs into the context of total development costs for multiple-family housing in the area, based on a report by Century Urban.3 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.

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3.2 INFRASTRUCTURE CONSTRAINTS

3.2.1 On and Off Site Improvements
As part of any development project, the City will evaluate and determine the appropriate on and off-site improvements. The type and extent of the improvements often relate to the type, size, complexity, and location of the project. Although each project is reviewed on a case-by-case basis, the City has procedures for determining when frontage improvements are required, which can help make the process more predictable.

Whenever a discretionary approval is required for a project, the City can require frontage improvements where none already exist. For new residential projects, if no frontage improvements exist, then new frontage improvements are required and they must meet City standards. The frontage improvements should generally match those of adjoining or nearby properties for aesthetic consistency and ease of use and shall include a curb, gutter, sidewalk, street trees, and street lights. A typical vertical curb, gutter and sidewalk would consist of an 18-inch gutter, 6-inch curb, and a minimum 5- foot sidewalk. In some instances, a planter strip or wider sidewalk may be required, depending on the location.

In cases where there are already existing frontage improvements, the owner is typically responsible to remove and replace damaged frontage improvements. Generally, off-site improvements occur within existing right-ofway and no additional land dedication or public easements are needed. Therefore, there should be no impacts to development setbacks, density or floor area ratio, which are important factors for making a development work.

New residential developments must also comply with the City’s Water Efficient Landscape Ordinance (Chapter

17.06) , which provides standards and guidelines for ensuring landscape designs are water efficient and prioritize water conservation.

All of these requirements add to the cost of construction. Financial incentives (such as fee waivers/credits) for affordable housing would help reduce costs and allow affordable housing development to be more feasible.

3.2.2 Water Infrastructure Availability
In addition to requiring jurisdictions to analyze each site for water and infrastructure availability, 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, a previous impediment to the production of residential units was a lack of water supply, ultimately leading to a 2016 moratorium on all new development due to the water emergency. In July 2017, the Chapter 3 - Page 32
City entered into an agreement with the City of Mountain View for $5 million to receive an allocation of 1 million gallons of water per day from San Francisco Public Utility Commission (SFPUC), and in 2018, the City received an allocation of 0.5 million gallons per day from Palo Alto, allowing the City to resume development.

With these added water allocations, the moratorium was lifted in 2018. The City will be able to meet the water demand that is necessary to accommodate planned growth to 2035 in accordance with the City’s General Plan.

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, similar to other jurisdictions statewide.

However, the City has taken major steps to address these shortfalls over the last five years.

The City worked with EKI Environment & Water to draft an updated Water System Master Plan (“WSMP”), which is available online. The WSMP identifies cost-effective 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.

On October 4, 2022, the City approved the 2022 Water System Master Plan (WSMP) and appropriated nearly $8.4 million to design and build several key City water infrastructure projects over the next two years. The WSMP is intended to provide the City with an overall plan for potable water infrastructure improvements for the next twenty (20) years to maintain water system reliability and support anticipated development within the City. The WSMP assesses the current operations and functionality of the City’s existing water system, identifies deficiencies, and prioritizes recommendations for future water system improvements to address both current operational issues and plan for future residential, commercial and industrial growth with the City’s water service territory.

Final designs for the water infrastructure projects are underway, with construction to begin in Summer 2023 and be completed by the end of the year. In the meantime, high-density housing proposals currently have the infrastructure constraint of needing to provide the water infrastructure and water pressure to meet fire flow requirements. For example, the Euclid Improvements Project agreement approved by City Council in November 2022 required that the developer provide a 1.5-million-gallon water tank and pump station (and the land it is on), to improve the overall water conveyance, supply and pressure in the neighborhood. A portion of the new infrastructure would be credited against the water capacity fees and public facilities fees to the developer, and the cost incurred by the developer in excess would be considered a community benefit, provided, the cost of the water tank and pump station, as well as related land, exceeds the required water capacity fees and the public facilities fees by at least $2,000,0000.

The City also has initiated and completed several key capital improvement projects aimed at improving water storage and distribution citywide:

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• 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- Adopted by resolution • Weeks Street Water Line Improvements – Funds have been allocated for the design and construction of the Weeks Street Improvements which will help serve 965 Weeks Street’) and the surrounding neighborhood.
• Woodland Avenue Gap Closure and Palo Alto Emergency Intertie – Design 100% complete and being reviewed by the City of Palo Alto for connection to their system for emergency flow.

The City of East Palo Alto is required by the California Urban Water Management Planning Act to prepare and adopt an Urban Water Management Plan (UWMP) and an associated Water Shortage Contingency Plan (WSCP) every five years. The purpose of the UWMP is for long term water resource planning; it ensures that sufficient water supplies meet existing and future water needs. Through the UWMP, the City identifies all water needs for long-range planning. The WSMP then provides a plan to fill any water infrastructure gaps that are needed to support RHNA sites. The last UWMP was the 2020 UWMP, adopted Summer 2021, based on the General Plan Vista 2035. The next UWMP will be adopted Summer 2026.

With the aforementioned and future 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 residents. As identified in the UWMP, the City has adequate water supply.

3.2.3 Water Improvements for Pipeline Affordable Housing Projects The Weeks Street Line Improvements and University Avenue and Cooley Avenue 12-inch Water Transmission Main are necessary to carry forward the City’s 95-unit affordable housing project known as Colibri Commons (formerly known as 965 Weeks). The East Palo Alto City Council approved water infrastructure upgrades, Chapter 3 - Page 34
which includes upsizing the 8” water main on Weeks Street between Cooley Avenue and Pulgas Avenue with a new 12” PVC main, as well as completing the design for the University Avenue 12” water Transmission Main Project. The City is funding a portion of the $7.6 million allocated for the design and construction of both these projects would provide the improved water flow needed to serve the future development of Colibri Commons.

Colibri Commons affordable housing development is scheduled to break ground in late 2023.

3.2.4 Sewer Infrastructure Availability
Many development projects have experienced delays due to the lack of a sanitary sewer connection from the East Palo Alto Sanitary District (“EPASD”). EPASD is a special district, and operates independently from the City. Special districts are local public/government agencies established by residents of a community to provide a service not provided by the county or city. Sufficient sewer treatment capacity is available to meet the planned growth for the City to 2035 as described in the City’s General Plan. However, upgrades to the sanitary sewer infrastructure system are necessary to accommodate new development. If sanitary 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”).

A Municipal Service Review (“MSR”) and sphere of influence update was adopted by SMCLAFCo on June 15, 2022. Additionally, subsequent actions by EPASD were discussed and addressed by City Council on June 21, 2022. A City Council study session to discuss next steps based on the SMCLAFCo recommendations was held on July 26, 2022. On October 18, 2022, the City Council adopted a resolution authorizing the submission of an application to the SMLAFCo requesting proceedings to establish the East Palo Alto Sanitary District (EPASD) as a subsidiary district of the City and expending up to $15,000 from the City’s General Fund Reserve for processing fees. On November 10, 2022, staff submitted the application to SMLAFCo.

On December 9, 2022, SMLAFCo forwarded a letter to the City requesting additional information/clarifications from the City’s application. The City has provided SMLAFCo with most of the requested information to date.

The City expects SMLAFCo to request further information in the future as this process moves on. City Council will be considering an RFQ for potential Sanitation services at the next scheduled meeting on February 7, 2023.

These steps have been incorporated into the Policies & Programs section of this Housing Element.

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3.2.5 Dry Utilities Availability Development allowed under the Housing Element Update, in combination with cumulative development within the PG&E’s service area would increase demand for electricity and natural gas.

However, development projects would be required to comply with applicable state and local regulations pertaining to energy conservation. PG&E routinely updates its long-range plans to incorporate potential growth in its service areas. Therefore, the electrical and natural gas infrastructure would be sufficient to serve cumulative development, including development allowed under the Housing Element Update.

Electricity and natural gas systems would have capacity and/or be adequate to serve cumulative development, including development allowed under the Housing Element Update. Therefore, the Housing Element Update, in combination with past, present, existing, approved, pending, and reasonably foreseeable future projects in the vicinity, would not contribute considerably to cumulative impacts on electricity and natural gas systems, and this cumulative impact would be less than significant.

The geographic context with respect to telecommunication service is the service areas for the telecommunication providers that serve the city. Development allowed under the Housing Element Update, in combination with cumulative development within the service areas for the telecommunication providers that serve the city would increase demand for telecommunication service. However, similar to the development provided for under the Housing Element Update, cumulative development of underground conduits and overhead cables to facilitate telecommunications services would be required to comply with applicable federal, state, and local standards pertaining to underground and overhead utility infrastructure.

3.2.6 Coordination with Water and Sewer Service Providers Water and sewer service providers must establish specific procedures to grant priority service allocations for water and sewer service to developments with units affordable to lower-income households. (Gov. Code, § 65589.7.). The City will deliver a copy of the housing element to water and sewer service providers describing the City’s housing needs and regional housing needs, to ensure continued coordination with service providers.

3.2.7 Public Transit
(refer to East Palo Alto 2035 General Plan, Chapter 6, Transportation) Transit lines are available to serve all neighborhoods in East Palo Alto. Most commute hour bus lines operate on 15- minute headways, thus requiring short waits between buses. However, there is a lack of efficient transit connections from East Palo Alto to regional transit corridors such as Caltrain and El Camino Real, and job and activity centers in neighboring municipalities. The barriers created by U.S. Highway 101 further constrains connectivity. However, pedestrian/bicycle bridge over Highway 101was recently completed in 2022 that provides access from the western neighborhoods of East Palo Alto to the rest of the City.

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The East Palo Alto 2023 General Plan includes the following goal and policies to enhance transit and address the diverse needs of the community:

Goal T-5. Support local and regional transit that is efficient, frequent, convenient, and safe.

Intent: To support planning and coordination of transit services to accommodate diverse community needs for safe, comfortable, and efficient local and regional transit.
• 5.1 Dumbarton rail service. Support ongoing regional efforts to reintroduce passenger rail service along the Dumbarton corridor and support multimodal access improvements to future rail station(s). • 5.2 Coordination with transit agencies. Coordinate with transportation service providers to improve transit service and access in the City, focusing particularly on areas with high concentrations of zero vehicle households, areas that currently lack public transit options, and on the improvement of transfers and connections between systems.
• 5.3 Transit priority. Ensure transit vehicles retain priority over other vehicles along transit network streets (as shown in Figure 6-3), prioritizing transit speed and schedule reliability. • 5.4 Access to transit. Provide connecting bicycle and pedestrian infrastructure and amenities to improve access to transit stations and stops, and encourage new development projects near transit to improve transit stop amenities.
• 5.5 Transit stops. Support the installation of transit stop amenities, including shelters, benches, real-time information panels, lighting, bike parking, bike sharing stations, etc. • 5.6 Local transportation services. Create or partner with transit providers, employers, educational institutions, major commercial entities and event organizers to improve local transportation services, including developing discount transit pass programs for groups such as students. • 5.7 Connection to Dumbarton corridor. Should Facebook be successful in lobbying for a fixed railway or Bus Rapid Transit (BRT) connection to their campus, request a pedestrian connection to a Willow Road station that transects the office park behind the Kavanaugh neighborhood. • 5.8 Senior transit. Support the expansion of affordable and reliable transportation options such as discounted transit passes for older adults and persons with disabilities, focusing on neighborhoods with high concentrations of elderly residents.
• 5.9 Cut-through traffic. Encourage and support efforts to improve regional transportation given that the majority of traffic congestion in the City is generated by regional circulation.

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3.3 NON-GOVERNMENTAL CONSTRAINTS
Land costs, construction costs, and market financing contribute to the cost of housing reinvestment andcan sometimes hinder the production of new affordable housing. Although many constraints are driven by market conditions, jurisdictions have some leverage in instituting policies and programs to address potential constraints.

3.3.1 Land Costs
21 Elements engaged Century Urban4to provide an analysis of residential development costs in San Mateo County that may be used in this analysis. The report includes an analysis of three years of San Mateo County residential sales data for single family and multifamily developments, with the San Mateo County-wide average land costs of approximately $1,000,000 for prototypical single-family developments, $1,000,000 for small multifamily developments, and $10,000,00 for large multifamily developments.

According to the report, in East Palo Alto, the land cost for single family homes ranges from $72 to $135 per square foot, with a median of $92. There were no data available specific to East Palo Alto for multifamily development.

While East Palo Alto land costs may be slightly lower than in surrounding jurisdictions, dramatic increases in East Palo Alto home prices since the last Housing Element cycle demonstrate the amount of development interest in the City and the upward pressure on prices from highly constrained housing development in the region.

3.3.2 Site Development Costs
The Century Urban report finds that the San Mateo County-wide total development costs range from $2,500,00 to $4,400,000 for a prototypical single family home development and range from $7,900,000 for a small multifamily development to $74,100,000 for a large multifamily development.

The high cost of development can be attributed both to the “hard costs” of development, including construction materials and labor, and to the “soft costs” of development, such as architecture, design, and engineering costs, in addition to permitting and other fees.

Hard costs constitute the much larger share of total development costs –approximately 60%, according to a 2020 analysis by the Terner Center.5 The same report found that Bay Area construction costs are the highest in the state. Labor and materials cost increases are also reflected in the Construction Cost Index; the March 2022 Construction Cost Index for the San Francisco area, as published by Engineering News Record, showed an increase of 8.9%, compared to 3.1% in 2021 and 1.6% in 2020.

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Construction costs are not within the control of local jurisdictions. However, jurisdictions must consider that additional costs placed on a development from both fees and delays to a project can make the difference between a feasible and infeasible project.

High development costs translate into higher rents and sales prices, a trend that is visible in recent data on East Palo Alto housing costs. This places rental and purchasing opportunities in East Palo Alto out of reach for many residents and contributes to an already high risk of housing insecurity, overcrowding, and displacement.

3.3.3 Financing Availability
The current median home price of approximately $941,30019 is about 2-3 times the approximately $378,000 price that would be affordable to a buyer with a median household income of $83,511.20 In addition to high housing prices in East Palo Alto and the surrounding County, many potential homebuyers are constrained by the lack of financing to purchase a house. Credit history, down payment, and closing costs are three major factors in a household’s ability to obtain a mortgage in East Palo Alto.

Interest rates remained low at the start of 2022 but increased substantially by the end of the year due to inflation.

According to the Freddie Mac Mortgage Market Survey, the interest rate for a fixed-rate, 30-year mortgage increased from 3.22 percent the week of January 6, 2022 to 6.48 percent the week of January 5, 2023. This constrains the ability of developers to finance both market-rate and affordable housing, and the ability of potential homebuyers to purchase a home.

As we look outside the typical borrower, it is important to also note that 43.1 percent of the population in East Palo Alto is foreign-born, and that lack of legal status can restrict the ability of migrants to obtain mortgages, build credit, and achieve financial security. While significant resources exist to help achieve homeownership, regulatory guidelines are increased for those without legal status. The burden of risk assessment is often displayed by requiring higher down payments, extensive work history, and vast documented income. It should also be noted that those without legal status often do not qualify for federal government assistance and can be barred from financial resources.21

3.3.4 Requests for Housing Developments at Reduced Densities Jurisdictions are required to report on any projects where a lower density was requested for a site as provided in the Sites Inventory. A review of the RHNA 6 2023-2031 Housing Element and current pipeline (i.e., entitled projects, SB 35 projects in process, or projects under construction) shows that this small number of sites from 19 Medium home price, income, foreign born: https://www.census.gov/quickfacts/eastpaloaltocitycalifornia 21 Information regarding the legal status of East Palo Alto residents and mortgage information comes from the local non-profit, EPACANDO.

Chapter 3 - Page 39
the Sites Inventory were proposed at densities at or above those assumed for the site. Generally speaking, residential development proposals that the City has received in recent years have requested close to the maximum or more through the Density Bonus.

3.3.5 Typical Timeframes between Approval for Housing Development and Application for Building Permits
Given the delays imposed by the City’s water moratorium from 2016-2018 and the continued delays related to the East Palo Alto Sanitary District and remaining lack of water flow to some areas of the City–discussed in detail elsewhere in this Constraints Analysis–it is challenging to estimate a “typical” timeframe between approval and application for Building permits. The majority of the City’s pipeline projects have only recently received entitlements, Zoning Clearance, or other streamlined clearance.

However, the City has seen a pattern among a small number of projects where the developer has not moved to apply for a Building permit despite being able to do so. This may be for a variety of reasons; chief among them may be the COVID-19 pandemic. For this reason, the City adopted a blanket extension through December 31, 2022, on Planning and Building permits set to expire between March 17, 2020, and December 31, 2021.

In some cases, the developer may attempt to sell the property with entitlements to a buyer who is interested in developing the project. A small number of developers may choose to change course after receiving project approvals if it becomes clear that there remains some project uncertainty, such as unresolved issues with the East Palo Alto Sanitary District. This constraint is discussed elsewhere in this analysis and is addressed in the Policies & Programs section.

3.3.6 Environmental Constraints
East Palo Alto’s bay side location creates a number of environmental constraints. These constraints limit development potential, often limiting densities. East Palo Alto’s policies prioritizes development away from the environmentally sensitive bay and protection of these natural resources. The City’s environmental constraints range from the need to protect environmentally sensitive habitat, risks of natural disaster and flooding. The City’s General Plan policies, development regulations, building code and other policies and regulations provide guidance to help avoid impacts and to maximize safety for residents. This section provides a general overview. Greater details of environmental constraints can be found in the General Plan, the multijurisdictional Local Hazard Mitigation Plan, State and Federal plans/maps.

Flood Risk
Flood risk places a physical constraint on the availability of land for new housing. The City’s lower elevation and proximity to the bay creates a higher risk of flooding to areas of the City. Removing flood risk requires Chapter 3 - Page 40
raising buildings at least 18 inches above the base flood elevation established by FEMA floodplain maps. In some areas this can require the building to be raised at least 4 feet from the existing ground. This is a costly portion of many of the large development projects located within the floodplain and can be cost prohibitive on smaller residential projects. City staff work closely with developers and homeowners to make sure these improvements are included in projects as required. In addition, the City participates in the Community Rating System (CRS), a voluntary program that recognizes and rewards communities for community floodplain management practices that exceed the minimum requirements of the National Floodplain Insurance Program standards. The City received a CRS certification in January 2023.

Additional levee improvements are proposed along the rest of the City’s Bayfront from the O’Connor Pump Station to Menlo Park. These improvements are intended to reduce flood risk of the 100-year storm while maintaining access to the bayfront. These projects are currently being spearheaded by the San Francisquito Creek Joint Powers Authority (SFCJPA) and are under preliminary design with coordination with the development projects within the Ravenswood Business District. Furthermore, creek widening is being conducted downstream to further decrease flood risk.

Natural Hazards
The City is subject to the same natural hazards that impact the bay area, including drought, earthquake, flood, landslide, sea level rise, severe weather, tsunami, wildfire and climate change. The City’s various documents and plans, such as the Climate Action Plan, provide mitigation and tools to address these concerns. Any proposed development would be subject to a thorough review, consistent with Federal, State and local law, including the California Building Code, and the California Environmental Quality Act (CEQA). The City’s policies also encourage development in the more urbanized areas of the city where infrastructure is already available, creating less impact away from sensitive habitat. Placement of development in urbanized areas also reduces greenhouse gas emissions versus development in new areas where more infrastructure is required.

Sensitive Habitats
As discussed above, the City’s proximity to the bay provides for sensitive habitat areas. These include wetlands, riparian corridors, coastal areas that may be home to native and sensitive species. All proposed development would be reviewed for impacts to these sensitive habitats. Projects are subject to environmental assessment consistent with CEQA, and comments are solicited from agencies such as the Bay Conservation and Development Commission (BCDC), the California Department of Fish and Wildlife, United States Fish and Wildlife Service, Corps of Engineers, and environmental organizations. The City also has policies, ordinances and an Urban Forest Master Plan that prioritizes the preservation and protection of the City’s canopy, which support a variety of wildlife, including protected birds. The City’s General Plan and ordinances provide the tools to ensure protection of these habitats, such as bird safe building standards and the conservation and preservation of environmentally sensitive open space lands. These areas are designated to retain their natural Chapter 3 - Page 41
biological function serving as defensive barriers to waves, high tides and storm surge and providing habitat for plants and animals.
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Chapter 4 – Page 1
4 AFFIRMATIVELY FURTHERING FAIR HOUSING – AN

ASSESSMENT OF FAIR HOUSING
What is AFFH?
The State of California’s 2018 Assembly Bill (AB 686) requires that all public agencies in the state affirmatively further fair housing (AFFH) beginning January 1, 2019. Public agencies receiving funding from the U.S. Department of Housing and Urban Development (HUD) are also required to demonstrate their commitment to AFFH. The federal obligation stems from the fair housing component of the federal Civil Rights Act mandating federal fund recipients to take “meaningful actions” to address segregation and related barriers to fair housing choice.

AB 686 requires all public agencies to “administer programs and activities relating to housing and community development in a manner that affirmatively furthers fair housing, and take no action inconsistent with this obligation”22
AB 686 also makes changes to Housing Element Law to incorporate requirements to AFFH as part of the housing element and general plan to include an analysis of fair housing outreach and capacity, integration and segregation, access to opportunity, disparate housing needs, and current fair housing practices.

Source: California Department of Housing and Community Development Guidance, 2021, page 14. 22 California Department of Housing and Community Development Guidance, 2021, page 9.

Affirmatively Furthering Fair Housing
“Affirmatively furthering fair housing” means taking meaningful actions, in addition to combating discrimination, that overcome patterns of segregation and foster inclusive communities free from barriers that restrict access to opportunity based on protected characteristics. Specifically, affirmatively furthering fair housing means taking meaningful actions that, taken together, address significant disparities in housing needs and in access to opportunity, replacing segregated living patterns with truly integrated and balanced living patterns, transforming racially and ethnically concentrated areas of poverty into areas of opportunity, and fostering and maintaining compliance with civil rights and fair housing laws. The duty to affirmatively further fair housing extends to all of a public agency’s activities and programs relating to housing and community development. (Gov.

Code, § 8899.50, subd. (a)(1).)”
Chapter 4 – Page 2
History of segregation in the region. The
United States’ oldest cities have a history of
mandating segregated living patterns—and
Northern California cities are no exception. ABAG, in
its recent Fair Housing Equity Assessment, attributes
segregation in the Bay Area to historically
discriminatory practices—highlighting redlining and
discriminatory mortgage approvals—as well as
“structural inequities” in society, and “selfsegregation” (i.e., preferences to live near similar people). Researcher Richard Rothstein, author of the
2017 book The Color of Law: A Forgotten History of How
Our Government Segregated America, adds to ABAG’s
characterization of segregation in the Bay Area by
chronicling how the public and private sectors
contributed to segregation through practices of
blockbusting—a scheme where real estate agents
and speculators convinced White families their
neighborhoods were turning into slums and
property values would drop; bought their homes less
than their worth; and rented or sold them to African
Americans above market prices. Rothstein’s analysis goes beyond blockbusting, however, as he describes the ways in which federal, state, and local governments imposed residential segregation throughout the Bay Area region: racial zoning, public housing, subsidies to create Whites-only suburbs, tax exemptions, and support for resistance to African Americans in White neighborhoods.

Residential segregation and the segregatory effects of blockbusting activities is well-documented in East Palo Alto. In 1954, after a White family in East Palo Alto sold their home to an African American family, then-president of the California Real Estate Association set up an office in East Palo Alto to scare White families into selling their homes (“for fear of declining property values”) to agents and speculators. Convincing White families that their neighborhoods were turning into “African American slums,” speculators purchased their homes for less than their worth and rented/sold them to African Americans at inflated prices, most of whom struggled to make their payments and had to double-up in their homes, creating overcrowding and deteriorating living conditions. Blockbusting practices in East Palo Alto quickly became widespread as agents recognized African Americans’ increasing need for housing. Within three months, one agent sold sixty previously White-owned homes to Black/African American families.23 Federal and state agencies exacerbated these effects through unlawful lending policies and practices. The Federal Housing Administration (FHA) and Veterans Administration, for instance, 23 Richard Rothstein, The Color of Law: A Forgotten History of How our Government Segregated America, New York: Liveright Publishing Corporation (2017), pp. 12-13.

This history of segregation in the
region is important not only to
understand how residential
settlement patterns came
about—but, more importantly,
to explain differences in housing
opportunity among residents
today. In sum, not all residents
had the ability to build housing
wealth or achieve economic
opportunity. This historically
unequal playing field in part
determines why residents have
different housing needs today.

Chapter 4 – Page 3
not only refused to insure mortgages for African Americans in designated White neighborhoods, but once East Palo Alto was integrated, White families could no longer obtain governmentinsured mortgages where African Americans were present. State-regulated insurance companies and leading California banks had similar policies with the consent of federal banking regulators.

Within six years, East Palo Alto—initially considered a jurisdiction with “Whites only” neighborhoods—became 82% Black/African American. Excluded from neighborhoods throughout the region and unable to make payments on homes purchased at inflated prices, many Black/African Americans were forced to double up in single-family homes, creating a “slum in East Palo Alto.”24 With increased density, the school district could no longer accommodate all East Palo Alto students, leading board members, in 1958, to propose the construction of a segregated second high school. Ignoring pleas from Black/African Americans and liberal White activists that it draw a boundary to establish two integrated secondary schools, the school board contemplated forcing Black/African American students to withdraw and attend school in the eastern section of East Palo Alto. In ways like these, Richard Rothstein writes, “federal, state, and local governments purposely created segregation in every metropolitan area of the nation.” Importantly, segregation and resistance to racial integration was not unique to East Palo Alto as it represented a larger problem effecting all of San Mateo County. According to the San Mateo County Historical Association, San Mateo County’s early African Americans worked in a variety of industries, from logging, to agriculture, to restaurants and entertainment. Expansion of jobs, particularly related to shipbuilding during and after World War II attracted many new residents into the Peninsula, including the first sizable migration of African Americans. Enforcement of racial covenants after the war forced the migration of the county’s African Americans into neighborhoods where they were allowed to occupy housing—housing segregated into less desirable areas, next to highways, and concentrated in public housing and urban renewal developments.

Throughout San Mateo County, neighborhood associations and City leaders responded to the influx of African Americans by thwarting the integration of communities. Some neighborhood residents supported or were indifferent to integration, but most fiercely opposed it.

Neighborhood associations often required the acceptance of all new buyers and builders with intentions to develop for buyers despite race faced significant barriers: development sites were rezoned by planning councils, large minimum lot size requirements, and/or were denied public infrastructure to support their developments or charged prohibitively high amounts for infrastructure.

These events and patterns were not limited to San Mateo County, either. They were instead prominent throughout the country, as portrayed in the timeline of major federal Acts and court decisions concerning fair housing choice and zoning and land use on the following page. 24 Ibid., pp. 12-13.

Chapter 4 – Page 4
Exclusive zoning practices were common in the early 1900s. Courts struck down only the most discriminatory and allowed those that would be considered today to have a “disparate impact” on classes protected by the Fair Housing Act. For example, the 1926 case Village of Euclid v. Amber Realty Co. (272 U.S. 365) supported the segregation of residential, business, and industrial uses, justifying separation by characterizing apartment buildings as “mere parasite(s)” with the potential to “utterly destroy” the character and desirability of neighborhoods. At that time, multifamily apartments were the only housing options for people of color, including immigrants.

The Federal Fair Housing Act was not enacted until nearly 60 years after the first racial zoning ordinances appeared in U.S. cities. This coincided with a shift away from federal control over lowincome housing toward locally-tailored approaches (block grants) and market-oriented choice (Section 8 subsidies)—the latter of which is only effective when adequate affordable rental units are available.

Resegregation. Though racial segregation has been seemingly addressed and solved through local, state, and federal policies, East Palo Alto and its lower-income and minority communities are being resegregated due to gentrification efforts, housing shortages, and rapidly rising rents and home prices. Gentrification in East Palo Alto dates back to the 1980s when developers began buying significant portions of land in the region. In recent years, however, gentrification has intensified as large tech companies—Meta (formerly Facebook), Google, and Amazon—move to the area. The Silicon Valley tech boom in East Palo Alto presents multiple problems for long-time residents. With the presence of large technology companies, places such as Meta have begun allocating money and resources to improve communities surrounding their headquarters. Job openings rarely go to residents, but rather young, well-paid tech professionals migrating to East Palo Alto in search of housing. This increase in workers has turned East Palo Alto into a “hunting ground” for real estate speculators eager to turn properties and apartments into sites for the tech sector.

Gentrification efforts and processes have resulted in resegregation as lower-income individuals and people of color in East Palo Alto are forcefully displaced and/or voluntarily leaving the City for cheaper alternatives. In fact, a study conducted by researchers at the University of California at Berkeley found that East Palo Alto “lost thousands of low-income black households from 2010 to 2015 with no similar effects reported in predominantly white neighborhoods” during the same time period.25 Providing background on this trend, the University mapped all Bay Area neighborhoods to identify gentrification risks and found that in East Palo Alto, 64.7% of households live in neighborhoods that are susceptible to or experiencing displacement and 0% live in neighborhoods at risk of or undergoing gentrification.26 Landlords are also contributing to 25 https://gunnoracle.com/19991/uncategorized/a-tale-of-two-cities-how-racism-in-housing-deeds-redlining-andgentrification-led-to-the-stark-divide-between-palo-alto-and-east-palo-alto/. 26https://www.cityofepa.org/sites/default/files/fileattachments/housing/page/19915/c2_abag_mtc_housing_needs_da ta_report_east_palo_alto_w_toc_1.pdf.

Chapter 4 – Page 5
displacement in the region and are reportedly using evictions and rent hikes to prepare residential neighborhoods for redevelopment.27
Local opposition to affordable housing. Affordable housing policies and measures in East Palo Alto have been a subject of severe controversy since the 1980s when rent stabilization ordinances were proposed.28 In 2021, debates over affordable housing policy arose again with the City’s proposed ordinance called the Opportunity to Purchase Act (OPA). 29 The proposed policy is aimed to help further housing preservation and anti-displacement efforts, by requiring owners to give renters, affordable housing nonprofits, or the City the opportunity to make an offer on the property before hitting the market. The City will be further studying this policy for consideration at the end of 2022 or in-2023.
27 https://www.washingtonpost.com/national/a-semi-feudal-society-in-east-palo-alto-the-influx-of-tech-companiespushes-residents-to-a-breaking-point-over-gentrification/2018/11/02/03e1004c-d17c-11e8-b2d2- f397227b43f0_story.html.
28 https://shelterforce.org/2022/03/22/the-nexus-between-rent-control-and-incorporation-in-east-palo-alto/. 29 https://www.paloaltoonline.com/news/2021/12/21/east-palo-alto-to-discuss-controversial-housing-purchasepolicy.

Chapter 4 – Page 6
Major Public and Legal Actions that Influence Fair Access to Housing Chapter 4 – Page 0
Access to resources and opportunity. Several other factors have limited the city’s ability to provide fair access to resources and opportunity. The widening of the Highway 101 in the late 1950’s destroyed the city’s once-thriving business district, the Whiskey Gulch. In the same decade, Palo Alto and Menlo Park annexed land from East Palo Alto, decreasing the area and size of the city to 2.5 square miles and limiting the number of vacant sites the City can develop on. Today, some sites in the Ravenswood Business District/Four Corners Specific Plan, the new designated area for the city’s missing business district, lie on contaminated land that requires further remediation to allow for mixed-use development. Romic Environmental Technologies and its predecessor hazardous waste management facilities that operated in East Palo Alto from the 1950’s until 2007, contaminated the soil and ground water beneath.

The lack of political power and agency over County and regional agency decisions was one contributing factor that led to the City’s long fight for incorporation from the late 1950’s until the City’s incorporation in 1983. Following incorporation, the City struggled with its revenue sources as it had previously depended on San Mateo County resources.

East Palo Alto is allocated 1.9 million gallons per day from the Hetch Hetchy Reservoir by the San Francisco Public Utilities Commission (SFPUC). The city was not incorporated when San Mateo County made the deal with SFPUC to divide the shares, which resulted in East Palo Alto receiving the lowest per-capita allocation on the Peninsula. In 2016, East Palo Alto adopted a water moratorium due to its city-wide water supply shortage, creating a de facto development moratorium. In 2017, the city went into an agreement with the City of Mountain View to pay $5 million for the allocation of 1 million gallons of water per day that would help supply the northern part of the city. In 2018, East Palo Alto received the allocation of a half-million gallons per day of water at no cost from Palo Alto. The city lifted the water moratorium in 2018, creating an influx of development proposals, including the development of a 120-unit low-income affordable housing development at 965 Weeks Street, two commercial developments and a primary school.

The City of East Palo Alto is at a crossroads. Today, the majority of the City’s multi-family affordable housing lies west of the Highway 101, while the majority of the single-family housing, unaffordable to younger generations, lies east of the highway. The City has the potential to allocate more affordable housing development on the eastside to balance the housing stock disparity created by the Highway 101. Data show that East Palo Alto residents have higher rates of asthma, diabetes, and poor health outcomes than the County. Continued exposure to carbon emissions due to the city’s high-transit location, low access to affordable 2–3-bedroom housing for larger family sizes, limited infrastructure and active public transportation systems, and ongoing home and rent increase pressures from the tech industry, as well as other issues will continue to impact resident’s health and access to opportunities if transformational steps are not taken.

Displacement as a continuous historical Pattern. Displacement risk varies among residential circumstances for different households. While median incomes have increased in recent years due to the entry of higher income households and the exit of lower income households, many Chapter 4 – Page 1
households remain in precarious circumstance and at substantial risk of displacement.

Overcrowding and overburdening are signs that rents are outpacing wages and become de facto anti-displacement strategies for jurisdictions lacking sufficient anti-displacement policy protections. While East Palo Alto has worked over the recent decade to pass and implement antidisplacement policy on multiple occasions, the intensity of real estate appreciation is uncharacteristically rapid in comparison to other geographies and thus has been difficult to proportionately respond to, especially considering that CA State and Federal resources have not paced with local need.

Regionally, East Palo alto experienced the most intense decline of youth population of any Bay Area city between 2010 and 2020, suggesting that youth and families are being displaced and/or blocked from entry. If families can’t secure housing in East Palo Alto over the long term, demographically the city may be at risk of population decline. According to the Urban Displacement Project, census tracts in East Palo Alto are included mamong the census tracts with substantial and high likelihoods of residential displacement.

Metrics of displacement risk that measure at the census tract level are useful tools, but local knowledge with enhanced granularity reveals that displacement has been intense and remains likely and risky for substantial portions of the population, particularly economically, racially, and gender-disadvantaged groups. Though temporary responses like the Coronavirus Eviction Moratorium helped to decelerate the rate of displacement by protecting some residents from eviction during unprecedented pandemic conditions, the lift of the moratorium has resulted in re-acceleration as rental property owners return to business as usual.

Further, the context of displacement is given additional meaning by the history of development in East Palo Alto. Developed in the mid 1900s for the purpose of segregating residential neighborhoods by race and class in service of the War Production economy, policies including but not limited to redlining and racially restrictive covenants have resulted to long term impacts excluding racially disadvantaged groups from benefits and targeting them for cost assignment.

More recently, environmental justice issues like toxic waste and innovative injustices like predatory lending have continued to contribute to the pattern of disadvantaged groups to be displaced and banished from East Palo Alto. While policies and programs to address displacement have been won and implemented to some success, more resources, especially from State and Federal repositories, will be needed to ensure that residents can remain housed and thrive in East Palo Alto.

Report content and organization. This Fair Housing Assessment follows the April 2021 State of California State Guidance for AFFH. The study was conducted as part of the 21 Elements process, which facilitates the completion of Housing Elements for all San Mateo County jurisdictions.

Chapter 4 – Page 2
Section I. Fair Housing Enforcement and Outreach Capacity reviews lawsuits/enforcement actions/complaints against the jurisdiction; compliance with state fair housing laws and regulations; and jurisdictional capacity to conduct fair housing outreach and education.

Section II. Integration and Segregation identifies areas of concentrated segregation, degrees of segregation, and the groups that experience the highest levels of segregation.

Section III. Access to Opportunity examines differences in access to education, transportation, economic development, and healthy environments.

Section IV. Disparate Housing Needs identifies which groups have disproportionate housing needs including displacement risk.

Appendices.
 Resident survey results—findings from a survey of San Mateo County residents on their experience finding and remaining in housing
 Disparate Access to Educational Opportunities—findings from a countywide analysis of access to education and educational outcomes by protected class.  Dissimilarities and Isolation Indices—summary of findings from an AFFH Segregation Report of Unincorporated San Mateo County, completed by UC Merced Urban Policy Lab and ABAG/MTC Staff.
 State Fair Housing Laws and Regulations—summary of key state laws and regulations related to mitigating housing discrimination and expanding housing choice  Fair Housing Organizations in San Mateo County—mission, services, and contact information
Primary findings. This section summarizes the primary findings from the Fair Housing Assessment for East Palo Alto including the following sections: fair housing enforcement and outreach capacity, integration and segregation, access to opportunity, disparate housing needs, and contributing factors and the city’s fair housing action plan.  9% (five complaints) of fair housing complaints filed in San Mateo County from 2017 to 2021 were in East Palo Alto—the city accounts for only 4% of the county’s population. The issues cited were terms, conditions, privileges, or services and facilities (4 complaints), and refusal to rent (one complaint).
 The majority of residents living in East Palo Alto are renters (60%). Female headed households are the most likely to be renters, with seven out of ten female-headed households renting. The area of the city bordering Menlo Park has a higher concentration of households made up of female-headed households with children.

Chapter 4 – Page 3
 Compared to the county, East Palo Alto has a relatively high share of households that include children (49% in the city v. 33% countywide).
 East Palo Alto is also home to larger share of Hispanic/Latinx and Black or African American residents compared to the county (Figure II-1). The share of the Black or African American population decreased significantly from 23% to 11% since 2000, while the Hispanic/Latinx population increased from 60% to 66% and the non-Hispanic White population increased from 7% to 10%.
 Most Racial and ethnic minority populations are disproportionately impacted by poverty, low household incomes, overcrowding, and homelessness compared to the nonHispanic White population in East Palo Alto. Additionally, racial and ethnic minorities, especially Hispanic/Latinx and Black or African American residents, are more likely to be denied for a home mortgage loan.
➢ Racial and ethnic minorities have higher rates of poverty (Figure II-5) and lower household incomes (Figure II-4) compared to the non-Hispanic White population in East Palo Alto.
➢ Overcrowding in the city is significantly higher than the county (Figure IV-15).

Hispanic/Latinx households have the highest share of overcrowded households, while Black or African American households have the lowest (Figure IV-17) ➢ Countywide, people who identify as American Indian or Alaskan Native, Black, White, and Hispanic/Latinx are overrepresented in the homeless population compared to their share of the general population (Figure IV-22). ➢ Hispanic/Latinx, American Indian or Alaska Native, and Black or African American households have the highest denial rates for mortgage loan applications in 2018 and 2019 (Figure IV-33).
 Compared to the county, East Palo Alto residents are more likely to be living in poverty (Figure II-28).
 Geospatially, the area bordering Menlo Park and west of Highway 101 tends to be disproportionately impacted by high poverty, low education opportunity, low economic opportunity, low environmental scores, high social vulnerability scores, concentrations of cost burdened households, overcrowding, and low resource scores. This area also has a concentration of renter households, and female headed households (Figure IV-13 and Figure II-22). These areas have:
➢ Education opportunity scores between 0 and 0.25—meaning they have the lowest education scores compared to the rest of the city (Figure III-1). ➢ Low economic opportunity scores between zero and 0.25 (Figure III-7).

Chapter 4 – Page 4
➢ The composite opportunity score for East Palo Alto shows census tracts in this area of the city fall within low resource areas while the rest of the city is within moderate areas (Figure III-14).
➢ The Social Vulnerability Index (SVI) provided by the CDC—ranks census tracts based on their ability to respond to a disaster. This area of the city is more vulnerable according to the SVI (Figure III-15).
➢ Concentration (60% to 80% of households) of cost burdened renter households (Figure IV-13). Overcrowded households are concentrated in the same areas as cost burdened households (Figure IV-19).
➢ The entire city is considered vulnerable to displacement (Figure IV-28).  The share of the population living with at least one disability is 6% in East Palo Alto, a slightly lower incidence than in San Mateo County. Unemployment is disproportionately high among residents living with a disability at 18% compared to 4% for residents without a disability in East Palo Alto—particularly when compared to the county (Figure III-20).  East Palo Alto is served by the Ravenswood City Elementary School District; and the Sequoia Union Unified High School District. Eighty-three of students qualify for reduced lunch in Ravenswood City Elementary, and 30% of students are experiencing homelessness. This is an outlier in the county, where overall just 2% are experiencing homelessness. Ravenswood also has a much higher share of Hispanic/Latinx students than San Mateo County (84% v. 38%).
 The city has relatively low education opportunity scores overall and disparities are present for minority students:
➢ Hispanic/Latinx students at Ravenswood City Elementary are the least likely to have met or exceeded mathematics and English testing standards in the county. ➢ At the high school level, Sequoia Union district has the highest dropout rate in the county (10%), and dropout rates among Pacific Islander (20%), Hispanic/Latinx (16%), and Black/African American (12%) students are much higher.  Almost 60% of all renter households in East Palo Alto are cost burdened, spending more than 30% of their gross income on housing costs, and close to one-third are extremely cost burdened, spending more than 50% of their gross income on housing costs (Figure IV-9). Hispanic/Latinx (58%) households experience the highest rates of cost burden, followed by Black or African American households (55%). Racial and ethnic minorities are also more likely than non-Hispanic White households to experience overcrowding in East Palo Alto.

Chapter 4 – Page 5
 The Black population of East Palo Alto declined both in real numbers and as a percentage of the city’s total population since incorporation, due to a number of factors including gentrification and displacement. Where in 1980 Black residents accounted for 55% of the
population, by 2010, only 16% of
the population was represented
by Black residents. During this
time, the city grew from a
population of about 17,000 to
about 30,000. In other words, a
population of about 9,300
Black residents dwindled to
about 4,700 Black residents
during a period in which the
city’s population grew 75%.

While East Palo Alto grew, many
Black residents have been
pushed out and new Black
renters may not be easily
entering the city.30
 Homeownership has been one mechanism that has helped some Black families remain rooted in East Palo Alto. According to the Housing Needs Report, of the 1,196 Black Households in the city, about 60% were owner-occupied and about 40% were renter occupied.31 The high proportion of homeownership among Black households is beneficial for those homeowners, but also indicates the history of displacement that reduced the number of Black renters in East Palo Alto. A larger proportion of Black renters might still reside in the city if not for the impacts of gentrification and displacement on East Palo Alto’s Black community.

Contributing factors and Fair Housing Action Plan. The disparities in housing choice and access to opportunity discussed above stem from historical actions; the inability of the broader region to respond to housing demand leading residents seeking 30 Rockefeller Harris & Cespedes (2015). East Palo Alto: An Island of Affordability in a Sea of Wealth. 31 ABAG/MTC & Driskell Community Planning. (2021). Housing Needs Data Report East Palo Alto Chapter 4 – Page 6
affordability into East Palo Alto; East Palo Alto’s relative affordability compared to the broader region; and the city’s very limited resources to respond to needs. Specifically, Fair housing issue: Residents of color—especially Black or African American residents—have been displaced from East Palo Alto due to rising rents.

Contributing factors:
o Lack of housing production the region overall, incentivizing property owners to raise rents.
o Redevelopment of naturally occurring affordable housing, despite city policies to help mitigate high rent increases.
o Wage stagnation or decline, especially among renters across racial groups, limits households’ ability to stay in place while rents increase, and also increases difficulty to save towards homeownership.

Fair housing issue: Families with children are disproportionately represented in East Palo Alto compared to the region and have lower access to quality educational environments.

Contributing factors:
o Lack of affordable family housing in the county.
o School district policies that concentrate low income families in under-resourced schools in East Palo Alto.
o Lack of resources for schools with children living in poverty to adequately students’ address needs.

Fair housing issue: Renters and female headed households with children are concentrated in neighborhoods with high poverty and low resources.

Contributing factors:

Lack of affordable family housing in the county.

Concentration of affordable housing in the area bordering Menlo Park and west of Highway 101.

Fair housing issue: East Palo Alto residents have high rates of cost burden, overcrowding, and denials when seeking mortgage loans.

Contributing factors:
o Historical discrimination in housing and employment markets that has limited the ability of residents of color to build family wealth and access high paying jobs. o Significant shortage of affordable housing in the city, county, and region overall.

Fair housing issue: Residents with disabilities have very high rates of unemployment (18%) compared to non-disabled residents and the county overall.

Contributing factors:
o Discrimination in the job market and lack of training and education. o Inability of employers to accommodate the needs of persons with disabilities.

Chapter 4 – Page 7
SECTION I. Fair Housing Enforcement and
Outreach Capacity
This section discusses fair housing legal cases and inquiries, fair housing protections and enforcement, and outreach capacity.

Fair housing legal cases and inquiries. California fair housing law extends beyond the protections in the Federal Fair Housing Act (FHA). In addition to the FHA protected classes— race, color, ancestry/national origin, religion, disability, sex, and familial status—California law offers protections for age, sexual orientation, gender identity or expression, genetic information, marital status, military or veteran status, and source of income (including federal housing assistance vouchers).

The California Department of Fair Employment in Housing (DFEH) was established in 1980 and is now the largest civil rights agency in the united States. According to their website, the DFEH’s mission is, “to protect the people of California from unlawful discrimination in employment, housing and public accommodations (businesses) and from hate violence and human trafficking in accordance with the Fair Employment and Housing Act (FEHA), Unruh Civil Rights Act, Disabled Persons Act, and Ralph Civil Rights Act.”32
DFEH receives, evaluates, and investigates fair housing complaints. DFEH plays a particularly significant role in investigating fair housing complaints against protected classes that are not included in federal legislation and therefore not investigated by HUD. DFEH’s website provides detailed instructions for filing a complaint, the complaint process, appealing a decision, and other frequently asked questions.33 Fair housing complaints can also be submitted to HUD for investigation.

Additionally, San Mateo County has a number of local enforcement organizations including Project Sentinel, the Legal Aid Society of San Mateo County, and Community Legal Services of East Palo Alto. These organizations receive funding from the County and participating jurisdictions to support fair housing enforcement and outreach and education in the county. East Palo Alto residents wishing to submit fair housing complaints can reach out to the abovementioned local enforcement organizations, also listed on the City’s Rent Stabilization page under “Housing Assistance, Fair Housing and Other Resources.”34 Residents may also contact the City’s Rent Stabilization Program, Housing Division, and Building/Code Enforcement Division for further assistance on their individual cases.

From 2017 to 2021, 57 fair housing complaints in San Mateo County were filed with the U.S.

Department of Housing and Urban Development (HUD)—9% of complaints were in East 32 https://www.dfeh.ca.gov/aboutdfeh/.
33 https://www.dfeh.ca.gov/complaintprocess/.
34 https://www.cityofepa.org/rent-stabilization/page/housing-assistance-fair-housing-and-other-resources Chapter 4 – Page 8
Palo Alto (five complaints). Countywide, most complaints cited disability status as the bias (56%) followed by race (19%), and familial status (14%). In East Palo Alto, the issues cited were terms, conditions, privileges, or services and facilities (4 complaints), and refusal to rent (one complaint).

Countywide, no cause determination was found in 27 complaints followed by successful conciliation or settlement with 22 complaints. Fair housing inquiries in 2020 were primarily submitted from the City of San Mateo, followed by Redwood City, Daly City, and Menlo Park.

Fair housing complaints filed with HUD by San Mateo County residents have been on a declining trend since 2018, when 18 complaints were filed. In 2019, complaints dropped to 5, increased to 11 in 2020, and had reached 6 by mid-2021.

Nationally, the National Fair Housing Alliance (NFHA) reported a “negligible” decrease in the number of complaints filed between 2019 and 2020. The primary bases for complaints nationally were nearly identical to San Mateo County’s: disability (55%) and race (17%). Familial status represented 8% of complaints nationally, whereas this basis comprised 14% of cases in the county.

NFHA identifies three significant trends in 2020 that are relevant for San Mateo County:
 First, fair lending cases referred to the Department of Justice from federal banking regulators has been declining, indicating that state and local government entities may want to play a larger role in examining fair lending barriers to homeownership.  Second, NFHA identified a significant increase in the number of complaints of harassment— 1,071 complaints in 2020 compared to 761 in 2019.
 Finally, NFHA found that 73% of all fair housing complaints in 2020 were processed by private fair housing organizations, rather than state, local, and federal government agencies— reinforcing the need for local, active fair housing organizations and increased funding for such organizations.35
35 https://nationalfairhousing.org/2021/07/29/annual-fair-housing-report-shows-increase-in-housing-harassment/ Chapter 4 – Page 9
Outreach and capacity. East Palo Alto City’s website provides easy to follow links to the rent stabilization program and housing programs, as well as the opportunity to share input on the Housing Element. The City improved the accessibility of fair housing information on its website and resources for residents experiencing housing discrimination, by adding general Chapter 4 – Page 10
information about the Fair Housing Act and a list of organizations to reach out to for fair housing complaints on its “Housing Assistance, Fair Housing, and Other Resources” page, which is linked on both the Rent Stabilization and Housing webpages. This resource page also provides information for homelessness and rental assistance, eviction and tenant legal assistance, housing inspections, affordable rental housing, mediation services, and more. Language accessibility is provided by having the option to translate information into Chinese, Samoan, and Spanish and selection the option at the bottom of each webpage. Language accessibility could be improved by providing some information in both English and Spanish, as well as placing the option to select a different language at the top of the website.

The City committed to increasing its outreach capacity for special needs groups, including extremely low-income tenants and monolingual Spanish-speaking residents, in its AntiDisplacement Services contract with Community Legal Services in East Palo Alto (CLSEPA), Youth United for Community Action (YUCA), and Nuestra Casa. Tenant legal services, rent relief workshops, and outreach were provided and expanded during the COVID_19 pandemic to address immediate community needs, using the City’s funds generated from Measure O. Upon expiration of the contract, the City issued another Request for Proposals and in August 2022, came into a new contract with CLSEPA, Nuestra Casa and YUCA for an additional one to two years of anti-displacement services, including legal representation, case management, education in tenant rights and housing laws, and outreach. The outreach is targeted to especially vulnerable neighborhoods in the community through workshops on the Westside, door-to-door knocking and communication with tenants living in single-family homes, and Spanish and Tongan translation and interpretation. Residents with fair housing complaints will have organizations readily available and proactively reaching out to address the complaints and redirect them to the right resources, such as Project Sentinel. In addition, the contracted service providers have quarterly reporting requirements and bi-monthly meetings with Rent Stabilization staff to identify and report fair housing complaints from residents.

Compliance with state law. East Palo Alto is compliant with the following state laws that promote fair and affordable housing and has not been found or alleged in violation of the following.
 Government Code Section 65852.2 (a), requiring cities to implement ordinances allowing for the creation of second units in single-family or multi-family residential zones;  Government Code Section 65915, giving housing developments the right to add density bonuses and incentives that reduce affordable housing costs;  Ellis Act, providing that cities do not bar the redevelopment and reconstruction of Rent Stabilization Program units;
Chapter 4 – Page 11
 State laws SB 1069 and AB 2299, allowing for the development of Accessory Dwelling units (ADUs) on most single-family lots to increase opportunities for housing production;  Fair Employment and Housing Act (FEHA), prohibiting discrimination in housing based on race, color, national origin, religion, sex, gender identity/expression, sexual orientation, familial status, disability, age, citizenship, language, source of income, or any other arbitrary basis.

East Palo Alto also complies with all provisions included in the Fair Housing Act and Fair Housing laws are appropriately followed with Planning Division staff making exceptions to the Zoning Code when appropriate.

Housing specific policies enacted locally. East Palo Alto identified, according to the 21 Elements AFFH Resident Survey and based on community input, the following local policies and programs that contribute to the regulatory environment for affordable housing development in the city.

Chapter 4 – Page 12
Local policies and programs in place to
encourage housing development.
 ADU Working Group
 CalHOME program for the creation of
affordable ADU units
 Inclusionary housing
 Measure HH commercial office space
special parcel tax revenue (passed in
2018)
 Measure O gross receipts tax revenue
(passed in 2016)
 Measure L business tax revenue (passed
in 2022)
Local barriers to affordable housing
development.
 Development impact fees
 High parking requirements
 Infrastructure needs in sanitary sewer
services
 Lengthy processing times and
requirements to develop properties
 Low staffing capacity in the Building,
Code Enforcement, Planning and
Housing divisions
 Missing ADU legalization program to
complement ADU streamlining
Local policies and programs that are
NOT in place but would provide the
best outcomes in addressing housing
shortages.
 Homebuyer assistance programs
 Mortgage and rental assistance (beyond
pandemic)
 Tenant Opportunity to Purchase Act/
Community Opportunity to Purchase Act
Local policies that are NOT in place,
but have potential Council interest for
further exploration.
 Acquisition and rehab program
 Anti-Displacement Plan
 First-time homebuyer and foreclosure
assistance
 Housing counseling
 Living wage employment ordinances
 Rental Registry
Local policies and programs in place
to mitigate or prevent displacement
of low income households.
 Affordable housing impact linkage fee
on new commercial development
 Community land trusts
 Condominium conversion regulations
 Fair housing legal services
 First source hiring ordinances
 Funding home sharing program (HIP
Housing)
 Inclusionary housing
 Just cause eviction
 Local preference
 Mobile home displacement prevention
 Rent review board and/or mediation
 Rent stabilization
 Rental assistance and tenant education
and empowerment
 Tenant relocation requirements
Chapter 4 – Page 13
According to the California Department of Housing and Community Development AFFH Data Viewer (HCD data viewer), East Palo Alto does not have any public housing buildings. However, the city does have a moderate (5% to 15%) share of households using housing vouchers.

Compared to nearby Menlo Park and Palo Alto, East Palo Alto appears accommodating to renters with housing vouchers because the city has a greater share of voucher holders compared to the surrounding communities. The presence of housing voucher users indicates available rental supply to house these residents and a lack of exclusionary behavior from landlords in the city.

Legal challenges. Legal challenges in the past two decades have placed East Palo Alto’s affordable rental housing stock in a unique situation and increased displacement among East Palo Alto residents unable to afford rising rent prices.

In 2006, Page Mill Properties, a Palo Alto-based real estate investment firm, assumed management of over 1,800 rental units in the Woodland Park neighborhood of East Palo Alto.

The property management group purchased the units at market value, intending to rehabilitate units with deferred maintenance issues such as new roofs, gates, seismic upgrades, night security, and surveillance cameras. To pay for such improvements, the majority of tenants’ rents increased twice during 2008—an average of 9% in the first rent change, followed by an average

7.7% increase.36 Abrupt and continuous rent increases can shift the composition of residents – pushing out or pressuring lower income households and inviting residents with higher incomes on average, often workers in Technology and other high paying industries driving gentrification. 37 This pattern helps explain how Black resident population declined from 22% of 27,503 in the year 2000 to 16% of 29,637 in the year 2010. When rent increases don’t displace, it can be because households resort to overcrowding and overburdening, both of which are prevalent (2/3rds of renter households were overburdened in East Palo Alto according to the Housing Needs Report 2021).

However, according to East Palo Alto’s 1988 Rent Control Ordinance, rents can be increased annually at 100% of the Consumer Price Index (CPI) as set by the United States Department of Labor for the San Francisco/Oakland Metropolitan Area which was approximately 2.9% in 2008.

Property managers claimed that because the previous property owner did not annually increase rents, they should be able to legally recapture the unused annual rent increases. Despite East Palo Alto’s efforts to declare the rent change unlawful, the San Mateo Superior County ruled in favor of property managers.38
36 https://www.hcd.ca.gov/housing-elements/docs/east-palo-alto-5th-draft021215.pdf. 37 Post, T. W. (2018, November 5). In East Palo Alto, the influx of tech companies pushes residents to a breaking point over gentrification. The Mercury News. Retrieved January 10, 2023, from https://www.mercurynews.com/2018/11/05/in-east-palo-alto-the-influx-of-tech-companies-pushes-residents-to-abreaking-point-over-gentrification/ 38 Ibid.

Chapter 4 – Page 14
In 2009, Page Mill Properties defaulted in its loan obligations, allowing Wells Fargo Bank to take title of the rental properties after foreclosure proceedings in 2010. In December 2011, Wells Fargo Bank sold the properties to a Chicago-based corporation, Equity Residential. As a result of rent increases, families have reportedly been displaced due to rent increases.

Chapter 4 – Page 15
SECTION II. Integration and Segregation
This section discusses integration and segregation of the population by protected classes including race and ethnicity, disability status, familial status, and income status. The section concludes with an analysis of racially and ethnically concentrated areas of poverty and affluence.

Integration and Segregation
“Integration generally means a condition in which there is not a high concentration of persons of a particular race, color, religion, sex, familial status, national origin, or having a disability or a particular type of disability when compared to a broader geographic area.

Segregation generally means a condition in which there is a high concentration of persons of a particular race, color, religion, sex, familial status, national origin, or having a disability or a type of disability in a particular geographic area when compared to a broader geographic area.”
Source: California Department of Housing and Community Development Guidance, 2021, page 31.

Race and ethnicity. The population distribution by race and ethnicity in East Palo Alto is more diverse compared to the county. East Palo Alto shows the largest portion of the population being Hispanic/Latinx (66% v. 39% in the county), followed by Black or African American (11% v. 2% in the county). 39 The Asian and non-Hispanic White population make up 10% of the population each. The share of the Black or African American population decreased significantly from 23% to 11% since 2000, while the Hispanic/Latinx population increased from 60% to 66% and the non-Hispanic White increased from 7% to 10%. The share of the Asian population has remained stable. Black population decline has been a consistent pattern since at least 1980.

Multiple contributing factors explain this pattern. A history of redlining, racially restrictive covenants, and employment discrimination limited stable housing opportunities and wealth accumulation for generations of Black residents. Among Black residents able to secure homeownership, some sold and left, using equity to purchase homes in the region’s outer edges, namely cities and neighborhoods in Solano County, eastern Contra Costa County, and Southern Alameda County.
40 The subprime mortgage foreclosure crisis which followed deregulation and racially targeted predatory lending also dispossessed Black homeowners of wealth and housing stability.41 Today, stable housing is an urgent need for all groups in the city, but especially so for Black residents whose population has continued to decline. 39 The share of the population that identifies as American Indian or Alaska Native is less than 1%. 40 Urban Displacement Project and California Housing Partnership, Migration by Race and Income in Northern California, 2015, https://www.urbandisplacement.org/maps/sf-bay-area-migration-by-race-and-income/ 41 Jiménez Tomás R. (2017). Introduction. In The other side of assimilation how immigrants are changing American Life. University of California Press.

Chapter 4 – Page 16
The share of the population age 65 and over that is Black or African American is 30% compared to only 6% of the population under age 17. This pattern is consistent with relatively high homeownership rates (approximately 60% of Black Households) largely represented by legacy homeowners who have lived through recent decades of neighborhood transition with the ability to remain in place. Similarly in alignment with extreme age variation, the ability to raise a family, or for families with children to enter the city of East Palo Alto, has become more out of reach for many, resulting in the steepest decline in youth population of any city in the Bay Area between 2010 and 2020.
42As elder homeowners age toward the end of life, and youth and young adults struggle to get a foothold in the city, continued decline may be likely without proportional intervention to support the ability to remain in place and thrive in East Palo Alto Racial and ethnic minority populations generally have higher rates of poverty and lower household incomes compared to the non-Hispanic White population in East Palo Alto. East Palo Alto has no non-Hispanic White majority census tracts43 and several census tracts have Hispanic/Latinx majority.44
Dissimilarity and isolation indices. The Dissimilarity Index, or DI, is a common tool that measures segregation in a community. The DI is an index that measures the degree to which two distinct groups are evenly distributed across a geographic area. The DI represents the percentage of a group’s population that would have to move for each area in the county to have the same percentage of that group as the county overall.

DI values range from 0 to 100—where 0 is perfect integration and 100 is complete segregation.

Dissimilarity index values between 0 and 39 generally indicate low segregation, values between 40 and 54 generally indicate moderate segregation, and values between 55 and 100 generally indicate a high level of segregation.

The isolation index is interpreted as the probability that a randomly drawn minority resident shares an area with a member of the same minority, it ranges from 0 to 100 and higher values of isolation tend to indicate higher levels of segregation.

ABAG and UC Merced completed an analysis of racial and income segregation by both census tracts and block groups in East Palo Alto and the Bay Area region. Throughout the analysis, several indices were used to assess segregation in the city to determine how the city differs from patterns of segregation and integration in the region overall. A detailed explanation of their analysis is featured in Appendix I of the analysis; however, primary findings include:
42 Neilson, S. (2022, July 29). Nearly every Bay Area City lost kids over the last decade - except this one. here's why. San Francisco Chronicle. Retrieved January 10, 2023, from https://www.sfchronicle.com/bayarea/article/BayArea-kid-population-17331003.php 43 Majority census tracts show the predominant racial or ethnic group by tract compared to the next most populous. 44 Redlining maps, otherwise known as Home Owners’ Loan Corporation (HOLC) maps, are not available for San Mateo County.

Chapter 4 – Page 17
◼ Racial isolation indexes in East Palo Alto are relatively similar to that of neighboring jurisdictions (e.g., Redwood City) and the Bay Area region. In East Palo Alto and the Bay Area, Asian/Pacific Islander and Hispanic/Latinx isolation have progressively increased between 2000 and 2020 while segregation levels for White and Black or African American residents have declined.
◼ Since 2000, Hispanic/Latinx isolation indexes in East Palo Alto have been significantly higher than that of White residents, most likely due to the jurisdiction’s large population of Hispanic/Latinx residents. However, this differs from the rest of San Mateo County and the Bay Area overall where White residents have long been the most isolated racial group.

In 2020, unincorporated San Mateo County’s isolation index for White residents was

0.599, the Bay Area 0.491, and 0.084 in East Palo Alto (compared to 0.672 for Hispanic/Latinx residents in East Palo Alto).
◼ Dissimilarity indexes across all racial groups included in the analysis have declined between 2000 and 2020 in East Palo Alto and the Bay Area region, though DI values in the region have declined slower than East Palo Alto.
◼ Overall, DI values show that the highest segregation in East Palo Alto is between and Black or African American and White residents. As noted above, however, values declined sharply between 2010 (0.439) and 2020 (0.225). Segregation between and Black or African American and White residents in East Palo Alto was similar to the Bay Area region in 2020 but differed from San Mateo County where segregation between Hispanic/Latinx and White residents is highest on average. ◼ In line with surrounding jurisdictions and the Bay Area, very low-income residents (0%- 50% AMI) in East Palo Alto became more segregated between 2010 and 2015, with isolation index values increasing by approximately six percentage points. Unlike other areas, however, during the same time-frame moderate-income residents (80%-120% AMI) also became more isolated, though not as severe as very low-income residents. ◼ Comparing East Palo Alto to San Mateo County shows a different story. In East Palo Alto, lower-income groups are significantly more segregated and higher-income groups are much less segregated than the county overall. In 2015, isolation index values for very low-income residents was 0.561 and 0.116 for above moderate-income residents (>120% AMI). This compares to San Mateo County’s overall 0.410 (very low-income) and

0.496 (above moderate-income) isolation values.
◼ Similar to the Bay Area, DI values across income groups between 2010 and 2015 either remained the same or declined slightly (approximately one percentage point).

In terms of declining segregation for White and Black or African American residents in East Palo Alto, there is a notable decline in the jurisdiction’s population of Black or African American residents. In two decades, the population declined from 6,641 people to 3,190 people.

Chapter 4 – Page 18
Segregation for White residents, however, cannot be determined by population levels alone as numbers have shifted over the years. It should be noted that White residents comprise a relatively small portion of East Palo Alto’s total population. ABAG and UC Merced advise paying close attention to small populations as DI values can be less reliable.

These indices also show inconsistencies in income segregation between East Palo Alto and San Mateo County. This is largely due to differences in household income. As shown in Figure II-25 of the Map and Data Packet, only 17% of households in East Palo Alto earn greater than 100% of AMI compared to the overall county’s 49%. Compared to both the Bay Area region and San Mateo County, noticeably more households in East Palo Alito earn 50% below the AMI.

Increased segregation for very low-income residents in East Palo Alto can also be attributed to the Silicon Valley tech boom which many say has “created two parallel societies where the people at the top benefit a lot and the people at the bottom do not.”45 Disability status. The share of the population living with at least one disability is 6% in East Palo Alto, slightly lower than in San Mateo County’s 8%. There are no census tracts in the city with a share of the population living with a disability that reach 10%. Just west of Highway 101 there is a census tract in Menlo Park with a slightly higher concentration of people with disabilities at 10-20%. Geographic concentrations of people living with a disability may indicates the area has ample access to services, amenities, and transportation that support this population.
45 https://www.paloaltoonline.com/news/2019/09/15/equity-ripples-east-palo-alto-continues-to-struggle-amidstneighboring-tech-boom.

Chapter 4 – Page 19
Chapter 4 – Page 20
To gain a better understanding disability status in East Palo Alto, the table below shows changes to the disability community over time by census tracts. Most tracts have seen minimal change, however, tract 6118 saw a 4% decrease in the number of people with a disability. It is hard to know if they went elsewhere in the city or had to seek resources elsewhere, but the pattern is important to note. The stagnation of disability status by census tract could indicate that the area cannot accommodate additional people with disabilities due to lack of accessible units, and thus they must seek other areas of San Mateo County.

Disability Status, 2014 and 2019
Census
Tract
2014 2019 Number
and %
change
2014-2019
6116 124 / 5% 157 / 6% 33 / 1%
6117 394 / 7% 435 / 8% 41 / 1%
6118 470 / 11% 323 / 7% -147 / -4%
6119 677 / 7% 423 / 4% -254 / -3%
6120 569 / 7% 551 / 8% -18 / -1%
6121 510 / 7% 656 / 8% 146 / 1%
Source: 5 year ACS 2014 and 2019
Familial Status. East Palo Alto is home to more large households (5-person or more) than the county with 27% of households compared to only 11% in the county. Additionally, there are fewer married couple households in the city and more female-headed family households compared to the county (21% v. 10% in the county). Female-headed households tend to have higher poverty rates, be younger and more diverse than the overall population. As shown in the table below, East Palo Alto has lost female-headed families over time, suggesting that this group has been priced out of housing in many census tracts.

Female-headed households with children present, 2014 and 2019 Census
Tract
2014 2019 Number
and %
change
2014-2019
6116 49 / 6% 21 / 3% -28 / -3%
6117 357 / 25% 169 / 12% -188 / -
13%
6118 175 / 21% 108 / 11% -67 / -10%
6119 220 / 9% 243 / 9% 23 / 0%
6120 73 / 5% 217 / 14% 144 / 9%
6121 207 / 8% 356 / 13% 149 / 5%
Source: 5-year ACS 2014 and 2019
Chapter 4 – Page 21
East Palo alto also has a higher share of households with children compared to the county (49% v. 33%). The area of the city bordering Menlo Park has a higher concentration of single female with children households.

The majority of residents living in East Palo Alto are renters (60%). Female headed households are the most likely to be renters, with seven out of ten female-headed households renting. The map shows that part of East Palo Alto and Menlo Park have a higher proportion of female-headed households with children than the surrounding area at 20%-40%. This concentration indicates that East Palo Alto likely offers affordable housing options to single mothers
Chapter 4 – Page 22
Chapter 4 – Page 23
Household income. The household income distribution by percent of area median income (AMI) in East Palo Alto is more concentrated at lower incomes than the county. In East Palo Alto 50% of households have income below 50% AMI compared to 24% in the county.

There are several census block groups in the city that have median incomes below the 2020 state median income of $87,100. In addition, census block groups with median incomes below $55,000 are located in the central part of the city and west of Highway 101. Compared to the county, East Palo Alto has higher poverty rates between 10% and 20% but the city has no concentrations of census tracts with poverty rates between 20% and 30%.

Chapter 4 – Page 24
Racially or ethnically concentrated areas of poverty and affluence. Racially Concentrated Area of Poverty or an Ethnically Concentrated Area of Poverty (R/ECAP) and Racially Concentrated Areas of Affluence (RCAAs) represent opposing ends of the segregation spectrum from racially or ethnically segregated areas with high poverty rates to affluent predominantly non-Hispanic White neighborhoods. Historically, HUD has paid particular attention to R/ECAPs as a focus of policy and obligations to AFFH. Recent research out of the University of Minnesota Humphrey School of Public Affairs argues for the inclusion of RCAAs to acknowledge current and past policies that created and perpetuate these areas of high opportunity and exclusion.46 46 Goetz, E. G., Damiano, A., & Williams, R. A. (2019). Racially Concentrated Areas of Affluence: A Preliminary Investigation. Cityscape: A Journal of Policy Development and Research, 21(1), 99–124 Chapter 4 – Page 25
It is important to note that R/ECAPs and RCAAs are not areas of focus because of racial and ethnic concentrations alone. This study recognizes that racial and ethnic clusters can be a part of fair housing choice if they occur in a non-discriminatory market. Rather, R/ECAPs are meant to identify areas where residents may have historically faced discrimination and continue to be challenged by limited economic opportunity, and conversely, RCAAs are meant to identify areas of particular advantage and exclusion.

R/ECAPs
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 (majoritypeople of color) or, for non-urban areas, 20 percent, AND a poverty rate of 40 percent or more; OR
 A census tract that has a non-White population of 50 percent or more (majoritypeople of color) AND the poverty rate is three times the average tract poverty rate for the County, whichever is lower.

Source: California Department of Housing and Community Development Guidance, 2021.

For this study, the poverty threshold used was three times the average tract poverty rate for the County—or 19.1%. In addition to R/ECAPs that meet the HUD threshold, this study includes edge or emerging R/ECAPs which hit two thirds of the HUD defined threshold for poverty—emerging R/ECAPs in San Mateo County have 2 times the average tract poverty rate for the county (12.8%).

In 2010 there were three census tracts that qualify as R/ECAPs (19.4% poverty rate) in the county and 11 that qualify as edge R/ECAPs (13% poverty rate). One of the R/ECAPs was located in East Palo Alto in 2010, and 2 edge R/ECAPs were located in East Palo Alto covering the entire are of the city east of Highway 101.

In 2019 there are two census tracts that qualify as R/ECAPs (19.1% poverty rate) in the county and 14 that qualify as edge R/ECAPs (12.8% poverty rate). Three of the 2019 edge R/ECAPs are located 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, and none of the census tracts that qualify as R/ECAPs are located in East Palo Alto. The area that used to be an R/ECAP is located west of Menlo Park Business Park area but east of Highway 101. The poverty rate in this area decreased from 26% in 2010 to 11% in 2019. While the overall share of residents who are people of color remained stable, the share of Black or African American residents decreased and the shares of Asian/Pacific Islander and Hispanic/Latinx residents increased. The tables below compare edge R/ECAPs and non-edge R/ECAPs. Many census tracts between the two categories share similar characteristics of overpayment of housing cost and high non-white population.

However, the R/ECAP census tracts generally have more renters and lower median income, Chapter 4 – Page 26
signifying deeper housing instability and need than non-R/ECAPs. Noticeably, the tracts with the highest incomes have the least overcrowding and overpayment issues.

Edge-R/CAPs
Census
Tract
Median
Income
% nonwhiteOwnerOccupied
Housing
Units
Renter
Occupied
Housing
Units
%
Overcro
wded
Househol
ds
%
Overpay
ment of
Renters
%
Overpay
ment of
Homeow
ners
6118 $68,083 71% 951 316 27% 57% 60%
6119 $100,038 61% 1,466 1,254 18% 28% 53%
6121 $57,627 48% 403 2,421 33% 68% 48%
Non-R/ECAPs
Census
Tract
Median
Income
%
nonwhite
OwnerOccupied
Housing
Units
Renter
Occupied
Housing
Units
%
Overcrowded
Households
%
Overpayment
of Renters
%
Overpayment
of
Homeowners
6116 $220,859 22% 665 114 0% 33% 27%
6117 $65,613 62% 656 795 23% 63% 43%
6120 $71,234 70% 836 754 34% 62% 59%
RCAAs. HCD’s definition of a Racially Concentrated Area of Affluence is “A census tract with a median income 1.25 times and more higher than in the region and a White population of 1.5 times and more higher than the region.” While many jurisdictions in San Mateo County are considered RCAAs, East Palo Alto is not a RCAA, as shown in Figure IV-34. This is most likely due to the greater portion of lower-income communities located in East Palo Alto and the small population of non-Hispanic White residents. In fact, people of color comprise more of East Palo Alto’s population than the Bay Area region as a whole. Historical local, state, and federal housing policies outlined in the beginning of this Assessment contributed to these patterns in neighborhood characteristics and disparities as many policies excluded people of color from accessing the same opportunities as White residents.

Unlike neighboring RCAAs, East Palo Alto is considered to be an overall low opportunity area and a moderate to low resource area with low education, economic, and environmental outcomes.

Though access to schools and other opportunities will be discussed in greater detail in Section III, it is important to note that although East Palo Alto residents have adequate access to schools, Chapter 4 – Page 27
education results are severely low, nearly all students come from low-income households (91%), and over half are English learners (54%).47 Consistent with 5-year trends, in the 2018-2019 school year, less than 2 in 10 students were on grade level in English and math. 48 Given these outcomes,
many families in East Palo Alto have tried getting their children into the Tinsley Program—a 1986 initiative allowing a small number of children from Ravenswood School District to transfer to schools in the surrounding K-8 districts: Belmont-Redwood Shores, Las Lomitas, Menlo Park, Palo Alto, Portola Valley, San Carlos, and Woodside; all of which are mapped as RCAAs (Figure IV-34).

In terms of job proximity, however, East Palo Alto scores higher or in line with surrounding RCAAs.

Addressing inequities. East Palo Alto has taken numerous steps to address inequities in the area. Solutions to enhancing access to opportunities, reducing segregation, and providing increased affordable housing have been proposed and/or implemented in the form of policies, programs, goal setting, strategies, and more. Examples include:
 Financial support policies to discourage gentrification and the displacement of existing residents;
 Coordinating with Ravenswood School District, Sequoia School District, and private schools to improve transportation to/from school;
 Development outreach—require sponsors of major development and/or infrastructure projects to initiative early and frequent communication with communities and show how community input was incorporated into plan prior to City Council approval;  CalHome ADU/JADU Loan Program—joint effort between City staff and EPA CAN DO, launched January 2022;
 Implement Affordable Housing Program—ongoing requirements for housing staff to maintain Inclusionary Housing program, Commercial Linkage Fee program, and Local Preference program;
 Affordable housing overlay zone;
 Jobs-housing linkage that links the production of commercial office spaces to affordable housing production;
 Leverage available federal funding support for down payment and first-time homebuyer assistance.
47 https://innovateschools.org/wp-content/uploads/2021/01/2020-Spotlight-on-Schools-within-RESD.pdf. 48 Ibid.

Chapter 4 – Page 28
In addition to the above, the City of East Palo Alto works with the following groups to advance and improve affordable housing and human services programs:
 Adults toward Independent Living;
 Bayshore Community Resources Center;
 Community Association for Rehabilitation, Inc.;
 Community Overcoming Relationship Abuse;
 Community Legal Services in East Palo Alto;
 EDEN Housing;
 El Comité del Lado Oeste;
 Elder Care Locater;
 EPA CAN DO;
 Habitat for Humanity;
 HIP Housing;
 Housing Choices;
 Housing Leadership Council of San Mateo County;
 Human Investment Project;
 MidPen Housing;
 Nuestra Casa;
 Preserving Affordable Housing Longterm, Inc;
 Project Sentinel;
 Samaritan House;
 Shelter Network;
 Spring St. Shelter/Mental Health Association;
 WeHOPE;
 Women and their Children’s Housing (WATCH);
 Youth united for Community Action in East Palo Alto
Chapter 4 – Page 29
SECTION III. Access to Opportunity
This section discusses disparities in access to opportunity among protected classes including access to quality education, employment, transportation, and environment.

Access to Opportunity
“Access to opportunity is a concept to approximate place-based characteristics linked to critical life outcomes. Access to opportunity oftentimes means both improving the quality of life for residents of low-income communities, as well as supporting mobility and access to ‘high resource’ neighborhoods. This encompasses education, employment, economic development, safe and decent housing, low rates of violent crime, transportation, and other opportunities, including recreation, food and healthy environment (air, water, safe neighborhood, safety from environmental hazards, social services, and cultural institutions).”
Source: California Department of Housing and Community Development Guidance, 2021, page 34.

The California Tax Credit Allocation Committee (TCAC) in collaboration with HCD developed a series of opportunity maps that help to identify areas of the community with good or poor access to opportunity for residents. These maps were developed to align funding allocations with the goal of improving outcomes for low-income residents—particularly children.

The opportunity maps highlight areas of highest resource, high resource, moderate resource, moderate resource (rapidly changing), low resource and high segregation and poverty. TCAC provides opportunity maps for access to opportunity in quality education, employment, transportation, and environment. Opportunity scores are presented on a scale from zero to one and the higher the number, the more positive the outcomes.

Education. TCAC’s education score is based on math proficiency, reading proficiency, high school graduation rates, and the student poverty rate. According to TCAC’s educational opportunity map, all areas in East Palo Alto score below 0.50—opportunity scores are presented on a scale from zero to one and the higher the number, the more positive the outcomes. Census tracts bordering Menlo Park and east of Highway 101 score below 0.25.

East Palo Alto is served by the Ravenswood City Elementary School District; and the Sequoia Union Unified High School District.

Enrollment in Ravenswood City Elementary decreased 30%. This represents a much larger decrease than the 1% decrease experienced in the county.

Enrollment in Sequoia Union increased by 18% from 2010 to 2020.

Chapter 4 – Page 30
Ravenswood City Elementary has a much higher share of Hispanic/Latinx students than San Mateo County (84% v. 38%). The enrollment composition in Sequoia Union is similar to the countywide distribution.

Overall, 29% of public school students in San Mateo County qualify for reduced lunch. This was substantially higher in Ravenswood City Elementary School District, where 83% of students qualify for reduced lunch. In Ravenswood City Elementary, 30% of students are experiencing homelessness. This is an outlier in the county, where overall just 2% are experiencing homelessness.

County-wide, 20% of public school students are English learners. Again, this rate is highest at Ravenswood City Elementary, where 53% of students are English learners.

In addition to the high concentration, Hispanic/Latinx students at Ravenswood City Elementary are the least likely to have met or exceeded mathematics and English testing standards in the county.

Countywide 27% of Hispanic/Latinx students met or exceeded mathematics testing standards and 40% met or exceeded English testing standards. These almost double the 15% and 21% in Ravenswood City.

Many high schoolers in the county met admission standards for a University of California (UC) or California State University (CSU) school. Of the high school districts in San Mateo County, Sequoia Union had the highest rate of graduates who met such admission standards at 69% followed by San Mateo Union High with 68%. Pacific Islander, Hispanic/Latinx, and Black/African American students in the Sequoia Union district were less likely to meet the admission standards with rates of 38%, 55%, and 50% respectively.

Despite the high share of students meeting college admission standards, Sequoia Union has the second to lowest college going rate, at 70%. The highest rate was 77% in San Mateo Union High.

In addition, Sequoia Union district has the highest dropout rate in the County (10%), and dropout rates among Pacific Islander (20%), Hispanic/Latinx (16%), and Black/African American (12%) students are much higher.

Employment. The top industry by number of jobs in East Palo Alto is the health and educational services, followed by retail, and arts, recreation, and other services. The top industries by workers living in East Palo Alto are the health and educational services, professional and managerial services, and arts, recreation, and other services.

East Palo Alto has a lower job to household ratio when compared to the county at 0.57 and 1.59 respectively. This makes the city an exporter of workers to other communities.

The city also has a higher unemployment rate than the county and the Bay Area.

TCAC’s economic opportunity score is comprised of poverty, adult educational attainment, employment, job proximity, and median home value. East Palo Alto scores are below 0.50 and Chapter 4 – Page 31
areas with the lowest economic opportunity scores—below 0.25— are concentrated in the part of the city that borders Menlo Park and are east of Highway 101.

HUD’s job proximity index shows these areas are in relatively close proximity to jobs. On a scale from zero to 100 where 100 is the closest proximity to jobs the majority of the city scores above

60. Transportation. This section provides a summary of the transportation system that serves East Palo Alto and the broader region including emerging trends and data relevant to transportation access in the city. The San Mateo County Transit District acts as the administrative body for transit and transportation programs in the county including SamTrans and the Caltrain commuter rail. SamTrans provides bus services in San Mateo County, including Redi-Wheels paratransit service.

In 2018, the Metropolitan Transportation Commission (MTC), which covers the entire Bay Area, adopted a coordinated public transit and human services transportation plan. While developing the coordinated plan, the MTC conducted extensive community outreach about transportation within the area. That plan—which was developed by assessing the effectiveness of how well seniors, persons with disabilities, veterans, and people with low incomes are served—was reviewed to determine gaps in services in San Mateo and the county overall. Below is a summary of comments relevant to East Palo Alto and San Mateo County. “San Mateo’s PCC and County Health System, as well as the Peninsula Family Service Agency provided feedback. The most common themes expressed had to do with pedestrian and bicycle needs at specific locations throughout the county, though some covered more general comments such as parked cars blocking sidewalk right-of-way and a desire for bike lanes to accommodate motorized scooters and wheelchairs. Transportation information, emerging mobility providers, and transit fares were other common themes.

While some comments related to the use of car share, transportation network companies (TNCs), or autonomous vehicles as potential solutions, other comments called for the increased accessibility and affordability of these services in the meantime.”49 Transit improvements recommended for East Palo Alto include:
“East Palo Alto individuals do not have direct, fixed-route service to San Mateo Medical Center. A transfer and drop off is located at El Camino Real and 37th Avenue, but patients are still required to walk the remaining distance up a hill to the SM Medical Center (County Hospital). The cost of this trip and transfers is a great hardship for low income individuals. Craig added that getting to this medical facility is a hardship for many people because of the distance to the stop and the terrain.”
49 https://mtc.ca.gov/sites/default/files/MTC_Coordinated_Plan.pdf Chapter 4 – Page 32
A partnership between the World Institute on Disability and the MTC created the research and community engagement project TRACS (Transportation Resilience, Accessibility & Climate Sustainability). The project’s overall goal is to, “stimulate connection and communication between the community of seniors and people with disabilities together with the transportation system– the agencies in the region local to the San Francisco bay, served by MTC.”50 As part of the TRACS outreach process, respondents were asked to share their compliments or good experiences with MTC transit. One respondent who had used multiple services said, “it is my sense that SamTrans is the best Bay Area transit provider in terms of overall disability accommodation.”
The San Mateo County Transit District updated their Mobility Plan for Older Adults and People with Disabilities in 2018. According to the district, the county’s senior population is expected to grow more than 70% over the next 20 years and the district is experiencing unprecedented increases in paratransit ridership. The plan is targeted at developing effective mobility programs for residents with disabilities and older adults including viable alternatives to paratransit, partnerships, and leveraging funding sources.51 MTC also launched Clipper START—an 18-month pilot project— in 2020 which provides fare discounts on single transit rides for riders whose household income is no more than double the federal poverty level.52
Environment. TCAC’s opportunity areas environmental scores are based on the CalEnviroScreen 3.0 indicators, which identify areas disproportionately vulnerable to pollution sources such as ozone, PM2.5, diesel PM, pesticides, toxic release, traffic, cleanup sites, groundwater threats, hazardous waste, impaired water bodies, and solid waste sites.

East Palo Alto has worse scores than neighboring communities. The city also scores lower on the California Healthy Places Index (HPI) developed by the Public Health Alliance of Southern California (PHASC).

The HPI includes 25 community characteristics in eight categories including economic, social, education, transportation, neighborhood, housing, clean environment, and healthcare.53 The area east of Highway 101 close to Menlo Park scores the lowest on the HPI.

Disparities in access to opportunity. Data show that racial and ethnic minorities are more likely to live in low resource areas compared to non-Hispanic White residents. Two thirds (64%) of the population living in low resource areas are Hispanic/Latinx. TCAC’s composite opportunity score for East Palo Alto shows census tracts in the west of Highway 101 and Tracts 50 https://wid.org/transportation-accessibility/
51https://www.samtrans.com/Planning/Planning_and_Research/Mobility_Plan_for_Older_Adults_and_People_with_ Disabilities.html
52 https://mtc.ca.gov/planning/transportation/access-equity-mobility/clipperr-startsm 53 https://healthyplacesindex.org/about/
Chapter 4 – Page 33
closer to Menlo Park fall within low resource areas while the rest of the city is within moderate resource areas.

The Social Vulnerability Index (SVI) provided by the CDC—ranks census tracts based on their ability to respond to a disaster—includes four themes of socioeconomic status, household composition, race or ethnicity, and housing and transportation. The area east of Highway 101 and close to Menlo Park is most vulnerable according to the SVI.

Most of the area east of Highway 101 in East Palo Alto qualifies as a disadvantaged community as defined under SB 535, “disadvantaged communities are defined as the top 25% scoring areas from CalEnviroScreen along with other areas with high amounts of pollution and low populations.”54
Disparities specific to the population living with a disability. Six percent of the population in East Palo Alto are living with at least one disability, a lower share than the county. The most common disabilities in East Palo Alto are ambulatory (4%), cognitive (2.6%), and independent living (2.5%).

Disability
“Disability types include hearing difficulty, vision difficulty, cognitive difficulty, ambulatory difficulty, self-care difficulty, and independent living difficulty.” Source: California Department of Housing and Community Development Guidance, 2021, page 36.

For the population 65 and over the share of the population with an ambulatory or independent living difficulty increases. As mentioned above under access to transportation, San Mateo County is rapidly aging, therefore this population with a disability is likely to increase.

Unemployment is disproportionately high among residents living with a disability at 18% compared to 4% for residents without a disability. High unemployment rates among this population points to a need for increased services and resources to connect this population with employment opportunities.
54 https://oehha.ca.gov/calenviroscreen/sb535
Chapter 4 – Page 34
Chapter 4 – Page 35
SECTION IV. Disparate Housing Needs
This section discusses disparate housing needs for protected classes including cost burden and severe cost burden, overcrowding, substandard housing conditions, homelessness, displacement, and other considerations.

Disproportionate Housing Needs
“Disproportionate housing needs generally refers to a condition in which there are significant disparities in the proportion of members of a protected class experiencing a category of housing need 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.”
Source: California Department of Housing and Community Development Guidance, 2021, page 39.

Housing needs. Population growth in East Palo Alto accelerated during the 2000’s and experienced a sharp decrease after the Financial Crisis. Between 2009 and 2010 the city lost around 5,000 residents (15%). Since then, population trends have followed countywide trends more closely.

Since 2015, the housing permitted to accommodate growth has largely been priced for above moderate- and low-income households with 35 and 34 permits issued respectively. During the same period 20 permits were issued for very low-income households and 6 for above moderate income households. The majority of the housing inventory in East Palo Alto was constructed between 1940 to 1980. The Housing Needs Data Report for East Palo Alto indicates new construction has not kept pace with demand throughout the Bay Area, “resulting in longer commutes, increasing prices, and exacerbating issues of displacement and homelessness.” 55 The variety of housing types available in the city in 2020 are predominately single family (54%) and medium to large scale multifamily (37%). From 2010 to 2020, the multifamily inventory increased less than single family, and the city has a lower share of multifamily housing compared to other communities in the region. 56
Compared to San Mateo County, East Palo Alto’s owner-occupied housing market has a greater share of units priced below $1 million—77% of units in the city fall within this price range compared to 44% in the county. According to the Zillow home value index, home prices 55 Housing Needs Data Report: San Mateo, ABAG/MTC Staff and Baird + Driskell Community Planning, 2021. 56 Housing Needs Data Report: San Mateo, ABAG/MTC Staff and Baird + Driskell Community Planning, 2021.

Chapter 4 – Page 36
experienced remarkable growth in the city but have slowed since 2018. East Palo Alto home values remain more affordable than home values in the County and the Bay Area.

Compared to the county, East Palo Alto has more affordable rental units—42% of units rent for less than $1,500 in the city compared to 19% in the county.

Cost burden and severe cost burden. Fifty eight percent of all renter households in East Palo Alto are cost burdened—spending more than 30% of their gross income on housing costs—and close one third are extremely cost burdened—spending more than 50% of their gross income on housing costs. Cost
burdened households have
less money to spend on other
essentials like groceries,
transportation, education,
healthcare, and childcare.

Extremely cost burdened
households are considered at
risk for homelessness.

The rates of cost burden in
East Palo Alto higher than the
county overall. Lower income
households are more likely to
experience housing cost
burden. Over two thirds of
households earning less
than 30% AMI—considered
extremely low-income
households—are severely
cost burdened.

Chapter 4 – Page 37
There are disparities in housing
cost burden in East Palo Alto by
race and ethnicity.

Hispanic/Latinx (58%) and other
or multi racial (58%) households
experience the highest rates of
cost burden in the city, followed
by Black or African American
(55%) households. Non-Hispanic
White (45%) and Asian/API (47%)
experience the lowest cost
burden.

In areas where renters are cost
burdened, it is likely that
homeowners are also
overpaying for housing. The
map below shows that all
homeowners in East Palo Alto
dedicate 40-60% of their
income towards their home.

The concentration of cost
burden extends west into
Menlo Park, but stops south of
East Palo Alto. This suggests
that south of the city, people
have incomes that are
adequate enough to keep pace
with housing costs.

Overcrowding. The majority
of households (74%) in East Palo Alto are not overcrowded—indicated by more than one occupant per room. However, the rates of overcrowdings are significantly higher than the county (26% v. 8% in the county). Renter households are significantly more likely to be overcrowded with 35.8% of households with more than one occupant per room compared to

11.1% of owner households.

Racial and ethnic minorities are more likely than non-Hispanic White households to experience overcrowding. Hispanic/Latinx households (44%), and other or multiple race households (36%), experience the highest rates of overcrowding. Low- and moderate-income households are also more likely to be overcrowded.

Chapter 4 – Page 38
Geographically,
overcrowded households
are concentrated in the
same areas as cost
burdened renter
households, to the west of
Highway 101 and closer to
Menlo Park. The map below
shows overcrowding in the
region. Outside of East Palo
Alto and Menlo Park there
are less households
experiencing overcrowding,
suggesting that households
in those regions are able to
afford homes that
accommodate their
household size or do not
have to double-up to afford
the home.

Substandard Housing. Data on housing condition are very limited, with the most consistent data available across jurisdictions found in the American Community Survey (ACS)— which captures units in substandard condition as self-reported in Census surveys. In East Palo Alto, renter households are also more likely to have substandard kitchen and plumbing facilities compared to owner households. Generally, a low share of households are lacking kitchen or plumbing. For renters, 2% are lacking kitchen facilities while 1.6% are lacking plumbing. For owners, 1.5% are lacking or plumbing facilities.

Chapter 4 – Page 39
As shown in Figure IV-35, excluding Redwood City, East Palo Alto has the highest percentage of households experiencing severe housing problems in the region. As previously noted, housing condition data are limited, making it difficult to explain why a greater proportion of households in East Palo Alto live in substandard conditions. It could, however, be attributed to East Palo Alto’s housing costs being some of the highest in the region for its lower income population. With such high costs, households—especially lower-income households and renters—may have no option but to live in substandard conditions as that is all they can afford. Alternatively, it may also be related to East Palo Alto’s higher proportion of residents over the age of 5 identifying as speaking English not well or not at all (13.8% v. 8% throughout the entire region)57 as residents may be unaware of their rights, resources to contact, or hesitant to engage with landlords or property owners and managers.

Chapter 2, Section 2.12.2.D of the Housing Element provides a description of where substandard housing is located throughout the City of East Palo Alto.

Homelessness. In 2019, 1,512 people were experiencing homelessness in the county (107 people in East Palo Alto), 40% of people were in emergency or transitional shelter while the remaining 60% were unsheltered. The majority of unsheltered people experiencing homelessness were in households without children. The majority of people in transitional housing were in households with children.

People who identify as American Indian or Alaskan Native (6% homeless, less than 1% general population), Black/African American (13%, 2%), White (67%, 51%), and Hispanic/Latinx (38%, 28%) are overrepresented in the homeless population compared to their share of the general population. People struggling with chronic substance abuse (112 people), severe mental illness (305), and domestic violence (127) represent a substantial share of the homeless population in 2019.

Displacement. Owner households generally enjoy a greater amount of housing stability whereas renter households are more mobile. In East Palo Alto all of the 466 income assisted rental units are at low risk for displacement. In San Mateo County, 417 units are at risk—8% of the total assisted housing units in the county.
57https://www.cityofepa.org/sites/default/files/fileattachments/housing/page/19915/c2_abag_mtc_housing_needs_da ta_report_east_palo_alto_w_toc_1.pdf.

Chapter 4 – Page 40
Displacement Sensitive Communities
“According to the Urban Displacement Project, communities were designated sensitive if they met the following criteria:
 They currently have populations vulnerable to displacement in the event of increased redevelopment and drastic shifts in housing cost. Vulnerability is defined as:
➢ Share of very low income residents is above 20%, 2017 ➢ AND
➢ The tract meets two of the following criteria:
− Share of renters is above 40%, 2017
− Share of people of color is above 50%, 2017
− Share of very low-income households (50% AMI or below) that are severely rent burdened households is above the county median, 2017
− They or areas in close proximity have been experiencing displacement pressures. Displacement pressure is defined as:
• Percent change in rent above county median for rent
increases, 2012-2017
OR
 Difference between tract median rent and median rent for surrounding tracts above median for all tracts in county (rent gap), 2017”
Source: https://www.sensitivecommunities.org/.

According to the Urban Displacement Project, the entire East Palo Alto area is vulnerable to displacement. An estimated 1,818 owner and 3,158 renter households are susceptible to or experiencing displacement. The highest concentration of renter households (over 80%) is found west of Highway 101.

Natural disasters. Natural disasters, specifically flooding, also places East Palo Alto residents at greater risk for displacement. As shown in Figure IV-31, over half of East Palo Alto is federally considered a flood hazard area, with areas located North and Northeast of Highway 101 at particular high risk of natural disasters.

Chapter 4 – Page 41
To preemptively address this threat to residents, the City implemented an ordinance in Chapter

14.12 of its Municipal Code titled “Tenants Displaced by Disasters.”58 The ordinance qualifies a disaster as any unforeseen circumstance that causes damage or loss including, but not limited to, fires, floods, earthquakes, and other accidents. According to the City’s Code, once repairs (due to a disaster) are completed, landlords must offer to the tenant the same unit under the same terms and conditions within 30 days. The tenant then has 30 days to accept or reject the offer and, if accepted, has 45 days to reoccupy the unit. Costs to repair damage not covered by insurance can legally be “passed through to the tenant”59 but tenants must be notified 30 days prior to rent increases.

Access to mortgage loans. Disparities by race and ethnicity are also prevalent for home mortgage applications, particularly in denial rates. Hispanic/Latinx (41% denial rate), and Black or African American (43%) have the highest denial rates for mortgage loan applications in 2018 and 2019. Conversely, non-Hispanic Asian (22%), and White households (18%) have the lowest rates during the same time. 58https://library.municode.com/ca/east_palo_alto/codes/code_of_ordinances?nodeId=EAPAALCA. 59 Ibid.

Chapter 4 – Page 1
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Chapter 5 – Page 1
5 SITES INVENTORY ANALYSIS
A critical component of the Housing Element is identification of sites for future housing development, and evaluation of the ability of these sites to accommodate the City’s share of regional housing needs as determined by the Association of Bay Area Governments (ABAG).

Regional Housing Needs Allocation (RHNA)
California state law requires that each city and county has land zoned to accommodate its fair share of regional housing needs over the course of the Housing Element planning period.

The California Department of Housing and Community Development (HCD) is responsible for determining the regional housing needs allocation (RHNA) for each region’s planning body. The Association of Bay Area Governments (ABAG) adopted a methodology for the RHNA in the Bay Area covering the 2023-2031 planning cycle (also known as the sixth cycle) and dividing housing needs into four income categories: very low-, low-, moderate-, and above moderate- income. HCD determined that the projected housing need for the Bay Area region is 441,176 new housing units for the sixth cycle Housing Element planning period. ABAG allocated this projected growth to the various cities and unincorporated county areas within the ABAG region, creating the RHNA. East Palo Alto’s RHNA for the projection period is 829 housing units, with the units distributed among the four income categories as shown in Table 5.0.A. As illustrated in this chapter, East Palo Alto has sufficient capacity under existing land use policy to meet its 2023-2031 RHNA obligations.

Table 5.0.A: East Palo Alto RHNA 6
Income Group Percent of
County Area
Median Income
(AMI)
Number of
RHNA 6
Housing Units
Percentage
of Units
Very Low Income (VLI) 0-50% 165 20%
Low Income (LI) 51-80% 95 11%
Moderate Income (MOD) 81-120% 159 19%
Above Moderate Income
(Above Mod)
120%+ 410 50%
Total 829 100%
Sites Inventory
For the Sites Inventory, jurisdictions must provide a site-by-site analysis of parcels in the City where housing development is expected to occur over the eight-year planning period to meet RHNA goals. Using an HCDprovided form, jurisdictions must provide information about each site to illustrate the key assumptions used to Chapter 5 – Page 2
calculate the estimated number of units. This form is included as Appendix A. The total number of units, by income category, from the sites in the Sites Inventory must meet or exceed the City’s RHNA.

While cities and counties are only required to plan for 100 percent of the RHNA goals, East Palo Alto’s sites inventory targets approximately 216 percent of the required RHNA, or approximately 1794 homes. Planning for more housing allows for more flexibility in future development and in ensuring housing development goals are met. The City will rezone its Ravenswood Business District/Four Corners Specific Plan Area to allow for additional housing density in mixed use zones. With these rezonings, the City will have enough development sites to exceed RHNA obligations and meet a 116 percent surplus of the RHNA 6 target.

Each site must be detailed in the Sites Inventory list with the following:

Table 5.0.A: Summary of Sites Inventory Details
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 lower-income 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 Chapter 5 – Page 3
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.

AB 725
For jurisdictions that are considered Metropolitan, the Housing Element must identify at least 25 percent of the remaining moderate and above moderate RHNA on sites that allow at least four units of housing (e.g., four plex or greater) (Gov. Code, § 65583.2, subd. (c)(4)). At least 25% of the City of East Palo Alto’s RHNA 6 moderateand above-moderate-income units are located in zoning districts that allow for at least four units or greater.

Extremely Low-Income Units
Based on Figure 11 in Appendix B, 3,837 of East Palo Alto’s households are 0-50% area median income (AMI), while 1,918 are extremely low-income. Therefore, extremely low-income (ELI) households represent 50 percent of households who are 0-50% AMI, as 1,918 divided by 3,827 is 50%. The projected housing need for ELI households is therefore 83 ELI units. This methodology aligns with HCD’s guidance to use U.S. Census data to calculate the percentage of very low-income RHNA that qualifies as extremely low-income households.

Half or 50 percent of the very low-income households in the RHNA (165) is 83 units.

There are approximately 231 projected extremely low-income units for the 2023-2031 planning period (half of 461 projected very low-income units is 230.5). The City’s Inclusionary Housing Ordinance (IHO) requires for rental developments to provide on-site rental units as inclusionary compliance broken down as follows: 5% ELI (at 35% AMI), 10% VLI (at 50% AMI) and 5% LI (at 60%). If the inclusionary requirement for rental units results in a fraction of a unit, the developer can provide a unit (such as an Accessory Dwelling Unit) at the lowest level of affordability (35% AMI), or any other Alternative Compliance Option, to be approved by City Council. Based on this data and the City’s IHO, the City will continue to prioritize extremely low-income units to address the City’s housing needs.

Sites Identified in Prior Planning Periods
Appendix D1 indicates which parcels in the City’s RHNA 6 sites inventory were identified in prior planning periods. Sites identified in prior planning periods cannot be deemed adequate to accommodate the housing needs for lower-income households unless a program, meeting statutory requirements, requires rezoning within three years. Of the sites identified in previous planning years, some are already approved and are now proceeding to the building permit stage. The remaining projects do not require rezoning within three years, as they are not designated to accommodate the housing needs for lower-income households or they have already been rezoned to allow for the number of units designated in the sites inventory.

Chapter 5 – Page 4
Replacement Housing Requirements
According to Government Code section 65583.2, subdivision (g), if the sites inventory identifies sites with existing residential uses, the housing element must include a replacement housing program for units affordable to lower-income households. Projects in the City are subject to Senate Bill 330 (SB 330), when applicable, and are required to provide replacement units.

Small Sites, Large Sites, and Vacant Sites
According to HCD guidance for choosing suitable sites to accommodate the RHNA, lower-income 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.61 Nonvacant sites should not exceed 50% of all sites in the Sites Inventory.

Sites smaller than half an acre or greater than ten acres are deemed inadequate to accommodate housing for lower-income households unless it is demonstrated, with sufficient evidence, that sites of equivalent size and affordability were successfully developed during the prior planning period or other evidence demonstrates the suitability of these sites.

Not all sites in the City’s Sites Inventory fall within the 0.5-to-10-acre limits. These sites may be used to account for Above-Moderate (market-rate) units only.62 Other sites have already been approved or will be receiving approval soon, and sufficient evidence is provided in Appendix D1 demonstrating suitability of the sites. 63 Well over half of the sites are vacant, with some key redevelopment sites.

Quantified Objectives
In addition to the sites inventoy, the City needs to provide an estimate of actual housing units that will be produced, rehabilitated and preserved. Table 5.0.B summarizes East Palo Alto’s quantified objectives for the next five years. Unless specifically identified, these numbers do not correspond to specific development proposals, rather than are an attempt to estimate what may happen in the future. 61 This is the “default density” for lower-income housing for San Mateo and other metropolitan jurisdictions, according to HCD:
https://www.hcd.ca.gov/planning-and-community-development/housing-elements/building-blocks/analysis-sites-and-zoning 62 For example, 2277 University and Waterfront are less than half an acre and are only counted toward the above-moderate income category.
63 See Table 5.2.A and Appendix D1.5.2 for the already approved projects and Table 5.3.A and Appendix D1.5.3 for projects expected to be approved soon.

Chapter 5 – Page 5
Table 5.0.B Quantified Objectives Over Next 5 Years: 2023-2028 Program New
Construction Renovation Conservation
Extremely Low
Income 115 19 0
Very Low Income 116 83 0
Low Income 122 19 0
Moderate Income 171 2 0
Above Moderate
Income
375 0 0
Total 899 123 0
Note: The Quantified Objectives for new construction over the next five years were taken as a half of the total opportunity sites numbers for each category: 231 VLI/ELI, 122 LI, 171 MOD, 375 Above-Mod. [Intentionally Left Blank]
Chapter 5 – Page 6

5.1 OVERVIEW OF TYPES OF SITES IN THE SITES INVENTORY
The number of estimated units total over the RHNA 6 period from all sites included in the Sites Inventory, also referred to as “Housing Opportunity Sites,” is summarized in Table 5.1.A. These Housing Opportunity Sites serve as quantified objectives for 2023-2031 because they provide the maximum number of housing units that can be constructed and redeveloped in the City over an eight-year timeframe. For the 2023-2031 housing cycle, the city’s quantified objectives for construction are 1,794 units, with 704 of those being affordable to East Palo Alto residents (very low income or low income).

Table 5.1.A: Total Units from Sites Inventory Sites vs. RHNA 6 VLI LI MOD Above-Mod Total
Housing Opportunity Sites 461 243 341 749 1794
RHNA 6 165 95 159 410 829
Percentage of RHNA 6 280% 256% 214% 183% 216%
Difference 296 148 182 339 965
Percentage Difference 179% over 156% over 114% over 83% over 116% over Note: Assumed 115 additional Accessory Dwelling Units or ADUs (30% VLI, 30% LI, 30% MOD, and 10% Above-Mod) based on prior years’ ADU counts. See methodology below in Section 5.8.

The East Palo Alto Sites Inventory or Housing Opportunity Sites 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 after July 1, 2022, or in subsequent years. All such units are included in the Sites Inventory and will count towards the 6th RHNA cycle. Taking these unit counts into account, the City can meet and slightly exceed the RHNA in every category.

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 rezoning of the parcel. For these reasons, in many the development proposal or preapplication was used to calculate the realistic capacity of the sites.

The Sites Inventory is broken down into the types of projects listed below (see Sections 5.2 to 5.8), each with its own description and further evidence of potential development, including whether the project is on a vacant site, what stage of the review process it is in, and under what conditions the site is currently in, in Appendix D1. In all the following charts, “Zoned Density” refers to the density permitted for that zoning type. “Assumed Density” is in nearly all cases the density of the proposed project, and in a few cases where rezoning is needed, the density used to calculate the number of units in each income category. Zoning and assumed densities are provided in dwelling units per acre (du/acre). The zoned densities are taken from either the Zoning Code or the Chapter 5 – Page 7
Ravenswood/Four Corners Area Specific Plan (“RBD”) zoning if the project falls within the RBD. City-wide the zoning is consistent with the General Plan because the City of East Palo Alto is not a charter City; it is a general law City. The only inconsistencies pertain to parcels/projects within the RBD area, and are being addressed with the Ravenswood Business District/Four Corners Area Specific Plan update that is currently underway with the tentative completion date of December 2023. [Intentionally Left Blank]
Chapter 5 – Page 8

5.2 ENTITLED OR APPROVED PROJECTS
Table 5.2.A shows an inventory of units that will be produced by projects already underway, including projects approved by planning via entitlements or preliminarily approved to proceed through the SB 9 process64 or the SB 35 process,
65 or substantially advanced in the permitting and approval process, but which have not yet been constructed. State law allows projects that have been approved but are not expected to be completed prior to June 30, 2022 to count toward the City’s RHNA. The units attributable to each project, in total and by income category, are based on specific project documents, and are not an estimate, assumption, or projection.

Collectively, these projects equal 719 units, or over 40 percent of the minimum RHNA target. See Appendix D, Section D1.5.2 for details on these approved projects.

Table 5.2.A: Entitled or Approved Projects
Site Size
(acres)
Zoned
Density
(du/acre)
Assumed
Density
(du/acre)
VLI LI MOD AboveModTotal
965 Weeks 2.52 up to 40 54 42 93 1 136
1804 Bay Rd. .99 up to 50 75 10 65 75
2331 University .89 22 to 65
(MUC-1) 37 4 3 26 33
760 Weeks .52 12 to 22 19 1 1 8 10
120-126 Maple Lane .177 12 to 15 15 4 4
APN 063265300
Runnymede/Clarke .156 12 to 15 15 1 2 3
805 Runnymede .92 up to 12 8 1 1
1215 Cypress .236 up to 12 4 1 1
APN 063186270
Lincoln St.
.254 up to 12 12 1 3 4
Woodland Park
Euclid Improvements

3.9 up to 175 155 271 173 444
990 Garden 1.32 up to 12 6 2 6 8
Total 53 101 275 290 719
Percentage of
RHNA 6
32% 106% 173% 71% 87%
64 SB 9 preliminarily approved projects include 805 Runnymede, 1215 Cypress, and Lincoln St. APN 063186270. 65 SB 35 preliminarily approved projects include 1804 Bay Rd. and 760 Weeks.

Chapter 5 – Page 9

5.3 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. See Appendix D, Section D1.5.3 for details on how these sites were identified to accommodate the RHNA.

Table 5.3: Projects Not Approved, but High Probability of Development Site Size
(acres)
Zoned
Density
(du/acre)
Assumed
Density
(du/acre)
VLI LI MOD AboveModTotal
Four Corners 6.1 up to 60 30 36 144 180
717 Donohoe .66 12
to 22 21 1 2 11 14
2340 Cooley .26 12
to 22 31 1 7 8
842 Green .59 up to
12 5 3 3
1201 Runnymede .93 up to 40 22 4 16 20
755 Schembri 1.381 up
to 15
4 6 6
851 Weeks .65 Up to 40 137 66 23 0 89
Total 102 25 6 187 320
Percentage of
RHNA 6 62% 26% 4% 46% 39%
[Intentionally Left Blank]
Chapter 5 – Page 10

5.4 PROJECTS WITH DEVELOPMENT INTEREST
The following sites have submitted preliminary review planning applications and/or have had substantial conversations with staff. This category consists largely of underdeveloped sites with just a single-family house, very low-density, above-moderate developments with proposed single family-home or townhome subdivisions and some smaller sites (less than 0.5 acres) to develop above-moderate income units. These new proposed developments will be subject to the City’s Inclusionary Housing Ordinance, but inclusionary housing assumptions have not yet been applied given the preliminary stage of the applications. Most of the projects in this Section 5.4 are similar to other projects in the City that have been redeveloped with multiple units. For example, 990 Garden, an 8-unit ownership project (with 2 deed-restricted inclusionary units) on 1.32 acres in R-LD zoning received Zoning Clearance in January 2023. Lincoln St (APN 063-186-270), a 3 rental unit project (with one deed-restricted attached ADU inclusionary unit) on .254 acres in R-LD zoning received approval via SB 9 in July 2022. See Appendix D, Section D1.5.4 for details on how these sites were identified to accommodate the RHNA.

Table 5.4: Projects with Development Interest
Site Size
(acres)
Zoned
Density
(du/acre)
Assumed
Density
(du/acre)
VLI LI MOD AboveModTotal
547 Runnymede .45 12 to 22 15 8 8
1062
Runnymede
.92 up to 12 6 6 6
812 Green .89 up to 12 6 5 5
801 Donohoe .45 12 to 22 6 5 5
807 E. Bayshore .55 up to 22 15 8 8
Total 0 0 0 32 32
Percentage of
RHNA 6 0% 0% 0% 8% 4%
[Intentionally Left Blank]
Chapter 5 – Page 11

5.5 PUBLICLY OWNED SITES WITH POTENTIAL FOR DEVELOPMENT OR

REDEVELOPMENT
These sites include a City-owned site and a site owned by the Ravenswood Elementary School District with housing development interest and a certain level of commitment from the respective agencies. Appendix D2 is a letter from the Ravenswood Elementary School District stating their interest in developing housing at the school site on Bay Road/Ralmar. Appendix D3 is a letter from the County of San Mateo stating their interest in developing affordable housing at the City site at 2277 University, after a land swap. The City will comply with the Surplus Land Act Article 8 (commencing with Section 54220) of Chapter 5 of Part 1 of Division 2 of Title 5 if there is any sale of City property. See Appendix D, Section D1.5.5 for details on how these sites were identified to accommodate the RHNA.

Table 5.5: Publicly Owned Sites with Potential for Development or Redevelopment Site Size
(acres)
Zoned
Density
(du/acre)
Assumed
Density
(du/acre)
VLI LI MOD AboveModTotal
2277 University .36 22 to 60 30 0 20 20
APN 063090080
Bay Rd.

2.59 N/A 30 26 26 26 78
Total 26 26 26 20 98
Percentage of
RHNA 6 16% 27% 16% 5% 12%
[Intentionally Left Blank]
Chapter 5 – Page 12

5.6 SITES WITH NONRESIDENTIAL ZONING, BUT RESIDENTIAL

DEVELOPMENT APPLICATION IN RAVENSWOOD BUSINESS DISTRICT These nonresidential zoning sites are in the Ravenswood Business District (RBD) area and have potential for rezoning to allow for residential development through the Ravenswood Business District/Four Corners Specific Plan update. See Appendix D, Section D1.5.6 for details on how these sites were identified to accommodate the RHNA.

Table 5.6: Sites with Nonresidential Zoning, But Residential Development Application in RBD Site Size
(acre)
Zoned
Density
(du/acre)
Assumed
Density
(du/acre)
VLI LI MOD AboveModTotal
EPA
Waterfront
9 N/A 30 52 208 260
1103 Weeks St
(Harvest the
Landing)

1.6 N/A 60 95 95
1200 Weeks St
(South of
Weeks)

2.7 up to 60
du/acre
30 51 30 81
Total 198 30 0 208 436
Percentage of
RHNA 6 120% 32% 0% 51% 53%
[Intentionally Left Blank]
Chapter 5 – Page 13

5.7 SITES WITH (RE)DEVELOPMENT POTENTIAL IN RAVENSWOOD

BUSINESS DISTRICT
These sites are located in the RBD area and are zoned for relatively dense housing. See Appendix D, Section D1.5.7 for details on how these sites were identified to accommodate the RHNA.

Table 5.7: Sites with (Re)development Potential in Ravenswood Business District Site Size
(acre)
Zoned
Density
(du/acre)
Assumed
Density
(du/acre)
VLI LI MOD AboveModTotal
791 Weeks .89 up to 40 30 22 12 34
1923 Bay Rd. .99 up to 50 40 25 15 40
Total 1.88 N/A N/A 47 27 0 0 74
Percentage of
RHNA 6 28% 28% 0% 0% 9%
[Intentionally Left Blank]
Chapter 5 – Page 14

5.8 ACCESSORY DWELLING UNITS (ADUS)
Accessory Dwelling Units (ADUs) and Junior Accessory Dwelling Units (JADUs) may be counted toward the RHNA based on past permitted units and other relevant factors. An ADU is accessory to a primary residence and has complete independent living facilities for one or more persons. ADUs can be new living spaces, detached or attached, to the primary residence. Existing space within a primary dwelling, an accessory structure, or an attached or detached garages may be converted to an ADU. This form of housing has enormous benefits for both renters and homeowners. Such units are considered natural affordable housing as market rents tend to be lower. These units also provide more flexible housing options for extended families, such as aging parents and adult children. ADUs also offer a solution for seniors to “age-in-place" while creating rental income to cover housing and living costs. This section includes projected ADUs for the eight-year planning period to count toward the RHNA Cycle 6.

Table 5.8.A shows the number of units permitted between the years 2018 to 2022, which can also be found on the California Department of Housing and Community Development’s Annual Progress Reports site. 66 Several
ADU streamlining bills have passed since 2018, which has created a steady growth in ADU permits over the years. In 2022, Senate Bill 9 added further ADU streamlining (see Appendix D1.5.8 for an overview of potential SB 9 sites). With additional state and City policy and program changes underway, the City projects even further growth in ADU permits. Between 2018-2022, the City has issued an average of 14.4 ADU permits per year.

The City projects 115 ADUs being permitted over the next eight-year planning period.

Table 5.8.A: ADU Permitting Trends
Year Permitted ADUs (Total)
2018 0
2019 8
2020 11
2021 30
2022 23
Total (2019-2022) 72
Average (2019-2022) 14.4
Projected (2023-2031) 115
66 See Annual Progress Reports – Data Dashboard and Downloads, https://www.hcd.ca.gov/planning-andcommunity-development/housing-open-data-tools/housing-element-implementation-and-apr-dashboard.

Note that the City will rectify any discrepancies in past Annual Progress Reports stemming from non-standardized labeling of Accessory Dwelling Units, and has started standardizing tracking and data collection.

Chapter 5 – Page 15
Using ABAG’s survey data to distribute the projected units by income category produces the following estimates:

City ADU Regulations
During the past decade, the California Legislature has passed multiple laws to allow ADUs by right in singlefamily and multi-family zoning districts. The objective of these laws is to facilitate the supply of a relatively affordable rental housing type within all residential communities in California. The latest bill, SB 897, took effect January 1, 2023. The City is working toward updating its City ADU regulations to conform with state legislation.

In June 2014, the City Council adopted Ordinance 380 to allow second units/ADUs, garage conversions to habitable space, and guest houses to promote local affordable housing options. Ordinance 380 was the subject of extensive community engagement and reflects the City’s interest in supporting these types of developments.

In January 2017, the City Council amended the ADU Ordinance to bring the regulations into compliance with the 2016 ADU legislation. The updated ADU regulations were codified in Chapter 18.96 of the East Palo Alto Municipal Code (EPAMC) as part of the comprehensive Development Code updates in 2018.

In November 2020, the City revised its ADU ordinance and brought the City's ADU regulations into compliance with then-current state legislation on ADUs. The 2017 ADU Ordinance was a critical reference point, as it provided a baseline of requirements that were adjusted for conformance with state legislation, as well as to reflect the City Council’s approach on such issues as the maintenance of community character through neighborhood compatibility.

The 2023-2031 Housing Element policies and programs provide objectives and milestones to complete a comprehensive amendment of the Development Code ADU regulations to bring provisions and requirements into conformance with current state ADU legislation, and to create greater flexibility and objective design standards.

Table 5.8.B: ADU Estimates for RHNA 6 Period
Income Category Percentage Total
Very low 30% 35
Low 30% 34
Moderate 30% 34
Above moderate 10% 12
Chapter 5 – Page 16
Financial Assistance
The City has a CalHome ADU/JADU loan program (“CalHome Program”) to provide low-interest loans of up to $80,000 to income-qualified homeowners interested in building ADU/JADUs, in exchange for renting their units to income-eligible East Palo Alto households (at 80% area median income). The California State Department of Housing and Community Development (“HCD”) awarded the City with the CalHome program award in an amount of $2 million in July 2020. On October 19, 2021, the City issued an agreement with East Palo Alto Community Alliance and Neighborhood Development Organization (“EPACANDO”) to help administer the CalHome program until June 2024, and launched the program on January 19, 2022. The CalHome Program helps pay for plans and permits, necessary site upgrades, and construction costs.

Since the program launch, EPACANDO has been working with several potential applicants. Knowing the universe of CalHome Program applicants and their overlap with code enforcement issues has led the City to consider other ways to support rehabilitation/repairs and formalize a City legalization program through development code and design review changes. The City is committed to continuing to apply for funding sources that support affordable housing development and rehabilitation, which includes ADUs.

Pre-Review/Approval of ADU Model Plans
With the growing interest among homeowners to construct ADUs, the design and construction industry have responded with model architectural plans and prefabricated or modular units for ADUs which provide “off-theshelf" design options for homeowners. These options can reduce the cost of hiring an architect or designer to prepare a customized plan for a client. While these plans still require a building permit from the City (or for prefabricated or modular units a state certification), the permit process can be simplified and streamlined. The City may consider pre-approved plans as a streamlining option, to provide homeowners with greater assurance that their plans meet building and fire code standards. It should be noted however that Zoning Clearance and a Building Permit are still required to confirm conformance with zoning standards and to review the foundation design, electrical, mechanical, and plumbing work.

Affordable Housing Deed Restriction
While ADUs are recognized as providing a good option for affordable housing, it does not guarantee that an ADU will be offered at an affordable rent or that the ADU will be available as a rental unit. Homeowners may choose to build an ADU to create more living space for an extended or growing family without the intent of generating income from the unit. The City may explore offering financial incentives if a homeowner, non-profit organization, or other entity is willing to record a deed restriction on a property to maintain an ADU as an affordable rental or ownership unit for a defined time period. Discussions have included targeting these units for veterans, disabled individuals, at-risk youths, unhoused persons, or other special needs populations.

Currently, the City has a Below Market Rate Program administrator that ensures deed-restriction compliance of ownership/for-sale units. In mid-2023, the City will be issuing another Request for Proposals to include Chapter 5 – Page 17
monitoring of deed-restricted rental and ownership Accessory Dwelling Units as part of its Below Market Rate administration and monitoring program.
[Intentionally Left Blank]
Chapter 5 – Page 18

5.9 AFFIRMATIVELY FURTHERING FAIR HOUSING CONSIDERATIONS FOR

SITES INVENTORY
AB 686 requires an analysis of sites identified to meet RHNA obligations for their ability to affirmatively further fair housing.

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.68 Furthermore, the Sites Inventory should limit the number of lower-income housing sites in areas deemed Racially/Ethnically Concentrated Areas of Poverty (“R/ECAPs”).69 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 the Woodland Park Communities Euclid Improvements project. 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.

The following is an analysis of the proposed sites for future development or “Sites Inventory,” which includes:
sites that have been ministerially approved or entitled projects; projects not yet approved, but highly probable; projects with lower probability of development, but with development interest; and non-residential zoning sites with residential development applications.

The sites inventory is well-distributed throughout the city, with the exception of the Ravenswood Business District (RBD) / 4 Corners Specific Plan area in the northeast of the city, which is uniquely available to address 68 TCAC opportunity map: https://belonging.berkeley.edu/2022-tcac-opportunity-map 69 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 (majority 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.

Chapter 5 – Page 19
the community’s jobs and housing needs. Maps 5.9.A to 5.9.C illustrate the city’s structure and where referenced RBD/4 Corners Specific Plan area sites reside. [Intentionally Left Blank]
Chapter 5 – Page 20
Map 5.9.A: Land Use Characteristics
Source: Vista 2035 General Plan, City of East Palo Alto Chapter 5 – Page 21
Map 5.9.B: City Structure, Activity Centers, and Transit Hubs
Map 5.9.C: RBD / 4 Corners Specific Plan Update
Source: Vista 2035 General Plan, City of East Palo Alto Source: Vista 2035 General Plan, City of East Palo Alto Chapter 5 – Page 22
Sites Inventory and Area Median Income
Map 3 provides the sites inventory overlayed on median household incomes based on the 2022 State Income Limits for San Mateo County.

The majority of the sites inventory is in census block areas with very low-income households (area median incomes between $54,800 - $91,350) and low-income households (area median incomes between $91,350-$146,350). There is only one census block area that consists of higher-income earners, and that is a single-family home neighborhood in the lower East side with no proposed housing development.

Sites Inventory and R/ECAPs
Three edge Racially/Ethnically Concentrated Areas of Poverty (R/ECAPs) are located in East Palo Alto, west of the Highway 101 (on the “Westside”). Maps 4 to 7 provide insight into the location of these edge R/ECAP areas, as they demonstrate the location of racial and ethnic populations, and the lowest income areas. The maps show that three census blocks in East Palo Alto, which are located west of Highway 101, are extremely low-income and have a majority of people of color. One redevelopment project (Woodland Park Communities Euclid Improvements) is located in this area, and will replace the existing 160 rent stabilized units one-for-one to allow these extremely low-income households to return, while also building 444 net new units (271 of which are considered moderate income and 173 of which are considered abovemoderate income), promoting greater integration in the Westside and lower racially/ethnically concentrated areas of poverty.

Source: ACS Table B19013, 2015-2019 5-Year Estimate.

Map 3: Sites Inventory and Median Household Income
Chapter 5 – Page 23
Map 4: Sites Inventory and Hispanic/Latinx Population (2020) Map 5: Sites Inventory and Black/African American Population (2020) Source: ACS Table B19013, 2015-2019 5-Year Estimate.

Chapter 5 – Page 24
Map 6: Sites Inventory and Asian/Pacific Islander Population (2020) Map 7: Sites Inventory and Median Household Income Source: ACS Table B19013, 2015-2019 5-Year Estimate.

Chapter 5 – Page 25
Distribution of Lower, Moderate- and Above-Income Units in the Sites Inventory The following maps demonstrate where the future development of housing units is located, broken down by affordability levels.

Sites Inventory – Very Low-Income Units
Very low-income units are primarily planned on the East side of Highway 101, where on average, there are fewer extremely low-income households. They are also primarily located in the Ravenswood Business District Specific Plan area (RBD) in close proximity to future job centers and in accordance with the City’s transit-oriented development plan. They are also located along transited streets such as Bay Road “Main Street,” University Avenue corridor, and Pulgas Avenue. This helps
create a more even distribution of lower-income
units due to a high proportion of
extremely low-income units
currently residing on the Westside
of Highway 101.
• 1804 Bay Road (10 units)
• 1923 Bay Rd. (25 units)
• 791 Weeks (22 units)
• 851 Weeks (66 units)
• 965 Weeks Street (42
units)
• EPA Waterfront (52 units)
• Four Corners 1675 Bay
Rd. (36 units)
• Harvest The Landing
Housing Offsite 1103
Weeks (95 units)
• Lincoln St. (APN 063-
186-270) (1 unit)
• Ravenswood Elementary
School District Bay Rd. Site (26 units)
• South Of Weeks (51 units)
Map 8: Distribution of Very Low-Income Units in Sites Inventory Chapter 5 – Page 26
Sites Inventory – Low-Income Units
Low-income units are primarily planned on the East side of Highway 101, where on average, there are currently fewer extremely low-income households. They are planned along transited streets such as: Bay Road “Main Street,” University Avenue corridor, Weeks street, Pulgas Avenue, and East Bayshore Road. This helps create a more even distribution of lower-income units due to a high proportion of extremely low-income units currently residing on the Westside of Highway 101.
• 1923 Bay Rd. (15 units)
• 2340 Cooley (1 unit)
• 717 Donohoe (1 unit)
• 760 Weeks Street (1 unit)
• 791 Weeks (12 units)
• 851 Weeks (23 units)
• 965 Weeks Street (93 units)
• 990 Garden (2 unit)
• APN 063265300
(Runnymede/Clarke) (1 unit)
• Ravenswood Elementary
School District Bay Rd.

Site/APN 063090080 (26
units)
• South Of Weeks (1200
Weeks St) (30 units)
• University Clarum Corner
2331 University (4 units)
Map 9: Distribution of Low-Income Units in Sites Inventory Chapter 5 – Page 27
Sites Inventory Moderate Income Units
Moderate-income units are planned
on the East side of Highway 101,
where on average, there are fewer
extremely low-income households,
and on the West side of Highway 101,
where on average, there are more
extremely low-income households.

They are planned along transited
streets such as: Bay Road “Main
Street,” University Avenue corridor,
Pulgas Avenue, and East Bayshore
Road.
• University Clarum Corner
2331 University (3 units)
• 1201 Runnymede (4 units)
• 760 Weeks Street (1 unit)
• 717 Donohoe (1 unit)
• Ravenswood Elementary
School District Bay Rd. Site
(26 units)
• Woodland Park Euclid
Improvements (271)
Map 10: Distribution of Moderate-Income Units in Sites Inventory Chapter 5 – Page 28
Sites Inventory Above-Moderate Income Units
Above moderate-income units are evenly
distributed throughout the City, and
scattered along transited streets such as:

Bay Road “Main Street,” University
Avenue corridor, Pulgas Avenue, and
West Bayshore Road. They are also
concentrated in the RBD/4 Corners
Specific Plan area.
• 965 Weeks Street (1 unit)
• 1804 Bay Road (65 units)
• University Clarum Corner 2331
University (26 units)
• 1201 Runnymede (16 units)
• 760 Weeks Street (8 units)
• 120-126 Maple Ln (4 units)
• APN 063265300 (Runnymede/
Clarke) (2 units)
• Lincoln St. (3 units)
• Woodland Park Communities
Euclid Improvements (173 units)
• Four Corners 1675 Bay Rd. (144
units)
• 717 Donohoe (11 units)
• 990 Garden (6 units)
• 2340 Cooley (7 units)
• 1215 Cypress (1)
• 547 Runnymede (8 units)
• 805 Runnymede (1 unit)
• 1062 Runnymede (6 units)
• 812 Green (5 units)
• 842 Green (3 units)
• 801 Donohoe (5 units)
• 755 Schembri Lane (6 units)
• 807 E. Bayshore (8 units)
• EPA Waterfront (208 units)
• 2277 University (20 units)
Map 11: Distribution of Above-Moderate-Income Units in Sites Inventory Chapter 5 – Page 29

5.10 SITES INVENTORY PROXIMITY TO AREAS
East Palo Alto is only 2.5 square miles and has limited variation between its census tracts. The following describes where the sites inventory units are distributed within the city. o High-resourced areas:
▪ 0.0% of residents in East Palo Alto live in neighborhoods identified as “Highest Resource” or “High Resource” areas by State-commissioned research. All the sites inventory is therefore within “Low Resource” or “High Segregation and Poverty” areas.
o High proficiency K-12 education institutions:
▪ According to Figure III-1, a majority of the City has a TCAC Opportunity Area Education Score of less than 0.50. Most of the sites inventory is therefore in areas with less positive education outcomes. There is little the City can do to change these outcomes without broader, state and district policy changes affecting school choice.
o Low social vulnerability:
▪ According to Figure III-15, a majority of the City has a higher Social Vulnerability Index. Most of the sites inventory is therefore in areas with high social vulnerability. o Good jobs proximity:
▪ East Palo Alto has more low-wage residents than low-wage jobs (where low-wage refers to jobs paying less than $25,000). At the other end of the wage spectrum, the City has more high-wage residents than high-wage jobs (where high-wage refers to jobs paying more than $75,000).

Discussions are currently underway to ensure that the sites in the Ravenwood Business District Specific Plan provide mixed-use development that provides a job-housing balance addressing the community’s needs.
o Healthy places:
▪ According to Figure III-11, a majority of the City has a Healthy Places Index less than 60%, which is lower than surrounding communities. Most of the sites inventory is therefore in areas with lower health.
o Flood hazards:
▪ A large portion of East Palo Alto is within the flood zone. See Flood Zone map here. Most sites inventory are therefore in high-flood risk areas. The largest contributors to 100-year storm flooding in East Palo Alto are spills from San Francisquito Creek and tidal inundation from San Francisco Bay. Learn about the City’s and San Francisquito Joint Powers Authority’s plans to add improved flood protection along the south and west sides of East Palo Alto and decrease flood risk in the 2014 Storm Drain Master Plan here.

Chapter 5 – Page 30
o Access to transportation:
▪ East Palo Alto has approximately seven SamTrans bus routes: 81, 83, 280, 281, 296, 296O, and 397. The majority of sites inventory are located along major transit coordinators (i.e., University Avenue, Bay Road, Pulgas Avenue, East Bayshore, and West Bayshore). See bus routes here. o Water access:
▪ Most of the City’s water connections (about 80%) are served by the City of East Palo Alto water system operated by Veolia, which supplies water from the San Francisco Public Utilities Commission (SFPUC). The remaining connections are served by either Palo Alto Park Mutual Water Company or O’Connor Tract Co-Op Water Company. See the City’s water service areas map here.
[Intentionally Left Blank]
Chapter 6 – Page 1
6 POLICIES AND PROGRAMS
This chapter incorporates themes and findings from several other sections of the Housing Element, including input from the community through various channels of community outreach; analysis of fair housing issues in compliance with Affirmative Furthering Fair Housing (AFFH) requirements; review of housing needs data; review of governmental and non-governmental constraints; and evaluation of the current 2015-2023 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 next eight years to address the City’s affordable and fair housing challenges and improve the overall state of housing in East Palo Alto.

This chapter builds upon the City’s accomplishments since RHNA 5, outlined in the Review of the Prior Housing Element chapter, positioning the City to pursue policies and programs aimed at addressing the City’s most challenging housing needs.

6.1 STRUCTURE OF RHNA 6 HOUSING ELEMENT WORKPLAN AND

GUIDING PRINCIPLES
In this Housing Element Workplan, there are nine overarching goals. Each goal is organized into objectives, which are then further broken down into policies and programs in a workplan format, with an emphasis on the timeline, staffing, and other resources needed to accomplish each one.

Common themes from the public, which, along with the AFFH Analysis, formed the guiding principles of this Housing Element Workplan, include: the need for more affordable housing to serve all household income categories, special needs populations, and racial groups, ensuring there is a jobs-housing balance, ensuring new jobs do not create displacement pressures on current residents and particularly vulnerable populations, and creating new and rehabilitated units that have better habitability.

6.2 AFFIRMATIVELY FURTHERING FAIR HOUSING CONSIDERATIONS

FOR POLICIES AND PROGRAMS
Addressing the issue of fair housing, equity and access is a key goal for the City, and as such, an analysis of the City’s efforts to affirmatively further fair housing is not only a stand-alone objective, but one that is incorporated throughout the Housing Element, including the policies and programs.

Chapter 6 – Page 2
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:
f. Rent increased more than I could pay; and
g. Landlord wanted to rent to someone else.
h. 29% of respondents indicated they had been discriminated against when looking for housing.

The AFFH Appendix C3 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 Chapter 6 – Page 3
• 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 in the AFFH Chapter identifies the following policy and program ideas, which are incorporated into the RHNA 6 Goals, Objectives, Policies & Programs. References to applicable Housing Element policies and programs for each fair housing issue are noted:
• Anti-Displacement Plan – 1.15, 1.17. 4.9, 4.11, 4.12, 5.1, 5.7, 5.8, 5.9, 6.1, 6.4, 10.1 • Rental registry – 3.2, 3.3, 3.4
• Homebuyer assistance program – 2.1, 2.2, 2.3, 2.4, 3.1, 9.4 • Mortgage and rental assistance (beyond pandemic) – 4.9, 4.11, 4.12 • Foreclosure assistance – 4.9
• Living wage employment ordinances – 4.14
• Housing counseling – 5.7, 5.8, 5.9,
• Affordable housing development – 1.6, 1.15, 1.17, 1.22, 1.23, 1.24 • Housing rehabilitation programs – 1.14, 4.3, 4.4, 4.5, 4.6. • Affordable housing units for larger families – 1.4, 7.7 • Alternative affordable home ownership models – 4.10
• Standardized development review metrics (including ADUs and SB 9) 1.1, 1.2, 1.3, 1.4,

1.11, 1.12, 1.21, 1.21, 1.25, 10.7, 10.8
• Special needs populations – 1.4, 4.8, 5.9, 7.1
• Unhoused population – 7.2, 7.3, 7.4, 7.5, 7.6, 10.2

6.3 GOALS, POLICIES AND PROGRAMS SUMMARY
Table 6.1 summarizes the RHNA 6 Goals, Objectives, Policies & Programs. This is followed by a detailed overview of the implementation plan for each. The main RHNA 6 Goals include:
• Goal 1: Create more housing opportunities, and more housing that is affordable to East Palo Alto residents.

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• Goal 2: Create homeownership opportunities for East Palo Alto residents and stability for existing homeowners.
• Goal 3: Promote stewardship and preservation of the City’s existing affordable housing stock. • Goal 4: Prevent displacement of East Palo Alto residents. • Goal 5: Apply environmental justice principles in planning for new housing development. • Goal 6: Promote safe and healthy housing in East Palo Alto. • Goal 7: Create more housing opportunities for special needs households, including large households, people at risk of or experiencing homelessness, and individuals with disabilities. • Goal 8: Improve transparency and communication between the City and the public on housing issues.
• Goal 9: Build City capacity for long-term housing planning and implementation of a range of Housing programs and initiatives.
• Goal 10: Amend zoning and other development regulations to facilitate the construction of housing.

For an overview of how these goals compare to RHNA 5 goals, see Review of Prior Housing Element chapter.
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Chapter 6 – Page 5
Table 6.1: Summary of RHNA 6 Goals, Objectives, and Policies & Programs Goal 1: Create more housing opportunities, and more housing that is affordable to East Palo Alto residents.

Implement measures to reduce overall processing times for residential development applications while maintaining robust community outreach and engagement.

Lead: Planning, Building and Code Enforcement
Policy 1.1: Develop objective development and design standards for all single-family and multifamily developments that simplify, clarify, and improve approval certainty and reduce the time for permit processing.

Policy 1.2: Implement existing processing guidelines and checklists for projects that qualify for byright, ministerial, or administrative approval and CEQA exemption under SB 35 and SB330.

Policy 1.3: Program: Review and adjust building permit review and approval procedures as needed to comply with the streamlining requirements in AB2234.

Policy 1.4: Develop standards to prioritize, incentivize, and expedite processing of residential projects that commit housing units for special needs populations such as the developmentally disabled, singlefemale head of households, at-risk youths, large family households, extremely low-income households, and unhoused individuals.

Incentivize affordable housing development.

Leads: Planning, Housing and Economic Development
Policy 1.5: Adopt by-right zoning for parcels in the Ravenswood/4 Corners Specific Plan area where there is a minimum of 20% lower-income units.

Policy 1.6: Seek and support financial resources from state, regional, and county housing programs, tax credits, and other sources that provide funding assistance for affordable housing projects to cover design and development costs and off-site public improvements.

Encourage smaller-scale housing that is relatively more affordable, including duplexes/triplexes and market-rate accessory dwelling units (ADUs).

Lead: Planning
Policy 1.7: Develop a “next-phase” streamlining effort for ADUs and JADUs, SB 9 projects, and any future small-development, ministerial approval process that builds on lessons learned from the ADU Streamlining collaboration with EPACANDO and City Systems. (See also ADU zoning amendments in Goal 10.)
Policy 1.8: Study feasibility and desirability of waiving or reducing fees or delaying payment of permit fees and development impact fees for ADUs and small projects, e.g., two or fewer units.

Program 1.9: Develop outreach materials targeting smaller developers aimed at informing future applicants and improving the quality of Planning and Building applications received.

Program. 1.10: Implement a preapproved and modular ADU designs program or participate in proposed 21 Elements clearinghouse to facilitate streamlined review and reduce design costs of ADUs.

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Program 1.11: Develop proposals for relaxing or allowing flexible zoning standards (e.g., building setbacks and height, open space, parking, and density) to facilitate the developing of SB 9 and small infill housing projects to increase housing opportunities and housing types throughout the community.

Incentivize production of deed-restricted ADUs, including deed-restricted units, to add to the City’s affordable housing stock.

Leads: Planning, Housing and Economic Development
Program 1.12: Develop a formalized legalization process for unpermitted second units. Identify zoning amendments to reduce the impediment to building ADUs, such as setback and open space standards.

Policy 1.13: Support and participate in a potential county-wide initiative to create a resource center to effectively educate homeowners, provide resources, and promote the construction of ADUs.

Policy 1.14: Research all available public and private sources of rehabilitation/repair funding and strengthen partnership with organizations in this area, such as Habitat for Humanity.

Develop long-term, sustainable funding sources that are flexible and may be used for affordable housing production and preservation and to prevent displacement and homelessness.

Lead: Housing and Economic Development
Policy 1.15: Implement the 2022 approval of Measure L which increased and expanded the City’s existing Gross Receipts Tax on rental residential properties for affordable housing and support programs.

Program 1.16: Update the City’s five-year strategic plan that lays out funding goals and priorities for the City’s affordable housing revenue sources for a finite period (1 year to 5 years).

Policy 1.17: Collaboratively (Planning and Housing) pursue state grant funds wherever possible to support affordable housing projects and programs and to address homelessness in the City.

Take reasonable measures to reduce the cost of development for fully affordable housing developments.

Leads: Planning, Housing and Economic Development
Policy 1.18: Use the opportunity of the RBD Specific Plan Update or initiate a city-wide study on the feasibility and desirability of fee waivers or reductions or deferred fee payments for fully affordable housing projects; additionally, consider providing City financial assistance to cover these fees.

Policy 1.20: Incorporate parking reductions into the City’s Transportation Demand Management Program including compliance with AB2097 and related state laws that eliminates parking minimums within one=half mile major transit stops and radius and parking maximums for affordable housing projects.

Encourage housing on sites zoned for mixed use in the
Ravenswood/4 Corners Specific Plan Area.

Lead: Planning
Policy 1,21: For sites within the RBD Specific Plan Area, study feasibility and effectiveness of an RBD-specific density bonus and relaxed zoning controls and incorporate possible provisions into the Specific Plan Update.

Leverage available public lands for affordable housing
development where feasible and beneficial to the community.

Program 1.22: Determine the feasibility and develop a proposal for redevelopment of Senior Center at 560 Bell St. to include affordable housing
Chapter 6 – Page 7
Leads: City Manager’s Office, Housing and Economic
Development
Responsible Agencies: County of San Mateo, Sequoia
Elementary School District
Program 1.23: Work with County of San Mateo to complete land swap and determine feasibility of the County developing affordable housing at 2277 University.

Program 1.24: Work with Sequoia Elementary School District to facilitate the development of the district-owned parcel at 2450 Ralmar Ave. as affordable public school employee housing.

Incentivize “missing middle” housing, or smaller-scale housing that is affordable to households at 80-120% of Area Median Income.

Lead: Planning
Policy 1.25: Revise City zoning standards to increase compatibility with SB 9 (e.g., flexible zoning standards for setbacks, open space, height and density) and make process improvements to encourage application of SB 9 on appropriately zoned parcels. Conduct informational outreach to property owners whose properties are prime candidates for SB 9 projects.

Monitor progress on Sites Inventory.

Leads: Planning. Housing and Economic Development
Policy1.26: At least every two years, evaluate the progress on meeting the City’s RHNA and adjust the Sites Inventory as needed. Track the production of inclusionary housing units, ADUs, SB 9 units, and housing for special needs populations.

Goal 2: Create homeownership opportunities for East Palo Alto residents and stability for existing homeowners.

Promote financial literacy as a means of encouraging
homeownership and support first-time homebuyers.

Lead: Housing and Economic Development
Policy 2.1: Develop a City led homebuyer support program or programs tailored to the needs of households in East Palo Alto. Conduct proactive outreach to seek interested applicants.

Policy 2.2: With the assistance of the City’s grant coordinator. seek and apply for funds from state and other sources to create and finance this program.

Create pathways to affordable homeownership opportunities.

Lead: Housing and Economic Development
Policy 2.3: Continue to study and develop an Opportunity to Purchase Act policy for tenants and/or qualified non-profits that builds on prior research and City Council direction in 2021-22.

Advocate for homebuyer and homeownership programs at the regional level.

Lead: Housing and Economic Development
Policy 2.4: Advocate for the homebuyer and homeownership programs at the county, regional, and state levels.

Goal 3: Promote stewardship and preservation of the City’s existing affordable housing stock.

Ensure that the City’s deed-restricted affordable housing and Below Market-Rate (BMR) portfolio remain well-maintained and monitored.

Lead: Housing and Economic Development
Program 3.1: Continue working with EPACANDO and Bay Area Affordable Homeownership Alliance (BAAHA) on the existing BMR Program contract and draft Request for Proposals (RFP) for next phase of BMR Program management, including additional rental and for-sale inclusionary housing units.

Improve data on affordability of the City’s rental housing stock outside of the Rent Stabilized portfolio.

Lead: Housing and Economic Development
Program 3.2: Prepare a feasibility study to create and fund a City rent registry and present to City Council for direction.

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Leverage County initiatives and affordable housing resources to increase public awareness of affordable housing
opportunities in East Palo Alto.

Lead: Housing and Economic Development
Responsible Agency: County of San Mateo
Program 3.3: Work with the County of San Mateo to list all affordable housing projects and inclusionary units on Doorway, a new regional platform for searching and applying for affordable housing and finding affordable housing resources; conduct proactive outreach.

Protect and preserve the City’s supply of rent-stabilized affordable housing units.

Lead: Housing and Economic Development
Policy 3.4: Continue to support the function of the Rent Stabilization Board to enforce the City’s Rent Stabilization Ordinance to protect tenants from unreasonable rent increase, to protect tenants from unlawful evictions, and to allow landlords sufficient rental income for maintenance and operating expenses and capital improvements.

Goal 4: Prevent displacement of East Palo Alto residents.

Connect the creation of new jobs in the City from commercial development to the creation of new housing at the appropriate affordability levels.

Leads: Planning, Housing and Economic Development
Policy 4.1: As part of the RBD Specific Plan update, develop a requirement to build new housing at specified levels of affordability based on a numerical linkage to office/R&D square footage in Ravenswood Business District (RBD).

Program 4.2: Participate in countywide nexus study led by 21 Elements to update the existing Commercial Linkage Fee.

Promote the preservation of existing housing stock and
rehabilitation of housing that is at-risk due to age, structural deficiencies, etc.

Leads: Housing and Economic Development, Building and
Code Enforcement
Policy 4.3: Develop a preservation strategy that addresses funding sources, identification of properties, and partnerships that can lead to preservation of affordable housing in East Palo Alto.

Policy 4.4: Identify and maintain a list of at-risk units and substandard buildings throughout the City.

Ensure property owners comply with the State Preservation Notice Law. Actively engage with property owners to reach agreements to preserve at-risk units and properly maintain their properties.

Policy 4.5: Study improvements to the City’s process for addressing code violations on residential properties, including, but not limited to, unpermitted second units.

Program 4.6: Develop a City housing rehabilitation program for City Council consideration that covers both single-family homes and multi-family apartments to preserve affordable housing opportunities, encourage proper maintenance and repairs, and increase energy conservation.

Support housing stability of existing lower-income
homeowners and enable the community’s seniors to age in place.

Lead: Public Works, Planning, Building, Housing and
Economic Development
Policy 4.7: Research establishing and funding a City home repairs program to assist low-income homeowners with major repairs and rehabilitation to address acute safety and livability issues.

Develop a public outreach plan and also inform homeowners of financial assistance available from other agencies such as energy conservation and electrification incentives.

Policy 4.8: Continue to implement public accessibility improvements in accordance with the City’s ADA Compliance Plan, and allow for reasonable accommodations through Municipal Code Chapter Chapter 6 – Page 9

14.10 – Reasonable Accommodations and Development Code Chapter 18.98 – Reasonable Accommodations
Policy 4.9: Study models of foreclosure prevention at the local level in similarly sized cities, whether through local investment or leveraging outside funding; evaluate establishing a mortgage assistance program for low-income households.

Promote community/cooperative ownership of land and
housing in East Palo Alto.

Lead: Housing and Economic Development
Program 4.10: Evaluate opportunities to support and/or leverage local community land trusts (CLTs) to create community ownership of new or preserved affordable housing, e.g., through scattered-site ADUs, small inclusionary projects, or preservation projects.

Prevent displacement due to high housing cost burden and barriers to housing, such as rental deposits.

Lead: Housing and Economic Development
Policy 4.11: Continue to appropriate funds and consider increasing funds for direct emergency financial assistance or rent relief to be administered by a qualified organization identified through a Request for Proposals (RFP) process. Conduct proactive public outreach, particularly to lower-income households and neighborhoods where a high housing cost burden has been documented in the fair housing assessment.

Policy 4.12: Develop a proposal for City Council consideration for a direct financial assistance program for first and last month’s rent/deposit assistance.

Implement an effective and fair housing compliant Local Preference Policy.

Lead: Housing and Economic Development
Policy 4.13: Complete and enforce guidelines on City’s existing Local Preference Policy.

Provide access to living wage jobs to allow residents to afford to remain to live in East Palo Alto.

Lead: Housing and Economic Development
Program 4.14: Through Measure HH, a parcel tax on large office developments approved by East Palo Alto residents in 2018, implement a Workforce Development Program to provide job training, apprenticeships, and job placement services to residents through partnerships with community-based non-profit organizations and private companies. Programs shall include proactive outreach to East Palo Alto residents, and service agreements shall define performance goals and metrics and required deliverables.

Goal 5: Apply environmental justice principles in planning for new housing development.

Adopt policies and programs to address environmental justice issues in the community.

Lead: Planning, Housing and Economic Development
Program 5.1: Update the Environmental Justice Element (Health and Equity) in the City’s General Plan to include a comprehensive set of policies and programs and an implementation plan to address environmental justice issues and public outreach, engagement and transparency; scope of work to include a robust community engagement process is integrated into the preparation of this Element.

Address water and sewer system constraints to housing
production, to the extent they are within the City’s control, through targeted capital and governance improvements.

Lead: City Manager’s Office, Public Works
Program 5.2: Establish and implement a plan to address the San Mateo County Local Agency Formation Commission (SMCLAFCo) Municipal Service Review and to resolve the delays to housing development caused by issues with the East Palo Alto Sanitary District.

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Responsible Agencies: San Mateo County Local Formation
Commission (SMCLFCo), East Palo Alto Sanitary District
Program 5.3: Implement the Water System Master Plan adopted in 2022 and complete the first-phase capital improvements in the plan. Update the Urban Water Management Plan to conform with the Master Plan and ensure adequate water service to parcels in the Sites Inventory (adequate water supply but water infrastructure upgrades may be needed for certain locations.) Policy 5.4: Work with water and sewer service providers to adopt a policy that prioritizes water and sewer capacity allocations to affordable housing projects and low-income households per SB1097.

Minimize new housing in highest-risk areas prone to
flooding/sea level rise or due to environmental contamination.

Lead: Public Works
Program 5.5: Leverage community partnerships to utilize and maintain data and maps wherever possible to monitor areas subject to flooding and identify sites for future development and to comply with Government Code 65302.

Program 5.6: Develop environmental “overlay” map with most up-to-date data to avoid housing in atrisk areas or with prescribed mitigation measures.

Expand and establish program to promote fair housing
practices for East Palo Alto residents.

Lead: Housing and Economic Development
Program 5.7: Implement fair housing and anti-eviction programs using Measure O and other qualifying local revenue sources to fund community-based organizations to provide legal services, financial assistance, case management, referrals, proactive community outreach (social media, workshops, flyers), posted resource information, and a citizen advocacy committee. Contracts with organizations will specify quantified deliverables for each of these areas.

Policy 5.8: Continue to support agencies such as Project Sentinel that provide consultation and landlord/tenant mediation services for residents.

Policy 5.9: Place program priority on providing fair housing and support services to special needs populations such as extremely low-income households, persons with disabilities, female heads of households, large family households, seniors, at-risk youths, and households at-risk of homelessness.

Target proactive public outreach to lower resource neighborhoods such as western and northern areas in East Palo Alto or projects where there is a higher presence of special needs populations based on the fair housing analysis
Goal 6: Promote safe and healthy housing in East Palo Alto.

Strengthen monitoring and enforcement of habitability issues.

Leads: Housing and Economic Development, Building and
Code Enforcement
Policy 6.1: Annually review the City’s habitability complaints and the Rent Stabilization Ordinance’s rules and regulations and evaluate whether any changes or updates may be made to how the City enforces habitability issues.

Incorporate amenities into multifamily housing that support households with children.

Lead: Planning
Policy 6.2: Determine the most effective means of incentivizing or requiring childcare facilities in new affordable housing developments and commercial developments.

Chapter 6 – Page 11
Improve energy conservation and reduce the carbon footprint of residential buildings.

Lead: Building and Code Enforcement
Program 6.3: Implement the East Palo Alto Reach Codes, which became effective in January 2021 and apply to all new construction and substantial rehabilitations and additions; continue to explore expanding building electrification requirements and support incentive programs for retrofitting existing buildings
Improve earthquake readiness and resilience.

Lead: Planning, Public Works, Building
Program 6.4: Complete and implement the recently updated Multi-Generational Local Hazard Mitigation Plan.

Program 6.5: Update the City’s Safety Element to address earthquakes, flooding, and other natural and manmade hazards; consider policies such as establishing a seismic retrofit program to address vulnerable populations living in soft-story buildings and establishing a program for remediation of lead-based paint in older residential buildings; incorporate targeted outreach to vulnerable and special needs populations to ensure their needs are well-addressed.

Ensure implementation and enforcement of flood protection and prevention measures.

Lead: Public Works, Planning, Building and Code
Enforcement
Responsible Agency: Federal Emergency Management Agency (FEMA)
Policy 6.6: Continue to disseminate information through onsite resources and workshops to homeowners, property owners, and developers on FEMA, state, and local regulations on floodplain construction and management practices.

Program 6.7: Continue to participate in FEMA’s Community Rating System Program to ensure that new housing development complies with floodplain construction standards with submittal of required certifications.

Goal 7: Create more housing opportunities for special needs households, including large households, people at risk of or experiencing homelessness, and individuals with disabilities.

Incorporate special housing needs into City-supported future affordable housing developments.

Lead: Housing and Economic Development
Policy 7.1: For affordable housing projects located near high-quality transit and on City-owned land, with City subsidy, or where otherwise legally defensible, require developers of affordable housing to demonstrate how they will serve people with disabilities in the development.

Provide housing solutions and support services for unhoused residents in East Palo Alto.

Leads: Housing and Economic Development, Planning
Program 7.2: Finalize the Master Temporary Use Permit process for temporary housing program rollout that includes City coverage of permit fees to provide housing for individuals experiencing homelessness in the community.

Program 7.3: Evaluate lessons learned and options for longer-term, holistic solutions to RVs parked in public right of way with the conclusion of the RV Safe Parking Program.

Program 7.4: Research all available public funding sources to address homelessness and consider City investment of funds for homeless outreach, case management and supportive housing to supplement the countywide system.

Policy 7.5: Pursue expansion of support programs for unhoused residents by establishing partnerships with other public agencies, private corporations and foundations, and non-profit service providers.

Chapter 6 – Page 12
Policy 7.6: Continue to support the low barrier navigation center and emergency shelter operated by WeHope, a community-based non-profit organization, that provides an interim shelter and supportive services for unhoused individuals. Accommodate the special needs of at-risk youths, households with children, and persons with disabilities.

Reduce overcrowding and unsafe housing conditions related to housing affordability in East Palo Alto.

Lead: Housing and Economic Development, Planning
Policy 7.7: Develop options for incentivizing deeply affordable housing units that serve larger household sizes, such as allowing additional density or other relaxed or flexible zoning regulations.

Policy 7.8: Continue to require residential projects to include Extremely Low-Income housing units through the City’s Inclusionary Housing Program. Encourage production of deed-restricted ADUs serving Extremely Low and Very Low-Income households as an Inclusionary Housing Alternative Compliance option instead paying in-lieu fees for fractional unit requirements Goal 8: Improve transparency and communication between the City and the public on housing issues.

Make the City website, social media, and newsletter a reliable source of housing information and make parallel efforts to reach residents through mailers and in-person meetings.

Lead: Housing and Economic Development
Program 8.1: Improve and maintain the Housing website as a primary means of communicating the work of the Division. Expand proactive measures to inform homeowners, landlords, and tenants about available local and County housing resources and supportive services.

Policy 8.2: Create a budget for mailers and non-digital outreach on Housing workplan items at the start of each fiscal year.

Incorporate language accessibility/language justice into City materials and meetings.

Leads: City Manager’s Office, Planning, Housing and
Economic Development
Policy 8.3: Provide translation of materials and interpretation of City Council, Planning Commission, Rent Stabilization, and other City meetings in alignment with City’s Language Policy.

Goal 9: Build City capacity for long-term housing planning and implementation of a range of Housing programs and initiatives.

Maintain sufficient Housing Division staff to implement Housing Element programs.

Leads: Housing and Economic Development, City Manager’s Office
Policy 9.1: Regularly assess the level of staffing or contract assistance to ensure that sufficient staffing is committed to implement the 6th cycle Housing Element policies and programs in a timely manner per the Implementation Plan.

Seek efficiencies and collaborative staffing and resource opportunities to simultaneously implement the Housing
Element programs and other Housing Division responsibilities.

Lead: Housing and Economic Development
Program 9.2: Join with other cities in San Mateo County to share housing staff to support longer-term housing initiatives and programs.

Work in close collaboration with the Planning Division to more efficiently achieve both divisions’ goals and workplan items.

Program 9.3: Collaboratively update the City’s Development Code to align Planning and Housing objectives, with an emphasis of resolving inconsistencies and ensuring consistency with the City’s General Plan.

Chapter 6 – Page 13
Leads: Planning, Housing and Economic Development
Seek financing sources for affordable housing construction and preservation.

Lead: Housing and Economic Development
Policy 9,4: As Notices of Funding Availability (NOFA) are issued (typically annually), proactively work with the City’s grant coordinator to selectively apply for regional, state, and federal grants to finance qualifying affordable housing projects and to fund Housing Element programs, such as housing rehabilitation program and first-time homebuyers program Monitor Housing Element Implementation Plan
Lead: Housing and Economic Development
Policy 9.5: Review the Sites Inventory annually to assess progress in achieving the City’s RHNA allocation and, as needed, consider identifying additional sites or adjusting development policies, programs, and priorities.

Goal 10: Amend Zoning and Other Development Regulations to Facilitate the Construction of Housing Require replacement housing to be provided for applicable housing developments.

Lead: Housing and Economic Development
Policy 10.1: For applicable development projects that will be removing residential units, require a replacement housing program for lower-income households in accordance with Government Code 65583.2(g).

Update zoning and development standards as needed for
Emergency Shelters.

Lead: Planning
Program 10.2: Evaluate current sites, development standards, and approval process and update zoning regulations and procedures to comply with AB139/Government Code Section 65583(a)(4)(A).

Update zoning as needed for By-Right Permanent Supportive Housing.

Lead: Planning
Program 10.3: Update zoning to require permanent supportive housing to be allowed by-right in residential and mixed-use zoning districts per Government Code 65651.

Update zoning as needed for Housing for Farmworkers.

Lead: Planning
Program 10,4: Update zoning and the definition of a “housekeeping unit” to comply with the Employee Housing Act.

Update zoning as needed for Accessory Dwelling Units (ADU) Lead: Planning
Program 10.5: Bring the ADU zoning regulations into compliance with the latest state laws, including addressing programs and policies to facilitate construction of ADUs in Goal 1. Consider additional measures to remove zoning impediments such as relaxing side and rear yard setback and open space standards and facilitating conversion of unpermitted accessory structures to ADUs.

Update zoning as needed for Residential Care Facilities.

Lead: Planning
Program 10.6: Update zoning regulations for residential care facilities to comply with state law and to reduce barriers for establishing facilities for special needs populations such as persons with disabilities.

Update other zoning ordinance regulations to comply with latest state law and reduce impediments for residential development.

Lead: Planning
Program10,7: Review zoning ordinance regulations and reduce development impediments or provide incentives such as standards pertaining to parking, open space, density bonuses, and objective design standards.

Chapter 6 – Page 14
Adopt update to Ravenswood/Four Corners Specific Plan to include residential uses at designated locations.

Lead: Planning
Program 10,8: Adopt update to Specific Plan to allow residential and mixed-use development at designated locations in plan area and address provisions as noted in other Housing Element policies/programs. Additionally. address by-right approval, objective design standards, minimum residential requirements for mixed use zoning, parking, open space, transportation demand management (TDM) program, and other development standards. Further, resolve inconsistencies between the General Plan and current Specific Plan,
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Chapter 6 – Page 15

6.4 IMPLEMENTATION PLAN
Goal 1: Create more housing opportunities, and more housing that is affordable to East Palo Alto residents.

Objective: Implement measures to reduce overall processing times for residential development applications while maintaining robust community outreach and engagement.

Lead: Planning, Building and Code Enforcement
Policy 1.1: Develop objective development and design standards that simplify and improve approval certainty and timing.
• Starting Fall 2023 and completion Fall 2024: engage consultant through ABAG Regional Early Action Planning Grant program to begin drafting standards. Conduct community outreach through 2023-2024. • Fall 2024: Planning Commission and City Council public hearings. • First quarter 2025: Draft standards available.

Policy 1.2: Implement existing processing guidelines and checklists for projects that qualify for by-right, ministerial, or administrative approval and CEQA exemption under SB 35 and SB330. • Ongoing
Policy 1.3: Program: Review and adjust building permit review and approval procedures as needed to comply with the streamlining requirements in AB2234.
• Effective January 1, 2028 for East Palo Alto; develop procedures by end of 2027.

Policy 1.4: Develop standards to prioritize, incentivize, and expedite processing of residential projects that commit housing units for special needs populations such as the developmentally disabled, single-female head of households, atrisk youths, large family households, extremely low-income households, and unhoused individuals. • Start Fall 2023 and complete Fall 2024
• Conduct proactive outreach to special needs populations and organizations serving these populations.

Objective: Incentivize affordable housing development.

Leads: Planning, Housing and Economic Development
Policy 1.5: Adopt by-right zoning for parcels in the Ravenswood/4 Corners Specific Plan area where there is a minimum of 20% lower-income units.
• January 2024 completion: Include in Specific Plan to be adopted by the City Council.

Chapter 6 – Page 16
• Approval process include community workshop, stakeholder meetings, EIR certification, and combined Planning Commission/City Council study sessions.
• Specific Plan will also include the zoning regulations for the properties in the plan area.

Policy 1.6: Seek and support financial resources from state, regional, and county housing programs, tax credits, and other sources that provide funding assistance for affordable housing projects to cover design and development costs and off-site public improvements.
• Annually review available grants and other funding sources and work with City’s grant coordinator to submit application in response to Notice of Funding Availability that most suitable for East Palo Alto.

Objective: Encourage smaller-scale housing that is relatively more affordable, including duplexes/triplexes and market-rate accessory dwelling units (ADUs).

Lead: Planning
Policy 1.7: Develop a “next-phase” streamlining effort for ADUs and JADUs, SB 9 projects, and any future smalldevelopment, ministerial approval process that builds on lessons learned from the ADU Streamlining collaboration with EPACANDO and City Systems. (See also ADU zoning amendments in Goal 10.) • Second quarter 2024: Survey surrounding jurisdictions with amnesty and/or legalization programs and make recommendations for an unpermitted second unit program. • Resource implications: Funds may be required for consultant costs. May be able to use SB 2 funds or REAP funds.

Policy 1.8: Study feasibility and desirability of waiving or reducing fees or delaying payment of permit fees and development impact fees for ADUs and small projects, e.g., two or fewer units. • Second quarter 2024: Bring proposal to City Council for adoption. • Obtain public input and determine possible sources for covering the fiscal impact of waiving, reducing, or deferring permit and development fees.
• Resource implication: City will need to absorb the staff costs of permit processing and uncollected development impact fees.

Program 1.9: Develop outreach materials targeting smaller developers aimed at informing future applicants and improving the quality of Planning and Building applications received. • Spring 2024: Review existing materials and update informational handouts for residents and developers. • Complete work after updating and adopting zoning amendments in Goal 10.

Program. 1.10: Implement a preapproved and modular ADU designs program or participate in proposed 21 Elements clearinghouse to facilitate streamlined review and reduce design costs of ADUs. • Fall 2024: Work with Building to preapprove plans, publicize to homeowners, and post on website.

Chapter 6 – Page 17
• Coordinate with regional effort by San Mateo County 21 Elements consortium that is considering a similar program.

Program 1.11: Develop proposals for relaxing or allowing flexible zoning standards (e.g., building setbacks and height, open space, parking, and density) to facilitate the developing of SB 9 and small infill housing projects to increase housing opportunities and housing types throughout the community. • Spring 2025: Bring recommended zoning amendment to City Council for consideration. • Conduct public meetings to receive input and obtain Planning Commission recommendation.

Objective: Incentivize production of deed-restricted ADUs, including deed-restricted units, to add to the City’s affordable housing stock.

Leads: Planning, Housing and Economic Development
Program 1.12: Develop a formalized legalization process for unpermitted second units. Identify zoning amendments to reduce the impediment to building ADUs, such as setback and open space standards. • Second quarter 2024: Survey surrounding jurisdictions with amnesty and/or legalization programs and make recommendations to City Council for an unpermitted second unit program.

Policy 1.13: Support and participate in a potential county-wide initiative to create a resource center to effectively educate homeowners, provide resources, and promote the construction of ADUs. • 2023-2024: Timing dependent on project schedule with 21 Elements consortium and participation of other San Mateo County jurisdictions.

Policy 1.14: Research all available public and private sources of rehabilitation/repair funding and strengthen partnership with organizations in this area, such as Habitat for Humanity. • Ongoing: Staff research all funding opportunities on an annual basis. • Ongoing: Pursue CalHOME in next available funding round to continue supporting low-income households to build deed restricted affordable ADUs.
• Ongoing: Work with community partners in the ADU Working Group to pursue philanthropic funds.

Resource implications: Funds may be required for consultant costs. May be able to use SB 2 funds or REAP funds.

Objective: Develop long-term, sustainable funding sources that are flexible and may be used for affordable housing production and preservation and to prevent displacement and homelessness.

Lead: Housing and Economic Development
Policy 1.15: Implement the 2022 approval of Measure L which increased and expanded the City’s existing Gross Receipts Tax on rental residential properties for affordable housing and support programs.

Chapter 6 – Page 18
• Beginning of 2023 to end of 2024: Work with staff to implement changes to Gross Receipts Tax (Measure L).
• Resource implications: The ballot measure is expected to increase revenue for affordable housing, but it will require staff coordination between Housing and Finance to ensure that taxes can be properly collected.

Program 1.16: Update the City’s five-year strategic plan that lays out funding goals and priorities for the City’s affordable housing revenue sources for a finite period (1 year to 5 years). • End of 2024 and annually: Incorporate into the City Council Priority-Setting process completed at the start of each year. Create plan based on City Council-directed funding priorities for the coming year.

Policy 1.17: Collaboratively (Planning and Housing) pursue state grant funds wherever possible to support affordable housing projects and programs and to address homelessness in the City. • Pursue next round of Regional Early Action Planning grants, additional planning grants from HCD, next round of CalHOME grants, and research funding for homelessness.

Objective: Take reasonable measures to reduce the cost of development for fully affordable housing developments.

Leads: Planning, Housing and Economic Development
Policy 1.18: Use the opportunity of the RBD Specific Plan Update or initiate a city-wide study on the feasibility and desirability of fee waivers or reductions or deferred fee payments for fully affordable housing projects; additionally, consider providing City financial assistance to cover these fees. • End of 2025: Study waiver or reduction of impact fees for fully affordable housing projects in the RBD area based on fiscal impact analyses performed for each of the major projects in RBD. • Resource implications: This may be combined with existing scope of for the RBD update process and/or ensuing implementation.

Policy 1.20: Incorporate parking reductions into the City’s Transportation Demand Management Program including compliance with AB2097 and related state laws that eliminates parking minimums within one=half mile major transit stops and radius and parking maximums for affordable housing projects. • End of 2025: Leverage existing consultant work on transportation and a potential Transportation Management Association (TMA) in the RBD area to establish a TDM program.

Objective: Encourage housing on sites zoned for mixed use in the Ravenswood/4 Corners Specific Plan Area.

Lead: Planning
Policy 1.21: For sites within the RBD Specific Plan Area, study feasibility and effectiveness of an RBD-specific density bonus and relaxed zoning controls and incorporate possible provisions into the Specific Plan Update.

Chapter 6 – Page 19
• End of 2026: Complete study of a by-right density bonus and higher floor area ratio for mixed-use projects with a minimum percentage of affordable units, or a similar policy, and make a recommendation for the RBD Specific Plan area.
• Resource implications: This may be funded out of the Regional Early Action Planning grant for objective design and development standards, other City-funded contract associated with the RBD Update, or through the City’s participation in 21 Elements.

Objective: Leverage available public lands for affordable housing development where feasible and beneficial to the community.

Leads: City Manager’s Office, Housing and Economic Development Responsible Agencies: County of San Mateo, Sequoia Elementary School District Program 1.22: Determine the feasibility and develop a proposal for redevelopment of Senior Center at 560 Bell St. to include affordable housing.
• End of 2025: Engage consultant and commence feasibility study for redevelopment of Senior Center. • Second quarter 2026: Provide recommendations to City Council on redevelopment of Senior Center. • End of 2027: If directed by City Council, and if requirements of Surplus Lands Act (Government Code Section 54222 et. Seq.) are fulfilled, secure a developer for Senior Center site. • Resource implications: Consultant costs for feasibility study not yet appropriated. Likely General Fund.

Program 1.23: Work with County of San Mateo to complete land swap and determine feasibility of the County developing affordable housing at 2277 University.
• Fourth Quarter 2023: complete and execute Exchange Agreement with the County of San Mateo. • First Quarter 2025, complete due diligence and environmental review, and make Surplus Lands Act findings pursuant to Government Code Section 54222(f) prior the exchange of properties.

Program 1.24: Work with Sequoia Elementary School District to facilitate the development of the district-owned parcel at 2450 Ralmar Ave. as affordable public school employee housing. • Fourth quarter 2023: Determine in collaboration with the School District whether a rezoning of the parcel is necessary.
• The timeframe of this development will be largely driven by the School District, including the Surplus Land Act requirements (Government Code 54222).
• Resource implications: If rezoning of the parcel(s) is necessary, it is likely the City must seek additional funds to support this work.

Objective: Incentivize “missing middle” housing, or smaller-scale housing that is affordable to households at 80-120% of Area Median Income.

Lead: Planning
Chapter 6 – Page 20
Policy 1.25: Revise City zoning standards to increase compatibility with SB 9 (e.g., flexible zoning standards for setbacks, open space, heights and density) and make process improvements to encourage application of SB 9 on appropriately zoned parcels. Conduct informational outreach to property owners whose properties are prime candidates for SB 9 projects.
• Second Quarter of 2025: Fully implement process improvements for ministerial approvals, including templates for SB 9 and SB 35 projects.
• End of 2025: Complete review of Development Code to ensure there are no barriers to utilization of SB 9 and propose changes (or full ordinance adoption) as necessary. Initial review completed.

Objective: Monitor progress on Sites Inventory.

Leads: Planning. Housing and Economic Development
Policy 1.26: At least every two years, evaluate the progress on meeting the City’s RHNA and adjust the Sites Inventory as needed. Track the production of inclusionary housing units, ADUs, SB 9 units, and housing for special needs populations.
• Ongoing: Report in Annual Progress Report.

Goal 2: Create homeownership opportunities for Palo Alto residents and stability for existing homeowners.

Objective: Promote financial literacy as a means of encouraging homeownership and support first-time homebuyers.

Lead: Housing and Economic Development
Policy 2.1: Develop a City-led homebuyer support program or programs tailored to the needs of households in East Palo Alto. Conduct proactive outreach to seek interested applicants. • By end of 2023: Staff research and report to City Council on the barriers to homebuying for households in East Palo Alto and effectiveness of federal, state, and local programs, with recommendation of either a City led program or partnership with local organization. Determine how such a program should be funded, and whether a Request for Proposals (RFP) is needed.
• 2024- 2025: Study and determine how East Palo Alto residents can benefit from the California Dream for All down payment program for first-time homebuyers.
• First quarter 2025: Launch a City or partner-led financial literacy, including credit counseling, and first-time homeowner program that focuses on 1.) younger households seeking homeownership options and 2.) seniors looking to downsize.
• Resource implications: Housing staff time with additional resources required for potential RFP.

Chapter 6 – Page 21
Policy 2.2: With the assistance of the City’s grant coordinator. seek and apply for funds from state and other sources to create and finance this program.
• Ongoing: On an annual basis, review grant opportunities and other sources that can fund programs and prepare and submit applications where East Palo Alto is most competitive.

Objective: Create pathways to affordable homeownership opportunities.

Lead: Housing and Economic Development
Policy 2.3: Continue to study and develop an Opportunity to Purchase Act policy for tenants and/or qualified non-profits that builds on prior research and City Council direction in 2021-22. • Spring 2023: Return to City Council with update policy and obtain direction. • By end of 2023: Implement direction provide by the City Council. • Resource implications: provide staffing and resources to develop and administer program.

Objective: Advocate for homebuyer and homeownership programs at the regional level.

Lead: Housing and Economic Development
Policy 2.4: Advocate for the homebuyer and homeownership programs at the county, regional, and state levels. • Ongoing: Monitor regional and state legislation proposed programs and brief City Council on submitting possible support and advocacy positions.

Goal 3: Promote stewardship and preservation of the City’s existing affordable housing stock.

Objective: Ensure that the City’s deed-restricted affordable housing and Below Market-Rate (BMR) portfolio remain well-maintained and monitored.

Lead: Housing and Economic Development
Program 3.1: Continue working with EPACANDO and Bay Area Affordable Homeownership Alliance (BAAHA) on the existing BMR Program contract and draft Request for Proposals (RFP) for next phase of BMR Program management, including additional rental and for-sale inclusionary housing units.

Improve data on affordability of the City’s rental housing stock outside of the Rent Stabilized portfolio. • First quarter 2023: Report on progress made under existing BMR contract and seek City Council direction on future BMR administration.
• When directed, release RFP for future BMR administration. • Resource implications: Utilize available Affordable Housing funds.

Chapter 6 – Page 22
Objective: Improve data on affordability of the City’s rental housing stock outside of the Rent Stabilized portfolio.

Lead: Housing and Economic Development
Program 3.2: Prepare a feasibility study to create and fund a City rent registry and present to City Council for direction. • By end of 2024: Study models of rent registries in the Bay Area and report to City Council with recommendations on potential creation of a rent registry in East Palo Alto.

Objective: Leverage County initiatives and affordable housing resources to increase public awareness of affordable housing opportunities in East Palo Alto.

Lead: Housing and Economic Development
Responsible Agency: County of San Mateo
Program 3.3: Work with the County of San Mateo to list all affordable housing projects and inclusionary units on Doorway, a new regional platform for searching and applying for affordable housing and finding affordable housing resources; conduct proactive outreach.
• Ongoing: Staff will be available on an ongoing basis, subject to the County’s timeline.

Objective: Protect and preserve the City’s supply of rent-stabilized affordable housing units.

Lead: Housing and Economic Development
Policy 3.4: Continue to support the function of the Rent Stabilization Board (RSB)to enforce the City’s Rent Stabilization Ordinance to protect tenants from unreasonable rent increase, to protect tenants from unlawful evictions, and to allow landlords sufficient rental income for maintenance and operating expenses and capital improvements. • Ongoing: Provide continuing staff support to inquiries from tenants and refer items to RSB for consideration as needed.

Goal 4: Prevent displacement of East Palo Alto residents.

Objective: Connect the creation of new jobs in the city from commercial development to the creation of new housing at the appropriate affordability levels.

Leads: Planning, Housing and Economic Development
Policy 4.1: As part of the RBD Specific Plan update, develop a requirement to build new housing at specified levels of affordability based on a numerical linkage to office/R&D square footage in Ravenswood Business District (RBD).

Chapter 6 – Page 23
• Second quarter 2024: Present to City Council the jobs-housing linkage requirement, together with the baseline requirements and community amenities that will apply to proposed projects in the RBD Specific Plan Area.
• Resource implications: This is incorporated into the current scope of work performed by Raimi + Associates for the overall RBD Specific Plan Update.

Program 4.2: Participate in countywide nexus study led by 21 Elements to update the existing Commercial Linkage Fee.
• End of 2024: Work with 21 Elements to determine scope and cost and report to City Council. • Resource implications: City Affordable Housing funds or General Fund. This multi-city effort should greatly reduce the cost of the study.

Objective: Promote the preservation of existing housing stock and rehabilitation of housing that is at-risk due to age, structural deficiencies, etc.

Leads: Housing and Economic Development, Building and Code Enforcement Policy 4.3: Develop a preservation strategy that addresses funding sources, identification of properties, and partnerships that can lead to preservation of affordable housing in East Palo Alto. • End of 2024: Work with Partnership for the Bay’s Future (PBF) Policy Grant Fellow to research and develop recommendations for preservation strategies.
• Resource implications: Policy Grant Fellow began working with the City in 2022 and is funded through mid2024 through a grant from the Partnership for the Bay’s Future.

Policy 4.4: Identify and maintain a list of at-risk units and substandard buildings throughout the City. Ensure property owners comply with the State Preservation Notice Law. Actively engage with property owners to reach agreements to preserve at-risk units and properly maintain their properties. • End of 2024: Update list of at-risk and substandard unit. • Ongoing: Engage and outreach to property owners on possible resources to address deficiencies.

Policy 4.5: Study improvements to the City’s process for addressing code violations on residential properties, including, but not limited to, unpermitted second units.
• End of 2024: Study programs in other Bay Area jurisdictions for best practices.

Program 4.6: Develop a City housing rehabilitation program for City Council consideration that covers both singlefamily homes and multi-family apartments to preserve affordable housing opportunities, encourage proper maintenance and repairs, and increase energy conservation.
• End of 2025: Bring a proposal to City Council for consideration. • 2026: Implement program per City Council recommendation.

Chapter 6 – Page 24
• Resource implications: allocate eligible local funds; provide staffing or contract assistance to administer program; seek grants other financial assistance; explore partnerships for leveraging staffing and resources.

Objective: Support housing stability of existing lower-income homeowners and enable the community’s seniors to age in place.

Lead: Public Works, Planning, Building, Housing and Economic Development Policy 4.7: Research establishing and funding a City home repairs program to assist low-income homeowners with major repairs and rehabilitation to address acute safety and livability issues. Develop a public outreach plan and also inform homeowners of financial assistance available from other agencies such as energy conservation and electrification incentives.
• End of 2024: Staff report to City Council on funding sources and potential programs based on other Bay Area jurisdictions.
• 2025: Implement direction provided by the City Council. • Resource implications: allocate eligible local funds; provide staffing or contract assistance to administer program; seek grants other financial assistance; explore partnerships for leveraging staffing and resources.

Policy 4.8: Continue to implement public accessibility improvements in accordance with the City’s ADA Compliance Plan and allow for reasonable accommodations through Municipal Code Chapter 14.10 – Reasonable Accommodations and Development Code Chapter 18.98 – Reasonable Accommodations. • Ongoing: Continue to implement existing City programs and ordinances.

Policy 4.9: Study models of foreclosure prevention at the local level in similarly sized cities, whether through local investment or leveraging outside funding; evaluate establishing a mortgage assistance program for low-income households.
• End of 2024: Staff survey other jurisdictions and report to City Council on findings in conjunction with reporting on City efforts to support homeownership.
• 2025: Implement direction provided by the City Council. • Resource implications: allocate eligible local funds; provide staffing or contract assistance to administer program; seek grants other financial assistance; explore partnerships for leveraging staffing and resources.

Objective: Promote community/cooperative ownership of land and housing in East Palo Alto.

Lead: Housing and Economic Development
Program 4.10: Evaluate opportunities to support and/or leverage local community land trusts (CLTs) to create community ownership of new or preserved affordable housing, e.g., through scattered-site ADUs, small inclusionary projects, or preservation projects.

Chapter 6 – Page 25
• Beginning of 2024: Work with Partnership for the Bay’s Future Policy Grant Fellow to research and develop recommendations for community/cooperative ownership of land in conjunction with housing preservation strategies.
• Resource implications: Policy Grant Fellow began working with the City in 2022 and is funded through mid2024 through a grant from the Partnership for the Bay’s Future.

Objective: Prevent displacement due to high housing cost burden and barriers to housing, such as rental deposits.

Lead: Housing and Economic Development
Policy 4.11: Continue to appropriate funds and consider increasing funds for direct emergency financial assistance or rent relief to be administered by a qualified organization identified through a Request for Proposals (RFP) process.

Conduct proactive public outreach, particularly to lower-income households and neighborhoods where a high housing cost burden has been documented in the fair housing assessment. • End of 2023: Release RFP and, if qualified organizations respond, provide funding recommendations to City Council for this purpose.
• 2023-2024: Establish program if approved by City Council; monitor direct financial assistance for duration of contract and report on the program to City Council at its conclusion in 2024. • Resource implications: Funds from the General Fund (“Measure O”) have already been appropriated for this RFP.

Policy 4.12: Develop a proposal for City Council consideration for a direct financial assistance program for first and last month’s rent/deposit assistance.
• End of 2024: Provide recommendations to City Council on a potential direct financial assistance program for rental deposit assistance.
• Resource implications: allocate eligible local funds; provide staffing or contract assistance to administer program; seek grants other financial assistance; explore partnerships for leveraging staffing and resources.

Objective: Implement an effective and fair housing compliant Local Preference Policy.

Lead: Housing and Economic Development
Policy 4.13: Complete and enforce guidelines on City’s existing Local Preference Policy. • End of 2023: Complete guidelines on Local Preference Policy and post to website.

Objective: Provide access to living wage jobs to allow residents to afford to remain to live in East Palo Alto.

Lead: Housing and Economic Development
Chapter 6 – Page 26
Program 4.14: Through Measure HH, a parcel tax on large office developments approved by East Palo Alto residents in 2018, implement a Workforce Development Program to provide job training, apprenticeships, and job placement services to residents through partnerships with community-based non-profit organizations and private companies.

Programs shall include proactive outreach to East Palo Alto residents, and service agreements shall define performance goals and metrics and required deliverables.
• Pilot Workforce Development Program approved by the City Council in October 2022 with authorization of Measure HH funds and City Manager to enter into agreements with three organizations. • Spring 2023: Execute agreements with organizations for 18-month pilot period. • Ongoing: Allocate funds upon submittal of quarterly invoices and performance reports; monitor success of meeting performance goals and quantified metrics.

Goal 5: Apply environmental justice principles in planning for new housing development.

Objective: Adopt policies and programs to address environmental justice issues in the community.

Lead: Planning, Housing and Economic Development
Program 5.1: Update the Environmental Justice Element (Health and Equity) in the City’s General Plan to include a comprehensive set of policies and programs and an implementation plan to address environmental justice issues and public outreach, engagement and transparency; scope of work to include a robust community engagement process is integrated into the preparation of this Element.
• 2024 Completion: Coordinated effort through 21 Elements with participation of several cities in San Mateo County. Begin community engagement in Summer 2023.

Resource implications: Obtain budget allocation from City Council to fund City’s share of consultant contract in Spring 2023.

Objective: Address water and sewer system constraints to housing production, to the extent they are within the City’s control, through targeted capital and governance improvements.

Lead: City Manager’s Office, Public Works
Responsible Agencies: San Mateo County Local Formation Commission (SMCLFCo), East Palo Alto Sanitary District Program 5.2: Establish and implement a plan to address the San Mateo County Local Agency Formation Commission (SMCLAFCo) Municipal Service Review and to resolve the delays to housing development caused by issues with the East Palo Alto Sanitary District.
• Early 2023: Draft resolution with draft application to SMCLAFCo to initiate the process of establishing EPASD as a Subsidiary District of the City.
• 2024: Completion of process depends on option selected and SMCLAFCo legal and procedural requirements.

Chapter 6 – Page 27
Program 5.3: Implement the Water System Master Plan adopted in 2022 and complete the first-phase capital improvements in the plan. Update the Urban Water Management Plan to conform with the Master Plan and ensure adequate water service to parcels in the Sites Inventory (adequate water supply but water infrastructure upgrades needed for certain locations.)
• End of 2022: City Council adoption of Water System Master Plan (completed). • End of 2023: Complete construction of University Ave. and Cooley Ave. 12-in Water Transmission Main. • End of 2023: Complete Pad D Standby Well construction. • End of 2025: 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.
• Resource implications: The Water System Master Plan is a 20-year capital improvement program to help guide future capital expenditures in the City. Funding for capital projects is outlined in the City’s Capital Improvement Plan.

Policy 5.4: Work with water and sanitary sewer service providers to adopt a policy that prioritizes water and sewer capacity allocations to affordable housing projects and low-income households per SB1097. • 2023: Coordinate with water and sanitary sewer service providers to adopt policy. Implementation of policy will be dependent on each service provider.

Objective: Minimize new housing in highest-risk areas prone to flooding/sea level rise or due to environmental contamination.

Lead: Public Works
Program 5.5: Leverage community partnerships to utilize and maintain data and maps wherever possible to monitor areas subject to flooding and identify sites for future development and to comply with Government Code 65302. • Ongoing: Update maps on an annual basis.

Program 5.6: Develop environmental “overlay” map with most up-to-date data to avoid housing in at-risk areas or with prescribed mitigation measures.
• End of 2023: Housing, Planning, and Public Works staff work with regional partners to obtain data and create a map that can be featured on the City’s website.

Objective: Expand and establish program to promote fair housing practices for East Palo Alto residents.

Lead: Housing and Economic Development
Program 5.7: Implement fair housing and anti-eviction programs using Measure O and other qualifying local revenue sources to fund community-based organizations to provide legal services, financial assistance, case management, Chapter 6 – Page 28
referrals, proactive community outreach (social media, workshops, flyers), posted resource information, and a citizen advocacy committee. Contracts with organizations will specify quantified deliverables for each of these areas. • Winter 2022: Conduct RFP process and receive City Council authorization of Measure O funds for antidisplacement services (completed) • Early 2023: Execute agreements with three service providers to provide prescribed services. • Ongoing: Monitor delivery of services and completion of deliverables specified in agreements.

Policy 5.8: Continue to support agencies such as Project Sentinel that provide consultation and landlord/tenant mediation services for residents.
• Ongoing: Continue existing resident referral procedures and conduct informational outreach.

Policy 5.9: Place program priority on providing fair housing and support services to special needs populations such as extremely low-income households, persons with disabilities, female heads of households, large family households, seniors, at-risk youths, and households at-risk of homelessness. Target proactive public outreach to lower resource neighborhoods such as western and northern areas in East Palo Alto or projects where there is a higher presence of special needs populations based on the fair housing analysis. • Ongoing: Conduct proactive outreach with targeted outreach to special needs populations. Coordinate with Measure O service providers that under contract with City to provide anti-displacement services.

Goal 6: Promote safe and healthy housing in East Palo Alto.

Objective: Strengthen monitoring and enforcement of habitability issues.

Leads: Housing and Economic Development, Building and Code Enforcement Policy 6.1: Annually review the City’s ordinances and enact amendments or updates, as needed, to effectively address and enforce habitability complaints and concerns.
• Ongoing: Conduct annual review and implement changes or updates as needed.

Objective: Incorporate amenities into multifamily housing that support households with children.

Lead: Planning
Policy 6.2: Determine the most effective means of incentivizing or requiring childcare facilities in new affordable housing developments and commercial development.
• End of 2024: Meet with affordable housing developers, nonprofits, and foundations for feedback on how childcare is incorporated into new developments and make recommendations to City Council for future Citysubsidized affordable housing developments or affordable housing in the RBD Specific Plan area.

Chapter 6 – Page 29
Objection: Improve energy conservation and reduce the carbon footprint of residential buildings.

Lead: Building and Code Enforcement
Program 6.3: Implement the East Palo Alto Reach Codes, which became effective in January 2021 and apply to all new construction and substantial rehabilitations and additions; continue to explore expanding building electrification requirements and support incentive programs for retrofitting existing buildings. • Spring 2023: Present recommendation to City Council to adopt amendments to Reach Code. • Ongoing: Continue to educate developers and property owners on Reach Code requirements and review building permits for compliance of Reach Code regulations.

Objective: Improve earthquake readiness and resilience.

Lead: Planning, Public Works, Building
Program 6.4: Complete and implement the recently updated Multi-Generational Local Hazard Mitigation Plan. • Ongoing staff work program.

Program 6.5: Update the City’s Safety Element to address earthquakes, flooding, and other natural and manmade hazards; consider policies such as establishing a seismic retrofit program to address vulnerable populations living in soft-story buildings and establishing a program for remediation of lead-based paint in older residential buildings; incorporate targeted outreach to vulnerable and special needs populations to ensure their needs are well-addressed. • 2024 Completion: Coordinated effort through 21 Elements with participation of multiple cities in San Mateo County. Begin community engagement in Summer 2023 and coordinate with update of Environmental Justice Element.
• Resource implications: Obtain budget allocation from City Council to fund City’s share of consultant contract in Spring 2023.

Objective: Ensure implementation and enforcement of flood protection and prevention measures.

Lead: Public Works, Planning, Building and Code Enforcement Responsible Agency: Federal Emergency Management Agency (FEMA) Policy 6.6: Continue to disseminate information through onsite resources and workshops to homeowners, property owners, and developers on FEMA, state, and local regulations on floodplain construction and management practices. • Ongoing staff work program.

Program 6.7: Continue to participate in FEMA’s Community Rating System Program to ensure that new housing development complies with floodplain construction standards with submittal of required certifications. • Ongoing staff work program.

Chapter 6 – Page 30
Goal 7: Create more housing opportunities for special needs households, including large households, people at risk of or experiencing homelessness, and individuals with disabilities.

Objective: Incorporate special housing needs into City-supported future affordable housing developments.

Lead: Housing and Economic Development
Policy 7.1: For affordable housing projects located near high-quality transit and on City-owned land, with City subsidy, or where otherwise legally defensible, require developers of affordable housing to demonstrate how they will serve people with disabilities in the development.
• Upon the next appropriate affordable housing development:
o Require a minimum percentage of Acutely Low-Income and Extremely Low-Income units with varying bedroom counts to serve the housing needs of special needs populations. o Require developers to affirmatively market accessible units to disability-serving organizations in San Mateo County (i.e., Golden Gate Regional Center, Housing Choices Coalition for Person with Developmental Disabilities, Center for Independence of Individuals with Disabilities, the Mental Health Alliance, and others).
o Encourage developers to coordinate onsite supportive services funded by the Golden Gate Regional Center.
• By 2031, reach 40 new Extremely Low-Income (ELI) units for residents with developmental disabilities.

Objective: Provide housing solutions for unhoused residents in East Palo Alto.

Leads: Housing and Economic Development, Planning
Program 7.2: Finalize the Master Temporary Use Permit process for temporary housing program rollout that includes City coverage of permit fees to provide housing for individuals experiencing homelessness in the community. • Council authorized this program in December 2022.
• First Quarter 2023: Create page on City website for potential applicants with contact information and supplemental TUP application. (Completed in 2022)
• First Quarter 2023: Authorize staff to use housing funds (from Transient Occupancy Tax) to cover permit fees and additional City expenses for Master TUP for temporary housing (Completed Dec. 2022) • First quarter 2023: Reach out to faith communities in East Palo Alto to raise awareness of the Master TUP and encourage applications.
• Resource implications: Housing and Planning staff time; an additional appropriation of $60,000 in Transient Occupancy Tax revenue to fund permit fees and cover additional City expenses for Master TUP applications, up to a maximum of $15,000 per application.

Program 7.3: Evaluate lessons learned and options for longer-term, holistic solutions to RVs parked in public right of way with the conclusion of the RV Safe Parking Program.

Chapter 6 – Page 31
• Ongoing: Continue monthly meetings with City staff, County of San Mateo, and Life Moves and Project WeHOPE to assess options for RVs parked in the public right of way in the coming year, with a view towards concluding the RV Safe Parking Program in April 2023. • Second quarter 2023: Work with Project WeHOPE to report on the successes and lessons learned from the RV Safe Parking Program from 2019-2023. Make recommendations to City Council.

Program 7.4: Research all available public funding sources to address homelessness and consider City investment of funds for homeless outreach, case management and supportive housing to supplement the countywide system. • Ongoing: research and report to City Council on funding opportunities that can support the City’s homelessness response.

Policy 7.5: Pursue expansion of support programs for unhoused residents by establishing partnerships with other public agencies, private corporations and foundations, and non-profit service providers. • 2023 and Ongoing: Continue to seek opportunities for partnerships and financial assistance.

Policy 7.6: Continue to support the low barrier navigation center and emergency shelter operated by WeHope, a community-based non-profit organization, that provides an interim shelter and supportive services for unhoused individuals. Accommodate the special needs of at-risk youths, households with children, and persons with disabilities. • Ongoing: Continue support to WeHope to operate low barrier navigation center and emergency shelter. • 2024: Explore opportunities to establish a facility that can cater to special needs populations.

Objective: Reduce overcrowding and unsafe housing conditions related to housing affordability in East Palo Alto.

Lead: Housing and Economic Development, Planning
Policy 7.7: Develop options for incentivizing deeply affordable housing units that serve larger household sizes, such as allowing additional density or other relaxed or flexible zoning regulations. • Spring 2024: Collect survey data or analyze existing data to identify whether East Palo Alto households consist of direct family, extended family, or other less common household formations to identify bedroom size needs.
• Spring 2024: Incorporate incentivizing larger affordable units into the Community Benefits Framework and broader analysis for implementation of the Ravenswood/Four Corners Specific Plan.

Policy 7.8: Continue to require residential projects to include Extremely Low-Income housing units through the City’s Inclusionary Housing Program. Encourage production of deed-restricted ADUs serving Extremely Low and Very LowIncome households as an Inclusionary Housing Alternative Compliance option instead paying in-lieu fees for fractional unit requirements
• End of 2024: On the City website, demonstrate examples of prior projects that have provided inclusionary ADUs and successfully leveraged incentive programs such as Density Bonus and SB 9.

Chapter 6 – Page 32
Goal 8: Improve transparency and communication between the City and the public on housing issues.

Objective: Make the City website, social media, and newsletter a reliable source of housing information and make parallel efforts to reach residents through mailers and in-person meetings.

Lead: Housing and Economic Development
Program 8.1: Improve and maintain the Housing website as a primary means of communicating the work of the Division. Expand proactive measures to inform homeowners, landlords, and tenants about available local and County housing resources and supportive services.
• Ongoing: Continue to expand and update the Housing Division website to provide a central resource for East Palo Alto residents on housing programs and services.

Policy 8.2: Create a budget for mailers and non-digital outreach on Housing workplan items at the start of each fiscal year.
• First quarter of each year: Review Housing budget for mailers/non-digital outreach. • On a quarterly basis, review Housing website and make improvements as necessary.

Objective: Incorporate language accessibility/language justice into City materials and meetings.

Leads: City Manager’s Office, Planning, Housing and Economic Development Policy 8.3: Provide translation of materials and interpretation of City Council, Planning Commission, Rent Stabilization, and other City meetings in alignment with City’s Language Policy. • Dependent upon timeframe of Citywide Language Policy adoption (goal 2023) Goal 9: Build City capacity for long-term housing planning and implementation of a range of Housing programs and initiatives.

Objective: Maintain sufficient Housing Division staff to implement Housing Element programs.

Leads: Housing and Economic Development, City Manager’s Office Policy 9.1: Regularly assess the level of staffing or contract assistance to ensure that sufficient staffing is committed to implement the 6th cycle Housing Element policies and programs in a timely manner per the Implementation Plan. • Ongoing: Annual review staffing and contract needs during the budget process based on Housing Element work program for the following fiscal year and include sufficient funds in Community Economic Development Department budget,
• Resource implications: Budget for necessary staff and contract costs.

Chapter 6 – Page 33
Objective: Seek efficiencies and collaborative staffing and resource opportunities to simultaneously implement the Housing Element programs and other Housing Division responsibilities.

Lead: Housing and Economic Development
Program 9.2: Join with other cities in San Mateo County to share housing staff to support longer-term housing initiatives and programs.
• The program is projected to be launched in July 2023. Obtain City Council authorization to appropriate funds for the shared housing staff program and execute the relevant agreements with San Mateo County before the end of 2023.
• First quarter 2024: Begin first project with shared housing staff. • Resource Implications: Evaluate City allocation of funds for shared staffing.

Objective: Work in close collaboration with the Planning Division to more efficiently achieve both divisions’ goals and workplan items.

Leads: Housing and Economic Development, Planning
Program 9.3: Collaboratively update the City’s Development Code to align Planning and Housing objectives, with an emphasis of resolving inconsistencies and ensuring consistency with the City’s General Plan. • End of 2023: Begin Development Code updates.
• End of 2025: Complete Development Code updates (amendments may be phased) • Resource implications: Funds available in existing contract with 21 Elements but may require an additional appropriation by the City Council or other grant sources.

Objective: Seek financing sources for affordable housing construction and preservation.

Lead: Housing and Economic Development
Policy 9,4: As Notices of Funding Availability (NOFA) are issued, proactively work with the City’s grant coordinator to selectively apply for regional, state, and federal grants to finance qualifying affordable housing projects and to fund Housing Element programs, such as housing rehabilitation program and first-time homebuyers program. • Ongoing: Annually survey available funding programs and NOFAs and agency announcements.

Objective: Monitor Housing Element Implementation Plan
Lead: Housing and Economic Development
Policy 9.5: Review the Sites Inventory annually to assess progress in achieving the City’s RHNA allocation and, as needed, consider identifying additional sites or adjusting development policies, programs, and priorities.

Chapter 6 – Page 34
• Ongoing: Evaluate during preparation or Annual Progress Report for Housing Element.

Goal 10: Amend Zoning and Other Development Regulations to Facilitate the Construction of Housing.

Objective: Require replacement housing to be provided for applicable housing developments.

Lead: Housing and Economic Development
Policy 10.1: For applicable development projects that will be removing residential units, require a replacement housing program for lower-income households in accordance with Government Code 65583.2(g). • Ongoing: Projects will be reviewed with conditions of approval and agreements executed as needed to ensure compliance with state law.

Objective: Update zoning and development standards to comply with state laws.

Lead: Planning
Program 10.2: Emergency Shelters - Evaluate current sites, development standards, and approval process and update zoning regulations and procedures to comply with AB139/Government Code Section 65583(a)(4)(A).

Program 10.3: Permanent Supportive Housing - Update zoning to require permanent supportive housing to be allowed by-right in residential and mixed-use zoning districts per Government Code 65651.

Program 10,4: Housekeeping Unit - Update zoning and the definition of a “housekeeping unit” to comply with the Employee Housing Act.

Program 10.5: Accessory Dwelling Units (ADUs) - Bring the ADU zoning regulations into compliance with the latest state laws, including addressing programs and policies to facilitate construction of ADUs in Goal 1. Consider additional measures to remove zoning impediments such as relaxing side and rear yard setback and open space standards and facilitating conversion of unpermitted accessory structures to ADUs.

Program 10.6: Residential Care Facilities - Update zoning regulations for residential care facilities to comply with state law and to reduce barriers for establishing facilities for special needs populations such as persons with disabilities. • End of 2023: Begin Development Code updates and with proactive community outreach to receive input; include English language translation in outreach materials and availability of language translation at meetings.

Chapter 6 – Page 35
• End of 2025: City Council adoption of Development Code updates (amendments may be phased) • Resource implications: Funds available in existing contract with 21 Elements but may require an additional appropriation by the City Council or other grant sources.

Objective: Update other zoning ordinance regulations to comply with latest state law and reduce impediments for residential development.

Lead: Planning
Program10,7: Review zoning ordinance regulations and reduce development impediments or provide incentives such as standards pertaining to parking, open space, density bonuses, and objective design standards. • 2023 – 2035: Incorporate zoning amendments and incentives into Development Code update process with objective to further to streamline development review and remove zoning impediments Objective: Adopt update to Ravenswood/Four Corners Specific Plan to include residential uses at designated locations.

Lead: Planning
Program 10,8: Adopt update to Specific Plan to allow residential and mixed-use development at designated locations in plan area and address provisions as noted in other Housing Element policies/programs. Additionally. address byright approval, objective design standards, minimum residential requirements for mixed use zoning, parking, open space, transportation demand management (TDM) program, and other development standards. Further, resolve inconsistencies between the General Plan and current Specific Plan. • Specific Plan Update is currently being prepared by staff with a consultant team and include an environmental impact report.
• End of 2023: Adopt Specific Plan Update, which will also serve as the development code for the plan area and include policies and zoning regulations to address above planning issues. • End of 2023: Plan area sites included in the Housing Element Sites Inventory will be rezoned as part of adoption of the Specific Plan Update.

Chapter 6 – Page 36
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Chapter 7- Page 1
7 REVIEW OF PRIOR HOUSING ELEMENT
State housing element law requires communities to reflect on the outcomes of the previous Housing Element’s goals, objectives, policies, and programs. This evaluation helps ensure that the updated element for 2023-2031 builds on success, learns from lessons learned, and responds to the community’s housing priorities.

7.1 ACCOMPLISHMENTS OF RHNA 5 HOUSING ELEMENT PERIOD
The following summary highlights key accomplishments and challenges from the previous Housing Element’s planning period (2015 to 2022).

Adoption and Implementation of the City’s 2018-2023 Affordable Housing Strategy. The Affordable Housing Strategy was adopted by the City Council in October 2018, a document with ten overarching affordable housing goals and comprehensive workplan comprised of 50 actions that complement and further the policies and programs of the 2015-2022 Housing Element. Since the adoption of the Affordable Housing Strategy, the City has made major progress across all ten areas, with all but three actions completed or in progress. Highlights include:
• Light Tree and 965 Weeks affordable housing developments: the redevelopment of Light Tree will result in 91 net new affordable units and is under active construction, with the final phase of construction completed by end of 2023; 965 Weeks will result in 136 new affordable units on a Cityowned parcel and is expected to begin construction in fall 2023. The building permit application was submitted in mid-December 2022. Light Tree is preserving/renovating 94 existing units and adding 91 new apartments affordable to extremely low-income and very low-income residents, and sets aside as many as 41 units for households with special needs: formerly homeless residents, youth aging out of foster care and households with a family member who has a disability. Light Tree is also the first allelectric affordable housing development in San Mateo County. 965 Weeks is building136 extremely low-income and low-income affordable housing units, ranging from studios to four-bedroom apartments, on a city-owned parcel. It will provide services to residents including a financial literacy program, a vocational development center, afterschool/summer programs and leadership development for youth, and functional assessment and cognitive/behavioral modification for people with special needs.
• Inclusionary Housing: the City Council adopted the most recent Inclusionary Housing Ordinance in November 2019, establishing an inclusionary program for both rental and for-sale units. Since the Ordinance became effective, the City has processed several Inclusionary Housing applications-- often in conjunction with a Density Bonus, and two applications under SB 35—creating a significant pipeline Chapter 7- Page 2
of lower-income rental and moderate-income for-sale units. It should be noted that the inclusionary housing ordinance has helped create greater integration, as it requires a mix of housing units, and housing for larger households, as it applies to all new housing development, including single-family homes, condos and townhomes.
• Investments in Affordable Housing: the City has made major investments in affordable housing in recent years, committing the $10 million in Catalyst Housing Funds to the Light Tree and 965 Weeks affordable housing developments; $714,000 in Housing Successor funds to 965 Weeks; and $1.7 million of Measure HH and Transient Occupancy Tax funds as a local match for the Local Housing Trust Fund program to benefit 965 Weeks.
• Leveraging State Funds for Affordable Housing: the City was a successful co-applicant on two Affordable Housing and Sustainable Communities (AHSC) grants for the Light Tree and 965 Weeks affordable housing developments. Housing and Planning staff have secured a ($2 million) CalHOME, ($160,000) SB 2, ($150,000) Local Early Action Planning, and ($70,000) Regional Early Action Planning (as a sub-allocation) grant over the last three years. • RV Safe Parking: this pilot program on a City-owned site at 1798 Bay Rd. in partnership with Project WeHOPE opened to the first RV households in May 2019; the program has continued with success through 2022, with over 35 individuals housed since the program’s start. This program has helped support persons experiencing homelessness.
• Accessory Dwelling Units: the City has partnered with local organizations to address unpermitted garage conversions and second units for several years and has most recently promoted ADUs through such efforts as: the ADU Streamlining contract, with EPACANDO and City Systems, funded by SB 2, the CalHOME ADU/JADU loan program, and monthly meetings of the ADU Working Group. Since new ADU laws became effective in 2020, the City has seen a more than doubling of ADU applications and permits. Work on legalization of second units continues as a cross-departmental City effort. At a City Council study session the Council directed staff to explore opportunities to encourage the development of ADUs. The City will work with a consultant to update the development code to be consistent with state legislative changes and to encourage more ADUs. This program has helped support large households and elderly residents who want live in single-family homes and want to build an accessory dwelling unit.
• Below Market-Rate Housing Administration: the City released an RFP for BMR Program Administration in 2018 to create a more efficient and cost-effective program. EPACANDO has administered the program since 2019, conducting annual monitoring, facilitating refinances and resales, and establishing ongoing contact with the owners of the City’s 53 BMR for-sale units. By establishing a proper filing system, protocols and guidelines, and a point of contact for public inquiries, EPACANDO has vastly improved the administration of the City’s portfolio and positioned the City well for an increase in units through the Inclusionary Housing Program.

Chapter 7- Page 3
• Homelessness Response: the City has consistently convened a group comprised of County of San Mateo Human Services Agency and Behavioral Health and Recovery Services staff, service providers LifeMoves and Project WeHOPE, and City staff from the Housing Division, Public Works, and Police Department since April 2021. The ongoing dialogue across agencies has created better coordination for housing individuals, monitoring and cleaning up encampments and RVs parked in the public right of way, and providing services to residents in East Palo Alto. • Improved Processing for Streamlined Projects. The City has developed materials for developers, such as zoning clearance forms for ADUs, SB 35, and SB 9 projects, and made internal process improvements to adapt to the ever-changing landscape of state housing law. This has resulted in successful implementation of housing streamlining on mixed-use and residential projects, most of which combine multiple policies – Inclusionary Housing, Density Bonus, and SB 35 or SB 9, for example. In 2021, a total of 88 units from three multifamily residential projects were entitled or received SB 35 Zoning Clearance. Each of these three projects included an inclusionary housing component, for a total of 13 deed-restricted inclusionary units ranging from 35-120% AMI. • Tenant Protections and Outreach. In addition to ongoing implementation of the Rent Stabilization Ordinance which covers approximately 2,500 rental units citywide, the Rent Stabilization Program oversees the City’s various tenant protections, including just cause for eviction, tenant relocation, and others. During the COVID-19 pandemic, the Rent Stabilization Program oversaw an emergency financial assistance program in partnership with Samaritan House and funded local organizations Nuestra Casa, Youth United for Community Action, and Community Legal Services in East Palo Alto to assist local residents with accessing state rental assistance and prevent evictions due to pandemicrelated rental hardships. Special needs populations, including elderly persons, persons with disabilities, large households, female-headed households, and farmworkers have benefitted from the tenant protections and outreach, which is targeted toward the most vulnerable populations.

Updates and Re-Zoning Efforts to General and Specific Plan Areas. The City adopted the Vista 2035 General Plan in 2016, including upzoning in strategic areas and other major changes, such as mixed-use corridors along University Ave, with an emphasis on improving public health through active transportation choices, access to open space, and safe and affordable housing. The Ravenswood/4 Corners Specific Plan Area, the City’s only Priority Development Area, was established in 2013 and is currently undergoing a targeted update that began in 2021 and will significantly increase the number of housing units, including affordable housing units, located near job centers and transit.2
Preservation Efforts. The City received a Challenge Grant and a Breakthrough Grant (“Policy Grants”) from the San Francisco Foundation’s Partnership for the Bay’s Future (PBF), each of which provides a two-year midcareer fellow to pursue housing preservation policies. The City Council considered an Opportunity to Purchase Act ordinance, which is expected to return in a revised form in 2023, and the current fellow is researching cooperative housing models, such as community land trusts, to preserve affordable housing.

Chapter 7- Page 4

7.2 HOUSING ELEMENT PROGRESS
Appendix E provides a program-by-program review of the City’s progress in implementing the 2015-2023 Housing Element programs and objectives, and indication of the programs’ continued appropriateness.

7.3 PROGRESS TOWARDS LOWER-INCOME RHNA 5 TARGETS
To date, the City has made major progress on the very low-income RHNA, exceeding the target by 65 units.

The City fell short of its low-income RHNA by only 19 units, with the largest deficit (196 units) in the abovemoderate income category. Overall, the City has met 53% of its RHNA. By income category, the City has met 27% of its market rate housing target and 88% of its affordable housing target.

Table 7.3 shows the City’s RHNA 5 targets and progress from 2015 to today:

Table 7.3: RHNA 5 Progress, 2015-2022
Income Level 2015 2016 2017 2018 2019 2020 2021 Totals RHNA Deficit
Extremely Low (0%-30% AMI) 16 26 8 50 n/a
Very Low (31%-49% AMI) 4 68 7 79 -65
Low (50%-80% AMI) 24 2 3 6 35 19
Moderate (81%-120% AMI) 1 5 1 2 2 6 17 66
Above Moderate (> 120% AMI) 50 2 5 3 1 4 5 70 196
Total 91 7 5 4 9 103 32 251 216
While the above Table 7.3 illustrates shortfalls in the City’s RHNA 5 targets, it does not show the number of units in the City’s pipeline. There are several major project applications currently under review that, together with several smaller developments, will add over 1,000 units to the City’s housing stock. This includes projects such as the Woodland Park Communities Euclid Improvements, a 605-unit redevelopment of a complex that currently contains 160 rent-stabilized units, for a net increase of 444 units; the EPA Waterfront proposal, a mixed-use project that would add 260 units, and the Harvest: The Landing off-site affordable housing proposal, which would add 95 lower-income units. It should be noted that all housing development in East Palo Alto was delayed due to the Water Moratorium in place from 2016 to 2018. Even with the moratorium no longer in effect, developers have faced further delays due to issues with the East Palo Alto Sanitary District. City Council has been working with the East Palo Alto Sanitary District to express concerns about delays and work toward a solution.

Chapter 7- Page 5

7.4 ONGOING CHALLENGES TO MEETING THE CITY’S HOUSING NEEDS Infrastructure. The chief impediment to further housing development in East Palo Alto remains infrastructure-related. Pipeline projects are experiencing significant delay as the City and developers of affected projects work with the East Palo Alto Sanitary District to find a feasible solution to the system’s capacity. In addition, while the City has largely met its water supply needs, water distribution with the current network of pipelines remains a challenge.

In addition, the City must balance environmental preservation with the utility and feasibility of building out transportation. This is particularly the case in the Ravenswood Business District (RBD)/4 Corners Specific Plan Area, the area of the City where concentrated commercial space and jobs growth, dense housing, and upgrades to transportation infrastructure are planned. Even with these improvements, the City lacks a rail connection.

These issues and the steps the City is taking to ameliorate them are detailed further in the Governmental Constraints analysis in the Housing Constraints chapter, and policies and programs addressing infrastructure are included in the Policies and Programs chapter.

Staffing resources. With limitations on City staff resources, the City is constrained in the actions it can take to counter strong market forces, which continue to push housing prices higher, threaten to displace residents, and fail to produce the types of housing needed most in the community.

Displacement pressures. Residents of East Palo Alto continue to face displacement pressures as housing prices rise in the region and within the city. Data show that, the median income within East Palo Alto is less than half that of the County of San Mateo median, making rents and home sales prices now further out of reach for many households. Overcrowding and substandard housing conditions are prevalent and are a direct result of the housing cost burden many residents face. As additional market-rate housing is proposed for East Palo Alto, it is important that the City pursue ambitious preservation efforts, explore new anti-displacement policies, and prioritize affordable housing as part of the City’s growth, especially in the RBD/4 Corners Specific Plan Area.
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APPENDIX A. PUBLIC OUTREACH AND PARTICIPATION
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Appendix A: Public Outreach and Participation - Page 1
APPENDIX A1 WEBPAGE PERFORMANCE
The following is a report of the City’s Housing Element Webpage analytics from its launch date of March 22, 2021, to July 7, 2022. As shown, the webpage had 640 desktop views, 79 mobile views, and 1 tablet view. The average time a resident spent on the page was 3 minutes. This is 0.15% of the total views the City of East Palo Alto website received in the same timeframe.

Appendix A: Public Outreach and Participation - Page 2
APPENDIX A2 SOCIAL MEDIA PERFORMANCE
The City promoted events and surveys on the City’s Facebook page, which has a total of 3.1K followers as of July 2022, in both English and Spanish (with an option to translate into other languages available through Facebook’s translation system).

Data analytics on Facebook post performance is only available for 90 days, between the dates of April 8, 2022, to July 7, 2022. “Post Reach” provides the number of people who saw any of the posts at least once (and does not include multiple views by the same people), while “Engagement” provides the number of times people engaged with the posts through reactions, comments shares, views and clicks.

In summary:

Our “Help us balance East Palo Alto’s potential future housing development” post on June 3, 2022, reached 494 people, and engaged 33 people.

Our “We’re updating East Palo Alto’s housing plan, and we want you to be part of the conversation” post on May 4, 2022, promoting the May 5, 2022, Community Meeting reached 3386 people and engaged 149 people.

Our “Join us on May 5th at 6pm!” post on May 3, 2022, promoting the May 5, 2022, Community Meeting reached 1284 people and engaged 79 people.

Our “Join us in-person on Thursday, May 5th at 6pm for a community meeting” post on April 28, 2022, promoting the May 5, 2022, Community Meeting reached 662 people and engaged 39.

Appendix A: Public Outreach and Participation - Page 3
Our “Join the joint City Council and Planning Commission Study Session on the Housing Element Update tonight at 6pm!” post promoting a public meeting held on April 26, 2022, reached 354 people and engaged 5 people.

Our “On Tuesday, July 19th, City Council will be discussing the Housing Element Update” post promoting a public meeting held on July 19, 2022, reached 683 people and engaged 24 people.

Data analytics on Event Page performance show a lower success rate in reaching people via event pages compared to posts.

Our May 5, 2022, Community Meeting event page reached 87 people and received 10 responses.

Our February 24, 2022, Community Meeting event page reached 205 people and received 5 responses.

Appendix A: Public Outreach and Participation - Page 4
The following is our highest-performing social media post, demonstrating that short text, strong visuals, and direct links performed better:

Appendix A: Public Outreach and Participation - Page 5
A3 EMAIL ALERTS PERFORMANCE
The City of East Palo Alto sent email alerts to community members subscribed to the Housing Element Update email alerts (15 subscribers until February 2022 and 100+ subscribers after May 2022), and to 500+ community members subscribed to the Ravenwood Business District/Four Corners Specific Plan email list interested in the Housing Element Update process. The email alerts averaged a 57% open rate and a 9% click rate.

July 19, 2021, Community Meeting Alert:

February 24, 2022, Community Meeting Alert:

Appendix A: Public Outreach and Participation - Page 6
April 28, 2022, Joint Planning Commission and City Council Study Session Alert:

May 5, 2022, Community Meeting Alert:

Appendix A: Public Outreach and Participation - Page 7
Balancing Act Survey Alert:

July 19, 2022, City Council Meeting Alert:

Appendix A: Public Outreach and Participation - Page 8
Sample Email Alert – Campaign Preview
1 2 3
Appendix A: Public Outreach and Participation - Page 9
Sample Email Alert – Plain Text Preview
Community meeting on Thursday, May 5 at 6pm.

Reunión comunitaria el jueves, 5 de mayo a las 6pm.

Register | Regístrese | Lesisita (https://us06web.zoom.us/we9egistergister/WN_a9WceWfNQYeAoS9VbiaZg) ----------------------------------------------------------’- We're holding an in-person community meeting to gather your input on the City of East Pal’ Alto's housing plan.

WHEN: Thursday, May 5, 2022, from 6:00-8:00 PM
WHERE: Cooley Landing (at the end of Bay Road) or Zoom
REGISTER: www.tinyurl.com/EPAHousingElement3
If you can't join us in-person you can watch the meeting as a webinar online. Spanish, Tongan, and Samoan interpretation will be available. We will also have free food and childcare. Note that COVID-19 safety precautions will be taken. Please register for the meeting details.

There are other ways to also engage:
* Fill out this survey (https://tinyurl.com/HousingElementSurvey) on Housing Element policies and programs. We want to hear your thoughts on how we are doing with our housing policies and programs, which policies we should keep, and which new policies we should consider to prioritize for the next 8 years!
* Visit Jamboard (https://tinyurl.com/HousingElementJamboard) to share your ideas about the following: what types of housing do you want to see, what locations/sites do you want to see explored, what environmental issues bring you the most concern, and what environmental considerations should we have when zoning for new housing.
* Watch the recent joint City Council and Planning Commission Study Session on the Housing Element Update here
(http://eastpaloalto.iqm2.com/Citizens/SplitView.aspx?Mode=Video&MeetingID=1808&MinutesID=15 29&Format=Minutes&MediaFileFormat=mpeg4).
* Visit the Housing Element Update (https://www.ci.east-palo-alto.ca.us/housing/page/housing-elementupdate-community-meeting-0)webpage.

What is the Housing Element?
The Housing Element is a chapter in the City’s General Plan that is updated every 8 years to plan for new housing and lays out the goals, policies and programs to meet the community’s housing needs. Every California City and county adopts a Housing Element!
Why is my participation in the Housing Element Update important? Your participation in the Housing Element, Safety Element, and Environmental Justice Element updates will help shape our City’s planning documents and determine the goals, policies and programs that will shape our community’s future. Your participation helps us ensure our process is as inclusive and community driven as possible.

What if I can’t make it?
Stay up-to-date and explore our Housing Element page at www.cityofepa.org/housing. You can also submit your comments to [email protected], using “Housing Element Update” in the subject line.

Find Out More (https://www.cityofepa.org/housing/page/housing-element-update-1) ------------------------------------------------------------ La Ciudad tendrá una reunión comunitaria en persona para obtener su opinión sobre el plan de vivienda de la Ciudad de East Palo Alto.

CUÁNDO: Jueves, 5 de mayo del 2022 de las 6:00-8:00 PM
DÓNDE: Cooley Landing (al final de Bay Road) o Zoom
REGÍSTRESE: www.tinyurl.com/EPAHousingElement3
Si no puede asistir en persona puede mirar la reunión como un seminario en línea. Habrá interpretación al español, tongano y samoano. También habrá comida gratis y cuidado de niños.

Tenga en cuenta que tomaremos precauciones de salud para evitar el contagio de COVID-19.

Por favor regístrese para los detalles de la junta.

Hay otras maneras de también involucrarse:
* Complete esta encuesta (https://tinyurl.com/HousingElementEncuesta) sobre las políticas y los programas del Elemento de Vivienda. ¡Queremos escuchar sus opiniones de cómo nos va con nuestras políticas y programas de vivienda, qué políticas debemos mantener y qué nuevas políticas debemos considerar para priorizar durante los próximos 8 años! * Visite Jamboard (https://tinyurl.com/HousingElementJamboard)para compartir sus ideas sobre lo siguiente: qué tipos de viviendas le gustaría ver, qué ubicaciones/sitios le gustaría ver explorados, qué problemas medioambientales le preocupan más y qué consideraciones medioambientales deberíamos tener al zonificar para nuevas viviendas. * Mire la Sesión Especial reciente con el Concejo Municipal y la Comisión de Planificación sobre el Elemento de Vivienda aquí
(http://eastpaloalto.iqm2.com/Citizens/SplitView.aspx?Mode=Video&MeetingID=1808&Minute sID=1529&Format=Minutes&MediaFileFormat=mpeg4).
* Visite la página sobre la Actualización del Elemento de Vivienda (https://www.ci.east-paloalto.ca.us/housing/page/housing-element-update-community-meeting-0). ¿Qué es el Elemento Vivienda?
El Elemento de Vivienda es un capítulo del Plan General de la Ciudad que se actualiza cada 8 años para planificar el desarrollo de nuevas viviendas y establece las metas, pólizas y programas para satisfacer las necesidades de vivienda de la comunidad. ¡Todas las ciudades y condados de California adoptan un Elemento de Vivienda! ¿Por qué es importante mi participación en la Actualización del Elemento de Vivienda? Su participación en las actualizaciones del Elemento de Vivienda, Elemento de Seguridad y Elemento de Justicia Ambiental ayudará a dar forma a los documentos de planificación de nuestra Ciudad y a determinar las metas, políticas y programas que darán forma al futuro de nuestra comunidad. Su participación nos ayuda a garantizar que nuestro proceso sea lo más inclusivo y comunitario posible.
¿Qué pasa si no puedo participar?
Manténgase actualizado/a visitando nuestra página de Elemento de Vivienda en www.cityofepa.org/housing. También puede enviar sus comentarios a [email protected], utilizando "Elemento de Vivienda" en la línea de asunto.

Más información (https://www.cityofepa.org/housing/page/housing-element-update-1) Appendix A: Public Outreach and Participation - Page 10 A4 COMMUNITY MEETINGS REPORT
The following is a summary of community meeting participation in the East Palo Alto community meetings and surveys, and how that compares to 2020 census demographics data.

Demographics Summary
Owner vs Renter Occupancy: Approximately 48% of community members that engaged in the Housing Element Update process were homeowners, and 52% were renters. This compares to a 40:60 ratio of owners vs. renters in the City Age: A majority of community members that engaged in the Housing Element Update process were between 30-49 years old; the second-largest engaged group were 50–69-year-olds. The City has a larger young population of 18 years or under, and a smaller older population of 70+ years.

Appendix A: Public Outreach and Participation - Page 11 Race & Ethnicity: Approximately 46% of community members that engaged in the Housing Element Update process were Hispanic/Latinx, 19% were non-Hispanic White, 16% were Black/African American, and 16% were Asian/Pacific Islander. The largest East Palo Alto population is Hispanic/Latinx at 66%.

Appendix A: Public Outreach and Participation - Page 12 Demographic Breakdown by Community Meeting
Community Meeting #1 – July 19, 2021
No registrant or participant data is available.

Community Meeting #2 - February 24, 2022
Registration & Participation Report
Registration
Time Participated Race/Ethnicity Housing Situation Neighborhood Primary
Language Age
1/28/2022 19:41 No Unknown Unknown Unknown Unknown Unknown 1/28/2022 21:53 Yes Black/African American Tenant (single-family/duplex) The Gardens English 40 – 59 1/28/2022 23:30 No Unknown Unknown Unknown Unknown Unknown 1/29/2022 8:49 Yes Unknown Unknown Unknown Unknown Unknown 1/29/2022 10:16 No Unknown Unknown Unknown Unknown Unknown 1/31/2022 17:20 Yes Other Live but not work in EPA Not applicable English 25 – 29 2/3/2022 12:36 Yes Unknown Unknown Unknown Unknown Unknown 2/3/2022 14:01 Yes White/European Landlord Weeks Area English 60+ 2/5/2022 6:48 No Unknown Unknown Unknown Unknown Unknown 2/5/2022 13:07 No Unknown Unknown Unknown Unknown Unknown 2/5/2022 15:59 Yes Asian Unknown Unknown Unknown Unknown 2/8/2022 11:29 No White/European Tenant (multi-family) Midtown English 30 – 39 2/9/2022 17:27 Yes Asian Work but not live in EPA Not applicable English 30 – 39 2/16/2022 8:51 Yes Black/African American Homeowner The Westside English 60+ 2/16/2022 14:51 No Hispanic/Latinx Other Not applicable English 40 – 59 2/17/2022 15:08 No Black/African American Landlord The Village English 60+ 2/18/2022 16:03 No Asian Homeowner The Gardens Other 40 – 59 2/18/2022 16:28 No Unknown Unknown Unknown Unknown Unknown 2/18/2022 16:48 No Hispanic/Latinx Tenant (single-family/duplex) The Westside English 40 – 59 2/18/2022 17:15 Yes Black/African American Homeowner The Gardens English Unknown 2/18/2022 18:26 Yes Unknown Unknown Unknown Unknown Unknown 2/18/2022 19:59 Yes White/European Homeowner with tenants Midtown English 60+ 2/18/2022 22:33 No Black/African American Live but not work in EPA The Westside English 60+ 2/18/2022 23:23 No Hispanic/Latinx Tenant (single-family/duplex) Unknown Español 30 – 39 2/19/2022 6:33 No White/European Unknown Unknown English Unknown 2/19/2022 6:59 No Unknown Unknown Unknown Unknown Unknown 2/20/2022 7:41 No White/European Homeowner The Westside English 60+ 2/20/2022 20:23 No Hispanic/Latinx Tenant (multi-family) The Westside Español 40 – 59 2/21/2022 9:09 No Unknown Unknown Unknown Unknown Unknown 2/21/2022 9:27 Yes White/European Live but not work in EPA Not applicable English 60+ 2/21/2022 11:18 No Other Tenant (multi-family) The Westside English 60+ 2/21/2022 14:07 Yes White/European Other Not applicable English 60+ 2/24/2022 8:35 Yes White/European Other Not applicable English Unknown 2/24/2022 9:57 Yes Hispanic/Latinx Tenant (multi-family) The Westside English 25 – 29 2/24/2022 11:00 Yes Unknown Unknown Unknown Unknown Unknown 2/24/2022 17:09 Yes Hispanic/Latinx Homeowner The Gardens English 40 – 59 2/24/2022 17:56 Yes Unknown Unknown Unknown Unknown Unknown 2/24/2022 17:59 Yes Unknown Unknown Unknown Unknown Unknown 2/24/2022 18:01 Yes Asian Tenant (multi-family) Not applicable English 18 – 24 Appendix A: Public Outreach and Participation - Page 13 Participant Demographics
Participation Rate:

Out of the 39 registrants, 20 people total (51%) participated.

Race/Ethnicity:

A larger share of participants was White/European and Black/African American.

Housing Situation:

A larger share of homeowners participated compared to tenants.

Neighborhood:

A larger share of participants indicated they live in The Gardens neighborhood, compared to other neighborhoods.

Appendix A: Public Outreach and Participation - Page 0
Language:

A majority of participants were English-speaking.

Age:

A larger share of participants were 60 years and older compared to other age groups.

Appendix A: Public Outreach and Participation - Page 1
Community Meeting #3 – May 5, 2022
Registration & Participation Report
Registration
Time Participated Race/Ethnicity Housing Situation Neighborhood Age Language
Interpretation Used Shuttle
4/28/2022 9:25 Yes, virtually American Indian/Alaska Native Unknown Unknown English 4/28/2022 9:30 Yes, virtually Black/African American Work but not live in EPA The Village 30 – 39 English 5/3/2022 13:20
Yes virtually &
in-person Hispanic/Latinx Tenant (multi-family) Unknown 40 – 59 Español Yes 5/3/2022 14:47 Yes, virtually Black/African American Homeowner The Gardens 60+ English 5/3/2022 15:07 Yes, virtually Hispanic/Latinx Tenant (multi-family) Unknown 30 – 39 English 5/3/2022 15:56 Yes, virtually Hispanic/Latinx Tenant (single-family/duplex) Unknown 40 – 59 Español 5/3/2022 19:13 Yes, virtually Black/African American Homeowner Not applicable 60+ English 5/4/2022 1:40 Yes, virtually Hispanic/Latinx Other Unknown 30 – 39 Español 5/4/2022 12:20 Yes, virtually Hispanic/Latinx Tenant (multi-family) The Westside 40 – 59 Español 5/4/2022 15:00 Yes, virtually Hispanic/Latinx Work but not live in EPA Not applicable 30 – 39 English 5/4/2022 15:57 Yes, virtually Native Hawaiian/Pacific Islander Single family home landlord Midtown 40 – 59 English 5/5/2022 7:19 Yes, virtually Unknown Unknown Unknown English 5/5/2022 9:07
Yes virtually &
in-person Native Hawaiian/Pacific Islander Homeowner Not applicable 40 – 59 Tongan 5/5/2022 10:29 Yes, virtually Asian Work but not live in EPA Not applicable 30 – 39 English 5/5/2022 16:42 Yes, virtually Black/African American Homeowner The Gardens 60+ English 5/5/2022 17:36 Yes, virtually Asian Landlord Not applicable 60+ English 5/5/2022 17:41 Yes, virtually Asian Single family home landlord Not applicable 40 – 59 English 5/5/2022 17:42 Yes, virtually Unknown Unknown Unknown English 5/5/2022 17:49 Yes, virtually Unknown Unknown Unknown English 5/5/2022 17:49 Yes, virtually Hispanic/Latinx Homeowner Unknown 40 – 59 English 5/5/2022 17:57 Yes, virtually Black/African American Work but not live in EPA Unknown 30 – 39 English 5/5/2022 17:59 Yes, virtually White/European Homeowner Unknown 40 – 59 English 5/5/2022 17:59 Yes, virtually Asian Homeowner Unknown 30 – 39 English 5/5/2022 17:59 Yes, virtually Asian Work but not live in EPA Not applicable 40 – 59 English 5/5/2022 18:05 Yes, virtually White/European Work but not live in EPA Not applicable 40 – 59 English 5/5/2022 18:05 Yes, virtually Asian Homeowner The Gardens 40 – 59 English 5/5/2022 18:05 Yes, virtually Asian Homeowner Unknown 30 – 39 English 5/5/2022 18:21 Yes, virtually Hispanic/Latinx Tenant (multi-family) The Westside 30 – 39 English 5/5/2022 18:31 Yes, virtually Hispanic/Latinx Other The Gardens 40 – 59 English 5/5/2022 18:32 Yes, virtually Unknown Unknown English
5/5/2022 18:52 Yes, virtually Hispanic/Latinx Landlord Unknown 40 – 59 English 5/5/2022 19:12 Yes, virtually Native Hawaiian/Pacific Islander Tenant (multi-family) The Westside 30 – 39 English 5/5/2022 19:40 Yes, virtually White/European Homeowner Midtown 40 – 59 English 4/28/2022 9:34 Yes, in-person Asian Homeowner Not applicable 25 – 29 English 5/2/2022 17:12 Yes, in-person Hispanic/Latinx Tenant (multi-family) The Westside 40 – 59 English Yes 5/3/2022 21:00 Yes, in-person Black/African American Unknown Unknown 60+ English 5/4/2022 19:48 Yes, in-person Black/African American Tenant (multi-family) The Westside 40 – 59 English 5/5/2022 8:51 Yes, in-person White/European Homeowner Not applicable 60+ English 5/5/2022 16:46 Yes, in-person Asian, Hispanic/Latinx Tenant (multi-family) The Westside 25 – 29 English 5/5/2022 16:49 Yes, in-person
Hispanic/Latinx, Native
Hawaiian/Pacific Islander Other Midtown 18 – 24 English 5/5/2022 16:54 Yes, in-person Native Hawaiian/Pacific Islander Work but not live in EPA The Westside 18 – 24 English Appendix A: Public Outreach and Participation - Page 2
4/28/2022 9:29 No Black/African American Tenant (single-family/duplex) The Village 30 – 39 English 4/28/2022 10:48 No Black/African American Tenant (multi-family) The Westside 40 – 59 English 4/28/2022 15:07 No Other Other Not applicable 60+ English 4/29/2022 19:10 No Hispanic/Latinx Tenant (multi-family) Unknown 40 – 59 Español 4/30/2022 11:10 No Unknown Unknown Unknown 40 – 59 English 4/30/2022 11:48 No Hispanic/Latinx Landlord Not applicable 40 – 59 English 5/1/2022 19:02 No Hispanic/Latinx Tenant (single-family/duplex) Unknown 40 – 59 English Yes 5/3/2022 8:28 No Unknown Work but not live in EPA Unknown English 5/3/2022 14:22 No Black/African American Homeowner Midtown 60+ English 5/3/2022 14:52 No Hispanic/Latinx Tenant (single-family/duplex) Unknown 25 – 29 English 5/3/2022 14:57 No Hispanic/Latinx Tenant (single-family/duplex) The Gardens 30 – 39 English 5/3/2022 20:24 No Black/African American Homeowner The Gardens 60+ English 5/3/2022 21:02 No Hispanic/Latinx Tenant (multi-family) The Village 40 – 59 English 5/3/2022 22:55 No Black/African American Tenant (single-family/duplex) The Gardens 40 – 59 English Yes 5/4/2022 7:31 No Hispanic/Latinx Tenant (ADU) The Westside 30 – 39 Español Yes 5/4/2022 9:52 No Black/African American Homeowner The Gardens 40 – 59 English 5/4/2022 11:07 No Black/African American Other Unknown 40 – 59 English 5/4/2022 11:29 No Hispanic/Latinx Tenant (multi-family) The Westside 25 – 29 English Yes 5/4/2022 14:47 No Hispanic/Latinx Other Midtown 30 – 39 English 5/4/2022 19:00 No Hispanic/Latinx Single family home landlord The Gardens 40 – 59 Español 5/4/2022 22:52 No Hispanic/Latinx Unknown Unknown 30 – 39 Español 5/5/2022 10:39 No Hispanic/Latinx Other Midtown 40 – 59 Español 5/5/2022 12:54 No White/European Homeowner Unknown 30 – 39 English 5/5/2022 16:40 No Hispanic/Latinx Tenant (multi-family) The Westside 18 – 24 English 5/5/2022 16:53 No Hispanic/Latinx Tenant (single-family/duplex) Midtown 18 – 24 English 5/5/2022 18:36 No White/European Homeowner The Gardens 30 – 39 English 5/5/2022 18:42 No Unknown Unknown Unknown 40 – 59 Español 5/5/2022 19:04 No Hispanic/Latinx Tenant (single-family/duplex) Unknown 60+ English Yes 5/5/2022 18:00 Yes, in-person Hispanic/Latinx Tenant Unknown 18-29 English Yes 5/5/2022 18:00 Yes, in-person White/European Homeowner Unknown 50-69 English 5/5/2022 18:00 Yes, in-person White/European Homeowner Unknown 30-49 English 5/5/2022 18:00 Yes, in-person Native Hawaiian/Pacific Islander Unknown Unknown 30-49 English 5/5/2022 18:00 Yes, in-person Asian, Hispanic/Latinx Unknown Unknown 50-69 English 5/5/2022 18:00 Yes, in-person Asian, Hispanic/Latinx Unknown Unknown 50-69 English 5/5/2022 18:00 Yes, in-person Hispanic/Latinx Tenant The Westside 30-49 Español 5/5/2022 18:00 Yes, in-person Hispanic/Latinx Tenant The Westside 30-49 Español 5/5/2022 18:00 Yes, in-person Hispanic/Latinx Tenant The Westside 30-49 English 5/5/2022 18:00 Yes, in-person Black/African American Tenant Unknown 70+ English 5/5/2022 18:00 Yes, in-person Black/African American Unknown Unknown 50-69 English 5/5/2022 18:00 Yes, in-person White/European Unknown Unknown 30-49 English 5/5/2022 18:00 Yes, in-person Black/African American Unknown The Westside 50-69 English 5/5/2022 18:00 Yes, in-person Hispanic/Latinx Unknown Unknown 30-49 English 5/5/2022 18:00 Yes, in-person Hispanic/Latinx Unknown Unknown 30-49 English 5/5/2022 18:00 Yes, in-person Black/African American Unknown Unknown 50-69 English Appendix A: Public Outreach and Participation - Page 3
Participant Demographics
Participation Rate:

Of the 85 registrants, 67% participated (24 participated in-person, 31 participated virtually, and 2 participated both in-person and virtually).

Race/Ethnicity:

Appendix A: Public Outreach and Participation - Page 4
Photos from May 5, 2022, Hybrid (In-Person and Virtual) Community Meeting Appendix A: Public Outreach and Participation - Page 5
A5 COUNTYWIDE MEETING SUMMARY
A series of countywide meetings about the Housing Element update were held from March to May 2021.

Each meeting provided community members with an introduction the Housing Element update, why it matters, information on the Let’s Talk Housing outreach effort and countywide trends. Breakout room discussions with individual cities and towns followed.

Who We Heard From
In total 1,024 registered for the series and 264 registered for the All About RHNA meeting. Of those who registered for the series, the majority identified as White (66%) or Asian (15%) and were 50 years or older; nearly half were 50 to 69 years old and almost a fifth were over 70. Almost half had lived over 21 years in their homes, and three-fourths owned their own homes.

East Palo Alto was part of the May 30th introductory meeting, along with Burlingame, Hillsborough, Millbrae and San Mateo City. Due to technical difficulties, a second meeting was held on May 6th.One person who lives in East Palo Alto registered as a participant. She was a renter who had lived in the City between 0 and 5 years. Demographically, she was a White woman between the ages of 50 and 69. This is not an appropriate sample of the participants, however, because between 10 and 15 people participated in the breakout room.

Appendix A: Public Outreach and Participation - Page 6
What We Heard
Main Meeting
People were asked to share a word in the chat describing housing now at the beginning of the meeting, and the housing they envisioned in their communities ten years from now.

Now In 2030
Breakout Session
There was a lively discussion with approximately 10-15 people in attendance. There was a feeling that East Palo Alto was doing a lot, with one participant saying, “It seems like EPA is the most ambitious City on the peninsula,” but that a lot is not enough. The primary concern heard from the group was the lack of affordable housing. This applied to both housing for extremely low-income households as well as moderate income/ownership opportunities. There was support for tiny homes and looking at employers to do more.

Post Event Survey
The post-event survey reflected the variety of opinions present on issues ranging from a desire to preserve communities as they are, to an appeal for more and diverse housing everywhere in the county. Despite the technical difficulties, community members responded that they valued the space and the information provided within it and looked forward to spaces where more meaningful and engaged discussion could take place.

Appendix A: Public Outreach and Participation - Page 7
A6 SURVEYS REPORT
Whiteboard Survey
Results
Input on July 19, 2021, Community Meeting
Note: Clearer version of sticky note responses is unavailable.

Appendix A: Public Outreach and Participation - Page 8
Jamboard Survey
Results
Slide 1 – Input from May 5, 2022 – July 7, 2022
Appendix A: Public Outreach and Participation - Page 9
Slide 2 - Input from February 24, 2022 – July 7, 2022
Appendix A: Public Outreach and Participation - Page 10 Survey Themes
• Improved housing & neighborhood conditions
• Deeper housing affordability
• More homeownership opportunities
• Reduced constraints to affordable housing
• Environmentally sustainable development
• Anti-displacement
Slide 3 - Input from February 24, 2022 – July 7, 2022
Slide 4 - Input from February 24, 2022 – July 7, 2022
Appendix A: Public Outreach and Participation - Page 11 May 5, 2022, Community Meeting In-Person Survey Results Online and In-Person Interactive Activity
Appendix A: Public Outreach and Participation - Page 12 In-Person Post-It Activity
Appendix A: Public Outreach and Participation - Page 13 Policies and Programs Survey
Survey Results

1. Which of the following goals is most important to you? • GOAL 1: Meet the RHNA & produce all housing types
• GOAL 2: Link jobs + housing
• GOAL 3: Available sites for the development of housing • GOAL 4: Reduced constraints & enhanced incentives for housing development • GOAL 5: Special needs housing
• GOAL 6: Financial or policy assistance to low-income households • GOAL 7: Increased homeownership opportunities
• GOAL 8: Minimized tenant displacement
• GOAL 9: Improved housing & neighborhood conditions
• GOAL 10: Fair Housing & decent, safe living environments for all • GOAL 11: Implementation & use of housing policies
• GOAL 12: Energy efficiency
• OTHER (written responses):
• Protection of the green space and wildlife habitat especially on the West Side • Finding a solution that benefits both tenants and homeowners • More trees and more parking spaces
• Enforce existing laws, parking on sidewalks, speeding and reckless driving, animal control, noise violations, fireworks, housing code enforcement etc… • Deal with the sewer company issues that have prevented housing or that will make low income folks pay for new sewer lines. Crazy!
• Re goal #6, increased first-time homeownership opportunities specifically for low-income, long-time residents and young people through policies like TOPA/COPA and more. • Homeless Transition Housing plus integrated social services • Have a clean and safe community where the law is enforce Appendix A: Public Outreach and Participation - Page 14 Appendix A: Public Outreach and Participation - Page 15 Goal 1: Sufficient numbers and varieties of housing units (houses, townhomes, condominiums, and apartments) needed to: meet the State’s mandate to replace affordable units/bedrooms demolished due to Redevelopment Agency action; address the City’s Regional Housing Needs Determination; and facilitate housing development for all incomes segments within East Palo Alto, including extremely low-, very low-, low-, moderate-, and above-moderate income housing.

GOAL 2: Balanced development that links housing to jobs.

GOAL 3: Available residential sites for the development of a range of housing types.

Appendix A: Public Outreach and Participation - Page 16 GOAL 4: Reduced constraints and enhanced incentives for housing development within the City, particularly in regard to affordable housing.

GOAL 5: Adequate housing for special needs groups in the City, including seniors, physically challenged, HIV positive or living with AIDS, homeless, at-risk youth (leaving the foster care system), small and large families, veterans, farm workers, people with developmental disabilities, and female headed households.

GOAL 6: Financial and policy assistance for low- and moderate-income households to ease housing cost burden and overcrowding.

Appendix A: Public Outreach and Participation - Page 17 GOAL 7: Increased homeownership opportunities for income-qualified households (focused on existing residents and workers in East Palo Alto).

GOAL 8: Minimized Displacement of Renter.

GOAL 9: Improved Housing and Neighborhood Conditions in East Palo Alto.

Appendix A: Public Outreach and Participation - Page 18 GOAL 10: Decent, safe living environments for City residents regardless of age, gender, race, color, ancestry, national origin, familial status, marital status, sexual preference, religion, disability, language, or any other arbitrary factor.

GOAL 11: Implemented housing policies and broad participation in associated programs.

GOAL 12: Increased energy efficiency in existing and new housing development, in part as a means of reducing housing cost.

Appendix A: Public Outreach and Participation - Page 19 Balancing Act Survey
Balancing Act Page Preview
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Appendix A: Public Outreach and Participation - Page 20 Sample Survey Questions
Appendix A: Public Outreach and Participation - Page 21 Performance Analytics
The City of East Palo Alto received the second-highest engagement compared to other California cities participating in this simulation tool, with 12 unique respondents total.

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 technological knowledge.

Balancing Act Survey Respondent Demographics
Resident Age Race/ Ethnicity Neighborhood Housing Situation 1 Yes 40 - 59 Other Westside Tenant (single-family/duplex) 2 Yes 30 - 39 Asian Westside Homeowner
3 Yes 40 - 59 White/European Gardens Homeowner
4 Yes 40 - 59 White/European Gardens Homeowner
5 No 60+ White/European Not applicable Work in EPA but live elsewhere 6 Yes 60+ White/European Unknown Single family home landlord 7 Yes 60+ White/European Unknown Homeowner
8 No 40 - 59 White/European Not applicable Work in EPA but live elsewhere 9 Yes Unknown Unknown Unknown Homeowner
10 Yes 40 - 59 Other Village Tenant (single-family/duplex) 11 Yes 30 - 39 Hispanic/Latinx Unknown Tenant (single-family/duplex) 12 Yes 40 - 59 Hispanic/Latinx Unknown Other
Appendix A: Public Outreach and Participation - Page 22 Balancing Act Survey Results
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 –
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
Appendix A: Public Outreach and Participation - Page 23 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 East Bayshore)
c. Weeks Street site (851 Weeks Street)
d. Donohoe Street site (801 Donohoe Street)
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 the East Palo Alto City Hall is currently located. Due to community input, and later conversations regarding feasibility on the site, 2415 University Ave. was not included in the sites inventory for future development.

Intercept Survey
Survey Results
On June 18, 2022, and June 15, 2022, we 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 we engaged, 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.

Respondent Demographics
Of the 30 respondents, approximately 13 were
homeowners, 15 were tenants, and 2 were young
people under the age of 18 and living with their
parents.

Appendix A: Public Outreach and Participation - Page 24 The majority of respondents (80%) were
monolingual Spanish-speakers.

The majority of respondents were women
between the ages of 30-49.

Appendix A: Public Outreach and Participation - Page 25 A7 – EQUITY ADVISORY GROUP INPUT
Following a series of Housing Element presentations by San Mateo County jurisdictions to the Equity Advisory Group (EAG), some members of the EAG followed up to 21 Element jurisdictions with a collaborative letter to send all their Housing Element feedback summarized in one letter. The following is the letter in its entirety:

To the 21 Elements team and all San Mateo County jurisdictions, The Equity Advisory Group exists to help San Mateo County jurisdictions implement policies that promote fair housing choice and access to opportunity for members of historically marginalized groups. We are a group of service providers and housing activists, convened to inform equitable policy making in housing elements.

Thank you to the 21 Elements team for promoting the EAG and thank you to the City staff that are giving us this opportunity to share our perspectives.

With this letter, the EAG proposes specific policies San Mateo County jurisdictions can implement to promote equity through their housing elements. These policies were selected by EAG members because of their proven track record for promoting equity goals, primarily the production of affordable homes and protection of renters. As service providers and advocates, we take a broad approach to housing equity. To us, equity means that everyone in a community, regardless of background, has access to safe, stable, affordable housing.

However, housing equity does not stop at a jurisdiction’s borders. True equity means that no one is excluded from a community because of lack of access to housing. “Lack of access” can come in many forms, whether that be physical inaccessibility, language barriers, distance from community resources, or prohibitive cost. In order to ensure that no one is excluded from a community, jurisdictions must affirmatively promote fair housing for all by regularly changing regulations to facilitate a wider range of housing types.

In practice, equity can be controversial, because increasing equity sometimes requires changes to status quo policies. We see this process as an opportunity for jurisdictions to commit to implementing new policies with the support of the state of California behind you.

Policy Recommendations
Guidance from HCD on how to affirmatively further fair housing states that jurisdictions must promote fair housing choice and access to opportunity in their goals, policies, and programs. HCD defines fair housing choice as encompassing:
• Actual choice, meaning the existence of realistic housing options • Protected choice, meaning housing that can be accessed without discrimination; and • Enabled choice, meaning realistic access to sufficient information regarding options so that any choice is informed.

Appendix A: Public Outreach and Participation - Page 26 Jurisdictions cannot meet the requirement to promote fair housing choice and access to opportunity without first completing a thorough and meaningful assessment of the housing needs of residents, including factors which may limit fair housing choice as well as both governmental and non-governmental constraints to housing production. Jurisdictions should complete all relevant analyses before formulating their policies and programs. As such, appropriate policies and programs for each jurisdiction will vary based on the needs of your specific community.

Below are a list of general policies which the EAG would recommend as a minimum to Affirmatively Furthering Fair Housing in your jurisdiction. Programs to implement these policies, as defined by HCD, must include concrete steps, timelines, and measurable outcomes.

Policy Description How does it AFFH?
Just cause eviction, relocation
benefits, and first right of
return
Tenant protections beyond state
law. (Ex: Oakland Just Cause for
Eviction Ordinance; Redwood
City Relocation Assistance
Program, LAHD Rent
Stabilization Ordinance)
Implemented in tandem, this set of policies
can protect lower-income tenants living in
NOAH who are evicted through no fault of
their own, providing them the resources to
relocate or the option to first right of return.

Prioritize City affordable
housing funds,
City-owned land, and land
dedicated to affordable
housing for projects which
include more units at deeper
levels of affordability or for
special needs populations at
greatest risk of homelessness
or displacement.

Scoring guidelines for RFPs for
these City resources should give
greater preference for projects
which include more units at
deeper levels of affordability or
target special needs populations.

In 2021, the SMC HSA Center on
Homelessness reported that 96% of
Homeless Outreach and Shelter Clients were
extremely low income. Jurisdictions cannot
begin to address the needs of the unhoused
and other at-risk populations without
addressing the lack of deeply affordable
housing.

Expand local funding
sources for development of
affordable housing
Can include policies such as
commercial linkage fees,
vacancy taxes, transfer tax, etc.
(Ex: San Jose Measure E)
Most affordable housing projects require a
source of gap funding in order to be
financially feasible, especially if they are
targeting deeper levels of affordability.

Local investment in these projects can also
make them more competitive for state and
federal funding.

Appendix A: Public Outreach and Participation - Page 27 Rent stabilization Tenant protections beyond state
law. (Ex: Oakland Rent
Adjustment Program, LAHD
Rent Stabilization Ordinance)
Stagnant wages for the lowest income
residents have not kept pace with rising
housing costs, becoming one of the largest
contributors to our current housing crisis.

Local rent control with greater protections
beyond state law will help to keep more
lower income renters stably housed.

Fee exemptions for 100%
affordable housing projects
According to the 21 Elements Fee Survey,
jurisdictions charge fees ranging from $6,824-
$167,210 per
unit in multifamily housing. These
additional fees can make many affordable
housing projects, which rely on public
subsidy, infeasible. Waiving or lowering
fees for 100% affordable housing projects
can promote the production of more
affordable housing across a spectrum of
income levels.

Allow exceptions to
development standards for
100% affordable housing
projects
Can include but is not limited to
reduced/waived parking
requirements, Minimum lot
sizes, widths, setbacks, etc (Ex:

Half Moon Bay)
Many projects utilize State Density Bonus
Law (SDBL) to increase financial feasibility
of projects through incentives and
concessions. Local exceptions to
development standards for 100% affordable
housing projects increases feasibility above
and beyond what would be enabled through
SDBL.

Implement inclusive
design standards
Implement design standards
beyond state and federal law to
increase cross-disability access
to housing (Refer to The
Kelsey’s Housing Design
Standards for Inclusion and
Accessibility)
While landlords are required to approve
reasonable accommodations requested by
persons with disabilities, often the burden of
financing physical modifications of a unit
falls upon the tenant, many of whom cannot
afford these expensive renovations.

Inclusive design can significantly reduce
requests for reasonable accommodations and
lower overall costs of modifying units.

Inclusive design also supports cross-disability
access.

Appendix A: Public Outreach and Participation - Page 28 Increase language
accessibility
Require affirmative
marketing of units to nonEnglish speakers, make
multilingual
applications available, and
perform active outreach to newly
arrived immigrants and
refugees.

Language can create one of the highest
barriers to access for affordable housing.

Affirmative marketing to non-English
speakers will ensure all members of our
communities can access the resources
available to them, regardless of country of
origin.

Promote fair housing
information to residents
Provide residents with information
about renter protections and
monetary relief available to
victims of unlawful housing
practices. Post information in
easily
Renters are often unaware of the protection
and resources afforded them under
California state law.

Jurisdictions can help promote fair housing by
proactively ensuring that renters are aware of
their rights.
available locations on jurisdiction
websites and send regular mailers
to renters within the community.

Analyze past racially
discriminatory policies and
report data regarding ongoing
impacts

1.Conduct a systematic review of
the preliminary title report and
eradicate any language of
racially restrictive covenants.

2. Provide information re: location
and ratio of renters and owners
and their correlation with the
patterns of racial and ethnic
segregation in San Mateo
County.

3. Provide information re:
demographics and
environmental health – identify
disparities in access to
environmentally healthy
neighborhoods.

Jurisdictions are most likely to reduce the
racial homeownership gap if they actively
identify the ways in which past racially
restrictive regulations and current barriers to
affordable housing create our socioeconomic
disparity in home ownership. Home
ownership is one of the most powerful
vehicles for multigenerational economic
security. Employing a health-equity lens
throughout planning and re-zoning efforts
will further fair housing policy goals.

Affordable housing overlay
for nonprofits and religious
institutions
Create a housing overlay allowing
at least the local mullin density
(20 or 30 du/ac) on all nonprofitor religious institution-owned land throughout the entirety of
jurisdiction. Relax design
standards and zoning regulations
for projects with 20% extremely
low income, 30% very low
Jurisdictions promote equity when they
allow affordable, multi-family housing in
new areas. Nonprofits and religious
institutions have strong incentives to
promote affordable housing development.

By facilitating affordable housing on land
owned by religious institutions, regardless of
local zoning, jurisdictions can help those
institutions accomplish their missions of
Appendix A: Public Outreach and Participation - Page 29 income, or 50% low income
units.
providing for the needy while also
affirmatively furthering fair housing in new
areas.

Accessible housing near
transit
Reduce parking minimums for
developments within 0.5 miles of
transit. Eliminate parking
minimums entirely for
developments within 0.5 miles of
transit that serve residents with
disabilities and low-, very low-, or
extremely low-income
households.

Parking minimums raise the price of housing
and de facto subsidize car ownership.

Especially when located near transit, these
policies impose a significant burden on
housing. In the cases of low-income
households, which can typically afford no
or limited car ownership, and the disabled,
these policies become entirely superfluous.

The Equity Advisory Group recommends that every jurisdiction in San Mateo County implement these proposals to the best of their abilities. Implementing these policies will demonstrate your community’s commitment to affirmatively furthering fair housing for all.

Thank you for your consideration, Kalisha Webster
Senior Housing Advocate, Housing Choices
Hyun-mi Kim
Housing Advocacy Director, Puente de la Costa Sur
Jeremy Levine
Policy Manager, Housing Leadership Council
Signed on behalf of the 21 Elements Equity Advisory Group Appendix A: Public Outreach and Participation - Page 30 A8 PUBLIC REVIEW PERIOD
Table A8.A summarizes the comments received during the public review period between August 29, 2022 and October 3, 2022, and how they are addressed in the Housing Element. An additional comment letter was received after the review period, on November 22, 2022, and is also included below.

Table A8.A: Comments During First Public Review Period
Date From Summary How It Is Addressed
9/29/2022 Victoria Wong,
MidPen
Housing
Asks for clarifying language regarding City capital
improvements and water line upgrades that will benefit the 965 Weeks development project.

Clarifying language was added.
9/29/2022 Melissa Borgesi,
Midpeninsula
Regional Open
Space District
Comments on development in the Ravenwood Business
District/4 Corners Specific Plan. Asks for additional park and open space requirements within RBD/4 Corners Specific
Plan, because new housing in the area can exasperate demand in visitation. Recommends several active transportation options when integration parking reduction.

City is still reviewing potential
densities.
9/30/2022 Corinne I.

Calfee, Opterra
Law Inc.
representing
Sand Hill
Property
Company
Highlights importance of entitled and highly probable
projects getting entitled and built. Comments on probability of two major development projects. Comments on processing times being longer, and need for streamlining.

City Council approved
Woodland Park Euclid
Improvements Development
Project on November 15, 2022.
which required General
Plan/zoning amendments to
significantly increase density,
an EIR, a tenant relocation plan,
infrastructure improvements,
and a development agreement.

City is prioritizing streamlining
development.
9/30/2022 Keith Diggs,
YIMBY Law
Commends City for doubling lower-income allocations.

Offers support if state law does not offer right of return support for displaced residents. Water is more important than design review. Also, need for shorter process times for new apartments.

City is prioritizing
streamlining development.

City also recently adopted
Master Water Plan (on
October 4, 2022). More
Appendix A: Public Outreach and Participation - Page 31 discussion around water was
added.
9/30/2022 Jeanne Yu,
resident
Comments on programs and policies recommended for nonprofits to own, acquire, and build property and land. Asks that nonprofits not interfere with home selling process.

City is still studying program,
no decision has been made.
9/30/2022 Kevin Keating,
14 year resident
Comments on density and zoning. Asks for re-evaluation of lots zoned higher density or urban residential near single family neighborhoods. Asks that higher density be along major thoroughfares (University Ave/Bay Road), close to transit and major arteries.

Housing opportunity sites take
into consideration transit
concerns.
9/30/2022 Moana Kofutua,
Youth United
for Community
Action
Asks for Spanish and Tongan translation and simplification of the Housing Element documents. Wants clarity on why
many affordable housing developments have not shown
promise for community members.

City Language Access Plan is
under way. City is prioritizing
development of extremely and
very low-income units in
alignment with community
needs.
9/30/2022 Julian Sierra,
Youth United
for Community
Action
Suggests breaking down abbreviations, translation in
Spanish and Tongan, and simplification of wording. Asked for more details on water sources. Asks for more City
staffing. Recommends community forum to actively
dismiss misinformation.

City Language Access Plan is
under way. Abbreviations
were broken down. Water
sources details were added.

City staffing is mentioned.
9/30/2022 Dani Montes,
Youth United
for Community
Action
Recommends focusing on incentivizing building affordable ADUs.

Plan for ADU streamlining
and incentives is in Policies
and Programs.
9/30/2022 Hailey Romero,
Youth United
for Community
Action
Comments on need for better marketing of affordable
housing units. Comments that the average housing income in East Palo Alto is lower than the moderate and above
moderate incomes. Comments on project delays generally.

Program for improved
dissemination of information
is in the City’s housing plan.

City is prioritizing
streamlining development.
9/30/2022 Estefani Ruiz,
Youth United
for Community
Action
Comments on need for translation of City fliers and notices. City Language Access Plan is under way.

Appendix A: Public Outreach and Participation - Page 32 9/30/2022 Jaliyah Minor,
Youth United
for Community
Action
Comments on need for quality education, and prioritizing ADUs.

Plan for ADU streamlining is
in Policies and Programs.
9/30/2022 Ingrid Ruiz,
Youth United
for Community
Action
Questions how moderate and above moderate housing will
benefit the community if the majority of East Palo Alto residents are low-income. Comments on need for more
affordable housing. Asks for accountability in carrying out Housing Element.

City is planning for moderate
and above moderate housing
to comply with RHNA 6
requirements.
9/30/2022 Ivan Valencia,
Youth United
for Community
Action
Comments on need for better quality education, and
addressing displacement and gentrification. Suggests
simplifying Housing Element language.

Plan to address displacement
and gentrification is in
Policies and Programs.

Abbreviations were broken
down for greater access.
9/30/2022 Xenia
Hernandez,
Youth United
for Community
Action
Comments on translation need for Spanish and Tongan
speakers to make the Housing Element more inclusive.

City Language Access Plan is
under way.
9/30/2022 Fernando
Medrano, Youth
United for
Community
Action
Comments on need to advertise new low income housing
(for LightTree apartments and Weeks).

Program for improved
dissemination of information
is in the City’s housing plan.
9/30/2022 Filiberto
Zaragoza, Youth
United for
Community
Action
Comments on need for lower income units, rather than
moderate and above moderate units because East Palo Alto is a low income community. Comments on need for
programs that support families in becoming homeowners.

City is planning for moderate
and above moderate housing
to comply with RHNA 6
requirements. Program for
homeownership opportunities
is in the City’s housing plan.
10/3/2022 Harvey
McKeon,
NorCal
Carpenters
Union 217
Comments on Four Corners and the Ravenwood Business
District Specific Plan Area. Asks that the City’s CEQA
analyze the impacts resulting from construction-related employment and the environmental impacts on the Project’s construction workers.

Environmental review of
RBD/4 Corners Specific Plan
Area is underway.

Appendix A: Public Outreach and Participation - Page 33 11/22/2022 Jeremy Levine,
Housing
Leadership
Council of San
Mateo County
Comments on City’s progress toward RHNA 6.

Examines sites inventory and constraints. Requests
additional evidence for realistic development on non-vacant sites. Comments that projected affordability levels of units at 2277 University Ave might be too low and financially infeasible. Requests 560 Bell rezoning to “Mixed-Use
High” to match surrounding area. Requests Bay Rd. site
rezoning to MUC-1 to facilitate school district development of site. Requests City commits to rezoning EPA Waterfront, 1103 Weeks St., and 1200 Weeks St., and reduce the
number of very low- and low-income units to include a
proportion of moderate and above-moderate income
housing. Recommends following changes to governmental
constraints: 1) increasing FARs; 2) reducing rear setbacks for high-density areas; 3) make firm commitments to
reduce discretionary approval times.

Evaluates goals, policies and programs, and provides
recommendations to remove constraints. Requests direct
connection to identified needs, governmental constraints, and sites inventory.

See Appendix D for
additional evidence for
realistic development on nonvacant sites.
2277 University Ave
assumptions based on
potential site merge. 560 Bell
removed from sites inventory
For FARs, setbacks, etc., sites
may be subject to density
bonus law, which creates
more flexibility. The City will
continue to convert subjective
standards to objective
standards, which will create
more certainty and efficiency.

Policies and Programs
updated to reflect
commitment to reducing
governmental constraints.

Table A8.B summarizes the comments in the months of January and February 2023, after releasing a revised draft of the Housing Element for additional public review. A second revised draft was released on January 17, 2023, before a Planning Commission discussion of the Housing Element on January 23, 2023, and a third revised draft was released February 6, 2023 for a 7-day review period.

Table A8.B: Comments During Second Public Review Period Date From Summary How It Is Addressed
1/17/2023 Jeremy Levine,

HLC-SMC
Sought response to letter from City Council Responses included in Appendix A8.A
1/23/2023 Federico
Andrade Garcia,
resident
City should focus on production of multi-family housing rather than preservation of single-family dwellings. City should “think outside the box” and have mixed-use
developments with apartments over retail or markets. Retail is City is encouraging mixed-use
development along the
University corridor and in the
Ravenswood Business
Appendix A: Public Outreach and Participation - Page 34 far away, people need to get in their cars. Stop impacting single family homeowners with OPA and search for other
solutions that benefit everyone.

District/Four Corners Specific
Plan Area. OPA is policy
consideration for housing
preservation and is only in
exploratory stage.
1/25/2023 Corie Calfee,
Opterra Law
Inc. representing
Sand Hill
Property
Company and
Woodland Park
Communities
Process unclear and confusing. Public review period needs to extend to full 7 days. No agenda posted for noticed January 24 City Council meeting. Need accurate, clear information.

Comments regarding 1) Governmental Constraints to
Housing, and 2) Feasibility/Likelihood of Development.

Regarding 1) Governmental Constraints: a) Housing Element does not address infeasibility of inclusionary housing
ordinance due to high level of inclusionary housing and deep affordability; it creates cost burden and threatens viability of market rate rental projects. Euclid Improvements had to seek alternative compliance to attempt to make project feasible.

City considering onerous requirements for projects in RBD that will make housing construction expensive; b) processing time for Euclid Improvements project took 46 months for submission of required entitlements pre-application, and City required 20 public meetings to approve. c) Four Corners project in process also long. Not clear how average
processing time is lower; d) business license taxes are governmental constraint. Regarding 2) Feasibility/Likelihood of Development within Housing Element Cycle: a) Housing Element should rely on projects expected to be developed during planning period, but concerned Euclid Improvements project unlikely to be developed during planning period.

Given climate of high interest rates and high construction costs, not reasonable for City to rely upon Euclid
improvements to meet RHNA.

Inclusionary housing ordinance
and business license tax added
to governmental constraints.

Note that these policies and
programs help affirmatively
further fair housing .

Project processing times further
differentiated for typical
projects that do not require
General Plan and zoning
changes. Euclid Improvements
Project required General Plan
and zoning changes, and a
Development Agreement with
complex relocation plan,
infrastructure issues, and offsite affordable housing
compliance.

Added policies and programs to
streamline development review.

City committed to
implementing AB 2234 to
permit streamlining for postentitlement building and related construction permits.
1/26/2023 Auria
Maleksalehi,
attorney, broker,
contractor
Sought copy of HCD comment letter and update on January 23, 2023 Planning Commission Meeting.

Information available on
Housing Element webpage.

Appendix A: Public Outreach and Participation - Page 35 2/2/2023 Wyatt Meyer,
The Mulholland
Drive Company
Asked if the Housing Element has been adopted and if the City is planning on rezoning properties in the Housing
Element
Information available on
Housing Element webpage.
2/3/2023 Ofelia Bello,
Youth United
for Community
Action
Comments regarding: 1) Governmental Constraints, 2)
Levels of Review, 3) Affirmatively Furthering Fair
Housing, and 4) Policies and Programs. Regarding 1)
Governmental Constraints, 1) urges City to explore
incentives and approaches that allows Low-Barrier
Navigating Center to support youth experiencing
homelessness; 2) asks City to continue to prioritize fair and lawful review processes in housing development, provides Woodland Park Euclid Improvements Project as example;
3) asks City to increase staffing capacity for Building, Code Enforcement, Planning and Housing departments; 4a) asks that OPA be included in Housing Element given its
incorporation in City’s 2018 Affordable Housing Strategy; 4b) urges City to prioritize work to address habitability issues; 4c) asks City to hire additional staff and prioritize building capacity for long-term housing planning and
implementation of programs
City can work with LBNC to
seek additional youth support;
Housing Element policies that
affirmatively further fair
housing balance need for
streamlining and community
input; increasing staffing
capacity included under
Policies and Program goals.
2/13/2023 Corie Calfee,
Opterra Law
Inc. representing
Sand Hill
Property
Company and
Woodland Park
Communities
Comments regarding:
1) City’s Inclusionary Housing Ordinance– provides that the ordinance is infeasible and the City as had no rental projects in compliance with the ordinance;
2) City’s Local Processing Times – questions accuracy of revised processing times for multi-family projects, states average underestimates amount of time projects take, and that the City does not propose any modifications to
processes to facilitate approvals;
3) City Fees and Taxes – adds City’s business license tax as governmental constraint;
1) Inclusionary Housing is in
governmental constraints.

City’s inclusionary housing
ordinance is in compliance
with state law and comparable
to other jurisdictions’
ordinances, allowing for
alternative compliance
options, incentivizing
construction of units over
paying in-lieu fees (including
an exemption for deedrestricted affordable units),
and promoting integration.

Several rental projects have
been approved in compliance
Appendix A: Public Outreach and Participation - Page 36 4) Feasibility and Likelihood of Projects – states Euclid Improvements project is unlikely to be constructed within planning period given City’s requirements for approval and current market conditions of high interest rates and high construction costs; states Four Corners site has been
delayed and City should commit to items beyond “study”. 5) Quantified Objectives – states unclear how quantified objectives were calculated, and Euclid Improvements and Four Corners projects should be removed from quantified objectives.
with the ordinance. 2)
Processing Times – the City
has approved two large multifamily projects: LightTree Apartments and 965 Weeks.

The processing times for the
Euclid Improvements Project
was an outlier, given nature
of the project, including the
number of units, required
entitlements (zoning text and
General Plan amendments), a
development agreement with
a robust relocation and antidisplacement plan,
3) Fees – the City added the
business license tax, Measure
L, to government constraints.

The fee will go toward
affordable housing
preservation and rental
assistance to protect tenants
from displacement
(affirmatively furthering fair
housing);
4) Feasibility – State Law
allows approved projects to be
counted in RHNA, including
the Euclid Improvements
project. Further, the additional
analysis identified (e.g.,
barriers to development) only
applies to projects not entitled
Appendix A: Public Outreach and Participation - Page 37 after June 30, 2021.70 City
committed to implementation
of AB 2234 to allow for
streamlined processing.
5) Quantified objectives
section was amended to
reflect methodology.
70 City of Union City’s 6th Cycle (2023-2031) Draft Housing Element (ca.gov) (requiring Union City “clarify the availability or likelihood these projects will be completed in the planning period, including necessary and anticipated steps for completion, phasing, build out horizons, any barriers to development and other factors and adjust projections as needed” because the project was not entitled after June 30, 2021).
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Appendix B: Housing Needs Data

APPENDIX B HOUSING NEEDS DATA
[Intentionally Left Blank]
Appendix B: Housing Needs Data – Page 1
APPENDIX B1 EAST PALO ALTO HOUSING NEEDS DATA REPORT
HOUSING NEEDS DATA REPORT: EAST

PALO ALTO
ABAG/MTC Staff and Baird + Driskell Community Planning
2021-04-02
Appendix B: Housing Needs Data – Page 2

0.1 Table of content

0.1 Table of content ..................................................................................................... 2

0.2 List of figures ........................................................................................................ 3

0.3 List of tables ......................................................................................................... 4 1 Introduction ............................................................................................................... 5 2 Summary of Key Facts ................................................................................................... 6 3 Looking to the Future: Regional Housing Needs ..................................................................... 9

3.1 Regional Housing Needs Determination ........................................................................... 9

3.2 Regional Housing Needs Allocation ................................................................................ 9 4 Population, Employment and Household Characteristics ......................................................... 11

4.1 Population...........................................................................................................11

4.2 Age ...................................................................................................................12

4.3 Race and Ethnicity..................................................................................................14

4.4 Employment Trends ................................................................................................15

4.4.1 Balance of Jobs and Workers ................................................................................15

4.4.2 Sector Composition ...........................................................................................19

4.4.3 Unemployment ................................................................................................20

4.5 Extremely Low-Income Households ...............................................................................21

4.6 Tenure ...............................................................................................................24

4.7 Displacement........................................................................................................28 5 Housing Stock Characteristics ........................................................................................ 30

5.1 Housing Types, Year Built, Vacancy, and Permits...............................................................30

5.2 Assisted Housing Developments At-Risk of Conversion .........................................................33

5.3 Substandard Housing ...............................................................................................34

5.4 Home and Rent Values .............................................................................................35

5.5 Overpayment and Overcrowding ..................................................................................38 6 Special Housing Needs ................................................................................................. 47

6.1 Large Households ...................................................................................................47

6.2 Female-Headed Households .......................................................................................48

6.3 Seniors ...............................................................................................................50

6.4 People with Disabilities............................................................................................51

6.5 Homelessness........................................................................................................53

6.6 Farmworkers ........................................................................................................63

6.7 Non-English Speakers...............................................................................................64 Appendix B: Housing Needs Data – Page 3

0.2 List of figures
Figure 1: Population Growth Trends .........................................................................................12 Figure 2: Population by Age, 2000-2019 .....................................................................................13 Figure 3: Senior and Youth Population by Race .............................................................................14 Figure 4: Population by Race, 2000-2019 ....................................................................................15 Figure 5: Jobs in a Jurisdiction ...............................................................................................16 Figure 6: Workers by Earnings, by Jurisdiction as Place of Work and Place of Residence ..............................17 Figure 7: Jobs-Worker Ratios, By Wage Group ..............................................................................18 Figure 8: Jobs-Household Ratio ...............................................................................................19 Figure 9: Resident Employment by Industry .................................................................................20 Figure 10: Unemployment Rate...............................................................................................21 Figure 11: Households by Household Income Level .........................................................................22 Figure 12: Household Income Level by Tenure ..............................................................................23 Figure 13: Poverty Status by Race ............................................................................................24 Figure 14: Housing Tenure ....................................................................................................25 Figure 15: Housing Tenure by Race of Householder ........................................................................26 Figure 16: Housing Tenure by Age ............................................................................................27 Figure 17: Housing Tenure by Housing Type.................................................................................28 Figure 18: Households by Displacement Risk and Tenure ..................................................................29 Figure 19: Housing Type Trends ..............................................................................................30 Figure 20: Housing Units by Year Structure Built ...........................................................................31 Figure 21: Vacant Units by Type..............................................................................................32 Figure 22: Substandard Housing Issues .......................................................................................35 Figure 23: Home Values of Owner-Occupied Units..........................................................................36 Figure 24: Zillow Home Value Index (ZHVI)..................................................................................36 Figure 25: Contract Rents for Renter-Occupied Units ......................................................................37 Figure 26: Median Contract Rent .............................................................................................38 Figure 27: Cost Burden by Tenure ............................................................................................39 Figure 28: Cost Burden by Income Level.....................................................................................40 Figure 29: Cost Burden by Race...............................................................................................41 Figure 30: Cost Burden by Household Size...................................................................................42 Figure 31: Cost-Burdened Senior Households by Income Level ............................................................43 Figure 32: Overcrowding by Tenure and Severity ...........................................................................44 Figure 33: Overcrowding by Income Level and Severity....................................................................45 Figure 34: Overcrowding by Race.............................................................................................46 Figure 35: Household Size by Tenure.........................................................................................47 Figure 36: Housing Units by Number of Bedrooms ..........................................................................48 Figure 37: Household Type ....................................................................................................49 Figure 38: Female-Headed Households by Poverty Status .................................................................50 Figure 39: Senior Households by Income and Tenure.......................................................................51 Figure 40: Disability by Type..................................................................................................52 Figure 41: Homelessness by Household Type and Shelter Status, San Mateo County....................................54 Figure 42: Racial Group Share of General and Homeless Populations, San Mateo County ..............................55 Figure 43: Latinx Share of General and Homeless Populations, San Mateo County......................................56 Figure 44: Characteristics for the Population Experiencing Homelessness, San Mateo County.........................62 Figure 45: Farm Operations and Farm Labor by County, San Mateo County..............................................64 Figure 46: Population with Limited English Proficiency ....................................................................65 Appendix B: Housing Needs Data – Page 4

0.3 List of tables
Table 1: Illustrative Regional Housing Needs Allocation from Draft Methodology .......................................10 Table 2: Population Growth Trends ..........................................................................................11 Table 3: Housing Permitting ..................................................................................................32 Table 4: Assisted Units at Risk of Conversion ...............................................................................33 Table 5: Population with Developmental Disabilities by Age ..............................................................53 Table 6: Population with Developmental Disabilities by Residence.......................................................53 Table 7: Students in Local Public Schools Experiencing Homelessness ...................................................62 Table 8: Migrant Worker Student Population ................................................................................63 Appendix B: Housing Needs Data – Page 5
1 INTRODUCTION
The Bay Area continues to see growth in both population and jobs, which means more housing of various types and sizes is needed to ensure that residents across all income levels, ages, and abilities have a place to call home. While the number of people drawn to the region over the past 30 years has steadily increased, housing production has stalled, contributing to the housing shortage that communities are experiencing today. In many cities, this has resulted in residents being priced out, increased traffic congestion caused by longer commutes, and fewer people across incomes being able to purchase homes or meet surging rents.

The 2023-2031 Housing Element Update provides a roadmap for how to meet our growth and housing challenges. Required by the state, the Housing Element identifies what the existing housing conditions and community needs are, reiterates goals, and creates a plan for more housing. The Housing Element is an integral part of the General Plan, which guides the policies of East Palo Alto.

Appendix B: Housing Needs Data – Page 6
2 SUMMARY OF KEY FACTS
• Population – Generally, the population of the Bay Area continues to grow because of natural growth and because the strong economy draws new residents to the region. The population of East Palo Alto increased by 4.4% from 2000 to 2020, which is below the growth rate of the Bay Area.
• Age – In 2019, East Palo Alto’s youth population under the age of 18 was 8,381 and senior population 65 and older was 2,033. These age groups represent 28.3% and 6.9%, respectively, of East Palo Alto’s population.
• Race/Ethnicity – In 2020, 10.1% of East Palo Alto’s population was White while 10.9% was African American, 9.6% was Asian, and 66.1% was Latinx. People of color in East Palo Alto comprise a proportion above the overall proportion in the Bay Area as a whole.71 • Employment – East Palo Alto residents most commonly work in the Health & Educational Services industry. From January 2010 to January 2021, the unemployment rate in East Palo Alto decreased by 5.4 percentage points. Since 2010, the number of jobs located in the jurisdiction increased by 470 (13.2%). Additionally, the jobs-household ratio in East Palo Alto has increased from 0.37 in 2002 to 0.57 jobs per household in 2018.
• Number of Homes – The number of new homes built in the Bay Area has not kept pace with the demand, resulting in longer commutes, increasing prices, and exacerbating issues of displacement and homelessness. The number of homes in East Palo Alto increased, 1.3% from 2010 to 2020, which is below the growth rate for San Mateo County and below the growth rate of the region’s housing stock during this time period.
• Home Prices – A diversity of homes at all income levels creates opportunities for all East Palo Alto residents to live and thrive in the community.
– Ownership The largest proportion of homes had a value in the range of $750k-$1M in 2019. Home prices increased by 160.0% from 2010 to 2020. – Rental Prices – The typical contract rent for an apartment in East Palo Alto was $1,630 in 2019. Rental prices increased by 65.7% from 2009 to 2019. To rent a typical apartment without cost burden, a household would need to make $65,560 per year.72 • Housing Type – It is important to have a variety of housing types to meet the needs of a community today and in the future. In 2020, 54.1% of homes in East Palo Alto were single family detached, 4.1% were single family attached, 3.4% were small multifamily (2-4 units), and 36.6% were medium or large multifamily (5+ units). Between 2010 and 2020, the number of single-family units increased more than multi-family units. Generally, in East Palo Alto, the 71 The Census Bureau’s American Community Survey accounts for ethnic origin separate from racial identity. The numbers reported here use an accounting of both such that the racial categories are shown exclusive of Latinx status, to allow for an accounting of the Latinx population regardless of racial identity. The term Hispanic has historically been used to describe people from numerous Central American, South American, and Caribbean countries. In recent years, the term Latino or Latinx has become preferred. This report generally uses Latinx, but occasionally when discussing US Census data, we use Hispanic or Non-Hispanic, to clearly link to the data source. 72 Note that contract rents may differ significantly from, and often being lower than, current listing prices.

Appendix B: Housing Needs Data – Page 7
share of the housing stock that is detached single family homes is above that of other jurisdictions in the region.
• Cost Burden – The U.S. Department of Housing and Urban Development considers housing to be affordable for a household if the household spends less than 30% of its income on housing costs.

A household is considered “cost-burdened” if it spends more than 30% of its monthly income on housing costs, while those who spend more than 50% of their income on housing costs are considered “severely cost-burdened.” In East Palo Alto, 28.8% of households spend 30%-50% of their income on housing, while 25.2% of households are severely cost burdened and use the majority of their income for housing.
• Displacement/Gentrification – According to research from The University of California, Berkeley, 64.7% of households in East Palo Alto live in neighborhoods that are susceptible to or experiencing displacement, and 0.0% live in areas at risk of or undergoing gentrification. 0.0% of households in East Palo Alto live in neighborhoods where low-income households are likely excluded due to prohibitive housing costs. Although the data show no risk of gentrification, anecdotally, the City has heard about the gentrification pressures residents are facing. There are various ways to address displacement including protection, preservation, and production policies.
• Neighborhood – 0.0% of residents in East Palo Alto live in neighborhoods identified as “Highest Resource” or “High Resource” areas by State-commissioned research, while 100.0% of residents live in areas identified by this research as “Low Resource” or “High Segregation and Poverty” areas. These neighborhood designations are based on a range of indicators covering areas such as education, poverty, proximity to jobs and economic opportunities, low pollution levels, and other factors.73 These neighborhood designations hinder the City’s ability to access Low Income Housing Tax Credits (LIHTC) and other state resources for affordable housing developments that target funding to high-resource areas.
• Special Housing Needs – Some population groups may have special housing needs that require specific program responses, and these groups may experience barriers to accessing stable housing due to their specific housing circumstances. In East Palo Alto, 6.4% of residents have a disability of any kind and may require accessible housing. Additionally, 27.5% of East Palo Alto households are larger households with five or more people, who likely need larger housing units with two bedrooms or more.74 20.6% of households are female-headed families, which are often at greater risk of housing insecurity.

Note on Data
Many of the tables in this report are sourced from data from the Census Bureau’s American Community Survey or U.S. Department of Housing and Urban Development’s Comprehensive Housing
73 For more information on the “opportunity area” categories developed by HCD and the California Tax Credit Allocation Committee, see this website: https://www.treasurer.ca.gov/ctcac/opportunity.asp. The degree to which different jurisdictions and neighborhoods have access to opportunity will likely need to be analyzed as part of new Housing Element requirements related to affirmatively furthering fair housing. ABAG/MTC will be providing jurisdictions with technical assistance on this topic this summer, following the release of additional guidance from HCD.
74 The assumption for larger (2+) bedroom size came from public input and the Affirmatively Furthering Fair Housing Survey, where respondents indicated not having enough space for all members of their household.

Appendix B: Housing Needs Data – Page 8
Affordability Strategy (CHAS) data, both of which are samples and as such, are subject to sampling variability. This means that data is an estimate, and that other estimates could be possible if another set of respondents had been reached. We use the five-year release to get a larger data pool to minimize this “margin of error” but particularly for the smaller cities, the data will be based on fewer responses, and the information should be interpreted accordingly.

Additionally, there may be instances where there is no data available for a jurisdiction for particular data point, or where a value is 0 and the automatically generated text cannot perform a calculation. In these cases, the automatically generated text is “NODATA.” Staff should reword these sentences before using them in the context of the Housing Element or other documents.

Note on Figures
Any figure that does not specify geography in the figure name represents data for East Palo Alto.

Appendix B: Housing Needs Data – Page 9
3 LOOKING TO THE FUTURE: REGIONAL HOUSING NEEDS

3.1 Regional Housing Needs Determination
The Plan Bay Area 205075 Final Blueprint forecasts that the nine-county Bay Area will add 1.4 million new households between 2015 and 2050. For the eight-year time frame covered by this Housing Element Update, the Department of Housing and Community Development (HCD) has identified the region’s housing need as 441,176 units. The total number of housing units assigned by HCD is separated into four income categories that cover housing types for all income levels, from very low-income households to market rate housing.76 This calculation, known as the Regional Housing Needs Determination (RHND), is based on population projections produced by the California Department of Finance as well as adjustments that incorporate the region’s existing housing need. The adjustments result from recent legislation requiring HCD to apply additional adjustment factors to the baseline growth projection from California Department of Finance, in order for the regions to get closer to healthy housing markets. To this end, adjustments focus on the region’s vacancy rate, level of overcrowding and the share of cost burdened households, and seek to bring the region more in line with comparable ones.77 These new laws governing the methodology for how HCD calculates the RHND resulted in a significantly higher number of housing units for which the Bay Area must plan compared to previous RHNA cycles.

3.2 Regional Housing Needs Allocation
A starting point for the Housing Element Update process for every California jurisdiction is the Regional Housing Needs Allocation or RHNA – the share of the RHND assigned to each jurisdiction by the Association of Bay Area Governments (ABAG). State Housing Element Law requires ABAG to develop a methodology that calculates the number of housing units assigned to each city and county and distributes each jurisdiction’s housing unit allocation among four affordability levels. For this RHNA cycle, the RHND increased by 135%, from 187,990 to 441,776. For more information on the RHNA process this cycle, see ABAG’s website: https://abag.ca.gov/our-work/housing/rhna-regional-housing-needsallocation Almost all jurisdictions in the Bay Area are likely to receive a larger RHNA this cycle compared to the last cycle, primarily due to changes in state law that led to a considerably higher RHND compared to previous cycles.

In January 2021, ABAG adopted a Draft RHNA Methodology, which is currently being reviewed by HCD.

For East Palo Alto, the proposed RHNA to be planned for this cycle is 829 units, a slated increase from the last cycle. Please note that the previously stated figures are merely illustrative, as ABAG has yet to issue Final RHNA allocations. The Final RHNA allocations that local jurisdictions will use for 75 Plan Bay Area 2050 is a long-range plan charting the course for the future of the nine-county San Francisco Bay Area. It covers four key issues: the economy, the environment, housing and transportation 76 HCD divides the RHND into the following four income categories:

Very Low-income: 0-50% of Area Median Income
Low-income: 50-80% of Area Median Income
Moderate-income: 80-120% of Area Median Income
Above Moderate-income: 120% or more of Area Median Income 77 For more information on HCD’s RHND calculation for the Bay Area, see this letter sent to ABAG from HCD on June 9, 2020: https://www.hcd.ca.gov/community-development/housing-element/docs/abagrhna-final060920(r).pdf Appendix B: Housing Needs Data – Page 10
their Housing Elements will be released at the end of 2021. The potential allocation that East Palo Alto would receive from the Draft RHNA Methodology is broken down by income category as follows:

Table 1: Illustrative Regional Housing Needs Allocation from Draft Methodology Income Group
East Palo
Alto
Units
San Mateo
County
Units
Bay Area
Units
East Palo
Alto
Percent
San Mateo
County
Percent
Bay Area
Percent
Very Low Income
(<50% of AMI) 165 12196 114442 19.9% 25.6% 25.9%
Low Income (50%-
80% of AMI) 95 7023 65892 11.5% 14.7% 14.9%
Moderate Income
(80%-120% of AMI) 159 7937 72712 19.2% 16.6% 16.5%
Above Moderate
Income (>120% of
AMI)
410 20531 188130 49.5% 43.1% 42.6%
Total 829 47687 441176 100.0% 100.0% 100.0%
Source: Association of Bay Area Governments Methodology and tentative numbers were approved by ABAG’s Executive board on January 21, 2021 (Resolution No. 02-2021). The numbers were submitted for review to California Housing and Community Development in February 2021, after which an appeals process will take place during the Summer and Fall of 2021.

THESE NUMBERS SHOULD BE CONSIDERED PRELIMINARY AND SUBJECT TO CHANGE PER HCD REVIEW Appendix B: Housing Needs Data – Page 11
4 POPULATION, EMPLOYMENT AND HOUSEHOLD

CHARACTERISTICS

4.1 Population
The Bay Area is the fifth-largest metropolitan area in the nation and has seen a steady increase in population since 1990, except for a dip during the Great Recession. Many cities in the region have experienced significant growth in jobs and population. While these trends have led to a corresponding increase in demand for housing across the region, the regional production of housing has largely not kept pace with job and population growth. Since 2000, East Palo Alto’s population has increased by

4.4%; this rate is below that of the region as a whole, at 14.8%. In East Palo Alto, roughly 10.6% of its population moved during the past year, a number 2.8 percentage points smaller than the regional rate of 13.4%.

Table 2: Population Growth Trends
Geography 1990 1995 2000 2005 2010 2015 2020
East Palo Alto 23451 24710 29506 32080 28155 30236 30794 San Mateo County 649623 685354 707163 719844 718451 761748 773244 Bay Area 6020147 6381961 6784348 7073912 7150739 7595694 7790537 Universe: Total population
Source: California Department of Finance, E-5 series
For more years of data, please refer to the Data Packet Workbook, Table POPEMP-01.

In 2020, the population of East Palo Alto was estimated to be 30,794 (see Table 2). From 1990 to 2000, the population increased by 25.8%, while it decreased by 4.6% during the first decade of the 2000s. In the most recent decade, the population increased by 9.4%. The population of East Palo Alto makes up

4.0% of San Mateo County.78
78 To compare the rate of growth across various geographic scales, Figure 1 shows population for the jurisdiction, county, and region indexed to the population in the year 1990. This means that the data points represent the population growth (i.e. percent change) in each of these geographies relative to their populations in 1990.

Appendix B: Housing Needs Data – Page 12
Figure 1: Population Growth Trends
Source: California Department of Finance, E-5 series Note: The data shown on the graph represents population for the jurisdiction, county, and region indexed to the population in the first year shown. The data points represent the relative population growth in each of these geographies relative to their populations in that year.

For some jurisdictions, a break may appear at the end of each decade (1999, 2009) as estimates are compared to census counts.

DOF uses the decennial census to benchmark subsequent population estimates.

For the data table behind this figure, please refer to the Data Packet Workbook, Table POPEMP-01.

4.2 Age
The distribution of age groups in a city shapes what types of housing the community may need in the near future. An increase in the older population may mean there is a developing need for more senior housing options, while higher numbers of children and young families can point to the need for more family housing options and related services. There has also been a move by many to age-in-place or downsize to stay within their communities, which can mean more multifamily and accessible units are also needed.

In East Palo Alto, the median age in 2000 was 25.8; by 2019, this figure had increased, landing at around 30 years. More specifically, the population of those under 14 has decreased since 2010, while the 65-and-over population has increased (see Figure 2).

Appendix B: Housing Needs Data – Page 13
Figure 2: Population by Age, 2000-2019
Universe: Total population
Source: U.S. Census Bureau, Census 2000 SF1, Table P12; U.S. Census Bureau, Census 2010 SF1, Table P12; U.S. Census Bureau, American Community Survey 5-Year Data (2015-2019), Table B01001 For the data table behind this figure, please refer to the Data Packet Workbook, Table POPEMP-04.

Looking at the senior and youth population by race can add an additional layer of understanding, as families and seniors of color are even more likely to experience challenges finding affordable housing.

People of color79 make up 68.2% of seniors and 65.9% of youth under 18 (see Figure 3). 79 Here, we count all non-white racial groups
Appendix B: Housing Needs Data – Page 14
Figure 3: Senior and Youth Population by Race
Universe: Total population
Notes: In the sources for this table, the Census Bureau does not disaggregate racial groups by Hispanic/Latinx ethnicity, and an overlapping category of Hispanic / non-Hispanic groups has not been shown to avoid double counting in the stacked bar chart.

Source: U.S. Census Bureau, American Community Survey 5-Year Data (2015-2019), Table B01001(A-G) For the data table behind this figure, please refer to the Data Packet Workbook, Table SEN-02.

4.3 Race and Ethnicity
Understanding the racial makeup of a city and region is important for designing and implementing effective housing policies and programs. These patterns are shaped by both market factors and government actions, such as exclusionary zoning, discriminatory lending practices and displacement that has occurred over time and continues to impact communities of color today80. Since 2000, the percentage of residents in East Palo Alto identifying as White has increased – and by the same token the percentage of residents of all other races and ethnicities has decreased – by 3.4 percentage points, with the 2019 population standing at 2,991 (see Figure 4). In absolute terms, the Hispanic or Latinx population increased the most while the Black or African American, Non-Hispanic population decreased the most.
80 See, for example, Rothstein, R. (2017). The color of law : a forgotten history of how our government segregated America. New York, NY & London, UK: Liveright Publishing.

Appendix B: Housing Needs Data – Page 15
Figure 4: Population by Race, 2000-2019
Universe: Total population
Notes: Data for 2019 represents 2015-2019 ACS estimates. The Census Bureau defines Hispanic/Latinx ethnicity separate from racial categories. For the purposes of this graph, the “Hispanic or Latinx” racial/ethnic group represents those who identify as having Hispanic/Latinx ethnicity and may also be members of any racial group. All other racial categories on this graph represent those who identify with that racial category and do not identify with Hispanic/Latinx ethnicity.

Source: U.S. Census Bureau, Census 2000, Table P004; U.S. Census Bureau, American Community Survey 5-Year Data (2015- 2019), Table B03002
For the data table behind this figure, please refer to the Data Packet Workbook, Table POPEMP-02.

4.4 Employment Trends

4.4.1 Balance of Jobs and Workers
A city houses employed residents who either work in the community where they live or work elsewhere in the region. Conversely, a city may have job sites that employ residents from the same city, but more often employ workers commuting from outside of it. Smaller cities typically will have more employed residents than jobs there and export workers, while larger cities tend to have a surplus of jobs and import workers. To some extent the regional transportation system is set up for this flow of workers to the region’s core job centers. At the same time, as the housing affordability crisis has illustrated, local imbalances may be severe, where local jobs and worker populations are out of sync at a sub-regional scale.

One measure of this is the relationship between workers and jobs. A city with a surplus of workers “exports” workers to other parts of the region, while a city with a surplus of jobs must conversely “import” them. Between 2002 and 2018, the number of jobs in East Palo Alto increased by 46.9% (see Figure 5).

Appendix B: Housing Needs Data – Page 16
Figure 5: Jobs in a Jurisdiction
Universe: Jobs from unemployment insurance-covered employment (private, state and local government) plus United States Office of Personnel Management-sourced Federal employment Notes: The data is tabulated by place of work, regardless of where a worker lives. The source data is provided at the census block level. These are crosswalked to jurisdictions and summarized.

Source: U.S. Census Bureau, Longitudinal Employer-Household Dynamics, Workplace Area Characteristics (WAC) files, 2002-2018 For the data table behind this figure, please refer to the Data Packet Workbook, Table POPEMP-11.

There are 15,101 employed residents, and 5,225 jobs81 in East Palo Alto - the ratio of jobs to resident workers is 0.35; East Palo Alto is a net exporter of workers.

Figure 6 shows the balance when comparing jobs to workers, broken down by different wage groups, offering additional insight into local dynamics. A community may offer employment for relatively lowincome workers but have relatively few housing options for those workers - or conversely, it may house residents who are low wage workers but offer few employment opportunities for them. Such relationships may cast extra light on potentially pent-up demand for housing in particular price categories. A relative surplus of jobs relative to residents in a given wage category suggests the need to import those workers, while conversely, surpluses of workers in a wage group relative to jobs means the community will export those workers to other jurisdictions. Such flows are not inherently bad, though over time, sub-regional imbalances may appear. East Palo Alto has more low-wage residents than low-wage jobs (where low-wage refers to jobs paying less than $25,000). At the other end of the wage spectrum, the city has more high-wage residents than high-wage jobs (where high-wage refers to jobs paying more than $75,000) (see Figure 6).82
81 Employed residents in a jurisdiction is counted by place of residence (they may work elsewhere) while jobs in a jurisdiction are counted by place of work (they may live elsewhere). The jobs may differ from those reported in Figure 5 as the source for the time series is from administrative data, while the cross-sectional data is from a survey. 82 The source table is top-coded at $75,000, precluding more fine grained analysis at the higher end of the wage spectrum.

Appendix B: Housing Needs Data – Page 17
Figure 6: Workers by Earnings, by Jurisdiction as Place of Work and Place of Residence
Universe: Workers 16 years and over with earnings
Source: U.S. Census Bureau, American Community Survey 5-Year Data 2015-2019, B08119, B08519 For the data table behind this figure, please refer to the Data Packet Workbook, Table POPEMP-10.

Figure 7 shows the balance of a jurisdiction’s resident workers to the jobs located there for different wage groups as a ratio instead - a value of 1 means that a city has the same number of jobs in a wage group as it has resident workers - in principle, a balance. Values above 1 indicate a jurisdiction will need to import workers for jobs in a given wage group. At the regional scale, this ratio is 1.04 jobs for each worker, implying a modest import of workers from outside the region (see Figure 7).

Appendix B: Housing Needs Data – Page 18
Figure 7: Jobs-Worker Ratios, By Wage Group
Universe: Jobs in a jurisdiction from unemployment insurance-covered employment (private, state and local government) plus United States Office of Personnel Management-sourced Federal employment Notes: The ratio compares job counts by wage group from two tabulations of LEHD data: Counts by place of work relative to counts by place of residence. See text for details.

Source: U.S. Census Bureau, Longitudinal Employer-Household Dynamics, Workplace Area Characteristics (WAC) files (Jobs); Residence Area Characteristics (RAC) files (Employed Residents), 2010-2018 For the data table behind this figure, please refer to the Data Packet Workbook, Table POPEMP-14.

Such balances between jobs and workers may directly influence the housing demand in a community.

New jobs may draw new residents, and when there is high demand for housing relative to supply, many workers may be unable to afford to live where they work, particularly where job growth has been in relatively lower wage jobs. This dynamic not only means many workers will need to prepare for long commutes and time spent on the road, but in the aggregate it contributes to traffic congestion and time lost for all road users.

If there are more jobs than employed residents, it means a city is relatively jobs-rich, typically also with a high jobs to household ratio. Thus bringing housing into the measure, the jobs-household ratio in East Palo Alto has increased from 0.37 in 2002, to 0.57 jobs per household in 2018 (see Figure 8).

Appendix B: Housing Needs Data – Page 19
Figure 8: Jobs-Household Ratio
Universe: Jobs in a jurisdiction from unemployment insurance-covered employment (private, state and local government) plus United States Office of Personnel Management-sourced Federal employment; households in a jurisdiction Notes: The data is tabulated by place of work, regardless of where a worker lives. The source data is provided at the census block level. These are crosswalked to jurisdictions and summarized. The ratio compares place of work wage and salary jobs with households, or occupied housing units. A similar measure is the ratio of jobs to housing units. However, this jobs-household ratio serves to compare the number of jobs in a jurisdiction to the number of housing units that are actually occupied. The difference between a jurisdiction’s jobs-housing ratio and jobs-household ratio will be most pronounced in jurisdictions with high vacancy rates, a high rate of units used for seasonal use, or a high rate of units used as short-term rentals.

Source: U.S. Census Bureau, Longitudinal Employer-Household Dynamics, Workplace Area Characteristics (WAC) files (Jobs), 2002-2018; California Department of Finance, E-5 (Households) For the data table behind this figure, please refer to the Data Packet Workbook, Table POPEMP-13.

4.4.2 Sector Composition
In terms of sectoral composition, the largest industry in which East Palo Alto residents work is Health & Educational Services, and the largest sector in which San Mateo residents work is Health & Educational Services (see Figure 9). For the Bay Area as a whole, the Health & Educational Services industry employs the most workers.

Appendix B: Housing Needs Data – Page 20
Figure 9: Resident Employment by Industry
Universe: Civilian employed population age 16 years and over Notes: The data displayed shows the industries in which jurisdiction residents work, regardless of the location where those residents are employed (whether within the jurisdiction or not). Categories are derived from the following source tables:

Agriculture & Natural Resources: C24030_003E, C24030_030E; Construction: C24030_006E, C24030_033E; Manufacturing, Wholesale & Transportation: C24030_007E, C24030_034E, C24030_008E, C24030_035E, C24030_010E, C24030_037E; Retail:

C24030_009E, C24030_036E; Information: C24030_013E, C24030_040E; Financial & Professional Services: C24030_014E, C24030_041E, C24030_017E, C24030_044E; Health & Educational Services: C24030_021E, C24030_024E, C24030_048E, C24030_051E; Other: C24030_027E, C24030_054E, C24030_028E, C24030_055E Source: U.S. Census Bureau, American Community Survey 5-Year Data (2015-2019), Table C24030 For the data table behind this figure, please refer to the Data Packet Workbook, Table POPEMP-06.

4.4.3 Unemployment
In East Palo Alto, there was a 5.4 percentage point decrease in the unemployment rate between January 2010 and January 2021. Jurisdictions through the region experienced a sharp rise in unemployment in 2020 due to impacts related to the COVID-19 pandemic, though with a general improvement and recovery in the later months of 2020.

Appendix B: Housing Needs Data – Page 21
Figure 10: Unemployment Rate
Universe: Civilian noninstitutional population ages 16 and older Notes: Unemployment rates for the jurisdiction level is derived from larger-geography estimates. This method assumes that the rates of change in employment and unemployment are exactly the same in each sub-county area as at the county level. If this assumption is not true for a specific sub-county area, then the estimates for that area may not be representative of the current economic conditions. Since this assumption is untested, caution should be employed when using these data. Only not seasonallyadjusted labor force (unemployment rates) data are developed for cities and CDPs.

Source: California Employment Development Department, Local Area Unemployment Statistics (LAUS), Sub-county areas monthly updates, 2010-2021.

For the data table behind this figure, please refer to the Data Packet Workbook, Table POPEMP-15.

4.5 Extremely Low-Income Households
Despite the economic and job growth experienced throughout the region since 1990, the income gap has continued to widen. California is one of the most economically unequal states in the nation, and the Bay Area has the highest income inequality between high- and low-income households in the state83.

In East Palo Alto, 17.4% of households make more than 100% of the Area Median Income (AMI)84, compared to 25.5% making less than 30% of AMI, which is considered extremely low-income (see Figure 11).
83 Bohn, S.et al. 2020. Income Inequality and Economic Opportunity in California. Public Policy Institute of California.
84 Income groups are based on HUD calculations for Area Median Income (AMI). HUD calculates the AMI for different metropolitan areas, and the nine county Bay Area includes the following metropolitan areas: Napa Metro Area (Napa County), Oakland-Fremont Metro Area (Alameda and Contra Costa Counties), San Francisco Metro Area (Marin, San Francisco, and San Mateo Counties), San Jose-Sunnyvale-Santa Clara Metro Area (Santa Clara County), Santa Rosa Metro Area (Sonoma County), and Vallejo-Fairfield Metro Area (Solano County). The AMI levels in this chart are based on the HUD metro area where this jurisdiction is located. Households making between Appendix B: Housing Needs Data – Page 22
Regionally, more than half of all households make more than 100% AMI, while 15% make less than 30% AMI. In San Mateo County, 30% AMI is the equivalent to the annual income of $44,000 for a family of four. Many households with multiple wage earners – including food service workers, full-time students, teachers, farmworkers and healthcare professionals – can fall into lower AMI categories due to relatively stagnant wages in many industries.

According to the data shown below (Figure 11), 3,837 of East Palo Alto’s households are 0-50% AMI while 1,918 are extremely low-income. Therefore, extremely low-income households represent 50.0% of households who are 0-50% AMI, as 1,918 divided by 3,837 is 50.0%. This option aligns with HCD’s guidance to use U.S. Census data to calculate the percentage of very low-income RHNA that qualifies for extremely low-income households, as the information in Figure 11 represents a tabulation of Census Bureau Data. See the estimate of extremely low-income units in the RHNA 6 opportunity sites in Chapter 5 of the 2023-2031 Housing Element.

Figure 11: Households by Household Income Level
Universe: Occupied housing units
Notes: Income groups are based on HUD calculations for Area Median Income (AMI). HUD calculates the AMI for different metropolitan areas, and the nine county Bay Area includes the following metropolitan areas: Napa Metro Area (Napa County), Oakland-Fremont Metro Area (Alameda and Contra Costa Counties), San Francisco Metro Area (Marin, San Francisco, and San Mateo Counties), San Jose-Sunnyvale-Santa Clara Metro Area (Santa Clara County), Santa Rosa Metro Area (Sonoma County), and Vallejo-Fairfield Metro Area (Solano County). The AMI levels in this chart are based on the HUD metro area where this jurisdiction is located. The data that is reported for the Bay Area is not based on a regional AMI but instead refers to the regional total of households in an income group relative to the AMI for the county where that household is located. Local jurisdictions are required to provide an estimate for their projected extremely low-income households (0-30% AMI) in their Housing Elements. HCD’s official Housing Element guidance notes that jurisdictions can use their RHNA for very low-income households (those making 0-50% AMI) to calculate their projected extremely low-income households. As Bay Area jurisdictions have not yet received their final RHNA numbers, this document does not contain the required data point of projected extremely low-income households. The report portion of the housing data needs packet contains more specific guidance for how local staff 80 and 120 percent of the AMI are moderate-income, those making 50 to 80 percent are low-income, those making 30 to 50 percent are very low-income, and those making less than 30 percent are extremely low-income. This is then adjusted for household size.

Appendix B: Housing Needs Data – Page 23
can calculate an estimate for projected extremely low-income households once jurisdictions receive their 6th cycle RHNA numbers.

Source: U.S. Department of Housing and Urban Development (HUD), Comprehensive Housing Affordability Strategy (CHAS) ACS tabulation, 2013-2017 release
For the data table behind this figure, please refer to the Data Packet Workbook, Table ELI-01.

Throughout the region, there are disparities between the incomes of homeowners and renters.

Typically, the number of low-income renters greatly outpaces the amount of housing available that is affordable for these households.

In East Palo Alto, the largest proportion of renters falls in the 0%-30% of AMI income group, while the largest proportion of homeowners are found in the Greater than 100% of AMI group (see Figure 12).

Figure 12: Household Income Level by Tenure
Universe: Occupied housing units
Notes: Income groups are based on HUD calculations for Area Median Income (AMI). HUD calculates the AMI for different metropolitan areas, and the nine county Bay Area includes the following metropolitan areas: Napa Metro Area (Napa County), Oakland-Fremont Metro Area (Alameda and Contra Costa Counties), San Francisco Metro Area (Marin, San Francisco, and San Mateo Counties), San Jose-Sunnyvale-Santa Clara Metro Area (Santa Clara County), Santa Rosa Metro Area (Sonoma County), and Vallejo-Fairfield Metro Area (Solano County). The AMI levels in this chart are based on the HUD metro area where this jurisdiction is located.

Source: U.S. Department of Housing and Urban Development (HUD), Comprehensive Housing Affordability Strategy (CHAS) ACS tabulation, 2013-2017 release
For the data table behind this figure, please refer to the Data Packet Workbook, Table POPEMP-21.

Currently, people of color are more likely to experience poverty and financial instability as a result of federal and local housing policies that have historically excluded them from the same opportunities extended to White residents.85 These economic disparities also leave communities of color at higher risk for housing insecurity, displacement or homelessness. In East Palo Alto, American Indian or Alaska 85 Moore, E., Montojo, N. and Mauri, N., 2019. Roots, Race & Place: A History of Racially Exclusionary Housing the San Francisco Bay Area. Hass Institute.

Appendix B: Housing Needs Data – Page 24
Native (Hispanic and Non-Hispanic) residents experience the highest rates of poverty, followed by Other Race or Multiple Races (Hispanic and Non-Hispanic) residents (see Figure 13).

Figure 13: Poverty Status by Race
Universe: Population for whom poverty status is determined Notes: The Census Bureau uses a federally defined poverty threshold that remains constant throughout the country and does not correspond to Area Median Income. For this table, the Census Bureau does not disaggregate racial groups by Hispanic/Latinx ethnicity. However, data for the white racial group is also reported for white householders who are not Hispanic/Latinx. Since residents who identify as white and Hispanic/Latinx may have very different experiences within the housing market and the economy from those who identify as white and non-Hispanic/Latinx, data for multiple white sub-groups are reported here. The racial/ethnic groups reported in this table are not all mutually exclusive. Therefore, the data should not be summed as the sum exceeds the population for whom poverty status is determined for this jurisdiction. However, all groups labelled “Hispanic and Non-Hispanic” are mutually exclusive, and the sum of the data for these groups is equivalent to the population for whom poverty status is determined.

Source: U.S. Census Bureau, American Community Survey 5-Year Data (2015-2019), Table B17001(A-I) For the data table behind this figure, please refer to the Data Packet Workbook, Table ELI-03.

4.6 Tenure
The number of residents who own their homes compared to those who rent their homes can help identify the level of housing insecurity – ability for individuals to stay in their homes – in a city and region. Generally, renters may be displaced more quickly if prices increase. In East Palo Alto there are a total of 7,724 housing units, and more residents rent than own their homes: 60.2% versus 39.8% (see Figure 14). By comparison, 39.8% of households in San Mateo County are renters, while 44% of Bay Area households rent their homes.

Appendix B: Housing Needs Data – Page 25
Figure 14: Housing Tenure
Universe: Occupied housing units
Source: U.S. Census Bureau, American Community Survey 5-Year Data (2015-2019), Table B25003 For the data table behind this figure, please refer to the Data Packet Workbook, Table POPEMP-16.

Homeownership rates often vary considerably across race/ethnicity in the Bay Area and throughout the country. These disparities not only reflect differences in income and wealth but also stem from federal, state, and local policies that limited access to homeownership for communities of color while facilitating homebuying for White residents. While many of these policies, such as redlining, have been formally disbanded, the impacts of race-based policy are still evident across Bay Area communities.86 In East Palo Alto, 60.2% of Black households owned their homes, while homeownership rates were 60.0% for Asian households, 27.7% for Latinx households, and 31.9% for White households. Notably, recent changes to state law require local jurisdictions to examine these dynamics and other fair housing issues when updating their Housing Elements.
86 See, for example, Rothstein, R. (2017). The color of law : a forgotten history of how our government segregated America. New York, NY & London, UK: Liveright Publishing.

Appendix B: Housing Needs Data – Page 26
Figure 15: Housing Tenure by Race of Householder
Universe: Occupied housing units
Notes: For this table, the Census Bureau does not disaggregate racial groups by Hispanic/Latinx ethnicity. However, data for the white racial group is also reported for white householders who are not Hispanic/Latinx. Since residents who identify as white and Hispanic/Latinx may have very different experiences within the housing market and the economy from those who identify as white and non-Hispanic/Latinx, data for multiple white sub-groups are reported here. The racial/ethnic groups reported in this table are not all mutually exclusive. Therefore, the data should not be summed as the sum exceeds the total number of occupied housing units for this jurisdiction. However, all groups labelled “Hispanic and Non-Hispanic” are mutually exclusive, and the sum of the data for these groups is equivalent to the total number of occupied housing units.

Source: U.S. Census Bureau, American Community Survey 5-Year Data (2015-2019), Table B25003(A-I) For the data table behind this figure, please refer to the Data Packet Workbook, Table POPEMP-20.

The age of residents who rent or own their home can also signal the housing challenges a community is experiencing. Younger households tend to rent and may struggle to buy a first home in the Bay Area due to high housing costs. At the same time, senior homeowners seeking to downsize may have limited options in an expensive housing market.

In East Palo Alto, 74.3% of householders between the ages of 25 and 44 are renters, while 26.4% of householders over 65 are (see Figure 16).

Appendix B: Housing Needs Data – Page 27
Figure 16: Housing Tenure by Age
Universe: Occupied housing units
Source: U.S. Census Bureau, American Community Survey 5-Year Data (2015-2019), Table B25007 For the data table behind this figure, please refer to the Data Packet Workbook, Table POPEMP-18.

In many cities, homeownership rates for households in single-family homes are substantially higher than the rates for households in multi-family housing. In East Palo Alto, 63.6% of households in detached single-family homes are homeowners, while 6.0% of households in multi-family housing are homeowners (see Figure 17).

Appendix B: Housing Needs Data – Page 28
Figure 17: Housing Tenure by Housing Type
Universe: Occupied housing units
Source: U.S. Census Bureau, American Community Survey 5-Year Data (2015-2019), Table B25032 For the data table behind this figure, please refer to the Data Packet Workbook, Table POPEMP-22.

4.7 Displacement
Because of increasing housing prices, displacement is a major concern in the Bay Area. Displacement has the most severe impacts on low- and moderate-income residents. When individuals or families are forced to leave their homes and communities, they also lose their support network.

The University of California, Berkeley has mapped all neighborhoods in the Bay area, identifying their risk for gentrification. They find that in East Palo Alto, 64.7% of households live in neighborhoods that are susceptible to or experiencing displacement and 0.0% live in neighborhoods at risk of or undergoing gentrification.

Equally important, some neighborhoods in the Bay Area do not have housing appropriate for a broad section of the workforce. UC Berkeley estimates that 0.0% of households in East Palo Alto live in neighborhoods where low-income households are likely to be excluded due to prohibitive housing costs.87
87 More information about this gentrification and displacement data is available at the Urban Displacement Project’s webpage: https://www.urbandisplacement.org/. Specifically, one can learn more about the different gentrification/displacement typologies shown in Figure 18 at this link:
https://www.urbandisplacement.org/sites/default/files/typology_sheet_2018_0.png. Additionally, one can view maps that show which typologies correspond to which parts of a jurisdiction here:
https://www.urbandisplacement.org/san-francisco/sf-bay-area-gentrification-and-displacement Appendix B: Housing Needs Data – Page 29
Figure 18: Households by Displacement Risk and Tenure
Universe: Households
Notes: Displacement data is available at the census tract level. Staff aggregated tracts up to jurisdiction level using census 2010 population weights, assigning a tract to jurisdiction in proportion to block level population weights. Total household count may differ slightly from counts in other tables sourced from jurisdiction level sources. Categories are combined as follows for simplicity: At risk of or Experiencing Exclusion: At Risk of Becoming Exclusive; Becoming Exclusive; Stable/Advanced Exclusive At risk of or Experiencing Gentrification: At Risk of Gentrification; Early/Ongoing Gentrification; Advanced Gentrification Stable Moderate/Mixed Income: Stable Moderate/Mixed Income Susceptible to or Experiencing Displacement: LowIncome/Susceptible to Displacement; Ongoing Displacement Other: High Student Population; Unavailable or Unreliable Data Source: Urban Displacement Project for classification, American Community Survey 5-Year Data (2015-2019), Table B25003 for tenure.

For the data table behind this figure, please refer to the Data Packet Workbook, Table POPEMP-25.

Appendix B: Housing Needs Data – Page 30
5 HOUSING STOCK CHARACTERISTICS

5.1 Housing Types, Year Built, Vacancy, and Permits
In recent years, most housing produced in the region and across the state consisted of single-family homes and larger multi-unit buildings. However, some households are increasingly interested in “missing middle housing” – including duplexes, triplexes, townhomes, cottage clusters and accessory dwelling units (ADUs). These housing types may open up more options across incomes and tenure, from young households seeking homeownership options to seniors looking to downsize and age-in-place.

The housing stock of East Palo Alto in 2020 was made up of 54.1% single family detached homes, 4.1% single family attached homes, 3.4% multifamily homes with 2 to 4 units, 36.6% multifamily homes with 5 or more units, and 1.9% mobile homes (see Figure 19). In East Palo Alto, the housing type that experienced the most growth between 2010 and 2020 was Single-Family Home: Detached.

Figure 19: Housing Type Trends
Universe: Housing units
Source: California Department of Finance, E-5 series
For the data table behind this figure, please refer to the Data Packet Workbook, Table HSG-01.

Production has not kept up with housing demand for several decades in the Bay Area, as the total number of units built and available has not yet come close to meeting the population and job growth experienced throughout the region. In East Palo Alto, the largest proportion of the housing stock was built 1940 to 1959, with 3,262 units constructed during this period (see Figure 20). Since 2010, 1.5% of the current housing stock was built, which is 128 units.

Appendix B: Housing Needs Data – Page 31
Figure 20: Housing Units by Year Structure Built
Universe: Housing units
Source: U.S. Census Bureau, American Community Survey 5-Year Data (2015-2019), Table B25034 For the data table behind this figure, please refer to the Data Packet Workbook, Table HSG-04.

Vacant units make up 7.4% of the overall housing stock in East Palo Alto. The rental vacancy stands at

8.5%, while the ownership vacancy rate is 2.4%. Of the vacant units, the most common type of vacancy is For Rent (see Figure 21).88
Throughout the Bay Area, vacancies make up 2.6% of the total housing units, with homes listed for rent; units used for recreational or occasional use, and units not otherwise classified (other vacant) making up the majority of vacancies. The Census Bureau classifies a unit as vacant if no one is occupying it when census interviewers are conducting the American Community Survey or Decennial Census. Vacant units classified as “for recreational or occasional use” are those that are held for shortterm periods of use throughout the year. Accordingly, vacation rentals and short-term rentals like Airbnb are likely to fall in this category. The Census Bureau classifies units as “other vacant” if they are vacant due to foreclosure, personal/family reasons, legal proceedings, repairs/renovations, abandonment, preparation for being rented or sold, or vacant for an extended absence for reasons such as a work assignment, military duty, or incarceration.89 In a region with a thriving economy and housing market like the Bay Area, units being renovated/repaired and prepared for rental or sale are likely to represent a large portion of the “other vacant” category. Additionally, the need for seismic retrofitting 88 The vacancy rates by tenure is for a smaller universe than the total vacancy rate first reported, which in principle includes the full stock (7.4%). The vacancy by tenure counts are rates relative to the rental stock (occupied and vacant) and ownership stock (occupied and vacant) - but exclude a significant number of vacancy categories, including the numerically significant other vacant.
89 For more information, see pages 3 through 6 of this list of definitions prepared by the Census Bureau:
https://www.census.gov/housing/hvs/definitions.pdf.

Appendix B: Housing Needs Data – Page 32
in older housing stock could also influence the proportion of “other vacant” units in some jurisdictions.90
Figure 21: Vacant Units by Type
Universe: Vacant housing units
Source: U.S. Census Bureau, American Community Survey 5-Year Data (2015-2019), Table B25004 For the data table behind this figure, please refer to the Data Packet Workbook, Table HSG-03.

Between 2015 and 2019, 95 housing units were issued permits in East Palo Alto. 6.3% of permits issued in East Palo Alto were for above moderate-income housing, 36.8% were for moderate-income housing, and 56.8% were for low- or very low-income housing (see Table 3).

Table 3: Housing Permitting
Income Group value
Moderate Income Permits 35
Low Income Permits 34
Very Low Income Permits 20
Above Moderate Income Permits 6
90 See Dow, P. (2018). Unpacking the Growth in San Francisco’s Vacant Housing Stock: Client Report for the San Francisco Planning Department. University of California, Berkeley.

Appendix B: Housing Needs Data – Page 33
Universe: Housing permits issued between 2015 and 2019
Notes: HCD uses the following definitions for the four income categories: Very Low Income: units affordable to households making less than 50% of the Area Median Income for the county in which the jurisdiction is located. Low Income: units affordable to households making between 50% and 80% of the Area Median Income for the county in which the jurisdiction is located. Moderate Income: units affordable to households making between 80% and 120% of the Area Median Income for the county in which the jurisdiction is located. Above Moderate Income: units affordable to households making above 120% of the Area Median Income for the county in which the jurisdiction is located.

Source: California Department of Housing and Community Development (HCD), 5th Cycle Annual Progress Report Permit Summary (2020)
This table is included in the Data Packet Workbook as Table HSG-11.

5.2 Assisted Housing Developments At-Risk of Conversion While there is an immense need to produce new affordable housing units, ensuring that the existing affordable housing stock remains affordable is equally important. Additionally, it is typically faster and less expensive to preserve currently affordable units that are at risk of converting to market-rate than it is to build new affordable housing.

The data in the table below comes from the California Housing Partnership’s Preservation Database, the state’s most comprehensive source of information on subsidized affordable housing at risk of losing its affordable status and converting to market-rate housing. However, this database does not include all deed-restricted affordable units in the state, so there may be at-risk assisted units in a jurisdiction that are not captured in this data table. There are 466 assisted units in East Palo Alto in the Preservation Database. Of these units, 0.0% are at High Risk or Very High Risk of conversion.91 HCD requires that Housing Elements list the assisted housing developments at risk of converting to market-rate uses. The list can be found in Chapter 2, Section 2.12.2 of the 2023-2031 Housing Element.

Table 4: Assisted Units at Risk of Conversion
Income East Palo Alto San Mateo County Bay Area
Low 466 4656 110177
Moderate 0 191 3375
High 0 359 1854
91 California Housing Partnership uses the following categories for assisted housing developments in its database:

Very-High Risk: affordable homes that are at-risk of converting to market rate within the next year that do not have a known overlapping subsidy that would extend affordability and are not owned by a large/stable non-profit, mission-driven developer.

High Risk: affordable homes that are at-risk of converting to market rate in the next 1-5 years that do not have a known overlapping subsidy that would extend affordability and are not owned by a large/stable non-profit, missiondriven developer.

Moderate Risk: affordable homes that are at-risk of converting to market rate in the next 5-10 years that do not have a known overlapping subsidy that would extend affordability and are not owned by a large/stable non-profit, mission-driven developer.

Low Risk: affordable homes that are at-risk of converting to market rate in 10+ years and/or are owned by a large/stable non-profit, mission-driven developer.

Appendix B: Housing Needs Data – Page 34
Income East Palo Alto San Mateo County Bay Area
Very High 0 58 1053
Total Assisted Units in Database 466 5264 116459
Universe: HUD, Low-Income Housing Tax Credit (LIHTC), USDA, and CalHFA projects. Subsidized or assisted developments that do not have one of the aforementioned financing sources may not be included.

Notes: While California Housing Partnership’s Preservation Database is the state’s most comprehensive source of information on subsidized affordable housing at risk of losing its affordable status and converting to market-rate housing, this database does not include all deed-restricted affordable units in the state. Consequently, there may be at-risk assisted units in a jurisdiction that are not captured in this data table. Per HCD guidance, local jurisdictions must also list the specific affordable housing developments at-risk of converting to market rate uses. This document provides aggregate numbers of at-risk units for each jurisdiction, but local planning staff should contact Danielle Mazzella with the California Housing Partnership at [email protected] to obtain a list of affordable properties that fall under this designation. California Housing Partnership uses the following categories for assisted housing developments in its database: Very-High Risk: affordable homes that are atrisk of converting to market rate within the next year that do not have a known overlapping subsidy that would extend affordability and are not owned by a large/stable non-profit, mission-driven developer. High Risk: affordable homes that are at-risk of converting to market rate in the next 1-5 years that do not have a known overlapping subsidy that would extend affordability and are not owned by a large/stable non-profit, mission-driven developer. Moderate Risk: affordable homes that are at-risk of converting to market rate in the next 5-10 years that do not have a known overlapping subsidy that would extend affordability and are not owned by a large/stable non-profit, mission-driven developer. Low Risk: affordable homes that are atrisk of converting to market rate in 10+ years and/or are owned by a large/stable non-profit, mission-driven developer.

Source: California Housing Partnership, Preservation Database (2020) This table is included in the Data Packet Workbook as Table RISK-01.

5.3 Substandard Housing
Housing costs in the region are among the highest in the country, which could result in households, particularly renters, needing to live in substandard conditions in order to afford housing. Generally, there is limited data on the extent of substandard housing issues in a community. However, the Census Bureau data included in the graph below gives a sense of some of the substandard conditions that may be present in East Palo Alto. For example, 2.0% of renters in East Palo Alto reported lacking a kitchen and 1.6% of renters lack plumbing, compared to 0.0% of owners who lack a kitchen and 1.5% of owners who lack plumbing.

HCD requires Housing Elements to estimate the number of units in need of rehabilitation and replacement. As a data source for housing units in need of rehabilitation and replacement is not available for all jurisdictions in the region, ABAG was not able to provide this required data point in this document. To produce an estimate of housing needs in need of rehabilitation and replacement, staff supplemented the data below on substandard housing issues with additional local information from code enforcement and the rent stabilization program. See this supplemental data in Chapter 2, Section 2.12.2.D of the 2023-2031 Housing Element.

Appendix B: Housing Needs Data – Page 35
Figure 22: Substandard Housing Issues
Universe: Occupied housing units
Notes: Per HCD guidance, this data should be supplemented by local estimates of units needing to be rehabilitated or replaced based on recent windshield surveys, local building department data, knowledgeable builders/developers in the community, or nonprofit housing developers or organizations.

Source: U.S. Census Bureau, American Community Survey 5-Year Data (2015-2019), Table B25053, Table B25043, Table B25049 For the data table behind this figure, please refer to the Data Packet Workbook, Table HSG-06.

5.4 Home and Rent Values
Home prices reflect a complex mix of supply and demand factors, including an area’s demographic profile, labor market, prevailing wages and job outlook, coupled with land and construction costs. In the Bay Area, the costs of housing have long been among the highest in the nation. The typical home value in East Palo Alto was estimated at $936,680 by December of 2020, per data from Zillow. The largest proportion of homes were valued between $750k-$1M (see Figure 23). By comparison, the typical home value is $1,418,330 in San Mateo County and $1,077,230 the Bay Area, with the largest share of units valued $1m-$1.5m (county) and $500k-$750k (region).

The region’s home values have increased steadily since 2000, besides a decrease during the Great Recession. The rise in home prices has been especially steep since 2012, with the median home value in the Bay Area nearly doubling during this time. Since 2001, the typical home value has increased 151.0% in East Palo Alto from $373,130 to $936,680. This change is above the change in San Mateo County, and above the change for the region (see Figure 24).

Appendix B: Housing Needs Data – Page 36
Figure 23: Home Values of Owner-Occupied Units
Universe: Owner-occupied units
Source: U.S. Census Bureau, American Community Survey 5-Year Data (2015-2019), Table B25075 For the data table behind this figure, please refer to the Data Packet Workbook, Table HSG-07.