CITY COUNCIL STAFF REPORT
AGENDA ITEM NO. 7B
TO: City Council DATE: September 14, 2026
DEPARTMENT: Community Development Department
PREPARED BY: MJC
PRESENTER: Marie Jones
AGENDA TITLE: Receive Report, Conduct Public Hearing, and Consider Amending the Fort Bragg Inland and Coastal General Plan and the Inland and Coastal Zoning Codes to meet Regional Housing Needs Assessment Requirements for the 2027 Housing Element Cycle.
RECOMMENDED ACTION
1. Adopt a Resolution Amending the Fort Bragg Inland General Plan to allow Multifamily in Commercial Zoning Districts in order to comply with new State Regional Housing Needs Assessment (RHNA) housing unit requirements (GPA 2-26).
2. Adopt a Resolution Amending the Fort Bragg Coastal General Plan to allow Multifamily in Commercial Zoning Districts in order to comply with new State RHNA housing unit requirements (GPA 2-26).
3. Introduce by title only, and waive the first reading of, an Ordinance Amending Chapter 18.22.20 of the Municipal Code to modify regulations of the development of Multifamily Housing projects in Commercial Zoning Districts.
4. Introduce by title only, and waive the first reading of, Ordinance Amending Chapter 17.22.20 of the Municipal Code to modify regulations of the development of Multifamily Housing projects in Commercial Zoning Districts.
BACKGROUND
The City of Fort Bragg adopted its current General Plan in December 2002. In 2009, 2014 and 2019 the City updated the Housing Element of the General Plan in compliance with California state law. An up-to-date Housing Element is necessary for the City to retain its eligibility for CDBG and HCD funding. The 2019 Housing Element is the blueprint for City actions with regard to housing through 2027. A new Housing Element will need to be prepared in 2026/27 to address new State requirements and a larger RHNA (Regional Housing Needs Assessment) allocation.
The proposed General Plan Land Use Element amendments to the Coastal and Inland General Plans and related zoning code amendments would allow the City to achieve the new required higher RHNA (Regional Housing Needs Assessment) housing allocation as part of the upcoming 2027 Housing Element process.
DISCUSSION AND ANALYSIS
As shown in Table below, the City’s share of the regional housing need allocation in 2019 was 137 units. The City was responsible for identifying the land that is both suitable for and can accommodate this level of residential development, which it did in the 2019 Housing Element.
Table 1: Fort Bragg Regional Housing Needs Assessment Allocation by Income Group Income Extremely
Low
Very
Low Low Moderate Above
Moderate Total
Housing Units 30 30 31 23 23 137
Source: MCOG, Mendocino County Regional Housing Needs Assessment Plan, 2018 However, per the RHNA allocation of Mendocino Council of Governments (MCOG) the new 2027 Housing Element must include an inventory of sufficient vacant parcels, with the appropriate zoning, which would also the development of housing per the RHNA allocation of 668 units as illustrated in the table below.
Many of the vacant parcels which can be used to achieve the RHNA allocation are in commercially zoned districts as illustrated in Attachment 1. The table below summarizes attachment 1 and it shows that one third of the required RHNA units (239 units) would need to be achieved on vacant commercial properties, while the remaining two thirds could be achieved on vacant residentially zoned parcels.
However, an issue in the General Plan “purpose” section was recently identified for all commercial zoning district that prohibits the development of multifamily housing in commercially zoned parcels unless they include retail/commercial on the street frontage. Unless this is corrected the City will not meet its RHNA threshold. If the City does not meet its RHNA threshold, the City would be required by the State (HCD) to upzone residential zoning districts to meet the required RHNA threshold. This would mean allowing more units per acre and increasing height limits in all multifamily residential zoning districts. Both approaches are analyzed below.
On August 26, 2026, the Planning Commission considered both approaches and recommends that the City Council proceed with Approach 1.
Approach 1: Allow Multifamily in Commercial Zoning Districts.
Geral Plan Changes. The problematic piece of each General Plan is in the “Purpose of Commercial Zoning Districts (8.222.020)” which require that all multifamily projects in commercial zoning districts dedicate the street facing frontage to commercial development (Attachment 1 & 2). This results in a challenge for the development of these parcels, as there is little to no market for new retail and commercial spaces and so this requirement puts a cost burden on the residential portion of the project. Both commercial and retail suffer from very low rents and high vacancy rates due to the advent of on-line purchasing of goods and services. There is not sufficient demand for commercial space to make these mixed-use projects feasible. Therefore, the only way a developer can get a project to be financially feasible is through inclusionary housing incentives (building 15% of units for low-income households) which per state law allows a developer to request incentives such as height increases, density bonuses and planning incentives to reduce the amount of commercial space on the street frontage of these projects.
The Planning Commission recommends revising this definition to allow multifamily housing without the requirement for commercial development which would result in smaller, more housing-friendly development.
Zoning Code Changes
RHNA Parcels by Zoning District
Acres Units
Commercial Parcels 9.55 239
Residential Parcels 34.86 449
Totals 44.41 688
Attachment 3 & 4 illustrates the proposed changes to the ILUDC/CLUDC to implement the above General Plan changes in the zoning ordinance, specifically it sets maximum and minimum zoning densities (units/acre) for each of the commercial zoning districts for mixed use and multifamily projects. Furthermore, the Planning Commission made the following recommendations which are incorporated into the attached ordinances:
• Multifamily projects should be permissible with a Use Permit in all of the Commercial Zones except for the Central Business District. o Multifamily should be permissible in the neighborhood commercial zoning district at densities of 6 to 12 units per acre. This would make some existing multifamily properties in the neighborhood commercial zoning districts into conforming uses. Additionally, the vacant parcel at the corner of Harold and Oak could be added to the RHNA inventory if this approach is taken. Finally, the Planning Commission recommended that multifamily projects of up to 35 feet in height be allowed with Use Permit approval in order to accommodate 12 units per acre and parking on a single site.
o As most of the Central Business District is fully developed, changing the regs to allow multifamily without commercial on the first floor would not greatly increase the number of possible RHNA units.
• The Planning Commission directed that multifamily should be allowed in the remaining commercial districts at a density of 12 to 24 units per acre which matches the minimum and maximum units per acre of the Very High-Density Residential Zoning District.
• The Planning Commission recommended that commercial uses on the bottom floor of these projects should be optional and that a minimum amount of commercial should not be required. The Planning Commission considered requiring 1,000 sf for projects with 10-20 units, 2,000 SF for projects of more than 20 units, with no commercial space requirements for projects of less than 10 units, but decided not to require this as there is so much vacant commercial space throughout town and there it make no sense to require more.
As a reminder State law provides for a 50% maximum density bonus if an applicant does 15% of units as inclusionary units that are affordable to very low-income households. For such a project, housing density would be increased to 36 units/acre maximum which would require a height incentive. The potential increase in units/acre exists even without this zoning change.
Please see the City Council’s resolution of adoption (Attachment 1 & 2) for the proposed changes to the Land Use Elements of the Inland and Coastal General Plans. See attachment 3 & 4 for revised ordinance language for the Development
Standards for the Commercial Zoning Districts. All changes are illustrated in red text and red text strikeout.
Approach 2: Upzone Multifamily Zoning Districts to Achieve the RHNA Allocation.
The Planning Commission considered and rejected the following approach, with which the City would up-zone residential zoning districts to achieve RHNA requirements. Per the table below zoning densities would have to increase by 37% to achieve the RHNA allocation entirely within the higher density zoning districts. (There are minimal vacant developable parcels in the low-density zoning district, so upzoning the low-density zoning district would not produce units for RHNA and so is not considered here.) Upzoning residential zoning districts by 37% would be more controversial and disruptive to neighborhoods than allowing multifamily on unutilized commercially zoned land, therefore this approach is not recommended.
ENVIRONMENTAL ANALYSIS:
• The ILUDC regulations qualify for the Commonsense Exemption (15061.b.3) because the commercial parcels located in the Inland Zone are already exempt from compliance with CEQA as they all qualify for the in-fill categorical exemption.
• An EIR addendum has been prepared for the proposed revisions to the Inland General Plan and that is attached as attachment 5.
• The proposed revisions to the General Plan and the ILUDC in the Coastal Zone are exempt from CEQA because the Coastal Commissions actions to adopt an LCP amendment are considered CEQA equivalent: “activities and approvals by a local government necessary for the preparation and adoption of a local coastal program or long-range development plan” pursuant to the California Coastal Act are statutorily exempt from compliance with CEQA, and Upzone Vacant Residential Zoning Districts to Meet RHNA Requirements Zoning District
Vacant
Parcels
(acres)
Current
Units/Acre Units Required Units
Upzoned
Units/Acre
Medium Density
Residential 7.0 12 84 116 16
High Density
Residential 2.5 15 38 54 21
Very High Density
Residential 15.2 24 364 499 33
Total 24.7 486 668
this statutory exemption “shifts the burden of CEQA compliance from the local agency to the California Coastal Commission (CEQA Guidelines § 15265 (c)).
COMMUNITY OUTREACH
Both the City Council and the Planning Commission have had multiple community meetings and hearing at which housing has been identified as a key need in the community.
CONSISTENCY
The proposed amendments create consistency between the City’s General Plans and Zoning Ordinances, as the zoning ordinance currently allows multifamily housing with a Use Permit in the Use Tables of Sections 17.22.030 and 17.22.050. However, this permission is contradicted by the purposes defined in the Coastal General Plan for the respective zoning districts, which currently only allow multifamily as part of a mixed-use project with street fronting commercial and the development standards of sections 17.22.050 and 18.22.050.
ALTERNATIVES:
The City Council could decide not to adopt the suggested changes to the General Plans and Zoning Ordinances; however this would make it difficult for the City to achieve its RHNA goals in the 2027 Housing Element.
• If the City does not amend the Land Use Element, the City could either lose its Housing Element certification or be forced to upzone residential areas to higher densities as analyzed earlier in this report.
• Municipalities which do not have certified Housing Elements are required to approve all multifamily housing projects by right, regardless of Use Permit requirements, location, level of affordability, and/or if they are proposed for a vacant or already developed lot. This would result in all multifamily housing projects being exempt from local permit authority.
ATTACHMENTS:
1. A Resolution of the Fort Bragg City Council Amending the Land Use Element (GPA 2- 26) Of the Fort Bragg Inland General Plan to Meet Regional Housing Needs Assessment Requirements for the 2027 Housing Element Cycle
2. Resolution of the Fort Bragg City Council Amending the Land Use Element (GPA 3- 26) Of The Fort Bragg Coastal General Plan To Meet Regional Housing Needs Assessment Requirements for the 2027 Housing Element Cycle
3. An Ordinance Amending Division 18 of the Fort Bragg Municipal Code (ILUDC 1-26) to Amend Title 18.22.020 - Purposes Of Commercial Zoning Districts and Title
18.22.050 - Commercial District Site Planning And Building Standards to Allow Multifamily Development and Set Minimum Densities for Multifamily and Mixed-Use Projects.
4. An Ordinance Amending Division 17 of the Fort Bragg Municipal Code (CLUDC 4-26) to Amend Title 17.22.020 - Purposes Of Commercial Zoning Districts and Title
17.22.050 - Commercial District Site Planning And Building Standards to Allow Multifamily Development and Set Minimum Densities for Multifamily And Mixed-Use Projects.
5. Resolution of the Fort Bragg Planning Commission Recommending that the City Council Amend the Fort Bragg Inland And Coastal General Plan and the Inland and Coastal Zoning Codes to Meet Regional Housing Needs Assessment Requirements for the 2027 Housing Element Cycle
6. EIR Addendum for Inland General Plan revisions.
NOTIFICATION:
1. “Notify Me” subscriber lists: Fort Bragg Downtown Businesses; and Economic Development Planning.