Fremont Draft 1 Preliminary Review
Received 8/25/2022
Questions
Page # Question Response
2-24 Prohousing – Status? Upcoming
opportunities? Add a program?
The City looks forward to continuing to
work with HCD to explore the possibility
of obtaining a pro-housing designation, as
discussed in Program 53.
4-32 Housing conditions – citywide
estimates? # of units in need of rehab
and replacement.
An estimate has been added on page 4-34.
5-11 Transitional and supportive housing –
permitted in D-E zone like
multifamily?
Program 76 has been updated to include
this correction.
5-32 Fees – any mitigations for infill, TOD,
special needs, park rich areas?
The City recently updated its Development
Impact Fees in June 2021 and added a
program to reduce fees by 50% for
affordable housing projects. Program 25
involves periodic review of the impact fee
schedule. Additional programs could be
considered in the future depending on
identified goals and the demonstrated
effectiveness of the current fee reduction
program.
5-35 Fees – townhome at approx. $125
per unit?
The table (now on 5-39) has been revised.
In the previous version, staff used
inconsistent assumptions about affordable
housing in-lieu fees, which made townhome
fees appear higher than single-family home
fees, when in fact they are ~$40,000/unit
lower for a new subdivision.
General Transparency – zoning, development
standards and fees posted on the
website?
All zoning standards and fees are posted on
the City’s website. This is now indicated on
page 5-20 (standards) and 5-35 (fees).
Fremont Draft 1 Preliminary Review
Received 8/25/2022
Preliminary Checklist
Topic Notes Revisions
Page Number
Prelim
Review
Housing Needs Assessment
Lower
income
overpayment
Quantify and analyze tenure 4-44 through 4-46
Extremely
low-income
Expand discussion including
disproportionate impacts,
comparisons to other income
groups, effectiveness of past
strategies and magnitude of
needs (including projected)
Disproportionate impacts based
on income are discussed in AFFH
Chapter:
Homelessness: 7-74
Tenure: 7-80
Cost-burden: 7-85, 7-86
Overcrowding: 7-91, 7-92
Substandard housing: 7-95
Displacement: 7-99 to 7-103
Past strategies analyzed on 6-7.
Magnitude of needs on 4-16 and
4-17.
Housing
conditions
Estimate or clarify city-wide
need for rehabilitation and
replacement
4-34 through 3-36
Housing
Costs
Add local data beyond ACS 4-39, 4-42
Affirmatively Furthering Fair Housing
Local Data
and
Knowledge
Complement state and federal
data with local knowledge (e.g.,
analysis of impediments,
outreach, CIP, other planning
documents, city staff
knowledge)
Staff has added additional local
knowledge throughout the AFFH
Chapter:
Connections to Alameda
County AI: 7-1, 7-10, 7-11, 7-
12, 7-40, 7-72, 7-76
Outreach: 7-30, 7-44, 7-52
CIP: 7-65, 7-66, 7-67
Other planning documents:
7-64, 7-78, 7-112
Staff knowledge: 7-30, 7-98
Other
relevant
factors
Complement state and federal
data with other relevant factors
such as historical land use
(zoning, initiatives, growth
control), federal and state
investment that impacted
socio-economic patterns, CIP,
redevelopment areas)
Staff has added additional
context and information
throughout the AFFH Chapter:
Historic land use: 7-31, 7-37
Federal/state investment: 7-
66, 7-104
CIP: 7-65, 7-66, 7-67
Redevelopment: 7-99, 7-101,
7-103
Contributing
factors
Prioritize list (e.g., high,
medium, low)
7-3
Goals and
Actions
TBD – HCD to re-evaluate Acknowledged.
Sites Inventory and Analysis
RHNA
Progress
Demonstrate pipeline will be
built in the planning periods and
support conclusions with
discussion of anticipated steps,
any known barriers, presence
or absence of phasing, typical
completion rates, drop out
rates, etc.
Discussion regarding typical
completion rates and potential
barriers to completion.
Adjustment factors added to
pipeline projects based on
analysis of previous Housing
Element.
8-4
Infrastructure Clarify sufficient water and
sewer for the RHNA
Discussion has been added to
regarding priority service
allocations for water and sewer
for lower income households.
5-32
Small sites Support conclusion about
common ownership and
consolidation with recent
trends by affordability or other
discussion of site characteristics
Examples provided of small lots
consolidated to facilitate an
affordable housing project.
Characteristics of the lots that
made them appropriate for
consolidation were provided, as
well confirmation that
consolidated inventory sites
were consistent with these
characteristics.
8-29
Environmental
constraints
Add discussion on any other
known conditions and impacts
on identified sites (shape,
easements, conditions,
compatibility)
Discussion added regarding
known environmental constraints
for inventory sites. Additional
adjustment factors added.
Nonvacant Add discussion of trends to
support factors (e.g., ILV,
age, existing FAR) and
relate to identified sites
with some typical examples
FYI – 50% nonvacant finding
in adoption resolution
Discussion has been added that
identified market conditions
correspond with observed
trends that led to residential
development. Representative
development projects reflecting
each trend were cited. Language
was added indicating the sites
inventory table keys market
trends with specific inventory
sites.
8-26
Adopting resolution will include
appropriate 50% nonvacant
finding.
Publicly
owned sites
For BART, Discuss steps, any
known barriers, development
schedule, necessary steps and
anticipated completion
8-39
ADUs Rescale assumptions closer to
recent four-year trend (60
units/year)
ADU assumptions have been
recalled to 60 units/year.
8-26
Electronic
sites
FYI Acknowledged.
Zoning for a Variety of Housing Types
Emergency
Shelters
Clarify by right is without
discretionary action and
areas/sites are not in areas unfit
for human habitation (discuss
other allowed uses)
5-17
Transitional
and
supportive
Clarify D-E zone or correct
table
5-12, 2-35
Governmental and Non-governmental Constraints
On- and off-
site
improvements
List improvement requirements
for typical/anticipated
development and evaluate cost
impacts
5-32
Transparency Clarify zoning, development
standards and fees are posted
or add a program
5-20, 5-35
Fees Evaluate as a constraint and
consider additional mitigation
programs (beyond affordable)
5-35
Persons with
disabilities
Reasonable
accommodation: list
approval findings and
evaluate
Describe and evaluate any
definition of family used in
zoning and land use
Clarify where and how
group homes (7 or more
persons) are permitted and
add program
Reasonable accommodation
information on 5-14 and 5-15
Definition of family on 5-14
Group home discussion on 5-
14. There is a program to
remove zoning barriers for
large residential care facilities
on page 2-33.
At-risk Preservation
Add list of qualified entities 4-33
Housing Programs
Beneficial
Impact
Add discrete timing (e.g., at
least annually or date) for
Programs 39, 52 and 53
Program 39 updated to
include specific commitment
to AHSC funding.
Program 52 updated to
include specific commitment
to apply to Homekey 3.0.
Program 53 updated to
include specific commitment
to eligibility fo
r PLHA funding.
Sites Depends on complete
analysis
Public lands/BART: add
schedule of actions,
including numeric targets
with affordability – HCD to
assist with language
2-30
Constraints Depends on complete analysis Acknowledged.
AFFH TBD – HCD to re-review Acknowledged.
At-risk Add commitment to complying
with noticing requirements,
outreach and coordination with
qualified entities and education,
outreach and support for
tenants
2-8
ADU Add specific commitment to
monitor more frequently
2-40, 2-41
Quantified Objectives
2-42 Add objectives for
rehabilitation
Add conservation objectives
beyond at-risk, can include
MHP, vouchers, tenant
stability, etc.
Objectives added for
rehabilitation based on Program
3 (Minor Home Repair Grant
Program).
Program 7 regarding Mobile
Home Park preservation has
been incorporated into
conservation objective.
General Plan Consistency
Add discussion of how
consistency will be maintained
throughout the planning period
5-9
Questions, Follow Ups, FYI, To Be Determined
FYI 50% nonvacant resolution
finding in the adopted
Acknowledged.
FYI Electronic sites inventory Acknowledged.
FYI Rezoning timing (within 1 year)
if compliance is late, including
prior identified sites by right
(Program 44)
Acknowledged.
TBD Public comments Acknowledged.
TBD ADU ordinance and HCD
review
Acknowledged.
TBD HAU inquiries Acknowledged.
TBD BART work plan Acknowledged.
TBD Other follows ups Acknowledged.
In addition to the edits requested by HCD, staff has made the following additional modifications to further update and strengthen the 2023-2031 Housing Element:
Revision Page Numbers
Goals, Policies, and Programs
Program 33 has been updated to commit to a bonus ADU program. 2-18 Programs 35, 37, and 40 have been revised to strengthen and explicitly state their connection to affirmatively furthering fair housing. 2-19, 2-20. 2-21
Program 35 has been updated to reflect the requirements of AB 2097. 2-19 Program 62 has been revised to clarify that the City submitted a Homekey
2.0 application and has assembled a shortlist of strong potential Homekey sites. The program’s timeline has been revised to commit to apply for Homekey 3.0 funding when the NOFA is released.
2-29
Program 89 has been added, which requires that staff annually identify residential development projects that were approved below maximum density and assess whether development standards precluded development at maximum density. Where development standards have been shown to preclude development at maximum density, the development standard shall be modified.
2-42
Program 90 has been added to identify sites that were made available for housing under SB 6 and AB 2011 and publish them on the City’s webpage along with the remainder of inventory sites.
2-43
Affirmatively Furthering Fair Housing
A regional analysis of disproportionate housing needs has been added. Homelessness: 7-74 Tenancy: 7-77
Cost burden: 7-82
Overcrowded
households: 7-89
Substandard housing: 7-
94 Displacement: 7-97, 7-
98, and 7-101
Displacement due to
Natural Disasters: 7-
104 to 7-109
Stronger ties between identified issues and proposed policies have been added throughout the AFFH chapter.
7-10, 7-38, 7-47, 7-54, and
7-113
Additional analysis has been added to show how the largest sites in the inventory support access to opportunity.
7-115 and 7-116
Sites Inventory
Average residential density in Commercial Town-Center district corrected from 33 to 39 du/ac.
8-30
Additional data added to various representative project tables.