Exhibit D - Public Comments — Fresno City Council, December 12, 2024 (part 2 of 2)

○ Establishanacquisitionandrehabilitationfundtopurchaseolder,blighted,or abandonedhomes/buildings. SeeAttachmentAat8.
○ Grantsforresidentswhowanttodevelopa ordable
accessorydwellingunitson
theirland. SeeAttachmentAat8.
○ UrbanGreeningasbu er
zonesforresidenceszonednearpollutinglanduses. See
AttachmentAat8.
○ ProhibitsitingindustrialusesnexttoHousingElementsitesusedtoaccommodate theRHNA. SeeAttachmentAat8.
○ SuitableVacantLandshouldbeprioritizedfora
ordable
housinginordertobring
VeryLowIncomeandLowIncomeRHNAallocationsintocompliance. See AttachmentAat9.
○ Impactfeesshouldbeplacedintoacommunitybene ﬁt
fundwhenpollutingland
usesandpracticesareplacednearhousing. SeeAttachmentAat9. ○ DevelopingPublicHealthImpactReportsfornewdevelopment. SeeAttachmentA at9.
○ EstablishaCargo/FreightProhibitionandRevenueTax. SeeAttachmentAat9. ○ IncorporateCompleteStreetsprinciplesintoalltransportationprojectsatallphases ofdevelopment. SeeAttachmentAat9.
○ EstablishaHousingElementImplementationCommitteetooversee 47thetimelines andimplementationofeachprogramandpolicy.Thecommitteeshouldbe comprisedprimarilybytenants,low-incomehomeowners,andat-riskpopulations toensureimplementationmeetstheneedsofmostat-riskcommunities. See AttachmentAat9.

B. TheNovemberDraftMustReviseImplementationProgramsWhichAre NoncompliantandShouldStrengthenProgramsWhichCouldBetterAFFH.

TheNovemberDraft,liketheJulyDraft,isnoncompliantunderGovernmentCodesections 8899.50and65583regardingsomeofitsimplementationprograms.Wealsowantedtoidentify programsthatcouldbestrengthenedtobetteraccomplishresidents’prioritiesandbettermove towardovercomingsegregationandcreatingareasofopportunityforR/ECAPs.Wedonothave anynewrecommendationsfortheNovemberDraft’sPrograms2,17,19,22,23,27,29,and32 beyondtherecommendationsinourpreviouscommentletters;pleasereferenceAttachmentBand AttachmentCforthosecommentsaswellasadditionalcommentsontheProgramswedoaddress below.Thefollowingincludestheprogramswiththerecommendedchangestopolicy,goals,and 47Theplanmustdescribethestandardsandproceduresthatthejurisdictionwillusetomonitoractivitiescarriedoutin furtheranceoftheplan,includingstrategiesandactionsthataddressthefairhousingissuesandgoalsidenti ﬁedinthe
AFH,andthatthejurisdictionwillusetoensurelong-termcompliancewithrequirementsoftheprogramsinvolved, includingcivilrightsrelatedprogramrequirements,minoritybusinessoutreach,andthecomprehensiveplanning requirements.See80Fed.Reg.at42365.

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concretestepsbestsuitedtoaddresscompliance,contributingfactors,andprioritizedcommunity fairhousingissues:
● MissingRequiredPrograms
○ AddressingGovernmentalandNongovernmentalConstraints
■ AstheAFHdidnotfullyidentifyandanalyzegovernmentaland
nongovernmentalconstraintsandconcludedthatthefewidenti
ﬁed
constraints
wereeithernotsigni ﬁcant
orwerebeingaddressed,theAction
Plandidnotincludeaprogram(s)toremovethem.TheNovemberDraft doesnotadequatelymeettherequirementsofGovernmentCodesection 65583(c)(3)toaddressandremoveconstraints.
■ Program25providessomelimiteddevelopmentcodeamendmentsto removebarrierstohousingdevelopment,buttheseareafarcryfrom addressingandremovingthemyriadconstraintstoa
ordable
housing
development.
■ Consideraddingaprogram(s)relatingtotheidenti ﬁed
governmentaland
nongovernmentalconstraintsidenti ﬁed
inSectionIII.A. supra.
○ EmergencyRentalAssistanceProgram
■ ThisprogramwasremovedentirelyfromtheJulyDrafttotheNovember Draft.ThisprogramshouldbeincludedinthenextHousingElementdraft astenantprotectionsisanidenti
ﬁed
communitypriority.
● Program1–MaintainAdequateSites
○ Createastrategytoworkwithunwillingdeveloperswhenrezoning. ○ CreateastrategyforrespondingtoYIMBY’swhenconductingcomprehensive outreach.
○ De
ﬁne
whotheCityisreachingouttoduringcomprehensiveoutreach.
○ Deﬁne
whattheCityisseekinginputonduringtheoutreach.
○ Developarobustoutreachstrategytoensurevariedandinclusiveoutreachas requiredbylaw,ensuringadiligente
ort
ismadebytheCitytoseekinputfrom
communitieswithprotectedcharacteristicsandful ﬁlling
itsdutytoAFFH.Gov’t
Code§65583(c)(9)–(10).
● Program3–EncourageandFacilitateAccessoryDwellingUnits ○ Specifytargetedareastopromotepublicoutreachfortheeducationalprogram aroundtheopportunityforADUs;thisisareasonableandmeasurableoutcome, whilepromotingtoallpartsofthecityisvagueandhardtoenforce. ○ MatchfundswithHousingChoiceVouchersforADUunitsinhighresourceareas forlandlordsthatmakeADUsdeedrestricteda
ordable
forlow-or
very-low-incomehouseholds,inadditiontowaivinginspectionfees. ○ AdvancetheCity’sfreeADUstandardplansforfarmworkerdwellingunitsand cottagecommunitiesbyaddingasectiondescribingthesestructures,showing December 11, 2023 City of Fresno Revised Draft Housing Element Comment Letter

Page 26 ends

pictures,andincludingtheplansontheCity’sADUProgramswebsite(i.e.,making thisamoreconcretecommitmentthansimply“encourag[ing]”theuseoftheplans). ○ Deﬁne
whatafarmworkerdwellingunitis.
○ CreateadditionalincentivesforlandlordswhoacceptHousingChoiceVouchersto makeitmorefeasibleforlow-incomehouseholds.
○ Instituteanadvertisingplansoallcommunities,especiallyR/ECAPs,areawareof theADUresourcesontheCity’swebsite,ADUhotline,andADUemailtoanswer questions.
○ Waiveinspectionfeesforlandlordsoflow-incomepropertiesimmediatelyupon adoptionoftheHousingElement(i.e.,removingtheunnecessarywaitingofthe timelinetostartwaivingfeesinJuly2024).
○ Provide
ﬁnancial
supporttofarmworkersinpovertystatuswhowanttobuild
ADUs—whootherwisewouldnothavethedownpaymenttobuildADUs. ● Program5–LargeandSmallLotDevelopment
○ Reviseobjective(of600units)tobuild800–1,000lower-incomeunits. ○ Createenforceableoutcomesinthetimeframesection—e.g.,createapermanent fundforassistingnonpro
ﬁt
developersbyJanuary1,2025;build200unitsby
December31,2025;build400unitsbyDecember31,2027,etc.
● Program8–ListofLocalLaborUnionsandApprenticeshipPrograms ○ Hostin-personandvirtualwebinarshighlightingthebene ﬁts ofhiringlocallabor
andbestpracticesforestablishingtheseprogramsandworkingwithlaborunions (i.e.,makingthisamoreconcretecommitmentthansimply“encourag[ing]”the hiringoflocallabor).
○ De
ﬁne
what“hirelocallabor”means(e.g.,statewhetherthereisaconnectionto laborunionsandapprenticeshipprograms).
● Program9–UseofSitesinPreviousHousingElements
○ EditthesecondparagraphtobecompliantwithGovernmentCodesection 65583.2(c).Itshouldread(importantcomponentsboldedforemphasis):
■ TheCitywillimplementazoningamendmentto permitdevelopmentsby rightwhere20percentormoreoftheunitsarea
ordable
tolower-income
householdsonany vacantsites identiﬁed
inthelower-incomeinventoryof
the4thand5thRHNAcycles andand non-vacantsites identiﬁed inthe
lower-incomeinventoryofthe 5thRHNAcycle aspartoftheHousing Element.
● Program10–AnnualReportingProgram
○ Developarobustoutreachstrategytoensurevariedandinclusiveoutreachas requiredbylaw,ensuringadiligente
ort
ismadebytheCitytoseekinputfrom
communitieswithprotectedcharacteristicsandful ﬁlling
itsdutytoAFFH.Gov’t
Code§65583(c)(9)–(10);HCDAFFHGuidanceat18.
○ Evaluate,modify,andreviseHousingElementimplementationprogramsbasedon inputreceivedfromthepublic.HCDAFFHGuidanceat51.

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○ TheHousingElementDoesNotCurrentlyProvideforAdequatePublic ParticipationRegardingtheImplementationProgramsfrom2023–2031. ● Program11–IncentivesforHousingDevelopment
○ Hostin-personandvirtualwebinarshighlightingtheincentivesforhousing developmentandbestpracticesforutilizingtheseandwheretoaccessadditional resourcesontheCity’swebsite(i.e.,makingthisamoreconcretecommitmentthan simply“post[ing]andmaintain[ing]”alist).
● Program12–LocalHousingTrustFund
○ Reviseobjective(of320unitstotal)tobuild300–400extremelylow-,400–500very low-,and400–500low-incomehousingunits.
● Program14–PartnershipswithA
ordable
HousingDevelopers
○ Reviseobjective(of1750units)tobuild1900–2000verylow-incomeunits. ● Program20–HousingChoiceVoucherIncentiveProgram
○ Reviseobjectivesection:ItshouldbeclearthattheCity,itself,willenforcesourceof incomelawsandtheCitywillworkwiththeFresnoHousingAuthorityonoutreach andeducationalopportunitiesregardingHCVs.
● Program24–SpecialNeedsHousing
○ TheNovemberDraft’sinsertionsarevague,unenforceable,andhaveunclear outcomes.Wordsneedingmorespeci
ﬁcity
,deﬁning,
ormeasurableoutcomesare
bolded.
■ TheCitywill supportandworkactively toidentifythehousingneedsof farmworkersinFresnoandwill cooperatewithpublicandprivateagencies toseekfundingto identifyandimplementstrategies leadingtothe provisionofhousingforfarmworkers.
■ TheMayor’sO ce
ofCommunityA airswill
assistinengaging all
residentsofthecommunityincludingyouth,Black,Indigenous,Peopleof Color(BIPOC),Latino,Asian/Paci
ﬁc
Islander,Indian,andLGBTQontheir
housingneeds.
● Program30–MobileHomeParks
○ Deﬁne
speciﬁc
aspectsoftherehabilitationresourcesandrepairprogram—e.g.,heat resiliency,weatherization,insulation,repairsforinspectionviolationsorother habitabilityconcerns.
○ EstablishaMobileHomeParkImprovementProgramfocusedoncommunity resourcessuchasgreenspace,parks,transitaccess,infrastructureandotherresource improvements.
● Program33–HomelessAssistance
○ Establishasafeparkingprogram(i.e.,providesanenforceableandmeasurable outcomeasopposedtomerely“explor[ing]thefeasibility”ofaprogram. ○ De
ﬁne
whatserviceswouldbeprovidedduringthesafeparkingprogramtohelp individualsﬁnd
permanenthousing.

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○ Provideatimelineforconductingandcompletingtheassessmentforyouthatriskof homelessness.
* * * * *
Thankyouforyourconsiderationofourcomments.Welookforwardtodiscussingthemwithyou andcontinuingtoworkwiththestateandtheCitytoensurethattheCityadoptsaHousing Elementthatfullycomplieswiththelawandaddressestheserioushousingneedsanddisparities thatimpacttheCityofFresno’sresidents.

Sincerely,
JasmineRobinson
LegalAdvocate/LegalFellowSponsoredbyWeil,Gotshal&MangesLLP LeadershipCounselforJustice&Accountability
ValerieFeldman
Sta
Attorney
PublicInterestLawProject
CityofFresnoCommunityResidents
YonasPaulos,SouthwestFresno
LisaFlores,SouthwestFresno
EstelaOrtega,AnnLeavenworth
IldaVilla,SoutheastFresno
CC: AshleyWerner,DirectingAttorney,LeadershipCounselforJustice&Accountability IvankaSaunders,RegionalPolicyManager(CityandCountyofFresno),Leadership CounselforJustice&Accountability
NatalieDelgado,PolicyAdvocate(CityofFresno),LeadershipCounselforJustice& Accountability
LeslieMartinez,CommunityEngagementSpecialist,LeadershipCounselforJustice&

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Accountability
ConnorMalone,CommunicationsManager,LeadershipCounselforJustice& Accountability
LandUseandPlanningUnit([email protected] ),CaliforniaDepartmentof HousingandCommunityDevelopment
JoseAyala,HousingPolicySpecialist,CaliforniaDepartmentofHousingand CommunityDevelopment
RobertSwanson,DeputyAttorneyGeneral,DepartmentofJustice—CaliforniaAttorney General’sBureauofEnvironmentalJustice
LucasWilliams,Partner,LexingtonLawGroup
December 11, 2023 City of Fresno Revised Draft Housing Element Comment Letter

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AttachmentA
CommentLetterfromLeadershipCouns.forJust.&Accountabilityetal.totheFresnoCnty.Bd.of Supervisors,theCitiesofFresnoCnty.CityCouncils,&DeputyDir.KristineCaioftheFresno CouncilofGov’ts(Oct.3,2022)(on
ﬁle
withauthor).

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AttachmentB
CommentLetterfromLeadershipCouns.forJust.&Accountabilityetal.toMayorJerryDyer, FresnoCityCouncilmembers,&MichelleZumwalt(Aug.16,2023)(on ﬁle withauthor).

August 16, 2023
Mayor Jerry Dyer
Fresno City Councilmembers
Michelle Zumwalt, Planning and Development Department
2600 Fresno Street, Room Fresno, CA 93721
RE: City of Fresno Draft 6th Cycle Housing Element
Dear Councilmembers, Mayor Dyer, and Ms. Zumwalt,
The undersigned organizations write to you to advocate for a Housing Element that is equitable, inclusive, and responsive to disadvantaged communities’ needs. We are a group of community-based organizations working alongside community partners and leaders throughout the City of Fresno. Housing Element Law requires that cities and counties make a diligent effort to meaningfully incorporate public input provided on the housing element update, prioritizing input provided by lower-income residents, residents with special housing needs, protected classes, and residents of lower-income and disadvantaged communities.

Goals, policies and actions must be aggressively set to overcome those contributing factors to meet the “meaningful impact” requirement in statute and to avoid actions that are materially inconsistent with the obligation to affirmatively further fair housing. Goals and policies must be created with the intention to have a significant impact, well beyond a continuation of past actions, and to provide direction and guidance for meaningful action. AFFH Guidance, p. 52.

The draft element’s Housing Action Plan contains numerous actions that lack concrete steps and measurable outcomes and will not necessarily result in a beneficial impact during the planning period in violation of the Housing Element Law’s standards. The following programs are inadequate and include our recommendations to improve them. ● Program 1 - Maintain Adequate Sites. Program 1 states that the City shall continue to maintain a current inventory of Housing Element sites to ensure that it can adequately accommodate the 2023-2031 RHNA” Given the impact of rezoning to the availability of and location of sites suitable for housing, the City should take additional steps to ensure transparency in decision-making related to proposed rezones and take diligent steps to provide notice of the proposed rezone along with an assessment of the potential impacts of the rezone on housing opportunity prior to a decision on the proposal. This includes but is not limited to public hearings and door to door canvassing to facilitate effective

notice. Further, the city must conduct a racial equity analysis which would include the benefits and disadvantages of the proposed rezone and whether it would result in displacement of protected racial/ethnic groups, reduce housing opportunities for protected groups, and how it would impact patterns of segregation. Finally, the program should explicitly prohibit the rezoning of sites suitable for lower income households to industrial land use classifications which would bring industrial uses next to or near neighborhoods that include or are planned for housing affordable to lower income residents. This is critical to ensure that the City is compliant with its duty to affirmatively further fair housing.
● Program 2 - Variety of Housing Opportunities in High Resource Areas (identified in the AFH as a Meaningful Action).

The program states that the City “will identify and pursue opportunities” with affordable housing developers to promote the development of affordable units in high resource areas. Unfortunately, it does not provide any details on how they will in fact promote the development of affordable units for lower income households in high opportunity areas.

There is no clear commitment to zone sites for multi-family development in areas of high opportunity or a commitment to ensure that such units are affordable to all income levels.

Further, there is no commitment to match funding opportunties with the identification of available sites to facilitate their development. Notably, the City will not conform with its duty to AFFH if it does not ensure adequate sites for affordable housing for lower income residents in high resource areas. Without clear and enforceable commitments and timelines, this program will not provide a beneficial impact or further fair housing.

Furthermore, in order to expeditiously address the lack of housing opportunities accessible to lower-income residents in high resource areas, the timeline of this program should be shortened.

Accordingly, a specific objectives of this program should be changed to (a) assess the number of sites that must be rezoned in high resource areas (as identified in TCAC/ HCD’s Opportunity Maps) to effectively AFFH , and (b) rezone the adequate number of sites pursuant to that analysis by December of 2025.
● Program 3 - Encourage and Facilitate Accessory Dwelling Units (ADUs) ( identified in the AFH as a Meaningful Action) . While we support and encourage the development of ADUs, the program does not outline clear commitments that will yield identifiable beneficial outcomes. The program states “a primary objective of this program is to increase the supply of affordable units throughout the city” but fails to identify any

specific commitments to take any action on how this objective will be reached.

Additionally, building ADUs is generally not an accessible housing option to low income households who cannot afford predevelopment costs associated with ADUs. We recommend additional measures in this program to make ADUs accessible to lower income households such as targeted outreach to low-income homeowners, incentives for landlords to make ADUs affordable, no interest loans for ADU development and waivers for inspection fees Additionally, a dedicated liaison in the Office of Community Affairs should be available for all questions regarding ADUs.
● Program 8 - Use of Sites in Previous Housing Elements. . Program 8 should be updated to clarify that streamlined approval will be available to both vacant and non-vacant sites through a zoning amendment. As written it appears that the zoning amendment will only apply to vacant sites included in the 4th and 5th cycle housing elements. ● Program 9 - Annual Reporting Program. While we appreciate the sentiment that the City will “engage all members of the Fresno community,” and the specific commitment to use multilingual notices and media, the City should revise this program and avoid using vague language with no commitments. To make the public engagement associated with this program meaningful, we recommend that the program include a commitment and associated timeframe for the City to implement input received through its various outreach efforts such as workshops and surveys in addition to the annual public hearing.

The annual report should include specific actions the City will take to overcome identified constraints and barriers to complying with Housing Element programs. ● Program 10 - Incentives for Housing Development ( identified in the AFH as a Meaningful Action) . This program does not present a commitment to address housing production for low-income units or actions that will be taken to complete the program. To facilitate and promote the use of available incentives, the city should make a list of incentives, including density bonus incentives and impact fee waivers, available to the public through an accessible database.

Additionally, the program’s current language that it will “identify site opportunities in higher resource areas and …improve access to resources” suffers from the same issues hat program 2 does insofar as it fails to identify clear and enforceable commitments and steps that it will take to ensure the availability of sites for lower income households in high opportunity areas. It is critical for this program’s success and the City’s role in AFFH that the housing element includes clear, timebound, and enforceable actions to

ensure availability of sites for lower income households in high resource areas, as outlined above.

Finally, the City should include enforceable commitments to avoid displacement and gentrification in the Downtown Planning Area, and assess the role that priority processing in the area has on the City’s duty to AFFH.
● Program 11 - Local Housing Trust Fund ( identified in the AFH as a Meaningful Action) . The Local Housing Trust Fund is a great tool to alleviate the housing crisis and we are glad to see the City’s commitment to leverage State matching funds. We recommend adding the creation of a Community Advisory Board as an action to ensure that projects are driven by a community process and benefit the most impacted residents.

Housing advocates have met previously with City staff to develop an equitable Community Advisory Board made up of a diverse group of residents most impacted by housing barriers, legal experts, and small landlords.
● Program 16 - Surplus Public Lands. The commitment to release surplus sites appears to simply be a commitment to comply with its existing duties under the Surplus Lands Act. The language is ambiguous, non-committal and must be revised. In addition, the program states the City will “consider depositing a portion of up to 100 percent [of sale proceeds] to the LHTF” We recommend instead that the City commit to depositing 100 percent of sale proceeds into the LHTF.
● Program 18 – Home Buyer Assistance ( identified in the AFH as a Meaningful Action) . While a critical program for many Fresnans, this Program should include additional commitments to ensure that low-income residents, undocumented residents, residents who speak languages other than English, and residents in racially and /ethnically-concentrated areas of poverty (R/ECAPs) have the opportunity to benefit from these funds. During the 5th Cycle planning period, many residents without social security numbers or who faced language access barriers were unable to apply for the City’s homebuyer assistance program. While the City was able to assist nine families with this program, this program must incorporate mechanisms that will allow more families to apply during the next 8-year cycle by addressing barriers and pursuing state funds every year. This program has other deficiencies that must be addressed such as lack of public outreach and lack of interpretation for applicants applying by phone. Solutions include:
ensuring that low-income residents are knowledgeable about the programs, undocumented residents are able to successfully apply for this program, including closing

costs as part of funding packages. In order to ensure that residents living in R/ECAPs are targeted, we recommend the City create annual reports listing how many applicants were assisted, outreach efforts made and whether they live in R/ECAPs. Due to the concerns outlined above, the program as currently implemented and drafted fails to adhere to HCD’s AFFH Guidance that “actions must be specific with timelines, discrete steps and measurable outcomes to have a ‘beneficial impact’ during the planning period.” ● Program 19 – Housing Choice Voucher Incentive Program (HCV) ( identified in the AFH as a Meaningful Action) . This action fails to include meaningful actions with specific timelines, and measurable outcomes to have a “beneficial impact” during the planning period. The program should develop and implement a proactive enforcement program housed within that legal department to ensure HCV . The City should revise this program action to include a timeline of one workshop a month (twelve workshops throughout the year) to ensure residents and landlords are able to access housing quickly and better assist residents/landlords going through any issues that prevent them from using/accepting HCV . Additionally, collaborating with and funding CBOs and fair housing organizations to provide information to voucher holders and landlords on California’s source of income discrimination prohibitions. The program should also commit the City of Fresno to finance billboard ads about protections against HCV discrimination and send informational materials to all landlords in Fresno registered in the rental registry regarding HCV . Finally, the program should be revised to include a commitment to actively pursue enforcement against discrimination against voucher-holders and supplementing vouchers with additional subsidies to support voucher use in higher-cost markets in high resource areas. Northeast Fresno has very limited HCV use, with only four census tracts north of Herndon Avenue containing any HCVs, and of those four tracts, no tract exceeds 5 percent HCV use. By revising the program to include the above recommendations would help address fair housing needs in Fresno.
● Program 21 – Housing Rehabilitation ( identified in the AFH as a Meaningful Action) . Government Code section 8899.50 requires “‘meaningful actions” well beyond combating discrimination to overcome patterns of segregation and foster inclusive communities. These actions, as a whole, must address significant disparities in housing needs and in access to opportunity.” The current program has failed to address the needs of extremely low income residents and vulnerable populations such as undocumented residents. As we continue to see the negative effects of Climate Change across the world, it is imperative that the City include weatherization such as cooling mechanisms, like

heat pumps, air conditioning, insulation and other cooling assets to increase resilience to extreme heat as part of the rehabilitation program. It is a critical and urgent need given that extreme heat kills thousands per year and impacts disadvantaged communities the most. Additionally, the City must establish an acquisition and rehabilitation fund to purchase older, blighted, and/or abandoned homes/buildings. The City of Fresno can establish a revolving fund to insure that rehabilitated homes are sold back to the community at a low cost.Finally, for the program to have a beneficial impact the timeframe section should include 15 rehabilitation grants annually, and 5 distressed property grants using PLHA and CDBG funding for extremely low and low income residents.
● Program 22 – Comprehensive Code Enforcement. While we appreciate Code Enforcement’s response and the City’s diligence to keep increasing staff, there are still additional actions that should be taken to create a comprehensive code enforcement.

HCD’s AFFH Guidance recommends that “to overcome contributing factors to fair housing and affirmatively further fair housing, actions must consider a wide range of actions across all action areas. The number and scale of actions will depend on the severity of the needs but regardless of need, a cohesive and effective program will consider multiple action areas.” This program as written continues to fail to address critical housing issues since the last housing element cycle. The program should be revised to include actions around legally holding landlords accountable for retaliation, unlawful evictions, and harassment towards tenants who file code enforcement complaints such as a commitment to adopt a tenant anti-harassment ordinance. As stated, we recommend that the City adequately analyze code enforcement’s procedures and incorporate tenant feedback for a comprehensive code enforcement program. ● Program 23 - Special Needs Housing ( identified in the AFH as a Meaningful Action) .

housing assistance, vouchers and other subsidies unless otherwise required by federal law.
● Program 26 - Equitable Community Investments ( identified in the AFH as a Meaningful Action) . Program 26 states it will “seek funding,” “continue to actively seek resources,” and “continue implementing the written policies.” These commitments are vague and non-committal. There are no actions on how these will be completed and is ambiguous and as a result provides no indication that a beneficial outcome will result from the program and further fair housing. The programs continue not to commit the City to take a lead role in planning, funding, and/or constructing projects or indeed any role beyond identifying issues and needs and seeking funding on an annual basis.

Additionally, it should not rely on the General Plan’s identification of Priority Areas for Development Incentives in Chapter 12 and should instead use the Urban Displacement Project data to guide investments.
● Program 28 – Opportunity To Purchase Act (OPA) ( identified in the AFH as a Meaningful Action) . Although we appreciate the City’s action to initiate research on a local Opportunity to Purchase Act, we strongly recommend that the City implements robust outreach and engagement, in partnership with CBOs that work closely with low-income communities in racially/ethnically-concentrated. Additionally, the program states it “shall research'' and “consider establishing an OPA.” These are not commitments and fail to implement any specific, firm, or enforceable commitment such that no beneficial outcome of the action is indicated.
● Program 29 – Mobile Home Parks ( identified in the AFH as a Meaningful Action) .

adequate and safe conditions for their tenants. For example, Three Palms Mobile Home Park had not had safe drinking water for quite some time and the owner was never made responsible for this clear human rights violation. Finally, consistent with the City’s responsibility to AFFH, the program should support quality of life and access to opportunity improvements for all mobilehome parks in Fresno by taking meaningful actions to increase green space, transit, and resources near mobile home parks. ● Program 30 – Emergency Rental Assistance Program ( identified in the AFH as a Meaningful Action) . Although we appreciate the City adding this program, it states that the City will “seek additional funding” and fails to commit ongoing funding that can come from the Local Housing Trust Fund, the General Fund, or its own permanent funding source to ensure a beneficial impact during the planning period. Identification and commitment of a permanent local source of funding by 2024 will highlight a commitment to prevent displacement and protect tenants. ● Program 31 - Eviction Protection Program (EPP) ( identified in the AFH as a Meaningful Action) . The Eviction Protection Program is a critical anti-displacement and anti-homeless tool. However, the program's current language to “seek additional funding to support the “EPP'' is not a strong commitment and does not provide indication that a beneficial outcome will occur if funding is not replenished. We strongly recommend that the City commit to staffing 5 full-time staff for screening so tenants are able to receive help as soon as possible. We also recommend program expansion to include:
● Wide-reaching outreach and education campaigns
● Direct legal representation and assistance for low-income tenants encountering legal issues. This includes but is not limited to being served with a notice from their landlord (e.g. 3-day notice, notice of rent increase, etc.) ● Evaluation of the Eviction Protection Program to ensure it is effective and address issues to improve the program.
● Program 33 – Homeless Assistance ( identified in the AFH as a Meaningful Action) .

● Program 34 - At-Risk Housing. Program 34 includes actions without a clear commitment to take steps that will lessen the severity or impact of the issue in any timeframe. Again, the language is non-commital, vague, and ambiguous in how the program will reach its objective. Additionally, stronger tenant protections should be included as an objective and completed no later than June 2024 for residents facing displacement and an affordable housing resource map for tenants so they have the option to relocate.

Additionally, the draft element lacks policies and programs identified in Leadership Counsel’s February 2023 letter, attached hereto. We incorporate the policies and programs recommended in that letter here by reference. In addition to the policies and programs highlighted in Leadership Counsel’s February 2023 letter, the draft element should also be revised to include the following programs:

A. Rent Control and Just Cause Protection Ordinance. The Housing Element draft mentions tenant protection “strategies” but in no way does the draft commit to tangible solutions. City of Fresno tenants, along with advocates, have been demanding rent control and just cause ordinance since 2021. The Here To Stay Report lists this as the communities’ top priorities. Tenants have attended City Council meetings for the past two years asking for this; they have met with every city council member; and have lifted this as a priority in the City’s Housing Element workshops. Yet, the City refuses to acknowledge residents’ need. We strongly recommend that the City incorporate this into the Housing Element.

B. Inclusionary Zoning Ordinance. The City should adopt a program to develop and adopt an inclusionary zoning ordinance by a date certain that is no more than three years into the planning period in order to allow the ordinance to result in the production of lower-income units during the planning period. To ensure that the ordinance AFFH and maximizes the production of affordable units, the ordinance should apply to single-family and multi-family housing and require a minimum share of affordable units (approx. 25-30%) and affordability levels of those units, including affordability for very-low and extremely-low income households. The City should develop this ordinance in partnership with lower-income residents and CBOs.

C. Urban Greening is used as buffer zones when residential is placed or already placed near existing polluting land uses to mitigate health impacts.

D. Citing industrial uses. Programs should explicitly prohibit the rezoning of sites suitable for lower income households to industrial land use classifications which would bring industrial uses next to or near neighborhoods that include or are

planned for housing affordable to lower income residents. This is critical to ensure that the City is compliant with its duty to affirmatively further fair housing.

E. Impact fees should be placed into a community benefit fund when polluting land uses and practices are placed near housing. The community benefit fund will be managed by the community directly impacted to dictate to who these funds should be allocated.

F. Establish local hire provisions requiring that a certain percentage of workers reside within 10 miles or less of a Project Site. This can reduce the length of trips, reduce greenhouse gas emissions and provide localized economic benefits G. Developing Public Health Impact Reports for new development in order to understand existing public health disparities and the potential of those conditions worsening as a result of development. Public health agencies should be resourced to support this analysis. The findings of these reports should be available publicly and be included in permit approval processes and other key decision-making milestones.

H. Establish a Cargo/Freight Prohibition and Revenue Tax to directly fund community-based housing and projects in the neighborhoods most negatively impacted by years of environmental toxicity caused by freight.

I. Incorporate Complete Streets principles into all transportation projects at all phases of development, including planning and land use decisions, scoping, design, implementation, maintenance, and performance monitoring.

J. Establish a Housing Element Implementation Committee to oversee the timelines and implementation of each program and policy. The committee should be composed primarily by tenants, low-income homeowners, and at-risk populations to ensure implementation meets the needs of most at-risk communities.

As discussed previously, each program must contain clear action steps, deadlines, and measurable outcomes that will be achieved within the planning period and address housing and fair housing needs prioritized during the public process. * * * * *
Thank you for your consideration of our comments. Please contact us if you would like to find a time to discuss them. We look forward to working together to advance access to safe, affordable housing for all City of Fresno residents.

Sincerely,
Karla Martinez, Policy Advocate
Leadership Counsel for Justice and Accountability
Edith Rico, Project Director
Building Healthy Communities
Shar Thompson, Central Valley Regional Coordinator
Tenants Together
Marisa Moraza, Campaign Director
Power California

December 11, 2023 City of Fresno Revised Draft Housing Element Comment Letter

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AttachmentC
CommentLetterfromPub.Int.L.Project&LeadershipCouns.forJust.&AccountabilitytoMayor JerryDyer,FresnoCityCouncilmembers,&MichelleZumwalt(Aug.16,2023)(on ﬁle with
author).

Leadership Counsel for Justice and Accountability write in collaboration with the Public Interest Law Project (“PILP”) and residents of South Fresno neighborhoods impacted by the severe lack of decent quality, affordable, and permanent housing options and gaping disparities in access to opportunity in Fresno to provide comments on the July 2023 Draft Appendix 1-E:

City of Fresno of the Fresno Multi-Jurisdictional 2023-2031 Housing Element (“City of Fresno Draft Housing Element” or “Draft Element”).

Leadership Counsel works alongside the most impacted communities to advocate for sound policy and eradicate injustice to secure equal access to opportunity regardless of wealth, race, income, and place. Leadership Counsel advocates for policy and practice changes to meet the housing needs of all residents in Fresno, especially low-income and residents with special housing needs, and to overcome fair housing disparities that impact low-income communities of color. Residents with whom we partner experience high rates of cost burden and escalating housing costs, reside in unsafe and unsanitary rental housing conditions, and ever-present and magnifying displacement risks and are simultaneously impacted by striking disparities in access to opportunity compared to more affluent Fresno neighborhoods, including a lack of access to a healthy environment and public and private investment in critical infrastructure, services, and amenities.

The Public Interest Law Project (PILP) works statewide to support local legal programs that address issues involving housing, land use, public benefits and homelessness. PILP has been providing substantive training, litigation support, and technical assistance in these areas for over 25 years.

The City of Fresno’s 6th cycle housing element update presents a critical opportunity for the City to identify and address long-standing, wide-ranging, and severe housing needs and fair housing disparities that impact the City’s residents, disadvantaged communities, and racially and 2210 San Joaquin Street, Fresno, California 93721
Telephone: (559) 369-2790

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ethnically concentrated areas of poverty (“R/ECAPs”), in particular, the Southwest, South Central and Southeast areas. The City must ensure that it does not miss this opportunity to develop and adopt a housing element that complies with the State Housing Element Law and civil rights laws and that meaningfully incorporates the input of lower-income residents and protected classes and the community-based organizations that work alongside them.

Our comments below highlight further steps and actions the City must take to meet State Housing Element Law requirements. In short, the Draft Element must be revised in order to meet Fresno’s housing needs and relevant statutory requirements in several different ways, including:
● Incorporate input regarding key housing issues and disparities and actions needed to address those issues provided to the City by community members as required by HCD’s AFFH Guidance;
● Revise the constraint analysis to address non-governmental constraints, as well as constraints on supportive housing and the maintenance of the housing stock. ● Revise the AFH analysis to consider all of the required displacement factors, barriers in access to opportunity, and fair housing issues associated with the Draft Sites Inventory; ● Revise programs to include specific actions and deadlines and add programs that will result in a beneficial impact on Fresno housing needs and disparities during the planning period and overcome patterns of segregation and foster inclusive communities, including but not limited programs 14, 15, 19, 23, 29, and 33;
● Revise the site inventory analysis to exclude projects that have not been approved during the projection period, include a realistic capacity calculation based on development throughout the 5th cycle, and determine the adequacy of the non-vacant site I. The City Has Not Diligently Engaged the Public As Required, Because the Draft Element Fails to Adequately Reflect Public Input
The City’s obligations to diligently engage all economic segments of the community and to affirmatively further fair housing through the housing element require more than just seeking input about the contents of the housing element. Government Code sections 65583(c)(8), 65583(10)(a) & 8899.50. Inviting residents to provide input but failing to incorporate that input into the housing element undermines the purpose of resident participation in the housing element update, fosters distrust, and fails to constitute “engagement” as required by section 65583(c)(8) of the Housing Element Law. HCD’s Affirmatively Furthering Fair Housing (“AFFH”) Guidance 2210 San Joaquin Street, Fresno, California 93721
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states that housing elements must describe “a summary of [public] comments and how the comments are considered and incorporated (including comments that were not incorporated), particularly with changes to the housing element. HCD, Affirmatively Furthering Fair Housing:

Guidance for all Public Entities and for Housing Element (“AFFH Guidance”), 2021, p. 22. 1 While the Draft Element provides some description of public input provided, its summary of public comments generally lacks sufficient detail for the reader to understand the nature of the issue raised or the solution proposed. In addition, the Draft Element fails to demonstrate the City’s incorporation of input provided and to identify input the City chose not to incorporate as required. For example, at the March 1, 2023 community workshop on the housing element update held at Helm Home, residents identified the establishment of rent control, tenant assistance and protections, and reducing barriers to undocumented residents as among their top suggestions and solutions. The Draft Element fails to demonstrate how this solution will be incorporated into the final draft and to even to study the housing needs of undocumented residents.

The Draft Element also fails to acknowledge, discuss, or incorporate recommendations contained in the letter submitted to the City by Leadership Counsel and several other community-based organizations in February 2023 relating to the development of this Draft.

Attachment 1, Leadership Counsel February 2023 Letter. The letter identifies policies and programs which the signatory organizations believe should be prioritized in the housing element update, based on our direct and daily work with low-income residents of color, farmworkers, residents of disadvantaged unincorporated communities, and other residents with special housing needs and members of protected classes. The City must revise the draft element to acknowledge this letter, summarize its contents, and revise goals, policies, and programs to incorporate its recommendations, in addition to other input it receives. The City must also revise the element to indicate what public input it chose not to incorporate, which the element currently fails to do.

II. The Housing Element Fails to Adequately Analyze and Remove Governmental Constraints to Housing Development
To fully comply with Housing Element law, the City of Fresno must identify constraints to the development of housing affordable to households at different income levels, as well as possible constraints to the development and maintenance of a variety of types of housing, including supportive housing, single room occupancy units, emergency shelters, and transitional housing. See Gov’t Code §65583(a)(5) and (c)(1). This analysis includes potential and actual governmental constraints upon the maintenance, improvement, or development of housing for all 1 All references to code sections hereafter refer to the Government Code unless stated otherwise. 2210 San Joaquin Street, Fresno, California 93721
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income levels. Gov’t Code § 65583(a)(5). Following a close analysis, the City must include a description of efforts to remove constraints and a program to remove those constraints. Gov’t Code §65583(c)(3).

A. Land Use Controls Are Under-Analyzed as a Constraint The Housing Element under analyzes the impacts of current and planned zoning regulations on housing development. A jurisdiction must include an analysis of potential and actual governmental constraints, including land use controls that directly impact the cost and supply of residential development. Gov’t Code § 65583(a)(5). The constraints analysis fails to demonstrate the direct connection between its currently proposed zoning on cost and supply of housing.

The City has not adequately analyzed the effects of constraints associated with wide-spread availability of single family zoning and the limited availability of high density zoned sites. For example, the HE acknowledges “growth in the City of Fresno over the past few decades has traditionally been low density suburban development, which has resulted in conditions of sprawl in various areas of the city. 2 Despite the acknowledgement, the City continues to allow by right single-family units in. Despite the historical preference for single family development, the abundance of available single family homes in Fresno, and the underproduction of affordable housing,the the City still permits single family uses by-right in many of the zones identified for increased high-density development: RM-1, NMX, CMX, RMX, CMS, CR, DTN, DTG.

Further, although single family development is allowed in almost every zone that permits residential development, higher-density units are not allowed in certain areas in the City. For example, multi-family units are not allowed in RS-1, RS-2, or RS-3 areas, despite the large majority of the City being zoned one of these zones, and where many high resource areas have developed. 3 Duplexes are similarly constrained, they are excluded from RS-1, RS-2, RS-3, RS-4, and only allowed through conditional use permit in R-5.

Because both single-family and multi-family development is permitted in most residential zones, it puts multi-family developers in competition with single family developers for the same sites.

Single family units also benefit from reduced permitting timelines. For single--family developments it typically takes up to 30 days for developers to pull building permits after its 3 City of Fresno, 2023. Data downloaded from HCD AFFH Data and Mapping Tool in 2021, based on ACS data. 2 Fresno Multi-Jurisdictional Housing Element July 2023, Appendix 1E: City of Fresno, 1E-4-1. 2210 San Joaquin Street, Fresno, California 93721
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entitlements are approved. 4 In contrast, based on recent projects, it can take three months to a year for multifamily developers to receive building permits after entitlements. 5 Although the Draft concluded that higher permit processing schedules for multi-family units compared to single family units are not a constraint, the increased complexity and expected timeline does appear to act as a constraint on multi-family development based on the very low production number of multi-family housing in the 5 th cycle. . 6 B. Land Use Controls’ Effect on Types of Housing
A complete constraint analysis does not only focus on housing by income levels but must also consider constraints to the different types of housing.. As noted above, the Draft constraint analysis must examine what constraints exist to the development of : supportive housing, transitional housing, single room occupancy units, and emergency shelters. Gov’t Code 65583(c)(1)

1. Single Room Occupancy (SRO) Units
The City’s constraint analysis regarding SRO’s should examine more than the limit on the number of units but also where SRO’s are permitted to develop. SRO’s are a crucial source of affordable housing for many people and can augment the deed restricted affordable housing available to lower income people. The City should commit not only to removing the limit on the number of units that can be contained in an SRO but also add it as a permitted use in the following zones:

RM-MH, RM-2, and downtown while removing conditional use permit requirements from RM-2, RM-3, NMX, CMX, and RMX.

2. Emergency Shelters
The Draft must consider whether its development standards act as a constraint on the development of emergency shelters. Although the City seems to determine that its requirements do not act as a constraint to the development of shelters it also states it may consider making further amendments to the development code to remove any possible constraints. If further amendments are necessary, especially any needed to comply with Government Code section 65583(a)(4)(A), the City should commit to making those changes immediately. For instance, the City’s current requirement for the number of toilets per person in a shelter (Muni Code section 6 Fresno Multi-Jurisdictional Housing Element July 2023, Appendix 1E: City of Fresno, 1E-4-38 5 Fresno Multi-Jurisdictional Housing Element July 2023, Appendix 1E: City of Fresno, 1E-4-35 4 Fresno Multi-Jurisdictional Housing Element July 2023, Appendix 1E: City of Fresno, 1E-4-35 2210 San Joaquin Street, Fresno, California 93721
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15-2729), if it exceeds the building code requirement is a likely constraint on the development of shelters because of the additional cost it adds to this type of development.

3. Supportive Housing
The Draft is silent as to whether the development oecd complies with Government Code section 65583(c)(3) that allows supportive housing in any zone where multi-unit or mixed use development is permitted. If the City’s code does not reflect this requirement that is a constraint on housing for people with disabilities and a program to revise the development code to comply with the statute is required.

4. The HE Under-Analyzes Parking Requirement Effects on Housing Construction
The Draft fails to fully analyze whether its parking requirements act as a constraint on housing development, especially in the downtown and along transit corridors. Parking requirements increase the cost of housing. 7 The Draft states it “determines the required number of parking spaces based on the type and size of the residential unit and has found the required parking spaces to be necessary to accommodate the number of vehicles typically associated with each residence.” 8 The analysis ignores principles of induced demand and downstream effects of entrenching car-centric land use. The Draft implicitly acknowledges that parking increases costs and may not be critical as it allows waivers for parking requirements in affordable housing developments and other transit-friendly areas. 9 The ad hoc basis of reduced parking requirements introduces uncertainty which can increase the overall cost and time delays in housing development.

Recently, the City has made clear how much of an impediment parking really is. In negotiations with the state to receive a large grant to support increased housing in downtown Fresno, the City earmarked about $70 million of a possible $250 million grant for two new parking structures in the downtown area. Mayor Jerry Dyer stated [the cost of parking structures] “is always a big challenge for us when we try to bring in developers to build housing… Taking that off the table allows for these projects not only to occur faster, but it allows the developers to be more incentivized to build in our downtown area.” 10 10 https://www.fresnobee.com/news/local/article275363746.html 9 Fresno Multi-Jurisdictional Housing Element July 2023, Appendix 1E: City of Fresno, 1E-4-10 8 Fresno Multi-Jurisdictional Housing Element July 2023, Appendix 1E: City of Fresno, 1E-4-10 7 http://database.greentrip.org/
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Although parking has been identified as a constraint to increased housing development, the City has not put forward a program to identify steps to remove the constraint. The City asserts “[p]parking standards are one area where many communities are seeking to decrease housing costs.” 11 Yet, minimum parking requirements are squarely within the control of the jurisdiction and could be reduced if the City so decided. The direct link on parking’s costs in relation to housing development in Fresno must be further analyzed, and a reduction in parking requirements is likely required.

C. Risk Analysis and Distribution of Affordable Housing The Draft’s analysis of at-risk housing is incomplete. under-analyzes the risks to publicly assisted affordable housing and its distribution. There are more than 8,500 publicly assisted affordable housing units in the City of Fresno. 12 . The Draft identified 695 units at risk of conversion to uses other than low-income residential within 10 years from the housing element adoption deadline. 13 Although the City of Fresno considered the cost of replacing the at-risk units as required under §65583(a)(8), it failed to examine which pathway would be most appropriate for the City and what constraints, if any, would be associated with the pathway chosen.

The City’s lack of tenant protections, such as source of income discrimination outreach and education, rent control, just cause protections may operate as a constraint on the maintenance of housing available to lower income people and facilitate the displacement of lower income renters. The lack of these protections should be analyzed as a constraint on the maintenance of housing under Government Code section 65583(a)(5).

III. The Housing Element Fails to Adequately Analyze and Remove Non-Governmental Constraints to Housing Development
In addition to analyzing governmental constraints, the HE must also analyze the potential and actual nongovernmental constraints upon the maintenance, improvement, or development of housing for all income levels. Gov’t Code § 65583(a)(6). To that end, the Draft failed to consider the effect of market forces, availability of financing, environmental concerns, and NIMBY opposition.
13 Fresno Multi-Jurisdictional Housing Element July 2023, Appendix 1E: City of Fresno, 1E-4-55 12 Fresno Multi-Jurisdictional Housing Element July 2023, Appendix 1E: City of Fresno, 1E-4-55 11 Fresno Multi-Jurisdictional Housing Element July 2023, Appendix 1E: City of Fresno, 1E-4-14 2210 San Joaquin Street, Fresno, California 93721
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A. NIMBY Opposition
The Draft must include an analysis of NIMBY opposition to housing development. As a largely sprawling suburban City, Fresno is prone to local opposition to increased density from existing single-family homeowners that have preconceived ideas of the impacts of increased density on their neighborhoods. Further, the zoning code requires conditional use permits for duplexes and multi-family housing in some areas, making them especially susceptible to opposition and defeat from NIMBY residents.

The chilling effect of NIMBY opposition to housing development is not a foreign concept to jurisdictions in Fresno County. For example, in the adjacent City of Clovis, the Clovis City Council recently voted to shut down a proposed 40-unit development near Old Town Clovis because neighbors expressed concerns about traffic congestion, overflow parking and the “monolithic” height of the planned apartment building. 14 NIMBY opposition to housing development is a widespread phenomenon across California but is especially prevalent in areas that have historically been primarily low-density developments. The Draft’s failure to analyze NIMBY opposition as a constraint must be addressed in the City’s next Housing Element draft, and the City should include a program to reduce this type of opposition by ensuring that more than single family developments are permitted by-right and reducing the discretionary review of multi-family housing.

B. Environmental Concerns
The Draft did not consider environmental constraints as part of its analysis under 65583(a)(6). Environmental constraints may include limitations to water supply, nearby pollution, or infrastructure development.

The City of Fresno relies heavily on groundwater and surface water. As climate change makes water availability less predictable the City must analyze how an increased population and land use will affect water availability and whether water availability will eventually constrain growth.

Further, separate from water availability, the City must consider the infrastructure requirements of delivering water to a denser population. For example, the City estimates that downtown Fresno, where a large portion of new housing development is projected, currently requires significant water and wastewater infrastructure upgrades. Broke Broche, the City’s director of public utilities, estimated that downtown Fresno would require between $160-$180 14 https://www.fresnobee.com/fresnoland/article255749376.html 2210 San Joaquin Street, Fresno, California 93721
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million in water and wastewater upgrades to support planned housing development. 15 The Draft should analyze the cost of these needed improvements as a possible constraint on development.

Finally, the Draft failed to consider industrial and polluting industries’ effect on future housing development. The City of Fresno has evolved as a car dependent City surrounded by heavy industry and highways. Therefore, future housing development will need to carefully consider placement and mitigation measures to avoid perpetuating environmental inequity.

C. Market Forces and Availability of Financing
The Draft failed to include an explanation of current housing development trends and applications across all income levels. Market forces are relevant to the types of housing that are likely to develop in the future. Once this analysis is done it might make it clear what actions the City must take, such as further financing for programs.. Using the example mentioned above, requiring private investment to implement required infrastructure in downtown Fresno would likely make housing development in the area infeasible. Similarly, lower margins or a lack of developer interest in serving lower income portions of the market may require the City to provide incentives to spur greater housing development in the segment. Without a proper analysis such a conclusion is impossible and falls short of the requirements listed in Government Code § 65583(a)(6).

For example, Fresno had some of the highest rental price increases in the country, with a 28% increase in one-bedroom rent prices between January 2021 and January 2022. 16 The spike in rent prices disproportionately affects low-income individuals who are often on fixed incomes or receive low wages that have not kept up with the rapid rise in rents. Further, existing conditions in many rental units in Fresno have failed to keep up with required maintenance and would fail habitability requirements. 17 The combination of unmaintained housing in Fresno alongside rising rents was not analyzed as a constraint. As a result, the condition of housing stock available to low-income populations must be analyzed and the City must take steps to redress those constraints identified.
17 https://www.fresnobee.com/fresnoland/article251600613.html 16 https://www.fresnobee.com/fresnoland/article258073823.html 15 https://www.fresnobee.com/news/local/article275363746.html 2210 San Joaquin Street, Fresno, California 93721
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IV . Further Revisions and Analysis are needed to determine if the City’s Draft Includes Adequate Sites
A. Regional Housing Need Allocation (RHNA)
The City’s calculation of the RHNA it must accommodate must be revised to exclude units that have not been approved during the projection period. State law permits cities to reduce the number of units they must accommodate in their inventory of adequate sites, by income level, by the number of units approved or permitted since the beginning of the planning period:

Projects that have been approved, permitted, or received a certificate of occupancy since the beginning of the RHNA projected period may be credited toward meeting the RHNA allocation based on the affordability and unit count of the development. For these projects, affordability is based on the actual or projected sale prices, rent levels, or other mechanisms establishing affordability in the planning period of the units within the project. See HCD’s Housing Element Sites Inventory Guidebook, p. 5, available at
https://www.hcd.ca.gov/community-development/housing-element/housing-eleme nt-memos/docs/sites_inventory_memo_final06102020.pdf
The City’s Draft Element appears to take credit for units that are still under review and have not yet been approved or permitted. The Draft Element cannot claim credit, meaning reduce the RHNA, with the following projects because project approvals have not been obtained for these units: Villa Baraca Apartments (P-1); DADA Lofts (p-13)(indicates the application is still being reviewed); Lincoln Park Apartments (P-16); Starling Townhomes (P-17); Latitudes at Armstrong (P-18); Helm Tower Office and Lofts (P-19); Elm Avenue Living (P-21); Majestic Palm Apartments (P-22); and, Los Pueblos Apartments (P-23).

The Number of sites needed to accommodate the RHNA should reflect the removal of the above-described projects.

B. Capacity calculation
If a site does not have a required minimum density then the City must analyze the development capacity based on the patterns of typical development patterns in the same zone.

The City uses a very narrow time frame to assess the development capacity of projects in the City – 2018-2020, it is unclear why the City has chosen such a narrow time frame but in order to assess if the Draft’s capacity calculations truly reflect realistic development patterns the City should use a broader time frame to establish the types of developments and capacity typically achieved.
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Also, the Draft should explain why the capacity calculation for the RM-1 zone was rounded down from 85 percent to 80 percent, while the same calculation was rounded up from 77 percent to 80 percent in the RM-3 zone.

The City has chosen not to rely on the minimum density to calculate capacity on some mixed-use zone site (NMX, CMX, RMX) and because there are no maximum densities imposed, the City instead creates a formula that determines what is likely “reasonable density” density that could develop on these sites and then divides that “reasonable density” in half to determine the Capacity for the site. This formula is flawed because it relies on very few submitted projects (that may not be approved) to determine what reasonable density might be during this planning period. It is crucial that the capacity calculation accurately reflects patterns of development especially where the City intends to accommodate a significant portion of the lower income RHNA (72 percent) on mixed-use sites. Two examples are not sufficient to establish a pattern of development.

Although the City relies less on the Downtown sites to accommodate the lower income RHNA, a correct calculation of capacity is still crucial in the DTC, DTG, and DTN zones and the DTN-AH overlay. And again, the City relies on very few projects during a very limited time period (2018-2020) to support its calculation for realistic capacity on downtown sites.

C. Non-vacant Sites
Non-vacant sites must demonstrate through the City’s methodology that they are feasible for residential development during the planning period. Government Code section 65583.2(g)(1). The methodology is required to consider certain factors. Id . The July Draft Element includes a description of the current use of the sites but the analysis must be revised to apply the required factors 18 in order to assess the availability and feasibility of these sites for residential development during the planning period beginning in December 2023, including the City’s past experience converting existing uses to higher density residential development. 18 The methodology shall consider factors including the extent to which existing uses may constitute an impediment to additional residential development, the city’s or county’s past experience with converting existing uses to higher density residential development, the current market demand for the existing use, an analysis of any existing leases or other contracts that would perpetuate the existing use or prevent redevelopment of the site for additional residential development, development trends, market conditions, and regulatory or other incentives or standards to encourage additional residential development on these sites. Gov. Code section 65583.2(g)(1).
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D. Large Sites and Concentrated Sites
The July Draft requires revisions to provide examples of whether “sites of equivalent size were successfully developed during the prior planning period for an equivalent number of lower income housing units as projected for the site…” Gov. Code section 65583.2(c)(2)(B). The Draft must also be revised to specifically identify what portions of the large parcels will accommodate the lower income housing needs in the City. The City is correct to assume that 100 percent of large sites, a site that is over 10 acres, will not likely develop for affordable housing. This is due, in part, to the limitation of available funding mechanisms for projects of over 200 units. But, identifying so many large parcels to accommodate housing for the lower income RHNA in close proximity to each other also acts as a constraint on development as affordable housing due to the same funding limitations. To be clear, identifying a large percentage of the sites to accommodate the lower income RHNA in close proximity to each other is a constraint on obtaining funding for affordable housing, funding which is critical to developing affordable housing, and it will create an obstacle to the development of these sites as affordable housing.

In addition, many of these sites are also concentrated in one area of the City and that also prevents the City from meeting its duties to remove patterns of segregation and comply with its duty to affirmatively further fair housing. [As mentioned in the AFFH section above, the over concentration of sites intended to accommodate the lower income housing need in specific areas of the City is inconsistent with the City’s duty to Affirmatively Further Fair Housing.] As noted above the City’s inventory of available sites will need revisions and further analysis in order to determine whether the City has identified adequate sites to accommodate its RHNA for this planning period.

V . The Assessment of Fair Housing Fails to Comply with Section 65583(c)(10) For generations, local mayors and council members have described Fresno as a “tail of two cities”, an illusion to Charles Dickens’ tragic 1859 novel of pre-revolution France, in acknowledgement of the outstanding disparities in quality of life and access to opportunity that exists between neighborhoods in the Northern and Southern portions of the City and the striking racial and economic differences that underlie them. Studies and data have repeatedly confirmed not only that South Fresno neighborhoods and people of color in Fresno are impacted by a severe lack of access to housing choice and access to opportunity across many indicators compared to North Fresno neighborhoods and White residents, but that the disparities impacting South Fresno, people of color and other protected classes stand out as among the most significant in the state and the country. The City’s duty to AFFH through the Housing Element and to complete an 2210 San Joaquin Street, Fresno, California 93721
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Assessment of Fair Housing in order to do so presents the City with a crucial new opportunity to address the intergenerational disparities and barriers to opportunity that persist in Fresno.

Unfortunately, as discussed further below, the AFH lacks information and analysis and fails to incorporate public input as necessary to address the requirements set forth in Section 65583(c)(10) and does not achieve the requirement to ensure that the City AFFHs through its housing element.

A. Integration and Segregation and R/ECAP and Concentrated Area of Affluence Analyses Lack Required Detail
The AFH’s analyses of patterns of integration and segregation and R/ECAPs and Racially Concentrated Areas of Affluence (“RCAAs”) fail to address important factors which must be considered as part of a complete analysis pursuant to section 65583(c)(10)(A)(ii) and HCD’s AFFH Guidelines. See AFFH Guidelines, pp. 30-34. These gaps render the AFH analysis incomplete and include but are not limited to the following:
● Failure to provide any data or analyze integration and segregation patterns for racial groups other than Hispanic/Latinos. Table 1:E-3.1, “Population by Race and Hisppanic Origin, Fresno, 2000-2020,” provides data about the share of the population of different racial groups in Fresno in 2000, 2010, and 2020, but no data is included that addresses the spatial composition and segregation or integration status of Black, AAPI, Native American, and other racial and ethnic groups. Similarly, the analysis fails to identify groups experiencing the highest levels of segregation as required. AFFH Guidelines, p.

31. ● Failure to accurately or thoroughly analyze distribution of low- and high-income households across Fresno. The Figure 1E-3.4, Median Household Income, Fresno, 2019 indicates median income levels across the City and depicts median incomes of $100,000 or over in some areas West of State Route 99, Northwest Fresno, Northeast Fresno, and in the Sunnyside neighborhood of South Fresno. Yet the AFH’s analysis of the data depicted by the map fails to acknowledge these high-income neighborhoods throughout the City, stating only that “Northwest neighborhoods of the city…have the highest median incomes. Otherwise, most of the remaining census block groups in the city have household incomes that fall below the statewide median indicating high poverty levels.” This analysis washes out important information about relative income levels across Fresno, including concentrations of high-income households and low-income households in specific neighborhoods, which should be used to inform and geographically-target programs and the location of sites included in the inventory to AFFH. See HCD 2210 San Joaquin Street, Fresno, California 93721
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Guidelines, p. 32. For neighborhoods like West Fresno, which experience particularly acute barriers to opportunity linked to policies and practices that created and enforced segregation, an accurate and complete analysis and programs that respond to that analysis are essential.
● The AFH’s analysis of R/ECAPs and RCAAs fails to address “public participation, past policies, practices, [and] investments” as required. HCD Guidance, p. 33. The R/ECAP analysis provides only the generic statement that “R/ECAPs generally have less private investment from financial institutions, grocery stores, and other retail outlets,” but does not provide any analysis specific to Fresno City or regional policies, practices, and investments that contributed to the creation and/or perpetuation of R/ECAPs. The RCAA analysis only identifies that 18 RCAAs exist in Fresno, with no analysis at all of the factors giving rise to those RCAAs or their persistence or variation over time nor does it consider any public input on this topic.

As a result of these and other deficiencies, the AFH’s analysis of integration and segregation and R/ECAPs and RCAAs is incomplete. The analysis and the Draft Element’s contributing factors, goals and actions must be revised accordingly.

B. Incomplete Analysis of Disproportionate Housing Needs Based on Race, Ethnicity, Familial Status, Disability, and Income
The analysis of disproportionate housing needs must analyze needs relating to cost burden, overcrowding, substandard housing, homelessness and other factors for protected characteristics, including at least race and ethnicity, familial status, persons with disabilities, and income. § 65583(c)(10)(A)(ii); AFFH Guidance, p. 39. 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” compared to the proportion of members of other relevant groups or the total population HCD’s guidance emphasizes that local data and knowledge are particularly important to this analysis. Id. The requirement to analyze disproportionate housing needs is fundamental to achieving the purpose of the AFH to ensure that the housing element affirmatively further fair housing by identifying disparities impacting protected classes which have been subject to historic discrimination, describes the factors contributing to those disparities, and adopts meaningful actions that overcome patterns of segregation and address disparities in housing needs and opportunity for protected classes. Yet, the AFH fails to satisfy this requirement. While it provides the percentage of households experiencing any one of four specified housing problems - lack of complete kitchen facilities, lack of complete plumbing facilities, overcrowding, cost burden – by race and ethnicity, the analysis of overcrowding, cost burden, and substandard conditions only addresses 2210 San Joaquin Street, Fresno, California 93721
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the prevalence of those housing issues based on housing tenure (renter or owner) and census tract. The analysis fails to include any information about the separate occurrence of overcrowding, cost burden, and substandard housing conditions based on race or ethnicity and fails to provide any information at all about how these factors disproportionately impact Fresno residents based on familial status and disability. While the AFH includes some data relating to the race, gender, and mental disability of unhoused residents, it fails to include information relating to familial status. Further, the analysis includes no information that reflects “local knowledge” or public input, depriving the analysis of details about specific housing needs within the categories identified above and the scale of those needs in relation to others.

The City must supplement its disproportionate needs analysis to include the required demographic information and revise the AFH further to ensure its contributing factors and meaningful actions reflect that information.

C. Displacement Risk Analysis Fails to Consider Relevant Housing Cost, Tenant Protection, Land Use, and Environmental Risks
The AFH evaluation of displacement risk consists of the identification of census tracts which qualify as “sensitive communities” that may be vulnerable to displacement as a result of rising housing costs and market-based displacement pressures based on demographic, tenure, rent burden, and rent change criteria developed by The Urban Displacement Project of UC Berkeley and the University of Toronto. Figure 1E-3.31, Communities Sensitive to Displacement in Fresno, provides useful information indicating that large swaths of the City, including most South Fresno and Central Fresno neighborhoods, as well as the Blackstone Avenue Corridor are vulnerable to displacement, the AFH’s displacement risk analysis falls short by failing to consider other relevant information relating to existing and potential housing cost pressures confronting low-income residents, residents of color, and other protected classes, as well as significant displacement risks associated with tenant protection limitations, City land use policies and practices, environmental hazards, and climate change. A complete displacement risk analysis must consider these and other relevant factors. See AFFH Guidance, pp. 40-43.

1. Displacements Risks Associated with Housing Cost Pressures As mentioned above, the AFH’s identification of sensitive communities using The Urban Displacement Project’s criteria provides a helpful high-level view of the displacement pressures impacting most of the City of Fresno, and almost all South Fresno and Central Fresno neighborhoods. That mapping alone however is not sufficient to accurately describe displacement risks impacting residents associated with housing cost pressures. 2210 San Joaquin Street, Fresno, California 93721
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First, the criteria used in the analysis rely on data from 2017 and earlier, including data relating to the change in rent between 2012 and 2017. This time period does not capture the sharp and sustained escalation in housing costs (both rental and ownership) that occurred during the COVID-19 pandemic between 2019 and 2022. 19 Between 2017 and 2021, Fresno experienced the greatest rent increases of all large U.S. cities, with rental prices increasing nearly 39% during that time. 20 Pandemic-era and ongoing housing price increases disproportionately impact the housing stability of renters, people of color, and other populations that have less disposable income and assets on average and are impacted by discrimina and sustained nature of the housing cost increases which have occurred in Fresno since 2017, the AFH’s displacement risk analysis must be supplemented with and revised based on more recent data.

Second, while the AFH’s displacement risk section provides a snapshot of neighborhoods vulnerable to increased housing costs that occurred between 2012 and 2017, the section does not actually discuss housing cost trends over time or analyze the factors driving increased housing costs across the City and certain neighborhoods. The use of census tract level data alone to determine whether an area qualifies as a “sensitive community” or not, without further discussion, also washes out unique vulnerabilities experienced by particular neighborhoods which comprise only a portion of a census tract. The City must supplement the displacement risk section to include this additional information and analysis, using available data and local knowledge, in order to meaningfully identify displacement risks associated with housing cost pressures and on particular neighborhoods and protected classes.

Several factors are likely or definitely associated with rising housing costs in Fresno which the AFH does not but must identify and evaluate for their impact on displacement risk.

These include but are not limited to the following:
● The expiration of affordability covenants attached to Low-Income Housing Tax Credit financed properties during the Planning Period. According to the Draft Housing Element’s At Risk Analysis, three properties consisting of 115 affordable units in the next four to eight years. The expiration of the affordability covenants on these properties creates a direct displacement risk to residents who are unable to pay market-rate rents.
20 Los Angeles Times, The Nation’s Hottest Housing Market? Surprise – it’s Fresno, Mar. 31, 2021, available at https://www.latimes.com/homeless-housing/story/2021-03-31/fresno-rent-spike-taps-into-california-covid-housing-t rends
19 CalMatters, Real estate prices soar during the pandemic, climbing 25% in parts of California, Dec. 5, 2020, available at https://calmatters.org/california-divide/2020/12/real-estate-climb-pandemic/ 2210 San Joaquin Street, Fresno, California 93721
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● Major federal, state, and local investments in public works infrastructure projects in South Fresno neighborhoods, including a $250 million phased budget commitment for downtown revitalization in the 2023/2024 California State Budget 21 ; the June 2023 Federal Railroad Administration and State High Speed Rail Authority $20 million award for the Fresno High-Speed Rail Station Historic Depot Renovation and Plaza Activation Project; and an $80 million July 2023 award from the State’s Transit and Intercity Rail Program 22 for grade separation and intersection improvements in Central Fresno at McKinley Avenue and Blackstone Avenue. None of these historic awards have requirements attached to them to reduce the risk of displacement as a result of rising rents associated with neighborhood improvements.
● The development of the California High Speed Rail project, with a depot in Fresno, which the draft Housing Element recognizes is expected to increase housing demand in Fresno by enabling commuting between Fresno, Coastal California, and/or Sacramento. Draft Housing Element, p. 3-79. The analysis should also consider the impact of speculation associated with HSR on housing availability, prices, and displacement risk.
● The conversion of housing units to short-term rentals and their impact on housing cost pressures and displacement risk. The Draft Housing Element indicates that 7% of vacant units in the city are seasonal, short-term rentals, or “other” housing accommodations, but does not state what percentage of total units are seasonal housing or short-term rentals. The Draft states that stakeholders with Llaves De Tu Casa (an initiative involving real estate professionals, banks, the City of Fresno, and affordable housing developers) expressed concern about investors displacing community members to establish short-term rentals. Draft Housing Element, p. 1E-6-15. According to a recent news story, 811 homes were available as short-term rentals in Fresno and Clovis in June 2023, which represents a 27% increase in available rentals since 2020 and almost twice the number of homes listed for sale at that time. 23
23 GVWire, Is an Airbnb Crisis Looming in Fresno as Demand Plummets?, June 29, 2023, available at https://gvwire.com/2023/06/29/is-an-airbnb-crisis-looming-in-fresno-as-demand-plummets/ 22 See Fresno Bee, State will help Fresno rebuild a major railroad crossing. Where is it, and what will it cost?, Jul. 6, 2023, available at https://www.fresnobee.com/news/local/article277074553.html 21 YourCentralValley, City of Fresno announced $250 million for downtown, June 28, 2023, available at https://www.yourcentralvalley.com/news/local-news/city-of-fresno-announces-250-million-for-downtown/ 2210 San Joaquin Street, Fresno, California 93721
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The AFH’s discussion of City “Displacement Avoidance Efforts” does not remedy the need for a complete analysis addressing the displacement risk factors above, including relevant City policies and practices, and the adoption of meaningful actions to address those risks. That section describes certain planning efforts the City undertook to evaluate displacement risks from rising housing prices and consider, but it does not actually provide any information about the findings of that policy recommendations and the policies that the City did or did not adopt.

Given the significant stakeholder engagement conducted for the development of the “Here to Stay Report,” the AFH should incorporate and consider relevant information and policy recommendations contained in that report.

2. Tenant Protection, Land Use, Environmental, and Climate-Related Displacement Risks Not Considered in the AFH Displacement Risk Analysis
A complete analysis of displacement risks considers not only displacement risks associated with housing cost pressures, but also other factors which result in housing instability, including factors relating to the adequacy of tenant protections, disinvestment, local land use policies and practices, environmental hazards, and risks associated with natural disasters and climate change.

The Draft Housing Element considers none of these risk categories, yet based on our direct work with tenants and low-income residents and residents of color, they represent real and significant risk factors for Fresno residents.

First, the Displacement Risk section does not address the adequacy of policies and resources to protect tenants from displacement as a result of eviction, harassment, and substandard housing. A coalition of residents and community-based organizations have called to the City’s attention the need for and have repeatedly asked the City to adopt additional and stronger policies and programs to protect tenants, including in particular more comprehensive and stringent rent control standards than those established by the state, just cause requirements for eviction, and right to return home for displaced residents. And while the AFH mentions the City’s code enforcement programs, it does not analyze how successful these programs have been in preventing tenant displacement and ensuring residents have a habitable space in which to live.

Draft Housing Element, p. 3-79.

Second, while the Draft Housing Element recognizes the occurrence of historic disinvestment and describes recent initiatives to increase investment in South Fresno neighborhoods, the AFH does not but should consider the extent to which public and private disinvestment and unequal investment continues to impact low-income neighborhoods, neighborhoods of color, and neighborhoods with a high proportion of tenants and how 2210 San Joaquin Street, Fresno, California 93721
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disinvestment perpetuates and/or increases displacement risk in these areas. See AFFH Guidance, p. 40. Yet even today, many South Fresno neighborhoods lack sidewalks, streetlights, park space, grocery stores and other public and private investments that contribute to neighborhood and housing-stability.

Third, the Draft Housing Element fails to consider the displacement risks associated with the City’s land use and permitting decisions which have directed and continue to allow for and promote the concentration of industrial and waste management facilities in and around neighborhoods in Jane Addams, Southwest Fresno, South Central Fresno (referred to by the Draft Housing Element as the “South Industrial Area”), and Southeast Fresno. The City’s General Plan land use map designates thousands of acres of land in these neighborhoods for industrial and business park uses, which encompass warehouse distribution facilities, agricultural processing operations (e.g., slaughterhouses, meat rendering facilities), chemical storage, landfills, waste transfer stations, biomass facilities, and more. Draft Housing Element, p. 1E-3-77. These designations are applied to land adjacent to land designated for and/or developed with residential neighborhoods as well land currently developed with housing. Several General Plan policies direct the City to expedite development on sites designated for industrial land uses by streamlining permitting and making sites “shovel ready” for new development through the installation of infrastructure and connection to services. City of Fresno General Plan, ED-1-d, ED-1-e, ED-1-j. The General Plan therefore envisions and plans for the conversion of existing housing and neighborhoods to industry and the continued proliferation of industrial land uses surrounding housing and other sensitive uses, both within existing City limits and within the City’s Sphere of Influence.
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City of Fresno Official General Plan Land Use and Circulation Map (Excerpt) 24 24 Portion of City of Fresno Official General Plan Land Use and Circulation Map, available at https://www.fresno.gov/wp-content/uploads/2023/03/Official-General-Plan-Land-Use_20220411-1.pdf 2210 San Joaquin Street, Fresno, California 93721
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Google Earth Image Depicting S Rose Ave. & E. Kaviland Ave Neighborhood, Zoned Industrial on General Plan Land Use Map, and Adjacent West Fresno (captured 08/16/2023)
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Google Earth Image of Unincorporated Daleville Neighborhood, Zoned Industrial on the General Plan Land Use Map, & Orange Center Elementary School 2210 San Joaquin Street, Fresno, California 93721
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San Joaquin Estates Mobile Home Park (“MHP”), Villa Fresno MHP, and Fresno MHP, Adjacent to and/or Surrounded by Industrial Zoning on the General Plan Land Use Map (captured 08/16/2023)
These new warehouse facilities, in combination with existing industrial facilities clustered in South Fresno neighborhoods, have severe negative and destabilizing impacts on nearby housing. Warehouse distribution facilities, such as the Amazon and Ulta Beauty warehouses in South Central Fresno, attract thousands of truck trips that travel on roads shared with homes, schools, and parks every day. This truck traffic creates toxic diesel air emissions, dust, vibration, noise, and light glare which negatively impacts residents in their homes, including their health and well-being, the longevity and potential future occupancy of their housing. The construction and operation of facilities themselves often creates excessive dust, noise, light glare, heat, odors, and other effects which have similar impacts on residents and housing quality and stability. We have attached to this comment letter a declaration from a South Central Fresno resident describing impacts she has experienced due to the proliferation of 2210 San Joaquin Street, Fresno, California 93721
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industrial facilities in her neighborhood. Attachment A, Declaration of Katie Taylor. 25 The City must revise the AFH’s Displacement Risk analysis to include a full evaluation of the impacts of its policies and practices relating to industrial development on displacement risks, including based on protected class status and income and reflecting the local knowledge of residents impacted by this issue, and incorporate meaningful actions to address those risks.

Fourth, the AFH’s Displacement Risk section does not and should be revised to consider displacement risks associated with environmental hazards, environmental disasters, and climate change, pursuant to HCD’s AFFH Guidance. AFFH Guidance, p. 42. For instance, South Fresno neighborhoods have been impacted by a series of fires at warehouse, recycling, and other industrial facilities that have occurred during the increasing number of high and extreme-heat days over the past five years. 26 Potentially toxic smoke from these fires has at times densely concentrated in South Fresno neighborhoods, which can make breathing difficult and unsafe for residents even within their homes with windows closed. In addition, residents who live in neighborhoods with incomplete sidewalks, stormwater drainage and other infrastructure and in housing without adequate cooling are at greater risk of displacement than other residents from climate-related weather events, including extreme heat and flooding. In Fresno, which recorded temperatures of 100 degrees Fahrenheit or higher on 23 days and a high temperature of 109 degrees in July 2023, extreme heat poses a serious threat of displacement for residents who lack adequate cooling in and/or cannot afford the cost of cooling their homes.

The City must revise the AFH to include a complete and accurate Displacement Risk analysis as described above and modify other sections of the Housing Element, including the AFHs contributing factors and meaningful actions to overcome disparities relating to access to a healthy environment associated with these land use patterns.

VI. The AFH Fails to Consider Significant Disparities in Access to Opportunity to Multi-Modal Transportation Options, a Healthy Environment, and Quality Education
26 See for example, ABC30, Crews Battling Large Fire at Southwest Fresno Recycling Center, June 18, 2021, available at https://abc30.com/fresno-fire-recycling-center-recylcing-timely/10807838/ ; KSEE24, Massive fire burns industrial building in Fresno. What made the battle difficult for firefighters, June 26, 2021, available at https://www.yourcentralvalley.com/news/local-news/massive-fire-breaks-out-at-warehouse-near-downtown-fresno/ ; ABC30, Flames break out at warehouse in Southeast Fresno with homes and businesses nearby,” Apr. 3, 2023, available at https://abc30.com/warehouse-fire-southeast-fresno-east-and-florence-homeless-activity/13077246/ 25 While the resident, Ms. Katie Taylor lives immediately outside of City of Fresno city limits, she resides within the City’s Sphere of Influence and her experiences of the impacts of industrial development mirror those of many South Fresno residents who reside within the City of Fresno.
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The AFH must include an analysis of disparities in access to opportunity. § 65583(c)(10)(A)(ii). Access to opportunity broadly encompasses the place-based characteristics which are linked to critical life outcomes, including “education, employment, economic development, safe and decent housing, low rates of violent crime, transportation, recreation, food, and a healthy environment (air, water, safety from environmental hazards, social services, and cultural institutions). AFFH Guidance, p. 34. The AFH fails to consider disparities relating to several key components of access to opportunity, including in particular disparities in access to multi-modal transportation opportunities, a healthy environment, and neighborhood investments – issues which residents and CBOs have long raised with the City.

A. Disparities in Access to Multi-Modal Transportation Opportunities An analysis of access to transportation opportunities must, at minimum, compare concentrations of protected groups with access to transportation options; assess any disproportionate transportation needs for members of protected classes; and analyze combined housing and transportation cost impacts on protected groups. Id. at p. 35. Transportation options include personal vehicles and public transportation, as well as options for pedestrians and bicyclists and other forms of group or shared transportation. See Id. at 48, 69, 73.

The AFH’s Transit Mobility analysis, as indicated by its title, focuses exclusively on the availability of public transit, including the FAX bus system and Handy Ride, through a brief discussion of available routes and programs and policies in place to reduce fares for certain populations. This analysis fails to compare access to transportation opportunities based on protected characteristics; assess any disproportionate transportation needs for members of protected classes; provide important information about the adequacy of public transportation service in different areas of the City, protected classes, and low-income households; and entirely fails to consider access to other forms of transportation, including walking and bicycling.

The City must revise the Draft Housing Element to include and analyze this missing information. In addition to the categories identified in the paragraph above, specific issues which must be considered include but are not limited to:
● Barriers to access to public transportation based on route limitations, especially for neighborhoods located on the fringes of the City. This includes both disadvantaged neighborhoods which are more strongly reliant on public transportation, such as Jane Addams and areas of West Fresno and South Central Fresno, and high resource neighborhoods in Northeast and Northwest Fresno, which Figure 1E-3.18, Fresno Area Express (FAX) indicates have significant less route access than South Fresno. The housing element must consider how route 2210 San Joaquin Street, Fresno, California 93721
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limitations in these areas impact mobility of residents of disadvantaged communities and their access to various forms of opportunity as well mobility and housing opportunities for low-income residents in North Fresno, considering affordable housing subsidy scoring criteria which often prioritizes public transit accessibility.
● Barriers to mobility resulting from lengthy travel times for residents’ using public transportation due to bus wait times, lack of direct routes, and route limitations requiring residents to use other forms of transportation to reach their first and last stop, especially for residents in fringe neighborhoods. ● Inadequate and/or absent infrastructure to facilitate safe and efficient active transportation, including but not limited to sidewalks, curbs, stormwater drainage, streetlights, crosswalks, and protected bike lanes.
● Inadequate and/or absent protection from extreme weather, including climate-related weather events, such as extreme heat and flooding, that impact walking, biking, and public transportation use. This includes but is not limited to the availability of shade (e.g., trees, structures), shelter, sidewalks, and stormwater drainage.
● The presence of high volumes of traffic, including heavy-duty truck traffic, on roadways used by pedestrians or bicyclists, including in and near areas zoned for industrial land uses and along designated truck routes.

B. Disparities in Access to a Healthy Environment
An analysis of access to a healthy environment must describe any disparities in access to environmentally healthy neighborhoods by protected groups, consider available statewide data such as CalEnviroScreen, evaluate consistency with the environmental justice element (if relevant), and discuss policies, practices, and investments that impact access to environmentally healthy neighborhoods. AFFH Guidance, p. 35. A complete analysis should consider any impacts on access to a healthy environment associated with the zoning, siting and operation of polluting or toxic land uses in disadvantaged communities and with climate change. Id. at pp. 16, 73. A robust analysis of disparities in access to a healthy environment, informed by public input, is especially important in Fresno given the high concentration of communities in low-income South Fresno neighborhoods of color that rank among the most burdened by multiple sources of pollution in the state and the relatively low-pollution burdens on many indicators born by comparatively affluent and Whiter North Fresno neighborhoods and RCAAs.

The AFH’s Healthy Environment analysis includes data demonstrating cumulative pollution burdens impacting Fresno neighborhoods by census tract and provides some 2210 San Joaquin Street, Fresno, California 93721
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information about industrial and waste processing facilities in South Fresno. However, it fails to include any discussion of City policies and practices underlying the stark environmental health disparities between South Fresno and North Fresno neighborhoods reflected in the data or any information or analysis about what policies, practices, and investment underlie those disparities.

The analysis points to agricultural industry practices as a basis for high pollution indicator scores in Western Fresno County but does not discuss the bases for pollution disparities impacting the City of Fresno itself, including West Fresno, Jane Addams, South East Fresno neighborhoods with high cumulative pollution scores.

As discussed above, City policies and practices have intentionally concentrated polluting and noxious industrial and waste management land uses in South Fresno neighborhoods and policies and practices remain in place that all promote the exacerbation of these patterns to the detriment of housing opportunities and quality of life for South Fresno residents. These policies and practices include but are not limited to impact fees for a community benefit fund, public health impact reports, and cargo/freight prohibition and revenue tax.

C. Disparities in Access to Educational Opportunity
The AFH’s analysis of educational opportunities must include an evaluation of the presence or lack of policies, practices, and investment to promote proficient schools or that contribute to a disparity in access to opportunity,” among other factors. HCD’s AFFH Guidance, p. 35. Disparities in access to transportation opportunities and environmental health, including those discussed above, significantly impact access to educational opportunity. For instance, a lack of or incomplete sidewalks, stormwater drainage, and streetlights in R/ECAPs; inefficient public transportation options; and the use of local roads by heavy-duty truck traffic may prevent students from traveling to and from school safely and on time, which may in turn have a series of impacts on students’ access to educational opportunity. Likewise, the presence of heavy industrial facilities near and surrounding schools and ongoing construction for the development of new warehouse distribution centers may disrupt learning by exposing students to air, noise and light pollution and increasing temperatures and thereby also undermining opportunities for outdoor recreation during school hours. The City should also consider how policies, practices, and investments or disinvestments relating to access to green space, tree canopy, and climate resiliency (including adequate cooling and wildfire smoke protection) impact educational opportunities at schools, especially in low-income neighborhoods. The City must revise its analysis of educational opportunities to address these and other issues not addressed in the Draft Element and revise and add to its actions accordingly.

VII. Incomplete Analysis of Housing Element Sites’ Compliance with AFFH Duty 2210 San Joaquin Street, Fresno, California 93721
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Housing Element Law requires that jurisdictions’ sites inventory “identify sites throughout the community” consistent with its duty to AFFH. § 65583.2; 8899.50; HCD AFFH Guidance, p. 45. The AFH must evaluate sites “relative to the full scope of the assessment of fair housing” and provide detailed instructions describing the required components of this evaluation.

AFFH Guidance, p. 45.

Here, the AFH fails to evaluate important components of whether the distribution of sites in the inventory AFFH and to summarize conclusions and identify specific programs to address fair housing issues associated with the locations of those sites. Deficiencies of the evaluation include but are not limited to the following:
● The AFH’s analysis of the sites inventory’s impact on segregation and integration trends, like other sections of the AFH, only briefly considers impacts on the distribution of Hispanic/Latino households and does not consider at all the impact on relative integration and segregation of other races. Critically, it fails to acknowledge how the lack of lower-income sites identified in high-resource areas, including for example Northeast Fresno, will perpetuate patterns of RCAAs and R/ECAPs. See AFFH Guidance, p. 45. ● The AFH lacks analysis of the impact of its sites locations on access to specific forms of access to opportunity and therefore fails to identify any programs to address fair housing barriers to which its site selection gives rise. The sites inventory includes a large share of sites in low-income neighborhoods of color impacted by poor environmental health indicators, industrial zoning and concentrations of industrial and waste management facilities. The inventory also includes sites located near State Routes 99, 41, and 180 as well as many sites on Blackstone Avenue, a heavily trafficked thoroughfare. The City must analyze these and other impacts on access to a healthy environment implicated in its choice of sites. In addition, the AFH lacks analysis of how absent or incomplete infrastructure, services, and amenities impact access to opportunity on sites included in the inventory and fails to identify programs to address these barriers. The Draft Element includes a significant share of sites in areas West of State Route 99 which are not yet developed and which lack basic infrastructure, services, and amenities, such as sidewalks, streetlights, public transportation, park space, and grocery stores as well as City water and sewer connections. Many of the lower-income sites identified in low-income South Fresno neighborhoods also experience disparities in access to critical infrastructure and services which must be considered in an analysis.
● Only 23% of sites included in the inventory to meet the lower-income RHNA are in high and highest resource areas, which the AFH states is due to the predominance of single-family zoning north of Shaw Avenue. 1E-3-109. “Where the analysis of the 2210 San Joaquin Street, Fresno, California 93721
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inventory indicates that the community has insufficient sites appropriately zoned and located to accommodate its lower-income RHNA in a manner that affirmatively further fair housing, the housing element must include a program to address this inconsistency, such as making additional sites available to accommodate its lower-income RHNA in a manner that affirmatively further fair housing.” AFFH Guidance, p. 45. Despite its recognition of the limited number of lower-income inventory sites in high resource areas, the AFH fails to describe a program included in the Draft Element to adequately address this fair housing issue. As further discussed in this letter below, while the AFH points to Program 2 as the Draft Element’s action to address this fair housing issue, the program fails to ensure that it will actually add sites to the inventory to meet the lower-income RHNA in high-resource areas or that it will facilitate development of lower-income housing in high-resource areas at all. The program commits only to “present potential sites or rezoning options for land in high resource areas for Council consideration for higher density development.” p. 1E-18. While the time frame section indicates that City will rezone sites in high resource areas by 2027, the language in the body of the program does not make commit the City to actually rezoning sites or to include additional sites located in high-resource areas to the housing element and therefore renders the commitment that the Program is making ambiguous. The Program also makes no commitment to ensure that sites that may or may not be rezoned or impacted by this Program are “suitable” for development pursuant to the Housing Element Law’s standards, including that increased capacity is created on vacant and/or underutilized sites. Further, the City provides no analysis justifying its selection of 750 units of additional capacity as its target or if that quantity is sufficient; if changes to permitting and zoning standards of sites located in the Office District will create sites near amenities and resources and with relatively low environmental burdens within high-resource census tracts; why rezoning of sites within low-density, higher income neighborhoods which are still under development is not proposed and that impact of the failure to include such sites on addressing patterns of segregation and exclusion. The Program also fails to address barriers to housing opportunity for lower-income residents who reside in housing developed in high resource areas, including inadequate public transportation options, affordable fresh food, and cultural and linguistic resources. ● The AFH sites inventory analysis includes no discussion of local knowledge and community input, pending development, development potential and other relevant factors which must be discussed in a complete analysis. AFFH Guidance, p. 45-46. 2210 San Joaquin Street, Fresno, California 93721
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The City must address these deficiencies in the AFH’s sites inventory analysis and include additional meaningful actions, with deadlines and clear outcomes, to overcome the fair housing issues associated with the Draft Element’s inventory.

VIII. Failure to Fully Analyze Contributing Factors and Lack of Meaningful Actions to Affirmatively Further Fair Housing Render the Draft Housing Element Noncompliant.

The City has failed to complete an adequate analysis of factors that have contributed to patterns of segregation and as discussed above the program actions included in the draft housing element do not and will not effectively AFFH as required by law. Unless and until the City fully analyzes factors that have contributed to patterns of segregation, identifies which factors it will address along with the programs and policies it will rely on to do so and metrics that demonstrate success, the housing Element will be out of compliance with state mandates. (See Government Code section 65583(c)(10))
IX. Failure to Adopt Community Identified Programs That Will Result in A Beneficial Impact During the Planning Period and AFFH
Housing Element Law requires that housing elements include programs with a schedule of actions with timelines and specific commitments that will have a “beneficial impact” within the planning period to achieve the housing element’s goals and objectives. As stated in the AFFH guidance “actions implement goals and consist of concrete steps, timelines, and measurable outcomes. ” Pursuant to the requirement that housing elements AFFH, housing elements must also include actions to implement priorities and goals identified in an Assessment of Fair Housing (AFH). Those actions must be “meaningful” and go beyond combatting discrimination to “overcome patterns of segregation and foster inclusive, affordable and stable communities.” AFFH Guidance, p. 46; See Government Code §§ 65583(c)(5)&(10, 8899.50(a)&(b).

Examples of inadequate programs, and some of our recommendations to improve them, include the following:
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● Program 1 - Maintain Adequate Sites. Program 1 states that the City shall continue to maintain a current inventory of Housing Element sites to ensure that it can adequately accommodate the 2023-2031 RHNA” Given the impact of rezoning to the availability of and location of sites suitable for housing, the City should take additional steps to ensure transparency in decision-making related to proposed rezones and take diligent steps to provide notice of the proposed rezone along with an assessment of the potential impacts of the rezone on housing opportunity prior to a decision on the proposal. This includes but is not limited to public hearings and door to door canvassing to facilitate effective notice. Further, the city must conduct a racial equity analysis which would include the benefits and disadvantages of the proposed rezone and whether it would result in displacement of protected racial/ethnic groups, reduce housing opportunities for protected groups, and how it would impact patterns of segregation. Finally, the program should explicitly prohibit the rezoning of sites suitable for lower income households to industrial land use classifications which would bring industrial uses next to or near neighborhoods that include or are planned for housing affordable to lower income residents. This is critical to ensure that the City is compliant with its duty to affirmatively further fair housing.
● Program 2 - Variety of Housing Opportunities in High Resource Areas (identified in the AFH as a Meaningful Action).

There is no clear commitment to zone sites for multi-family development in areas of high opportunity or a commitment to ensure that such units are affordable to all income levels.

Furthermore, in order to expeditiously address the lack of housing opportunities accessible to lower-income residents in high resource areas, the timeline of this program should be shortened.
2210 San Joaquin Street, Fresno, California 93721
Telephone: (559) 369-2790
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production for low-income units or actions that will be taken to complete the program. To facilitate and promote the use of available incentives, the city should make a list of incentives, including density bonus incentives and impact fee waivers, available to the public through an accessible database.

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additional commitments to ensure that low-income residents, undocumented residents, residents who speak languages other than English, and residents in racially and /ethnically-concentrated areas of poverty (R/ECAPs) have the opportunity to benefit from these funds. During the 5th Cycle planning period, many residents without social security numbers or who faced language access barriers were unable to apply for the City’s homebuyer assistance program. While the City was able to assist nine families with this program, this program must incorporate mechanisms that will allow more families to apply during the next 8-year cycle by addressing barriers and pursuing state funds every year. This program has other deficiencies that must be addressed such as lack of public outreach and lack of interpretation for applicants applying by phone. Solutions include:
ensuring that low-income residents are knowledgeable about the programs, undocumented residents are able to successfully apply for this program, including closing costs as part of funding packages. In order to ensure that residents living in R/ECAPs are targeted, we recommend the City create annual reports listing how many applicants were assisted, outreach efforts made and whether they live in R/ECAPs. Due to the concerns outlined above, the program as currently implemented and drafted fails to adhere to HCD’s AFFH Guidance that “actions must be specific with timelines, discrete steps and measurable outcomes to have a ‘beneficial impact’ during the planning period.” ● Program 19 – Housing Choice Voucher Incentive Program (HCV) ( identified in the AFH as a Meaningful Action) . This action fails to include meaningful actions with specific timelines, and measurable outcomes to have a “beneficial impact” during the planning period. The program should develop and implement a proactive enforcement program housed within that legal department to ensure HCV . The City should revise this program action to include a timeline of one workshop a month (twelve workshops throughout the year) to ensure residents and landlords are able to access housing quickly and better assist residents/landlords going through any issues that prevent them from using/accepting HCV . Additionally, collaborating with and funding CBOs and fair housing organizations to provide information to voucher holders and landlords on California’s source of income discrimination prohibitions. The program should also commit the City of Fresno to finance billboard ads about protections against HCV discrimination and send informational materials to all landlords in Fresno registered in the rental registry regarding HCV . Finally, the program should be revised to include a commitment to actively pursue enforcement against discrimination against voucher-holders and supplementing vouchers with additional subsidies to support voucher use in higher-cost markets in high resource areas. Northeast Fresno has very 2210 San Joaquin Street, Fresno, California 93721
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limited HCV use, with only four census tracts north of Herndon Avenue containing any HCVs, and of those four tracts, no tract exceeds 5 percent HCV use. By revising the program to include the above recommendations would help address fair housing needs in Fresno.
● Program 21 – Housing Rehabilitation ( identified in the AFH as a Meaningful Action) . Government Code section 8899.50 requires “‘meaningful actions” well beyond combating discrimination to overcome patterns of segregation and foster inclusive communities. These actions, as a whole, must address significant disparities in housing needs and in access to opportunity.” The current program has failed to address the needs of extremely low income residents and vulnerable populations such as undocumented residents. As we continue to see the negative effects of Climate Change across the world, it is imperative that the City include weatherization such as cooling mechanisms, like heat pumps, air conditioning, insulation and other cooling assets to increase resilience to extreme heat as part of the rehabilitation program. It is a critical and urgent need given that extreme heat kills thousands per year and impacts disadvantaged communities the most. Additionally, the City must establish an acquisition and rehabilitation fund to purchase older, blighted, and/or abandoned homes/buildings. The City of Fresno can establish a revolving fund to insure that rehabilitated homes are sold back to the community at a low cost.Finally, for the program to have a beneficial impact the timeframe section should include 15 rehabilitation grants annually, and 5 distressed property grants using PLHA and CDBG funding for extremely low and low income residents.
● Program 22 – Comprehensive Code Enforcement. While we appreciate Code Enforcement’s response and the City’s diligence to keep increasing staff, there are still additional actions that should be taken to create a comprehensive code enforcement.

HCD’s AFFH Guidance recommends that “to overcome contributing factors to fair housing and affirmatively further fair housing, actions must consider a wide range of actions across all action areas. The number and scale of actions will depend on the severity of the needs but regardless of need, a cohesive and effective program will consider multiple action areas.” This program as written continues to fail to address critical housing issues since the last housing element cycle. The program should be revised to include actions around legally holding landlords accountable for retaliation, unlawful evictions, and harassment towards tenants who file code enforcement complaints such as a commitment to adopt a tenant anti-harassment ordinance. As stated, 2210 San Joaquin Street, Fresno, California 93721
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we recommend that the City adequately analyze code enforcement’s procedures and incorporate tenant feedback for a comprehensive code enforcement program. ● Program 23 - Special Needs Housing ( identified in the AFH as a Meaningful Action) .

Much of the language in this program is vague, noncommittal, and does not provide adequate actions in order to provide a beneficial outcome. This program states the City “shall advocate for provision of special needs,” “partner with and encourage local and state non profits,” and “provide/encourage.” These actions are not concrete or specific and provide no assurance of a beneficial impact on persons’ with disabilities access to housing. This should be revised to include review and enforcement of compliance with legal requirements for accessibility of multi-family and affordable housing, including in permitting processes, not just “encourage[ing]” accessibility features. Additionally, we recommend that the program add specific actions to remove barriers to housing by special needs groups such as allowing undocumented residents to apply for and receive housing assistance, vouchers and other subsidies unless otherwise required by federal law.
● Program 26 - Equitable Community Investments ( identified in the AFH as a Meaningful Action) . Program 26 states it will “seek funding,” “continue to actively seek resources,” and “continue implementing the written policies.” These commitments are vague and non-committal. There are no actions on how these will be completed and is ambiguous and as a result provides no indication that a beneficial outcome will result from the program and further fair housing. The programs continue not to commit the City to take a lead role in planning, funding, and/or constructing projects or indeed any role beyond identifying issues and needs and seeking funding on an annual basis.

Additionally, it should not rely on the General Plan’s identification of Priority Areas for Development Incentives in Chapter 12 and should instead use the Urban Displacement Project data to guide investments.
● Program 28 – Opportunity To Purchase Act (OPA) ( identified in the AFH as a Meaningful Action) . Although we appreciate the City’s action to initiate research on a local Opportunity to Purchase Act, we strongly recommend that the City implements robust outreach and engagement, in partnership with CBOs that work closely with low-income communities in racially/ethnically-concentrated. Additionally, the program states it “shall research'' and “consider establishing an OPA.” These are not commitments 2210 San Joaquin Street, Fresno, California 93721
Telephone: (559) 369-2790
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and fail to implement any specific, firm, or enforceable commitment such that no beneficial outcome of the action is indicated.
● Program 29 – Mobile Home Parks ( identified in the AFH as a Meaningful Action) .

Program 29 contains no commitments, actions, or enforceable language that will ensure a beneficial impact throughout the planning period. Additionally, this program repeats verbatim language included in Program 10A of the 2015-2023 without explaining how or why reliance on the same program action will have better results during the next planning period. With residents like Three Palms and Trails End Mobile Home Park experiencing the negative impacts of slumlords , it is crucial that the City make significant improvements to the program actions. Furthermore, the program must address the need for heat resiliency such as weatherization and insulation especially to older mobile home parks by funding a mobile home park renovation fund for all mobile homes. This fund will help low income families with issues that they need to address due to inspection violations or other habitability concerns. Additionally, this program should include a commitment to penalize and fine mobile home park owners who are not providing adequate and safe conditions for their tenants. For example, Three Palms Mobile Home Park had not had safe drinking water for quite some time and the owner was never made responsible for this clear human rights violation. Finally, consistent with the City’s responsibility to AFFH, the program should support quality of life and access to opportunity improvements for all mobilehome parks in Fresno by taking meaningful actions to increase green space, transit, and resources near mobile home parks. ● Program 30 – Emergency Rental Assistance Program ( identified in the AFH as a Meaningful Action) . Although we appreciate the City adding this program, it states that the City will “seek additional funding” and fails to commit ongoing funding that can come from the Local Housing Trust Fund, the General Fund, or its own permanent funding source to ensure a beneficial impact during the planning period. Identification and commitment of a permanent local source of funding by 2024 will highlight a commitment to prevent displacement and protect tenants. ● Program 31 - Eviction Protection Program (EPP) ( identified in the AFH as a Meaningful Action) . The Eviction Protection Program is a critical anti-displacement and anti-homeless tool. However, the program's current language to “seek additional funding to support the “EPP'' is not a strong commitment and does not provide indication that a beneficial outcome will occur if funding is not replenished. We strongly recommend that 2210 San Joaquin Street, Fresno, California 93721
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the City commit to staffing 5 full-time staff for screening so tenants are able to receive help as soon as possible. We also recommend program expansion to include:
● Wide-reaching outreach and education campaigns
● Direct legal representation and assistance for low-income tenants encountering legal issues. This includes but is not limited to being served with a notice from their landlord (e.g. 3-day notice, notice of rent increase, etc.) ● Evaluation of the Eviction Protection Program to ensure it is effective and address issues to improve the program.
● Program 33 – Homeless Assistance ( identified in the AFH as a Meaningful Action) .

Program 33 does not commit the City to any concrete action. The program states it will “identify partnership opportunities,” “leverage the homeless assistance response team” and “support the V oucher Incentive Program” none of which commit to any enforceable and actionable items. The city must commit to completing an adequate analysis of needs of unhoused City residents. This should include the completion of an AFH analysis of disproportionate needs.
● Program 34 - At-Risk Housing. Program 34 includes actions without a clear commitment to take steps that will lessen the severity or impact of the issue in any timeframe. Again, the language is non-commital, vague, and ambiguous in how the program will reach its objective. Additionally, stronger tenant protections should be included as an objective and completed no later than June 2024 for residents facing displacement and an affordable housing resource map for tenants so they have the option to relocate.
* * * * *
2210 San Joaquin Street, Fresno, California 93721
Telephone: (559) 369-2790
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Thank you for your consideration of our comments. We look forward to discussing them with you and continuing to work with the state and the City to ensure that the City adopts a Housing Element that fully complies with the law and addresses the serious housing needs and disparities that impact Fresno City residents.

Sincerely,
Valerie Feldman Karla Martinez
Staff Attorney Policy Advocate

PILP LCJA
CC: Hillary Prasad, Housing Policy Specialist, California Department of Housing and Community Development
Jose Ayala, Housing Policy Specialist, California Department of Housing and Community Development
Scott Lichtig, Deputy Attorney General, Bureau of Environmental Justice, Department of Justice
Robert Swanson, Deputy Attorney General, Bureau of Environmental Justice, Department of Justice
2210 San Joaquin Street, Fresno, California 93721
Telephone: (559) 369-2790

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Attachment A:

Resident Katie Taylor’s Declaration of Industrial Impacts 2210 San Joaquin Street, Fresno, California 93721
Telephone: (559) 369-2790

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2210 San Joaquin Street, Fresno, California 93721
Telephone: (559) 369-2790

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2210 San Joaquin Street, Fresno, California 93721
Telephone: (559) 369-2790

A Nonprofit Housing and Community Development Organization

Main Office: 8445 W. Elowin Court · P.O. Box 6520 · Visalia, CA 93290 · Phone (550)651 -1000 · Fax (559)651-3634 ___________________________________________________________________________________________ ______________________ [email protected] · www.selfhelpenterprises.org

October 20, 2023

Re: Comment Letter - 6th Cycle 2023-2031 Housing Element Update (HEU)

Dear Partner:

Self-Help Enterprises (SHE) appreciates the opportunity to comment on your 6th Cycle Housing Element Update. We believe it is essential we all work together to identify meaningful opportunities to create affordable housing opportunities in the San Joaquin valley. Our service territory includes San Joaquin, Stanislaus, Mariposa, Merced, Madera, Fresno, Tulare, Kings, and Kern counties.

Incorporated as a nonprofit in 1965, SHE has built, acquired, or substantially rehabilitated nearly 16,000 units of home ownership and rental housing exclusively for low-income households in this footprint. Our general comments are outlined below:

1. Affirmatively Furthering Fair Housing: It is imperative that cities and counties include as many high or highest resource sites as possible in their Housing Element site inventory. The ratio of these sites to other lower resource sites should be 1:1. The City/County should overlay the high opportunity zones on the housing inventory map to determine sufficient high opportunity sites are included and/or identify additional high opportunity sites to be included in the site inventory. This should be done in accordance with the 2023 California Tax Credit Allocation Committee and the Department of Housing and Community Development Opportunity Mapping Methodology to promote access to opportunities.

2. Surplus sites: We encourage City/County partners to adopt a program to review all surplus property within one year of adoption of the Housing Element and make those sites available for the development of affordable housing. There are provisions in the Surplus Land Act (SLA) which allow for an expedited process for sites that qualify as “exempt surplus land” which is land determined by a local agency and verified by HCD and allows for streamlining the process for disposing of land for affordable housing. There are currently scoring incentives for funding affordable housing on surplus sites and it is imperative these sites be identified quickly and made available for the development of affordable housing.

3. Entitlement Processes: Increasingly, we have found it expedient to utilize “by right” pathways to project approvals through density bonus law, SB 35 permit streamlining, and the Housing Accountability Act. Frivolous and NIMBY-driven CEQA challenges have been “discovered” in valley communities to delay and sometimes kill projects. It is imperative that cities and counties ensure their ordinances and local practices do not conflict with such streamlined processes. Requirements for Conditional Use Permits in otherwise compatible zoning is to be discouraged wherever possible.

Self-Help Enterprises Comment Letter Page 2 of 2

4. Suitable Sites: Many jurisdictions in past Housing Element cycles have come up with what may initially look like impressive inventories of available sites, when in fact most have no feasibility for development. Suitable sites must include:

a. Sewer, water, and dry utilities proximate to the site in question, without a need for upsizing or significant offsite development.

b. A significant portion of the available acreage in the adequate sites inventory (at least 50%) should have minimum parcel sizes of 2.5 to 3 acres (and larger if onsite storm drainage is required.)

c. Reasonable densities. In most valley communities’ reasonable densities are 20-50 units per acre, and projects below 50 units are generally not feasible in today’s funding environment.

d. Access to quality transit. The City/County should adopt a program to evaluate the site inventory in relation to the transit system and ensure 75% of the inventory sites available for high density multifamily development are within 0.5 miles of a transit stop.

5. Manufactured Homes
The City/County should consider adding a program to revise its zoning ordinance to add Manufactured Home on a Permanent Foundation to be allowed in all zones that allow single- family residences. The City/County should allow this in the identified zones without requiring a discretionary approval process.

6. Fee Waivers or Deferral
The City/County should consider a fee waiver program for projects that include 100% affordable housing serving households below 80% of area median oncome. If the City/County is unable to waive fees, we strongly encourage deferral for a period not to exceed 30 years with the deferral recorded as a form of deferred note and secured by the property for affordable single-family housing development and 55 years for affordable multi-family housing development. The note would be due and payable if the property were sold, refinanced, or the rent is no longer affordable (with multifamily properties), or is no longer occupied by the owner (single-family home).

Thank you for the opportunity to comment on your Housing Element. Self-Help Enterprises is available to serve as an affordable housing resource and we encourage you to reach out if you ever have questions on how to promote and support affordable housing development in your community. If you are interested in consultation, please contact me at [email protected] or at (559) 802-1653.

Sincerely,

Betsy McGovern-Garcia
Vice President

From: Susan B. <[email protected]>
Sent: Wednesday, August 16, 2023 2:13 PM
To: HousingElement <[email protected]>
Subject: Comments on Fresno City Planning

External Email: Use caution with links and attachments

To whom it may concern

I attended the meeting at Nelson Elementary with the planning group. It is clear that expanding affordable housing is and will be a pervasive issue especially in California.

As a local homeowner I object to the proposal to mix our established single family neighborhood with any version of higher density building. I am also concerned about the various financial incentives to the land owner/developer and the city; that puts their interests counter to mine as any high density housing will lower my property values.

Thank you for your consideration of my concerns.

Best - Susan Barrows

To Whom it may Concern,

This housing plan is so flawed it is hard to know where to begin to critique it first. I suppose a good start is the attempt to hide the plan from the public by holding the public comment meeting during the month of August, a month when many of the potential citizens at risk from this plan would be on vacation and otherwise unavailable for comment.

The basic premise of the plan is that it is only "equitable" for the majority of the rezoning for low income housing to occur in "high resource" areas, which is another way of stating high income neighborhoods. This is egregiously unfair to current homeowners in these neighborhoods, who chose to buy their homes when existing zoning laws stipulated that these neighborhoods were ONLY for single family homes of a specified lot size. If the rules of the game are to be changed, it is only fair that commingling of low and high income housing only occur in new areas of property development, where potential home owners know from the beginning that they are buying into a mixed ownership neighborhood. Purchasing a home is one of the largest investments most people make during their lifetime. Allowing low income housing in high income neighborhoods will destroy the property values in those areas where people have chosen to invest their life savings in their homes. Not only is this manifestly unfair, it represents an untested socialist belief that "seeding" these neighborhoods with the poor will somehow improve their lot in life. What it will achieve instead is the degradation of once stable communities and an erosion of the property values of these communities.

I strenuously object to almost all elements of this plan and would urge that more meetings, well announced to the public in advance, be conducted to review any potential plans before their implementation. Furthermore, in the interest of transparency, all financial incentives for developers, current property owners, and municipalities need to be explicitly delineated for the public to understand potential conflicts of interest.

Sincerely yours,
Stephen P. Yeagle
7525 N. Teilman Ave.

Fresno, CA 93711

From: Michael O'Banion <[email protected]>
Sent: Wednesday, August 16, 2023 7:29 PM
To: HousingElement <[email protected]>
Subject: Fresno Multi-Jurisdictional Housing Element

External Email: Use caution with links and attachments

Hello,

I am a long time resident of northwest Fresno at address:

Michael Scott O'Banion
1589 W. Moraga Rd.

Fresno, CA 93711

I am concerned about the Fresno Multi-Jurisdictional Housing Element program disrupting the neighborhood that I have called home for years. When my neighborhood was developed, it was zoned for single family dwellings and not multi-family residences and whatnot. We feel this program is unfair to the long-time property owners in this area who purchased and built homes with the understanding the single family zoning laws would be upheld and honored - not have the rules changed at a later date.

Thanks,

Mike O'Banion

City of Fresno of the Fresno Multi-Jurisdictional 2023-2031 Housing Element (“City of Fresno Draft Housing Element” or “Draft Element”).

Michelle Zumwalt

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Because both single-family and multi-family development is permitted in most residential zones, it puts multi-family developers in competition with single family developers for the same sites.

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RM-MH, RM-2, and downtown while removing conditional use permit requirements from RM-2, RM-3, NMX, CMX, and RMX.

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15-2729), if it exceeds the building code requirement is a likely constraint on the development of shelters because of the additional cost it adds to this type of development.

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million in water and wastewater upgrades to support planned housing development. 15 The Draft should analyze the cost of these needed improvements as a possible constraint on development.

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The Number of sites needed to accommodate the RHNA should reflect the removal of the above-described projects.

B. Capacity calculation
If a site does not have a required minimum density then the City must analyze the development capacity based on the patterns of typical development patterns in the same zone.

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Assessment of Fair Housing in order to do so presents the City with a crucial new opportunity to address the intergenerational disparities and barriers to opportunity that persist in Fresno.

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Several factors are likely or definitely associated with rising housing costs in Fresno which the AFH does not but must identify and evaluate for their impact on displacement risk.

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Draft Housing Element, p. 3-79.

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VII. Incomplete Analysis of Housing Element Sites’ Compliance with AFFH Duty 2210 San Joaquin Street, Fresno, California 93721
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AFFH Guidance, p. 45.

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VIII. Failure to Fully Analyze Contributing Factors and Lack of Meaningful Actions to Affirmatively Further Fair Housing Render the Draft Housing Element Noncompliant.

Examples of inadequate programs, and some of our recommendations to improve them, include the following:
2210 San Joaquin Street, Fresno, California 93721
Telephone: (559) 369-2790
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There is no clear commitment to zone sites for multi-family development in areas of high opportunity or a commitment to ensure that such units are affordable to all income levels.

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HCD’s AFFH Guidance recommends that “to overcome contributing factors to fair housing and affirmatively further fair housing, actions must consider a wide range of actions across all action areas. The number and scale of actions will depend on the severity of the needs but regardless of need, a cohesive and effective program will consider multiple action areas.” This program as written continues to fail to address critical housing issues since the last housing element cycle. The program should be revised to include actions around legally holding landlords accountable for retaliation, unlawful evictions, and harassment towards tenants who file code enforcement complaints such as a commitment to adopt a tenant anti-harassment ordinance. As stated, 2210 San Joaquin Street, Fresno, California 93721
Telephone: (559) 369-2790
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Additionally, it should not rely on the General Plan’s identification of Priority Areas for Development Incentives in Chapter 12 and should instead use the Urban Displacement Project data to guide investments.
● Program 28 – Opportunity To Purchase Act (OPA) ( identified in the AFH as a Meaningful Action) . Although we appreciate the City’s action to initiate research on a local Opportunity to Purchase Act, we strongly recommend that the City implements robust outreach and engagement, in partnership with CBOs that work closely with low-income communities in racially/ethnically-concentrated. Additionally, the program states it “shall research'' and “consider establishing an OPA.” These are not commitments 2210 San Joaquin Street, Fresno, California 93721
Telephone: (559) 369-2790
Michelle Zumwalt

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Sincerely,
Valerie Feldman Karla Martinez
Staff Attorney Policy Advocate

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Attachment A:

Resident Katie Taylor’s Declaration of Industrial Impacts 2210 San Joaquin Street, Fresno, California 93721
Telephone: (559) 369-2790

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2210 San Joaquin Street, Fresno, California 93721
Telephone: (559) 369-2790

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2210 San Joaquin Street, Fresno, California 93721
Telephone: (559) 369-2790

There is no clear commitment to zone sites for multi-family development in areas of high opportunity or a commitment to ensure that such units are affordable to all income levels.

Furthermore, in order to expeditiously address the lack of housing opportunities accessible to lower-income residents in high resource areas, the timeline of this program should be shortened.

specific commitments to take any action on how this objective will be reached.

ensure availability of sites for lower income households in high resource areas, as outlined above.

C. Urban Greening is used as buffer zones when residential is placed or already placed near existing polluting land uses to mitigate health impacts.

planned for housing affordable to lower income residents. This is critical to ensure that the City is compliant with its duty to affirmatively further fair housing.

DATE: August 16, 2023

TO: Michelle Zumwalt, Sophia Pagoulatos- City of Fresno

FROM: Scott Miller, President/ CEO

RE: Multi-Jurisdictional Housing Element (2023 – 2031) Appendix 1-E Fresno

On behalf of our board and membership, sincere thanks for the opportunity to provide feedback on this important document. Our chamber recognizes the importance of fostering a balanced and sustainable housing landscape that not only supports the growing needs of our community but also respects the rights and interests of property owners. We appreciate the efforts made to address housing challenges within the county, and we strongly support the administration’s One Fresno Housing Plan in general. Simply put, we believe all of us in Central California should do what we can to aggressively increase the supply of housing and remove the obstacles to getting it done quickly and affordably.

With that in mind, we will continue to focus on the following:

1. Transparent, market driven solutions with measurable outcomes: We commend the plan for creating new expedited permissions for ADUs, encouraging creative financing strategies and meaningful expansion of public- private partnerships. By implementing measures that encourage affordable housing without burdening developers or property owners, we can stimulate growth while ensuring housing remains within reach for residents of various economic backgrounds. We hope to see even more incentives such as density bonuses and increases in tax relief for favorable projects moving forward.

2. Reduce impediments: We applaud the steps taken by programs 5 and 20 in the draft plan and encourage more.

To foster a thriving housing ecosystem, we will always advocate locally and at the State level for streamlined regulatory processes that expedite development without compromising safety and quality. We’d like to see the plan go further to create regulatory exemptions for the development of affordable housing.

3. Respecting Property Owner Rights: As a matter of principle, we generally oppose rezoning of private property without the consent of the property owner. We ask that language be included in Program 1 (and other sections as appropriate) specifically discouraging forced rezoning except as a last resort in implementation of the RHNA.

4. Reconsideration of the Opportunity to Purchase Act: We think this program (28) could have potential pitfalls.

While we’d encourage local nonprofit organizations to own and develop housing in partnership with the City, we recommend removal (or clarification) of the language that implies possible intervention in private sales to create a de facto first right of refusal scenario.

Since 1885, our Chamber has been committed to the idea that collaboration and creativity are keys to a prosperous Fresno County. We are eager to actively engage in discussions and offer our insights to ensure that the final Housing Element reflects the best interests of our diverse community. As always, we’re grateful for the opportunity to provide feedback and appreciate the positive working relationship.

Scott Miller

August 16th, 2023

Michelle Zumwalt
Planning and Development Department, City of Fresno,
2600 Fresno Street, Room 3065, Fresno, CA 93721

On behalf of the California Apartment Association (CAA), I extend CAA’s support for the Fresno County Multi-Jurisdictional Housing Element Update as currently written. The Housing Element update’s core goals and proposed policies reflect the importance and urgency of developing housing across Fresno County that is affordable and available to families of all income levels. CAA looks forward to working with all jurisdictions in successfully implementing this plan’s goals.

CAA participated in many of the workshops during the public outreach period and appreciates that many of the goals and policies referenced in the latest Housing Element draft reflect the input of the community and underscore the importance of building the homes our community needs.

The first goal, with good reason, is new housing development. All Fresno County jurisdictions need to significantly increase housing units over the next eight years, and this is especially true in the extremely low, very low, and low economic segments. (Policy

1.2) This cannot be achieved without the rapid implementation of Policy 1.4, which addresses minimizing unnecessary development costs which add to the costs of housing production. Additionally, incentivizing infill housing development, along with promoting higher-density housing, mixed use zoning, and TOD development will significantly add to housing supply while reducing VMT and aligning with the goals set forth in AB 32.

Goal 2 relates specifically to affordable housing, and we believe all aspects should be implemented as soon as practicable. CAA is happy to work with the county and cities in sharing best practices from around the state to ensure the policy goals are adopted quickly and as seamlessly as possible. The need for these initiatives is particularly crucial in Fresno County, which has a significant number of economically-challenged households as discussed in the demographic section of the Housing Element Update. CAA is currently working with Fresno Housing to host a series of webinars regarding accepting Housing Choice Vouchers (Policy 2.2) as we have done in many other cities and counties throughout California. Our experience has been that once rental housing providers understand the program, and the benefits of accepting Housing Choice Vouchers, HCV reach is significantly expanded.

Goal 3, Improving and maintaining the quality of housing and residential neighborhoods is another area of emphasis for CAA. (Policies 3.3 and 3.4) Our organization was a key stakeholder in the developing and implementing the Anti-Slum Enforcement Team (ASET) and the Rental Housing Improvement Act (RHIA). CAA continues to work with the City of Fresno through the Neighborhood Revitalization Team and the School Area Team to ensure all rental housing providers, CAA members and non-members alike, abide by and embrace these programs. We welcome the opportunity to work with other jurisdictions as well.

Goal 5, Fair and Equal Housing Opportunities, reflects a core element of CAA’s mission. CAA offers meetings and webinars throughout the year, to ensure rental housing providers are educated on federal, state, and local laws and to allow our members to be reminded of these laws as well as any changes in the preceding year. CAA has worked in Fresno, and throughout the state, in conjunction with local governments educating rental housing providers on the importance of all Fair Housing laws. CAA aims to be a partner with all cities in the region to help educate housing providers and their residents on their rights and responsibilities under applicable laws.

CAA appreciates the work Fresno County, the incorporated cities of Fresno County, and the Council of Governments have done on this Housing Element update. CAA looks forward to working with all stakeholders in the passage and implementation of the Multi-Jurisdictional Housing Element as currently presented.

Sincerely,

Greg Terzakis
Senior Vice President

California Apartment Association
980 Ninth Street, Suite 1430
Sacramento, CA 95814
(800) 967-4222 • caanet.org

The California Apartment Association is the largest
statewide rental housing trade association in the country, representing over 50,000 rental housing providers offering over 1 million rental homes statewide.

August 16, 2023

Michelle Zumwalt
Planning and Development Department
City of Fresno
2600 Fresno Street, Room 3065
Fresno, CA 93721

Dear Ms. Zumwalt;
On behalf of the more than 4,500 members of the Fresno Association of REALTORS® (F.A.R), I am writing to express support for the Fresno County Multi -Jurisdictional Housing Element Update as currently written. The Update’s core goals and policies address the importance and urgency in developing and increasing housing supply in Fresno County. F.A.R looks forward to working with our coalition partners and all jurisdictions in successfully implementing this Update.

California is witnessing a historic housing shortage. While this is universally recognized, there is less agreement about how to define and measure it, or even what makes the shortage so intense. Many factors have applied acute pressure in the housing market amid the general shortage conditions. There are many consequences for those living within Fresno County and no one is likely exempt from the effects of this crisis.

F.A.R. participated in several of the workshops during the public outreach period and would like to emphasize and extend support for the following goals and policies referenced in the latest Housing Element draft.

The first goal is new housing development, and we cannot emphasize this particular goal enough. All jurisdictions within the Element need to significantly increase housing stock over the next eight years, and this is especially true in the extremely low, very low, and low economic segments. (Policy 1.2) This cannot be achieved without the rapid implementation of Policy 1.4, which addresses minimizing unnecessary development costs which adds to the costs of housing p roduction. Additionally, incentivizing infill housing development, along with promoting higher-density housing, mixed use zoning, and TOD development with significantly add to housing supply while reducing VMT and aligning with the goals set forth in AB 32.

Goal 2 specifically addresses affordable housing, and we are in support of implementing all aspects as soon as practicable. F.A.R. intends to work closely with our coalition partners, such as the California Apartment Association (CAA) to share and support best practices to ensure public policy goals are achieved as quickly as possible. We understand that the need for these initiatives is particularly crucial in Fresno County, which has a significant number of economically challenged households as indicated in the demographic section of the Housing Element Update.

Goal 3, Improving and maintaining the quality of housing and re sidential neighborhoods is another area of importance and emphasis for F.A.R. (Policies 3.3 and 3.4)

Goal 5, Fair and Equal Housing Opportunities, Real estate professionals and consumers depend on strong fair housing laws and practices for our communit ies and economy to thrive. Discrimination distorts the housing market and closes the door on the American dream of homeownership for qualified buyers. At F.A.R., we advance our commitment to fair housing through policy advocacy, innovative programming, and legal guidance. F.A.R. promotes public policy to advance broader homeownership availability, accessibility, and affordability in all communities. We prioritize efforts to narrow homeownership gaps among demographic groups and promote strong enforcement of anti-discrimination laws in the housing market. F.A.R. promotes awareness, education and understanding to advance fair housing in the industry.

F.A.R. commends the work Fresno County, the incorporated cities of Fresno County, and the Council of Governments have done on this Housing Element update. Further, we would like to thank Mayor Dyer and his One Fresno Plan for his leadership, vision, and practical strategy to address the housing crisi s we face today and, in the years to come. F.A.R. looks forward to working with all stakeholders in the passage and implementation of the Multi-Jurisdictional Housing Element as currently written.

Thank you for the opportunity to provide our feedback and we thank you for your leadership.

Sincerely,

Brian Domingos

Brian Domingos, President
Fresno Association of REALTORS®
EMAIL TO: [email protected] BY AUGUST 15TH! SUBJECT: MJHE Plan 2 and PLAN 3

The following are my reasons for opposing Plans 2 and 3:

1- Your MJHE Plan is a Plan which takes a law passed in Sacramento to address the issues of homelessness and housing shortages and arrives at “A SACRAMENTO SOLUTION”.

Homelessness & housing shortages are conditions that WE IN THIS NEIGHBORHOOD did NOT create!

2. ADU’s (Plan 2)- Most of us chose this neighborhood BECAUSE it is zoned “Single-Family Residential”. AARP cites that “ADUs change the character of a neighborhood and cause problems for a community that was NOT BUILT for higher density”. We SAVED to buy our homes in this lower density neighborhood!

3. Your “Masterpiece Plan” presents a VERY ONE-SIDED VIEW of ADUs. It emphasizes “Make an income/extra money. House extra family or caregivers.” Shame on you for not providing FULL DISCLOSURE of the downside to ADUs to any and all interested parties!

4. In reviewing professional, expert opinions, we are advised “DO NOT COUNT ON ADU INCOME TO LIVE ON… due to the frequent jurisdictional changes [for rentals] that occur''. (Think Covid- property owners were unable to evict for non-payment, unable to collect rent owed, owners are limited to a “Sacramento-fixed” percentage of raising rent depending on how many rentals they owned- just to identify a few issues.)

5. Your Plan states placing ADUs in single-family neighborhoods with higher median incomes is to “facilitate housing mobility opportunities for lower-income households…” (Pg 1E-4-17).

This is nothing more than a “Calif Social Experiment"!
Your Plan has no mention of:

6. … the costs and responsibilities involved in rental units that eat into passive rent income. Yet you highlight income...

7. … how extra POLICE or FIRE PROTECTION will be provided at a time when our Mayor and Chiefs of Police & Fire are desperate for recruits to fill CURRENT vacancies. Then there are CITY RENTAL INSPECTIONS!

8. … details like parked cars crowding our streets, about how adding mailboxes or garbage cans will be determined, the disruption to the privacy of neighbors and those in the main home w/ADU renters coming or going.

9. ... about a home that is already a rental. Can the property owner simply ADD an ADU if the current renter objects?

10. Low-Income Housing (Plan 3)- Fresno’s low-income housing is poorly kept. I OBJECT to what becomes eyesores in my neighborhood!

11. Building low-income, multi-family units in our neighborhood- in your “Infill Opportunity Zones” or ANY "rezoned" property- again brings up the issue of A LACK OF police and fire personnel.

12. In the Wall Street Journal, 8/8/23, front page HEADLINES- “Apartment Landlords Face Peril As Their Debt Costs Skyrocket”. Talk about housing that will be falling apart, will be unattended, and become OUR NEIGHBORHOOD’S PROBLEM…

13. Incorporating your Plans 2 & 3 into NEW areas of building homes- NOT IN EXISTING SINGLE- FAMILY, LOW-DENSITY NEIGHBORHOODS- is where these plans need to be enacted. Home buyers will KNOW what they're getting, they'll KNOW what the residential components will be/are, and these buyers will have 100% awareness of the decision they make to buy in such a neighborhood. It is CRUEL to inflict these misguided plans on our neighborhoods!

14. HERE’S TWO IDEAS-
A- CONTINUE the outstanding efforts to remodel and repurpose the motels and inns that have fallen into disrepair or been abandoned and use these for low-income/homeless opportunities.

B- Bring in the “NECESSARY RESOURCES” to these sites.

Thank you

Joseph Gugliemo
Rachel Gugliemo
Concerned Resident’s
From: [email protected] <[email protected]>
Sent: Friday, August 11, 2023 11:48 AM
To: HousingElement <[email protected]>
Subject: MJHE Plan 2 & 3

External Email: Use caution with links and attachments

The following are my reasons for opposing Plans 2 and 3:

1- Your MJHE Plan is a Plan which takes a law passed in Sacramento to address the issues of
homelessness and housing shortages and arrives at “A SACRAMENTO SOLUTION”.

Homelessness camps; housing shortages are conditions that WE IN THIS NEIGHBORHOOD did NOT
create!

2. ADU’s (Plan 2)- Most of us chose this neighborhood BECAUSE it is zoned “Single- Family
Residential”. AARP cites that “ADUs change the character of a neighborhood and cause problems for a community that was NOT BUILT for higher density”. We SAVED to buy our
homes in this lower density neighborhood! Nobody, gave us a handout! We created our neighborhood on our own.

3. Your “Masterpiece Plan” presents a VERY ONE-SIDED VIEW of ADUs. It emphasizes “Make an
income/extra money. House extra family or caregivers.” Shame on you for not providing FULL
DISCLOSURE of the downside to ADUs to any and all interested parties!

4. In reviewing professional, expert opinions, we are advised “DO NOT COUNT ON

ADU INCOME
TO LIVE ON… due to the frequent jurisdictional changes [for rentals] that occur. (Think Covid-
property owners were unable to evict for non-payment, unable to collect rent owed, owners
are limited to a “Sacramento-fixed” percentage of raising rent depending on how many rentals
they owned- just to identify a few issues.)

5. Your Plan states placing ADUs in single-family neighborhoods with higher median incomes is
to “facilitate housing mobility opportunities for lower-income households…” (Pg 1E-4- 17).

This is nothing more than a “Calif Social Experiment!"

Your Plan has no mention of:

6. … the costs and responsibilities involved in rental units that eat into passive rent income. Yet
you highlight income...

7. … how extra POLICE or FIRE PROTECTION will be provided at a time when our Mayor and
Chiefs of Police & Fire are desperate for recruits to fill CURRENT vacancies. Then there are CITY
RENTAL INSPECTIONS!

8. … details like parked cars crowding our streets, about how adding mailboxes or garbage
cans will be determined, the disruption to the privacy of neighbors and those in the main home
w/ADU renters coming or going.

9. ... about a home that is already a rental. Can the property owner simply ADD an ADU if the
current renter objects?

10. Low-Income Housing (Plan 3)- Fresno’s low-income housing is poorly kept. I OBJECT to what
becomes eyesores in my neighborhood! Excessive trash litter the streets, yards not kept up, etc.

11. Building low-income, multi-family units in our neighborhood- in your “Infill Opportunity
Zones” or ANY "rezoned" property- again brings up the issue of A LACK OF police and fire
personnel.

12. In the Wall Street Journal, 8/8/23, front page HEADLINES- “Apartment Landlords Face Peril
As Their Debt Costs Skyrocket”. Talk about housing that will be falling apart, will be unattended,
and become OUR NEIGHBORHOOD’S PROBLEM…

13. Incorporating your Plans 2 & 3 into NEW areas of building homes- NOT IN

EXISTING SINGLE-
FAMILY, LOW-DENSITY NEIGHBORHOODS- is where these plans need to be enacted. Home
buyers will KNOW what they're getting, they'll KNOW what the residential components will
be/are, and these buyers will have 100% awareness of the decision they make to buy in such a
neighborhood. It is CRUEL to inflict these misguided plans on our neighborhoods!

14. HERE’S TWO IDEAS-
A- CONTINUE the outstanding efforts to remodel and repurpose the motels and inns that
have fallen into disrepair or been abandoned and use these for low-income/homeless opportunities.

B- Bring in the “NECESSARY RESOURCES” to these sites.

Thank you,
Dennis Statham
559-779-4779

From: Sarah A <[email protected]>
Sent: Wednesday, August 09, 2023 11:16 AM
To: HousingElement <[email protected]>; Sophia Pagoulatos <[email protected]>; Veronica Martinez <[email protected]>; Michelle Zumwalt <[email protected]>
Cc: Sarah A <[email protected]>
Subject: Following up about Multi-Jurisdictional Housing in our Fresno 93711 bluff area

External Email: Use caution with links and attachments

To: M.Zumwalt, Room 3065, Planning & Development
Department

Dear Planning department representatives,
Thank you, thank you for all the good work you do. I know it's difficult dealing with NIMBYism and you remained perfectly calm.

Thank you for listening to my concerns.

I've copied the note I sent to our District 2 Councilman, mostly due to my lack of time to repeat it. Please consider my comments.

In addition to the comments below, I'm in support of the new and restorative planning within City limits, as opposed to urban sprawl and leapfrog development. Maybe design/infrastructure
committees exist to give Developers advice/boundaries on building attractive, green, sustainable communities that will add long-term value to our beautiful city. And wouldn't it be great to have more shady green spaces and urban farms throughout Fresno?
Please let me know if there is anyway I can help your efforts here.

Thank you in advance for all you do!

Sarah Adams
1772 W. Alluvial Avenue, Fresno, CA 93711

Dear Councilman Karbassi,
I attended the jurisdictional housing meeting last night at Nelson Elementary. The planning department staff had a challenging time giving an overview of the City's projects last night. The residents in the Bluff area seemed most concerned about the large piece of land at east end of Alluvial Ave; as well, the lot at SW corner of Van Ness and Alluvial; and in general, the trauma and de-valuation of neighborhood properties that could happen to the existing established high-end homes in our area, IF flanked by super dense apartment style housing or a high-travelled Alluvial Ave somehow connecting to Palm....

Some residents in the room also expressed concern about parking issues related to ADU additions. It seems to me ADUs might fit better on larger lots, minimum of 1/2 acre, with mandatory off- street parking planned/enforced, to avoid congestion concerns.

Also, by keeping Alluvial blocked on the East end, the high-end neighborhood would be preserved, and not opened up to through- traffic, or wandering transient folks. .......

Maybe there was some consensus last night (?) that high density, MEDIUM-INCOME housing could fit into NEW undeveloped
areas, as opposed to existing areas.

Also, it seems there was some approval of less-dense density, and housing FOR SALE instead of for RENT. If there are individual homeowners, there is shared long term interest and responsibility for the neighborhood. Other comments included the need for thoughtful open space planning, landscaping, infrastructure, pedestrian and bike pathways........

On a personal note, I walked around the large lot east of Alluvial Ave this morning--maybe 40 acres?--which is zoned for office buildings apparently. Why is this not zoned for medium-income, dense, townhouse 2-story housing with green space, paths to the ParkPlace shopping center with gym, cafes, restaurants? These businesses would be patronized by local community and there would be less turnover. As well, having access to the river on existing paths and views, is a super extension of the San Joaquin River Parkway and Conservation Trust's mission. This would allow home buying opportunities for young professionals, families, and retired; therefore, creating diversity. There is even a private pre- school in the neighborhood and Nelson elementary school not far away.

If I were looking for new community housing, more affordable, as a working person, I'd be interested in this north Fresno location! It sounds like the City doesn't need more office buildings in the area, due to plenty of existing office space....so why not use this acreage to build a wonderful dense townhouse development, and to keep existing Bluff residents to its west happy, don't connect Alluvial. It appears that it could easily be accessed off Palm.

We hope you can consider and support these ideas.

Best wishes,

Sarah J. Adams
tel. 760/937-6581

From: Mike C. <[email protected]>
Sent: Wednesday, August 09, 2023 7:54 AM
To: HousingElement <[email protected]>
Subject: #Program

External Email: Use caution with links and attachments

Program(s)are effective but there's not enough of them. and the ones that there are, are only for families.. There are single people that need just as much help as people that have families..

Wish I had a program now.
#needone
Sent from Yahoo Mail on Android

From: Lynette S. <[email protected]>
Sent: Wednesday, August 09, 2023 1:06 PM
To: HousingElement <[email protected]>
Subject: MJHA PLAN 2 and Plan 3

External Email: Use caution with links and attachments

I attended last night's meeting at Nelson Elementary. I would like to emphatically "go on the record" as being in opposition to Plan 2 (ADUs) and Plan 3 (multi-family, low income housing)!

I am a life-long Fresno County resident and have resided the past 31 years at my current address- 7264 N Brooks Ave, Fresno, 93711 (Herndon/West/Alluvial).

The following are my reasons for opposing Plans 2 and 3:
1- Your MJHE Plan- this is a Plan which takes a law passed in Sacramento to address the issues of homelessness and housing shortages and arrives at “A SACRAMENTO SOLUTION”. (Homelessness & housing shortages are conditions that WE IN THIS NEIGHBORHOOD did NOT create!)

3. Your “Masterpiece Plan” presents a VERY ONE-SIDED VIEW of ADUs. It emphasizes “Make an income/extra money. House extra family or caregivers.” Shame On You for not providing FULL DISCLOSURE of the downside to ADUs!

4. Reviewing professional, expert opinions, we are advised “DO NOT COUNT ON ADU INCOME TO LIVE ON… due to the frequent jurisdictional changes [for rentals] that occur''. (Think Covid- property owners wereunable to evict for non-payment, unable to collect rent owed, owners are limited to a “Sacramento-fixed” percentage of raising rent depending on how many rentals they owned.)

5. Your Plan states placing ADUs in single-family neighborhoods with higher median incomes is to “facilitate housing mobility opportunities for lower-income households…” (Pg 1E-4-17). This is nothing more than a “Calif Social Experiment"!
Your Plan has no mention of:

6. … the costs and responsibilities involved in rental units that eat into passive rent income. Yet you hilight income...

9. ... about a home that is already a rental. Can the property owner simply ADD an ADU if the current renter objects?

10. Low-Income Housing (Plan 3)- Fresno’s low-income housing is poorly kept. I OBJECT to what becomes eyesores in my neighborhood!

11. Building low-income, multi-family units in our neighborhood- in your “Infill Opportunity Zones” or ANY "rezoned" property- again brings up the issue of A LACK OF police and fire personnel.

12. WSJ, 8/8/23, Front Page HEADLINES- “Apartment Landlords Face Peril As Their Debt Costs Skyrocket”. Talk about housing that will be falling apart, will be unattended, and become OUR NEIGHBORHOOD’S PROBLEM…

13. Incorporating your Plans 2 & 3 into NEW areas of building homes- NOT IN EXISTING SINGLE- FAMILY, LOW DENSITY NEIGHBORHOODS- is where these plans need to be enacted. Home buyers will KNOW what they're getting, they'll KNOW what the residential components will be/are, and will have 100% awareness of the decision they make to buy in such a neighborhood. It is CRUEL to inflict these misguided plans on our neighborhoods!

14. HERE’S TWO IDEAS-
A- CONTINUE the outstanding efforts to remodel and repurpose the motels and inns that have fallen into disrepair or been abandoned as housing solutions for the low-income and homeless populations. B- Increase “NECESSARY RESOURCES” in those areas!

Thank you,
Lynette Statham, LCSW
559.284.7092

From: Valarie Armstrong <[email protected]>
Sent: Tuesday, August 08, 2023 9:59 AM
To: HousingElement <[email protected]>
Subject: Multi_Jurisdictional Housing Element Public Comment

External Email: Use caution with links and attachments

City planning and ordinances need to adopt special caveats for �ny homes. Lenders need to be encouraged to provide longer term loans.

Tiny homes ($80-160K) and RV park model homes ($59-120k) are less expensive to build and maintain and yield a reduced environmental impact.

Tiny home communi�es foster a stronger sense of community and belonging. Providing aﬀordable op�ons in a housing market that has outpaced wages.

If a commited developer could create �ny home subdivisions on smaller plots of land, the op�ons to reduce carbon footprints and s�ll maintain aﬀordable purchase prices are endless.

Thank you

Valarie Armstrong
Human Resources Director
Comprehensive Youth Services of Fresno Inc.
4545 N. West Ave.

Fresno CA 93705

(559) 229-3561 xt122 | Direct (559) 230-6322 | Fax (559) 229-3681 www.cysfresno.org | [email protected]

CONFIDENTIALITY NOTICE: This e-mail is intended only for the use of the individual or entity to which it is addressed and may contain information that is privileged, confidential and exempt from disclosure under applicable law. If you have received this communication in error, please do not distribute it.

Please notify the sender by e-mail at the address shown and delete the original message. Thank you.

From: Martha Gonzalez <[email protected]>
Sent: Tuesday, August 08, 2023 10:44 AM
To: HousingElement <[email protected]>
Subject: The City need to do more for homeless people. I had call and left several messages about a homeless couple living next to our property for over a year and nothing has been done by the City. They have 2 poor dogs tied up all day and the smell is terribl...

External Email: Use caution with links and attachments

-----Original Message-----
From: Patrick C. <[email protected]>
Sent: Tuesday, August 08, 2023 12:34 PM
To: HousingElement <[email protected]>
Subject: Public comment for housing element

External Email: Use caution with links and attachments

Cathy Caples, 7232 W Dovewood Lane. I understand that the housing element is basically a number report to the State. And agree more affordable housing in different styles is needed around the City.

However, one strategy I feel is missing in this report is the deliberate planning that’s needed to build a community with services that are needed within walking distance that would include medical, food, public transit and green space to help clean the air and provide space for play and exercise. City planners have called them catalytic corridors in meetings I’ve attended. I think there needs to be a goal to work collaboratively with parks, arts commission, public works. the Planning commission should not be allowed to make changes to a well thought out plan just because a developer asks. There needs to be a moratorium on changes.

Thank you

Sent from my iPhone

From: Vanesa Donangtavanh <[email protected]> Sent: Monday, July 31, 2023 9:11 AM
To: Betsy McGovern-Garcia <[email protected]>; Sophia Pagoulatos <[email protected]>
Cc: Michelle Zumwalt <[email protected]>; HousingElement <[email protected]>
Subject: RE: City of Fresno Housing Element Public Draft Available

External Email: Use caution with links and attachments

Good morning Sophia,

Following up on this item. Is there anything else we need to do on our end to get this issue addressed in the Housing Element?

Thanks,
Vanesa

VANESA DONANGTAVANH

PROJECT MANAGER

Self-Help Enterprises

8445 W. Elowin Court
P.O. Box 6520
Visalia, CA 93290
559-931-2479 Office

559-651-3634 Fax:

[email protected]
Http://www.selfhelpenterprises.org

From: Betsy McGovern-Garcia <[email protected]> Sent: Monday, July 17, 2023 2:10 PM
To: Sophia Pagoulatos <[email protected]>
Cc: Michelle Zumwalt <[email protected]>; HousingElement <[email protected]>; Vanesa Donangtavanh <[email protected]> Subject: RE: City of Fresno Housing Element Public Draft Available Importance: High

Sophia,

We are concerned that any housing project over 1 unit requires a discretionary approval in the City of Fresno. Would the City consider adding a program to create a process wherein any affordable housing project of 100 units or less, in a zone which allows multifamily housing, would be by-right?

This is a MAJOR barrier in Fresno.

Thanks.

Betsy

From: Sean Z. <[email protected]>
Sent: Sunday, July 30, 2023 7:19 PM
To: HousingElement <[email protected]>
Subject: Housing element public comment

External Email: Use caution with links and attachments

Housing is way too expensive in Fresno and getting worse. Specifically I think Fresno needs a lot more apartments, particularly tall apartment buildings built near transit lines. We are way too sprawled out and need to focus on building some density around the downtown core. I would really love to see Fresno use a social housing program similar to Vienna, where the city government builds and owns lots of apartment buildings, keeping rent low. I say this as a homeowner that housing prices are out of control and something needs to be done to bring it down. I would also love to see very strict rent control. In addition we need to be building way more housing for the homeless, as its both cruel and unconscionable to have so many people sleeping on the streets, and lessens everyone's enjoyment of the city.

From: Jeffrey M. <[email protected]>
Sent: Thursday, July 27, 2023 5:52 PM
To: HousingElement <[email protected]>
Subject: Please don,t meddle in things that aren't your purview. Government great at creating additional problems doing things that are free market in nature don't trust you or your motives. Stop meddling:

External Email: Use caution with links and attachments

From: Amber F. <[email protected]>
Sent: Thursday, July 27, 2023 11:31 AM
To: HousingElement <[email protected]>
Subject:

External Email: Use caution with links and attachments

What part of town are they going to be located in? How much will our taxes go up to pay for this shit? Don't we pay enough already? This state and county is sucking us dry! Soon there will be no one left working and paying taxes, all homeless and welfare, who'll pay then?

From: rudemaq <[email protected]>
Sent: Thursday, July 20, 2023 11:36 AM
To: HousingElement <[email protected]>
Subject: Rental Housing Rehad Assistance

External Email: Use caution with links and attachments

Hello,
I am a owner investor. I have a rental property that recently got inspected by the City for health and safety. The unit pass the inspection with only a couple of minor corrects.

Since this inspection was done by the City.

I was wondering if the City has any programs or know of any other agencies or programs to assist with energy window replacement for energy saving purposes? Such as a loan program or rebates?

Thank you,
Rudy Quintana

From: Kathleen O. <[email protected]>
Sent: Thursday, July 20, 2023 12:02 PM
To: HousingElement <[email protected]>
Subject: attention: M. Zumwalt, Community Discussion

External Email: Use caution with links and attachments

The city needs to take professionals who are low-income into account. Many people work for entities like Fresno Unified School District but do not make a living wage that lets them afford an apartment or a house. It is absolutely insane that we expect people to teach our children in daycares, preschools, elementary, middle, and high schools, and yet they cannot afford housing because there is no regulation. When an apartment costs nearly $2000, the monthly take-home for many of these workers, and the landlord or management company demands 2x, 3x, even 4x rent in income requirements, you are demanding that homeless teachers teach your children.

From: Glenn Miller <[email protected]>
Sent: Thursday, July 20, 2023 1:38 PM
To: Veronica Martinez <[email protected]>
Subject: Re: Multi-Jurisdictional Housing Element

External Email: Use caution with links and attachments

WE HAVE HAPPILY MOVED OUT OF THE FAST DECLINING LIVING CONDITIONS IN FRESNO AND CALIFORNIA. WE HAVE LIVED THERE 70 YEARS AND GREW SICK OF IT. SORRY BUT I SEE NO FIXING IT UNDER CURRENT POLITICAL CONDITIONS, WE ARE IN EAST TN. AND HAVE NEVER FELT SO FREE. GOOD BYE FOREVER. P.S. there 300k others who have done the same just last year.

On Thursday, July 20, 2023 at 10:06:18 AM PDT, City of Fresno <[email protected]> wrote:

From: Cheyenne J. <[email protected]>
Sent: Thursday, July 20, 2023 9:36 PM
To: Sophia Pagoulatos <[email protected]>
Cc: Cheyenne J. <[email protected]>
Subject: SW Planning Meeting Response 7-20-23

External Email: Use caution with links and attachments

Dear Sophia,

You saw how upset I got tonight. I’m not ashamed, maybe a little embarrassed I cursed & made people
uncomfortable but oh well! This needs to make people
uncomfortable!

I am with UU church of Fresno, Social Justice committee, and sub- committee IAF, Industrial Areas Foundation. We fight for people's rights and justice for all!

The city is lying through their teeth. You know that the affordable housing isn’t for us locals, it’s for all the commuters living here for cheap & working in LA, SF or Bay Area. Affordable housing means for the outsiders coming into Fresno & buying up stuff. They have no interest in Fresno. They don’t shop here or eat here. They just sleep here & occupy space! The city knows the potential here to be the next LA. They don’t care about us locals or that they are shortening front yards/backyards for stupid bike lanes & more traffic to come.

Yet you deny this. More pollution. More traffic. More noise. And not a single resident being affected is notified! The city knows & has already deemed these people to be uneducated & so you intimate folks with big words & fancy confusing sentences & spreadsheets so people won’t engage. The people will give in! And the city wins.

I sat next to three people who are poor & were waiting for their keys to get into their home tonight. Keys they were promised but nope, city had other plans! These people don’t deserve to be lied to and strung along! They were so confused by all the big talk language. It’s no wonder the city is getting away with this.

I look at ALL the pamphlets given from tonight! My god. I’m looking at all this information from tonight’s meeting and it’s BS! The lowest income to qualify for an elderly person is $43,650 & for mortgage assistance it’s $46,200. I barely make $43,680 and I have a job! Most people are on welfare, fixed incomes of SSI/SDI/Retirement/etc. or homeless. There’s no way for them to qualify for a home. I wouldn’t even qualify. Then there’s “borrow up to $100,000 and no monthly fees on the loan”, For who??? Certainly not me or those more poor. We certainly won’t qualify for that.

The City of Fresno knows what they are doing. The water issue is besides the point. This has always been an issue here in Fresno with our water as a wager to gain more power. But the point is the City of Fresno is robbing people of their homes. Their land. Their neighborhoods. Their peace of mind & living. And not telling them the truth! No notice!

My contacts tonight since we are to connect from these events are:
-Alysonn Walker/SW Rep & formed SW
-The pastor of Westside Church of God
-Tasha Jones/Talk2Tasha-Social media site 559-246-7000. Knows Alysonn really well

I wrote my input on the white boards. Doubt it’ll go anywhere but land on deaf ears.

And hope you all understand that I’m just super passionate about standing up for what’s right! I’m in this mix of people. I sit right in this with them. I’ll never have a home of my own. I’ll always be stuck in Apt living.

And it’s NOT ok! $850/month used to get someone rent on a 1-bedroom home. Now it’s $1600 a month.

Please stop this! Thank you!

Live Vertically,
Cheyenne

Sophia,

This is a MAJOR barrier in Fresno.

Thanks.

Betsy

BETSY MCGOVERN-GARCIA

VICE PRESIDENT

Self-Help Enterprises

8445 W. Elowin Court
P.O. Box 6520
Visalia, CA 93290
559-802-1653 Office

559-651-3634 Fax:

[email protected]
Http://www.selfhelpenterprises.org

Sophia,

This is a MAJOR barrier in Fresno.

Thanks.

Betsy

BETSY MCGOVERN-GARCIA

VICE PRESIDENT

Self-Help Enterprises

8445 W. Elowin Court
P.O. Box 6520
Visalia, CA 93290
559-802-1653 Office

559-651-3634 Fax:

[email protected]
Http://www.selfhelpenterprises.org

Fresno City CouncilDecember 12, 2024

Fresno City Council
December 12, 2024