We conducted two different tests, using MapCraft pro forma feasibility assessments (for more details, see approach outlined in Test 4) to estimate the market potential on the sites in the inventory. By comparing MapCraft’s market feasible unit estimates to the unit capacity claimed in the site inventory, we were able to identify sites where upzoning may yield more capacity than currently tabulated.
Test 5a – Maximum density of potential upzoned sites
As a first test, we considered the most intense housing options that could be feasibly built on each site. We first identified the array of feasible housing development prototypes on each site, which may include both high- and low-density housing options. In this case, financial feasibility was based on a development project’s prospects of paying more for the site than the current property value.
We compared the housing capacity of the densest of those feasible prototypes to the capacity claimed in the site inventory to determine if further upzoning could yield more capacity.
Across the 933 sites that we analyzed, 790 could be financially feasible for redevelopment at a capacity that exceeded the capacity proposed for the parcel in the site inventory. Of those sites, none were sites slated to be rezoned and all were sites that were not slated to be rezoned. The table and charts below show the resulting estimated units, based on the greatest density of development types that had market potential to displace the existing use, and how that estimate compares to the total claimed units in the inventory.
Table 10: Estimated Units from Max Density of Potential Upzones (Test 5a)
Number of sites where
feasible development
exceeded claimed capacity (%
of all inventoried sites in that
category)
Potential Incremental Units
Identified by Test 5a (Claimed
Units)
Site planned for rezone in site
inventory 0 (0%) 0 (0)
Site NOT planned for rezone in
site inventory 790 (85%) 17,583 (3,330)
*This test was applicable on 100% of the sites we analyzed 1807 of 1910
MAPCRAFT
MapCraftLabs.com 11
Exhibit 3: Estimated Units from Max Density of Potential Upzones (Test 5a)
Test 5b – Maximum feasibility of potential upzoning
We conducted a second test that considered the most financially feasible options. that could be built on each site. As in Test 5a, we considered the array of feasible housing development prototypes on each site. For Test 5b, we compared the housing capacity of the most feasible prototype to the capacity claimed in the site inventory to determine if further upzoning could yield more capacity. Because the most feasible prototype could be lower density than other feasible prototypes, this approach produced more conservative outcomes than Test 5a.
Accordingly, there were 781 sites that had feasible development options with capacity that exceeded what was claimed in the site inventory. Of those sites, none were sites slated to be rezoned and all were sites that were not slated to be rezoned. The table and charts below show the resulting estimated units, based on the greatest density of development types that had market potential to displace the existing use, and how that estimate compares to the total claimed units in the inventory.
Table 11: Results of Test 5b
Number of sites where
feasible development
exceeded claimed capacity (%
of all inventoried sites in that
category)
Potential Incremental Units
Identified by Test 5a (Claimed
Units)
Site planned for rezone in site
inventory 0 (0%) 0 (0)
Site NOT planned for rezone in
site inventory 781 (84%) 11,593 (3,126)
*This test was applicable on 100% of the sites we analyzed 1808 of 1910
MAPCRAFT
MapCraftLabs.com 12
Exhibit 4: Estimated Units from Max Feasibility of Potential Upzones (Test 5b)
Given these results, we believe that there is substantial capacity “left on the table” for sites currently in the site inventory - for both sites already planned to be rezoned as well as sites not expected to be rezoned. But there are opportunities to identify additional parcels where market feasible capacity exists and add those sites to the proposed site inventory.
Viable upzoning opportunities exist in many parts of the city, and we observed concentrations of sites with greater market feasible housing capacity in the Vineyard, Mariposa, Pacific-Edison, and Grandview neighborhoods. These locations may be areas where Glendale could effectively add more market-feasible sites to the inventory by rezoning these sites to allow for denser development.
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MAPCRAFT
MapCraftLabs.com 13
Exhibit 5: Map of Concentrations of Potential Upzoning Opportunities
Key Takeaways:
● Additional capacity could be achieved on the majority of sites in the inventory where market-feasible opportunities to upzone exist. Glendale could consider upzoning parcels already in the inventory to reduce any potential housing production shortfall. ● Comparing results from Test 5a to 5b, it appears that the most financially feasible development options may be less intense than other feasible development options in some cases. For example, for-sale townhomes may be more profitable than small rental apartment buildings with more housing units. For that reason, if the city decides to adjust their zoning, they may consider establishing site utilization minimums so that sites redevelop at higher intensities.
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STATE OF CALIFORNIA - BUSINESS, CONSUMER SERVICES AND HOUSING AGENCY GAVIN NEWSOM, G overnor
DEPARTMENT OF HOUSING AND COMMUNITY DEVELOPMENT
DIVISION OF HOUSING POLICY DEVELOPMENT
2020 W. El Camino Avenue, Suite 500
Sacramento, CA 95833
(916) 263-2911 / FAX (916) 263-7453
www.hcd.ca.gov
Phi
lip Lanzafame, Director
Community Development Department
City of Glendale
633 E. Broadway, Room 103
Glendale, CA 91206
D
ear Philip Lanzafame:
R
E: City of Glendale’s 6th Cycle (2021-2029) Draft Housing Element T
hank you for submitting the City of Glendale’s (City) draft housing element received for review on November 2, 2021. As the City submitted revisions late in the review period on December 27, 2021 to incorporate feedback from public comments, HCD was unable to consider these revisions in the review. Pursuant to Government Code section 65585, subdivision (b), the California Department of Housing and Community Development (HCD) is reporting the results of its review. Our review was facilitated by a conversation on December 29, 2021 with Erik Krause, Deputy Director of Community Development, and consultant Amanda Tropiano. In addition, HCD considered comments from Abundant Housing LA and YIMBY Law; Our Future LA Coalition; Karen Kwak; Abundant Housing LA; Mike Van Gorder; and Tieira pursuant to Government Code section 65585, subdivision (c).
T
he draft element addresses many statutory requirements; however, revisions will be necessary to comply with State Housing Element Law (Article 10.6 of the Gov. Code). The enclosed Appendix describes the revisions needed to comply with State Housing Element Law.
A
s a reminder, the City’s 6th cycle housing element was due October 15, 2021. As of today, the City has not completed the housing element process for the 6th cycle. The City’s 5th cycle housing element no longer satisfies statutory requirements. HCD encourages the City to revise the element as described above, adopt, and submit to HCD to regain housing element compliance.
F
or your information, pursuant to Assembly Bill 1398 (Chapter 358, Statutes of 2021), if a local government fails to adopt a compliant housing element within 120 days of the statutory deadline (October 15, 2021), then any rezoning to accommodate the regional housing needs allocation (RHNA), including for lower-income households, shall be completed no later than one year from the statutory deadline. Otherwise, the local government’s housing element will December 31, 2021
1812 of 1910
Philip Lanzafame, Director
no longer comply with St ate Housing Element Law, and HCD may revoke its finding of substantial compliance pursuant to Government Code section 65585, subdivision (i).
Pu
blic participation in the development, adoption and implementation of the housing element is essential to effective housing planning. Throughout the housing element process, the City should continue to engage the community, including organizations that represent lower- income and special needs households, by making information regularly available and considering and incorporating comments where appropriate.
Sev
eral federal, state, and regional funding programs consider housing element compliance as an eligibility or ranking criteria. For example, the CalTrans Senate Bill (SB) 1 Sustainable Communities grant; the Strategic Growth Council and HCD’s Affordable Housing and Sustainable Communities programs; and HCD’s Permanent Local Housing Allocation consider housing element compliance and/or annual reporting requirements pursuant to Government Code section 65400. With a compliant housing element, the City meets housing element requirements for these and other funding sources.
For
your information, some general plan element updates are triggered by housing element adoption. HCD reminds the City to consider timing provisions and welcomes the opportunity to provide assistance. For information, please see the Technical Advisories issued by the Governor’s Office of Planning and Research at:
http://opr.ca.gov/docs/OPR_Appendix_C_final.pdf
and
http://opr.ca.gov/docs/Final_6.26.15.pdf.
HC
D appreciates the dedication and cooperation Erik Krause, Deputy Director of Community Development, and consultant Amanda Tropiano provided during the review. We are committed to assisting the City in addressing all statutory requirements of State Housing Element Law. If you have any questions or need additional technical assistance, please contact Hillary Prasad, of our staff, at [email protected].
Si
ncerely,
Senior
Program Manager
Enc
losure
Paul McDougall
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City of Glendale’s 6th Cycle Draft Housing Element Page 1 December 31, 2021
APPENDIX
CITY OF GLENDALE
The following changes are necessary to bring the City’s housing element into compliance with Article 10.6 of the Government Code. Accompanying each recommended change, we cite the supporting section of the Government Code.
Housing element technical assistance information is available on HCD’s website at http://www.hcd.ca.gov/community-development/housing-element/housing-element-memos.shtml .
Among other resources, the housing element section contains HCD’s latest technical assistance tool, Building Blocks for Effective Housing Elements (Building Blocks), available at http://www.hcd.ca.gov/community-development/building-blocks/index.shtml and includes the Government Code addressing State Housing Element Law and other resources.
A. Review and Revision
Review the previous element to evaluate the appropriateness, effectiveness, and progress in implementation, and reflect the results of this review in the revised element. (Gov. Code, § 65588 (a) and (b).)
As part of the review of programs in the past cycle, the element must provide an evaluation of the effectiveness of goals, policies, and related actions in meeting the housing needs of special needs populations (e.g., elderly, persons with disabilities, large households, female headed households, farmworkers, and persons experiencing homelessness).
B. Housing Needs, Resources, and Constraints
1. Affirmatively further[ing] fair housing in accordance with Chapter 15 (commencing with Section 8899.50) of Division 1 of Title 2…shall include an assessment of fair housing in the jurisdiction (Gov. Code, § 65583, subd. (c)(10)(A))
Outreach: Outreach specifically related to affirmatively furthering fair housing (AFFH) is foundational to a complete analysis and formulating appropriate goals and actions to overcome patterns of segregation and foster more inclusive communities. The element mentions outreach as part of the Analysis of Impediments to Fair Housing Choice (AI) and fair housing survey. However, the element should relate this input to all components of the AFFH analysis and modify or add goals and actions as appropriate. Also, the outreach from the fair housing survey appears limited to fair housing complaints If broader outreach, such as neighborhood specific or broader concerns on quality of life, are not available in the AI, the City should consider additional outreach methods related to AFFH.
Assessment of Fair Housing: The element reports and maps data on components of the assessment of fair housing (e.g., segregation and integration, disparities in access to opportunity) but it must also analyze the information such as evaluating patterns, trends, conditions and circumstances, coincidence with other components of the assessment of 1814 of 1910
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fair housing and the effectiveness of past and current strategies to promote inclusive communities and equitable. This analysis should be complemented by local data and knowledge, including input from commenters, and other relevant factors as described below.
Enforcement: While the element discusses capacity to investigate fair housing complaints, it should quantify and evaluate the characteristics of complaints to the extent possible. In addition, this analysis must also describe compliance with existing fair housing laws and regulations.
Racial/Ethnic Areas of Concentration of Poverty (R/ECAP) and Affluence (RCAA): The element states that a R/ECAP does not exist, however, HCD notes the City does have an area of High Segregation and Poverty according to TCAC/HCD Opportunity maps. In addition, the element identifies a concentrated area of affluence. As a result, the element should include specific analysis of these areas, as described above, to formulate appropriate goals and actions.
Access to Opportunity: The element only provides state data regarding Access to Opportunity, the element must include a local and regional analysis. A complete analysis should include the locally and regional disparities of the educational, environmental, economic, and transportation scores. Please refer to page 35 of the AFFH guidebook (link:
https://www.hcd.ca.gov/community-development/affh/index.shtml#guidance) for specific factors that should be considered when analyzing access to opportunities as it pertains to educational, employment, environmental, transportation, and any factors that are unique to Glendale.
Disproportionate Housing Needs including Displacement: While the element describes the City’s plans to study displacement, the element must analyze data on overcrowded households, substandard housing conditions, cost burdened households, and displacement. The element should analyze this data looking at trends, patterns, and local data and knowledge and other relevant factors, and conclude with a summary of issues.
For housing conditions, the City could utilize information from code enforcement to evaluate patterns from neighborhood to neighborhood. For displacement risk, the City could utilize information from the Urban Displacement Project at https://www.urbandisplacement.org/maps/los-angeles-gentrification-and-displacement/.
Sites Inventory: While the element summarizes where sites are located in relation to the AFFH analysis, the element does not identify sites, especially for lower-income households in high resource or high-income areas and sites are not distributed throughout the community in a manner that AFFH. To support appropriate conclusions, the element should analyze the location of all sites and number of units by income group, magnitude of the impact on existing patterns of socio-economic characteristics and any isolation of the sites. The element must also discuss whether the distribution of sites improves or exacerbates conditions. If sites exacerbate conditions, the element should identify further program actions that will be taken to mitigate this (e.g., anti-displacement strategies) such as significant steps to rezone a variety of housing choices elsewhere or place-based strategies to assure equitable quality of life.
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Contributing Factors: The element should re-assess and prioritize contributing factors upon completion of analysis and make revisions as appropriate.
Goals, Priorities, Metrics, and Milestones: The element must be revised to add or modify goals and actions based on the outcomes of the analysis described above. Goals and actions must specifically respond to the analysis and prioritize contributing factors to fair housing issues. Actions must have metrics and milestones as appropriate and address housing mobility enhancement, new housing choices and affordability in high opportunity areas, place-based strategies for community preservation and revitalization and displacement protection.
2. Include an analysis of population and employment trends and documentation of projections and a quantification of the locality's existing and projected needs for all income levels, including extremely low-income households. (Gov. Code, § 65583, subd. (a)(1).)
Extremely-Low Income (ELI) Households: The element identifies the projected housing needs for ELI households and includes some brief discussion of situations and available programs. However, given the unique and disproportionate housing needs of ELI households, the element should evaluate the needs of ELI households such as overpayment, affordability gaps, effectiveness of programs and resources in addressing the housing needs and consideration of new strategies based on the outcomes of the analysis.
3. An inventory of land suitable and available for residential development, including vacant sites and sites having realistic and demonstrated potential for redevelopment during the planning period to meet the locality’s housing need for a designated income level, and an analysis of the relationship of zoning and public facilities and services to these sites. (Gov. Code, § 65583, subd. (a)(3).)
Progress in Meeting the RHNA: The City’s regional housing needs allocation (RHNA) may be reduced by the number of new units built since June 30, 2021, however, the element must describe the status of each project and how likely they are to be developed during the planning period as well as whether they were counted toward 5 th cycle RHNA
progress. The element indicates (p. 88) that 77 units affordable to very low-income households and 21 units affordable to low-income household have been built or are under construction or approved. Public comments received during HCD’s review indicated that many projects listed as progress towards meeting RHNA were completed and occupied prior to June 30, 2021. The element must clarify that the sites identified as progress toward meeting RHNA were not occupied or receive certificate of occupancy before June 30, 2021.
In addition, the element does not clarify whether projects in Table 58 (p. 94) are being counted as progress toward RHNA or in the sites inventory. The element must clarify and add additional information as appropriate (i.e. sites inventory and default density requirements or clarifying the existence of deed restrictions and/or market trends to support affordability assumptions).
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Finally, the element appears to utilize some market rate projects toward the moderate- income RHNA. The element should include additional information to demonstrate affordability based on actual or anticipated sales prices or rents. This is particularly important given current market rents noted in the element (p. 38).
Parcel Listing: While the element includes many requirements for the sites inventory, it must also include the general plan designation, whether a site is vacant or nonvacant, describe any existing use for nonvacant sites, whether sites were previously identified in the 4
th or 5th cycle, the unit count for pending projects listed in the inventory, and incorporate realistic capacity assumptions. Descriptions of existing uses should be sufficiently detailed to facilitate an analysis of redevelopment potential.
Realistic Capacity: While the element provides assumptions of buildout for sites included in the inventory, it must also provide support for these assumptions. For example, the element should demonstrate what specific trends, factors, and other evidence led to the assumptions. The estimate of the number of units for each site must be adjusted as necessary, based on the land use controls and site improvements, typical densities of existing or approved residential developments at a similar affordability level in that jurisdiction. For example, the element lists all recent projects in the downtown specific plan to support a realistic capacity but should also discuss their level of affordability to demonstrate whether sites with 100 percent affordability are built at the assumed densities.
For sites with zoning that allows 100 percent nonresidential uses, e.g. commercial and mixed use zones, the element must account for the likelihood of 100 percent nonresidential uses and adjust residential calculations as appropriate. To account for the likelihood of 100 percent non-residential uses, the element should discuss development trends, any performance standards mandating a specified portion of residential and any factors increasing the potential for residential development such as incentives for residential use.
Suitability of Nonvacant Sites: While the element identifies nonvacant sites to accommodate the regional housing need for lower-income households, it must describe the methodology used to determine the additional development potential within the planning period. The methodology must consider factors including the extent to which existing uses may impede additional residential development, development trends, market conditions, any existing leases or other contracts that would perpetuate the existing use or prevent redevelopment of the site for additional residential development, and regulatory or other incentives or standards to encourage additional residential development on these sites. (Gov. Code, § 65583.2, subd. (g).) The element generally does not address all of these requirements. For example, the element discusses residential recycling where sites can accommodate at least two additional units are assumed suitable for above moderate-income households but it must also rescale this assumptions or demonstrate the likelihood of redevelopment based on development trends and the extent that existing uses impede additional development. For another example, sites in the Downtown Specific Plan, the element lists factors to identify sites but must also support those factors based on development trends, relate the trends to 1817 of 1910
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identified sites, reflect the values of each of the factors in the inventory, discuss existing uses and impediments to redevelopment and other factors as discussed above.
In addition, the housing element relies upon nonvacant sites to accommodate more than 50 percent of the RHNA for lower-income households, the housing element must demonstrate that the existing use is not an impediment to additional residential development in the planning period (Gov. Code, § 65583.2, subd. (g)(2).). This can be demonstrated by providing substantial evidence that the existing use is likely to be discontinued during the planning period (Gov. Code, § 65583.2, subd. (g)(2).
Finally, if element utilizes sites with existing residential uses. Absent a replacement housing policy, these sites are not adequate sites to accommodate lower-income households. The replacement housing policy has the same requirements as set forth in Government Code section 65915, subdivision (c) (3).
Adequate Sites Alternatives: To credit the conversion of 699 units of existing multifamily units to deed restricted affordable units (pages 41 and 89), City’s regional housing need, the element must demonstrate compliance with all the statutory requirements. (Gov.
Code, § 65583.1.) For example, the element must demonstrate that the units will be preserved, and the local government has provided those units with committed assistance. The City must also provide the Alternative Adequate Sites Checklist to support the assumptions. In addition, the element must demonstrate that the units credited toward moderate income meet all of the requirements outlined in AB 787 including the deed restriction was recorded between June 30, 2021 and October 15, 2021. The element must describe the funding source, how long the deed restriction is in place, and include a program in the element to commit to the funding. For additional information and an Alternative Adequate Sites Checklist, see the Building Blocks at http://www.hcd.ca.gov/community-development/building-blocks/site-inventory- analysis/analysis-of-sites-and-zoning.shtml#realistic.
Accessory Dwelling Units (ADU): The element assumes an ADU build out of 159 ADU and/or junior accessory dwelling unit (JADU) per year based upon approvals between 2018 and 2020. The element should base its estimate on the average number of ADUs permitted per year since 2018. Given that the City has only produced an average of 107 units per year since 2018, it is not clear if this production level will be achievable in the planning period. As a result, the element should be updated to include a realistic estimate of the potential for ADUs and include policies and programs that incentivize the production of ADUs. Depending on the analysis, the element must commit to monitor ADU production throughout the course of the planning period and implement additional actions if not meeting target numbers anticipated in the housing element. In addition to monitoring production, this program should also monitor affordability. Additional actions, if necessary, should be taken in a timely manner (e.g., within six months). Finally, if necessary, the degree of additional actions should be in stride with the degree of the gap in production and affordability. For example, if actual production and affordability of ADUs is far from anticipated trends, then rezoning or something similar would be an appropriate action. If actual production and affordability is near anticipated trends, then measures like outreach and marketing might be more appropriate.
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Availability of Infrastructure: While the element describes water and sewer infrastructure, it must state whether there is enough water and sewer capacity available and accessible accommodate the City’s RHNA and include programs if necessary.
Environmental Constraints: While the element generally describes a few environmental conditions within the City, it must describe any known environmental constraints or othe conditions such as litigation within the City that could impact housing development on identified sites in the planning period.
Zoning for a Variety of Housing Types:
• Emergency Shelters: While the element states that emergency shelters are allowed in industrial, special purpose, and IMU. The element must clarify if they are allowed by-right as well as describe the requirements and standards. The element must also analyze the availability of sites and appropriateness of the identified zones.
• Transitional and Supportive Housing: Transitional housing and supportive housing must be permitted as a residential use in all zones allowing residential uses and only subject to those restrictions that apply to other residential dwellings of the same type in the same zone. (Gov. Code, § 65583, subd. (a)(5).) The element must add or revise programs which comply with the statutory requirements. • Single Room Occupancy (SRO) Units: The element does not describe where SRO units are allowed. This is an important housing type, and the element must be revised to allow SROs.
• Employee Housing: The element must clarify if the City has zones allowing for agricultural uses and must demonstrate the zoning is consistent with the Employee Housing Act (Health and Safety Code, § 17000 et seq.), specifically, sections 17021.5 and 17021.6. Section 17021.5 requires employee housing for six or fewer employees to be treated as a single-family structure and permitted in the same manner as other dwellings of the same type in the same zone. Section 17021.6 requires employee housing consisting of no more than 12 units or 36 beds to be permitted in the same manner as other agricultural uses in the same zone.
• Manufactured Housing: the element does not describe where mobile home parks are allowed within the City. The element must describe where mobile home parks are allowed or add a program as appropriate.
• Accessory Dwelling Units (ADU): The element must clarify compliance with ADU law such as whether ADUs are allowed in the Town Center Specific Plan where multifamily residential is allowed.
4. An analysis of potential and actual governmental constraints upon the maintenance, improvement, or development of housing for all income levels, including the types of housing identified in paragraph (1) of subdivision (c), and for persons with disabilities as identified in the analysis pursuant to paragraph (7), including land use controls, building codes and their enforcement, site improvements, fees and other exactions required of developers, and local processing and permit procedures. The analysis shall also demonstrate local efforts to remove governmental constraints that hinder the locality from meeting its share of the regional housing need in accordance with Government 1819 of 1910
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Code section 65584 and from meeting the need for housing for persons with disabilities, supportive housing, transitional housing, and emergency shelters identified pursuant to paragraph (7). Transitional housing and supportive housing shall be considered a residential use of property and shall be subject only to those restrictions that apply to other residential dwellings of the same type in the same zone. (Gov. Code, § 65583, subd. (a)(5).)
Land Use Controls: While the element describes the general plan and zoning designations for most residential uses, the element must describe whether 100 percent residential or commercial uses are allowed by-right in the Downtown Specific Plan and mixed-use zones. The element should also describe the interaction between the General Plan High Density designation which allows for 35-60 dwelling units an acre, but the corresponding zone allows for up to 34 dwelling units an acre. In addition, the element must alco clarify whether three story multifamily developments are allowed by right in the Downtown Specific Plan areas that limit height to a maximum of 35 feet. The element must also revise parking standards requiring more than one space for efficiency and one-bedroom units as well as the guest parking requirement in the PRD zone. The element should analyze the 40 percent and 50 percent maximum lot coverage requirements for single family and multifamily developments respectively as well as the maximum of two stories for multifamily developments on lots less than 90 feet in width. In addition, the element should clarify the maximum densities equal in multifamily zones.
The element must describe the maximum number of units in the Town Center Specific Plan in relation to the plan size. The element states that a maximum of 338 units are allowed over the planning area of 16.5 acres at a density up to 100 dwelling units an acre. The element should describe how many units exist in the specific plan currently, whether more units are planned, and whether sites identified in the inventory are in the specific plan. The element must also describe any lot coverage maximums in the Specific Plan. In addition, the element must revise parking standards that require two spaces for studio and one-bedroom units as well as analyze the parking structure requirements and add a program as appropriate.
Fees and Exaction: The element must describe all required fees for single family and multifamily housing development, including impact fees, and analyze their impact as potential constraints on housing
supply and affordability. While the element includes
many fees, table on page 78 must also include site plan, specific plan, development agreement, and negative declaration fees. The element must also describe whether the fees listed are applicable for both single family and multifamily developments. In addition, the element must describe the proportion of fees in comparison to overall development cost for a typical single family and multifamily development. The element must also analyze whether the change of use annual parking fee is a constraint and add a program as appropriate.
Local Processing and Permit Procedures: While the element describes the review authority for type of approval or permit, it must describe and analyze the City’s permit processing and approval procedures by zone and housing type (e.g., multifamily rental housing, mobilehomes, housing for agricultural employees, supportive housing). The analysis must evaluate the processing and permit procedures’ impacts as potential 1820 of 1910
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constraints on housing supply and affordability. For example, the analysis should consider processing and approval procedures and time for typical single- and multi- family developments, including type of permit, level of review, approval findings and any discretionary approval procedures. It must also list the typical review time for each permit procedure. In addition, the element must analyze the conditional use findings as a constraint for multifamily developments in the MU-R zones, in particular the employment and compatibility findings, as well as the live work findings, including inhibiting commercial or industrial uses. The element should list the findings for an administrative use permit.
Local Ordinances: While the element states that there are inclusionary and short term rental ordnances, the element must specifically analyze locally adopted ordinances that directly impact the cost and supply of residential development. The analysis should demonstrate local efforts to remove governmental constraints that hinder the locality from meeting its share of the regional housing need and from meeting the need for housing for persons with disabilities, supportive housing, transitional housing, and emergency shelters.
Design Review: The element must describe and analyze the design review guidelines and process, including approval procedures and decision-making criteria, for their impact as potential constraints on housing supply and affordability. For example, the analysis could describe required findings and discuss whether objective standards and guidelines improve development certainty and mitigate cost impacts. The element must demonstrate this process is not a constraint or it must include a program to address this permitting requirement, as appropriate.
On/Off-Site Improvements: The element must identify subdivision level improvement requirements, such as minimum street widths (e.g., 40-foot minimum street width), and analyze their impact as potential constraints on housing supply and affordability.
Constraints on Housing for Persons with Disabilities: Residential care facilities serving seven or more persons are permitted in commercial zones by-right but subject to a conditional use permit (CUP) in some residential zones and not allowed in others. The element should analyze the process as a potential constraint on housing for persons with disabilities and add or modify programs as appropriate to ensure zoning permits group homes objectively with approval certainty. In addition, the element must add or revise a program as appropriate to remove constraints to the reasonable accommodation procedure, such as finding five. The element must also describe the City’s definition of family and analyze for constraints on housing for persons with disabilities.
5. An analysis of potential and actual nongovernmental constraints upon the maintenance, improvement, or development of housing for all income levels, including the availability of financing, the price of land, the cost of construction, the requests to develop housing at densities below those anticipated in the analysis required by subdivision (c) of Government Code section 65583.2, and the length of time between receiving approval for a housing development and submittal of an application for building permits for that housing development that hinder the construction of a locality’s share of the regional housing need in accordance with Government Code section 65584. The analysis shall 1821 of 1910
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also demonstrate local efforts to remove nongovernmental constraints that create a gap between the locality’s planning for the development of housing for all income levels and the construction of that housing. (Gov. Code, § 65583, subd. (a)(6).)
Financing: While the element describes land and construction costs, the element must describe whether financing is available within the City.
Developed Densities and Permit Times: The element must be revised to include analysis of requests to develop housing at densities below those anticipated, and the length of time between receiving approval for a housing development and submittal of an application for building permits that potentially hinder the construction of a locality’s share of the regional housing need.
6. Analyze the opportunities for energy conservation with respect to residential development. (Gov. Code, § 65583(a)(8).)
The element indicates the City enforces Title 24 and describes conservation programs of local utilities. However, it must include analysis of energy conservation opportunities in residential development. The analysis should facilitate the adoption of housing element policies and programs. For example, programs could provide incentives to promote higher density housing along transit, encourage green building techniques and materials in new construction and remodels, promote energy audits and participation in utility conservation programs, and facilitate energy conserving retrofits upon resale of homes.
7. Analyze existing assisted housing developments that are eligible to change to non-low- income housing uses during the next 10 years due to termination of subsidy contracts, mortgage prepayment, or expiration of use restrictions. (Gov. Code, § 65583, subd. (a)(9) through 65583(a)(9)(D).).
On page 52, the element identifies existing affordable units that are at-risk during the planning period. There were units that have rental restrictions expiring within the next ten years that were not included in the total at-risk units. The element should describe the methodology used to determine whether units are at-risk. In addition, all properties should list type of governmental assistance, and include an analysis of replacement/ preservation costs. The element should also include a list of qualified entities and potential funding sources to preserve the units.
C. Housing Programs
1. Include a program which sets forth a schedule of actions during the planning period, each with a timeline for implementation, which may recognize that certain programs are ongoing, such that there will be beneficial impacts of the programs within the planning period, that the local government is undertaking or intends to undertake to implement the policies and achieve the goals and objectives of the Housing Element through the administration of land use and development controls, the provision of regulatory concessions and incentives, and the utilization of appropriate federal and state financing and subsidy programs when available. The program shall include an identification of the 1822 of 1910
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agencies and officials responsible for the implementation of the various actions. (Gov.
Code, § 65583, subd. (c).)
To address the program requirements of Government Code section 65583, subdivision (c)(1-6), and to facilitate implementation, programs should include: (1) a description of the City’s specific role in implementation; (2) definitive implementation timelines (i.e. month and year); (3) objectives, quantified where appropriate; and (4) identification of responsible agencies and officials. Examples of programs to be revised include the following:
• Program 1C (Surplus Lands): The Program must include a timeframe of when the initial list will be created as well as how often it will be updated. • Program 2A (Multi-family Acquisition/Rehabilitation Loan Program): The Program should include a specific implementation date as well as include proactive outreach to developers.
• Program 2C (Code Enforcement): This program should clarify if there is any assistance available to homeowners who cannot afford repairs. • Program 2D (Neighborhood “Target Areas”): The Program should describe any timeframes regarding the approval of the Tropico study plan. • Program 3A (Density Bonus Program): This Program should implement an update of the ordinance within one year of adoption as well as evaluate and update the ordinance at a set interval throughout the planning period. • Program 3E (Mixed Use Standards on Transportation Corridors): The Program lists that the study will be complete in February 2023, but it should also include a discrete timeframe of when the study results will be implemented. • Program 5A (New Types of Subdivision): This Program should include an action and implementation component. The element should clarify what will occur by December 2023.
• Program 6A (Care Management Services): The element should describe whether any outreach will occur.
• Program 6C (Developmental Disabilities Housing Services): The program should describe when the brochure will be available and how often outreach will occur.
2. Identify actions that will be taken to make sites available during the planning period with appropriate zoning and development standards and with services and facilities to accommodate that portion of the city’s or county’s share of the regional housing need for each income level that could not be accommodated on sites identified in the inventory completed pursuant to paragraph (3) of subdivision (a) without rezoning, and to comply with the requirements of Government Code section 65584.09. Sites shall be identified as needed to facilitate and encourage the development of a variety of types of housing for all income levels, including multifamily rental housing, factory-built housing, mobilehomes, housing for agricultural employees, supportive housing, single-room occupancy units, emergency shelters, and transitional housing. (Gov. Code, § 65583, subd. (c)(1).)
As noted in Finding B3, the element does not include a complete site analysis; therefore, the adequacy of sites and zoning were not established. Based on the results of a 1823 of 1910
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complete sites inventory and analysis, the City may need to add or revise programs to address a shortfall of sites or zoning available to encourage a variety of housing types. In addition, the element should be revised as follows:
Previously Identified Nonvacant and Vacant Sites: While the element includes Policy
1.11, it should be revised to require multifamily development with 20 percent affordability to be permitted by right and add a program as appropriate.
Replacement Housing Requirements: The housing element must include a program to provide replacement housing. Nonvacant sites identified in the sites inventory with existing, vacated, or demolished residential uses and occupied by, or subject to an affordability requirement for, lower-income households within the last five years, require a replacement housing program for units affordable to lower-income households. (Gov.
Code, § 65583.2, subd. (g)(3).) Absent a replacement housing program, these sites are not adequate sites to accommodate lower-income households. The replacement housing program must adhere to the same requirements as set forth in Government Code section 65915, subdivision (c)(3).
Program 1E (Adaptive Reuse): This Program should include an implementation component and go farther than exploring potential incentives for adaptive reuse of commercial and office buildings for housing.
3. Address and, where appropriate and legally possible, remove governmental and nongovernmental constraints to the maintenance, improvement, and development of housing, including housing for all income levels and housing for persons with disabilities.
The program shall remove constraints to, and provide reasonable accommodations for housing designed for, intended for occupancy by, or with supportive services for, persons with disabilities. (Gov. Code, § 65583, subd. (c)(3).)
As noted in Finding(s) B4 and B5, the element requires a complete analysis of potential governmental and nongovernmental constraints. Depending upon the results of that analysis, the City may need to revise or add programs and address and remove or mitigate any identified constraints. In addition, the element should be revised as follows:
• Program 6B (Homeless Services): This Program should be revised to clarify which programs will be supported. It should also include regular outreach and assistance for annual funding applications.
• Program 8B (Permit Streamlining): This Program must include an action to reduce permit approval times, a specific timeframe as to when it will be implemented, and how often the process will be reviewed throughout the planning period.
• Program 9A (Monitor Changes in Federal and State Housing, Planning, and Zoning Laws): This program should revise the timing to include annual monitoring as well as how often updates will occur in the planning period. • Program 9B (Zoning Code Amendments – Housing Constraints): While the element includes revisions to employee housing and agricultural worker housing, it must be consistent with Employee Housing Act (Health and Safety Code, § 17000 et seq.), specifically, sections 17021.5 and 17021.6. 1824 of 1910
City of Glendale’s 6th Cycle Draft Housing Element Page 12 December 31, 2021
4. Promote and affirmatively further fair housing opportunities and promote housing throughout the community or communities for all persons regardless of race, religion, sex, marital status, ancestry, national origin, color, familial status, or disability, and other characteristics protected by the California Fair Employment and Housing Act (Part 2.8 (commencing with Section 12900) of Division 3 of Title 2), Section 65008, and any other state and federal fair housing and planning law. (Gov. Code, § 65583, subd. (c)(5).)
As mentioned in Finding B1, programs throughout the element should be revised to address enhancing housing mobility strategies; encouraging development of new affordable housing in high resource areas; improving place-based strategies to encourage community conservation and revitalization, including preservation of existing affordable housing; and protecting existing residents from displacement. The programs should include metrics and milestones to provide benchmarks and ensure housing outcomes.
In addition, Program 7A (Fair Housing Plan) should be strengthened and include how often outreach will occur. Program 7C (Affirmatively Furthering Fair Housing Program) should be revised to refer fair housing complaints to the Department of Fair Employment and Housing (not HCD), the land use component should commit to an action based on the review, it should also include how often outreach will occur, and all implementation actions should include metrics and timing.
5. The housing program shall preserve for low-income household the assisted housing developments identified pursuant to paragraph (9) of subdivision (a). The program for preservation of the assisted housing developments shall utilize, to the extent necessary, all available federal, state, and local financing and subsidy programs identified in paragraph (9) of subdivision (a), except where a community has other urgent needs for which alternative funding sources are not available. The program may include strategies that involve local regulation and technical assistance. (Gov. Code, § 65583, subd. (c)(6).)
While the element includes Program 2E (Conservation of Existing and Future Affordable Housing Units), it should incorporate preservation notice law (Government Codes 65863.10, 65863.11, 65863.13) as well as include proactive outreach to owners beginning three years before expiration of rental agreements. The program can also commit resources to preserve existing affordable units.
8. Develop a plan that incentivizes and promotes the creation of accessory dwelling units that can be offered at affordable rent, as defined in Section 50053 of the Health and Safety Code, for very low, low-, or moderate-income households. For purposes of this paragraph, “accessory dwelling units” has the same meaning as “accessory dwelling unit” as defined in paragraph (4) of subdivision (i) of Section 65852.2. (Gov. Code, § 65583, subd. (c)(7).)
While the element includes Program 1F (Accessory Dwelling Units), the program should include a monitoring component every two years and identify additional sites if ADU projections are not meeting the assumptions. In addition, the language regarding incentives should be revised to go farther than evaluate potential incentives and should strengthened to implement specific incentives listed in the program. 1825 of 1910
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D. Quantified Objectives
Establish the number of housing units, by income level, that can be constructed, rehabilitated, and conserved over a five-year time frame. (Gov. Code, § 65583, subd. (b)(1 & 2).)
The element must include quantified objectives to establish an estimate of housing units by income category that can be constructed, rehabilitated, and conserved over the planning period. While the element includes these objectives by income group, the element must breakout the objective for conservation/preservation for extremely low-, very low-, low- income households.
E. Public Participation
Local governments shall make a diligent effort to achieve public participation of all economic segments of the community in the development of the Housing Element, and the element shall describe this effort. (Gov. Code, § 65583, subd.(c)(8).)
While the element includes a general summary of the public participation process, it must also demonstrate diligent efforts were made to involve all economic segments of the community in the development of the housing element. The element could describe the efforts to circulate the housing element among low- and moderate-income households and organizations that represent them and to involve such groups and persons in the element throughout the process. In addition, the element should also summarize the public comments and describe how they were considered and incorporated into the element.
In addition, HCD understands the City made the element available to the public on November 1, 2021, concurrent with its submittal to HCD. By not providing an opportunity for the public to review and comment on a draft of the element in advance of submission, the City has not yet complied with statutory mandates to make a diligent effort to encourage the public participation in the development of the element and it reduces HCD’s ability to consider public comments in the course of its review. The availability of the document to the public and opportunity for public comment prior to submittal to HCD is essential to the public process and HCD’s review. The City must proactively make future revisions available to the public, including any commenters, prior to submitting any revisions to HCD and diligently consider and address comments, including making revisions to the document where appropriate. HCD’s future review will consider the extent to which the revised element documents how the City solicited, considered, and addressed public comments in the element. The City’s consideration of public comments must not be limited by HCD’s findings in this review letter.
F. Consistency with General Plan
The Housing Element shall describe the means by which consistency will be achieved with other general plan elements and community goals. (Gov. Code, § 65583, subd. (c)(7).) 1826 of 1910
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The housing element affects a locality’s policies for growth and residential land uses. The goals, policies and objectives of an updated housing element may conflict with those of the land-use, circulation, open space elements as well as zoning and redevelopment plans. The general plan is required to be “internally consistent.” As part of the housing element update, the City should review the general plan to ensure internal consistency is maintained. In addition, The City should consider an internal consistency review as part of its annual general plan implementation report required under Government Code section 65400. 1827 of 1910
From: Anthony Dedousis
To: Krause, Erik; Brotman, Daniel; Agajanian, Vrej; Devine, Paula; Najarian, Ara; Kassakhian, Ardashes; Golanian, Roubik
Cc: Jon Wizard; Leonora Camner
Subject: Re: Comment letter - Glendale draft housing element Date: Tuesday, January 04, 2022 10:07:35 AM
CAUTION: This email was delivered from the Internet. Do not click links, open attachments, or reply if you are unsure as to the sender.
Dear Councilmembers and Planning staff:
I'm reaching out to share an economic analysis of Glendale's proposed housing element - in particular, the claims made in the City's site inventory and proposed rezoning program.
While
the City’s site inventory and rezoning program claimed capacity for about 14,700 housing units, our analysis, a joint undertaking of Abundant Housing LA and MapCraft, found that expected housing capacity could fall short by 1,500 to 3,000 housing units.
This cover letter
has additional information about our research, and you can review the full report here. We have shared this analysis with HCD, and encouraged them to incorporate the findings into their review of Glendale's housing element. We would be happy to discuss our findings with you, as well as our November comment letter on the proposed housing element.
Thank you,
Anthony
On Fri, Nov 19, 2021 at 10:27 AM Anthony Dedousis <[email protected] >
wrote:
Dear Councilmembers and Planning Staff:
I'm reaching out to share a letter from Abundant Housing LA and YIMBY Law commenting on Glendale's draft housing element.
We have major concerns about the City's intended
approach to updating the housing element.
We believe that the City's intended approach
does not satisfy the intent of state law, which is to expand housing availability at all income levels.
Of particular concern is the improper counting of at least 1,537 housing units, completed during the 5th cycle, towards the 6th cycle RHNA goal.
It is completely
unacceptable that the City has double-counted these buildings towards its 6th cycle RHNA goals.
The attached letter contains a detailed explanation of where we view this effort as having fallen short of HCD's standards and state law.
We respectfully request the opportunity to
discuss our concerns with you.
Thank you for your consideration.
Regards,
Anthony Dedousis
--
1828 of 1910
Anthony Dedousis
Director, Policy and Research
Abundant Housing LA
515 S Flower Street, 18th Floor
Los Angeles, CA 90071
516-660-7402
We request that candidates do not send us confidential campaign strategy information, including polling data or other information that is not publicly available.
--
Anthony Dedousis
Director, Policy and Research
Abundant Housing LA
515 S Flower Street, 18th Floor
Los Angeles, CA 90071
516-660-7402
We request that candidates do not send us confidential campaign strategy information, including polling data or other information that is not publicly available.
1829 of 1910
January 4, 2022
Gustavo Velasquez, Director
California Department of Housing & Community Development 2020 West El Camino Avenue, Suite 500
Sacramento, CA 95833
Dear Director Velasquez:
We are writing on behalf ofAbundant Housing LAregarding Glendale’s 6th Cycle housing element update. As you know, we have shared several comment letters with HCD describing our concerns about major deficiencies in the City’s housing element update. Among our concerns is the City’s failure to identify enough parcels in its site inventory and proposed rezoning program to achieve its RHNA target of 13,425 homes by 2029.
Assembly Bill 1397 (2017) requires cities to provide an accurate assessment of realistic site capacity, including “the city’s or City’s past experience with converting existing uses to higher density residential development, the current demand for the existing use, and an analysis of existing leases or other contracts that would perpetuate the existing use or prevent redevelopment.”
When cities allocate over 50% of their lower-income RHNA targets to nonvacant sites, they must demonstrate throughsubstantial evidence that the current use of these sites is likely to be discontinued during the planning period. This is necessary in order to ensure that enough parcels for affordable housing production are identified, and that the lower-income RHNA targets are ultimately achieved. To date, the City has not yet adequately provided this substantial evidence.
Abundant Housing LA has partnered withMapCraft Labs, an economic and policy analysis firm with expertise in housing elements and quantitative real estate analysis, to forecast the true realistic capacity of the City’s site inventory and proposed rezoning program. The analysis considers the likely impact of housing element updates on housing production and proposes alternative rezoning scenarios that are more likely to achieve the RHNA target. In particular, MapCraft analyzed the market feasibility of the unit capacity claims made on parcels included in jurisdictions’ site inventories.
This analysis calls into question the City’s conclusion that its housing element creates the conditions for achieving the RHNA target. Among our core findings:
● While the City’s site inventory and rezoning program claimed capacity for about 14,700 housing units, our analysis suggests that expected housing capacity could fall short by 1,500 to 3,000 housing units.
1830 of 1910
● On 41 sites where the City has claimed 3,465 housing units, our analysis found that these sites are either unlikely to be redeveloped to the density that the City is claiming, or are unlikely to be redeveloped altogether.This represents 41% of the housing units in the City's site inventory.
In light of this information, we respectfully recommend that HCD urge the City to reassess its site capacity claims, and revise its site inventory and proposed rezoning program. The City should add more parcels to its site inventory and expand its proposed rezoning program, particularly for low-density parcels in high-demand neighborhoods like Vineyard, Mariposa, Pacific-Edison, and Grandview. The City should also consider eliminating or reducing on-site parking requirements, which would greatly improve the economic feasibility of denser housing development.
We encourage you to review Abundant Housing LA and MapCraft’s full report describing how these conclusions were reached. We would be happy to discuss our findings with you and your colleagues. Thank you for your team’s continued hard work and dedication to solving California’s housing shortage and affordability crisis.
Sincerely,
Leonora Camner
Executive Director
Abundant Housing LA
Anthony Dedousis
Director of Policy and Research
Abundant Housing LA
1831 of 1910
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Abundant Housing LA Feedback on Glendale Housing Element
Date: December 16, 2021
To: Abundant Housing LA
From: MapCraft Inc
Subject: Housing Element Analysis Results
Executive Summary
Based on an analysis of the sites found in the City of Glendale’s site inventory, which claimed capacity for over 14,700 total units across over 940 sites, our analysis suggests that Glendale’s expected housing capacity could fall short by between 1,500 and 3,000 units.
Glendale could consider the following actions to meet RHNA goals:
● Right-sizing claimed capacity on sites in the current site inventory, both by reducing expectations on many sites and by upzoning other sites. The city could revisit additional opportunities to rezone more parcels in the inventory, particularly in areas like the Vineyard, Mariposa, Pacific-Edison, and Grandview neighborhoods. ● Adding more sites to the site inventory and evaluating rezoning of those sites. The inventory includes 14% of the city’s 6,700 parcels, so there are many places that could be explored further to address this potential shortfall.
● Reducing or eliminating parking requirements and promoting automobile alternatives to reduce households’ demand for parking. If developers could meet household demand with fewer on-site parking stalls, it could make multifamily development in many parts of the City more economically feasible.
● Introducing new economic incentives to increase the financial feasibility of redevelopment, especially for projects that include below-market-rate units.
● Consider establishing development minimums to ensure high utilization of sites with feasible housing capacity.
Purpose of this Analysis
The State of California requires local jurisdictions to periodically update their housing elements to address housing needs, as identified by the Regional Housing Needs Assessment (RHNA). Cities in the Southern California Association of Governments (SCAG) region are in the process of developing updates to their housing elements, as part of the 6th cycle of the RHNA Allocation Plan, which will cover the planning period October 2021 through October 2029.
In March 2021, California’s Department of Housing and Community Development (HCD) approved SCAG’s adopted RHNA Allocation Plan, apportioning the region’s housing growth target to its 1832 of 1910
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jurisdictions. City governments in SCAG are responsible for updating their Housing Elements and submitting them to HCD by October 2021. The Housing Elements must include an inventory of parcels suitable and available for residential development. The total capacity of the sites must be sufficient to accommodate the total housing need, by income level, allocated throughout the planning period.
Abundant Housing LA (AHLA) is a pro-housing, nonprofit advocacy organization working to help solve Southern California’s housing crisis. AHLA is providing feedback on housing elements to jurisdictions during the public comment period, and communicating to HCD staff its assessment of the housing elements. AHLA’s review of housing elements is intended to ensure that jurisdictions develop high-quality housing element updates, and fully comply with state housing element law.
To that end, AHLA partnered with MapCraft to assess the site inventories shared by jurisdictions as part of their housing element updates. The analysis considers the likely impact of the draft housing elements on housing production and suggests alternative rezoning scenarios that are more likely to achieve cities’ RHNA goals. MapCraft worked with a team to determine the likelihood that new housing production would be possible at the scale assumed by draft housing elements. In particular, MapCraft analyzed the market feasibility of the unit capacity claims made on sites included in jurisdictions’ site inventories. This memorandum serves as the documentation for the results of various analyses completed by MapCraft for assessing Glendale’s Housing Element.
Categorizing Site Inventory Claims
We conducted multiple tests of the City of Glendale’s proposed site inventory. For each site for which data was available, we assessed the following:
1. How historic development patterns compared with the unit capacity claimed in the site inventory
2. How physical zoned capacity, taking into account major zoning constraints, beyond just the allowed units per acre, compared with the unit capacity claimed in the site inventory
3. How the scale of pipeline developments identified in the site inventory compare to the unit capacity claims made on similar sites in the site inventory
4. How financially feasible scales of development compared to the unit capacity claimed in the site inventory
Based on the tests on each site, we classified the housing capacity claimed on each site in the site inventory as one of three categories: reasonable, questionable, or unreasonable. Although the tests were nuanced, in general these categories meant:
● Capacity estimates were categorized as “reasonable” when a MapCraft test found that viable capacity on the site was greater than what the jurisdiction claimed in the inventory ● Capacity estimates were categorized as “questionable” when a MapCraft test found that viable capacity was roughly similar to, though lower than, the claim in the inventory 1833 of 1910
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● Capacity estimates were categorized as “unreasonable” when a MapCraft test found that viable capacity was deemed substantially less than what was claimed Multiple feasibility tests were performed for each site. If the number of claimed units on a site was found to be unreasonable according to multiple tests, we are confident that a reevaluation of the site is warranted.
● More specifically, if the site’s claimed capacity resulted in “unreasonable” for more than one third of the applicable tests, we concluded the site’s claim was unreasonable. ● If none of the tests resulted in an “unreasonable” finding, and more than one third of the applicable tests resulted in “reasonable”, then we concluded the site’s claim was reasonable.
● The rest of the sites, which fall between our thresholds for “reasonable” and “unreasonable,” were defined as “questionable.”
We analyzed 943 sites in Glendale’s site inventory, with a total claimed capacity of 9,356 units. This includes 10 sites with 490 units in projects that are already pending, which we assumed to be reasonable capacity claims and did not analyze further. It also includes 933 sites with 8,866 units that were identified for potential future development, which we analyzed further. Our analysis suggests that on 41 sites where Glendale has claimed 3,465 units, the capacity claims we analyzed were “unreasonable” or “questionable.” This represents 41% of the total capacity of the sites we analyzed.
Table 1: Results of Site Inventory Categorization
Number of Sites Claimed Units Percent of Sites Percent of Units Reasonable 888 5,023 96% 59%
Questionable 24 940 3% 11%
Unreasonable 17 2,525 2% 30%
Subtotal 929 8,488 100% 100%
Incomplete data* 4 378 N/A N/A
Total 933 8,866 100% 100%
*Sites with Incomplete data needed for our tests. These Sites were not included in our analysis
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Exhibit 1: Sites Inventory Categorization – Percent of Sites
Exhibit 2: Sites Inventory Categorization – Percent of Units
Additionally, we estimated the scale of development that might reasonably be expected on parcels in the site inventory. Our analysis suggests that Glendale’s expected capacity could fall short by anywhere between 1,498 units and 2,995 units, as compared to the 8,866 units claimed on the inventory sites that we analyzed.
To arrive at a range of unit assumptions, we applied two different sets of assumptions about the viability of units being developed on sites deemed reasonable, questionable, or unreasonable. For a more conservative estimate, we assumed 100% viability for reasonable, 50% viability for questionable, and 0% viability for unreasonable, whereas for a more lenient estimate, we assumed 100%, 75%, and 50% respectively and subtracted those units from the total. 1835 of 1910
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Table 2: Expected Capacity Shortfall
Site
Classifications
Claimed
Units on
Sites
Conservative Estimates Lenient Estimates
Expected
viability of Units
on Site
Claimed units
that are not
viable
Expected
viability of units
on sites
Claimed units
that are not
viable
Reasonable 5,023 100% Viable - 100% Viable -
Questionable 940 50% Viable 470 75% Viable 235
Unreasonable 2,525 0% Viable 2,525 50% Viable 1,263
Total 7,815 2,995 (35% Not
Viable)
1,498 (18% Not
Viable)
The city has multiple potential policy actions available to increase the viability of redevelopment on the site inventory parcels, such as:
● Add more market-feasible sites to the site inventory
● Upzone sites to enable more intense market-feasible housing development opportunities on sites already in the inventory and any sites added to the inventory ● Consider introducing new incentives and other “carrots” to encourage housing production, such as fee waivers or direct subsidies, a faster permitting process, and greater flexibility on setback size or maximum lot coverage
● Consider establishing development minimums to ensure high utilization of sites with feasible housing capacity
Test Results
The following tests were conducted on sites in the Glendale site inventory to assess whether the claimed development density in the housing element was reasonable. This was based on a comparison of the inventory claims to historic development patterns, sites’ zoned capacity, similar projects under development, and the current financial feasibility of projects of a similar scale.
1. Analysis of Historic Development Patterns (Utilization of Zoned Capacity) MapCraft evaluated projects built in the last ten years, using Los Angeles County tax assessor data, to estimate whether the claimed development density of a site inventory parcel was comparable with Glendale’s recent record of housing production.
Test 1a – Historic Development Scale
As a first test, we searched for projects built anywhere in Glendale over the last 10 years that were on sites whose size was within 20% of the site size identified in the inventory and with development densities (units per acre) that were within 20% of the density claimed in the inventory (units divided by site size).
If recent developments matched the claimed density of a site inventory parcel, we categorized the parcel as “Reasonable.” If no similar historical developments existed, we assumed that zoning had 1836 of 1910
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prohibited such developments or other factors precluded such developments from being built in Glendale and categorized the parcel as “Questionable.” We refrained from categorizing any site inventory parcel as “unreasonable” based on the historic development scale test.
Table 3: Analysis of Historic Development Scale Results (Test 1a) Percent of Sites Percent of Units
Reasonable 61% 33%
Questionable 39% 67%
*This test was applicable on 100% of the sites we analyzed Test 1b – Historic Development in Zones
For site inventory parcels where rezoning is not proposed in the housing element, we conducted two other tests comparing the historic development patterns to the number of units claimed on sites in the site inventory.
Test 1b determined whether development occurred in the last 10 years on parcels whose zoning matches the zoning of the site in the inventory. Sites were categorized as “reasonable” if there was development in that zoning category in the last 10 years, or “unreasonable” if there was not.
Table 4: Analysis of Historic Development in Zones Results (Test 1b) Percent of Sites Percent of Units
Reasonable 99% 87%
Unreasonable 1% 13%
*This test was applicable on 100% of the sites we analyzed Test 1c – Historic Development Scale in Zones
Test 1c compared the observed density of historic developments in each zoning category to the claimed density of sites in the inventory in the same zoning category. This test categorized sites as “reasonable” if the claimed density for the site was less than the density of recent projects in the same zoning category, “questionable” if the parcel’s proposed density for redevelopment was within 10% of the maximum historic development density in the same zoning category, or “unreasonable” if the parcel’s proposed density for redevelopment exceeded 10% of the maximum historic development density in the same zoning category.
Table 5: Analysis of Historic Development Scale in Zones Results (Test 1c) Percent of Sites Percent of Units
Reasonable 20% 40%
Questionable 79% 37%
Unreasonable 1% 23%
*This test was applicable on 99% of the sites we analyzed
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Key Takeaways:
● A majority (61%) of the sites in the inventory have claimed densities that match recent developments in Glendale, which corresponds to a reasonable claim for 33% of the units. ● The vast majority (99%) of sites are in zones that have seen some scale of development in the last 10 years, which corresponds to 87% of the claimed units. ● For sites in zones that have experienced development, under a quarter (20%) have claimed densities that are reasonable (i.e. less than the average density observed in those zones in the last 10 years). This only accounts for under half (40%) of the claimed units for this subset of sites.
● For sites in zones that have seen development, a large majority (79%) have claimed densities that are questionable and greater than the average density observed in those zones in the last 10 years. This accounts for a smaller proportion (37%) of the claimed units for this subset of sites.
2. Evaluation of Zoned Capacity
For site inventory parcels where rezoning is not proposed, MapCraft conducted tests based on the physical capacity of the zoning code, acknowledging that various zoning parameters might result in a lower effective capacity than the units per acre allowed in a zone. We collected several zoning attributes for each zone listed in the inventory, including maximum height limits, maximum FAR, maximum impervious coverage, minimum lot area per unit, maximum dwelling units per lot, and maximum dwelling units per acre. Using the zoning category noted for each site in Glendale’s site inventory, we estimated how many units could be accommodated on the site under the relevant zoning limits and compared the result to what was claimed in the site inventory.
This test categorized sites as “reasonable” if the claimed density for the site was less than the density resulting from any of the zoning attributes, “questionable” if the claimed density was less than the maximum density resulting from the majority of zoning attributes (e.g. based on height, based on FAR, etc.) but the claimed density was up to 10% greater than what one or more zoning attributes would accommodate, or “unreasonable” if the claimed density was greater than what a majority of zoning attributes would accommodate.
Table 6: Evaluation of Zoned Capacity Results (Test 2)
Percent of Sites Percent of Units
Reasonable 98% 98%
Questionable 2% 1%
Unreasonable 0% 0%
*This test was applicable on 100% of the sites we analyzed Key Takeaways:
● Almost all the sites in the inventory (98%) have density claims that are reasonable, which corresponds to the same proportion of the claimed units for this subset of sites. 1838 of 1910
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● About 2% of the sites in the inventory have density claims that are questionable.
3. Analysis of Site Inventory Pipeline
To understand the current conditions for housing development on site inventory parcels where rezoning is not proposed, MapCraft used the pipeline project data in Glendale’s site inventory as another way of determining what scales of development could be expected on other sites in the inventory. The scale of the pipeline projects planned on sites in a given zone provided a sample of real-world development densities for other developments in those Glendale zones. The samples were used to compare the development density (units per acre) of upcoming projects to the claimed density on each site in the inventory that was not expected to be rezoned.
This test categorized sites as “reasonable” if the claimed density for the site was less than the pipeline patterns in the zone, “questionable” if it was within 10% of the maximum pipeline development density, or “unreasonable” if it exceeded 10% of the maximum pipeline development density.
Table 7: Analysis of Site Inventory Pipeline Results (Test 3) Percent of Sites Percent of Units
Reasonable 98% 63%
Questionable 0% 0%
Unreasonable 2% 37%
*This test was applicable on 82% of the sites we analyzed Key Takeaways:
● This test was applicable for four fifths (82%) of the sites in the inventory, meaning that less than a fifth of the sites (18%) are in zones that currently do not have any pending or approved projects listed among pipeline sites.
● Most sites (98%) that could be compared to pipeline projects in the same zone had claimed densities that are reasonable. However, this only corresponds to 63% of the claimed units for this subset of sites.
4. Financial Feasibility Analysis (Market-Driven Development Expectations) MapCraft assessed the financial viability of the claims made in the site inventory by evaluating the financial feasibility of developing housing at a scale similar to the densities claimed on each site in the inventory.
MapCraft used real estate pro formas to analyze the financial feasibility of a variety of housing development types. To determine whether the unit capacity claimed on each site in the inventory might be financially feasible, MapCraft evaluated the financial feasibility of development types that had densities that were within 10% of the claimed density on each site.
Pro forma analyses can help identify market feasible development types by determining whether the value of a potential development is greater than the project’s construction costs, land costs, 1839 of 1910
MAPCRAFT
MapCraftLabs.com 9
and other costs. MapCraft estimated the land cost for each site in the inventory, using the market values provided by the Los Angeles County tax assessor. This comparison also helps to demonstrate that the existing use of a parcel is likely to be discontinued. Costs also included parking provision, which was tested in two ways: 1) based on current parking provision in the Glendale submarket and 2) assuming an aggressive reduction in mandated parking ratios and parking demand. To ensure the results reflected the market conditions applicable to each site in the inventory, the pro forma for each development type was run with the corresponding neighborhood-level market inputs.
Test 4a – Feasibility with Historic Parking Provision
For the first test, which considered parking provided at rates observed in existing development in the submarket, MapCraft categorized sites as “reasonable” if there were feasible development types that matched the scale of development claimed on each site. Sites were categorized as “questionable” if there were not feasible prototypes with similar densities. We did not include the option for an “unreasonable” result because this tested the feasibility of development using current observed parking provision, which may be higher than what is possible in new development today.
Table 8: Feasibility Analysis Results - historic parking provision (Test 4a) Percent of Sites Percent of Units
Reasonable 0% 0%
Questionable 100% 100%
Unreasonable N/A N/A
*This test was applicable on 98% of the sites we analyzed Test 4b – Feasibility with Reduced Parking Provision
The second test considered more lenient parking provision, which can contribute to development feasibility by reducing cost and saving space. MapCraft categorized sites as “questionable” if there were feasible development types that matched the scale of development claimed on each site. Sites were classified as “unreasonable” if the most financially feasible of the prototypes with similar densities could not pay for land based on the assessor’s estimate of total value. We did not include the option for a “reasonable” result for this test, given the more lenient parking assumptions may not be viable in all submarkets.
Table 9: Feasibility Analysis Results - reduced parking provision (Test 4b) Percent of Sites Percent of Units
Reasonable N/A N/A
Questionable 100% 100%
Unreasonable 0% 0%
*This test was applicable on 98% of the sites we analyzed Key Takeaways:
● We found that today’s housing market does not support the scales of development claimed on many sites in the inventory.
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MAPCRAFT
MapCraftLabs.com 10
● We found that today’s housing market could better support the scales of development claimed on many sites in the inventory if less parking were demanded and required than what has historically been provided. The City could reduce or eliminate parking requirements and promote automobile alternatives to reduce households’ demand for parking, thereby making it more economically feasible to develop multifamily housing in many areas, especially as construction costs continue to rise.
Test Results of Rezoning Scenarios
We analyzed 933 sites to assess whether there was market potential to exceed the capacity claimed in the site inventory should Glendale upzone site inventory parcels more ambitiously than what’s proposed in the housing element. For this analysis, we considered all sites in the inventory, both the sites that Glendale is already planning to rezone and sites where the existing zoning is expected to persist.
We conducted two different tests, using MapCraft pro forma feasibility assessments (for more details, see approach outlined in Test 4) to estimate the market potential on the sites in the inventory. By comparing MapCraft’s market feasible unit estimates to the unit capacity claimed in the site inventory, we were able to identify sites where upzoning may yield more capacity than currently tabulated.
Test 5a – Maximum density of potential upzoned sites
As a first test, we considered the most intense housing options that could be feasibly built on each site. We first identified the array of feasible housing development prototypes on each site, which may include both high- and low-density housing options. In this case, financial feasibility was based on a development project’s prospects of paying more for the site than the current property value.
We compared the housing capacity of the densest of those feasible prototypes to the capacity claimed in the site inventory to determine if further upzoning could yield more capacity.
Across the 933 sites that we analyzed, 790 could be financially feasible for redevelopment at a capacity that exceeded the capacity proposed for the parcel in the site inventory. Of those sites, none were sites slated to be rezoned and all were sites that were not slated to be rezoned. The table and charts below show the resulting estimated units, based on the greatest density of development types that had market potential to displace the existing use, and how that estimate compares to the total claimed units in the inventory.
Table 10: Estimated Units from Max Density of Potential Upzones (Test 5a)
Number of sites where
feasible development
exceeded claimed capacity (%
of all inventoried sites in that
category)
Potential Incremental Units
Identified by Test 5a (Claimed
Units)
Site planned for rezone in site
inventory 0 (0%) 0 (0)
Site NOT planned for rezone in
site inventory 790 (85%) 17,583 (3,330)
*This test was applicable on 100% of the sites we analyzed 1841 of 1910
MAPCRAFT
MapCraftLabs.com 11
Exhibit 3: Estimated Units from Max Density of Potential Upzones (Test 5a)
Test 5b – Maximum feasibility of potential upzoning
We conducted a second test that considered the most financially feasible options. that could be built on each site. As in Test 5a, we considered the array of feasible housing development prototypes on each site. For Test 5b, we compared the housing capacity of the most feasible prototype to the capacity claimed in the site inventory to determine if further upzoning could yield more capacity. Because the most feasible prototype could be lower density than other feasible prototypes, this approach produced more conservative outcomes than Test 5a.
Accordingly, there were 781 sites that had feasible development options with capacity that exceeded what was claimed in the site inventory. Of those sites, none were sites slated to be rezoned and all were sites that were not slated to be rezoned. The table and charts below show the resulting estimated units, based on the greatest density of development types that had market potential to displace the existing use, and how that estimate compares to the total claimed units in the inventory.
Table 11: Results of Test 5b
Number of sites where
feasible development
exceeded claimed capacity (%
of all inventoried sites in that
category)
Potential Incremental Units
Identified by Test 5a (Claimed
Units)
Site planned for rezone in site
inventory 0 (0%) 0 (0)
Site NOT planned for rezone in
site inventory 781 (84%) 11,593 (3,126)
*This test was applicable on 100% of the sites we analyzed 1842 of 1910
MAPCRAFT
MapCraftLabs.com 12
Exhibit 4: Estimated Units from Max Feasibility of Potential Upzones (Test 5b)
Given these results, we believe that there is substantial capacity “left on the table” for sites currently in the site inventory - for both sites already planned to be rezoned as well as sites not expected to be rezoned. But there are opportunities to identify additional parcels where market feasible capacity exists and add those sites to the proposed site inventory.
Viable upzoning opportunities exist in many parts of the city, and we observed concentrations of sites with greater market feasible housing capacity in the Vineyard, Mariposa, Pacific-Edison, and Grandview neighborhoods. These locations may be areas where Glendale could effectively add more market-feasible sites to the inventory by rezoning these sites to allow for denser development.
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MAPCRAFT
MapCraftLabs.com 13
Exhibit 5: Map of Concentrations of Potential Upzoning Opportunities
Key Takeaways:
● Additional capacity could be achieved on the majority of sites in the inventory where market-feasible opportunities to upzone exist. Glendale could consider upzoning parcels already in the inventory to reduce any potential housing production shortfall. ● Comparing results from Test 5a to 5b, it appears that the most financially feasible development options may be less intense than other feasible development options in some cases. For example, for-sale townhomes may be more profitable than small rental apartment buildings with more housing units. For that reason, if the city decides to adjust their zoning, they may consider establishing site utilization minimums so that sites redevelop at higher intensities.
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Krause, Erik
From: Leonora Camner <[email protected]>
Sent: Monday, December 13, 2021 11:50 AM
To: Jason Elliott; Kirkeby, Megan@HCD; [email protected]; [email protected]; McDougall, Paul@HCD; Krause, Erik; Devine, Paula; Najarian, Ara; Agajanian, Vrej; Brotman, Daniel; Kassakhian, Ardashes Subject:
Glendale Housing Element - OFLA comment letter
Attachments: 211119 OFLA HE Letter - Glendale.pdf
CAUTION: This email was delivered from the Internet. Do not click links, open attachments, or reply if you are unsure as to the sender.
I am transmitting this public letter on behalf of Our Future LA.
--
Leonora Camner
(She/Her)
Executive Director, Abundant Housing LA
646-512-2093
515 S Flower Street, 18th Floor
Los Angeles, CA, 90071
*Note - Parking is not available at our office*
We request that candidates do not send us confidential campaign strategy information, including polling data or other information that is not publicly available. 1845 of 1910
Read about the coalition here
1846 of 1910
JOHN JACKSON
November 19, 2021
Glendale City Council
City of Glendale
613 E. Broadway
Glendale, CA 91206
Dear Councilmembers:
Thank you for the opportunity to comment on the process of updating the housing element of Glendale’s general plan. We are writing on behalf of theOur Future LA Coalition regarding the 6th Cycle housing element update.
Why does this matter? Because we face a cascade of housing crises in our region. And while nearly everyone in Los Angeles County feels the crush of our housing crisis, Black and Latino residents feel it more than most:
2 1847 of 1910
● Black households have 1.12% the wealth of white households, and Latino households less than 5% (Federal Reserve Bank of San Francisco)
● Black people make up 8% of the county population, but 33.7% of people experiencing homelessness (LAHSA)
● Even under COVID-related eviction moratoriums, Black and Latino neighborhoods face disproportionately higher eviction threats (Los Angeles Times, UCLA) ● One in four AAPIs pay more than half of their income toward housing costs compared to whites (16 percent), putting many on the edge of financial vulnerability. This segment of the population is considered severely cost-burdened (Crisis to Impact Report, A joint publication of the National Coalition of Asian Pacific American Community Development and the University of California, Los Angeles)
These are the effects of decades of racist policies that we have not eradicated: Restrictive covenants, exclusionary zoning, and redlining made it impossible for Black families to build wealth through homeownership, and result in lower homeownership and higher rents today. The California Constitution’s Article 34 and local “crime-free housing” policies put roadblocks in the way of addressing racial divisions in Californians’ housing affordability and security.
This impact was felt devastatingly during the pandemic, when essential workers living in overcrowded housing were exposed to COVID at work and had no choice but to expose their families at home, leading to disproportionate deaths among Black and Latino people.
Neighborhoods in South and Southeast LA, where nearly 20% of homes are overcrowded (defined as more than one person per room) had COVID rates of roughly 14,000 cases per 100,000 people. Neighborhoods on the Westside, where less than 5% of homes are overcrowded, had rates well under 5,000 cases per 100,000 people. 1 Death rates were similarly
disproportionate -- at a time (January 2021) when the city of Beverly Hills was reporting 21 COVID deaths, and the neighborhood of Brentwood 9, the city of Compton reported 147, and the neighborhood of Westlake 202.
2 In all, COVID-19 mortality rates in LA County were roughly twice as high for Black people (31 deaths/100,000 individuals) and Latinos (29/100K) as for whites (15/100K) (from CGLA).
Of the 3,007 counties in the United States, L.A. County ranks last in housing affordability, overcrowding, and unsheltered homelessness. We are not doing enough to preserve and create homes for working class and lower-income people. The affordable housing crisis, rampant speculation, lack of tenant protections and rent control, and affordable housing shortage have gotten so bad that lower-income Black, Latino and AAPI families are being pushed out of their homes and communities at an alarming rate. At the rate we’re going, next generations won’t be able to live in Los Angeles County.
Los Angeles County is legally required to build 341,000 affordable homes by 2030. To truly address our needs, we need more than double that. At the rate we’re going today, we might build 25,000. That’s 7% of what’s needed. That kind of failure will fall hardest on Black and 2 “We Are Forced to Live in These Conditions’: In Los Angeles, Virus Ravages Overcrowded Homes”, NY Times, 1/23/21 1 “When coronavirus invaded their tiny apartment, children desperately tried to protect dad”, LA Times, 1/29/21 3 1848 of 1910
Latino families, who disproportionately face eviction, homelessness and having to choose between rent and food. Our Future LA demands we not let that happen.
In order to create a better housing future, we must make every neighborhood resource-rich so people can live where they want to live and don’t have to leave their community to find opportunity. The Housing Element must also consider the intersection between housing, public health, and environmental justice. The very communities facing the highest rent burden are often the same communities who bear the brunt of the negative impacts brought on by environmental contamination and exposure to the worst air and soil qualities. For example, in LA County, 75% of active oil wells are located within 2,500 feet of homes, the vast majority of which are occupied by low-income people of color. We must also achieve equitable land use and zoning so that historically exclusionary communities build at greater densities, with value capture, while also ensuring that areas already zoned for density are protected from environmental and spatial racism and displacement pressures. As the region plans for growth, there must be no conversion of wildlife habitat to housing or further development in wildfire hazard areas, as identified by CalFire. We understand that the City cares deeply about these issues, and we hope to offer assistance in addressing them.
As it stands right now, the draft housing element will not meet the City’s goals around equity and affordability. We submit these comments in the spirit of collaboration in order to partner and provide research, grounded data to help in meeting housing needs. We are interested in having a meeting to discuss these comments more.
Our Future LA Housing Element Comments
1. Protections
A. The housing element should expand just-cause eviction protections to cover all tenants and establish a corresponding enforcement program.
B. The housing element should implement a local RSO or strengthen/reduce the annual allowable rent increase for the existing RSO program.
C. The housing element should codify a tenant’s right to counsel in an eviction proceeding.
D. The housing element should create a permanent tenant education program to inform tenants of their rights and how to access eviction defense resources.
E. The housing element should create and implement a tenant anti-harassment ordinance combined with enforcement resources.
2. Preservation
4 1849 of 1910
A. The housing element must do more to prioritize rezoning - with value capture - in high-resource neighborhoods which are transit- and job-rich, including single-family zoned areas. This is necessary to expand affordable housing opportunities while minimizing the impact on existing renters in multifamily-zoned areas.
B. The housing element should exclude parcels containing RSO housing units in the housing element’s site inventory.
C. The housing element should require that no net loss provisions apply to parcels in the site inventory and rezoning program with a monitoring and implementation program.
D. The housing element should institute local programs and funding sources for preservation of existing affordable housing.
3. Prioritization of affordable housing
A. The housing element should utilize a value capture mechanism, such as inclusionary zoning, to locally fund and/or incentivize affordable housing.
B. The housing element should prioritize creation of affordable housing on public land.
C. The housing element should streamline affordable housing production.
D. The housing element should include programs for 100% affordable housing zoning overlays, and should ensure that these overlays apply to high-opportunity areas.
E. The housing element should include programs for 100% affordable housing zoning overlays, and should ensure that these overlays apply to high-opportunity areas currently zoned R1.
4. Site Capacity Assessment
A. The housing element should estimate and report both the likelihood of development and the net new units if developed of inventory sites, both vacant and nonvacant.
Comparison of claimed vs. estimated additional development potential Income
Category RHNA Target
Claimed
Capacity in
Draft HE
NNL Buffer
Estimated
Add'n Dev
Potential in
Draft HE
(45% dev
likelihood)
Recommended
Add'n Dev
Potential
w/20% NNL
Gap in
Add'n Dev
Potential
VLI + LI 5,602 8,053 44% 3,624 6,722 -3,099
MI 2,249 1,664 -26% 749 2,699 -1,950
5 1850 of 1910
AMI 5,574 5,027 -10% 2,262 6,689 -4,427
Total 13,425 14,744 10% 6,635 16,110 -9,475
We estimate that the draft housing element will fall short of the RHNA goal, by 9,475 units of realistic capacity. The City must fairly estimate the likelihood of development for all parcels on the suitable sites inventory.
B. The housing element should report the proportion of sites from the previous housing element’s inventory that were developed during the previous planning period, and HCD-recommended methodologies and data sources should be used in order to conduct a thorough “factors” analysis of sites’ realistic development capacity.
C. The housing element assigns more than 50% of the lower-income RHNA target to nonvacant sites, but should use statistical methods (e.g. surveying a random sample of owners of nonvacant sites) to determine that the sites’ existing uses are likely to be discontinued during the planning period.
D. A buffer of at least 15-30% extra capacity is not included in the housing element site inventory. This capacity buffer is especially necessary in order to accommodate the lower-income RHNA target.
See No Net Loss (NNL) section of 4A.
E. The housing element should not improperly count at least 1,537 units, completed during the 5th cycle, towards the 6th cycle RHNA goal. The housing element should provide a quantitative estimate of the likelihood that in-pipeline projects will be completed, based on historical data, and should adjust the number of in-pipeline units counted towards the 6th cycle RHNA target accordingly.
F. The housing element should commit to a mid-cycle review to verify the housing element’s assumptions about development probabilities.
5. Affirmatively Furthering Fair Housing
A. The housing element should meaningfully increase the concentration of lower-income households in areas of the city where the existing concentration of lower-income households is low.
B. The housing element should meaningfully reduce the concentration of lower-income households in areas with significant exposure to noise/pollution, and commit to reducing/addressing noise and pollution.
C. The housing element should ensure community-serving investment in historically disinvested areas. This includes place-based strategies that create a net gain of affordable housing and 6 1851 of 1910
stop displacement, prioritize environmental justice, enhance community health and strengthen equitable community leadership in land use planning.
D. The housing element should include a thorough analysis of local patterns in socioeconomic/racial segregation and integration, including patterns of overt racial or ethnic discrimination in the housing and land development market.
E. The housing element should adequately prioritize high-opportunity census tracts and well-resourced areas (e.g. near transit, jobs, schools, parks, etc.) when selecting sites for lower-income housing opportunities.
F. The housing element should adequately identify funding sources, public resources, and density bonus programs to maximize the likelihood that projects with below-market-rate units are built.
G. The jurisdiction did not adequately solicit public feedback and commentary on the housing element in a way that accurately reflects the jurisdiction’s socioeconomic makeup.
6. Forecasts of ADU Development
A. The housing element did not use an HCD-recommended safe harbor methodology for forecasting future ADU production.
B. The housing element should provide for mid-cycle adjustments if inventory sites are developed at lower rates, or lesser densities, than the housing element anticipated and if ADU production falls short of projections. Mid-cycle adjustments should automatically implement a by-right density bonus on inventory sites, starting mid-cycle, and be large enough to make up for an ADU shortfall.
C. The housing element should assess the affordability of forecasted ADUs using city-specific data; it instead uses a regional average.
***
We request the opportunity to meet with you and your colleagues to address the concerns raised in this letter. Thank you for your time and consideration.
Sincerely,
Lisa Hirsch Marin
COO, Wellnest, Emotional Health & Wellness
Our Future LASteering Committee Member
7 1852 of 1910
CC: Jason Elliott, Senior Counselor to Governor Gavin Newsom Megan Kirkeby, Deputy Director, Housing Policy Development, HCD Melinda Coy, Land Use and Planning Manager, HCD
Tyrone Buckley, Assistant Deputy Director of Fair Housing, HCD Paul McDougall, Housing Policy Development Manager, HCD 8 1853 of 1910
Krause, Erik
From: Greg Astorian <[email protected]>
Sent: Tuesday, December 14, 2021 7:07 AM
To: Krause, Erik; Asp, Kristen; Zemaitaitis, Vilia; David Kissinger Subject: GAOR Comments : Glendale Housing Element
Attachments: KraussHousingElementFinal-DigiSign.pdf; GlendaleHousingElement.pdf CAUTION: This email was delivered from the Internet. Do not click links, open attachments, or reply if you are unsure as to the sender.
Dear Mr. Krauss: Enclosed please find our letter and comments. Please provide a copy to the Planning Commission as well. Thank you.
Sending you my best regards,
Greg Astorian, CCIM
Government Affairs Director | GAOR
Glendale Association Of Realtors®
C: 818-807-7428
O: 818-409-0040 Ext. 115
E: [email protected]
2016 President Glendale Association Of Realtors®
2015 Realtor Of The Year Glendale Association Of Realtors®
CONFIDENTIALITY NOTICE: Sender intends this e-mail message and any attachments to be used only by the person(s) or entity to which it is addressed. This message may contain confidential and/or legally privileged information. If the reader is not the intended recipient of this message or an employee or agent responsible for delivering the message to the intended recipient, you are hereby notified that you are prohibited from printing, copying, storing, disseminating or distributing this communication. If you received this communication in error, please delete it from your computer and notify the sender by reply e-mail.
1854 of 1910
1855 of 1910
Glendale Housing Element Input.
Glendale Association of Realtors®
Property / Parcel Building
SQFT.
Land
SQFT. Leases
Potential
Units Per
Housing
Element
Report
Type of Units
Per City Report
Not A Good RHNA Candidate.
Here is Why.
APN: 5642-014-952 70,274 229 Low Income The Green Space in Americana containing the Trolly ride, the Fountain, and the public park is perhaps the attraction that is most important to the Americana Draw. Potential covenant in all of Americana Retail leases to be maintained as green space. Also recorded in the condominium
subdivision map for over 152 condos in Americana.
322 Americana Way
43,412 69,670 YES 147 Low Income Movie Theater. Part of Americana at Brand. Potential Long-Term Lease with AMC, the current operator
200 W. Broadway Ave. 140,000 43,560 Yes 75 Low Income Dicks Sporting Goods & Golds Gym. Net Operating Income (NOI) of $2,345Mill per year. Being marketed for sale. If property sold for a CAP rate of 4%, the per square foot price of
land will be over $1,333.00! No developer will pay
such a sum to develop 75 units.
130 N. Central Ave. 41,936 Yes 125 Low Income Owner, Holland Partners, had a development agreement with the city when they purchased the property in 2013.
We believe the agreement was for market rate housing,
not low-income housing as represented in the city report. 1856 of 1910
Glendale Housing Element Input.
Glendale Association of Realtors®
Property / Parcel
Building
Size
Land Size
Leases
Potential
Units Per
Housing
Element
Report
Type of Units
Per Report
Not A Good RHNA Candidate.
Here is Why.
201 W. Lexington Drive 120,000 Yes 390
*Should be
247 Units a
reduction of
143 Units
Low Income The California Community Housing Agency purchased the property at 275 W. Lexington Drive from Cypress Equity
Investments. Note: 494 units. The credit for low-income housing should be 25% to 50% of the number of the
units, or up to 247 units and not the 390 units
represented in the report
232 N. Orange Ave. 91,000 22,798 Parking
Structure
74 Low Income You will have an uprising amongst mid-Brand merchants such as Porto’s, Panera, etc. if the city decides to
demolish 1000+ space parking structure to build 74 units! 225 W. Broadway Ave. 122,000 76,665 Yes 250 Low Income Occupied by tenants. IRS and Social Security Admin are the two largest tenants. IRS lease ends 4 years in this RHNA cycle. Unless sure that IRS won’t renew and or has no
options to renew, the report’s assumption of 250 low-
income units should be revised.
300 S. Central Ave. 9,921 25,987 Yes 85 Low Income Chase Bank and Shoe City are the tenants. Owned by Caruso Affiliated. Renovated in 2011. Leases started 2011
1857 of 1910
Glendale Housing Element Input.
Glendale Association of Realtors®
Property / Parcel
Building
Size
Land Size
Leases
Potential
Units Per
Housing
Element
Report
Type of Units
Per Report
Not A Good RHNA Candidate.
Here is Why.
APN: 5642-006-064 43,074 49,268 YMCA 161 Low Income Historic Landmark. Four-story Spanish Colonial Revival building. YMCA Building. Note: Part of the property on the Kenwood Ave. side was already developed (Ace 121).
APN: 5643-001-912 211,286 85,339 Altana
Apt. Bldg.
278
*Reduction of
25 units
Low Income Altana was built in 2016. 507-unit apartment Bldg. The California Community Housing Agency purchased the
property. The credit for low-income housing should be
25% to 50% of the number of the units, or up to 253 units and not the 278 units represented in the report.
APN: 5643-003-047 27,007 88 This parcel number does not exist in Assessor’s data base 6136 San Fernando Rd. 31,363 Water
Treatment
Center
13 Low Income More explanation needed
Adjustment (1,415) Units
1858 of 1910
From: Anthony Dedousis
To: Krause, Erik; Brotman, Daniel; Agajanian, Vrej; Devine, Paula; Najarian, Ara; Kassakhian, Ardashes; Golanian, Roubik
Cc: Jon Wizard; Leonora Camner
Subject: Comment letter - Glendale draft housing element Date: Friday, November 19, 2021 10:29:57 AM
Attachments: 211119 Glendale Draft HE Comment Letter.pdf CAUTION: This email was delivered from the Internet. Do not click links, open attachments, or reply if you are unsure as to the sender.
Dear Councilmembers and Planning Staff:
I'm reaching out to share a letter from Abundant Housing LA and YIMBY Law commenting on Glendale's draft housing element. We have major concerns about the City's intended approach to updating the housing element. We believe that the City's intended approach does not satisfy the intent of state law, which is to expand housing availability at all income levels.
Of particular concern is the improper counting of at least 1,537 housing units, completed during the 5th cycle, towards the 6th cycle RHNA goal. It is completely unacceptable that the City has double-counted these buildings towards its 6th cycle RHNA goals.
The attached letter contains a detailed explanation of where we view this effort as having fallen short of HCD's standards and state law. We respectfully request the opportunity to discuss our concerns with you. Thank you for your consideration.
Regards,
Anthony Dedousis
--
Anthony Dedousis
Director, Policy and Research
Abundant Housing LA
515 S Flower Street, 18th Floor
Los Angeles, CA 90071
516-660-7402
We request that candidates do not send us confidential campaign strategy information, including polling data or other information that is not publicly available. 1859 of 1910
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1892 of 1910
From: Karen
To: Krause, Erik
Cc: [email protected]; Devine, Paula; Agajanian, Vrej; Brotman, Daniel; Kassakhian, Ardashes; Najarian, Ara; Zovak, Peter
Subject: 6th Cycle Housing Element Draft for Glendale, CA--comments Date: Tuesday, November 30, 2021 2:59:26 PM
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Dear Mr. Krause,
Here are my comments on the City of Glendale's Housing Element draft for the Sixth cycle, 2021-2029.
Let's begin with the positive.
1) I appreciate the inclusion of Program 5B, "Tenant/Community Opportunity to Purchase" or TOPA/COPA. I have spent a good deal of time this year talking about TOPA, which is a tenant-led initiative.
However, the Program Goals section fails to mention that these purchases are happening already, with the assistance of community land trusts. It also fails to note that it would actually cost the city nothing to pass a TOPA ordinance, to inform tenants that their buildings have been offered for sale; funding sources to assist tenants with these purchases and converting them into tenant-led, limited equity co-ops can be explored separately. It also fails to mention critical reasons why this proposed ordinance is attractive to tenants—namely, that it would secure permanently affordable housing and enable us to build equity. Building equity would help reduce the racial wealth gap, because most household wealth in this country is in the form of housing. As of 2020, 75% of white people are homeowners, whereas the majority of Black people are renters.
And now for the disappointing elements.
2) Consider this extraordinary statement on pdf page 216:
“The City finds that there are no known historic patterns of segregation by race and ethnicity, persons with disabilities, familial status, age, or income.”
As noted by Ms. Tara Peterson on November 15, this sentence completely contradicts the Sundown Town resolution passed by the City Council on September 15, 2020, which acknowledges the historical redlining and racist housing practices of this city. This resolution specifically noted realtors’ ads on “Keeping Glendale 100% Caucasian.”
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The Programs 7A and 7C on Fair Housing make no mention of the fact that Black people are 2% of Glendale's population, compared to forming 8% of LA County. The absence of Black people in Glendale is a clear indicator of discrimination, especially in light of Glendale's Sundown Town resolution. In addition to investigating discrimination against residents who already live here, there should be an investigation of how Black people are kept out of the city in the first place. For example, national studies show that Black people are less likely to be shown apartments by landlords, and they are quoted higher prices for the apartments that are shown to them.
Although I appreciate the lack of local prejudices that an out-of-town consultant can bring to this subject, Glendale residents know exactly where income segregation occurs —the 134 highway. Although there are exceptions, “north Glendale” means rich (white) homeowners and “south Glendale” means poor renters (of color).
One wonders if the Planning Department staff have read the Sundown Town resolution, and whether this information was conveyed to the consultant from Orange County.
Also, the “race/ethnicity” section fails to recognize the large number of Armenian people in Glendale, who form approximately 40% of the population; surely, they can be separated from the general White category in the same way that the Hispanic population is often separated into "White Hispanic" and "Non-white Hispanic" groups. This fact might be unfamiliar to an out-of-town the consultant, but it is surely known to members of the Planning Dept. Armenian tenants I’ve talked to are motivated to stay in Glendale so that they can remain part of this significant community.
3) There is a wealth of data in the Background Report section, including the following facts:
·
Tenants are 67% of the residents of Glendale
· 57% of tenants are rent-burdened, paying more than 30% of their income in rent
·
35% of tenants are paying more than 50% of their income in rent
This represents tens of thousands of people in economic pain. These numbers are substantially the same as in the 5
th Cycle Housing Element, indicating zero progress in
meeting their needs. And in spite of this abundant data, the meager programs offered in Part 1 of this 6
th Cycle draft don’t even acknowledge this great need, much less attempt to meet it.
May I also point out that the more money tenants spend on rent, the less money we have to spend at other businesses in the city. The interests of landlords and developers are, therefore, often in conflict with those of other area businesses. Perhaps this inherent conflict should be acknowledged by separating the Housing Dept from the rest of 1894 of 1910
Economic/Community Development.
Goal 2 “A city with high quality residential neighborhoods that are attractive and well designed” is given prominence, however. Although rent-burdened tenants have no objection to good design, it is hardly in our top 10 list of priorities. My fellow tenants who sometimes watch Design Review Board cases with me regard them as “rich people problems,” as in “So this is how people fill their time when their basic needs are met.” “Good” design is a priority for affluent homeowners, who form a minority of this city.
Also, in light of Glendale’s historical racism, people of color have very different views on which elements of Glendale’s neighborhoods should be retained and which need to be changed.
4) Review of the 5th Cycle Housing Element. Glendale built 4,493 units in 2014-2021, but 4,131, or 92%, of those were above-moderate, market-rate homes. Glendale did not even come close to meeting the need for housing at lower income levels (362 of 1,155 units, or 31%). This city is not building the right kinds of housing for the people who live here.
The oversupply of above-moderate, market-rate housing shows wishful thinking along the lines of "If we build it, they will come"; considering that the need for lower-income housing has increased considerably since 2014, and that the median income of Glendale renters is $50K, I would conclude that higher-income renters have largely chosen not to live in Glendale, perhaps because there are other, more attractive options in LA County for them.
The attitude of Glendale city officials toward lower-income people seems to be, "If you can’t afford the rents here, you should just move out," rather than attempting to meet our needs. City officials clearly have extraordinary amounts of time to spend discussing the small design details of other people’s private, single-family houses, however.
And here are the elements that are completely missing.
5) As I noted on November 15, Appendix B on Public Engagement lists over 260 developers as stakeholders but completely omits the Glendale Tenants Union (GTU), the sole group that represents the 67% of the residents of Glendale who are renters.
This is a curious omission because I have spent the better part of this year working with the Coalition for an Anti-Racist Glendale and GTU to lobby the City Council to create a Tenant-Landlord Committee, precisely because tenant voices routinely go unheard. The senior Housing Dept staff are also aware of GTU; Mr. Peter Zovak sent us an email about the Housing Element survey in April.
This leads me to wonder if the Planning Dept. spends much time talking to the Housing staff or to the City Council.
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The message is clear, however, that the concerns of developers and affluent homeowners are given a great deal of attention by the city, while the concerns of renters are brushed aside or ignored entirely.
The City of Pasadena formed a task force for the Housing Element, with at least one tenant member who was appointed by the mayor. If the City of Glendale wanted to include diverse community voices in this draft, they could have found more effective ways to do so, beginning in the early stages.
I noticed that “Abundant Housing LA,” formerly known as YIMBY, is listed as a stakeholder, although they do not operate in Glendale. I met a gentlemen from this group, and this homeowner in LA was surprised to hear that our range of tenant concerns went well beyond that of mere housing supply.
Here are some of the elements that tenants would like to see included in this report:
Rent Stabilization. From reading this 410-page document, one would have no idea that thousands of tenants spent years advocating for rent stabilization in Glendale. Although our ballot measures did not pass (yet), the wishes and efforts of thousands of residents should at least be acknowledged, instead of erased. This effort is well known to the Glendale City Council.
Right to Counsel. Tenants should be guaranteed a right to legal counsel in eviction cases, the same way the Sixth Amendment guarantees the right to counsel in criminal cases. In LA County, there are sufficient nonprofit lawyers to represent tenants in only 12% of eviction cases, and 98% of tenants who arrive in eviction court without a lawyer lose their cases. Therefore, the lack of tenant-side lawyers virtually guarantees that laws will not be enforced on landlords who break the law. Several cities have passed Right to Counsel laws, including New York City, which saw a decline in eviction cases after they passed this law. Landlords are filing fewer frivolous eviction cases, from the deterrent of knowing that tenants will have legal representation. This benefits the legal system in general, as well as tenants in particular.
Anti-Harassment Ordinance. During the pandemic, harassment against tenants in LA County soared by 300% or higher. The City of Los Angeles recently passed an anti- harassment ordinance and it would be fairly easy to adopt a similar measure for Glendale.
6) The pandemic is not discussed in this draft. Large segments of the population have been completely re-thinking their approach to housing and work, in light of changes made during the pandemic. Many people would prefer to work from home permanently, and many parents have felt the need for assistance with balancing working from home 1896 of 1910
and educating their children. From pdf page 116: “The creation of innovative housing for female-headed households could include co-housing developments where childcare and meal preparation responsibilities can be shared.”
We could begin studying different forms of social housing, because not everyone wants to live in an individual box, separate from other people. The goal of some people is to create an integrated community, as opposed to maximizing the amount of profit that can be made from each individual box.
Although we are still in the midst of seeing these pandemic-inspired changes, this shift should at least be noted and studied; otherwise, this report runs the risk of becoming obsolete almost immediately after it is approved.
Conclusion: Major Revisions Needed
In conclusion, my opinion as a professional editor is that this draft reads like a document that was cut and pasted from other housing elements, with small modifications to adapt to this particular time and city. It was written in a vacuum, by authors who sat studying maps and spreadsheets in an attempt to meet minimum requirements. It displays significant errors and gaps in relevant knowledge, and very little effort to solve the serious problems of the people who live here.
To adopt a phrase from my many years in scientific publishing, I would return this draft to its authors for “Major Revision.” That is, the draft requires not simply minor revisions to its organization and language, but a substantial re-thinking of its methodology, data, analysis, and conclusions.
Sincerely,
Karen Kwak
Glendale, CA
P.S. I am copying the City Council because policy decisions always rest with them. I would also like to thank Mr. Najarian for pointing out that this draft was prepared by a consultant from Orange County.
1897 of 1910
From: Tara Peterson
To: Krause, Erik
Subject: Housing Element Public Comment
Date: Tuesday, November 30, 2021 4:09:22 PM
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Dear Erick Krause,
YWCA Glendale and Pasadena requests the Housing Element Planning Committee to engage the local community and advocacy organizations to address the historical and present-day racial inequities impacting the lives of women and girls in Glendale as part of the 6th Cycle (2021-20219) Housing Element Update.
The City of Glendale is the fourth largest in Los Angeles County. Census data stated the Black population in Glendale in 1920 was 0.16 percent, and in 2019, it was only 1.6 percent. The low population percentages result from historical anti-Black practices as acknowledged by the City on September 15, 2021, with the passing of a Sundown Town Resolution.
The disparate outcomes from these discriminatory housing programs reflected today include American Indian, Black, and other People of Color facing significant income inequality, poor health outcomes, exposure to environmental pollutants, low homeownership rates, high eviction rates, and poor access to healthy food, quality, and well-resourced schools, and infrastructure. In the 6th Cycle (2021-20219) Housing Element Update we urge you to develop and implement a new, community-driven goal, Goal 6 Racial Equity. The City has acknowledged unjust and unequal practices. Now is the time to address housing discrimination against communities of color as a root cause for disparate outcomes.
YWCA is an organization that relies on effective housing advocacy for women experiencing domestic violence. We work to advance racial equity through systems change approach and address the root causes of housing inequities. We recognize that affordable, safe, and accessible housing is key to achieving economic vitality through this approach.
Racial equity is "both an outcome and a process." Racial equity prioritizes ensuring people of color have the opportunities they have historically been denied and from which they continue to be excluded (Reyes, 2021). Housing planning is critical to ensuring women and children have a safe and permanent home.
Through YWCA advocacy and services, we see how Black women and other women of color are discriminated against and harmed by systems, laws, and policies supposed to provide access to housing. At the same time, we rely on those very same systems and their 1898 of 1910
implementation to aid so many of the more than 2,000 women, children, and families that we serve each year. We need to work together to ensure no family faces housing discrimination, in particular racial discrimination, in our city.
The 6th Cycle (2021-20219) Housing Element Update must:
Amplify and prioritize BIPOC families in the City's engagement process, removing all barriers to civic engagement.
Establish community-driven goals and policies for City officials to identify the City's existing and projected housing needs.
Operationalize the City's commitment as the Sundown Town Resolution stated. Thus, reviewing and revising its policies, procedures, ordinances, values, goals, and mission through an anti-racism lens fosters an unbiased and inclusive environment free of discrimination and harassment toward any person or group.
Measure racial and social equity in each step of the planning process for housing. Assess and pursue ways to achieve beneficial outcomes for American Indian, Black, and other People of Color.
Develop strategies to repair the harm of historical racial, ethnic, and other social discrimination for Black, Indigenous, and People of Color.
Develop strategies to strengthen racial and cultural anchors and increase housing opportunities to build wealth.
Additionally, in September 2021, Governor Gavin Newsom signed 31 affordable housing bills focusing on four areas:
Streamlining the building of new homes.
Breaking down barriers to build more affordable housing.
Addressing systemic bias by elevating fair housing principles.
Holding local governments accountable under the new Housing Accountability Unit (HAU) at the California Department of Housing and Community Development (HCD).
The Housing Element Planning Committee, in a community-driven consultation process, can review the Technical Elements of Inclusionary Housing Policies and Practices, shown in Appendix A and that include the following highlights:
Choose income targets for the affordable units that match those of renter households of color. Most inclusionary housing policies have tended to serve households earning between 60% and 120% of Area Median Income (AMI). But in many communities, renter households of color are disproportionately represented in lower-income groups below 60% of AMI.
Require or encourage the construction of unit sizes that match the household sizes of renter households of color. In some communities, new market-rate multifamily development is largely composed of smaller units— studios, one-bedrooms, and two- bedrooms. But low-income renter households of color may have disproportionately 1899 of 1910
larger household sizes; for example, people of color are more likely to live in multigenerational households than White people.
Adopt building design standards to avoid stigmatizing residents of affordable units:
When people of color, regardless of their economic status, occupy buildings with predominantly White residents, they may experience "othering" or micro- aggressions from their neighbors, such as cold-shoulders, blame for noise, or suspicions about property damage.
Consider the use of city subsidies to advance racial equity goals. New market-rate development tends to occur in high-opportunity areas from which people of color have been systematically excluded and are often unable to afford. In communities with stronger housing markets, inclusionary housing is an effective tool to provide affordable homes in high-opportunity areas. But in communities with less strong housing markets, it may not be financially feasible for developers to include affordable units in new market-rate development.
Base the decision about compliance alternatives on the needs and preferences of households of color. Some people assume that requiring affordable units to be built "on-site" with market-rate units is the best way to advance racial equity. If a primary policy goal is to ensure that affordable units are built in high-opportunity neighborhoods from which people of color have been historically excluded, on-site development is by far the most straightforward way to achieve that goal.
As the Housing Element Planning Committee may identify, YWCA Glendale and Pasadena is pleased to support a community-driven process that advances racial equity in the 6th Cycle (2021-20219) Housing Element Update. We look forward to receiving your prompt reply.
1900 of 1910
From: Brigid McNally
To: Krause, Erik
Cc: Najarian, Ara; Kassakhian, Ardashes; Devine, Paula; Agajanian, Vrej; [email protected]; [email protected]; [email protected]; Brotman, Daniel Subject: PUBLIC COMMENT: 6th Cycle Housing Element Draft for Glendale, CA Date: Tuesday, November 30, 2021 4:03:51 PM
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Dear Mr. Krause,
I am writing as a concerned resident of Glendale regarding the recent 6th Cycle Housing Element Draft.
I am curious and, quite frankly, concerned that the outreach efforts for this Housing Element Draft did not include Glendale Tenants Union considering that the draft itself states that renters comprise
67.8% of Glendale households. This makes renters the super-majority in Glendale and from all of my research appears to be the highest per capita renter city in all of California. So, why then was the only organization in Glendale dedicated to supporting and advocating for the renter population not consulted or flagged as “stakeholders” yet numerous developers were? With deliberate choices like this, it is not difficult to see the power that monied interests have over housing decisions in the City of Glendale.
I am duly concerned with the City of Glendale’s intended actions and policies potentially arising from this Housing Element Cycle-- or the likely lack thereof. Glendale did not meet our lower income housing goals from the 5th Cycle Housing Element, yet we exceeded moderate-upper income housing, (essentially market rate housing) by 500%. That is preposterous and, once again, demonstrates that the City of Glendale's primary interest is appeasing wealthy developers.
I attended the "Housing Element Virtual Community Meetings" that was held via Zoom earlier in November. During the meeting, the presenters of the event were already engaging in dishonest manipulation of the data to hide the reality that Glendale has woefully under-supported our lower income communities. What assurances are we, as residents of Glendale, being afforded by the City of Glendale that this Housing Element Cycle will prove anything more than the lip service that the previous element proved to be?
These housing element updates are required by the State of California, not as a means of simply wasting taxpayer dollars to pay consultant firms that operate outside of the city or county itself to make 300-page reports and Powerpoint Zoom presentations, but rather so that the City is forced to consider whether it is meeting the needs of its residents. It is clearly not.
The only consideration put forth by this current draft that holds any weight or demonstrates any interest by the City of Glendale to properly support its super-majority renter population is the interest in exploring a Tenant Opportunity to Purchase (TOPA). I would like to highlight that the goal should be implementation rather than exploration of these policies. I would like to flag that studies regarding these TOPA policies already exist and robust policies have been developed for municipalities across LA County. I hope that the City of Glendale chooses to connect with currently existing Community Land Trust organizations when exploring the possibilities of TOPA policies here in Glendale rather than privatized consultant firms based in Orange County or elsewhere. Here is a link for ease:
https://www.cacltnetwork.org/
I am CC'ing officials who represent the interests of Glendale residents at the local and state level in the hopes of directing their attention to the woeful inadequacy of the City of Glendale's approach to their constituents' housing needs.
Thank you.
Best,
Brigid McNally
1901 of 1910
From: Rondi Werner
To: Krause, Erik
Cc: Zemaitaitis, Vilia; Asp, Kristen; Stephen Meek
Subject: Draft Housing Element Comments
Date: Tuesday, November 30, 2021 5:56:50 PM
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Hello Erik,
As a longtime resident and homeowner in Glendale with some experience in the land use arena, I would like to weigh in on the Draft Housing Element on behalf of the Adams Hill Neighborhood Association.
First, we are glad that no additional up zoning is required in order to meet the RHNA numbers. Past up zoning has resulted in the overdevelopment of market rate units, leaving very little land left for affordable housing.
As I mentioned during the November 15 Community Meeting, the Housing Plan should remove offensive, dehumanizing language such as “handicapped” and “the homeless” to refer to people with disabilities or to people who are experiencing homelessness.
The Draft Housing Element seems lacking in providing/addressing the following:
The list of “Surplus City-owned lands” that the City has earmarked for possible affordable housing development.
Where is the “Opportunity Area Map?”
Which locations are considered “Underutilized Mixed-Use Sites” One of the Goals is “A City with Housing that is Livable and Sustainable” but the Housing Element does not provide specifics on how we might encourage sustainable building practices. Given that construction is a major contributor to climate change, the Housing Element should provide actionable and measurable requirements.
What are the Quality of Life Improvements for Neighborhood “Target Areas" as alluded to in “Program 2D.”
Past Housing Elements have touched on the need for more Open Space and Recreation Areas, but the shortfall is getting worse instead of improving. the Plan should outside specific steps on how the extremely park starved areas of the City will be addressed.
What are the specifics on how they plan to achieve “Goal 2: High quality residential neighborhoods that are well designed” amidst intensified streamlining that limits design review.
How we can prioritize affordable housing when mandates like SB9 don’t require that housing be affordable?
In the November 15 Community meeting, someone commented on single room occupancy units (SRO) being only in hotel/motel zones. We are very much against allowing SRO development in residential zones. Cities such as New York experienced increases in crime in the SRO developments to the point that NYC incentivized developers to replace these crime magnets with other types of developments.
The Housing Element should focus on design equity for affordable units instead of allowing 1902 of 1910
people of limited means to be relegated to substandard living conditions.
Given that the City has a long record of overdeveloping market rate units, the Housing Element should include mandatory requirements that new multi-family housing contain high quality affordable housing. Affordable housing should not be made substandard through multiple concessions and incentives that degrade the quality of life for residents in and around the developments.
Thank you for your consideration.
Rondi Werner, CSI, CCS, CCCA, CDT, LEED GA, AIA Allied Vice President, Glendale Homeowners Coordinating Council Vice President, Adams Hill Neighborhood Association
[email protected]
| (818) 415-4832 mobile
1903 of 1910
From: Mike Van Gorder
To: Housing Elements@HCD; Amanda Tropiano; Lanzafame, Philip; Najarian, Ara; Brotman, Daniel; Devine, Paula; Agajanian, Vrej; Kassakhian, Ardashes; Krause, Erik; Zemaitaitis, Vilia Subject: Public Comments on Glendale"s 6th cycle HE draft Date: Friday, December 03, 2021 1:28:28 PM
Attachments: Glendale HE Response - Mike Van Gorder.docx CAUTION: This email was delivered from the Internet. Do not click links, open attachments, or reply if you are unsure as to the sender.
Hello Mr. Krause,
I’m providing you, the city council, and my fellow housing element reviewers my feedback on the Glendale 6th Cycle Housing Element Draft. In that I was not assigned the city’s element in my official workload, I am free to provide this feedback from the perspective of a private citizen and concerned Glendale tenant, as somebody that wants to raise my family here but who sees virtually no options available should that family grow at all. I hope you will carefully consider them moving forward.
Quick notes:
The draft claims that Glendale has ‘no history of economic segregation’, despite providing a map that shows such economic segregation
It claims Glendale has no history of racial segregation, despite the city council’s extraordinary acknowledgement by ordinance of Glendale’s history as a ‘Sundown Town’
The draft claims that the city can exclusively produce affordable units in the downtown area, and that such an availability means their RHNA targets are all satisfied; however, considering realistic development reduces the projected yield of low-income sites from a surplus of 2,451 to a deficit of -2,940
An analysis of the thirty three downtown sites claimed reveals only five sites that suggest developability, further reducing the low-income yield to a deficit of -3,580 The draft misunderstands “Affirmatively Furthering Fair Housing” as ‘responding to fair housing complaints’, rather than “acknowledge a history of racist housing policy to create opportunities for underserved communities in both low-resource and high- resource areas”
The draft claims to meet RHNA goals without needing to upzone anywhere, yet due to the above figures it does not meet the goals, and upzoning wealthier neighborhoods is a key part of Affirmatively Furthering Fair Housing
The report acknowledges Racially Concentrated Areas of Affluence without analysis and without mention of an intent to create low-income opportunities therein Public participation occurred after the draft was submitted to the state in violation of HE requirements
The Housing Element Draft is certainly noncompliant with state law and is, at its worst moments, a tone-deaf attempt to maintain a broken status quo There is much deeper analysis of each of these elements in the document attached.
Thank you kindly!
1904 of 1910
Analysis of the 6th Cycle Glendale Housing Element Draft Mike Van Gorder
Quick Notes
• The draft claims that Glendale has ‘no history of economic segregation’, despite providing a map that shows such economic segregation
• It claims Glendale has no history of racial segregation, despite the city council’s extraordinary acknowledgement by ordinance of Glendale’s history as a ‘Sundown Town’ • The draft claims that the city can exclusively produce affordable units in the downtown area, and that such an availability means their RHNA targets are all satisfied; however, considering realistic development reduces the projected yield of low-income sites from a surplus of 2,451 to a deficit of -2,940
• An analysis of the downtown sites claimed reveals only five sites that suggest developability, further reducing the yield to a deficit of -3,580
• The draft misunderstands “Affirmatively Furthering Fair Housing” as ‘responding to fair housing complaints’, rather than “acknowledge a history of racist housing policy to create opportunities for underserved communities in both low-resource and high-resource areas” • The draft claims to meet RHNA goals without needing to upzone anywhere, yet due to the above figures it does not meet the goals, and upzoning wealthier neighborhoods is a key part of Affirmatively Furthering Fair Housing
• The report acknowledges Racially Concentrated Areas of Affluence without analysis and without mention of an intent to create low-income opportunities therein • Public participation occurred after the draft was submitted to the state in violation of HE requirements
• The Housing Element Draft is certainly noncompliant with state law and is, at its worst moments, a tone-deaf attempt to maintain a broken status quo Analysis
The city housing department prides itself on being more productive than all its neighbors but falls into the exact same trap as it did in the 5
th cycle – overproducing market rate units and failing to meet every other target below 120% Area Median Income. This Housing Element Draft will be noncompliant with state law.
The RHNA Shuffle – Core to the city’s comfort level with the draft element they’ve produced is the idea that they’ve found enough sites to accommodate their RHNA – and without the need for upzoning. The city notes 33 parcels in the Downtown Specific Plan as being “extremely feasible for redevelopment” but does not elaborate very well what criteria they use to determine this. [I have analyzed the sites in question and have determined that this is in bad faith, as some of these sites are recently built luxury apartments, some are long-serving faith institutions, and most show no signs of being “extremely feasible”. This analysis is at the end of my comments.] They then assign the entirety of “assumed capacity” of all such parcels to the production of lower-income units, thereby justifying their claim of 5,038 low-income unit sites in the RHNA, which then is used to defend a lack of RHNA siting for all other lower-income categories.
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No project in the downtown area has been 100% affordable, and expecting thirty-three consecutive such projects is unrealistic and smacks of bad faith. Per AB 1397, a site chosen for the housing element must consider the “realistic development capacity for the site” and the “typical densities of existing or approved residential developments at a similar affordability level in that jurisdiction”. The city failed to do this and claimed that every developable unit in every site in the downtown area would be developed and would be affordable. In reality, the only measure of affordable units in south Glendale has been inclusionary zoning. If we go off such inclusionary zoning measures, then the best we can expect is 15% of total produced units to be low income. Therefore, to reflect likelihood of development, the city must reduce the 5,038 units for its Low-income RHNA to 755. The assumed surplus of +2,451 low-income units in the RHNA will drop to a deficit of -1,832.
The city assumes that mixed use sites will only accommodate low-income units. Based on likelihood of development, this 1,303 number must in good faith be reduced to 195. The city assumes that “residential sites” – by which we are led to understand means single-family zoned areas – will only accommodate above moderate-income units. This lets them maintain the idea that no upzoning is necessary, because according to their misleading accounting of the downtown development capacity the city’s lower-income RHNA will have a 2,451 surplus. However, a far more honest (and legally compliant) number would incorporate likelihood of development – and be reduced to a deficit of -2,940.
The city claims that moderate and above moderate unit demand will be satisfied with the surplus from low-income category. Without considering the market distortion of offering units intended for low-income households to above-moderate income households (which the city should do if it intends to Affirmatively Further Fair Housing), accounting for the likelihood of development means that there will again be a massive surplus of above moderate-income sites and a huge gap for low- and moderate- income units. The city must find such sites elsewhere.
Furthermore, this 15% inclusionary-zoning estimate of affordable unit yield is charitable. The “proposed projects” section outlines housing projects currently under review, and gives us a far bleaker image of likelihood of development:
o ELI/VI – 19 units, or 3.7% of its RHNA target
o LI – 1 unit, or .05%
o MI – 15%
While this bodes slightly better for the agonizing ‘missing middle’ that is dramatically pronounced in the city’s housing portfolio, it suggests that less than five percent of housing development will be affordable to lower-income households. Taking real-world expectations into account, this is a failure to meet RHNA obligations. The city must find more sites or upzone more areas.
The presentation repeatedly mentioned that, “we didn’t have to upzone anywhere in order to meet our RHNA!” but this seems more like a desperate attempt to soothe twitchy homeowners than a wise or realistic goal.
Affirmatively Furthering Fair Housing – The legislative intent of AB 686, affirmatively furthering fair housing, is acknowledging that our housing systems were developed to protect and enrich some communities at the great expense of others. To affirmatively further fair housing, we need to see the physical development of our cities and neighborhoods as more than some inevitable force that 1906 of 1910
miraculously deposited older, whiter homeowners in the hills and everyone else scrunched together in between malls and auto dealerships. This draft housing element completely fails to affirmatively further fair housing because its concept of AFFH is “responding to housing discrimination complaints”. There is a difference between AFFH – which is acknowledging an ugly and lopsided economic history as essential toward creating opportunities for underserved communities – and housing discrimination, “fair housing” issues. This is mirrored in the city’s use of outdated Analysis of Impediments, and not the legally required Assessment of Fair Housing. The Analysis of Impediments as is provided is merely a laundry list of problems without any real analysis as how to resolve them. There is no calculation for goals, histories, or community participation. The housing department wants to identify poor areas and ‘replace segregated living patterns’, an empty quotation from AB 686. It does not mention wealthy areas, nor their role in maintaining segregative poverty.
The city cheerfully claims that there is not economic segregation in the community, referring to a chart (page 197) that absolutely demonstrates economic segregation in the community. Average income for a homeowner in Glendale is $116K and average income for a renter is $50K; there are virtually no opportunities to rent in the Kenneth Village, Sparr Heights, San Rafael, and other hilly R-1 neighborhoods. The lack of racial and economic analysis as to why this is the case – particularly after acknowledging without follow up that the city has Racially Concentrated Areas of Affluence – is a glaring failure toward the legislative intent of Affirmatively Furthering Fair Housing.
The draft bafflingly claims that there is no historic patterns of segregation by race and ethnicity.
Glendale city council recently acknowledged via ordinance the city’s history as a Sundown Town, a deeply redlined, racially segregated whites-only community that endured only until the Fair Housing Act.
The afterlife of all that segregation remains in the form of the R-1 neighborhood and the incomes of homeowners being 2.32 times higher than renters. This housing element does not acknowledge or analyze Glendale’s segregative and racist housing history and thus does not satisfy the requirements of AFFH.
This is physically borne out as the city continues to rely on its most modest areas to create any increase of density. I disagree that ‘affordable units are well dispersed throughout the community’, as is claimed under ‘Future growth need’. Any predominately single-family neighborhood will offer only such ADUs as are not inhabited by members of the primary homeowners’ families – this is not ‘well dispersed’, it is an abdication of responsibility.
In terms of displacement risk, new development may not have an immediate and quantifiable effect on displacement, as is claimed. Though, of course, the residents of the apartments that were recently bulldozed to make room for the college’s Garfield parking lot might disagree. But certainly failing to provide real low-income options – 0 units of ELI during the 5th cycle, half of what was needed for VI, two-thirds of what was needed for LI, and barely over 5% of what was needed for MI – means that any displacement is permanent. 31 affordable units were created under the city’s density bonus ordinance, and 18,414 applications came in for them. Low-income residents had a .16% chance of “winning” an affordable home! This, to the city council and the housing department, is ‘progress’.
Figure 6 shows where the RHNA allocation will go in relation to racial diversity, and claims that proposed lower-income RHNA sites are going into places of high diversity, with no sites going into areas of lower diversity. This is not integration. Our most diverse places are our more modest neighborhoods, 1907 of 1910
and Racially Concentrated Areas of Affluence are lower-diversity places that NEED racial and economic integration. That is the point.
Public input – This draft element was only made available to the public after it was submitted to HCD. But! Not before there was deep consultation with private housing developers. This flies directly against HCD requirements for public engagement. The take on access to opportunity in 7C is “we’ll try to find some poor people to serve on government boards” and then immediately undermines that with “as positions are made available”. Lower income folks do not have as much time! And why would “the community” participate in planning – like this – if their input is only solicited AFTER the draft has been submitted to the state? In keeping with AFFH, we need to recognize different communities. Older, whiter homeowners have far more ability to participate in local government and neighborhood-defining activity than others. That means adjusting the process to suit the more challenging schedules and elevated needs of the people who cannot as easily participate. We need to meet our working-class communities where they are, on their terms if we hope to benefit from their experience.
Weak Language – Goals are listed as being “considering” programs like tenant opportunity to purchase. Shouldn’t the goal be to create that kind of ordinance? In 3D the city vows to “continue to work with and identify”, which has no actionable goal. In 7C, “efforts may include”. In 2E “consider and implement other creative solutions”. 1F has “evaluate potential incentives”. These are weasel words.
They are not goals, they’re feints.
Parking, still - what did the city do with the destruction of the Glendale College Naturally Occurring Affordable Housing-to-parking-lot units? Were “replacement” units provided at identical rents? What happened to those tenants? Adaptive reuse must include parking lots, and to address our glut of parking lots, we need to institute parking maximums. The city is overparked. In 3E, parking is blamed for the lack of development in commercial zones in the city. Why is parking required at all? Siting Problems – The downtown specific plan sites form the core of the city’s argument that the RHNA is satisfied. They list 33 sites and claim that they are ‘extremely feasible’ for redevelopment.
According to AB 1397, if the city relies on non-vacant sites to meet 50% or more of its lower-income RHNA targets, it must supply substantial evidence that the present uses will end during the eight-year housing cycle. It does not provide this evidence.
And anyway, the account of thirty-three “good” sites is simply not true. I count five sites that are good candidates for development and eighteen that are absolutely not. Five out of thirty three sites drops our downtown RHNA unit potential to 15% of what was initially projected – 736 units, from 5,038.
If we calculate inclusionary zoning as being the sole reliable means of developing affordable housing on these sites, then we get 115 units of affordable housing. Adding this to our other demonstrated gap gives the city a -3,580 deficit in low-income units.
First, the good choices.
• 406 E Colorado is a small commercial building that is home to a medical center. It is underutilized, sandwiched between two habitually empty parking lot strips, and seems likely for renovation.
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• 503 E Colorado is a pet grooming store, one of two active units on an underutilized strip mall, the other two units of which have been empty for years. I’m not sure why this address is on the list and not the other three.
• 124 Maryland – now Artsakh Ave – is part of a massive commercial complex with a huge dine-in movie theater. I believe 124 is the theatre, which just reopened under another brand name after being shut down by the pandemic. There are a half-dozen businesses and restaurants here.
It’s in a less-traversed part of the downtown commercial strip – the backside – but I’d estimate likelihood of development is middling.
• 116 W Doran is the vestigial single-floor commercial extension of a massive office building, currently housing a Wells Fargo. As offices start to go the way of the buffalo, turning this building into housing makes a lot of sense, though it would have to contend with the north- facing windows in the aforementioned office building (535 N Brand). Likelihood of development is middling.
• 340 N Orange is a two-story parking structure that feeds the Bank of America “Financial Center”.
I can’t speak to its being over or underutilized, but I’ve never used it and google maps images of the structure show it as being nearly empty.
Now, the bad ones.
• 322 Americana Way is a theater that just very publicly signed a 15-year lease with AMC. There is no likelihood of development.
• 320 S Central is a very recent mixed-use building, the Lex on Orange, that advertises an available studio at $2,332 and an available 2-bedroom at $4,207. It is a dense, four-story luxury complex that appears to be nearly leased up. It is unclear as to how more housing can be fit on it, nor how this fits into the city’s plan for affordable housing. o The city folds the same complex in its sites under the address 321 N Orange. Both addresses are completely built up and leased.
• 300 S Central is another recent luxury apartment building, the Legendary. The same story as 320 S Central applies here.
• 120 W Colorado is the site of a proposed hotel – the AC Hotel - that the city council has fast- tracked, despite this author’s opposition to the site being used for something other than housing. It is deeply aggravating to see it on this list, currying credit for potential housing while the city council is blasting past housing advocates to help turn it into another unneeded hotel. • 326 E Colorado is the Hotel Xilo, which is active and enjoys a 4.6 rating on google. • 500 E Colorado is a medical and commercial center that JUST opened. There’s no way this is going to turn into housing within the next eight years. • 305 E Colorado is the parking lot of the United Community Church. I would, admittedly, love to see housing here, but I don’t know what the church plans to do with the lot. • 300 W Colorado is a Robbins Brothers engagement ring store. I know that diamonds are going out of fashion because young people aren’t buying them for the same reasons that they’re not buying housing, but this building must be demolished to make new housing and it is unclear if the jeweler will be going out of business any time soon. • 352 W Colorado is part of a large faith center (The Foundation of Niscience) that has existed in the same spot since 1953 and it is highly unlikely to leave. 1909 of 1910
• 200 W Broadway is the Dick’s Sporting Goods in the Glendale Galleria, a huge sports store that plugs directly into the indoor mall in two places. I would love to see this turn into housing but I cannot imagine it happening before 2030.
• 225 W Broadway is the Glendale Financial Square, a massive commercial lot where at least the Nurses’ Union (CNA) have a lease. The emblem on the outside of the building says “Social Security”, an institution that strikes me as being a sound long-term lease. • 313 E Broadway is the United States Post Office, which might be a historical landmark, because it certainly looks like it. No way does this get developed into housing. • 305 E Harvard is three accessory buildings to the Glendale Presbyterian Church. The side of the building says, “Children’s Ministries” and I’d be interested to see if the church would sell all three buildings. Nonetheless, I’d put likelihood as low. • 134 N Kenwood is the First Methodist Church of Glendale. I attended a community event here a while back. I don’t think it’s being bulldozed any time soon. • 233 S Kenwood Street is the Lighthouse Bible Church Los Angeles. It’s manicured. Likelihood is low.
• 900 N Central is the Crab Avenue restaurant, which is, at the time of this writing, in business.
While the restaurant across the street has shuttered, the city needs to produce proof that the restaurant’s lease will expire during the 6
th cycle.
• 232 N Orange is the municipal parking lot that serves the downtown commercial district, just across from the Alex Theater. This is a rare parking lot that makes a lot of sense and serves a necessary purpose. There’s no way that the city will tear it down to build housing.
If I had far more time, I would as happily dive into the much longer list of what the city considers candidate sites. Nevertheless, the city wants to claim RHNA building potential on, among other things, three leased-up, high-density luxury apartment complexes, trying to have its cake and eat it too – have existing market-rate housing count as ‘potential low-income sites’.
This draft does not conform with state law and must be rejected. 1910 of 1910