Members of the public identifying themselves as residing in the neighborhood of northeast Gustine on the inventory map have stated they have concerns over accessibility of all three sites in their neighborhood proposed for higher-density and/or lower-income RHNA units, including Site 4, Site 5 and (later) Site 11. The planning team has taken seriously these concerns and has combed through again both the Sixth Cycle guidebook and the related sections of the Government Code upon which the guidebook is based.
However, the State again provides less than clear direction regarding how it intends to evaluate accessibility in review of potential sites. The State guidelines on access direct that there must not be major constraints to development of parcels on the Inventory.
It appears that residents citing access concerns believe the sites do not provide sufficient access as the three are not cited along existing City streets. Consultants have advised that they do believe the parcels have sufficient access in that accessibility for developing projects can be met not only by being located along public streets but also by access that could be obtained through easements and other dedications.
Parcel maps for Site 4, Site 5 and Site 11 are included again on Exhibits G, H & I to this packet and the attachments state where it is thought access would come from for each of the three sites. There are also photos on each Exhibit in order to provide further clarification on questions of available access on these sites.
Weighing Potential Certification Factors
As pointed out in the presentation, it is the responsibility of the planning team to recommend the path to Council that, based upon State actions thus far, would appear to provide the best chance for approval from the State. The Site Inventory list presented at the November 21 meeting and here as Exhibit A, represents an attempt at that based upon reasonable consideration of State directives. The planning team’s initial recommendation has been based heavily upon what has been estimated to be a common sticking point from the State—equitable distribution.
At the same time, it is important to acknowledge that the recommendation beyond the 15 initial sites is based upon best estimation of how the State might respond to potential submittal combinations. The Council could submit the site list as is on map Exhibit A and the State could come back and question whether access would limit interest in development in some of those sites. Or, if the Council submits only sites for which the public has not questioned access, the State could return to the City and comment that the alternate sites are too concentrated in an area and direct the City to look at the sites where the public questioned access.
It is impossible for the planning team to know precisely what the State will come back with but the recommendation to the Council thus far has been based upon what is thought to be both most readily acceptable by the State and also is most equitable to property owners in all the neighborhoods throughout Gustine.
The Council holds the authority and responsibility to direct staff on what sites to include on the inventory for the Housing Element and ultimately that decision comes down to how the Council collectively assigns value to the issues identified thus far.
Deadlines and Direction
The Council needs to direct staff regarding the Site Inventory draft to include in the Housing Element Submission. The November 21st Council discussion did not provide clear