APPENDIX D
Response to Comments on the
Public Review Draft
2023-2031 Housing Element
Appendix D
Hughson 2023-2031 Housing Element Update
Public Review Draft Comments and Responses
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COMMENTER # SUMMARY OF COMMENTS RESPONSE TO COMMENTS
Anna Felix 1.0 I saw an article in the Turlock Journal about the housing plans for Hughson. It saddened me to see that you are considering adding more housing. I just moved here from Turlock a little over a year ago. I moved into an existing house, and I love everything about this town so far. The things that are attractive about it, are the things that will be lost with bringing in new housing. A good general grocery store is needed now and with more growth that would be imperative, and I don't believe the schools could handle such growth. The size of Hughson is perfect, once you start growing it, you need a lot more infrastructure to keep up with more people and traffic. The downtown area could use more development now. Adding more houses is going to take the focus away from that, and bring more of what is not needed.
If more low-income housing is a priority, I think some
apartments and condo developments near downtown would be feasible, incorporating some commercial spaces that already exist. Thanks for considering our opinions. Let's keep Hughson great!
This comment is noted. The City is in the process of updating the Housing Element of the General Plan to meet the future housing needs of Hughson for the 2023-2031 planning period. Under State law, each city and county in California is required to update its Housing Element every eight years to address specific requirements and submit the document to the Department of Housing and Community
Development (HCD) for certification. The Housing Element serves as Hughson’s blueprint for meeting the housing needs of our residents at all economic levels and addressing segments of the population with special housing needs.
At the beginning of the update process, HCD calculates the Regional Housing Needs Determination (RHND) for Stanislaus County. The Stanislaus Council of Governments (StanCOG) is then tasked with creating a methodology for distributing the RHND across all jurisdictions in the Stanislaus region.
Distribution of the RHND results in each jurisdiction’s Regional Housing Needs Assessment (RHNA), which is the total number of housing units by income category (i.e., very low-, low-, moderate-, and above moderate-income) that the jurisdiction must plan for in the new Housing Element. The allocation for the City of Hughson is 881 total housing units divided as follows:
• 284 very low-income units
• 196 low-income units
• 122 moderate-income units
• 279 above moderate-income units
Through the Housing Element Update, and per State law, the City must demonstrate that Hughson can accommodate all of its RHNA allocation during the 2023-2031 planning period. The Housing Element does this by showing that there is adequate land available with zoning in place to meet the RHNA. The Housing Element also includes programs to facilitate housing development. Note that the City’s role is to ensure that development can realistically happen over the planning period, while it is still up to the market for that development to occur.
Appendix D
Hughson 2023-2031 Housing Element Update
Public Review Draft Comments and Responses
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COMMENTER # SUMMARY OF COMMENTS RESPONSE TO COMMENTS
Also note that the City agrees with your comments regarding the need for a local grocery store and redevelopment to occur in the downtown and efforts by the City to attract new business development in Hughson are ongoing.
Marlene
Hutchinson
2.0 I am NOT in, favor of more housing, what about the schools being over loaded and how about the water issue. We only water 2 times a week. NOW your bringing in more houses and people. You wouldn't join in with Turlock and Ceres for the water treatment and will the SEWER be big enough to handle extra 1000 people.
This comment is noted. The City is in the process of updating the Housing Element of the General Plan to meet the future housing needs of Hughson for the 2023-2031 planning period. Under State law, each city and county in California is required to update its Housing Element every eight years to address specific requirements and submit the document to the Department of Housing and Community
Development (HCD) for certification. The Housing Element serves as Hughson’s blueprint for meeting the housing needs of our residents at all economic levels and addressing segments of the population with special housing needs.
At the beginning of the update process, HCD calculates the Regional Housing Needs Determination (RHND) for Stanislaus County. The Stanislaus Council of Governments (StanCOG) is then tasked with creating a methodology for distributing the RHND across all jurisdictions in the Stanislaus region.
Distribution of the RHND results in each jurisdiction’s Regional Housing Needs Assessment (RHNA), which is the total number of housing units by income category (i.e., very low-, low-, moderate-, and above moderate-income) that the jurisdiction must plan for in the new Housing Element. The allocation for the City of Hughson is 881 total housing units divided as follows:
• 284 very low-income units
• 196 low-income units
• 122 moderate-income units
• 279 above moderate-income units
Through the Housing Element Update, and per State law, the City must demonstrate that Hughson can accommodate all of its RHNA allocation during the 2023-2031 planning period. The Housing Element does this by showing that there is adequate land available with zoning in place
Appendix D
Hughson 2023-2031 Housing Element Update
Public Review Draft Comments and Responses
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COMMENTER # SUMMARY OF COMMENTS RESPONSE TO COMMENTS
to meet the RHNA. The Housing Element also includes programs to facilitate housing development. Note that the City’s role is to ensure that development can realistically happen over the planning period, while it is still up to the market for that development to occur.
Chapter 3 Housing Constraints, Section C Public Facilities and Infrastructure, assessed the City’s water and sewer capacity. It was determined that there is sufficient capacity to support the City’s RHNA allocation during the planning period.
Jennifer Stone 3.0 I am inquiring about the Hughson Housing Element Plan, specifically when the public comments will be and how I can send or provide some feedback regarding individuals with Intellectual and/or Developmental Disabilities and their affordable and low-income housing needs in the community of Hughson. We have quite a few individuals that live in your city on fixed income, both individuals and families that have a member with an intellectual disability. Often there are misconceptions about what a person with an intellectual and/or developmental disability can or cannot do (related to housing) and VMRC would like to ensure that this population is
represented accurately and with dignity.
I have been reviewing the current Housing Element Plan. Our agency is listed in the plan, however there are quite a few errors and inconsistencies that need to be addressed as it relates to this population. I did look on the website as well as the newsletter but there are no current dates for comment. Should I send the comments to you? I am available by phone or zoom as well to discuss how our population that lives in the City of Hughson can be represented in the development of community housing needs. I did leave a voicemail message for Fabian Ramos.
I also wanted to let you know that VMRC is looking to partner with developers, agencies, and cities to support the efforts of increasing the supply of low income and affordable inclusive housing in the City of Hughson for our VMRC users to access. We The City of Hughson would welcome Valley Mountain Regional Center’s (VMRC) input and insight on the housing needs and challenges faced by the developmental disability community. The comments from VMRC on the Housing Element are addressed in order below. Going forward, the City will be certain to coordinate with VMRC as the Housing Element programs specific to this special needs population are implemented.
Appendix D
Hughson 2023-2031 Housing Element Update
Public Review Draft Comments and Responses
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COMMENTER # SUMMARY OF COMMENTS RESPONSE TO COMMENTS
are able apply for GAP funding annually through the Department of Developmental Services to use for renovation, new
construction, Acquisition, and predevelopment of multifamily projects. I would be happy to give you more information about this and discuss possible collaboration. Please call or email me as your schedule allows.
3.1 Page HBR-14 and 15
It is important to remember that many of our individuals can and do live independently (especially adults and seniors).
On page HBR 15 about a third of the way down the page, the Housing Element states, “Housing with features for a disabled person (ramp, grab bars, low counters and cabinets, assistive devices or hearing or visually impaired person)” Not all of our VMRC eligible users with developmental disabilities require accommodations of this nature. And there are many of the community that don’t have a disability that DO require these or other accommodations.
The developmental disabilities that would make someone
eligible for VMRC services are Autism, Epilepsy, Cerebral Palsy, Intellectual Disability, and a fifth category (such as TBI) and these do often impact an individual’s daily life and living skills.
However, there are many that can work, drive, attend college, volunteer, and self-advocate. It is unfortunate that all persons with disabilities are grouped together, and that the assumption is that they can’t live on their own or without assistance. That is simply not true. Many of our individuals who live independently need services for their daily living, but they do not need them built into their housing situation nor do they want to live in a ‘residential care facility with 24-hour staff’. Often these settings are too restrictive and the goal of VMRC is to assist individuals to live in the least restrictive setting of their choosing. They may not need physical accommodations necessarily, but they need other supports and services. They are often on a fixed income and need affordable housing to live in their choice of housing.
And it would be good to keep in mind that there may be some of This comment is noted. For clarity, the mention of “Housing with features for a disabled person (ramp, grab bars, low counters and cabinets, assistive devices for hearing- or visually-impaired persons)” was included under the discussion on Senior Households, whereby the combination of being a senior and having a disability may require these types of accommodations. Furthermore, this was based on feedback received during public outreach. Nonetheless, it is helpful to know that the needs of the developmental disability community can vary.
Through the implementation of the housing programs in the Housing Element, the City intends to create as many avenues as possible for the development of a wide range of housing options, both in terms of housing type and level of affordability. Much of the housing the City will focus on during the 2023-2031 planning period is affordable housing – very low-, low-, and moderate-income – as these are the income categories that still need to be fulfilled over the planning period. The City also recognizes that a “one size fits all” approach to housing development in Hughson will not suffice given the diverse needs and resources of Hughson’s residents, including the developmental disability community.
Appendix D
Hughson 2023-2031 Housing Element Update
Public Review Draft Comments and Responses
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COMMENTER # SUMMARY OF COMMENTS RESPONSE TO COMMENTS
our individuals that end up homeless or unhoused because they cannot afford ‘affordable housing’.
3.2 Pg HBR-15 under the section of Persons with Disabilities (2nd paragraph): “Physical, mental, and/or developmental disabilities could prevent a person from working, restrict a person’s mobility or make caring for oneself difficult. Therefore, disabled persons often require special housing needs related to potential limited earning capacity the lack of accessible and affordable housing, and high health costs associated with disabilities. Additionally, people with disabilities require a wide range of different housing, depending on the type and severity of their disability.
Housing needs can range from institutional care facilities to facilities that support partial or full independence (i.e. group care homes). Supportive services such as daily living skills and employment assistance need to be integrated in the housing situation.”
This is a good start, but it is not necessarily true. At VMRC and the Department of Developmental Services, the goal is to have LESS institutionalized settings, and not MORE. Yes it is true that some of our individuals may not be able to live on their own without some kind of ‘institutional’ setting, but many more would prefer to have more community INCLUSIVE settings (i.e. their own apartment or trailer, rental unit, etc.). Some would even like to be homeowners. This paragraph in the Housing Element goes on that “Individuals with developmental
disabilities and other physical and mental conditions that prevent them from functioning independently may require assisted care or group home environments.” This is misleading because again, all individuals with disabilities are grouped together.
And (next bullet point), “Individuals with disabilities may require financial assistance to meet their housing needs because a higher percentage that the population at large are low-income and their special housing needs are often more costly than conventional housing.” What do you mean by “require financial This comment is noted. Again, the City’s aim is for there to be many different housing options for all residents in Hughson. As it relates to the developmental disability community, the Housing Element is attempting to identify the wide range of housing needs for the developmental disability community and the City fully understands that individuals with a developmental disability vary in the severity of their disability and their degree of independence.
The intent of the Housing Element is not to single out a group, but what the City is required to do in the Housing Element is identify the housing related needs of special populations. It is correct that “there are a lot of individuals who do not have a disability that require financial assistance,” and other special needs populations that may also require financial assistance for housing are examined in the Housing Element, including senior households, large households, farmworkers, female heads of households, and homeless individuals.
Appendix D
Hughson 2023-2031 Housing Element Update
Public Review Draft Comments and Responses
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COMMENTER # SUMMARY OF COMMENTS RESPONSE TO COMMENTS
assistance?” there are a lot of individuals who do not have a disability that require financial assistance. Why are individuals with disabilities being singled out it this regard?
3.3 Page HBR- 16: The first paragraph of this page is misleading and assumes that the unemployment is directly correlated to a disability. It would be interesting to see what percentage of the population with an ID (Intellectual Disability and/or a DD (Developmental Disability) decreased employment because of their disability and what part is due to limitations of the current economy, or is it because there are not employment options for the persons with DD in Hughson. What does the transportation environment look like?
Are the data points on this page reflecting the number of developmentally disabled individuals in Hughson working in Hughson or living in Hughson and working outside of the city limits?
This comment is noted. The analysis in the Housing Element is sometimes limited by the available data and although multiple data sources were used in the preparation of the Housing Element, as noted on page HBR-5, the analysis for some topics may not be as nuanced as the analysis on others. The primary source of information for Persons with Disability by Employment Status was the American Community Survey (ACS) 5-Year Estimates, which could not parse out whether the decrease in employment of persons with disabilities was the result of their disabilities or was due to limitations of the economy during the period 2015-2020. Of course, the economy was impacted by the onset of the COVID-19 pandemic in March 2020.
Although there is data that can show the inflow and outflow of labor into and out from the City of Hughson, that data is not so detailed as to indicate who in the labor force has a developmental disability.
3.4 Page HBR-17 has significant errors under Persons with Developmental Disabilities. The second paragraph initially references Valley Mountain Regional Center, but then farther in the paragraph incorrectly references NBRC. NBRC is North Bay Regional Center, and they are not the regional center for Hughson. THIS DATA IS INCORRECT.
This comment is noted and corrections to the Housing Element have been made.
3.5 I also do not see where VMRC was contacted or included in any of the surveys that were taken. We are happy to enter into the conversation with and on behalf of our VMRC users. We are happy to provide data and additional information for your research. But I don’t understand how the Housing Element can be developed ‘for persons with a disability’ if you do not include discussion with this population and the largest agency that provides support for this population in Hughson and Stanislaus County. Just thoughts to consider.
This comment is noted. During any outreach process the City strives to connect with as many key stakeholders as possible for their valuable input. The Housing Element identifies many agencies and service providers and although the City may have missed the opportunity to engage with VMRC earlier, we are pleased that the checks and balances in the outreach process allowed for this exchange during the Public Review period. Moreover, the City looks forward to having open channels of communication with VMRC as the housing programs are implemented.
3.6 As follow up to my comments from yesterday, I would like to include some attachments about Valley Mountain Regional Center (who we are, what we do, and who we serve). As of August, VMRC has about 109 individuals with open and active This comment is noted and the City looks forward to exploring partnership opportunities with Valley Mountain Regional Center.
Appendix D
Hughson 2023-2031 Housing Element Update
Public Review Draft Comments and Responses
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COMMENTER # SUMMARY OF COMMENTS RESPONSE TO COMMENTS
services *who live in the City of Hughson) with an assigned service coordinator. Many are families that have a child under the age of 18 with a disability, some older individuals (ages 18- 59) live with family or in a roommate setting. VMRC has only one vendored residential facility (care home) in Hughson and there are 4 adult individuals who are residents there, and 4 children under the age of 18 live in a foster care setting but have a developmental disability.) They are placed by CPS in non vendored care or group homes that are not associated with VMRC. 5 individuals live independently in the community with varying degrees of support. One individual is over the age of 59 and considered a senior. Please note that this is not ALL of the individuals with a developmental disability living in Hughson, ONLY the ones who have an open and active case/services with VMRC at this moment. We are a voluntary agency.
I have attached our VMRC pamphlet and an FAQ sheet. Please note that the FAQ is updated as of last year and VMRC currently provides services to over 22,000 open and active individuals throughout our five county catchment area of Stanislaus, San Joaquin, Calaveras, Amador, and Tuolumne Counties,
I am also attaching some information about the Department of Developmental Services (or DDS) related to GAP Funding that regional centers can apply for to partner with counties, cities, developers, and agencies in order to develop community
integrated and including multifamily housing projects to address the need for extremely low, low, and affordable housing solutions as it relates to your Housing Element Plan. I would be happy to schedule a meeting to provide more information for you. This is another funding opportunity that is often either not known about or not explored. I’m sure that we have individuals who live with family that would benefit from and desire to live in a place of their own where they can be independent.
Michael Mitchell 4.0 1) How/when did our local planning commission lose control over planning? I believe the local county re-development These comments are noted. Responses to the specific points are as follows:
Appendix D
Hughson 2023-2031 Housing Element Update
Public Review Draft Comments and Responses
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COMMENTER # SUMMARY OF COMMENTS RESPONSE TO COMMENTS
commissions were defunded several years ago. Again the state appears to supersedes any local planning.
2) What happens when a property owner does not want to sell or retain part of an identified property in the sphere of influence?
3) Is the city willing (or forced) to re-zone areas to higher density building? Will the public have any say over this zoning if it devalues their property? 4) If Hughson's infrastructure cannot support more building of these projects and/or unable to financially invest via increased taxes what would be consequences? We just received utility increases last year to make the upgrades necessary to several wells and it was a significant increase.
5) If the Dept of Housing and Community development decides to pursue penalties, is the city able to partner with other cities to sue and go through the legal system to prevent these mandated and onerous expectations? Any penalties will bankrupt
communities.
Finally, myself and several neighbors have been looking for the Draft Housing Element online to comment before the 30 days were up. In the future would you please put a notice in the monthly Hughson newsletter, City of Hughson site and FB platform to bring attention to these important items.
1) Under State law, each city and county in California is required to update its Housing Element every eight years to address specific requirements and submit the document to the
Department of Housing and Community Development (HCD)
for certification. The Housing Element serves as Hughson’s blueprint for meeting the housing needs of our residents at all economic levels and addressing segments of the population with special housing needs.
Furthermore, the City must demonstrate that Hughson can accommodate all of its Regional Housing Needs Assessment (RHNA) of 881 total housing units during the 2023-2031
planning period. The Housing Element does this by showing that there is adequate land available with zoning in place to meet the RHNA. The Housing Element also includes programs to facilitate housing development. Note that the City’s role is to ensure that development can realistically happen over the planning period, while it is still up to the market for that development to occur.
Redevelopment Agencies were in fact dissolved by the State a number of years ago; however, the activities of former
Redevelopment Agencies and the state-mandated
requirement for cities to prepare Housing Elements are two distinctly different matters.
2) During the 2023-2031 planning period it may be the case that a property owner of a site identified in the Housing Element Sites Inventory chooses not to develop or to develop in a manner different than anticipated by the Housing Element.
Also during the planning period, the City will monitor the development activity on the Housing Element sites. There is surplus capacity in the Sites Inventory to absorb the loss of a site, but if too many sites are lost in this way then the City may need to reanalyze the availability of land and identify additional sites to accommodate its RHNA allocation of 881 units. Note too that the City will receive credit for current
Appendix D
Hughson 2023-2031 Housing Element Update
Public Review Draft Comments and Responses
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COMMENTER # SUMMARY OF COMMENTS RESPONSE TO COMMENTS
development activity which includes 319 units that are either under construction or have recently received final building approval and Certificates of Occupancy, effectively lowering the remaining number of housing units that still need to be accommodated during the 2023-2031 planning period.
3) The Public Review Draft Housing Element has identified sufficient sites with the capacity to accommodate the City’s RHNA allocation. No rezoning of sites is currently proposed.
However, the Housing Element will be reviewed by the
Department of Housing and Community Development (HCD)
and still needs to go through adoption by the Planning
Commission and City Council. Should it be determined that rezoning is required to meet the City’s RHNA then a zoning amendment will occur, which is a discretionary process that requires a public hearing where residents and property
owners can comment on the proposed rezoning. At this time though, no rezoning is proposed.
4) Chapter 3 Housing Constraints, Section C Public Facilities and Infrastructure, assessed the City’s water and sewer capacity. It was determined that there is sufficient capacity to support the City’s RHNA allocation during the planning period.
5) The City is committed to complying with State law as it pertains to the Housing Element and avoiding challenges from HCD, and any other party, altogether. The City is mindful that its role in this process is to ensure that development can realistically happen over the planning period, while it is still up to the market for that development to occur.
Each city’s Housing Element can be challenged for different reasons and at different times, which makes any effort to consolidate a legal action with another city difficult and, in most cases, impractical. Although the City aims to comply with State law pertaining to the Housing Element, should a
Appendix D
Hughson 2023-2031 Housing Element Update
Public Review Draft Comments and Responses
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COMMENTER # SUMMARY OF COMMENTS RESPONSE TO COMMENTS
dispute arise between the City and HCD, the City will
investigate all remedies available to it.
Although there was a social media blast (X, Facebook, Instagram, and Nextdoor) and announcement of the availability of the Public Review Draft Housing Element on the project website and through other means, your comments are noted and the City will widen the announcements during future phases of the Housing Element Update process.
STATE OF CALIFORNIA - BUSINESS, CONSUMER SERVICES AND HOUSING AGENCY GAVIN NEWSOM, Governor
DEPARTMENT OF HOUSING AND COMMUNITY DEVELOPMENT
DIVISION OF HOUSING POLICY DEVELOPMENT
651 Bannon Street, Suite 400
Sacramento, CA 95811
(916) 263-2911 / FAX (916) 263-7453
www.hcd.ca.gov
June 22, 2026
Carla C. Jauregui, Director
Community Development Department
City of Hughson
7018 Pine Street
Hughson, CA 95326
Dear Carla C. Jauregui:
RE: City of Hughson’s 6th Cycle (2023-2031) Revised Draft Housing Element Thank you for submitting the City of Hughson’s (City) revised draft housing element received for review on May 20, 2026, along with minor technical modifications received on June 22, 2026. Pursuant to Government Code section 65585, the California Department of Housing and Community Development (HCD) is reporting the results of its review. Our review was facilitated by a conversation with you and your consultant on June 10, 2026.
The revised draft element, including minor technical modifications, meets the statutory requirements of State Housing Element Law (Gov. Code, § 65580 et seq), including findings that were described in HCD’s May 11, 2026 review. However, the housing element cannot be found in substantial compliance until the City has completed the necessary rezones (see below) to accommodate the Regional Housing Needs Allocation (RHNA). The housing element will substantially comply with State Housing Element Law when all necessary rezoning and the element are adopted, submitted to, and approved by HCD, in accordance with Government Code section 65585.
A jurisdiction that did not adopt a compliant housing element within 120 days from the statutory deadline (December 31, 2023) must rezone sites within one year of the statutory deadline and meet requirements pursuant to Government Code sections 65583, subdivision (c)(1)(A) and 65583.2, subdivisions (c), (h) and (i), as applicable. As this year has passed and Program 11B (Adequate Sites for Lower Income Households) has not been completed, the housing element cannot be found in substantial compliance until rezoning has been completed to meet all statutory requirements.
Carla C. Jauregui, Director
As a reminder, the City’s 6th cycle housing element was due December 31, 2023. 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 expeditiously complete the rezone, adopt the housing element, and submit to HCD to regain housing element compliance.
Public 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.
Please be aware, any revisions to the element must be posted on the local government’s website and to email a link to all individuals and organizations that have previously requested notices relating to the local government’s housing element at least seven days before submitting to HCD.
For your information, the element relies on nonvacant sites to accommodate 50 percent or more of the housing needs for lower-income households, which triggers requirements to make findings based on substantial evidence that the existing use is not an impediment and will likely discontinue in the planning period. Absent findings (e.g., adoption resolution) based on substantial evidence, the existing uses will be presumed to impede additional residential development and will not be utilized toward demonstrating adequate sites to accommodate the RHNA.
For your information, pursuant to Government Code section 65583.3, the City must submit an electronic sites inventory with its adopted housing element. The City must utilize standards, forms, and definitions adopted by HCD. Please see HCD’s housing element webpage at https://www.hcd.ca.gov/planning-and-communitydevelopment/housing-elements for a copy of the form and instructions. The City can reach out to HCD at [email protected] for technical assistance.
Several 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 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 will meet 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 Land Use and Climate Innovation at:
https://www.lci.ca.gov/planning/general-plan/guidelines.html.
Carla C. Jauregui, Director
HCD appreciates the efforts of the housing element update team throughout the housing element update and review. We are committed to assisting the City in addressing all statutory requirements of State Housing Element Law and welcome the opportunity to provide technical assistance during the adoption and rezone process. If you have any questions or need additional technical assistance, please contact Emily Hovda, of our staff, at [email protected].
Sincerely,
Paul McDougall
Senior Program Manager
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CITY OF HUGHSON
CITY COUNCIL
ORDINANCE NO. 2026-03
AN ORDINANCE OF THE CITY COUNCIL OF THE CITY OF HUGHSON AMENDING MUNICIPAL CODE CHAPTER 17.02 TO ADD A HOUSING OVERLAY DISTRICT IN CONFORMANCE WITH THE 6TH CYCLE 2023-2031 HOUSING ELEMENT UPDATE
WHEREAS, State Housing Element Law (Government Code § 65580 et seq.) requires that the City of Hughson adopt a Housing Element for the 8year planning period 2023- 2031 to accommodate the City’s regional housing need allocation (RHNA) of 881 housing units, comprised of 284 very low-income units, 196 low-income units, 122 moderate-income units, and 279 above moderate-income units; and
WHEREAS, to comply with State Housing Element Law, the City of Hughson has prepared the 6th Cycle 2023-2031 Housing Element in compliance with State Housing Element Law and has identified sites that can accommodate housing units meeting the City’s RHNA; and WHEREAS, on August 18, 2026, the Planning Commission conducted a duly and properly noticed public hearing regarding the proposed Housing Element, reviewed the Housing Element and all pertinent documents, maps, and exhibits, including the Department of Housing and Community Development’s (HCD) findings, the City’s response to HCD’s findings, the staff report, and all attachments, and oral and written public comments and recommended approval of the Housing Element to the City Council; and
WHEREAS, on August 24, 2026, the City Council adopted the City’s 6th Cycle 2023- 2031 Housing Element for the 8-year planning period in compliance with State law; and WHEREAS, the adopted Housing Element includes Part 1 – Housing Plan that identifies the goals, policies, and programs the City of Hughson is responsible for undertaking to facilitate the production of housing by reducing regulatory barriers, providing incentives, and developing supporting programs which create or preserve housing, including for special needs populations; and
WHEREAS, Program 11B Adequate Sites for Lower Income Households directs the City to allow developments by right pursuant to Government Code § 65583.2(c) when 20 percent or more of the residential units are affordable to low and very-low income households for sites identified in previous Housing Element Sites Inventories; and WHEREAS, to comply with this Government Code Section, the City is establishing by ordinance the Housing Overlay District covering those 4th and 5th Cycle reused sites to allow development by-right when 20 percent or more of the residential units are affordable to lower income households; and
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WHEREAS, the Planning Commission, at a properly noticed public hearing on August 18, 2026, carefully considered all of the information presented to it, including the staff report and information submitted at the public hearing by interested persons, and adopted a resolution recommending that the City Council adopt an ordinance establishing the Housing Overlay District; and
WHEREAS, as an independent and alternative basis to the statutory exemption described below, and regardless of the status of HCD's review of the Housing Element, the City as Lead Agency determined that the General Plan Amendment to update the Housing Element is covered by the common sense CEQA exemption (CEQA Guidelines Section 15061(b)(3)), which provides that CEQA applies only to projects that have the potential for causing a significant effect on the environment. Since no development project or other physical change to the environment would be approved by the adoption of the Housing Element, it can be seen with certainty that there is no possibility that the Housing Element adoption would have a significant effect on the environment, and therefore is not subject to CEQA.
Further, and as the primary basis for this determination, Public Resources Code Section 21080.085 provides for a statutory exemption from CEQA for rezoning undertaken to implement the schedule of actions in a housing element that has been approved by the California Department of Housing and Community Development (HCD). Therefore, the rezoning actions included in the 6th Cycle Housing Element’s Housing Plan required under Government Code Section 65583(c) qualify for CEQA exemption once, and to the extent, HCD has approved the 6th Cycle Housing Element pursuant to Government Code Section 65585.
WHEREAS, pursuant to Government Code § 65860, the City Council finds that this Ordinance is consistent with the City of Hughson General Plan, as amended by the 2023-2031 Housing Element, in that the City has an officially adopted General Plan and the land uses authorized by the Housing Overlay District are compatible with the objectives, policies, general land uses, and programs specified in the General Plan, including Housing Element Program 11B (Adequate Sites for Lower Income Households).
NOW, THEREFORE THE CITY COUNCIL OF THE CITY OF HUGHSON DOES ORDAIN AS FOLLOWS:
Section 1. Findings. The recitals set forth above are hereby incorporated into this Ordinance as findings of the City Council of the City of Hughson and shall be considered an integral part of this Ordinance.
Section 2. Chapter 17.02 of the Hughson Municipal Code is amended to as follows:
Chapter 17.02 ZONING DISTRICTS
§ 17.02.004 Establishment and designation of zones.
§ 17.02.008 Residential zones.
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§ 17.02.012 Commercial zones.
§ 17.02.016 I – Industrial zone.
§ 17.02.020 Public use zones.
§ 17.02.024 Specific plan zone.
§ 17.02.028 Planned development overlay zone.
§ 17.02.030 Housing overlay zone.
§ 17.02.032 Uses allowed in each district.
§ 17.02.004 Establishment and designation of zones.
A. Designation of Zones. The zones hereby established and into which the city is divided are designated as follows:
R-1 Low Density Residential
R-2 Medium Density Residential
R-3 High Density Residential
R-A Rural Residential
C-1 Neighborhood Commercial
C-2 General Commercial
C-3 Service Commercial
I Industrial
P Public Facility
O-S Park/Open Space
S-P Specific Plan
P-D Planned Development Overlay
H Housing Overlay
…
§ 17.02.030 Housing overlay zone.
A. Purpose. The Housing Overlay Zone is intended to facilitate the development of affordable housing while promoting infill development on sites previously identified on housing inventories in the City’s 4th and 5th Cycle Housing Elements. Only those projects that have 20 percent of the total number of units deed restricted for low- and very low-income units are eligible for by-right development in this overlay district.
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B. Applicability. The Housing Overlay Zone is applicable to those sites identified in the Table 17.02.030 below. These sites are the reused sites from the 4th and 5th Cycle Housing Elements. These sites are also identified in Appendix A of the 6th Cycle 2023- 2031 Housing Element in the Inventory of Residential Sites.
Table 17.02.030
Reused 4th and 5th Housing Element Cycle Sites
6th Cycle HE Site
Inventory
Number APN Number
Zoning
Designation
General Plan
Land Use
Designation
Allowable
Density
(du/ac)
45 018-018-020-000 R-2 MDR 5.1-14
38 018-022-020-000 R-3 HDR 10.1-27
42 018-022-021-000 R-3 HDR 10.1-27
35 018-022-029-000 R-3 HDR 10.1-27
31 018-022-031-000 R-3 HDR 10.1-27
3 018-032-062-000 R-3 HDR 10.1-27
5 018-034-010-000 R-2 MDR 5.1-14
8 018-036-001-000 R-3 HDR 10.1-27
9 018-036-064-000 R-3 HDR 10.1-27
10 018-036-070-000 R-3 HDR 10.1-27
15 018-049-070-000 R-3 HDR 10.1-27
16 018-049-071-000 R-3 HDR 10.1-27
17 018-049-072-000 R-3 HDR 10.1-27
18 018-049-073-000 R-3 HDR 10.1-27
23 018-053-022-000 R-3 MDR 5.1-14
C. By-Right Development. The City shall implement by-right development for the sites identified above when a developer builds a project with at least 20 percent affordable units deed restricted for low- and very-low income units. Pursuant to Government Code Section 65583.2 (c), byright development means the following are not required for development:
1. Conditional Use Permit;
2. Planned Unit Development Permit;
3. Design Review other than Objective Development Design Standards; or
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4. Other discretionary review or approval that would constitute a “project” as defined in Section 2100 of the Public Resources Code (California Environmental Quality Act “CEQA”).
Section 3. If any provision of this Ordinance or application thereof to any person or circumstances is held invalid, such invalidity shall not affect other provisions or applications of the Ordinance which can be given effect without the invalid provision or application, and to this end the provisions of this Ordinance are severable. The City Council hereby declares that it would have adopted this Ordinance irrespective of the validity of any particular portion thereof.
Section 4. This Ordinance shall become effective thirty (30) days after its final passage.
Section 5. Within fifteen (15) days after its final passage, the City Clerk shall cause a summary of this Ordinance to be published in accordance with Section 36933 of the Government Code.
The foregoing Ordinance No. 2026-03 was introduced and the title thereof read at the regular meeting of the City Council of the City of Hughson held on , 2026, and by a vote of the council members present, further reading was waived.
On motion of __________, seconded by __________, the foregoing Ordinance No. 2026- 03 was duly passed by the City Council of the City of Hughson at a regular meeting thereof held on , 2026, by the following vote:
AYES:
NOES:
ABSTENTIONS:
ABSENT:
GEORGE CARR, Mayor
ATTEST:
DOMINIQUE ROMO, City Manager