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Pacifica City Council
October 16, 2023

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October 16, 2023
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CITY OF PACIFICA

CITY COUNCIL AGENDA
Council Chambers
2212 Beach Blvd
Pacifica, CA 94044
Mayor Tygarjas Bigstyck
Mayor pro Tem Sue Vaterlaus
Councilmember Sue Beckmeyer
Councilmember Mary Bier
Councilmember Christine Boles
City Council Joint Study Session 1 October 16, 2023
SPECIAL MEETING for

JOINT STUDY SESSION CITY COUNCIL AND PLANNING COMMISSION October 16, 2023 (MONDAY) – 7:00 PM
www.cityofpacifica.org
Off-street parking is allowed by permit for attendance at official public meetings.

Vehicles parked without permits are subject to citation. You should obtain a permit from the rack in the lobby and place it on the dashboard of your vehicle in such a manner as is visible to law enforcement personnel.

PLEASE SILENCE CELL PHONES DURING MEETING
Alternative Ways to Observe and Participate in the Meeting:

The primary method for observing and participating in the meeting is in-person at the meeting location published in the meeting agenda. However, there are alternative ways to observe and participate:
• Join Zoom Webinar: https://pacifica-gov.zoom.us/j/81156158241 • Watch on TV on Comcast channel 26
• Watch a Live Stream of the meeting by following https://www.cityofpacifica.org/LiveStream or www.pacificcoast.tv
• Live Remote Public Comments (offered on a pilot basis):
• Join Zoom Webinar: https://pacifica-gov.zoom.us/j/81156158241 • OR Dial-in: 1-669-900-6833 | Webinar ID: 811 5615 8241 o Press * 9 to raise your hand to request to speak.
o Press * 6 to unmute when called upon to speak by the last 4-digits of your phone #. • When the Mayor announces the Agenda Item on which you would like to comment, raise your hand in Zoom. You will be called upon my screenname or last 4-digits of phone number if dialing in. Please mute any background sound and state your full name at the start of your comment.

Please note that Alternative platforms for participation are subject to underlying technology functionality and may be modified or interrupted at any time without notice. • For Special Meetings, Public Comments are limited to Items on the Agenda only. • Written Public Comments:

BEFORE THE MEETING: Written public comments may be submitted in advance by 12:00 p.m. on the meeting date by email to: [email protected]. Written public comments submitted by email should adhere to the following:
• Specify “Joint Study Session 10/16/2023” in the Subject Line • Include the submitter’s full name
Written public comments received by 12:00 p.m. on the meeting date will be provided in their entirety to the City Council and posted to the City’s website prior to the meeting but will not be read verbally at the meeting.

AT THE MEETING: Materials in writing provided at the meeting should provide seven (7) copies to provide for each Councilmember, City Clerk and City staff.

City Council Joint Study Session 2 October 16, 2023
7:00 PM - OPEN JOINT STUDY SESSION OF CITY COUNCIL & PLANNING COMMISSION Call to Order
Roll Call
Reading of Land Acknowledgment
The City of Pacifica acknowledges that we occupy the unceded ancestral homeland of the Ramaytush Ohlone peoples, who are the original inhabitants of the San Francisco Peninsula. We honor the Ramaytush Ohlone peoples for their enduring commitment to Mother Earth. As the Indigenous protectors of this land and in accordance with their traditions, the Ramaytush Ohlone have never ceded, lost, nor forgotten their responsibilities as the caretakers of this place, as well as for all peoples who reside in their traditional territory. We affirm their sovereign rights as First Peoples and wish to pay our respects to the ancestors, elders, and relatives of the Ramaytush Ohlone peoples.

Salute to the Flag led by Councilmember Beckmeyer

CONSIDERATION

1. Continued joint study session of City Council and Planning Commission to consider and provide direction on the Draft 2023-2031 Housing Element of the General Plan.

PROPOSED ACTION: Receive a presentation and provide direction regarding outstanding items on the Draft 2023-2031 Housing Element of the General Plan.

ADJOURN
NOTICE: If you challenge a city's zoning, planning or other decision in court, you may be limited to raising only those issues you or someone else raised at the public hearing described in this notice, or in written correspondence delivered to the City Council at, or prior to, the public hearing. Judicial review of any city administrative decision may be had only if a petition is filed with the court not later than the 90th day following the date upon which the decision becomes final. Judicial review of environmental determinations may be subject to a shorter time period for litigation, in certain cases 30 days following the date of the final decision The City of Pacifica will provide assistance for disabled citizens upon at least 24 hours advance notice to the City Manager’s Office (650) 738-7301, or send request via email to:
[email protected] if you need sign language assistance or written material printed in a larger font or taped, advance notice is necessary. All meeting rooms are accessible to the disabled.

The Pacifica Municipal Code is available online at the City’s website (www.cityofpacifica.org/municode);

HOW TO OBTAIN CITY COUNCIL AGENDAS
Posted agendas:

Agendas are posted no later than Friday prior to the City Council meeting date, at the entrance to the City Hall location at the Pacifica Community Center, 540 Crespi Drive.

View on the Internet:

Follow the link to Council agenda, at www.cityofpacifica.org E-mail subscription:

Send a request to Sarah Coffey, at [email protected] City Clerk’s Office/City Manager’s Office
City Hall, 540 Crespi Drive
Council meetings:

Agendas are available at the City Council meeting
City Council Joint Study Session 3 October 16, 2023

HOW TO REACH YOUR GOVERNMENT OFFICIALS
• Governor Gavin Newsom, State Capitol Building, Sacramento CA 95814 (916) 445-2841 • State Senator Josh Becker, 1528 So. El Camino Real, Suite 303, San Mateo CA 94402 (650) 212-3313 • Assembly Member Marc Berman, 721 Colorado Ave, Suite 101, Palo Alto CA 94303 (650) 324-0224 • Congresswoman Anna Eshoo, 698 Emerson Street, Palo Alto CA 94301 (650) 323-2984 • Senator Alex Padilla, B03 Russell Senate Office Building, Washington DC 20510 (202) 224-3553 • Senator Laphonza Butler, SD-G10 Dirksen Senate Office Building, Washington DC 20510 (202) 224-3841 • President Joseph R. Biden, 1600 Pennsylvania Ave. NW, Washington DC 20500

CITY COUNCIL
• Mayor Tygarjas Bigstyck, tbigstyck@ pacifica.gov
• Mayor pro Tem Sue Vaterlaus, [email protected]
• Councilmember Sue Beckmeyer, [email protected]
• Councilmember Mary Bier, [email protected]
• Councilmember Christine Boles, [email protected]

CITY OF PACIFICA

COUNCIL AGENDA SUMMARY REPORT
10/16/2023
1 SUBJECT:

Continued joint study session of City Council and Planning Commission to consider and provide direction on the Draft 2023-2031 Housing Element of the General Plan.

RECOMMENDED ACTION:

Receive a presentation and provide direction regarding outstanding items on the Draft 2023- 2031 Housing Element of the General Plan.

STAFF CONTACT:

Christian Murdock, AICP, Planning Director
(650) 738-7341
[email protected]
BACKGROUND/DISCUSSION:

September 25 Study Session
The City Council and Planning Commission held a joint study session on September 25 to consider revisions to the Draft Housing Element (Attachment A), to provide an opportunity for these decision makers to ask questions and provide direction on preparation of the revised Draft Housing Element in response to the California Department of Housing and Community Development’s (HCD’s) August 8, 2023, comment letter on the first Draft Housing Element (Attachment B – red numbering assigned by staff to aid references in this staff report). The Study Session also provided an additional public input opportunity for the community. The public was also invited to submit written public comments. The staff report from the September 25 joint study session is available on the City Council Meeting Portal1.

During the joint study session, the City Council and Planning Commission were asked to provide direction on a number of proposed new or modified policy and site approaches so that staff could revise the Housing Element before returning to the Planning Commission and City Council for adoption and re-transmittal to HCD, as described in the “Next Steps” section below.

The City Council and Planning Commission provided direction on the majority of items on which input was requested, and continued the joint study session to conclude the discussion at a continued meeting.

Outstanding Key Policy Items for City Council and Planning Commission Discussion The table below summarizes the outstanding key policy items on which staff requires City Council and Planning Commission feedback. Staff has removed from the table those items initially presented on September 25 and for which clear direction has already been provided.

The remaining items include two items on sites that were not discussed at the September 25 joint study session, one item on sites on which staff would like any additional feedback, and an item on which the City Council and Planning Commission desired staff to pursue an alternative 1 https://pacificacityca.iqm2.com/Citizens/FileOpen.aspx?Type=1&ID=1495&Inline=True 1 Packet Pg. 4
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approach other than noted in the September 25 staff report.

Comment Number
& Description
Discussion & Staff Recommendation
B.3.1
Reorganization of
Housing Sites
Inventory
HCD has asked for more clarity on which sites in the Housing Site Inventory the City is counting towards its RHNA obligations and which sites are considered as surplus or “buffer” sites. Staff has restructured the Housing Sites Inventory to provide clarity on this point as demonstrated in Attachment C. These changes, along with others such as those necessary to address HCD comments on infrastructure constraints (Comment B.3.9), suitability of nonvacant sites (Comment B.3.4), and direction provided on September 25 to remove Site 26 (Caltrans Quarry) and Site 36 (Sea Bowl), have resulted in some changes to the numbers of units in each income category and the total number of units proposed for inclusion in the Housing Site Inventory, as shown in the table below.

For purposes of this table, “Core RHNA” sites are those indicated as necessary to comply with the City’s RHNA. “Surplus Sites” are those not required to comply with the City’s RHNA but which count towards the City’s buffer above the RHNA. Ample buffer units are important to ensure the City’s ongoing compliance with “No Net Loss” provisions of state law.

Lower Income Moderate
Income
Above
Moderate
Income
TOTAL
RHNA
Requirement
848 291 753 1,892
Core RHNA 851 312 898 2,061
Surplus Sites 396 108 32 536
TOTAL 1,247 420 930 2,597
Buffer Above
RHNA*
47% 44% 24% 37%
* The Buffer Above RHNA calculations include the following numbers of units from Core RHNA sites in excess of the required RHNA: Lower Income - 3 units; Moderate Income - 21 units; and, Above Moderate Income - 145 units.

A map showing the updated Housing Site Inventory is included as Attachment D. This updated map distinguishes between Core RHNA sites, Surplus Sites, and Sites with Existing Capacity.

Update from September 25 Joint Study Session: The City Council and Planning Commission provided direction to remove Site 26 (Caltrans Quarry) and Site 36 (Sea Bowl), as noted above. These will be removed from the maps after final direction on sites upon conclusion of the joint study session.

In addition, staff is providing clarification that the mapped parcels in Attachment D consistent of the entire Assessor Parcels for the respective sites, although in some cases more particular site polygons will reduce the area or specific location of the Housing Element site to a subarea of the Assessor Parcel. The map in Attachment D is illustrative of the general locations of Housing Element sites in Pacifica while the specific Housing Element site location is controlled by the associated more specific polygon on sites for 1 Packet Pg. 5
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which a polygon has been prepared.

B.3.2.B
AB 2011 Sites
The Draft Housing Element relied on the provisions of Assembly Bill (AB) 2011 that established a by-right development process for qualifying sites locating along major highways. The Draft Housing Element had identified seven sites along the Highway 1 corridor:
● Site 10: 4275 Coast Hwy, Lumberyard
● Site 12: Former Caltrans right-of-way, now private property

3. Site 18: Linda Mar Park & Ride

4. Site 27: Pacific Manor Shopping Center

5. Site 32: Brentwood Shopping Center

6. Site 34: Vallemar Station

7. Site 36: Sea Bowl
However, HCD commented that the City must include local examples of sites redeveloping with qualifications similar to those required under AB 2011, in order to demonstrate that the sites could qualify for development under AB 2011. Due to the recency of the law (it was enacted in 2022), and the City’s maximum development density of 21.8 dwelling units per acre under the previous 1980 General Plan, the City is unable to provide this analysis.

Alternatively, HCD indicated the City could rezone to the assumed 60 dwelling units per acre for these sites. Based on the reorganization of the Housing Site Inventory as described above under Comment B.3.1, the following sites would be rezoned to 60 dwelling units per acre:

CORE RHNA SITES

1. Site 10: 4275 Coast Hwy, Lumberyard (49 units, Moderate)

2. Site 18: Linda Mar Park & Ride (54 units, Lower)

3. Site 27: Pacific Manor Shopping Center (115 units, Above Moderate with Below-market Rate Inclusionary)

4. Site 32: Brentwood Shopping Center (97 units, Lower) CORE RHNA TOTALS: 160 Lower + 57 Mod + 98 Above Mod = 315 Total Units

SURPLUS SITES

5. Site 12: Former Caltrans, now private (169 units, Lower)

6. Site 34: Vallemar Station (97 units, Lower)
SURPLUS SITE TOTALS: 266 Lower Income Units
A decision not to rezone these sites to 60 dwelling units/acre density may require increases in density on other sites in the Housing Site Inventory.

Update from September 25 Joint Study Session: The City Council and Planning Commission provided direction to remove Site 36 (Sea Bowl) from the Housing Site Inventory. Site 36 is a surplus/buffer site and will be removed after final direction on sites upon conclusion of the joint study session.
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B.3.9
Infrastructure
Constraint
(Rockaway Beach
Pump Station)
HCD commented on the infrastructure constraint identified in the Draft Housing Element related to wet-weather capacity of the Rockaway Beach Pump Station, a sewer pump station used to convey wastewater from the pump station’s catchment area to the Calera Creek Water Recycling Plant. The approximate catchment area is included as Attachment E.

In response, staff revised the Housing Site Inventory to dramatically reduce the number of units in the catchment area from approximately 700 to approximately 180 units. Staff is continuing to analyze whether this reduction in units, combined with already planned capital improvements to replace all sewer main lines in the catchment area, will result in a sufficient reduction in inflow and infiltration (I&I) to accommodate the new sewer flows generated by the 180 units included in the catchment area in the Housing Site Inventory. I&I during rainfall events is the most significant contributing factor to the Rockaway Beach Pump Station capacity limitation, which the sewer main line replacement is intended to address. The pump station has sufficient capacity during periods of dry weather.

Without pursuing this analytical approach, revisions to the Housing Site Inventory would be necessary to relocate the approximately 180 units of capacity to other areas in the city.

Update from September 25 Joint Study Session: The City Council and Planning Commission provided direction to remove Site 26 (Caltrans Quarry) and Site 36 (Sea Bowl) from the Housing Site Inventory. Both of these sites are surplus/buffer sites.

Staff needs confirmation that no other changes to sites located within the Rockaway Beach Pump Station catchment area are desired.

B.3.2.C
100%
Nonresidential Sites
HCD commented that the City’s Housing Site Inventory included commercial sites that allow residential use, but that also would allow 100% nonresidential uses such as commercial offices or retail. HCD’s concern may be related to other jurisdictions in the Bay Area where strong commercial development demand, such as for biotech offices, may result in commercial-only development of mixed-use sites. Staff does not believe market conditions in Pacifica are likely to result in these types of development outcomes in the eight-year Housing Element cycle. However, a response to HCD’s comment is still necessary.

Update from September 25 Joint Study Session: Staff’s interpretation of HCD’s comment and recommendation based on its experience and professional judgment is indicated in the report for the September 25 joint study session. Feedback received at the September 25 joint study session reflected a consensus to not include a program to revise the City’s General Plan and zoning regulations to make a 100 percent residential project a permitted use in the applicable commercial/mixed use zoning districts. Based on that feedback, staff proposes a revised approach to address the comment, as summarized below:

1. Demonstrate Past Development Resulted in Mixed Use
Pacifica’s recent experience with approved development projects has shown a strong market for mixed-use commercial and residential 1 Packet Pg. 7
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development projects and few 100% commercial projects. This has been true even in zoning districts where either 100% commercial or mixed commercial/residential projects could be allowed. These approved projects demonstrate that market conditions are such that mixed-use projects are most likely to develop, even under the prior maximum mixed-use density of 21.8 dwelling units per acre. The analysis is further reinforced when considering that the allowable residential density for mixed use projects under the Housing Element will increase to a range of 30-60 dwelling units per acre, an increase of 36-172% over prior densities. This strengthens the economic case that a strong financial incentive will exist to undertake mixed-use development considering residential use is the more profitable of the two land use types in Pacifica’s local market.

2. Clarify that General Plan Land Use Designations and Zoning Regulations Will Require Mixed-use Development
The City’s Mixed Use land use designations in the General Plan and zoning regulations to be developed to implement the Housing Element will require mixed use commercial and residential development at the minimum densities specified therein. Therefore, residential development will be a required component of development in all mixed use designated sites, and sites included in the Housing Site Inventory will not allow or result in development of 100% commercial (i.e., nonresidential) projects.

Public Comments
Public comments on this item received prior to agenda publication are included as Attachment F.

Community Engagement
As noted in the staff report for the September 25 Study Session, public input has been an important part of the process to prepare the Draft Housing Element. The City has provided numerous public input opportunities that have included online and in-person engagements. The community engagement strategy was developed with City Council input and the City Council approved the strategy on August 8, 2022. The City held three community meetings in late-2022 (one online and two in-person) to seek community input for the Housing Element Update (HEU) to address RHNA 6 and guide its work to prepare the Draft Housing Element.

The City also conducted a City Council-Planning Commission joint study session on March 21, 2023, provided a written public review and comment period from February 24 through March 27, 2023, and held three Planning Commission meetings to discuss ODS on June 19, August 21, and September 5, 2023.

A full discussion of the extensive community engagement process undertaken through transmittal of the Draft Housing Element to HCD for review is included in Appendix A:

Community Consultation of the Draft Housing Element (Attachment A). 1 Packet Pg. 8
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Next Steps
Feedback from the City Council and Planning Commission on the outstanding items described above is essential to staff’s revision of the Draft Housing Element in response to HCD’s August 8 comment letter. Following this study session, staff will complete the revisions to the Draft Housing Element to incorporate the feedback received. Staff estimates that preparation of the next draft of the Draft Housing Element will take another four to six weeks after the study session.

Once the Draft Housing Element has been updated, staff will release a Negative Declaration for public review and comment to comply with the California Environmental Quality Act (CEQA), followed by scheduling Planning Commission and City Council public hearings to consider adoption of the Housing Element. Adoption of the Housing Element after revisions in response to HCD’s comment letter is consistent with the actions taken by other Bay Area jurisdictions following receipt of their HCD comment letters. Following adoption, staff will then transmit the adopted Draft Housing Element to HCD for a 60-day review period. The potential exists for HCD to have additional comments on the adopted Housing Element which may require further revisions. Staff will request that the Council, when adopting the Housing Element, authorize staff to make revisions that are requested by HCD to achieve certification and that are consistent with Council direction. More substantive revisions could require readoption by City Council before the City achieves certification.

ALTERNATIVE ACTION:

This is a study session and staff is requesting input from the City Council and Planning Commission. Adoption of the Housing Element will occur at a future public hearing with public notice provided as required by law.

RELATION TO CITY COUNCIL GOALS AND WORK PLAN:

The Housing Element Update is consistent with the following item(s) in the Council-adopted Strategic Plan and Priority Work Plan for FY 2023-24:
● Goal 3: Prioritize protection and development of affordable housing. ○ Strategy A: Complete the Housing Element Update.

FISCAL IMPACT:

There is no direct fiscal impact from the joint study session.

ORIGINATED BY:

Planning Department
ATTACHMENT LIST:

Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (PDF) Attachment B - HCD Comment Letter on First Draft Housing Element (with numbering) (PDF) Attachment C - Revised Housing Site Inventory Tables (DOCX) Attachment D - Revised Housing Site Inventory Maps (PDF) Attachment E - Rockaway Beach Pump Station Catchment Area Map (PDF) Attachment F - Public Comments (PDF)
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Packet Pg. 281 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session

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Packet Pg. 282 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session

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Packet Pg. 284 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session

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Packet Pg. 285 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session

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Packet Pg. 286 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session

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Packet Pg. 287 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session

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Packet Pg. 288 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session

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Packet Pg. 289 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session

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Packet Pg. 290 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session

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Packet Pg. 291 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session

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Packet Pg. 292 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session

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Packet Pg. 293 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session

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Packet Pg. 294 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session

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Packet Pg. 295 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session

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Packet Pg. 296 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session

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Packet Pg. 297 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session

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Packet Pg. 298 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session

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Packet Pg. 299 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session

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Packet Pg. 300 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session

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Packet Pg. 301 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session

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Packet Pg. 302 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session

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Packet Pg. 303 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session

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Packet Pg. 304 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session

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Packet Pg. 305 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session

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Packet Pg. 306 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session

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Packet Pg. 307 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session

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Packet Pg. 308 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session

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Packet Pg. 309 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session

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Packet Pg. 310 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session

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Packet Pg. 311 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session

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Packet Pg. 312 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session

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Packet Pg. 313 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session

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Packet Pg. 314 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session

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Packet Pg. 315 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session

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Packet Pg. 316 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session

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Packet Pg. 317 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session

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Packet Pg. 318 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session

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Packet Pg. 319 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session

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Packet Pg. 320 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session

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Packet Pg. 321 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session

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Packet Pg. 322 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session

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Packet Pg. 323 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session

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Packet Pg. 324 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session

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Packet Pg. 325 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session

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Packet Pg. 326 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session

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Packet Pg. 327 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session

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Packet Pg. 328 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session

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Packet Pg. 329 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session

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Packet Pg. 330 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session

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Packet Pg. 331 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session

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Packet Pg. 332 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session

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Packet Pg. 333 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session

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Packet Pg. 334 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session

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Packet Pg. 335 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session

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Packet Pg. 336 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session

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Packet Pg. 337 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session

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Packet Pg. 338 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session

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Packet Pg. 339 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session

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Packet Pg. 340 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session

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Packet Pg. 341 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session

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Packet Pg. 342 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session

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Packet Pg. 343 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session

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Packet Pg. 344 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session

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Packet Pg. 345 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session

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Packet Pg. 346 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session

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Packet Pg. 347 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session

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Packet Pg. 348 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session

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Packet Pg. 349 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session

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Packet Pg. 350 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session

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Packet Pg. 351 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session

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Packet Pg. 352 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session

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Packet Pg. 353 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session

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Packet Pg. 354 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session

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Packet Pg. 355 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session

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Packet Pg. 356 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session

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Packet Pg. 357 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session

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Packet Pg. 358 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session

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Packet Pg. 359 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session

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Packet Pg. 360 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session

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Packet Pg. 361 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session

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Packet Pg. 362 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session

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Packet Pg. 363 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session

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Packet Pg. 364 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session

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Packet Pg. 365 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session

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Packet Pg. 366 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session

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Packet Pg. 367 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session

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Packet Pg. 368 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session

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Packet Pg. 369 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session

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Packet Pg. 370 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session

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Packet Pg. 371 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session

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Packet Pg. 372 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session

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Packet Pg. 373 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session

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Packet Pg. 374 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session

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Packet Pg. 375 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session

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Packet Pg. 376 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session

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Packet Pg. 377 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session

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Packet Pg. 378 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session

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Packet Pg. 379 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session

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Packet Pg. 380 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session

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Packet Pg. 381 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session

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Packet Pg. 382 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session

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Packet Pg. 383 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session

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Packet Pg. 384 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session

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Packet Pg. 385 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session

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Packet Pg. 386 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session

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Packet Pg. 387 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session

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Packet Pg. 388 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session

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Packet Pg. 389 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session

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Packet Pg. 390 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session

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Packet Pg. 391 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session

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Packet Pg. 392 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session

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Packet Pg. 393 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session

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Packet Pg. 394 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session

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Packet Pg. 395 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session

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Packet Pg. 396 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session

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Packet Pg. 397 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session

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Packet Pg. 398 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session

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Packet Pg. 399 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session

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Packet Pg. 400 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session

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Packet Pg. 401 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session

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Packet Pg. 402 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session

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Packet Pg. 403 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session

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Packet Pg. 404 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session

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Packet Pg. 405 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session

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Packet Pg. 406 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session

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Packet Pg. 407 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session

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Packet Pg. 408 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session

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Packet Pg. 409 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session

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Packet Pg. 410 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session

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Packet Pg. 411 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session

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Packet Pg. 412 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session

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Packet Pg. 415 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session

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Packet Pg. 416 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session

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Packet Pg. 447 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session

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Packet Pg. 448 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session

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Packet Pg. 452 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session

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Packet Pg. 455 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session

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Packet Pg. 456 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session

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Packet Pg. 457 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session

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Packet Pg. 458 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session

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Packet Pg. 459 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session

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Packet Pg. 460 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session

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Packet Pg. 461 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session

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Packet Pg. 462 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session

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Packet Pg. 463 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session

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Packet Pg. 464 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session

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Packet Pg. 465 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session

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Packet Pg. 466 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session

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Packet Pg. 467 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session

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Packet Pg. 468 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session

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Packet Pg. 469 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session

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Packet Pg. 470 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session

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Packet Pg. 471 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session

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Packet Pg. 472 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session

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Packet Pg. 473 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session

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Packet Pg. 474 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session

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Packet Pg. 475 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session

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Packet Pg. 476 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session

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Packet Pg. 477 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session

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Packet Pg. 478 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session

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Packet Pg. 479 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session

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Packet Pg. 480 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session

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Packet Pg. 481 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session

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Packet Pg. 482 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session

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Packet Pg. 483 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session

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Packet Pg. 484 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session

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Packet Pg. 485 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session

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Packet Pg. 486 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session

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Packet Pg. 487 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session

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Packet Pg. 488 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session

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Packet Pg. 489 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session

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Packet Pg. 490 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session

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Packet Pg. 491 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session

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Packet Pg. 492 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session

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Packet Pg. 493 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session

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Packet Pg. 494 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session

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Packet Pg. 495 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session

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Packet Pg. 496 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session

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Packet Pg. 497 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session

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Packet Pg. 498 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session

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Packet Pg. 499 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session

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Packet Pg. 500 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session

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Packet Pg. 501 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session

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Packet Pg. 502 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session

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Packet Pg. 503 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session

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Packet Pg. 504 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session

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Packet Pg. 505 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session

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Packet Pg. 506 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session

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Packet Pg. 507 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session

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Packet Pg. 508 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session

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Packet Pg. 509 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session

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Packet Pg. 510 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session

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Packet Pg. 511 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session

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Packet Pg. 512 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session

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Packet Pg. 513 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session

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Packet Pg. 514 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session

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Packet Pg. 515 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session

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Packet Pg. 516 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session

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Packet Pg. 517 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session

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Packet Pg. 518 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session

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Packet Pg. 519 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session

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Packet Pg. 520 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session

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Packet Pg. 521 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session

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Packet Pg. 522 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session

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Packet Pg. 523 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session

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Packet Pg. 524 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session

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Packet Pg. 525 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session

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Packet Pg. 526 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session

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Packet Pg. 527 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session

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Packet Pg. 528 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session

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Packet Pg. 529 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session

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Packet Pg. 530 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session

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Packet Pg. 531 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session

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Packet Pg. 532 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session

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Packet Pg. 533 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session

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Packet Pg. 534 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session

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Packet Pg. 535 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session

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Packet Pg. 536 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session

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Packet Pg. 537 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session

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Packet Pg. 538 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session

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Packet Pg. 539 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session

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Packet Pg. 540 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session

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Packet Pg. 541 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session

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Packet Pg. 542 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session

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Packet Pg. 543 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session

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Packet Pg. 544 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session

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Packet Pg. 545 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session

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Packet Pg. 546 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session

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Packet Pg. 547 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session

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Packet Pg. 548 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session

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Packet Pg. 549 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session

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Packet Pg. 550 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session

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Packet Pg. 551 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session

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Packet Pg. 552 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session

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Packet Pg. 553 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session

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Packet Pg. 554 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session

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Packet Pg. 555 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session

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Packet Pg. 556 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session

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Packet Pg. 557 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session

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Packet Pg. 558 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session

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Packet Pg. 559 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session

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Packet Pg. 560 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session

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Packet Pg. 561 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session

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Packet Pg. 562 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session

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Packet Pg. 563 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session

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Packet Pg. 564 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session

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Packet Pg. 565 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session

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Packet Pg. 566 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session

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Packet Pg. 567 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session

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Packet Pg. 568 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session

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Packet Pg. 569 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session

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Packet Pg. 570 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session

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Packet Pg. 571 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session

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Packet Pg. 572 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session

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Packet Pg. 573 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session

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Packet Pg. 574 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session

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Packet Pg. 575 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session

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Packet Pg. 576 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session

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Packet Pg. 577 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session

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Packet Pg. 578 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session

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Packet Pg. 579 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session

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Packet Pg. 580 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session

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Packet Pg. 581 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session

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Packet Pg. 582 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session

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Packet Pg. 583 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session

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Packet Pg. 584 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session

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Packet Pg. 585 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session

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Packet Pg. 586 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session

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Packet Pg. 587 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session

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Packet Pg. 588 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session

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Packet Pg. 589 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session

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Packet Pg. 590 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session

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Packet Pg. 591 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session

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Packet Pg. 593 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session

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Packet Pg. 594 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session

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Packet Pg. 595 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session

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Packet Pg. 596 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session

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Packet Pg. 599 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session

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Packet Pg. 600 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session

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Packet Pg. 601 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session

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Packet Pg. 604 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session

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Packet Pg. 605 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session

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Packet Pg. 606 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session

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Packet Pg. 607 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session

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Packet Pg. 608 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session

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Packet Pg. 609 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session

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Packet Pg. 611 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session

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Packet Pg. 614 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session

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Packet Pg. 621 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session

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Packet Pg. 623 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session

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Packet Pg. 630 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session

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Packet Pg. 633 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session

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Packet Pg. 777 Attachment: Attachment A - Draft Housing Element - May 10, 2023 (HCD Review Version) (5494 : Housing Element Joint Study Session STATE OF CALIFORNIA - BUSINESS, CONSUMER SERVICES AND HOUSING AGENCY GAVIN NEWSOM, Governor

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
August 8, 2023
Christian Murdock, Planning Director
Planning Department
City of Pacifica
540 Crespi Drive, Address
Pacifica, CA 94044
Dear Christian Murdock
RE: City of Pacifica’s 6th Cycle (2023-2031) Draft Housing Element Thank you for submitting the City of Pacifica’s (City) draft housing element received for review on May 10, 2023. 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 site visit and conversations with you and your staff on July 7 and 27, 2023. In addition, HCD considered comments from Summer Lee, John Keener, CKS Environmental, Toll Brothers, YIMBY Law, Galla Bradshaw, Jan Turner, Nancy Tierner, David Kellogg, Jeffrey E. Sinder, Remi Tan and Suzanne Moore, pursuant to Government Code section 65585, subdivision (c).

The draft element addresses many statutory requirements; however, revisions will be necessary to substantially comply with State Housing Element Law (Gov. Code, § 65580 et seq). The enclosed Appendix describes the revisions needed to comply with State Housing Element Law.

As a reminder, the City’s 6th cycle housing element was due January 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 revise the element as described above, adopt, and submit to HCD to regain housing element compliance.

For your information, pursuant to Assembly Bill 1398 (Chapter 358, Statutes of 2021), as the City failed to adopt a compliant housing element within 120 days of the statutory deadline (January 31, 2023), sites to make prior identified sites available or accommodate the regional housing needs allocation (RHNA) must be completed no later than one year from the statutory deadline. Otherwise, the local government’s housing element will no longer comply with State Housing Element Law, and HCD may revoke its finding of substantial compliance pursuant to Government Code section 65585, subdivision (i). Please be aware, if the City fails to adopt a compliant housing

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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.

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 Strategic Growth Council and HCD’s Affordable Housing and Sustainable Communities program, 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 Planning and Research at:
https://www.opr.ca.gov/planning/general-plan/guidelines.html.

We are committed to assist the City in addressing all statutory requirements of State Housing Element Law. If you have any questions or need additional technical assistance, please contact Sohab Mehmood, of our staff, at [email protected].

Sincerely,
Paul McDougall
Senior Program Manager
Enclosure

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APPENDIX

CITY OF PACIFICA
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 https://www.hcd.ca.gov/planning-and-community-development/hcd-memos. Among other resources, the housing element section contains HCD’s latest technical assistance tool, Building Blocks for Effective Housing Elements (Building Blocks), available at https://www.hcd.ca.gov/planning-and-community-development/housing-elements/buildingblocks 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).)
The element must provide a cumulative evaluation of the effectiveness of past 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).) Enforcement: While the element included an evaluation of local and regional patterns, trends, and enforcement capacity, it must also identify and address past or current fair housing lawsuits, findings, settlements, judgements, or complaints. For additional information, please see pages 28-30 on HCD’s Affirmatively Furthering Fair Housing (AFFH) Guidance Memo at https://www.hcd.ca.gov/community-development/affh/docs/AFFH_Document_Final_4-27- 2021.pdf.

2. Analyze any special housing needs such as elderly; persons with disabilities, including a developmental disability; large families; farmworkers; families with female heads of households; and families and persons in need of emergency shelter. (Gov. Code, § 65583, subd. (a)(7).)
The element includes data and a general discussion of housing challenges faced by special needs households. However, the element must be revised to include an analysis B.2
A.1
B.1

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of the existing needs and resources for each special need group including seniors, farmworkers, large households, and persons with disabilities including developmental disabilities and extremely low-income (ELI) households. For example, the element should discuss the existing resources to meet housing needs (availability of shelter beds, number of large units, number of deed restricted units, etc.,), an assessment of any gaps in resources, and proposed policies, programs, and funding to help address those gaps.

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 Regional Housing Need Allocation (RHNA): As you know, the City’s RHNA may be reduced by the number of new units built since July 1, 2022.

However, the element must demonstrate the availability of these units in the planning period. First, it is unclear how many units the City is counting as credit towards the RHNA. For example, the element analyzes several potential projects equating 232 units (Table F-5); however, Table F-7 only reflects credit for 139 units. The element should reconcile these numbers and accurately reflect the number of units as credit towards the RHNA. Second, while the element provided some general information regarding each project’s status, it should still demonstrate the likelihood that these units will be built during the planning period. To demonstrate the availability of these units, the element could analyze infrastructure schedules, City’s past completion rates on pipeline projects, outreach with project developers, describe any expiration dates on entitlements, anticipated timelines for final approvals, and any remaining steps for projects to receive final entitlements. Based on a complete analysis, the element may need to add or modify programs committing to facilitating and encouraging the development of these projects.

Realistic Capacity:
• General – The element is generally assuming 80 percent of maximum allowable densities to calculate residential capacity on identified sites. Further, the element includes examples of recent projects that have developed between 25-100 percent of the maximum allowable density with an average density of 81 percent (Table F-4). The element should analyze projects including information on typical densities on all recent and pipeline projects, the zone, acreage, built density, allowable density, level of affordability, outliers from the assumed densities and presence of exceptions such as a density bonus. Further, the element should analyze and evaluate this data to support its realistic capacity calculations. • AB 2011 Capacity Assumptions – The element is assuming additional capacity on sites that will be rezoned during the planning period beyond the projected densities that will be allowed once the rezoning is completed. Specifically, the element assumes additional capacity pursuant to AB 2011 (Statues of 2022) which allows sites and projects that meet specific criteria to qualify for additional B.3.1
B.3.2.A
B.3.2.B
B.3

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densities and ministerial approvals. However, for the element to utilize AB 2011 capacity assumptions, the City must demonstrate the likelihood that the sites and potential projects will qualify to utilize the provisions of AB 2011. The element should include local examples of sites redeveloping with qualifications similar to those required under AB 2011. Alternatively, the element could commit to rezoning to similar densities allowed under AB 2011 (60 units per acre) as a method to utilizing these capacity assumptions. Based on a complete analysis, the element may need to adjust capacity assumptions and include or modify programs committing to rezoning to appropriate densities. • Sites in Zones that Allow 100 Percent Nonresidential Uses – The element identifies sites in zones that allow nonresidential uses. The element must analyze the likelihood that the identified units will be developed as noted in the inventory in zones that allow 100 percent nonresidential uses. This analysis should consider the likelihood of nonresidential development, performance standards, and development trends supporting residential development. For additional information, see the Building Blocks at https://www.hcd.ca.gov/planning-andcommunity-development/housing-elements/building-blocks/analysis-sites-andzoning.

Site Size: The element identifies several sites at less than a half-acre to accommodate the lower-income RHNA. These sites are not eligible absent a demonstration that sites of equivalent size and affordability were successfully developed during the prior planning period or unless other evidence is provided. The inventory indicates that some of the sites would be consolidated; however, the element should provide an analysis demonstrating the potential for lot consolidation. For example, the analysis could describe the City’s role or track record in facilitating small-lot consolidation; policies or incentives offered or proposed to encourage and facilitate lot consolidation, conditions rendering parcels suitable and ready for lot consolidation; or information from the owners of each aggregated site.

Suitability of Nonvacant Sites: The element is utilizing nonvacant sites to accommodate a portion of the RHNA. However, the element must demonstrate the potential for additional development. The methodology for demonstrating additional development on nonvacant sites must discuss existing uses, development trends, and policies and programs to encourage additional residential development. For example, the element indicates several factors that may have been utilized when demonstrating the likelihood for redevelopment including the degree of underutilization based on the current build out of the site, age of existing uses, vacancies, and other trends (p. F-15). However, the element must provide support for these assumptions including analyzing and discussing how these factors are indicative of redevelopment potential. Second, the element should relate these factors to the actual sites and quantify where possible (e.g., age of building, current vs. allowed floor area ration (FAR), etc.,). Based on a complete analysis the element may need to add or revise programs to facilitate redevelopment.

Additionally, to provide sufficient capacity for the RHNA during the planning period and as part of identifying sites with potential for development, the element should consider B.3.2.C
B.3.3
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public comments received regarding the inclusion of sites from property owners written interest in residential development in the planning period.

Finally, if the housing element relies upon nonvacant sites to accommodate more than 50 percent of the RHNA for lower-income households, the City must make findings based on substantial evidence, the existing uses will be presumed to impede additional residential development. (Gov. Code, § 65583.2, subd. (g)(2).) Absent findings (e.g., adoption resolution), the existing uses will be presumed to impede additional residential development and will not be utilized toward demonstrating adequate sites to accommodate the RHNA.

Publicly-Identified Sites: The element identifies several publicly-identified sites to accommodate a portion of the RHNA including school district and City-Owned sites. The element must include an analysis addressing address general plan designations, allowable densities, support for residential capacity assumptions, existing uses, and any known conditions that preclude development in the planning period and the potential schedule for development. For example, the element should evaluate public comments and other information to evaluate the likelihood of redevelopment of these sites during the planning period. If zoning does not currently allow residential uses at appropriate densities, then the element must include programs to rezone sites pursuant to Government Code section 65583.2, subdivisions (h) and (i). In addition, the housing element must include a description of whether there are any plans to sell the property during the planning period and how the jurisdiction will comply with the Surplus Land Act (Article 8 (commencing with Section 54220) of Chapter 5 of Part 1 of Division 2 of Title 5).

CalTrans Sites: The element identifies multiple CalTrans sites to accommodate a portion of the RHNA. The element should include additional information to determine that these sites will be available for residential development with the appropriate zoning and densities during the planning period. Additionally, the element should include a commitment to the decertification of any applicable Caltrans sites within three years from the start of the planning period and alternative actions if this does not occur (e.g., identify additional adequate sites) by January 31, 2026.

Availability of Zoning: The element indicates that several sites that do not have appropriate zoning or densities to accommodate the RHNA (p. 12). As such, the element shows a shortfall of 1,039 units including 510 units for lower-income households. While the element includes programs committing to rezoning sites (Program 1-1 General Plan and Zoning Amendments), because zoning was not in place at the start of the planning period (January 31, 2023), the element must include a program committing to housing element rezone requirements pursuant to Government Code section 65583.2 (h) and (i). As part of these rezoning requirements, the element must commit to establishing a minimum density of 20 units per acre (Gov. Code 65583.2 (h)). Please see the programs section of this review for additional information.

AB 725: For jurisdictions that are considered Metropolitan, the element must identify at least 25 percent of the remaining moderate and above-moderate RHNA on sites that B.3.5
B.3.6
B.3.7
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allow at least four units of housing (e.g., four plex or greater) (Gov. Code, § 65583.2, subd. (c)(4)).

Availability of Infrastructure: The element states that “nearly” all housing sites have the most efficient infrastructure except two areas that will need additional analysis and that may impact the design and timing of the development (p. G-30). Additionally, the element indicates that potential infrastructure constraints related to water pump stations, among other things, may impact a projects ability to reach maximum capacity. First, the element must specifically indicate if total infrastructure capacity (existing and planned) is available to accommodate the RHNA. Second, the element must include a program committing to actions and a timeline to make sufficient infrastructure available to accommodate the RHNA.

Zoning for a Variety of Housing Types:
• Emergency Shelters: Zoning to permit emergency shelters without discretionary action was required as part of the 4th cycle housing element and prior to the 5th cycle housing element. The element states that the City’s zoning regulations does not address emergency shelters (p. G-16) and the City will include a program committing to comply with Government Code section 65583, subdivision (a)(4).). Further, the City provided additional documentation indicating that the City’s definition of special care facilities includes people experiencing homelessness and is permitted by-right for six or fewer persons. However, the City does not explicitly address emergency shelters and only allows by-right approvals for similar uses in limited circumstances (e.g., six of fewer persons).

Additionally, because zoning for emergency shelters was supposed to be completed two planning periods ago and the time to identify appropriate zoning has lapsed, HCD cannot find the element in compliance until the appropriate zoning to permit emergency shelters without discretionary action is demonstrated or completed. For additional information, please see
https://www.hcd.ca.gov/planning-and-community-development/housingelements/building-blocks/zoning-variety-of-housing-types.

As part of implementing zoning changes to permit emergency shelters without discretion, the City should address compliance with parking standards pursuant to Government Code section 65583, subdivision (a)(4)(A) and additional requirements regarding zoning, capacity and habitability pursuant to Chapter 654, Statutes of 2022 (AB 2339). For additional information and timing requirements, please see HCD’s memo at
https://www.hcd.ca.gov/sites/default/files/docs/planning-and-community/ab2339- notice.pdf.
• 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 notes that the City does not currently address supportive and transitional housing and includes Program HE 1-14 (State and Federal Law B.3.10.B
B.3.9
B.3.10.A

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Packet Pg. 784 Attachment: Attachment B - HCD Comment Letter on First Draft Housing Element (with numbering) (5494 : Housing Element Joint Study City of Pacifica’s 6th Cycle (2023-2031) Draft Housing Element Page 6 August 8, 2023
Conformance) committing to address this housing type. However, the Program should be revised to amend zoning that specifically commits to permitting these housing types as a residential use and only subject to those restrictions that apply to other residential dwellings of the same type in the same zone pursuant to Government Code Section 65583 (a)(5).
• Accessory Dwelling Units (ADUs): After a cursory review of the City’s ordinance, HCD discovered several areas which were not consistent with State ADU Law.

This includes, but is not limited to, definition of site, minimum landscaping requirements, parking, and subjective standards, among others. HCD will provide a complete listing of ADU non-compliance issues under a separate cover. As a result, the element should add a program to update the City’s ADU ordinance in order to comply with state law. For more information, please consult HCD’s ADU Guidebook, published in December 2022, which provides detailed information on new state requirements surrounding ADU development:
https://www.hcd.ca.gov/sites/default/files/2022-07/ADUHandbookUpdate.pdf. • Single-Room Occupancy (SRO) Units: The element indicates that SROs are defined as a boardinghouse that includes lodging and meals. SROs provide a valuable source of affordable housing especially for persons experiencing homelessness and extremely low-income households. The element should analyze any occupancy standards, length of stay, and whether SROs are permitted as a residential use under the current definition. Based on complete analysis, the element may need to add or modify programs with a commitment to removing any potential constraints on the development of SROs. For additional information, please see: https://www.hcd.ca.gov/planning-and-communitydevelopment/housing-elements/building-blocks/zoning-variety-of-housing-types.

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... (Gov. Code, § 65583, subd. (a)(5).)
Land Use Controls (Parking): The element notes that one-bedroom multifamily units are required to provide 1.5 spaces per unit, including one garage or carport space (p. G-11).

Requiring smaller bedroom types (e.g., one-bedroom units) to provide 1.5 parking spaces is considered a constraint. Additionally, the element must analyze covered parking requirements for impacts on cost, supply, housing choices, affordability and achieving maximum densities. The element must include a program committing to reducing parking requirements for smaller bedroom types (e.g., one space per onebedroom unit).

B.3.10.C
B.4.1
B.3.10.D
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Fees and Exaction: The element some general information regarding fees including total amount of fees and their proportion to the development costs for both single family and multifamily housing. However, a complete analysis must include a listing of 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. For additional information and a sample analysis and tables, see the Building Blocks at https://www.hcd.ca.gov/planning-and-community-development/housing-elements/buildingblocks/fees-and-exactions.

Local Processing and Permit Procedures:
• Multifamily Housing – The element indicates that multifamily housing is required to obtain a Site Development Permit and listed the required approval findings (p.

G-23) illustrating constraints for multifamily development. For example, the approval findings require multifamily housing to meet several subjective criteria related to impacts on surrounding uses and character of the neighborhood. The approval findings also indicates that the applicant must meet both the City’s subjective findings in addition to the City’s design guidelines. Secondly, the element notes that 1) clustered housing including zero lot line projects and condominiums and 2) multifamily and mixed-use development in commercial zones are required to obtain both a Site Development and Conditional Use permits (CUP). However, several of the required CUP findings are similar to the site development permit findings. Lastly, the analysis noted that a typical multifamily project has a 9–24 month approval timeline (pg. G-22). The analysis demonstrated that 1) multifamily housing is subjected to a highly discretionary process with subjective findings and minimal guidance to promote certainty and objectivity 2) the City subjects some multifamily housing and other housing types to two types of processes that are subjective and potentially redundant of each other and 3) multifamily housing is subjected to a lengthy approval process. The element must include or modify a program addressing and removing or modifying the Site Development Plan and CUP (beyond objective standards) for multifamily housing in zones that are intended to permit multifamily housing (e.g., residential).
• Planned Development (PD) – The element described the general process for projects in the PD zoning, indicating that this process is highly discretionary (p. G-22). However, the analysis should clearly explain whether PDs are optional or required for areas intended for residential uses and whether there are established development standards prior to the approval of the PD. If the PD is mandatory in areas intended for residential uses without fixed development standards, the element should specifically evaluate these requirements for impacts on cost, supply, feasibility, and approval certainty of housing. Based on a complete analysis, the element may need to add or modify programs to address any potential constraints.

B.4.3.A
B.4.2
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• Permit Streamlining Act (PSA) and CEQA – The element should address public comments on this draft submittal and discuss compliance with the Permit Streamlining Act and intersections with CEQA and timing requirements, including streamlining determinations and add or modify programs as appropriate.

Inclusionary Housing: The element generally mentions the City’s inclusionary zoning ordinance, but it must also analyze the City’s inclusionary housing requirements, including its impacts as potential constraints on the development of housing for all income levels. The analysis should evaluate the inclusionary broader policy’s implementation framework, including the percentage of new residential construction that is dedicated to affordable housing, the types of options and incentives offered, relationships with State Density Bonus Law (SDBL) and any other factors that may impact housing costs.

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. For additional information and a sample analysis, see the Building Blocks at https://www.hcd.ca.gov/planning-and-community-development/housingelements/building-blocks/codes-and-enforcement-and-onsite-offsite-improvementstandards.

Constraints on Housing for Persons with Disabilities:
• Reasonable Accommodation –The element briefly describes its reasonable accommodation procedures (p. G-16). However, the element should also describe the process and decision-making criteria such as approval findings and analyze any potential constraints on housing for persons with disabilities.

Additionally, HCD understands that the City must make findings that the request would not cause impacts on surrounding uses and coastal zone resources. In addition to describing the reasonable accommodation process and listing the required approval findings, the element must analyze these findings for potential constraints on persons with disabilities. Based on a complete analysis, the element may need to add or modify programs to remove any potential constraints.
• Group Homes of Seven or More Persons – The element notes that the City defines group homes for seven or more persons as a “special care facility” and that this use is subject to a discretionary use permit and must comply with a 500- foot spacing requirements. For your information, zoning should simply implement a barrier-free definition of family instead of subjecting, potentially persons with disabilities, to special regulations such as the number of persons, population types and licenses. These housing types should not be excluded from residential zones, most notably low-density zones, which can constrain the availability of housing choices for persons with disabilities. Requiring these housing types to obtain a special use or CUP could potentially subject housing for persons with B.4.6.B
B.4.6.A
B.4.3.C
B.4.4
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disabilities to higher discretionary standards where an applicant must demonstrate compatibility with the neighborhood, unlike other residential uses.

As such, the element must include a program removing the spacing requirements and commit to allowing these uses in any zone that permits residential uses and only subject to those restrictions that apply to similar residential uses. Please see HCD’s for more info https://www.hcd.ca.gov/sites/default/files/docs/planning-andcommunity/group-home-technical-advisory-2022.pdf.

5. An analysis of potential and actual nongovernmental constraints upon the maintenance, improvement, or development of housing for all income levels, including 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... (Gov. Code, § 65583, subd. (a)(6).) The element must analyze the length of time between receiving approval for a housing development and submittal of an application for building permits, and any local efforts to address or mitigate nongovernmental constraints such as reduced fees, financing for affordable housing or expedited processes. The analysis should address any hinderances on the construction of a locality’s share of the regional housing need and programs should be added or modified as appropriate.

6. Analyze existing assisted housing developments that are eligible to change to non-lowincome 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).).

The element indicates the City has 101 affordable units with expiring affordability restrictions within the next eight years (e.g., 2025). The element must include an assessment of conversion risk and estimate and analyze the cost for replacing versus preserving the units. For more information on the analysis, please visit:
https://www.hcd.ca.gov/planning-and-community-development/housingelements/building-blocks/assisted-housing-developments-risk-conversion.

C. Housing Programs

1. 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).)
B.5
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Packet Pg. 788 Attachment: Attachment B - HCD Comment Letter on First Draft Housing Element (with numbering) (5494 : Housing Element Joint Study City of Pacifica’s 6th Cycle (2023-2031) Draft Housing Element Page 10 August 8, 2023
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 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:

Shortfall of Sites: As noted above, because zoning was not in place at the start of the planning period, the City is showing a shortfall of 1,039 units including 510 units for lower-income households. While the element included Program 1-1 (General Plan and Zoning Amendments) committing to rezoning to allow residential uses at appropriate densities to accommodate the RHNA, programs to address the lower-income RHNA must specifically commit to rezoning pursuant to Government Code sections 65583, subdivision (c)(1) and 65583.2, subdivisions (h) and (i). Examples of requirements include permitting, without discretionary action, multifamily developments in which 20 percent or more of the units are affordable to lower-income households, requiring minimum densities and residential performance standards. For more information, please see HCD’s site inventory guidance memo: https://www.hcd.ca.gov/communitydevelopment/housing-element/docs/sites_inventory_memo_final06102020.pdf.

Additionally, since the City failed to adopt a compliant housing element within 120 days of the statutory deadline (January 31, 2023), all rezones to accommodate the RHNA must be completed no later than one year from the statutory deadline. As such, Program 1-1 (General Plan and Zoning Amendments) to accommodate a shortfall and rezones to address prior identified sites must be completed no later than one year from the statutory deadline.

Program HE-1-4 (Accessory Dwelling Units (ADUs)): This Program commits to various actions to facilitate the development of ADUs. However, given the City’s reliance on ADUs, the element must include a commitment to adjusting projected assumptions if the number of units and affordability do not actualize during the planning period.

Specifically, 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 the element must commit to amending the housing element, identifying additional sites, and rezoning within a timely manner (e.g., within six months).

Publicly Identified Sites: While the element included Program 1-1 (General Plan and Zoning Amendments) and 1-3 (Public Land Planning), these programs may need to be revised based on a complete sites analysis (see above finding). Additionally, while these programs commit to outreach and issuing requests for proposals (RFP), actions need to be revised with additional actions, firm commitments, discrete timelines, and quantifiable metrics. The element should also include specific actions, as needed, to making the Caltrans sites available during the planning period. Additional actions to facilitate development should include commitments to compliance with the Surplus Land Act, annual outreach with developers, rezoning and financial assistance, issuing requests for proposals, facilitating any subsequent entitlements, and numerical objectives by affordability.

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C.1.3
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Packet Pg. 789 Attachment: Attachment B - HCD Comment Letter on First Draft Housing Element (with numbering) (5494 : Housing Element Joint Study City of Pacifica’s 6th Cycle (2023-2031) Draft Housing Element Page 11 August 8, 2023

2. The Housing Element shall contain programs which assist in the development of adequate housing to meet the needs of extremely low-, very low-, low- and moderateincome households. (Gov. Code, § 65583, subd. (c)(2).) The element includes general commitments to addressing various special needs populations. However, given the importance of farmworkers and the local and regional needs, the element must include specific actions to addressing this population.

Examples of actions could include proactive outreach with developers and the community, identifying potential sites, provide incentives (e.g., expediated permitting, flexible development standards, gap funding, fee waivers), and applying for state and federal funding.

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 Findings 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, Program HE 1-2 (Zoning and Streamlining) identifies various changes to development standards and other process to the facilitate development of housing.

However, several of the actions state that the City “will consider” addressing and implementing including increasing heights, reducing parking, modifying densities standards, changes to the City’s definition of family, etc., Given the importance and need of several of these actions, the element should be revised to affirmatively commit to these changes.

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... (Gov. Code, § 65583, subd. (c)(5).)
Goals, Priorities, Metrics, and Milestones: Goals and actions must specifically respond to the analysis and to the identified and prioritized contributing factors to fair housing issues and must be significant and meaningful enough to overcome identified patterns and trends. Actions must have specific commitment, metrics, and milestones as appropriate and must address housing mobility enhancement, new housing choices and affordability in high opportunity areas, place-based strategies for community preservation and revitalization and displacement protection. Additionally, quantified metrics that target beneficial impacts for people, households, and neighborhoods (e.g., number of people or households assisted, number of housing units built, number of parks or infrastructure projects completed). Lastly, the City is considered a majority C.2
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racially and concentrated area of affluence (RCAA). Therefore, the element must include significant and meaningful programs (beyond the RHNA) that target RCAA and relatively higher income neighborhoods to enhance housing mobility and provide housing choices and affordability throughout the City.

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).)
While the element includes quantified objectives for new construction, it currently targets no objectives for housing rehabilitation and should be revised accordingly. In addition, the element could increase its housing conservation and preservation objectives accordingly.

For your information, conservation objectives may include the variety of strategies employed by the City to promote tenant stability, code enforcement, naturally affordable housing, and the preservation of units at-risk of conversion to market rate use.

E. Consistency with General Plan
Coastal localities shall document the number of low- and moderate-income units converted or demolished, and the number of replacement units provided. (Gov. Code, § 65588, subd. (d).)
The element analyzes the housing stock in the coastal zone. Specifically, the element stated that 57 housing units were demolished within the coastal zone between 2015-2022 due to an emergency natural disaster. In conversations with the City, it was noted that the City was not able to identify the number of lower-income renters in these units due to the emergency and that the owner generally did not maintain the property including complying with building codes. Furthermore, the City noted that while these units were not deed-restricted, anecdotal information indicates that there were a number of lower- and moderate -income households living in these units. The element should include a program committing to actions that preserve coastal housing units for lower-and moderate-income households. This Program could commit to annual monitoring, commitment to complying with replacement requirements and proactive noticing and outreach to non-profits and service providers in the event that future coastal housing is at-risk.

D.1
E.1

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Packet Pg. 791 Attachment: Attachment B - HCD Comment Letter on First Draft Housing Element (with numbering) (5494 : Housing Element Joint Study TABLE: RHNA CAPACITY ANALYSIS
LowerIncome
Capacity
ModerateIncome
Capacity
Above
ModerateIncome
Capacity
Total
Capacity
RHNA 848 291 753 1,892
Pipeline 52 8 188 248
Projected ADU's 112 56 19 187
Core Sites (Existing Capacity) 24 76 21 121
Core Sites (Rezoning Required) 663 172 670 1,505
Core RHNA Units Subtotal 851 312 898 2,061
Surplus Sites 396 108 32 536
Grand Total 1,247 420 930 2,597
Surplus/Buffer* RHNA 399 129 177 705
Surplus/Buffer* RHNA % 47% 44% 24% 37%
* The Surplus/Buffer RHNA figures include the following numbers of units from Core Sites in excess of the required RHNA: Lower Income - 3 units; Moderate Income - 21 units; and, Above Moderate Income - 145 units.

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Packet Pg. 792 Attachment: Attachment C - Revised Housing Site Inventory Tables (5494 : Housing Element Joint Study TABLE
: “CORE” RHNA SITES
Site #Location Existing
Land Use
Existing
Allowed
Density
(DU/A)
Proposed
Density
(DU/A)
Revise
to Allow
Residential
Use
Lower
Income
Capacity
Moderate
Income
Capacity
Above
Moderate-
Income
Capacity
Total
Capacity
2 751 Oceana HDR 30 40 N/A66 68 80
3 Vacant
Santa Maria/Palmetto
MUN 26 Same N/A77
6 Vacant
Talbot/Goodman*
HDR 30 Same N/A 21 21
10 Former
Lumberyard
4275 Coast Hwy
MUN 30 60 N/A 49 49
11 Vacant
Coast Hwy north
of Former
Lumberyard*
MUN 30 60 N/A 69 69
15 Crespi Storage
610 Crespi*
MUC 50 Same N/A 55 55
16 Park Mall
1015 Terra Nova
Blvd*
MUN 30 50 N/A54 52 61
18 Caltrans Park n
Ride
Linda Mar Blvd
MUN 30 60 N/A 54 54
19 7th Day
Adventist, 533
Hickey Blvd
MDR 15 30 N/A 15 15
20 Public Works
Corp Yard, 155
Milagra Dr*
Retail0 40 Yes 39 39
21 Oceana HS,
401 Paloma Ave
Public0 30 Yes 14 12 152 178
22 Terra Nova HS,
1450 Terra Nova
Blvd
Public0 30 Yes 109 110 129
24 Sanchez Library,
1111 Terra Nova
Blvd
Public0 40 Yes 65 65
25 Caltrans ROW,
Skyline Blvd
N/A N/A 40 Yes 162 162

1.c
Packet Pg. 793 Attachment: Attachment C - Revised Housing Site Inventory Tables (5494 : Housing Element Joint Study 27 Pacific Manor
Shopping Center,
440 Manor Pl*
Retail/
MUN
0-30 60 Yes 9 8 98 115
28 Fairmont
Shopping Center,
777 Hickey Blvd*
Retail 0 50 Yes 3 3 35 41
29 Linda Mar
Shopping Ctr, 500
Linda Mar Blvd*
Retail 0 50 Yes 14 13 155 182
30 Builders
Exchange,
520 San Pedro
Ave
Retail 0 30 Yes 23 23
31 Ace Hardware,
560 San Pedro
Ave*
Retail 0 30 Yes 30 30
32 Brentwood
Shopping Center,
Oceana/Manor*
Retail 0 60 Yes 97 97
33 US Bank,
1655 Oceana
Blvd
MUC 30 50 N/A 14 14
37 St Peter's Church
700 Oddstad
Open
Space/Ag/Res
30 Same N/A 24 24
38 Vacant
Coast Hwy north
of Our Savior
Church*
MUN 30 60 N/A 61 61
G Skyline Blvd Utilities 0 40 Yes 55 55
TOTAL CORE RHNA SITES 687 248 691 1,626
Note: Sites indicated with an asterisk (*) include the more than one parcel. Each APN listed is included in Appendix F. Source: City of Pacifica

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Packet Pg. 794 Attachment: Attachment C - Revised Housing Site Inventory Tables (5494 : Housing Element Joint Study TABLE: SURPLUS/“BUFFER” SITES
Site
#
Location Existing
Land Use
Existing
Allowed
Density
(DU/A)
Proposed
Density
(DU/A)
Revise
to Allow
Residential
Use
Lower
Income
Capacity
Moderate
Income
Capacity
Above
ModerateIncome
Capacity
Total
Capacity
12 Coast Hwy,
Between 4300-
4400 Coast Hwy
MUN 30 60 N/A 169 169
23 Sanchez Art
Center, 1220
Linda Mar Blvd
Public 0 40 Yes 130 130
34 Vallemar Station,
2125 Coast Hwy
Retail 0 60 Yes 97 97
35 Vacant,
Coast Hwy/Sea
Bowl Ln
Visitor
Commercial
0 20 Yes 32 32
A Latter Day Saints
730 Sharp Park
Rd
Public and
Semi Public
0 30 Yes 23 23
B Ramallah Plaza
2480 Skyline
Retail 0 30 Yes 11 11
D Vacant
340 Waterford
Retail 0 40 Yes 7 7
E Car Wash
340 Waterford
Retail 0 40 Yes 9 9
F Vacant w/ Acces
Bldg.

Oddstad Blvd
MUN 30 40 N/A 16 16
H Pavilion of
Flowers,
801 Oceana Blvd.

Office 0 40 Yes 42 42
TOTAL SURPLUS RHNA SITES 396 108 32 536
Note: Sites indicated with an asterisk (*) include the more than one parcel. Each APN listed is included in Appendix F. Source: City of Pacifica

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Packet Pg. 795 Attachment: Attachment C - Revised Housing Site Inventory Tables (5494 : Housing Element Joint Study This figure shows the parcels on which housing is intended to be developed on all or a portion of the parcel.

Where the entire parcel is not intended to be developed with housing, the specific areas of the parcel intended for housing development are depicted in Appendix F, Figures F-2 through F-11 “Areas assumed for housing (in blue shading).” The areas of the parcels that are not shown as “Areas assumed for housing (in blue shading)” are not included in the Housing Element site inventory.

Core RHNA Rezoning Sites
Sites With Existing Capacity
(included in Core RHNA)
Housing Element Buffer Sites
Sites with Lower Income Capacity
Hwy 1
Skyline Blvd
Sh arp Park Rd
Manor Dr
Fassler Ave
Crespi Dr
Terra Nova Blvd
Linda Mar Blvd
2 3
6 11 10
12 15
24 18
19 20
21 22
23 16
25 27
28 29 30
31 32
33 34
35 36
38 F
H
A
D
E
37 C
G
B
26 1.d
Skyline Blvd
28 25
19 27
32 20
2 21
33 3
6 Manor Dr
A
H
G
B
This figure shows the parcels on which housing is intended to be developed on all or a portion of the parcel. Where the entire parcel is not intended to be developed with housing, the specific areas of the parcel intended for housing development are depicted in Appendix F, Figures F-2 through F-11 “Areas assumed for housing (in blue shading).” The areas of the parcels that are not shown as “Areas assumed for housing (in blue shading)” are not included in the Housing Element site inventory.

E
D
C
Core RHNA Rezoning Sites
Sites With Existing Capacity
(included in Core RHNA)
Housing Element Buffer Sites
Sites with Lower Income Capacity

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Packet Pg. 797 Attachment: Attachment D - Revised Housing Site Inventory Maps (5494 : Housing Element Joint Study Session (Continued)) 34 22
35 36
12 10
11 15
18 38
29 26
Hwy 1
Fassler Ave
This figure shows the parcels on which housing is intended to be developed on all or a portion of the parcel. Where the entire parcel is not intended to be developed with housing, the specific areas of the parcel intended for housing development are depicted in Appendix F, Figures F-2 through F-11 “Areas assumed for housing (in blue shading).” The areas of the parcels that are not shown as “Areas assumed for housing (in blue shading)” are not included in the Housing Element site inventory.

Core RHNA Rezoning Sites
Sites With Existing Capacity
(included in Core RHNA)
Housing Element Buffer Sites
Sites with Lower Income Capacity

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Packet Pg. 798 Attachment: Attachment D - Revised Housing Site Inventory Maps (5494 : Housing Element Joint Study Session (Continued)) 30 23
Fassler Ave
Hwy 1
This figure shows the parcels on which housing is intended to be developed on all or a portion of the parcel. Where the entire parcel is not intended to be developed with housing, the specific areas of the parcel intended for housing development are depicted in Appendix F, Figures F-2 through F-11 “Areas assumed for housing (in blue shading).” The areas of the parcels that are not shown as “Areas assumed for housing (in blue shading)” are not included in the Housing Element site inventory.

Core RHNA Rezoning Sites
Sites With Existing Capacity
(included in Core RHNA)
Housing Element Buffer Sites
Sites with Lower Income Capacity
36 29
15 18
31 1.d
Packet Pg. 799 Attachment: Attachment D - Revised Housing Site Inventory Maps (5494 : Housing Element Joint Study Session (Continued)) Fassler Ave
24 16
37 23
22 F
This figure shows the parcels on which housing is intended to be developed on all or a portion of the parcel.

Where the entire parcel is not intended to be developed with housing, the specific areas of the parcel intended for housing development are depicted in Appendix F, Figures F-2 through F-11 “Areas assumed for housing (in blue shading).” The areas of the parcels that are not shown as “Areas assumed for housing (in blue shading)” are not included in the Housing Element site inventory.

Core RHNA Rezoning Sites
Sites With Existing Capacity
(included in Core RHNA)
Housing Element Buffer Sites
Sites with Lower Income Capacity

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Packet Pg. 800 Attachment: Attachment D - Revised Housing Site Inventory Maps (5494 : Housing Element Joint Study Session (Continued)) !(
³±
³±
³±
³±
³±
³±

LINDA MAR

ODDSTAD

FASSLER
GRAND

REINA DEL MAR

FAIRWAY

PALMETTO
PALOMA

SHARP PARK

ESPLANADE
AVALON
MANOR

MONTEREY
HICKEY

PERALTA

ROCKAWAY BEACH
§¨¦280
UV35
UV82
UV35
·|}þ1
·|}þ1
·|}þ1

DE SOLO

BARCELONA
NELSON

BROOKHAVEN

CRESTMOOR

BEACHVIEW

FREMONT

CATALINA
CRESPI
CCWRP
Skyridge PS
Rockaway PS
Linda Mar PS
Sharp Park PS
David Davis/Brighton PS
Linda Mar EQ Basin

DALY CITY

SAN BRUNO

UNINCORPORATED

SOUTH SAN FRANCISCO

UNINCORPORATED
COLMA
Pacific Ocean
!(
Modeled Sewers
Force Main
Unmodeled Sewers
Equalization Basin
Facilities
³±
Pump Station
³±
Water Recycling Plant
³±
Pump Station
(unmodeled)
Pacifica City Limits
Other City Boundaries ±
0 0.125 0.25 0.5
Miles
Legend
Rockaway Beach Pump
Station Catchment Area
Map

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Packet Pg. 801 Attachment: Attachment E - Rockaway Beach Pump Station Catchment Area Map (5494 : Housing Element Joint Study Session (Continued)) 1 From: Peter Loeb < >
Sent: Monday, September 25, 2023 11:06 AM
To: Public Comment
Subject: Comments re: Housing Element joint study session Attachments: PH4A Housing Element policies.pdf; HCD revisions.pdf [CAUTION: External Email]
Attached 2 pdf’s and same text pasted in below summarize 1) Pacifica Housing 4 All (PH4A) recommended policies for preserving, protecting, and producing housing for tenants and low income and affordable housing, and 2) summary of HCD’s required revisions to address special needs populations, persons with disabilities, emergency shelter and supportive and transitional housing, housing for all income levels, farmworkers, and preserving coastal housing for lower-income households.

Pacifica Housing 4 All
Recommended Policies for Housing Element Consideration
Policies for tenant protection and preservation of affordable housing • Rental registry. Example: Concord, cost $5-15 per unit. Advantages: data source, track complaints, track displacement indicators referenced in Sharp Park Specific Plan, AirB&B tax compliance.
• Anti-harassment ordinance, City of Richmond, January 2022. • Red Tag Ordinance, City of San Mateo, requires property owners to provide relocation payments to tenants displaced because of code violations. • Short term rental regulations linked to vacancy rate, below 5% vacancy. • Substantial renovation ordinance: pulled permits required before tenant eviction, tenant first right of return, tenant 3 month relocation benefits. • Just cause eviction protection from 1st day of rental. • Developer buyout allowing tenants first opportunity of purchase.

Policies to incentivize low-income housing
• Increase inclusionary rate to 20% to produce more low-income housing. In-lieu fees should be based on market values ($750K/unit) • Create dedicated housing fund supported by:

1. Vacancy fee: all residential properties, NOT just rental properties – see Sand Francisco, Oakland, Vancouver BC 2017 – 1% non-primary residence unoccupied for more than 6 months annually including short term rentals.

2. In lieu fees, developer impact fees (to benefit low income housing), sale of city land. • Pathway for preservation of existing affordable housing – HIP housing and HEART: to leverage funds from dedicated housing fund. Redwood City has an established system to be ready in the event an opportunity for affordable housing presents.

Dept. of Housing and Community Development (HCD)
comments on Pacifica’s Housing Element
HCD sent a cover letter and 12-page appendix listing required revisions to the Housing Element. HCD was critical of Pacifica’s plans for special needs populations and the need for transitional and supportive housing, and that zoning doesn’t address emergency shelter, and programs to achieve moderate to extremely low income housing. These comments are summarized below. There were many other required revisions in other areas.

Special needs populations. “The element must be revised to include an analysis of the existing needs and resources for each special need group including seniors, farmworkers, large households, and persons with disabilities including developmental disabilities and extremely low-income (ELI) households.”

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Packet Pg. 802 Attachment: Attachment F - Public Comments (5494 : Housing Element Joint Study Session (Continued)) 2 Emergency Shelters. “Zoning to permit emergency shelters without discretionary action was required as part of the 4th cycle housing element and prior to the 5th cycle housing element.” “HCD cannot find the element in compliance until the appropriate zoning to permit emergency shelters without discretionary action is demonstrated or completed.” 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.” Housing for all income levels. “An analysis of … governmental constraints … upon development of housing for all income levels … and for persons with disabilities.” “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.” Programs for extremely low, very low, low, and moderate-income housing. “The Housing Element shall contain programs which assist in the development of adequate housing to meet the needs of extremely low-, very low-, low- and moderate- income households.” Farmworker housing. “Given the importance of farmworkers and the local and regional needs, the element must include specific actions to addressing this population. Examples of actions could include proactive outreach with developers and the community, identifying potential sites, provide incentives (e.g., expedited permitting, flexible development standards, gap funding, fee waivers), and applying for state and federal funding.” Preserve coastal housing units for lower- and moderate-income households. “The element should include a program committing to actions that preserve coastal housing units for lower- and moderate-income households.

CAUTION: This email originated from outside of the City of Pacifica. Unless you recognize the sender's email address and know the content is safe, do not click links, open attachments or reply.

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Packet Pg. 803 Attachment: Attachment F - Public Comments (5494 : Housing Element Joint Study Session (Continued)) Pacifica Housing 4 All
Recommended Policies for Housing Element Consideration
Policies for tenant protection and preservation of affordable housing • Rental registry. Example: Concord, cost $5-15 per unit. Advantages: data source, track complaints, track displacement indicators referenced in Sharp Park Specific Plan, AirB&B tax compliance.
• Anti-harassment ordinance, City of Richmond, January 2022. • Red Tag Ordinance, City of San Mateo, requires property owners to provide relocation payments to tenants displaced because of code violations. • Short term rental regulations linked to vacancy rate, below 5% vacancy. • Substantial renovation ordinance: pulled permits required before tenant eviction, tenant first right of return, tenant 3 month relocation benefits.
• Just cause eviction protection from 1st day of rental. • Developer buyout allowing tenants first opportunity of purchase.

Policies to incentivize low-income housing
• Increase inclusionary rate to 20% to produce more low-income housing. In-lieu fees should be based on market values ($750K/unit)
• Create dedicated housing fund supported by:

1. Vacancy fee: all residential properties, NOT just rental properties – see Sand Francisco, Oakland, Vancouver BC 2017 – 1% non-primary residence unoccupied for more than 6 months annually including short term rentals.

2. In lieu fees, developer impact fees (to benefit low income housing), sale of city land. • Pathway for preservation of existing affordable housing – HIP housing and HEART: to leverage funds from dedicated housing fund. Redwood City has an established system to be ready in the event an opportunity for affordable housing presents.

1.f
Packet Pg. 804 Attachment: Attachment F - Public Comments (5494 : Housing Element Joint Study Session (Continued)) Dept. of Housing and Community Development (HCD)
comments on Pacifica’s Housing Element
HCD sent a cover letter and 12-page appendix listing required revisions to the Housing Element.

HCD was critical of Pacifica’s plans for special needs populations and the need for transitional and supportive housing, and that zoning doesn’t address emergency shelter, and programs to achieve moderate to extremely low income housing. These comments are summarized below.

There were many other required revisions in other areas.

Special needs populations. “The element must be revised to include an analysis of the existing needs and resources for each special need group including seniors, farmworkers, large households, and persons with disabilities including developmental disabilities and extremely low-income (ELI) households.”
Emergency Shelters. “Zoning to permit emergency shelters without discretionary action was required as part of the 4th cycle housing element and prior to the 5th cycle housing element.” “HCD cannot find the element in compliance until the appropriate zoning to permit emergency shelters without discretionary action is demonstrated or completed.” 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.” Housing for all income levels. “An analysis of … governmental constraints … upon development of housing for all income levels … and for persons with disabilities.” “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.”
Programs for extremely low, very low, low, and moderate-income housing. “The Housing Element shall contain programs which assist in the development of adequate housing to meet the needs of extremely low-, very low-, low- and moderate- income households.” Farmworker housing. “Given the importance of farmworkers and the local and regional needs, the element must include specific actions to addressing this population. Examples of actions could include proactive outreach with developers and the community, identifying potential sites, provide incentives (e.g., expedited permitting, flexible development standards, gap funding, fee waivers), and applying for state and federal funding.”
Preserve coastal housing units for lower- and moderate-income households. “The element should include a program committing to actions that preserve coastal housing units for lowerand moderate-income households.

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Packet Pg. 805 Attachment: Attachment F - Public Comments (5494 : Housing Element Joint Study Session (Continued)) 1 From: Sue Digre < >
Sent: Monday, September 25, 2023 11:48 AM
To: Public Comment
Subject: Fwd: HOUSING ELEMENT. for Developmental Disabilities 9 25 2023 [CAUTION: External Email]
Regarding :

Disposition of City owned land; award of financing; density bonus concessions,land use exceptions or waivers for any affordable project:

City: require that the housing developer implement an affirmative marketing plan that provides disabilityserving organizations adequate prior notice of availability; and a process for supporting people with qualifying disabilities to apply.

Note persons who have a developmental disability are included and do have some additional core agencies of assistance that must be approptiately notified.

The City too should have responsibility to do thourough,timely outreach to the Golden Gate Regional Center and the Vendorized Agencies that provide appropriate wrap around services. Including Brilliant Corners Housing & Housing Choices.
... regarding persons who have a developmental disability:

In addition to implementing the Calif density bonus statute ,the City shall provide an additional LOCAL density bonus , incentives and/or concessions for housing projects that include at least 5% of the units for people at the Extremely lowincome Affordability level.

Or.

Commit to make a percentage of the units subject to a preference for people with special needs, persons who have a developmental disability. (Persons who have a developmental disability will benefit from COORDINATED ON SITE SERVICES , such as services from the State GoldenGate Regional Center, which vendorizes assisting services).

A strong collaboration with these core agencies should be involved for appropriate & effective partnership. ..The same type of language should be in the competitive proposals for City owned land dedicated to affordable housing under the Inclusionary Ordinances .

Offer Developers a menu of options for achieving truly affordability.

Adjust the percentage of units required to be affordable for persons who have a developmental disability who will benefit from coordinated on-site services provided by the local State Regional Center & its Vendorized Agencies for supportive services.

These collaboration, partnership like relationships can enable the City to reach some significant priority housing gaps. ..Grant additional points to proposals that address the housing needs those who are most difficult to house .( those who haveva developmental disability)

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Packet Pg. 806 Attachment: Attachment F - Public Comments (5494 : Housing Element Joint Study Session (Continued)) 2 ...City include plans to Further Fair Housing particularly those with disabilities ,including developmental disabilities, that include policies designed to increase the production extremely low income units . ( Vendorized GGRC Agencies provide assistance services). ...Include adequate staff capacity to implement and monitor the impact of these policies.

A strong collaboration with the local Golden Gate Regional Center and their Vendorized Service Agencies is imperative.

The State Department on Developmental Disabilities can be a supportive Govt.Agency .They oversee the Regional Centers.
..A goal of 30 new extremely low-income housing units for Pacifica residents with a developmental disability over the HE period would represent meaningful progress .
(Persons who have a developmental disability are eager to be positive , contributing members of their Community.) .....consider similar " set asides", preference, incentives, points for extremely low-income Accessory Dwelling Units ., esp for persons who a developmental disability & wrap around services . ..CIty establish on on-going funding source for financing Extremely-low income units for persons who have a developmental disability.
...Transportation. Most persons who have a developmental disability can not drive. Public transportation can be essential.

The City collaboration with GGRC the State Regional Center and the County &,Regional Transportation Agencies can worked together to improve Public Transportation for everyone. Ridership important for sustainability. These core agencies planning together can have a better probability of creating a sustainable shared transportation endeavor for everyone. The Regional Center does have a Transportation Vendor. All public transportation services need such collaborative type partnership to make significant changes in our City & area cities.

City should have a staff member dedicated to following through on these new comprehensive "partnership". It will take diligence & leadership. The goods are available.

Kalisha of Housing Choices submitted an excellent report. Please refer to it CAUTION: This email originated from outside of the City of Pacifica. Unless you recognize the sender's email address and know the content is safe, do not click links, open attachments or reply.

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Packet Pg. 807 Attachment: Attachment F - Public Comments (5494 : Housing Element Joint Study Session (Continued)) From: Harkousha, Brianne
To: Harkousha, Brianne
Subject: FW: HOUSING ELEMENT for Developmental Disabilities Date: Tuesday, October 3, 2023 10:23:04 AM
From: Sue Digre
Sent: Monday, September 25, 2023 11:52 AM
To: Housing <[email protected]>
Subject: Fwd: HOUSING ELEMENT for Developmental Disabilities [CAUTION: External Email]
---------- Forwarded message ---------
From: Sue Digre
Date: Mon, Sep 25, 2023, 11:46 AM
Subject: HOUSING ELEMENT for Developmental Disabilities To: Sue Digre
Regarding :

Disposition of City owned land; award of financing; density bonus concessions,land use exceptions or waivers for any affordable project:

City: require that the housing developer implement an affirmative marketing plan that provides disability-serving organizations adequate prior notice of availability; and a process for supporting people with qualifying disabilities to apply.

Note persons who have a developmental disability are included and do have some additional core agencies of assistance that must be approptiately notified.

The City too should have responsibility to do thourough,timely outreach to the Golden Gate Regional Center and the Vendorized Agencies that provide appropriate wrap around services. ... regarding persons who have a developmental disability:

In addition to implementing the Calif density bonus statute ,the City shall provide an additional LOCAL density bonus , incentives and/or concessions for housing projects that include at least 5% of the units for people at the Extremely low-income Affordability level.

Or.

Commit to make a percentage of the units subject to a preference for people with special needs, persons who have a developmental disability. (Persons who have a developmental disability will benefit from COORDINATED ON SITE SERVICES , such as services from the State GoldenGate Regional Center, which vendorizes assisting services).

1.f
Packet Pg. 808 Attachment: Attachment F - Public Comments (5494 : Housing Element Joint Study Session (Continued)) A strong collaboration with these core agencies should be involved for appropriate & effective partnership.
..The same type of language should be in the competitive proposals for City owned land dedicated to affordable housing under the Inclusionary Ordinances .

Offer Developers a menu of options for achieving truly affordability.

Adjust the percentage of units required to be affordable for persons who have a developmental disability who will benefit from coordinated on-site services provided by the local State Regional Center & its Vendorized Agencies for supportive services.

These collaboration, partnership like relationships can enable the City to reach some significant priority housing gaps.
..Grant additional points to proposals that address the housing needs those who are most difficult to house .( those who haveva developmental disability)
...City include plans to Further Fair Housing particularly those with disabilities ,including developmental disabilities, that include policies designed to increase the production extremely low income units .
( Vendorized GGRC Agencies provide assistance services). ...Include adequate staff capacity to implement and monitor the impact of these policies.

A strong collaboration with the local Golden Gate Regional Center and their Vendorized Service Agencies is imperative.

The State Department on Developmental Disabilities can be a supportive Govt.Agency .They oversee the Regional Centers.
..A goal of 30 new extremely low-income housing units for Pacifica residents with a developmental disability over the HE period would represent meaningful progress . (Persons who have a developmental disability are eager to be positive , contributing members of their Community.)
.....consider similar " set asides", preference, incentives, points for extremely low-income Accessory Dwelling Units ., esp for persons who a developmental disability & wrap around services . ..CIty establish on on-going funding source for financing Extremely-low income units for persons who have a developmental disability.
...Transportation. Most persons who have a developmental disability can not drive. Public transportation can be essential.

The City collaboration with GGRC the State Regional Center and the County &,Regional Transportation Agencies can worked together to improve Public Transportation for everyone.

Ridership important for sustainability. These core agencies planning together can have a better probability of creating a sustainable shared transportation endeavor for everyone. The Regional Center does have a Transportation Vendor. All public transportation services need such collaborative type partnership to make significant changes in our City & area cities.

1.f
Packet Pg. 809 Attachment: Attachment F - Public Comments (5494 : Housing Element Joint Study Session (Continued)) City should have a staff member dedicated to following through on these new comprehensive "partnership". It will take diligence & leadership. The goods are available.

Kalisha of Housing Choices submitted an excellent report. Please refer to it CAUTION: This email originated from outside of the City of Pacifica. Unless you recognize the sender's email address and know the content is safe, do not click links, open attachments or reply.

1.f
Packet Pg. 810 Attachment: Attachment F - Public Comments (5494 : Housing Element Joint Study Session (Continued))

1.f
Packet Pg. 811 Attachment: Attachment F - Public Comments (5494 : Housing Element Joint Study Session (Continued)) 1 From: Pat Kremer < >
Sent: Monday, September 25, 2023 11:57 AM
To: Public Comment; _City Council
Cc: Pat Kremer
Subject: Comments for Study Session Sept. 25
Attachments: PatriciaKremerComments.pdf
[CAUTION: External Email]
I have attached a memo fort distribution to the members of the Pacifica City Council, Planning Commission and staff of the Planning Department.

Regards,
Patricia Kremer
CAUTION: This email originated from outside of the City of Pacifica. Unless you recognize the sender's email address and know the content is safe, do not click links, open attachments or reply.

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Packet Pg. 812 Attachment: Attachment F - Public Comments (5494 : Housing Element Joint Study Session (Continued)) To: City of Pacifica City Council, Planning Commission, Planning Department
From: Patricia Kremer (5 Eastlake Avenue, Sharp Park)
Date: September 25, 2023
Subject: Housing Element Study Session
Since the first version of the Draft Housing Element, I have been particularly interested in the Tables that have included lists of potential RHNA Sites with information about zoning status and proposed income distribution of the proposed housing units (Lower –> Above-Moderate). My comments and questions pertain to the RHNA Tables included in the packet for tonight’s Joint Study Session.

What is the status of each of these sites, both “CORE” and “BUFFER”, with respect to how realistic the specific site is to be developed with residential housing during the next several years? How close is the property to being “shovel ready”? It is surprising to me that the Draft Housing Element from May 2023 included very detailed information about each of the sites in Appendix F, while stating: “The analysis does not include the economic feasibility of specific sites, nor does it take into consideration the owner’s intended use of the land now or in the future. It does not dictate where residential development will actually occur, and the decision whether to develop any particular site always remains with the owner of the property, not the City.”
During the Scoping Meeting on Aug. 1, 2023, I was surprised to learn that not all the owners of the “Opportunity Sites” listed in the revised Housing Element Draft from May 2023 had been consulted about being included as part of the City’s RHNA list.

This seems to me to be irresponsible on the part of the City that specific information about numbers of units in a range of

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Packet Pg. 813 Attachment: Attachment F - Public Comments (5494 : Housing Element Joint Study Session (Continued)) income levels is included in the Tables of CORE and BUFFER RHNA Sites without input from the owners of the properties.

In looking at the Tables included for tonight’s meeting, many of the numbers were changed from earlier Tables in Appendix F in the May 2023 Draft. That is not surprising, and most of the changes were relatively minor. The change for the Sea Bowl (Site #36) was dramatic however. The May HE Draft included 219 units of “Lower Income Capacity” while the current Table shows 186 “Above Moderate-Income Capacity” with only 17 units as “Lower-Income”. I hope someone at tonight’s meeting inquires about the justification for the original data and for the change.

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Packet Pg. 814 Attachment: Attachment F - Public Comments (5494 : Housing Element Joint Study Session (Continued))

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Packet Pg. 815 Attachment: Attachment F - Public Comments (5494 : Housing Element Joint Study Session (Continued)) 2 Special needs populations. “The element must be revised to include an analysis of the existing needs and resources for each special need group including seniors, farmworkers, large households, and persons with disabilities including developmental disabilities and extremely low-income (ELI) households.”
Emergency Shelters. “Zoning to permit emergency shelters without discretionary action was required as part of the 4th cycle housing element and prior to the 5th cycle housing element.” “HCD cannot find the element in compliance until the appropriate zoning to permit emergency shelters without discretionary action is demonstrated or completed.” 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.” Housing for all income levels. “An analysis of … governmental constraints … upon development of housing for all income levels … and for persons with disabilities.” “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.” Programs for extremely low, very low, low, and moderate-income housing. “The Housing Element shall contain programs which assist in the development of adequate housing to meet the needs of extremely low-, very low-, low- and moderate- income households.” Farmworker housing. “Given the importance of farmworkers and the local and regional needs, the element must include specific actions to addressing this population. Examples of actions could include proactive outreach with developers and the community, identifying potential sites, provide incentives (e.g., expedited permitting, flexible development standards, gap funding, fee waivers), and applying for state and federal funding.”
Preserve coastal housing units for lower- and moderate-income households. “The element should include a program committing to actions that preserve coastal housing units for lower- and moderate-income households. --
Suzanne Moore
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Packet Pg. 816 Attachment: Attachment F - Public Comments (5494 : Housing Element Joint Study Session (Continued)) From: Harkousha, Brianne
To: Harkousha, Brianne
Subject: FW: Pacifica CA input 2nd draft Housing Element Date: Tuesday, October 3, 2023 10:22:50 AM
From: Suzanne Moore
Sent: Sunday, September 24, 2023 12:49 PM
To: Housing <[email protected]>; [email protected]; _Planning Commission Group <[email protected]>; _City Council <[email protected]> Subject: Pacifica CA input 2nd draft Housing Element
[CAUTION: External Email]
Suzanne Moore from the Manor, and member of Pacifica Housing 4 All.

It’s been several years since the Association of Bay Area Governments promoted the 3 Ps to address our regional housing crisis: production of housing at all levels of affordability, preservation of existing low-income, affordable housing, and protection from displacement.

Those recommendations are visibly present in California’s Fair Housing Law, and the HCD looks for evidence of this as they evaluate Housing Elements.

Pacifica’s Housing Element needs assessment was clear: Pacifica 1) has not built low-income housing in decades,
2) Pacifica’s homeless numbers are 3rd in the county: Pacifica is 5% of the County’s population but has 15% of the homeless - of which nearly 75% have strong ties to Pacifica and many of whom were previously housed here.
3) Pacifica’s tenants face difficult challenges:
- rents increased and wages stagnated: median contract rent increased 62% since 2009 - rental market in Pacifica is constrained partially due to vacation rentals - Some populations are disproportionately impacted by housing costs: female headed households, seniors, disabled, farmworkers, low-wage earners, homeless, Hispanics The HCD response letter made several important suggestions:
1)Pacifica’s Housing Element must provide a cumulative evaluation of the effectiveness of past 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). 2) Emergency Shelters: Zoning to permit emergency shelters without discretionary action was required as part of the 4th cycle housing element and prior to the 5th cycle housing element. The element states that the City’s zoning regulations do not address emergency shelters (p. G-16) and the City will include a program committing to comply with Government Code section 65583, subdivision
3) 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

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Packet Pg. 817 Attachment: Attachment F - Public Comments (5494 : Housing Element Joint Study Session (Continued)) zone.
4) The element includes general commitments to addressing various special needs populations. However, given the importance of farmworkers and the local and regional needs, the element must include specific actions to address this population.

Here is input from the Housing Leadership Council:

All of the elaborate research that makes up Housing Elements are supposed to lead to policy outcomes that respond to what the city learns. The analyses alone cannot make a housing element comply with state law, only appropriate policy change can.

Taking all these recommendations together, I feel it is necessary for our Housing Element to promote what we have failed to achieve and what our community lacks:
protection, preservation and production with the priority goal of assisting those most vulnerable.

Protection: Anti-displacement measures successfully demonstrated in other communities:
just cause for eviction, anti-harassment language,
Preservation. Utilize existing housing to create:
- interim housing and programs as transitions from homelessness, - supportive housing for those in need of additional help to maintain independence, - short-term rental regulations.

Production:
- create a clear pathway to incentivize below-market rate housing priorities. - streamline what is most desperately needed,
- create a specialized team: HCD recommends examples of actions like proactive outreach with developers and the community, identify potential sites, provide incentives (e.g., expedite permitting, flexible development standards, gap funding, fee waivers), and apply for state and federal funding.

Housing is necessary for the life and health of the individual, families, and the community as a whole. Our Housing Element must address past failures and prioritize what Pacifica needs most: stable housing especially at below-market rate levels of affordability. --
Suzanne Moore
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Packet Pg. 818 Attachment: Attachment F - Public Comments (5494 : Housing Element Joint Study Session (Continued)) 1 From: Samuel Casillas
Sent: Monday, September 25, 2023 7:40 PM
To: Public Comment
Subject: Item 1.) 9/25/23 Joint study session of City Council and Planning Commission for 2023-2031 Housing Element
Attachments: Housing Element comments for joint meeting 9 25 2023.docx [CAUTION: External Email]
Hello,
Please enter my public comment for the joint session to discuss the Housing Element.

Thank you,
Sam Casillas
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Packet Pg. 819 Attachment: Attachment F - Public Comments (5494 : Housing Element Joint Study Session (Continued)) Housing Element comments for Pacifica
The current housing element is not acceptable due to the fact that there is actually no approved general plan as the LCLUP has not been approved by the California Coastal Commission, the proposed EIR format will be inadequate as it is not properly outlining how hazards, traffic mitigation and water issues will not be properly addressed and therefore violate CEQA. We also need to consider economic sustainability for the city itself.

On the economic sustainability question the SeaBowl site #36 is particularly problematic. In order to accommodate 200+ housing units here it is being discussed that the SeaBowl venue would have to be demolished and thus eliminating Pacifica’s only family friendly tax revenue generating venue. Does it make sense to eliminate tax revenue generating businesses? Remember that this site would need to be rezoned in order to allow housing so the city can dictate to a developer that housing needs to be built around the SeaBowl so that we can preserve some of our sales tax revenue base.

We need to honestly discuss what the impact of taking this venue out of our tax base to put up more nonrevenue generating housing that will only cost us more economic hardship as any well executed Cost of Service Study (COS) will point out.

This committee should be studying and recommending how to keep venues that generate tax revenue for the city and not eliminating them. The SeaBowl site is a prime example of whether we have thoughtful city leadership that is serious about building a sustainable economy or just acquiescing to real estate lobbying interests.

I realize that economic sustainability is not a legal challenge to this housing element but the fact that we will need a well vetting EIR that considers traffic mitigation, wastewater treatment plant expansion, hazard areas including fire, landslides ESHA flooding and drinking water availability are issues that will take this plan down.

Thank you,
Sam Casillas

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Packet Pg. 820 Attachment: Attachment F - Public Comments (5494 : Housing Element Joint Study Session (Continued)) 1 From: Mickey Mouse
Sent: Monday, September 25, 2023 9:49 PM
To: Public Comment
Subject: Fwd: For September 25th 2023 meeting.
[CAUTION: External Email]
To:

Begin
To: [email protected]
Subject: For September 25th 2023 meeting.

For todays meeting:

SPECIAL MEETING for

JOINT STUDY SESSION CITY COUNCIL AND PLANNING COMMISSION It would be reckless to assume building housing at the Oceana High School. Many if not all residence in the Oceana High School area see this area as neighborhood courtyard. People from other surrounding neighborhoods come as well to use the field Site#21 as recreation on a daily basis. Please look elsewhere for land to develop.

One such piece of property that I can recommend is just south of WestPort Dr. and North of Mori RidgeTrail off Hwy 1 (North Bound)on the east side (of HWY 1), this property is just as big as the Oceana High School. Why not try and obtain that property? Furthermore, we are unfairly represented (us people near Oceana High School) because we are a few. Do any city council people or planners live in the valley where Oceana High is located? I doubt it. If they did, they wouldn’t want this neighborhood to be destroyed by senseless overdevelopment of this neighborhood.

Pacifican Resident
Rocky Rome
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Packet Pg. 821 Attachment: Attachment F - Public Comments (5494 : Housing Element Joint Study Session (Continued))

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