The San Mateo County Health Officer may determine and declare that rabies or other contagious diseases are epidemic or that other health and safety hazards exist among dogs or other animals within the County. Upon the making of such a declaration, the Health Officer shall prepare and promulgate such orders, rules, and regulations as are necessary for appropriate control of all the animals concerned within the County. Said rules and regulations of the Health Officer may include, but are not limited to, impoundment, quarantine, vaccination, or destruction. It shall be the duty of the Animal Control Officers to assist the Health Officer in carrying out such rules and regulations.
6-1.220 - Bite Reporting Requirements.
(a) Any Owner or other Person who is responsible for the care, custody, or control of an animal that bites a human or other animal shall provide their name and current residence address and telephone number and shall present their driver's license or other form of identification and any information regarding any rabies vaccination for the biting animal to the person bitten or the Owner of the animal bitten. If the Person bitten is a minor, the Owner or Person in control of the biting animal shall provide the required information to the parent or guardian of the minor. (b) In addition to the above requirements, it shall be the duty of any Person having knowledge of any animal which has bitten a human being or other animal within the County to immediately, in no case later than the end of the next calendar day, report the bite to an Animal Control Officer or peace officer and to furnish as much information as possible, including date, time and location of bite, description of animal or Person bitten, 4 Packet Pg. 287
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name and license number of the biting animal, and rabies vaccination history of the biting animal.
6-1.221 - Administrative Citations.
(a) Should an Animal Control Officer, Humane Officer or peace officer determine that a Person has violated any provision this Article, that enforcement officer shall have authority to issue and serve notice of an administrative citation as set forth in section 6-1.226, to the Person violating the Article.
(b) Each administrative citation shall contain the following information:
(1) The name and address of the Owner or other Person to be cited. (2) The date(s) of the violation.
(3) The address or a specific description of the location where the violation occurred.
(4) The section, subsection, and/or provision of this Article violated by the Person cited and a description of that violation.
(5) A prohibition of the continuation or repetition of the violation described in the administrative citation.
(6) If applicable a description of the potential consequence(s) should the violation continue or be repeated.
(7) Either:
i) The amount of the administrative fine charged and to be paid by the Person cited as a result of the violation; or
ii) A notice to correct a certain violation within a reasonable time, and the amount of an administrative fine that may occur if the violation is not corrected or remedied by the date specified.
(8) A description of the procedure to pay the fine, to include the time period for and place of payment, and the process by which the County may collect any unpaid amount owed.
(9) A description of the administrative citation review process, including the time within which the administrative citation may be appealed and how to appeal the administrative citation, including any form to 4 Packet Pg. 288
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do so.
(10) The name and signature of the citing Animal Control Officer, Humane Officer or peace officer or County designee.
(c) An administrative citation may be any format, including letter, which conveys the information set forth above.
6-1.222 - Appeal of Administrative Citation.
(a) A recipient of an administrative citation may contest the citation including, but not limited to, on the basis that the underlying violation did not occur, or that recipient is not the party responsible for the violation and thus was the improper recipient of the administrative citation. The recipient must contest the citation on the form provided by the Animal Program Manager or Animal Control Officer and file the appeal with the Animal Control Program Manager within twelve (12) calendar days from the date of service of the administrative citation. Any appeal not timely filed will be rejected.
(b) The appeal shall contain the following provided by the Person appealing the citation:
(1) The name, mailing address, and telephone number of the party requesting the appeal;
(2) A copy of the administrative citation or a reference number thereto; (3) A statement of the grounds for the contest, including a description of the evidence to be presented in support of the contest and copies of any statements or documents to be submitted at the hearing in support of the appeal.
(4) The signature of the appealing party;
(5) A deposit of the fine assessed as set forth in the citation(s), to be refunded if the appeal is successful.
(c) Should an appeal be properly and timely requested, the requesting party shall be provided a hearing before a hearing officer to be held pursuant to the procedures set forth in section 6-1.215 as applicable. The Animal Control Program shall notify the Person requesting the appeal hearing of the time and place set for the hearing pursuant to section 6-1.226. 6-1.223 - Payment of Administrative Fines.
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(a) In the absence of an appeal by the recipient of the administrative citation, the Person cited shall pay the administrative fine in full within thirty (30) calendar days from the date of service of the notice of citation. In the event of an appeal, after which the violation is upheld, if not already paid, the fine shall be paid in full within ten (10) calendar days after the date that the decision of the hearing officer was served on the recipient. (b) Payment of any fine shall not excuse the failure to correct the violation, nor shall it bar further enforcement of the same or any similar violation or any other violation by any applicable means.
(c) Failure to pay any fines assessed within the guidelines set forth in this Article will result in a late charge pursuant to section 6-1.224, which will be collected by the Animal Control Program Manager.
6-1.224 - Amount of Administrative Fines.
(a) Any Person issued an administrative citation for a violation of, and pursuant to, this Article shall be assessed and pay a fine as follows:
(1) One hundred dollars ($100) for a first citation.
(2) Two hundred dollars ($200) for a second citation for the same violation within a one-year period.
(3) Five hundred ($500) for each additional citation for the same violation within a one-year period.
6-1.225 - Misdemeanor Violations.
(a) A Person violating any provision of this Article shall be guilty of an infraction except as otherwise specifically provided.
(b) A Person violating any provision of section 6-1.205, subsection (a) of section 6-1.209 or subsection (a) of section 6-1.213 of this Article shall be guilty of a misdemeanor.
(c) This section shall not limit any other available criminal, civil or administrative remedies. Any or all applicable remedies shall remain available for violation of the provisions of this Article. 6-1.226 - Violation of Article a Public Nuisance; Remedies Cumulative. (a) Violation of this Article is a public nuisance subject to any and all applicable civil, administrative, and criminal remedies, according to the provisions and procedures set forth in this Article and other applicable 4 Packet Pg. 290
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state and local law.
(b) This section is not intended to limit any other available criminal, civil or administrative remedies. Any or all applicable administrative, civil and /or criminal remedies shall be available for violation of the provisions of this Article.
(c) Each day a violation continues shall constitute a separate violation. 6-1.226- SERVICE OF DOCUMENTS AND NOTICES.
(a) Unless otherwise specified herein, the appropriate representative of the Animal Control Program shall provide any required notice or service of documents in the one of the following manners: (1) by personal delivery to the Person to be notified or served; or (2) by posting on the property at the address where the subject animal is licensed or the Owner of such animal resides; or (3) by depositing in the United States Mail, in a sealed envelope, first class postage prepaid, and addressed to such Person to be notified or served at their last-known business or residence address or as the same appears in the last equalized County assessment roll. Service by mail shall be deemed complete at the time of deposit in the United States Mail receptacle and shall include a declaration or affidavit of service which shall include notice of the date mailed. If agreed in writing by the Person to be served, notices or documents may be served electronically at the address provided by the Person to be served, to be effective upon being sent.
(b) Failure to receive any notice specified herein does not affect the validity of proceedings conducted hereunder.
6-1.227 - Field Return Fee.
A fee shall be charged for any animal impounded by a representative of the Animal Control Program and returned by an Animal Control Officer in the field to the Owner or Person who is responsible for the care, custody, or control of the animal. The fee charged shall be paid by the Owner or Person who is responsible for the care, custody, or control of said animal. Such fee shall be set forth in Section 6-1.230. 6-1.228 - Redemption and Spay/Neuter Fee.
(a) Upon redemption of any impounded unaltered animal, the Person responsible for the care, custody or control of any animal will be required to pay a spay or neuter fee in the amount of $100.00 in addition to the impound fees imposed under Section 6-1.230 of this Article. Such fee shall be refundable upon proof of spay and neuter of the animal within thirty (30) calendar days following the date of redemption.
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(b) Any unaltered animal impounded twice or more within a three-year period shall be altered at a cost to be paid by the Owner/Caretaker or person responsible for the care, custody, or control of said animal prior to redemption. At the option of the Owner/Caretaker or Person responsible for the care, custody, or control of said animal, required spaying or neutering may be performed by a private veterinarian within thirty (30) calendar days.
(c) Any Owner or Caretaker of an impounded animal subject to mandatory spay/neuter under Subsection (b) of this Section may appeal this requirement by submitting a written request for an administrative hearing to the Animal Control Program Manager. The administrative hearing will be conducted according to the provisions of Section 6-1.215 of this Article. (d) The Animal Control Program Manager may waive any County or City fee for County or City spay/neuter, vaccination or impoundment of an animal, if the animal is a feral or stray cat and the Person bringing the animal to the shelter agrees that the Person shall have no rights in the animal or any right to direct or control treatment or disposition of the animal by the Animal Control Program which will retain sole discretion in determining the disposition of the animal, which may include but not be limited to treatment and/or adoption, or euthanasia.
6-1.229 - Quarantine Fee.
A quarantine fee, as set forth in Section 6-1.230, shall be paid by the Owner or Caretaker of any animal involved, or potentially involved, in a bite. Such quarantine fee is in addition to any other fees charged set forth in Section 6-1.230 of this Article to recover costs incurred by the Animal Control Program for the sheltering and caring for the quarantined animal.
6-1.230 - Schedule of Fees and Charges.
This Section 6-1.230 sets forth the fees for the Animal Control Program and Licensing Program. No animal shall be released to its Owner, or other person responsible for the care, custody, or control of the animal, unless applicable fees have been paid.
Animal Control and Licensing fees and charges established by this code are as follows:
(a)
(a) License Fees.
Dogs
Unaltered dog
1-year license $55.00
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3-year license $160.00
Unaltered dog Senior Pet Owner (over 60 yrs.)
1-year license
3-year license
$23.00
$64.00
Altered dog
1-year license $25.00
3-year license $70.00
Altered dog Senior Pet Owner (over 60 yrs.)
1-year license $10.00
3-year license $25.00
Misc. dog fees
Late fee $20.00
Duplicate tag $10.00
Cats
Unaltered cat
1-year license $20.00
3-year license $55.00
Unaltered cat Senior Pet Owner (over 60 yrs.)
1-year license
3-year license
$12.00
$31.00
Altered cat
1-year license $8.00
3-year license $19.00
Altered cat/ Senior Pet Owner (over 60 yrs.)
1-year license $5.00
3-year license $12.00
Misc. cat fees
Late fee $7.00
Duplicate tag $5.00
(b) Redemption Charges
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Type A & B (large or medium size animals — horses, cows, hogs, sheep, etc.)
Impound cost $100.00
Board cost per day $30.00
Trailering cost (per use) $100.00
Type C (dogs, and cats)
Impound Costs — First Impound
Altered — licensed, wearing tag $40.00
Unaltered — licensed, wearing tag $65.00
Altered — unlicensed, no tag $55.00
Unaltered — unlicensed, no tag $85.00
Impound Costs — Second Impound
Altered — licensed, wearing tag $90.00
Unaltered — licensed, wearing tag $125.00
Altered — unlicensed, no tag $105.00
Unaltered — unlicensed, no tag $140.00
Impound Costs — Third Impound
Altered — licensed, wearing tag $135.00
Unaltered — licensed, wearing tag $155.00
Altered — unlicensed, no tag $155.00
Unaltered — unlicensed, no tag $180.00
Impound Costs — Fourth Impound
Altered — licensed, wearing tag $180.00
Unaltered — licensed, wearing tag $215.00
Altered — unlicensed, no tag $200.00
Unaltered — unlicensed, no tag $240.00
Impound Costs — Fifth Impound and up
Altered — licensed, wearing tag $225.00
Unaltered — licensed, wearing tag $260.00
Altered — unlicensed, no tag $245.00
Unaltered — unlicensed, no tag $285.00
Board charges (per day)
Altered — dogs/ $25.00
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Unaltered — dogs/ $35.00
Altered — cats $16.00
Unaltered — cats $22.00
Type D (small size animals, e.g., birds, hamsters, or other) Impound cost $20.00
Board cost $10.00
(c) Surrender, Euthanasia and DOA (Dead on Arrival) Disposal Fees Dog — Licensed or unlicensed
Surrender $60.00
Euthanasia $50.00
DOA Disposal $30.00
Cat — Licensed or unlicensed
Surrender $60.00
Euthanasia $50.00
DOA Disposal $30.00
Rabbit/Small Animal
Surrender $40.00
Euthanasia $30.00
DOA Disposal $15.00
Litter of Three or more
Surrender $50.00
Euthanasia $40.00
DOA Disposal $20.00
Bird/Fowl
Surrender $20.00
Euthanasia $15.00
DOA Disposal $20.00
All Other Companion Animals (Reptiles, Amphibians, etc.) Surrender $25.00
Euthanasia $25.00
DOA Disposal $20.00
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Farm Animals
Surrender $60.00
Euthanasia: Under 100 pounds
Over 100 pounds
$60.00
$125.00
DOA Disposal: Under 100 Pounds
Over 100 pounds
$30.00
$100.00
(d) Other Animal Control Fees
Quarantine Fee $60.00
Dangerous Animal Permit (DAP) Fee $300.00
DAP Inspection Fee $100.00
DAP Signage $15.00
Field Retrieval/Return Fee $40.00
Breeding Permit Fee $150.00
Fancier Permit and/or Exotic Pet Fee $100.00
Return Check Fee $25.00
Service Dog Application Processing Fee $50.00
(b) Miscellaneous Fee Provisions
(1) The Animal Control Program, and/or Licensing Program, may establish license discounts for recognized animal rescue organizations. (2) License fees include a one dollar ($1) annual surcharge on all licenses for the animal population trust fund.
(3) At the discretion of the Animal Control Program Manager, a payment plan for all fees outstanding may be permitted upon a showing of good cause.
If a Person is in compliance with an agreed upon payment plan, their outstanding balance shall never be considered “nonpayment” as that term is used in this Article.
(4) The animal control fees for any animal related service not specified in this section shall be reviewed by the Chief of Health or their designee for reimbursement of costs. The Chief of Health or their designee shall have the authority to determine the fee charged for said services. The fee charged shall be paid by the Owner or Caretaker of the animal(s) for which said service(s) have been 4 Packet Pg. 296
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provided.
(5) Each calendar year, the Animal Control Program Manager shall designate one month as an amnesty period for payment of cat and dog license late fees and for compliance with section 6-1.202 of this Article, as provided herein. During the amnesty period, applicants for cat and dog licenses shall not be assessed any late penalty fee or any other penalty for failure to obtain such license or pay any applicable license fee, notwithstanding sections 6-1.204 and 6-
1.230 of this Article.
(6) All revenue derived from the fees, fines, forfeitures, and penalties related to the enforcement of this ordinance shall be used to offset the cost of enforcement and administration of this Article. (7) If the Animal Control Program Manager determines that payment of any fees by the Owner or Caretaker for an impounded animal would cause extreme financial difficulty to the Owner or Caretaker, and that it is in the best interests of the County to allow release of the animal upon these terms, the Animal Control Program Manager may, at their discretion, set up a payment plan or waive all or part of the fees incurred for the animal.
6-1.231 – Scope.
The provisions of this Article shall apply within the geographic boundaries of the City.
6-1.232 – Severability.
If any section, subsection, sentence, clause, phrase, or word of this Article should be held to be invalid or unconstitutional by a court of competent jurisdiction, such invalidity or unconstitutionality thereof shall not affect the validity or constitutionality of any other section, subsection, clause, phrase, or word of this Article.” SECTION 2. Compliance with CEQA. The City Council hereby finds that the action to adopt this Ordinance is not subject to review under the California Environmental Quality Act (CEQA) pursuant to Public Resources Code Section 21000, et seq. and the CEQA Guidelines (14 Cal. Code Regs. §§ 15000 et. seq.), including without limitation, Public Resources Code section 21065 and California Code of Regulations 15378 as this is not a “project” that may cause a direct, or reasonably foreseeable indirect, physical change in the environment and if a “project,” is exempt under the “common sense” exception (14 Cal. Code Regs. § 15061(b)(3)) because it can be seen with certainty that there is no possibility that this action may have a significant effect on the environment.
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SECTION 3. Publication. The City Clerk is hereby ordered and directed to certify the passage of this Ordinance by the City Council of the City of Pacifica, California, and cause the same to be published in accordance with State law.
SECTION 4. Effective Date. This Ordinance shall be in full force and effective thirty (30) days after its adoption and shall be published and posted as required by law.
This ordinance shall become effective thirty days after adoption. • • • • •
PASSED AND ADOPTED at a special and regular meeting of the City Council of the City of Pacifica, California, held on the 22nd day of January, 2024, by the following vote:
AYES, Councilmembers:
NOES, Councilmembers:
ABSENT, Councilmembers:
ABSTAIN, Councilmembers:
_________________________________
Sue Vaterlaus, Mayor
ATTEST: APPROVED AS TO FORM:
______________________________ _________________________________ Sarah Coffey, City Clerk Michelle Kenyon, City Attorney 4 Packet Pg. 298
Pacifica City Council 40 January 22, 2024
* * * * *
(ID # 5560) at 1/22/2024 5:30 PM City Council Regular Meeting 4 Packet Pg. 299
Estimated Fee Increase Analysis by City
22-23 Year Control rev
less control & licensing
exp less licensing rev
CY 2022 licensing
revenue
TOTAL OF AC&L
Rev less exp
$5,632,725 $1,254,246 $6,886,970
CITY Service Level Service Level Field Animals Service Level Final Final CY 2022 Licensing Revenue Adjusted Percentage Percentage Services Received Percentage 2022-2023 2022-23 Percent Percent Distribution 2022-2023 City Cost
CY 2019 Actual
Yr 2 CY 2020
Actual CY2021 CY2021
Yr 3 CY 2021
Actual
Before subtracting license
revenue % of total revenue
Licensing Revenue
Collected
Estimated 22-23
City Cost w/ Fee
Increase
22-23 Estimated
City Cost w/out
Fee Increase
Estimated
Cost Increase
(Decrease) per
City with Fee
Increase
Atherton 1.07% 1.02% 1.09% 0.93% 1.00% 1.03% $70,808 1.18% $ 14,809 $55,999 $58,721 ($2,722) Belmont 2.65% 2.92% 3.28% 2.36% 2.74% 2.77% $190,597 4.49% $ 56,303 $134,294 $144,502 ($10,207) Brisbane 0.88% 0.48% 0.57% 0.51% 0.54% 0.63% $43,470 0.70% $ 8,829 $34,641 $36,258 ($1,617) Burlingame 3.41% 4.36% 4.06% 3.62% 3.80% 3.86% $265,833 4.85% $ 60,791 $205,042 $216,179 ($11,137) Colma 0.40% 0.54% 0.59% 0.38% 0.46% 0.47% $32,396 0.21% $ 2,634 $29,762 $30,284 ($522) Daly City 9.92% 10.04% 8.13% 10.59% 9.58% 9.85% $678,260 7.55% $ 94,687 $583,573 $601,405 ($17,832) East Palo Alto 8.04% 7.94% 5.96% 9.54% 8.07% 8.02% $552,159 1.04% $ 13,090 $539,069 $542,384 ($3,315) Foster City 2.49% 3.07% 4.23% 2.89% 3.44% 3.00% $206,791 3.97% $ 49,790 $157,001 $166,098 ($9,096) Half Moon Bay 1.94% 2.29% 1.60% 1.62% 1.61% 1.95% $134,104 2.82% $ 35,347 $98,757 $105,194 ($6,437) Hillsborough 1.83% 1.82% 1.68% 1.47% 1.55% 1.74% $119,529 2.65% $ 33,241 $86,288 $92,326 ($6,038) Menlo Park 5.10% 4.81% 4.69% 4.18% 4.39% 4.77% $328,220 3.67% $ 46,041 $282,179 $290,844 ($8,665) Millbrae 2.29% 2.09% 2.48% 2.06% 2.23% 2.20% $151,856 2.65% $ 33,215 $118,641 $124,739 ($6,098) Pacifica 6.06% 4.80% 6.08% 4.81% 5.33% 5.40% $371,752 7.38% $ 92,593 $279,159 $296,045 ($16,886) Portola Valley 0.41% 0.58% 0.61% 0.42% 0.50% 0.50% $34,121 1.34% $ 16,780 $17,341 $20,345 ($3,004) Redwood City 13.92% 12.33% 12.90% 15.92% 14.68% 13.64% $939,701 12.55% $ 157,456 $782,245 $811,535 ($29,290) San Bruno 5.80% 5.26% 3.79% 5.25% 4.65% 5.23% $360,397 5.73% $ 71,818 $288,579 $301,823 ($13,244) San Carlos 2.90% 2.89% 4.25% 2.49% 3.21% 3.00% $206,582 5.43% $ 68,099 $138,483 $150,783 ($12,299) San Mateo 13.71% 13.55% 13.93% 15.94% 15.11% 14.12% $972,619 15.16% $ 190,096 $782,523 $817,600 ($35,077) S. San Francisco 9.75% 10.02% 8.35% 10.18% 9.43% 9.73% $670,307 7.69% $ 96,443 $573,864 $591,988 ($18,124) Woodside 1.02% 1.31% 1.68% 1.37% 1.50% 1.27% $87,759 1.28% $ 16,102 $71,657 $74,629 ($2,972) County 6.41% 7.87% 10.06% 3.48% 6.18% 6.82% $469,708 7.66% $ 96,082 $373,626 $391,308 ($17,682) Total 100.00% 100.00% 100.00% 100.00% 100.00% 100.00% $6,886,969 100.00% $1,254,246 $5,632,723 $5,864,987 ($232,264) Estimated Fee Increase Analysis by City
as of 11/22/2023
4.a
Packet Pg. 300 Attachment: Attachment A: Estimated Fee Increase Analysis by City (5560 : Ordinance Adoption- Animal City
% of Total
Revenue
Collected Revenue Collected w/ Fee Increase Total
Atherton 1.18% $ 12,219.00 $ 2,590.27 $ 14,809.27
Belmont 4.49% $ 46,452.50 $ 9,850.07 $ 56,302.57
Brisbane 0.70% $ 7,293.00 $ 1,535.65 $ 8,828.65
Burlingame 4.85% $50,151.25 $ 10,639.83 $ 60,791.08
Colma 0.21% $ 2,173.25 $ 460.69 $ 2,633.94
Daly City 7.55% $ 78,124.25 $ 16,563.04 $ 94,687.29
East Palo Alto 1.04% $ 10,808.00 $ 2,281.53 $ 13,089.53 Foster City 3.97% $ 41,080.21 $ 8,709.31 $ 49,789.52
Half Moon Bay 2.82% $ 29,161.00 $ 6,186.46 $ 35,347.46
Hillsborough 2.65% $ 27,427.00 $ 5,813.52 $ 33,240.52
Menlo Park 3.67% $ 37,990.25 $ 8,051.17 $ 46,041.42
Millbrae 2.65% $ 27,401.50 $ 5,813.52 $ 33,215.02
Pacifica 7.38% $ 76,402.75 $ 16,190.10 $ 92,592.85
Portola Valley 1.34% $ 13,840.50 $ 2,939.67 $ 16,780.17 Redwood City 12.55% $ 129,924.25 $ 27,531.94 $ 157,456.19 San Bruno 5.73% $ 59,248.00 $ 12,570.36 $ 71,818.36
San Carlos 5.43% $ 56,186.50 $ 11,912.23 $ 68,098.73
San Mateo 15.16% $ 156,838.11 $ 33,257.70 $ 190,095.81
South San Francisco 7.69% $ 79,572.84 $ 16,870.17 $ 96,443.01 Woodside 1.28% $ 13,294.00 $ 2,808.04 $ 16,102.04
County 7.66% $ 79,277.75 $ 16,804.35 $ 96,082.10
100.00% $ 1,034,866 $ 219,380 $ 1,254,246
Animal Licensing CY 2022
4.a
Packet Pg. 301 Attachment: Attachment A: Estimated Fee Increase Analysis by City (5560 : Ordinance Adoption- Animal Control)
CITY OF PACIFICA
COUNCIL AGENDA SUMMARY REPORT
1/22/2024
1 SUBJECT:
General Plan Amendment GPA-106-24 for Adoption of the 2023-2031 Housing Element of the General Plan (File No. 2023-025). Recommended California Environmental Quality Act (CEQA) Action: Adoption of an Initial Study/Negative Declaration.
RECOMMENDED ACTION:
Move to adopt the attached Resolution to:
A. Adopt an Initial Study/Negative Declaration;
B. Approve the 2023-2031 Housing Element of the General Plan; and C. Incorporate all maps and testimony into the record by reference.
STAFF CONTACT:
Christian Murdock, AICP, Planning Director
(650) 738-7341
[email protected]
Brianne Harkousha, AICP, Senior Planner
(650) 738-7341
[email protected]
BACKGROUND/DISCUSSION:
• Background
State law1requires every city and county to adopt a housing element as one of the mandated elements of the general plan. The housing element of the general plan must be substantially compliant with state housing element law2 and updated periodically to maintain consistency with the Regional Housing Needs Allocation (RHNA) process. The RHNA and housing element update processes occur every eight years. Currently, local agencies are adopting housing element updates to address the 6th Cycle RHNA, which in the Association of Bay Area Governments (ABAG) region covers the period from 2023-2031.
Work on the Housing Element Update (HEU) commenced in August 2022, immediately following City Council’s adoption of the comprehensive 2040 General Plan Update in July 2022.
Staff’s efforts over that period have resulted in preparation of a Draft Housing Element that includes all components necessary to comply with state law, as described in detail in Exhibit A to Attachment A. Following City Council adoption, staff will transmit the Adopted Housing Element to the California Department of Housing and Community Development (HCD) for review and certification.
1 Government Code § 65302(c).
2 Government Code § 65580 et seq.
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• Community Engagement and Input
Public input has been an essential part of the process to prepare the Draft Housing Element.
The City has provided numerous public input opportunities that have included online and inperson engagements. The community engagement strategy was developed with public and City Council input, including a FlashVote poll asking the community how it would prefer to be engaged during the HEU process, and also including a citywide mailer to all residential and business recipients in Pacifica announcing the HEU process and how to be involved. The City Council approved the community engagement 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 HEU to address RHNA 6 and guide its work to prepare the Draft Housing Element. These community meetings informed the public about the requirements for the HEU and the City’s obligation to plan for the RHNA. Public feedback received at these meetings confirmed the overall sites strategies and priorities to accommodate Pacifica’s RHNA, which was essential to the preparation of an initial 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 objective development standards (ODS) on June 19, August 21, and September 5, 2023.
The City held two additional City Council-Planning Commission joint study sessions on September 25 and October 16, 2023, to discuss specific revisions to the Draft Housing Element in response to comments from HCD. Following revisions to the Draft Housing Element and release of an updated draft on December 8, 2023, an additional written public comment period on the Draft Housing Element was provided between publication of the latest Draft Housing Element and this public hearing.
A full discussion of the extensive community engagement process undertaken during development of the Draft Housing Element is included in Appendix A: Community Consultation of the Draft Housing Element (Attachment B).
• Review by California Department of Housing and Community Development (HCD) Staff transmitted a Draft Housing Element to the California Department of Housing and Community Development (HCD) for a 90-day review period on May 10, 20233. City staff met with HCD staff assigned to review Pacifica’s Draft Housing Element on July 7 and July 27, with the first meeting including a site visit to Pacifica. The meetings provided City staff an opportunity to explain the approaches to sites and programs contained in Pacifica’s Draft Housing Element, and to describe the challenges and constraints that informed the approaches.
The site visit included a tour of key sites and allowed staff to demonstrate how the physical environment in Pacifica relates to the Draft Housing Element. City staff was able to answer numerous HCD staff questions and also heard HCD’s perspectives on key themes that must be addressed in a housing element in order to be certified by HCD.
HCD issued a comment letter to the City on August 8, 2023 (Attachment C). The letter included more than 30 unique comments that required further analysis by staff and revisions to the Draft Housing Element. The HCD comment letter attached to the staff report includes red numbering assigned by staff to aid reference to individual comments. Overall, staff assessed 3 The cover letter and first draft transmitted to HCD are available on the Project Documents page of PlanPacifica.org.
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that HCD’s comments were generally as expected, and Pacifica did relatively well as compared to HCD comments made to other San Mateo County jurisdictions on their first submittals. Staff has revised the Draft Housing Element to address all HCD comments as further detailed in Exhibit B to Attachment A.
• Prior Consideration of Draft Housing Element
The City Council has been extensively involved throughout development of the Draft Housing Element. As summarized above, the City Council has already participated in three meetings to consider various aspects of the Draft Housing Element. Input from the City Council has been critical to the process and ensured that public input has been thoroughly considered and incorporated where possible. In addition, the Planning Commission held a further three-meeting series on matters related to the HEU to further inform the process and provide public input opportunities. The following list summarizes the City Council and Planning Commission’s prior involvement:
• March 21, 2023 | Joint study session of City Council and Planning Commission o Agenda report | Meeting video | Minutes
• June 19, 2023 | Planning Commission Discussion of ODS o Agenda report | Meeting video | Minutes
• August 21, 2023 | Planning Commission Discussion of ODS o Agenda report | Meeting video | Minutes
• September 5, 2023 | Planning Commission Discussion of ODS o Agenda report | Meeting video | Minutes not yet available • September 25, 2023 | Joint study session of City Council and Planning Commission o Agenda report | Meeting video | Minutes
• October 16, 2023 | Joint study session of City Council and Planning Commission o Agenda report | Meeting video | Minutes
The ODS discussed by the Planning Commission included height, setbacks, lot coverage, floor area ratio (FAR), open space per dwelling unit, and off-street parking standards that will apply to the various sites in the Housing Sites Inventory. These six ODS will provide the basic framework to guide development of the sites in the Housing Sites Inventory and will be brought forward for adoption concurrently with the “Phase 1” rezoning action later in 2024, as described in Program HE-I-1, which is necessary to accommodate the City’s RHNA. Additional ODS will be considered as part of the Phase 2 rezoning action described in Program HE-I-2.
Key Policy Items Discussed by City Council and Planning Commission at Joint Study Sessions on September 25 and October 16, 2023
At the two City Council-Planning Commission joint study sessions on September 25 and October 16, 2023, more than a dozen specific comments in HCD’s letter from August 8, 2023, were discussed. The discussion and guidance provided allowed staff to incorporate changes into the Draft Housing Element related to the following, which comprised the most significant policy items requiring revisions in response to HCD’s comment letter:
• Reorganization of Housing Sites Inventory (HCD Comment B.3.1) • Assembly Bill (AB) 2011 Sites (HCD Comment B.3.2.B)
• Infrastructure Constraints (Rockaway Beach Pump Station) (HCD Comment B.3.9)
• Farmworker Housing (HCD Comments B.2 & C.2)
• Affirmatively Furthering Fair Housing (AFFH): Mobility Support and Transit Advocacy (HCD Comment B.2)
• 100% Nonresidential Sites (HCD Comment B.3.2.C)
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• Site Consolidation Program (HCD Comment B.3.3)
• Surplus Lands Act for City/School District/Caltrans Sites (HCD Comments B.3.5 & B.3.6)
• Emergency Shelter Zoning (HCD Comment B.3.10.A)
• Zoning for Transitional and Supportive Housing (HCD Comment B.3.10.B) • Accessory Dwelling Unit (ADU) Zoning (HCD Comment B.3.10.C) • Single-Room Occupancy (SRO) Zoning (HCD Comment B.3.10.D) • Off-street Parking Minimum Requirements (HCD Comment B.4.1) • Permits & Findings for Housing Approvals (HCD Comment B.4.3.A) • Planned Development (P-D) Zoning (HCD Comment B.4.3.B) • Group Homes for 7+ Persons (HCD Comment B.4.6.B)
• Affirmatively Furthering Fair Housing (AFFH): Affirmative Marketing Strategy in Racial Concentrated Areas of Affluence (RCAA) (HCD Comment C.4) • Housing Rehabilitation (HCD Comment D.1)
Staff also made other revisions to the Draft Housing Element based on its assessment of applicable legal requirements and professional judgment. These revisions are, in staff’s judgment, relatively minor compared to the significant policy items for which the Planning Commission and City Council already provided direction and/or confirmed staff’s recommended policy approaches.
A full depiction of revisions made to the prior Draft Housing Element from May 2023 in response to HCD’s comments4is provided in the redline version of the latest Draft Housing Element on the Project Documents page of PlanPacifica.org.
• Key Housing Element Components
The Draft Housing Element consists of a main chapter and seven appendices covering specific subject matter as follows:
• Appendix A: Community Consultation
• Appendix B: Prior Housing Element Review
• Appendix C: Housing Needs
• Appendix D: Assessment of Fair Housing
• Appendix E: Housing Resources
• Appendix F: Housing Sites
• Appendix G: Housing Constraints
Due to the length and complexity of the Draft Housing Element, this staff report focuses on summarizing two key components of the document: the Housing Sites Inventory and the proposed Policies and Programs.
A. Housing Sites Inventory
The Draft Housing Element describes the City’s RHNA and identifies specific sites that can accommodate development of housing consistent with the RHNA. This information is summarized primarily in the main chapter and in Appendix F: Housing Sites.
The City of Pacifica’s 6th Cycle RHNA allocation is 1,892 housing units. These housing units 4 As a parallel work effort not specifically reflected in the Draft Housing Element, the City Council also adopted Ordinance No. 894-C.S. on December 11, 2023, to update the City’s Emergency Shelter Ordinance in response to HCD’s comment letter.
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are further segmented by income5to ensure that sufficient housing can be approved and constructed for all income levels, as demonstrated in Table 1, below:
Table 1: Pacifica’s 6th Cycle RHNA
Very Low
Income6
<50% of
AMI
Low Income
50-80% of
AMI
Moderate
Income
80-120% of AMI
Above
Moderate
Income
>120% AMI TOTAL
Units 538 310 291 753 1,892
Pacifica’s 6th Cycle RHNA is an increase of 1,479 units, or 358 percent, compared to its 5th Cycle RHNA allocation of 413 units. The increased RHNA required extensive evaluation of potential housing sites during preparation of the Draft Housing Element. Appendix F of the Draft Housing Element includes a detailed discussion of the City’s plan to satisfy its RHNA, including identification of specific sites and their suitability for housing affordable at various income levels.
The Housing Site Inventory identifies five sites with suitable existing General Plan land use designations and 21 sites that will require General Plan amendments and/or rezoning to make them suitable for RHNA purposes. Table 2 includes a summary of the methods used to satisfy the RHNA:
Table 2: Methods Used to Satisfy 6th Cycle RHNA
Method Units
Existing General Plan Capacity 122
Amended General Plan Capacity (i.e., “Rezoning”) 2,042
Accessory Dwelling Units (ADUs) 187
Approved Housing Units 223
TOTAL 2,574
The combined effect of the four methods used to satisfy Pacifica’s 6th Cycle RHNA is a buffer of 36 percent above the 1,892-unit requirement, for a total demonstrated capacity for the approval and construction of 2,574 housing units. HCD’s Housing Element Site Inventory Guidebook7 suggests that housing elements include a buffer of “at least 15 to 30 percent more capacity than required, especially for capacity to accommodate the lower income RHNA,” and goes on to indicate that jurisdictions can also create a buffer by “projecting site capacity at less than the maximum density.”
The site inventory in the Draft Housing Element places an emphasis on the lower income RHNA by providing a 50 percent buffer for that income category. The buffers for each income level are demonstrated in Table 3, below. Additional buffer is provided across all income levels by assuming only 81 percent of the maximum density on each site based on an average of densities for projects actually approved in Pacifica in recent years. 5 The income levels in the RHNA refer to Area Median Income, or AMI, for the county in which a local jurisdiction is located. The 2023 AMI thresholds for San Mateo County are published by the San Mateo County Department of Housing and vary by family size. The Department of Housing’s published data also indicate the maximum rents considered to be affordable for each income level.
6 The RHNA only provides a Very Low Income (VLI) assignment for the lowest income level. However, other provisions of state law require the City to address Extremely Low Income (ELI) housing needs (0-30% of AMI). The Draft Housing Element apportions half of the VLI RHNA to the ELI category as permitted by law. 7 Available at: https://www.hcd.ca.gov/community-development/housingelement/docs/sites_inventory_memo_final06102020.pdf. 5 Packet Pg. 306
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Table 3: Buffers by RHNA Income Level
Lower
Income
Capacity
Moderate
Income
Capacity
Above Moderate
Income
Capacity TOTAL
RHNA Requirement 848 291 753 1,892
Draft Housing
Element
1,271 437 866 2,574
Buffer 50% 38% 15% 36%
Beyond simply meeting the numerical requirement to accommodate the RHNA, the site inventory also balances the distribution of new housing throughout the city as shown in Figure 1, below. Please note that Figure 1 differentiates between sites that count toward the City’s RHNA requirement, referred to as “Core RHNA,” and sites that are intended as “buffer” sites that exceed the RHNA requirement. Please also note that, as explained in a note at the bottom of Figure 1, in some cases, housing development will only occur on a portion of the housing site and, in those cases, a separate figure included in the Housing Element specifies the exact location on the site on which housing is intended to be developed. 5 Packet Pg. 307
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Figure 1: Housing Site Inventory Map
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-10 “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.
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The site inventory considered factors such as access to transportation and other infrastructure, proximity to public transit and other services, high-opportunity areas near schools and parks, and prior public input including avoidance of hillsides to the maximum extent practicable and prioritizing redevelopment of single-use commercial centers into mixed-use residential/commercial. Importantly, and as further analyzed in Appendix D: Assessment of Fair Housing, the site inventory must support Affirmatively Furthering Fair Housing (AFFH). This includes actions to counter historic patterns of racial segregation in housing, avoiding concentration of lower income housing in the lowest income/lowest resource areas of the city, and identifying opportunities for affordable housing construction in the highest opportunity/highest resource areas of the city. The site inventory achieves these AFFH objectives by distributing housing sites in a balanced manner throughout Pacifica.
B. Policies and Programs
The policies and programs contained in the Draft Housing Element are an important companion to the Housing Site Inventory used to accommodate the RHNA. One important purpose of the policies and programs is to facilitate implementation of the RHNA by reducing or removing barriers to housing approval and construction. These are considered Housing Constraints and are analyzed in Appendix G. The policies and programs are also intended to address other non-production aspects of housing, such as protection and preservation of housing units to prevent their loss or conversion to non-housing uses.
In total, the Draft Housing Element contains 14 programs (with numerous implementation actions associated with the programs). Some notable programs in the Draft Housing Element include the following:
• HE-I-1: General Plan and Zoning Amendments to Achieve RHNA o Includes future General Plan amendments and rezoning needed to accommodate the RHNA, along with six core ODS to guide development until Program HE-I-2 is completed
• HE-I-2: Zoning Modernization and Streamlining
o Includes a comprehensive update to the City’s zoning regulations to implement a broad range of objective development and design standards to guide development
• HE-I-5: Fund a Housing Action Fund
o Includes establishing and funding8 a special purpose City fund to pursue affordable housing-related activities
• HE-I-8: Rehabilitation of Homes in Lower Resource and Coastal Areas o Includes assignment of Code Enforcement staff to proactively identify properties in need of significant maintenance, prior to receipt of a complaint and initiation of enforcement activity, to ascertain underlying reasons for the degraded property condition, and connection with available local, state, and federal resources that can assist with property rehabilitation for lower income or disabled property owners • HE-I-12: Fair Housing Affirmative Marketing Strategy
o Includes improving the marketing activities for affordable housing units when they become available, such as adding schools outside the RCAA 8 The City has already taken steps to implement this program by establishing the Housing Action Fund and allocating approximately half of the $3.4 million of Excess Educational Revenue Augmentation Funding (ERAF) revenues projected to be collected in FY2023-24 (approximately $1.67 million) during the annual budget process.
While the city is not guaranteed to receive Excess ERAF long-term, the allocation of these funds in the FY 2023-24 budget demonstrates the City’s commitment to support housing activities. 5 Packet Pg. 309
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to the required recipient list for application solicitations to increase the chances of families with children outside the RCAA to learn about affordable housing opportunities within the RCAA
• HE-I-14: State and Federal Law Conformance
o Includes significant modernization of the Pacifica Municipal Code to align with state law addressing various housing-related topics The timeline for implementation of each program is set forth in the main chapter of the Draft Housing Element. In total, work to implement Housing Element programs will comprise a major work program for the Planning Department and other City staff during the eight-year planning period.
• Planning Commission Review
The Planning Commission held a public hearing to consider a recommendation to the City Council on adoption of an Initial Study/Negative Declaration (IS/ND) and adoption of the 2023- 2031 Housing Element Update on January 4, 2024. Following public comment and deliberation, the Planning Commission adopted Resolution 2024-001 recommending City Council adoption of both items (Attachment D). The Planning Commission staff report and draft minutes from January 4, 2024, are included as Attachments E and F, respectively.
The Planning Commission’s deliberation on the Draft Housing Element acknowledged its extensive prior consideration of the document and the efforts by staff to incorporate public and Council/Commission input into its contents. Commissioners asked various clarifying questions on the document and California Environmental Quality Act (CEQA) review process, and directed a small number of clarifying corrections to the document. These clarifying corrections, in addition to limited additional clarifying revisions identified as necessary by staff following the Planning Commission’s review, are summarized in Attachment G. The Draft Housing Element included as Attachment B incorporates all of these revisions into a “clean” version of the document. None of the Planning Commission or staff revisions alter the substantive content of the Draft Housing Element.
• California Environmental Quality Act
The Executive Board of the Association of Bay Area Governments (ABAG), the council of governments that encompasses the City of Pacifica, issued a final regional housing allocation to the City of Pacifica on December 16, 2021. Section 15283 of the California Environmental Quality Act (CEQA) Guidelines provides that CEQA does not apply to regional housing needs determinations made by HCD, a council of governments, or a city or county pursuant to Section 65584 of the Government Code. Therefore, the determination that the City of Pacifica must accommodate its assigned RHNA was an action exempt from CEQA pursuant to state law.
As a separate action, adoption of the Draft Housing Element is subject to environmental review pursuant to CEQA. To comply with CEQA, staff has prepared an Initial Study/Negative Declaration (IS/ND), entitled “Housing Element Update – 2023-2031,” State Clearinghouse No. 2023110438 (Attachment H).
The IS/ND found that adoption of the Draft Housing Element could not have a significant effect on the environment. The primary reason for this conclusion is that the Draft Housing Element is a policy document. It does not propose or approve specific projects, change General Plan land use designations or rezone properties, or implement ordinance amendments. Rather, it sets forth a plan for how the City may best facilitate housing development in a manner consistent 5 Packet Pg. 310
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with and required by state law, which will be implemented over the eight-year Housing Element cycle.
The IS/ND was available for public review and comment from November 16 through December 18, 2023. The City received eight comment letters from private individuals but did not receive any comments from public agencies during the public comment period (Attachment I). While CEQA does not require preparation of a formal response to comments for adoption of an IS/ND, staff has nevertheless prepared the responses below to address key themes in the public comment letters submitted.
Comment Theme 1: The Housing Element will add approximately 2,000 new housing units to the City of Pacifica, which will result in potentially significant environmental impacts including potential cumulative impacts. Environmental review should not be deferred to a project-byproject basis, and an environmental impact report (EIR) should be prepared.
Response to Comment: Environmental review is not being deferred to a project-byproject basis, but is being completed for the General Plan amendments and rezoning to implement the Housing Element. The Draft Housing Element itself, if adopted, would not amend the Land Use Element of the General Plan, or rezone the Zoning Map. Rather, these actions would require further Planning Commission and City Council actions in the future. General Plan amendments to the Land Use Element of the General Plan and rezoning to the Zoning Map are actions that would be subject to environmental review pursuant to CEQA. As noted above, the City will prepare an environmental impact report (EIR) to assess potentially significant environmental impacts that would result from implementation of Housing Element Program HE-I-1 which includes the General Plan amendment and rezoning actions necessary to create new housing capacity and to accommodate the RHNA. Because adoption of the Housing Element would not amend the Land Use Element of the General Plan or rezone sites to create new housing capacity, this action would not result in any direct or indirect physical impacts to the environment.
Comment Theme 2: Development of housing on Site 21 (Oceana High School) would have potentially significant effects on the environment and should have been evaluated in the IS/ND.
Response to Comment: As described in the response to Comment Theme 1, the Draft Housing Element, if adopted, would not amend the Land Use Element of the General Plan, or rezone the Zoning Map. Therefore, adoption of the Housing Element would not result in any direct or indirect physical impacts to the environment. Furthermore, the specific setbacks, lot coverage, height, and other development standards associated with the future General Plan amendment and rezoning necessary to establish new housing capacity on Site 21 are not known at this time. As a result, potential aesthetic impacts are not reasonably foreseeable at this time and cannot be adequately analyzed.
As noted in the response to Comment Theme 1, the City will prepare an EIR to assess the impacts of Housing Element Program HE-I-1.
Comment Theme 3: State Planning and Zoning Law requires housing elements to provide an “inventory of land suitable and available for residential development” that have “realistic and demonstrated potential for redevelopment during the planning period to meet the locality’s housing need.” (Gov. Code sec. 65583(a)(3)). As a result, the Draft Housing Element should include the former Sea Bowl bowling alley site in the Housing Site Inventory based on a specific development proposal contemplated for the site.
Response to Comment: This comment does not relate to the sufficiency or adequate of the IS/ND. Rather, the comment relates to the content of the Housing Site Inventory in 5 Packet Pg. 311
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the Draft Housing Element. The comment has been made available to the City Council for consideration.
Based on the foregoing public comments, no revisions to the IS/ND prepared by staff and attached to this staff report are required at this time. • Public Comments
The City received extensive written public comments during the course of development of the Draft Housing Element. These are consolidated in Appendix A: Community Consultation of the Draft Housing Element (Attachment B).
The public remains welcome to submit written public comments at [email protected] until Housing Element adoption and certification by HCD.
• Recommendation
The City Manager recommends adoption of the attached Resolution which would make certain findings, and adopt the Negative Declaration and the 2023-2031 Housing Element of the General Plan.
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 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. The City Manager requests 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, as reflected in the proposed resolution. More substantive revisions could require readoption before the City achieves certification.
ALTERNATIVE ACTION:
Staff has identified no alternative action.
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 4: Prioritize protection and development of affordable housing. ○ Strategy A: Complete the Housing Element Update.
FISCAL IMPACT:
No direct fiscal impact.
ORIGINATED BY:
Planning Department
ATTACHMENT LIST:
Attachment A - Draft Resolution (PDF)
Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (PDF) 5 Packet Pg. 312
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Attachment C - HCD Comment Letter on First Draft Housing Element (with numbering) (PDF) Attachment D - Planning Commission Resolution No. 2024-001 (PDF) Attachment E - Planning Commission staff report (no attachments) - January 4, 2024 (PDF) Attachment F - Planning Commission Draft Minutes - January 4, 2024 (DOC) Attachment G - Changes to Housing Element After Planning Commission Recommendation (DOCX)
Attachment H - Initial Study/Negative Declaration (IS/ND) (PDF) Attachment I - Public Comments on IS/ND (PDF)
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RESOLUTION NO.
A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF PACIFICA ADOPTING
AN INITIAL STUDY/NEGATIVE DECLARATION TO COMPLY WITH THE
CALIFORNIA ENVIRONMENTAL QUALITY ACT, AND AN UPDATE TO THE HOUSING ELEMENT OF THE GENERAL PLAN FOR THE 6TH CYCLE REGIONAL HOUSING NEEDS ALLOCATION COVERING THE PERIOD 2023-2031 AS PROVIDED IN STATE LAW.
_______________________________________________________________ WHEREAS, State Housing Element Law (Government Code Sections 655580 et seq.) requires that the City Council adopt a Housing Element for the eight-year period 2023-2031 to accommodate the City of Pacifica’s (City) regional housing need allocation (RHNA) of 1,892 units, comprised of 538 very-low income units (of which 269 units are designate for extremelylow income), 310 low-income units, 291 moderate-income units, and 753 above moderateincome units; and WHEREAS, the City has prepared a Housing Element Update (HEU) for the period 2023-2031 in compliance with State Housing Element Law, with input from the public, and has identified sites that can accommodate housing units meeting the City’s RHNA; and WHEREAS, the City released the first public review draft of the Housing Element Update for the period 2023-0231 for public review on February 24, 2023 and held a Joint Study Session with the City Council/Planning Commission on March 21, 2023; and WHEREAS, the City submitted the first draft to the State of California Department of Housing and Community Development (“HCD”) on May 10, 2023 and received comments from HCD on August 8, 2023; and
WHEREAS, the City held a Joint Study Session with City Council/Planning Commission on September 25, 2023 and October 16, 2023 to review HCD’s comments on the first draft of the Housing Element; and
WHEREAS, the City released a second public review draft of the Housing Element for public review on December 8, 2023; and
WHEREAS, in order to allow for flexibility in future housing development, to create additional opportunities to address the housing crisis, and to increase opportunities for affordable housing to be constructed at the benefit of lower-income households, the Housing Element update sets a target of 36 percent over the required RHNA, or approximately 2,574 total housing units, comprised of 1,271 very-low and low-income units, 437 moderate-income units, and 866 above-moderate income units; and
WHEREAS, City of Pacifica is the Lead Agency for preparing the environmental review for the Project pursuant to the California Environmental Quality Act (CEQA); and WHEREAS, the City of Pacifica Planning Division issued a Notice of Intent to adopt a Negative Declaration on November 16, 2023, for the Housing Element Update for the period of 2023-2031, which was distributed in compliance with CEQA Guidelines Section 15072; and
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WHEREAS, on November 16, 2023, the City of Pacifica distributed copies of the Negative Declaration to public agencies which have jurisdiction by law with respect to the Housing Element Update and to publicly accessible repositories including the Sharp Park and Sanchez branches of the Pacifica Library and invited comments on the Negative Declaration in compliance with CEQA Guidelines Sections 15082; and
WHEREAS, the 30-day minimum public review and comment period for the Negative Declaration was from November 16, 2023 through December 18, 2023; and WHEREAS, written comments on the Negative Declaration were collected and considered; and
WHEREAS, the Planning Commission of the City of Pacifica held a duly noticed public hearing to consider a recommendation on the Negative Declaration and the Housing Element Update (HEU) at a special meeting on January 4, 2024, at which time it adopted Resolution No. 2024-001 recommending City Council adoption of an Initial Study/Negative Declaration (IS/ND) and adoption of the 2023-2031 Housing Element Update; and WHEREAS, the City Council of the City of Pacifica did hold a duly noticed public hearing to consider the Negative Declaration and the HEU at a regular meeting on January 22, 2024, at which time it considered all oral and documentary evidence presented, and incorporated all testimony and documents into the record by reference.
NOW, THEREFORE BE IT RESOLVED, that the City Council of the City of Pacifica does hereby find as follows:
1. The above recitals are true and correct and material to this Resolution.
2. In making its findings and adopting this resolution, the City Council relied upon and hereby incorporates by reference all correspondence, oral and written comments, staff reports, and other related materials in connection with this agenda item.
BE IT FURTHER RESOLVED, that, with respect to the Negative Declaration, the City Council of the City of Pacifica hereby:
1. Finds that (a) it has independently reviewed, analyzed, and considered the Negative Declaration and all written documentation and public comments prior to approval of the Housing Element Update, (b) the Negative Declaration has been completed in compliance with CEQA and consistent with state and local guidelines implementing CEQA, (c) the revisions to the Housing Element since the time of original circulation of the Negative Declaration do not require amendment or recirculation of the Negative Declaration pursuant to CEQA Guidelines Section 15073.5, since the revisions do not alter any of the findings or conclusions of the Negative Declaration, (d) the Negative Declaration represents the independent judgment and analysis of the City as lead agency for the Project, and (e) that on the basis of the whole record there is no substantial evidence in the record that the Housing Element will have a significant effect on the environment.
2. Adopts the Negative Declaration, which is attached to the staff report, in accordance with the California Environmental Quality Act.
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3. Declares that the custodian of the documents and other materials which constitute the record of proceedings upon which this decision is based is the Planning Department of the City of Pacifica, 540 Crespi Drive, Pacifica, CA 94044.
BE IT FURTHER RESOLVED, that the City Council of the City of Pacifica does hereby:
1. Find that the public health, safety, and general welfare are best served by adoption of the Housing Element.
2. Finds that the Housing Element substantially complies with Housing Element Law, as provided in Government Code 65580 et seq. and contains all provisions required by State Housing Element Law, as set forth in Exhibit “A” to this Resolution, which is incorporated herein by this reference and which identifies where each applicable requirement of the Government Code is addressed in the document.
3. Finds that the Housing Element substantially complies with all requirements of State Housing Element Law as interpreted by HCD. As required by Government Code Section 65585(e), the City Council has considered the findings made by HCD included in its letter dated August 8, 2023, as required by Government Code Section 65585(f). The City has revised the Housing Element to address each of the findings in the HCD letter. The revisions, and the manner in which the Housing Element addresses HCD comments, have been listed in Exhibit “B” to this Resolution, which is incorporated herein by reference.
4. Adopts the Housing Element Update for the period of 2023-2031, in substantially similar form to that included as Exhibit “C”
to this Resolution. The City Council further authorizes staff to make revisions to the Housing Element Update that are requested by HCD to achieve certification and that are consistent with Council action and direction. * * * * *
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PASSED AND ADOPTED at a regular meeting of the City Council of the City of Pacifica, California, held on the 22nd day of January 2024.
AYES, Council Members:
NOES, Council Members:
ABSENT, Council Members:
ABSTAIN, Council Members:
______________________________
Sue Vaterlaus, Mayor
ATTEST: APPROVED AS TO FORM:
______________________________ ______________________________ Sarah Coffey, City Clerk Michelle Marchetta Kenyon, City Attorney
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EXHIBIT A
FINDINGS OF SUBSTANTIAL COMPLIANCE WITH STATE HOUSING
ELEMENT LAW, AS PROVIDED IN GOVERNMENT CODE 65580 ET SEQ.
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Conformance of Housing Element with State Law Requirements, Article
10.6 [65580 – 65589.11]
Note: All page number references are to the “clean” Adoption Draft version of the Housing Element published on December 8, 2023. Provisions labelled N/A are not applicable to the City of Pacifica
GOVERNMENT CODE PROVISION HOUSING ELEMENT COMPLIANCE
Section 65583
The housing element shall consist of an identification and analysis of existing and projected housing needs and a
statement of goals, policies, quantified objectives, financial resources, and scheduled programs for the preservation, improvement, and development of housing.
Section 5 (Housing Needs)
Section 6 (Assessment of Fair
Housing)
Section 11 (Goals and Policies)
Section 14 (Quantified Objectives)
Appendix C (Housing Needs)
Appendix D (City of Pacifica
Assessment of Fair Housing)
The housing element shall identify adequate sites for
housing, including rental housing, factory-built housing, mobilehomes, and emergency shelters, and shall make
adequate provision for the existing and projected needs of all economic segments of the community.
Section 8 (Housing Sites Inventory)
Section 10 (Fair Housing Plan)
Appendix F (Housing Sites)
Appendix D (City of Pacifica Assessment
of Fair Housing)
The element shall contain all of the following: N/A
(a) An assessment of housing needs and an inventory of
resources and constraints relevant to the meeting of these needs. The assessment and inventory shall include all of the following:
Section 5 (Housing Needs)
Section 9 (Housing Constraints)
Appendix C (Housing Needs)
Appendix G (Housing Constraints)
(a)(1) An analysis of population and employment trends and documentation of projections
Appendix C (Housing Needs)
(a)(1) A quantification of the locality’s existing and projected housing needs for all income levels, including extremely low income households, as defined in subdivision (b) of Section 50105 and Section 50106 of the Health and Safety Code.
These existing and projected needs shall include the
locality’s share of the regional housing need in accordance with Section 65584. Local agencies shall calculate the subset of very low income households allotted under Section 65584 that qualify as extremely low income households. The local agency may either use available census data to calculate the percentage of very low income households that qualify as extremely low income households or presume that 50
percent of the very low income households qualify as
extremely low income households. The number of extremely low income households and very low income households
shall equal the jurisdiction’s allocation of very low income households pursuant to Section 65584.
Section 8 (Housing Sites Inventory)
Appendix F (Housing Sites Inventory)
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GOVERNMENT CODE PROVISION HOUSING ELEMENT COMPLIANCE
(a)(2) An analysis and documentation of household
characteristics, including level of payment compared to ability to pay,
Section 5 (Housing Needs)
Appendix C (Housing Needs)
(a)(2) housing characteristics, including overcrowding, and Section 5 (Housing Needs) Appendix C (Housing Needs)
(a)(2) housing stock condition. Section 5 (Housing Needs) Appendix C (Housing Needs)
(a)(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, and an analysis of the relationship of the sites identified in the land inventory to the jurisdiction’s duty to affirmatively further fair housing.
Section 8 (Housing Sites Inventory)
Appendix F (Housing Sites Inventory)
Appendix D (City of Pacifica Assessment
of Fair Housing)
[Note that AB 2339 (Chapter 654, Statutes of 2022)
amended Section 65583(a)(4). It does not apply to ABAGarea housing elements unless the first draft of the housing element is submitted to ABAG after January 31, 2023 or a draft is submitted after April 1, 2023. Therefore the sections below include the statutory provisions of Section 65583(a)(4) effective in 2022. Jurisdictions
adopting their housing element after January 31, 2023
should describe why AB 2339 is not applicable to them.] Appendix G (Housing Constraints)
(a)(4)(A) The identification of a zone or zones where
emergency shelters are allowed as a permitted use without a conditional use or other discretionary permit. The identified zone or zones shall include sufficient capacity to
accommodate the need for emergency shelter identified in paragraph (7), except that each local government shall
identify a zone or zones that can accommodate at least one year-round emergency shelter.
Appendix G (Housing Constraints);
Program HE-1-14
(a)(4)(A) If the local government cannot identify a zone or zones with sufficient capacity, the local government shall include a program to amend its zoning ordinance to meet the requirements of this paragraph within one year of the
adoption of the housing element. The local government may identify additional zones where emergency shelters are
permitted with a conditional use permit.
Appendix G (Housing Constraints);
Program HE-1-10
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(a)(4)(A) The local government shall also demonstrate that existing or proposed permit processing, development, and management standards are objective and encourage and
facilitate the development of, or conversion to, emergency shelters.
Appendix G (Housing Constraints)
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GOVERNMENT CODE PROVISION HOUSING ELEMENT COMPLIANCE
(a)(4)(A) Emergency shelters may only be subject to those development and management standards that apply to
residential or commercial development within the same zone except that a local government may apply written, objective standards that include all of the following:
(i) The maximum number of beds or persons permitted to be served nightly by the facility.
(ii) Sufficient parking to accommodate all staff working in the emergency shelter, provided that the standards do not
require more parking for emergency shelters than other
residential or commercial uses within the same zone.
(iii) The size and location of exterior and interior onsite waiting and client intake areas.
(iv) The provision of onsite management.
(v) The proximity to other emergency shelters, provided that emergency shelters are not required to be more than 300 feet apart.
(vi) The length of stay.
(vii) Lighting.
(viii) Security during hours that the emergency shelter is in operation.
Appendix G (Housing Constraints);
Program HE-1-14
(a)(4)(B) The permit processing, development, and
management standards applied under this paragraph shall not be deemed to be discretionary acts within the meaning of the California Environmental Quality Act (Division 13
(commencing with Section 21000) of the Public Resources Code).
Appendix G (Housing Constraints);
Program HE-1-14
(a)(4)(C) A local government that can demonstrate to the satisfaction of the department the existence of one or more emergency shelters either within its jurisdiction or pursuant to a multijurisdictional agreement that can accommodate that jurisdiction’s need for emergency shelter identified in paragraph (7) may comply with the zoning requirements of subparagraph (A) by identifying a zone or zones where new emergency shelters are allowed with a conditional use
permit.
N/A
(a)(4)(D) A local government with an existing ordinance or ordinances that comply with this paragraph shall not be required to take additional action to identify zones for emergency shelters. The housing element must only
describe how existing ordinances, policies, and standards are consistent with the requirements of this paragraph.
N/A
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GOVERNMENT CODE PROVISION HOUSING ELEMENT COMPLIANCE
(a)(5) 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 [Note: The types of housing identified in Section
65583(c)(1) include multifamily rental housing, factorybuilt housing, mobilehomes, housing for agricultural employees, supportive housing, single-room occupancy
units, emergency shelters, and transitional housing.]
Section 9 (Housing Constraints)
Appendix G (Housing Constraints)
(a)(5) for persons with disabilities as identified in the analysis pursuant to paragraph (7),
Appendix C (Housing Constraints)
(a)(5) including land use controls, Appendix G (Housing Constraints), Section 2 (Governmental Constraints)
(a)(5) building codes and their enforcement, Appendix G (Housing Constraints), Section 2 (Governmental Constraints)
(a)(5) site improvements, Appendix G (Housing Constraints), Section 2 (Governmental Constraints)
(a)(5) fees and other exactions required of developers, Appendix G (Housing Constraints), Section 2 (Governmental Constraints)
(a)(5) local processing and permit procedures, Appendix G (Housing Constraints), Section 2 (Governmental Constraints)
(a)(5) and any locally adopted ordinances that directly impact the cost and supply of residential development.
Appendix G (Housing Constraints),
Section 2 (Governmental Constraints)
(a)(5) The analysis shall also demonstrate local efforts to remove governmental constraints that hinder the locality from meeting its share of the regional housing need in accordance with Section 65584
Section 11 (Goals and Policies)
Section 12 (2023-2031 Programs),
programs HE-I-1, HE-1-2
(a)(5) and from meeting the need for housing for persons with disabilities, supportive housing, transitional housing, and emergency shelters identified pursuant to paragraph (7).
Section 11 (Goals and Policies)
Section 12 (2023-2031 Programs),
programs HE-1-9, HE-1-10, HE-1-11,
HE-1-12
(a)(6) An analysis of potential and actual nongovernmental constraints upon the maintenance, improvement, or
development of housing for all income levels, including the availability of financing,
Appendix G (Housing Constraints)
Section 11 (Goals and Policies),
programs HE-1-1, HE-1-2
(a)(6) the price of land, Appendix G (Housing Constraints) (a)(6) the cost of construction, Appendix G (Housing Constraints) (a)(6) the requests to develop housing at densities below those anticipated in the analysis required by subdivision (c) of Section 65583.2,
Appendix F (Housing Sites)
(a)(6) and the length of time between receiving approval for a housing development and submittal of an application for building permits for that housing development that hinder the construction of a locality’s share of the regional housing need in accordance with Section 65584.
Appendix G (Housing Constraints)
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(a)(6) The analysis shall also demonstrate local efforts to remove nongovernmental constraints that create a gap
between the locality’s planning for the development of
housing for all income levels and the construction of that housing.
Section 11 (Goals and Policies)
Section 12 (2023-2031 Programs),
programs HE-1-1, HE-1-2
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(a)(7) An analysis of any special housing needs, such as those of the
Section 5 (Housing Needs)
Appendix C (Housing Needs)
(a)(7) elderly; Appendix C (Housing Needs)
(a)(7) persons with disabilities, including a developmental disability, as defined in Section 4512 of the Welfare and Institutions Code;
Appendix C (Housing Needs)
(a)(7) large families; Appendix C (Housing Needs)
(a)(7) farmworkers; Appendix C (Housing Needs)
(a)(7) families with female heads of households; Appendix C (Housing Needs) (a)(7) and families and persons in need of emergency
shelter.
Appendix C (Housing Needs)
(a)(7) The need for emergency shelter shall be assessed based on the capacity necessary to accommodate the most recent homeless point-in-time count conducted before the start of the planning period, the need for emergency shelter based on number of beds available on a year-round and
seasonal basis, the number of shelter beds that go unused on an average monthly basis within a one-year period, and the percentage of those in emergency shelters that move to permanent housing solutions.
Appendix G (Housing Constraints)
(a)(7) The need for emergency shelter may be reduced by the number of supportive housing units that are identified in an adopted 10-year plan to end chronic homelessness and that are either vacant or for which funding has been identified to allow construction during the planning period.
N/A
(a)(7) An analysis of special housing needs by a city or county may include an analysis of the need for frequent user coordinated care housing services.
N/A
(a)(8) An analysis of opportunities for energy conservation with respect to residential development. Cities and counties are encouraged to include weatherization and energy
efficiency improvements as part of publicly subsidized
housing rehabilitation projects. This may include energy efficiency measures that encompass the building envelope, its heating and cooling systems, and its electrical system.
Section 11 (Goals and Policies),
Program HE-P-4
(a)(9) An analysis of existing assisted housing developments that are eligible to change from low-income housing uses during the next 10 years due to termination of subsidy
contracts, mortgage prepayment, or expiration of restrictions on use. “Assisted housing developments,” for the purpose of this section, shall mean multifamily rental housing that receives governmental assistance under federal programs listed in subdivision (a) of Section 65863.10, state and local multifamily revenue bond programs, local redevelopment
programs, the federal Community Development Block Grant Program, or local in-lieu fees. “Assisted housing
developments” shall also include multifamily rental units that Appendix C (Housing Needs)
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were developed pursuant to a local inclusionary housing program or used to qualify for a density bonus pursuant to Section 65915.
(a)(9)(A) The analysis shall include a listing of each
development by project name and address, the type of
governmental assistance received, the earliest possible date of change from low-income use, and the total number of
elderly and nonelderly units that could be lost from the locality’s low-income housing stock in each year during the 10-year period. For purposes of state and federally funded projects, the analysis required by this subparagraph need only contain information available on a statewide basis.
Appendix C (Housing Needs), Section 9
(a)(9)(B) The analysis shall estimate the total cost of producing new rental housing that is comparable in size and rent levels, to replace the units that could change from lowincome use, and an estimated cost of preserving the assisted housing developments. This cost analysis for replacement housing may be done aggregately for each five-year period and does not have to contain a project-by-project cost
estimate.
Appendix C (Housing Needs)
(a)(9)(C) The analysis shall identify public and private nonprofit corporations known to the local government that have legal and managerial capacity to acquire and manage these housing developments.
Appendix E (Housing Resources)
(a)(9)(D) The analysis shall identify and consider the use of all federal, state, and local financing and subsidy programs that can be used to preserve, for lower income households, the assisted housing developments, identified in this
paragraph, including, but not limited to, federal Community Development Block Grant Program funds, tax increment
funds received by a redevelopment agency of the
community, and administrative fees received by a housing authority operating within the community. In considering the use of these financing and subsidy programs, the analysis shall identify the amounts of funds under each available program that have not been legally obligated for other
purposes and that could be available for use in preserving assisted housing developments.
Appendix E (Housing Resources)
(b) (1) A statement of the community’s goals, quantified objectives, and policies relative to affirmatively furthering fair housing and to the maintenance, preservation, improvement, and development of housing.
Section 5 (Housing Needs)
Section 6 (Assessment of Fair
Housing)
Section 11 (Goals and Policies)
Section 14 (Quantified Objectives)
Appendix C (Housing Needs)
Appendix D (City of Pacifica
Assessment of Fair Housing)
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(2) It is recognized that the total housing needs identified pursuant to subdivision (a) may exceed available resources and the community’s ability to satisfy this need within the content of the general plan requirements outlined in Article 5 (commencing with Section 65300). Under these
circumstances, the quantified objectives need not be
identical to the total housing needs. The quantified objectives shall establish the maximum number of housing units by
income category, including extremely low income, that can be constructed, rehabilitated, and conserved over a five-year time period.
Section 14 (Quantified Objectives)
(c) A program that sets forth a schedule of actions during the planning period, each with a timeline for implementation, that may recognize that certain programs are ongoing, such that there will be beneficial impacts of the programs within the planning period, that the local government is undertaking or intends to undertake to implement the policies and achieve the goals and objectives of the housing element
Section 12 (2023-2031 Programs)
(c) through the administration of land use and development controls,
Section 12 (2023-2031 Programs), HE1-1, HE-1-2, HE-1-3, HE-1-8, HE-I-14 (c) the provision of regulatory concessions and incentives, Section 12 (2023-2031 Programs), HEI-9 (c) the utilization of appropriate federal and state financing and subsidy programs when available,
Section 12 (2023-2031 Programs), HEI-7
(c) and the utilization of moneys in a low- and moderateincome housing fund of an agency if the locality has established a redevelopment project area pursuant to the Community Redevelopment Law (Division 24 (commencing
with Section 33000) of the Health and Safety Code).
Section 14 (Quantified Objectives)
In order to make adequate provision for the housing needs of all economic segments of the community, the program shall do all of the following:
N/A
(c)(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 Section 65584.09.
Section 12 (2023-2031 Programs),
program HE-I-1, HE-1-2, HE-1-6, HE-1-
12 (c)(1) Sites shall be identified as needed to affirmatively further fair housing
Appendix D (City of Pacifica
Assessment of Fair Housing)
(c)(1) and to facilitate and encourage the development of a variety of types of housing for all income levels, including multifamily rental housing,
Appendix C (Housing Needs)
Appendix D (City of Pacifica
Assessment of Fair Housing)
(c)(1) factory-built housing, Appendix G (Housing Constraints)
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(c)(1) mobilehomes, Appendix B (Prior Housing Element
Review), Mobile Home Preservation
(c)(1) housing for agricultural employees, Appendix G (Housing Constraints) Chapter 12 (2023-2031 Programs),
program HE-I-14
(c)(1) supportive housing, Appendix G (Housing Constraints) Chapter 12 (2023-2031 Programs),
program HE-I-14
(c)(1) single-room occupancy units, Appendix G (Housing Constraints) Chapter 12 (2023-2031 Programs),
program HE-I-14
(c)(1) emergency shelters, Appendix G (Housing Constraints) Chapter 12 (2023-2031 Programs),
program HE-I-14
(c)(1) and transitional housing. Appendix G (Housing Constraints) Chapter 12 (2023-2031 Programs),
program HE-I-14
(c)(1)(A) Where the inventory of sites, pursuant to paragraph (3) of subdivision (a), does not identify adequate sites to accommodate the need for groups of all household income levels pursuant to Section 65584, rezoning of those sites, including adoption of minimum density and development
standards, for jurisdictions with an eight-year housing element planning period pursuant to Section 65588, shall be completed no later than three years after either the date the housing element is adopted pursuant to subdivision (f) of Section 65585 or the date that is 90 days after receipt of comments from the department pursuant to subdivision (b) of Section 65585, whichever is earlier, unless the deadline is extended pursuant to subdivision (f). Notwithstanding the foregoing, for a local government that fails to adopt a housing element that the department has found to be in substantial compliance with this article within 120 days of the statutory deadline in Section 65588 for adoption of the housing
element, rezoning of those sites, including adoption of minimum density and development standards, shall be
completed no later than one year from the statutory deadline in Section 65588 for adoption of the housing element.
Section 12 (2023-2031 Programs),
program HE-I-1, HE-I-2
(c)(1)(B) Where the inventory of sites, pursuant to paragraph (3) of subdivision (a), does not identify adequate sites to accommodate the need for groups of all household income levels pursuant to Section 65584, the program shall identify sites that can be developed for housing within the planning period pursuant to subdivision (h) of Section 65583.2. The identification of sites shall include all components specified in Section 65583.2. Note: Please see Section 65583.2
regarding the land inventory and conformance with
subdivision (h).
Section 12 (2023-2031 Programs),
program HE-I-1, HE-I-2
Appendix F (Housing Sites)
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(c)(1)(C) Where the inventory of sites pursuant to paragraph (3) of subdivision (a) does not identify adequate sites to accommodate the need for farmworker housing, the program shall provide for sufficient sites to meet the need with zoning that permits farmworker housing use by right, including density and development standards that could accommodate and facilitate the feasibility of the development of farmworker housing for low- and very low income households.
Section 12 (2023-2031 Programs),
program HE-1-12
(c)(2) Assist in the development of adequate housing to meet the needs of extremely low, very low, low-, and moderateincome households.
Section 12 (2023-2031 Programs), all
programs
(c)(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
Appendix G (Housing Constraints)
(c)(3) 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.
Appendix G (Housing Constraints)
Section 12 (2023-2031 Programs),
programs HE-I-9, HE-I-12
(c)(3) Transitional housing and supportive housing shall be considered a residential use of property and shall be subject only to those restrictions that apply to other residential dwellings of the same type in the same zone.
Appendix G (Housing Constraints)
Section 12 (2023-2031 Programs),
programs HE-I-14
(c)(3) Supportive housing, as defined in Section 65650, shall be a use by right in all zones where multifamily and mixed uses are permitted, as provided in Article 11 (commencing with Section 65650).
Appendix G (Housing Constraints)
Section 12 (2023-2031 Programs),
programs HE-I-14
(c)(4) Conserve and improve the condition of the existing affordable housing stock, which may include addressing
ways to mitigate the loss of dwelling units demolished by public or private action.
Appendix G (Housing Constraints)
Section 12 (2023-2031 Programs),
programs HE-I-8, HE-I-12
(c)(5) Promote and affirmatively further fair housing
opportunities and promote housing throughout the
community or communities for all persons regardless of race, religion, sex, marital status, ancestry, national origin, color, familial status, or disability, and other characteristics protected by the California Fair Employment and Housing Act (Part 2.8 (commencing with Section 12900) of Division 3 of Title 2), Section 65008, and any other state and federal fair housing and planning law.
Section 6 (Assessment of Fair Housing)
Section 10 (Fair Housing Plan)
Appendix D (City of Pacifica Assessment
of Fair Housing)
(c)(6) Preserve for lower income households the assisted housing developments identified pursuant to paragraph (9) of subdivision (a).
Section 6 (Assessment of Fair Housing)
Section 10 (Fair Housing Plan)
Appendix D (City of Pacifica Assessment
of Fair Housing)
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(c)(6) The program for preservation of the assisted housing developments shall utilize, to the extent necessary, all available federal, state, and local financing and subsidy programs identified in paragraph (9) of subdivision (a), except where a community has other urgent needs for which alternative funding sources are not available.
Appendix C (Housing Needs)
(c)(6) The program may include strategies that involve local regulation and technical assistance.
Section 12 (2023-2031 Programs),
programs HE-I-5, HE-I-7
(c)(7) Develop a plan that incentivizes and promotes the creation of accessory dwelling units that can be offered at affordable rent, as defined in Section 50053 of the Health and Safety Code, for very low, low-, or moderate-income households. For purposes of this paragraph, “accessory
dwelling units” has the same meaning as “accessory dwelling unit” as defined in paragraph (4) of subdivision (i) of Section 65852.2.
Section 12 (2023-2031 Programs),
programs HE-I-4
(c)(8) Include an identification of the agencies and officials responsible for the implementation of the various actions and the means by which consistency will be achieved with other general plan elements and community goals.
Section 15 (Consistency with General
Plan, Zoning Code, and Local Coastal
Land Use Plan)
(c)(9) Include a diligent effort by the local government to achieve public participation of all economic segments of the community in the development of the housing element, and the program shall describe this effort.
Appendix F (Housing Sites)
(c)(10)(A) Affirmatively further fair housing in accordance with Chapter 15 (commencing with Section 8899.50) of Division 1 of Title 2. The program shall include an assessment of fair housing in the jurisdiction that shall include all of the following components:
Appendix C (Housing Needs)
Appendix D (City of Pacifica Assessment
of Fair Housing)
(c)(10)(A)(i) A summary of fair housing issues in the
jurisdiction
Appendix C (Housing Needs)
Appendix D (City of Pacifica Assessment
of Fair Housing)
(c)(10)(A)(i) and an assessment of the jurisdiction’s fair housing enforcement and fair housing outreach capacity.
Appendix A (Community Consultation)
Appendix C (Housing Needs)
Appendix D (City of Pacifica Assessment
of Fair Housing)
(c)(10)(A)(ii) An analysis of available federal, state, and local data and knowledge to identify integration and segregation patterns and trends,
Appendix C (Housing Needs)
Appendix D (City of Pacifica Assessment
of Fair Housing)
(c)(10)(A)(ii)racially or ethnically concentrated areas of poverty and affluence,
Appendix C (Housing Needs)
Appendix D (City of Pacifica Assessment
of Fair Housing)
(c)(10)(A)(ii) disparities in access to opportunity, Appendix C (Housing Needs) Appendix D (City of Pacifica Assessment
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of Fair Housing)
(c)(10)(A)(ii) and disproportionate housing needs, Appendix C (Housing Needs) Appendix D (City of Pacifica Assessment
of Fair Housing)
(c)(10)(A)(ii) including displacement risk. Appendix C (Housing Needs) Appendix D (City of Pacifica Assessment
of Fair Housing)
(c)(10)(A)(ii) The analysis shall identify and examine such patterns, trends, areas, disparities, and needs, both within the jurisdiction.
Appendix C (Housing Needs)
Appendix D (City of Pacifica Assessment
of Fair Housing)
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(c)(10)(A)(ii) and comparing the jurisdiction to the region in which it is located, based on race and other characteristics protected by the California Fair Employment and Housing Act (Part 2.8 (commencing with Section 12900) of Division 3 of Title 2) and Section 65008.
Appendix C (Housing Needs)
Appendix D (City of Pacifica Assessment
of Fair Housing)
(c)(10)(A)(iii) An assessment of the contributing factors, including the local and regional historical origins
Appendix C (Housing Needs)
Appendix D (City of Pacifica Assessment
of Fair Housing)
(c)(10)(A)(iii) and current policies and practices, for the fair housing issues identified under clauses (i) and (ii).
Appendix C (Housing Needs)
Appendix D (City of Pacifica Assessment
of Fair Housing)
(c)(10)(A)(iv) An identification of the jurisdiction’s fair housing priorities and goals, giving highest priority to those factors identified in clause (iii) that limit or deny fair housing choice or access to opportunity, or negatively impact fair housing or civil rights compliance,
Appendix C (Housing Needs)
Appendix D (City of Pacifica Assessment
of Fair Housing)
(c)(10)(A)(iv) and identifying the metrics and milestones for determining what fair housing results will be achieved.
Appendix C (Housing Needs)
Appendix D (City of Pacifica Assessment
of Fair Housing)
(c)(10)(A)(v) Strategies and actions to implement those priorities and goals, which may include, but are not limited to, enhancing mobility strategies
Section 12 (2023-2031 Programs), HEI-11, HE-1-12
(c)(10)(A)(v) and encouraging development of new affordable housing in areas of opportunity,
Section 12 (2023-2031 Programs),
HE-I-8, HE-I-9
(c)(10)(A)(v) as well as place-based strategies to encourage community revitalization, including preservation of existing affordable housing,
Section 12 (2023-2031 Programs), all
programs
(c)(10)(A)(v) and protecting existing residents from
displacement.
Section 12 (2023-2031 Programs), HEI-7
(c)(10)(B) A jurisdiction that completes or revises an
assessment of fair housing pursuant to Subpart A
(commencing with Section 5.150) of Part 5 of Subtitle A of Title 24 of the Code of Federal Regulations, as published in Volume 80 of the Federal Register, Number 136, page
42272, dated July 16, 2015, or an analysis of impediments to fair housing choice in accordance with the requirements of Section 91.225 of Title 24 of the Code of Federal Regulations in effect before August 17, 2015, may incorporate relevant portions of that assessment or revised assessment of fair housing or analysis or revised analysis of impediments to fair housing into its housing element.
Section 6 (Assessment of Fair Housing)
(c)(10)(C) The requirements of this paragraph shall apply to housing elements due to be revised pursuant to Section
65588 on or after January 1, 2021.
Applicable; see compliance provisions
noted above
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(d)(1) A local government may satisfy all or part of its requirement to identify a zone or zones suitable for the development of emergency shelters pursuant to paragraph (4) of subdivision (a) by adopting and implementing a
multijurisdictional agreement, with a maximum of two other adjacent communities, that requires the participating
jurisdictions to develop at least one year-round emergency shelter within two years of the beginning of the planning period.
N/A. No multi-jurisdictional agreement
for emergency shelter
(d)(2) The agreement shall allocate a portion of the new shelter capacity to each jurisdiction as credit toward its emergency shelter need, and each jurisdiction shall describe how the capacity was allocated as part of its housing
element.
N/A. No multi-jurisdictional agreement
for emergency shelter
(d)(3) Each member jurisdiction of a multijurisdictional agreement shall describe in its housing element all of the following:
N/A. No multi-jurisdictional agreement
for emergency shelter
(d)(3)(A) How the joint facility will meet the jurisdiction’s emergency shelter need.
(d)(3)(B) The jurisdiction’s contribution to the facility for both the development and ongoing operation and management of the facility.
(d)(3)(C) The amount and source of the funding that the jurisdiction contributes to the facility.
N/A. No multi-jurisdictional agreement
for emergency shelter
(d)(4) The aggregate capacity claimed by the participating jurisdictions in their housing elements shall not exceed the actual capacity of the shelter.
N/A. No multi-jurisdictional agreement
for emergency shelter
(e) Except as otherwise provided in this article, amendments to this article that alter the required content of a housing element shall apply to both of the following: [Note that this provision is applicable to AB 2339 (Chapter 654, Statutes of 2022), which amended Section 65583(a)(4).
Jurisdictions adopting their housing element after
January 1, 2023 should describe why this amendment is
not applicable to them.]
The City Council has adopted an
emergency shelter ordinance that
complies with the applicable statutory
requirements.
(1) A housing element or housing element amendment
prepared pursuant to subdivision (e) of Section 65588 or Section 65584.02, when a city, county, or city and county submits a draft to the department for review pursuant to Section 65585 more than 90 days after the effective date of the amendment to this section.
The City Council has adopted an
emergency shelter ordinance that
complies with the applicable statutory
requirements.
(2) Any housing element or housing element amendment
prepared pursuant to subdivision (e) of Section 65588 or Section 65584.02, when the city, county, or city and county fails to submit the first draft to the department before the due date specified in Section 65588 or 65584.02.
The City Council has adopted an
emergency shelter ordinance that
complies with the applicable statutory
requirements.
(f) – (j): Not applicable N/A
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GOVERNMENT CODE PROVISION HOUSING ELEMENT COMPLIANCE
Section 65583.1(a)
(a) The Department of Housing and Community
Development, in evaluating a proposed or adopted housing element for substantial compliance with this article, … may also allow a city or county to identify sites for accessory dwelling units based on the number of accessory dwelling units developed in the prior housing element planning period whether or not the units are permitted by right, the need for these units in the community, the resources or incentives available for their development, and any other relevant factors, as determined by the department.
Appendix F (Housing Sites)
(b) Sites that contain permanent housing units located on a military base undergoing closure or conversion as a result of action pursuant to the Defense Authorization Amendments and Base Closure and Realignment Act (Public Law 100-
526), the Defense Base Closure and Realignment Act of
1990 (Public Law 101-510), or any subsequent act requiring the closure or conversion of a military base may be identified as an adequate site if the housing element demonstrates that the housing units will be available for occupancy by
households within the planning period of the element. No sites containing housing units scheduled or planned for demolition or conversion to nonresidential uses shall qualify as an adequate site.
N/A (no military base in Pacifica)
Note: If communities are using the provisions of Section 65583.1(c), which allow RHNA credit for conversion of
non-affordable to affordable housing and for
preservation of existing affordable housing at risk of
loss, the applicable provisions need to be added to this table.
N/A. Provision is not being used for
RHNA credit.
Section 65583.2
(a) A city’s or county’s inventory of land suitable for residential development pursuant to paragraph (3) of
subdivision (a) of Section 65583 shall be used to identify sites throughout the community, consistent with paragraph (10) of subdivision (c) of Section 65583,
Appendix F (Housing Sites)
(a) that can be developed for housing within the planning period and that are sufficient to provide for the jurisdiction’s share of the regional housing need for all income levels pursuant to Section 65584. As used in this section, “land suitable for residential development” includes all of the following sites that meet the standards set forth in
subdivisions (c) and (g):
Appendix F (Housing Sites)
(a)(1) Vacant sites zoned for residential use. Appendix F (Housing Sites) (a)(2) Vacant sites zoned for nonresidential use that allows residential development.
Appendix F (Housing Sites)
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GOVERNMENT CODE PROVISION HOUSING ELEMENT COMPLIANCE
(a)(3) Residentially zoned sites that are capable of being developed at a higher density, including sites owned or leased by a city, county, or city and county
Appendix F (Housing Sites)
(a)(4) Sites zoned for nonresidential use that can be
redeveloped for residential use, and for which the housing element includes a program to rezone the site, as necessary, rezoned for, to permit residential use, including sites owned or leased by a city, county, or city and county.
Appendix F (Housing Sites)
(b) The inventory of land shall include all of the following: N/A (b)(1) A listing of properties by assessor parcel number. Appendix F (Housing Sites) (b)(2) The size of each property listed pursuant to paragraph (1), and the general plan designation and zoning of each property.
Appendix F (Housing Sites)
(b)(3) For nonvacant sites, a description of the existing use of each property.
Appendix F (Housing Sites)
(b)(3) If a site subject to this paragraph is owned by the city or county, the description shall also include whether there are any plans to dispose of the property during the planning period and how the city or county will comply with Article 8 (commencing with Section 54220) of Chapter 5 of Part 1 of Division 2 of Title 5.
Appendix F (Housing Sites)
Section 12 (2023-2031 Programs),
program HE-I-1
(b)(4) A general description of any environmental constraints to the development of housing within the jurisdiction, the documentation for which has been made available to the
jurisdiction. This information need not be identified on a sitespecific basis.
Appendix G (Housing Constraints)
(b)(5)(A) A description of existing or planned water, sewer, and other dry utilities supply, including the availability and access to distribution facilities.
Appendix F (Housing Sites)
Appendix G (Housing Constraints)
(b)(5)(B) Parcels included in the inventory must have
sufficient water, sewer, and dry utilities supply available and accessible to support housing development or be included in an existing general plan program or other mandatory
program or plan, including a program or plan of a public or private entity providing water or sewer service, to secure sufficient water, sewer, and dry utilities supply to support housing development. This paragraph does not impose any additional duty on the city or county to construct, finance, or otherwise provide water, sewer, or dry utilities to parcels included in the inventory.
Appendix F (Housing Sites)
(b)(6) Sites identified as available for housing for above moderate-income households in areas not served by public sewer systems. This information need not be identified on a site-specific basis.
N/A. All new development in the City of
Pacifica would be served by a public
sewer system.
(b)(7) A map that shows the location of the sites included in the inventory, such as the land use map from the
jurisdiction’s general plan, for reference purposes only.
Figures F-1 through F-10
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GOVERNMENT CODE PROVISION HOUSING ELEMENT COMPLIANCE
(c) Based on the information provided in subdivision (b), a city or county shall determine whether each site in the inventory can accommodate the development of some
portion of its share of the regional housing need by income level during the planning period, as determined pursuant to Section 65584. The inventory shall specify for each site the number of units that can realistically be accommodated on that site and whether the site is adequate to accommodate lower income housing, moderate-income housing, or above moderate-income housing.
Appendix F (Housing Sites)
(c) A nonvacant site identified pursuant to paragraph (3) or (4) of subdivision (a) in a prior housing element and a vacant site that has been included in two or more consecutive
planning periods that was not approved to develop a portion of the locality’s housing need shall not be deemed adequate to accommodate a portion of the housing need for lower
income households that must be accommodated in the
current housing element planning period unless the site is zoned at residential densities consistent with paragraph (3) of this subdivision and the site is subject to a program in the housing element requiring rezoning within three years of the beginning of the planning period to allow residential use by right for housing developments in which at least 20 percent of the units are affordable to lower income households. An unincorporated area in a nonmetropolitan county pursuant to clause (ii) of subparagraph (B) of paragraph (3) shall not be subject to the requirements of this subdivision to allow residential use by right.
Appendix F (Housing Sites)
Section 12 (2023-2031 Programs),
program HE-I-1
(c) Notwithstanding the foregoing, for a local government that fails to adopt a housing element that the department has found to be in substantial compliance with state law within 120 days of the statutory deadline in Section 65588 for adoption of the housing element, rezoning pursuant to this subdivision shall be completed no later than one year from the statutory deadline in Section 65588 for adoption of the housing element.
N/A – Statutory provision addresses
timing for rezoning, not Housing
Element compliance.
(c) The analysis shall determine whether the inventory can provide for a variety of types of housing, including multifamily rental housing,
Appendix F (Housing Sites)
Section 12 (2023-2031 Programs),
programs HE-I-1, HE-I-4, HE-I-5, HE-I7, HE-I-12
(c) factory-built housing, mobilehomes, Appendix F (Housing Sites) Section 12 (2023-2031 Programs),
programs HE-I-4, HE-I-5, HE-I-7, HE-I12
(c) housing for agricultural employees, supportive housing, Appendix F (Housing Sites) Section 12 (2023-2031 Programs),
programs HE-I-4, HE-I-5, HE-I-7, HE-I12
(c) single-room occupancy units, Appendix F (Housing Sites) Section 12 (2023-2031 Programs),
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programs HE-I-4, HE-I-5, HE-I-7, HE-I12
(c) emergency shelters, and Appendix F (Housing Sites)
Section 12 (2023-2031 Programs),
programs HE-I-4, HE-I-5, HE-I-7, HE-I12
(c) transitional housing Appendix F (Housing Sites)
Section 12 (2023-2031 Programs),
programs HE-I-4, HE-I-5, HE-I-7, HE-I12
(c) and whether the inventory affirmatively furthers fair housing.
Appendix F (Housing Sites)
Section 12 (2023-2031 Programs),
programs HE-I-4, HE-I-5, HE-I-7, HE-I12
(c) The city or county shall determine the number of housing units that can be accommodated on each site as follows:
Appendix F (Housing Sites)
Section 12 (2023-2031 Programs),
programs HE-I-4, HE-I-5, HE-I-7, HE-I12
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GOVERNMENT CODE PROVISION HOUSING ELEMENT COMPLIANCE
(c)(1) If local law or regulations require the development of a site at a minimum density, the department shall accept the planning agency’s calculation of the total housing unit capacity on that site based on the established minimum
density. If the city or county does not adopt a law or
regulation requiring the development of a site at a minimum density, then it shall demonstrate how the number of units determined for that site pursuant to this subdivision will be accommodated.
Appendix F (Housing Sites)
(c)(2) The number of units calculated pursuant to paragraph (1) shall be adjusted as necessary, based on the land use controls and site improvements requirement identified in paragraph (5) of subdivision (a) of Section 65583,
(c)(2) the realistic development capacity for the site, Appendix F (Housing Sites) (c)(2) typical densities of existing or approved residential developments at a similar affordability level in that
jurisdiction,
Appendix F (Housing Sites)
(c)(2) and on the current or planned availability and
accessibility of sufficient water, sewer, and dry utilities.
Appendix F (Housing Sites)
(c)(2)(A) A site smaller than half an acre shall not be deemed adequate to accommodate lower income housing need
unless the locality can demonstrate that sites of equivalent size were successfully developed during the prior planning period for an equivalent number of lower income housing units as projected for the site or unless the locality provides other evidence to the department that the site is adequate to accommodate lower income housing.
Appendix F (Housing Sites)
(c)(2)(B) A site larger than 10 acres shall not be deemed adequate to accommodate lower income housing need
unless the locality can demonstrate that sites of equivalent size were successfully developed during the prior planning period for an equivalent number of lower income housing units as projected for the site or unless the locality provides other evidence to the department that the site can be
developed as lower income housing.
Appendix F (Housing Sites)
(c)(2)(B) For purposes of this subparagraph, “site” means that portion of a parcel or parcels designated to
accommodate lower income housing needs pursuant to this subdivision.
Appendix F (Housing Sites)
(c)(2)(C) A site may be presumed to be realistic for
development to accommodate lower income housing need if, at the time of the adoption of the housing element, a
development affordable to lower income households has
been proposed and approved for development on the site.
Appendix F (Housing Sites)
(c)(3) For the number of units calculated to accommodate its share of the regional housing need for lower income
households pursuant to paragraph (2), a city or county shall do either of the following:
Appendix F (Housing Sites)
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GOVERNMENT CODE PROVISION HOUSING ELEMENT COMPLIANCE
(c)(3)(A) Provide an analysis demonstrating how the adopted densities accommodate this need. The analysis shall include, but is not limited to, factors such as market demand, financial feasibility, or information based on development project experience within a zone or zones that provide housing for lower income households.
Appendix F (Housing Sites)
(c)(3)(B) The following densities shall be deemed appropriate to accommodate housing for lower income households:
(i) For an incorporated city within a nonmetropolitan county and for a nonmetropolitan county that has a micropolitan area: sites allowing at least 15 units per acre.
(ii) For an unincorporated area in a nonmetropolitan county not included in clause (i): sites allowing at least 10 units per acre.
(iii) For a suburban jurisdiction: sites allowing at least 20 units per acre.
(iv) For a jurisdiction in a metropolitan county: sites allowing at least 30 units per acre.
Appendix F (Housing Sites)
(4)(A) For a metropolitan jurisdiction:
(4)(A)(i) At least 25 percent of the jurisdiction’s share of the regional housing need for moderate-income housing shall be allocated to sites with zoning that allows at least 4 units of housing, but not more than 100 units per acre of housing.
Appendix F (Housing Sites)
(4)(A)(ii) At least 25 percent of the jurisdiction’s share of the regional housing need for above moderate-income housing shall be allocated to sites with zoning that allows at least 4 units of housing.
Appendix F (Housing Sites)
(B) The allocation of moderate-income and above moderateincome housing to sites pursuant to this paragraph shall not be a basis for the jurisdiction to do either of the following:
(i) Deny a project that does not comply with the allocation. (ii) Impose a price minimum, price maximum, price control, or any other exaction or condition of approval in lieu thereof.
This clause does not prohibit a jurisdiction from imposing any price minimum, price maximum, price control, exaction, or condition in lieu thereof, pursuant to any other law.
(iii) The provisions of this subparagraph do not constitute a change in, but are declaratory of, existing law with regard to the allocation of sites pursuant to this section.
The City of Pacifica’s 2023-2031
Housing Element is not inconsistent with
this requirement.
(C) This paragraph does not apply to an unincorporated
area.
N/A
(D) For purposes of this paragraph: N/A
(i) “Housing development project” has the same meaning as defined in paragraph (2) of subdivision (h) of Section
65589.5.
N/A
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GOVERNMENT CODE PROVISION HOUSING ELEMENT COMPLIANCE
(ii) “Unit of housing” does not include an accessory dwelling unit or junior accessory dwelling unit that could be approved pursuant to Section 65852.2 or Section 65852.22 or through a local ordinance or other provision implementing either of those sections. This paragraph shall not limit the ability of a local government to count the actual production of accessory dwelling units or junior accessory dwelling units in an annual progress report submitted pursuant to Section 65400 or other progress report as determined by the department.
Appendix F (Housing Sites)
(E) Nothing in this subdivision shall preclude the subdivision of a parcel, provided that the subdivision is subject to the Subdivision Map Act (Division 2 (commencing with Section 66410)) or any other applicable law authorizing the
subdivision of land.
N/A
(d) For purposes of this section, a metropolitan county, nonmetropolitan county, and nonmetropolitan county with a micropolitan area shall be as determined by the United
States Census Bureau. A nonmetropolitan county with a
micropolitan area includes the following counties: Del Norte, Humboldt, Lake, Mendocino, Nevada, Tehama, and
Tuolumne and other counties as may be determined by the United States Census Bureau to be nonmetropolitan counties with micropolitan areas in the future.
N/A. San Mateo County is a
metropolitan county
(e) (1) Except as provided in paragraph (2), a jurisdiction shall be considered suburban if the jurisdiction does not meet the requirements of clauses (i) and (ii) of subparagraph (B) of paragraph (3) of subdivision (c) and is located in a
Metropolitan Statistical Area (MSA) of less than 2,000,000 in population, unless that jurisdiction’s population is greater than 100,000, in which case it shall be considered
metropolitan. A county, not including the City and County of San Francisco, shall be considered suburban unless the
county is in an MSA of 2,000,000 or greater in population in which case the county shall be considered metropolitan.
N/A
(2)(A)(i) Notwithstanding paragraph (1), if a county that is in the San Francisco-Oakland-Fremont California MSA has a
population of less than 400,000, that county shall be
considered suburban. If this county includes an incorporated city that has a population of less than 100,000, this city shall also be considered suburban. This paragraph shall apply to a housing element revision cycle, as described in
subparagraph (A) of paragraph (3) of subdivision (e) of Section 65588, that is in effect from July 1, 2014, to
December 31, 2028, inclusive.
N/A.
(2)(A)(ii) A county subject to this subparagraph shall utilize the sum existing in the county’s housing trust fund as of June 30, 2013, for the development and preservation of housing affordable to low- and very low income households.
N/A
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GOVERNMENT CODE PROVISION HOUSING ELEMENT COMPLIANCE
(2)(B) A jurisdiction that is classified as suburban pursuant to this paragraph shall report to the Assembly Committee on Housing and Community Development, the Senate
Committee on Housing, and the Department of Housing and Community Development regarding its progress in
developing low- and very low income housing consistent with the requirements of Section 65400. The report shall be
provided three times: once, on or before December 31, 2019, which report shall address the initial four years of the housing element cycle, a second time, on or before December 31, 2023, which report shall address the subsequent four years of the housing element cycle, and a third time, on or before December 31, 2027, which report shall address the
subsequent four years of the housing element cycle and the cycle as a whole. The reports shall be provided consistent with the requirements of Section 9795.
N/A
(f) A jurisdiction shall be considered metropolitan if the jurisdiction does not meet the requirements for “suburban area” above and is located in an MSA of 2,000,000 or greater in population, unless that jurisdiction’s population is less than 25,000 in which case it shall be considered suburban.
See notes below.
(g)(1) For sites described in paragraph (3) of subdivision (b) [non-vacant sites], the city or county shall specify the additional development potential for each site within the planning period and shall provide an explanation of the methodology used to determine the development potential.
See Appendix F (Housing Sites) for
analysis of development potential and
explanation of the methodology.
(g)(1) The methodology shall consider factors including the extent to which existing uses may constitute an impediment to additional residential development,
See Appendix F (Housing Sites) for
methodology.
(g)(1) the city’s or county’s past experience with converting existing uses to higher density residential development, See Appendix F (Housing Sites) for
methodology.
(g)(1) the current market demand for the existing use, See Appendix F (Housing Sites) for methodology.
(g)(1) an analysis of any existing leases or other contracts that would perpetuate the existing use or prevent
redevelopment of the site for additional residential
development,
See Appendix F (Housing Sites) for
methodology.
(g)(1) development trends, See Appendix F (Housing Sites) for methodology.
(g)(1) market conditions, See Appendix F (Housing Sites) for methodology.
(g)(1) and regulatory or other incentives or standards to encourage additional residential development on these sites.
See Appendix F (Housing Sites) for
methodology.
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(g)(2) In addition to the analysis required in paragraph (1), when a city or county is relying on nonvacant sites described in paragraph (3) of subdivision (b) to accommodate 50
percent or more of its housing need for lower income
households, the methodology used to determine additional development potential shall demonstrate that the existing use identified pursuant to paragraph (3) of subdivision (b) does not constitute an impediment to additional residential
development during the period covered by the housing
element. An existing use shall be presumed to impede
additional residential development, absent findings based on substantial evidence that the use is likely to be discontinued during the planning period.
N/A – the Housing Element does not
rely on nonvacant sites to
accommodate 50 percent or more of
Pacifica’s housing need for lower
income households.
(g)(3) Notwithstanding any other law, and in addition to the requirements in paragraphs (1) and (2), sites that currently have residential uses, or within the past five years have had residential uses that have been vacated or demolished, that are or were subject to a recorded covenant, ordinance, or law that restricts rents to levels affordable to persons and families of low or very low income, subject to any other form of rent or price control through a public entity’s valid exercise of its police power, or occupied by low or very low income households, shall be subject to a policy requiring the
replacement of all those units affordable to the same or lower income level as a condition of any development on the site.
Replacement requirements shall be consistent with those set forth in paragraph (3) of subdivision (c) of Section 65915.
N/A – the Housing Element does not
include any sites that are covered by
the criteria in this statutory provision.
(h) The program required by subparagraph (A) of paragraph (1) of subdivision (c) of Section 65583 shall accommodate 100 percent of the need for housing for very low and lowincome households allocated pursuant to Section 65584 for which site capacity has not been identified in the inventory of sites pursuant to paragraph (3) of subdivision (a) on sites that shall be zoned to permit owner-occupied and rental multifamily residential use by right for developments in which at least 20 percent of the units are affordable to lower income households during the planning period.
Appendix F (Housing Sites)
Section 12 (2023-2031 Programs),
program HE-I-1, HE-I-8
(h) These sites shall be zoned with minimum density and development standards that permit at least
Appendix F (Housing Sites)
Section 12 (2023-2031 Programs),
program HE-I-1
(h) 16 units per site at a density of at least 16 units per acre in jurisdictions described in clause (i) of subparagraph (B) of paragraph (3) of subdivision (c),
Appendix F (Housing Sites)
Section 12 (2023-2031 Programs),
program HE-I-1
(h) shall be at least 20 units per acre in jurisdictions described in clauses (iii) and (iv) of subparagraph (B) of paragraph (3) of subdivision (c)
Appendix F (Housing Sites)
Section 12 (2023-2031 Programs),
program HE-I-1
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(h) and shall meet the standards set forth in subparagraph (B) of paragraph (5) of subdivision (b).
Appendix F (Housing Sites)
Section 12 (2023-2031 Programs),
program HE-I-1
GOVERNMENT CODE PROVISION HOUSING ELEMENT COMPLIANCE
(h) At least 50 percent of the very low and low-income
housing need shall be accommodated on sites designated
for residential use and for which nonresidential uses or mixed uses are not permitted, except that a city or county may accommodate all of the very low and low-income housing
need on sites designated for mixed uses if those sites allow 100 percent residential use and require that residential use occupy 50 percent of the total floor area of a mixed-use project.
Appendix F (Housing Sites)
Section 12 (2023-2031 Programs),
program HE-I-1
(i) For purposes of this section and Section 65583, the phrase “use by right” shall mean that the local government’s review of the owner-occupied or multifamily residential use may not require a conditional use permit, planned unit
development permit, or other discretionary local government review or approval that would constitute a “project” for purposes of Division 13 (commencing with Section 21000) of the Public Resources Code. Any subdivision of the sites shall be subject to all laws, including, but not limited to, the local government ordinance implementing the Subdivision Map
Act.
Appendix F (Housing Sites)
Section 12 (2023-2031 Programs),
program HE-I-1, HE-I-2, HE-I-4
(i) A local ordinance may provide that “use by right” does not exempt the use from design review. However, that design review shall not constitute a “project” for purposes of Division 13 (commencing with Section 21000) of the Public
Resources Code. Use by right for all rental multifamily residential housing shall be provided in accordance with subdivision (f) of Section 65589.5.
Section 12 (2023-2031 Programs),
program HE-I-2.
(j) Notwithstanding any other provision of this section, within one-half mile of a Sonoma-Marin Area Rail Transit station, housing density requirements in place on June 30, 2014, shall apply.
N/A
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EXHIBIT B
FINDINGS OF SUBSTANTIAL COMPLIANCE WITH STATE HOUSING
ELEMENT LAW BASED ON REVISIONS TO HOUSING ELEMENT TO
ADDRESS FINDINGS IN THE CALIFORNIA DEPARTMENT OF HOUSING AND COMMUNITY DEVELOPMENT (HCD) LETTER FROM AUGUST 8, 2023
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Demonstration of Substantial Compliance through Responses to California Department of Housing & Community Development (HCD) Findings on Draft Pacifica 2023-2031 Housing Element
On May 10, 2023, the City of Pacifica submitted its Draft Housing Element to the California Department of Housing & Community Development (HCD) for that agency’s review. Pursuant to Government Code section 65585, subdivision (b), HCD reviewed the Draft Housing Element and reported the results of its review 90 days after receiving the Draft. The City received HCD’s findings on August 8, 2023. HCD found that the Draft met many statutory requirements but required revisions to be compliant with Housing Element law (Article 10.6 of the Government Code). HCD’s letter included a 12-page Appendix describing the revisions needed. On July 27, 2023, City staff and consultants met with the HCD reviewer, who shared HCD’s intent and expectations on several of the required revisions.
The City of Pacifica has prepared this document to demonstrate that it has edited the Draft Housing Element to respond to all HCD comments, and produced a Draft that is substantially compliant with State Law. The City has also prepared a tracked change (redlined) version of the Draft Housing Element reviewed by HCD showing every change made. This document has organized the HCD findings in numeric sequence, from 1 to 41. Comments are numbered in bold red font. The HCD findings are copied verbatim from the August 8 letter in black font. The City’s responses appear below each finding in blue italic font. The responses direct the reader to the specific location in the “tracked change” document where the edits are located and summarize the edits made. Page number references are to the tracked change version of the Draft Housing Element. All of the tracked edits are incorporated in a “clean” version of the document.
A. Review and Revision
A.1
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, femaleheaded households, farmworkers, and persons experiencing homelessness).
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Packet Pg. 345 Attachment: Attachment A - Draft Resolution (5559 : 2023-2031 Housing Element Update Adoption) Exhibit B: Responses to HCD Findings – January 22, 2024 B-2 City Response:
See Appendix B, Section 4. An additional section that provides a cumulative evaluation of the effectiveness of past goals, policies, and actions regarding the special needs populations has been added to Appendix B.
B. Housing Needs, Resources, and Constraints
B.1
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/communitydevelopment/affh/docs/AFFH_Document_Final_4-27- 2021.pdf.
City Response:
See Appendix D. pp. 7, 16. An analysis of past or current fair housing lawsuits, findings, settlements, judgements, or complaints has been added to Appendix D. As noted in the added text, the City of Pacifica has not been a party to fair housing complaints or legal action in the past nor has the City been required to operate under a state or federal consent decree related to fair housing.
B.2
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 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
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Packet Pg. 346 Attachment: Attachment A - Draft Resolution (5559 : 2023-2031 Housing Element Update Adoption) Exhibit B: Responses to HCD Findings – January 22, 2024 B-3 proposed policies, programs, and funding to help address those gaps.
City Response:
See Housing Element Section 12. 2023-2031 Programs. Implementation Actions within HE-I-2, HE-I-3, HE-I-5, and Section 10. Fair Housing Plan. See also Appendix C Housing Needs (throughout). An analysis of the existing needs and resources for each special need group has been added to multiple sections within Appendix C and Section 10. Fair Housing Plan has been expanded to connect the analysis included in Appendix C with previous and new program implementation actions. Additional language has been added at the beginning of each program to explicitly tie Constraints, Fair Housing Issues, Contributing Factors, and Special Needs to that program’s Implementation Actions. Implementation Actions to address needs have been added and expanded and include provisions to support the production of larger units; remove discretionary review of multifamily housing—including special needs housing; establish a funding source for ELI-housing that establishes support for housing with people with disabilities including developmental disabilities as a high-priority investment.
B.3
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).) The above introductory statement does not require a response.
B.3.1
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
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Packet Pg. 347 Attachment: Attachment A - Draft Resolution (5559 : 2023-2031 Housing Element Update Adoption) Exhibit B: Responses to HCD Findings – January 22, 2024 B-4 analysis, the element may need to add or modify programs committing to facilitating and encouraging the development of these projects.
City Response:
See Revised Tables F-2 and F-9 (formerly F-7) and related narrative in Section F-4. Planned and Approved Projects. The number of units has been reconciled and language on each project’s status has been added. Based on HCD guidance, planning applications that have a high likelihood of approval have been included as an offset to RHNA. (In the prior version, they were included as opportunity sites.)
B.3.2.A
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.
City Response:
See Appendix F. The element has been revised to include additional analysis regarding typical densities on recent and pipeline projects including additional information on the zone, acreage, built density, allowable density, etc. These criteria have been analyzed and the conclusions applied to the revised sites list. See Appendix F for discussion of realistic capacity, development trends, and redevelopment potential of sites on the revised inventory.
B.3.2.B
• 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 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
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Packet Pg. 348 Attachment: Attachment A - Draft Resolution (5559 : 2023-2031 Housing Element Update Adoption) Exhibit B: Responses to HCD Findings – January 22, 2024 B-5 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.
City Response:
See Program HE-I-1.10. The Housing Element has been revised to incorporate the alternative suggested by HCD. Specifically, the Housing Element has been revised with commitments to rezone to 60 units per acre any sites that remain on the inventory that had previously assumed AB 2011 densities. Therefore, capacity assumptions regarding AB 2011 are no longer applicable to sites identified within the Housing Element.
B.3.2.C
• 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-and- community-development/housingelements/building-blocks/analysis-sites-and- zoning.
City Response
See revisions to Appendix F, Section 9. The Housing Element has been revised to ensure that 100 percent nonresidential uses will not be permitted to occupy the entirety of these sites once rezonings are complete. The sites will be required to include residential uses (see Program HE-I-2). As such, additional analysis for any such sites is not required. See also Appendix G, Section 2. subsection "Processing and Permitting Procedures" subsubsection "findings." B.3.3
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
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Packet Pg. 349 Attachment: Attachment A - Draft Resolution (5559 : 2023-2031 Housing Element Update Adoption) Exhibit B: Responses to HCD Findings – January 22, 2024 B-6 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.
City Response:
See Housing Element Section 8. The sites inventory has been revised and includes no low income designated sites on sites of less than one half-acre.
The implementation action regarding site consolidation incentives previously numbered as HE.I-1.5 has been removed accordingly.
B.3.4
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 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.
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Packet Pg. 350 Attachment: Attachment A - Draft Resolution (5559 : 2023-2031 Housing Element Update Adoption) Exhibit B: Responses to HCD Findings – January 22, 2024 B-7 City Response:
See Appendix F, Section: Other Commercial Opportunity Sites (pp. F-21-F-26).
The housing sites inventory analysis included in Appendix F has been significantly revised to include new redevelopment factor analysis and precedent trend analysis to supplement prior analysis. Non-vacant parcels are included on the sites list as potential residential development opportunities based on five redevelopment characteristics and rezoning to densities in the range of 30-60 DU/A. Nonvacant sites must meet four out of five criteria to be included on the sites list as discussed in the section: “Other Commercial Opportunity Sites.” The factors were gathered from approved projects in Pacifica and some of its surrounding neighboring cities. The site characteristics are summarized in Table F-7. How the factors were considered in relation to specific sites is provided in site list tables F-10 and F-11.
B.3.5
Publicly-Identified Sites: The element identifies several publicly-identified sites to accommodate a portion of the RHNA including school district and CityOwned sites. The element must include an analysis addressing 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).
City Response:
See Housing Element Program HE-I-1 and HE-I-3. An analysis of public comments and other factors has been expanded in relation to publicly owned sites as described in Appendix F. Specifically, Implementation Action HE-I-1.6 commits to completion of the Surplus Land Act (SLA) and other required processes for City-owned sites. Implementation Action HE-I-3 commits to coordination with the Pacifica School District and Jefferson Union High School District to complete the SLA process for school district-owned sites.
Implementation Actions HE-I-1.5, 1.6, and 1.11 commit to completion of the decertification process for Caltrans-owned sites within three years from the start of the planning period.
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Packet Pg. 351 Attachment: Attachment A - Draft Resolution (5559 : 2023-2031 Housing Element Update Adoption) Exhibit B: Responses to HCD Findings – January 22, 2024 B-8 B.3.6
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.
City Response:
See Housing Element Program HE-I-1 and HE-I-3. The analysis of Caltransowned sites has been expanded as described in Appendix F. Implementation Actions HE-I-1.5, 1.6, and 1.11 commit to completion of the decertification process for Caltrans-owned sites within three years from the start of the planning period. The program now includes timelines and backup actions.
B.3.7
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 lowerincome 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.
City Response:
See Housing Element Section 8, Programs HE-I-1 and HE-I-4, and Appendix F Section 9. Pacifica Sites List. The Element has been revised to ensure consistency with Government Code section 65583.2 and commits to establishing a minimum of 20 units per acre. Please see the revised organization and composition of the sites inventory, specifically tables 4, F-5, F7, and F-9 to F-12. See also the analysis included within Appendix F sections 6 and 7.
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Packet Pg. 352 Attachment: Attachment A - Draft Resolution (5559 : 2023-2031 Housing Element Update Adoption) Exhibit B: Responses to HCD Findings – January 22, 2024 B-9 B.3.8
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 allow at least four units of housing (e.g., four plex or greater) (Gov. Code, § 65583.2, subd. (c)(4)).
City Response:
See Appendix F, Section 8. Income Assumptions on RHNA Sites List. All (100%) of the moderate and above-moderate sites included in the housing element sites list allow for at least four housing units, ranging from 6 to 64 units. This complies with AB 725. See also the revised sites list and analysis in Appendix F, Section 8.
B.3.9
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. G30). 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.
City Response:
See revised housing site inventory in Section 9. and Appendix F. See also Appendix G. The revised housing sites inventory significantly reduces the number of units in the Rockaway Pump Station catchment area from approximately 700 to approximately 180 units. Analysis, described in Appendix G, demonstrates that when combined with already planned capital improvements to replace all sewer main lines in the catchment area, there is no water pump infrastructure constraint to the development of the 180 units included in the inventory.
Zoning for a Variety of Housing Types:
B.3.10.A
• 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
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Packet Pg. 353 Attachment: Attachment A - Draft Resolution (5559 : 2023-2031 Housing Element Update Adoption) Exhibit B: Responses to HCD Findings – January 22, 2024 B-10 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 byright 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-andcommunity/ab2339- notice.pdf.
City Response:
See Appendix G, Ordinance 849-C.S. (Adopted December 11, 2023), and Housing Element Program HE-I-14. See also Appendix B.
After the publication of the Housing Element in May, 2023, the City of Pacifica adopted Ordinance 849-C.S. Emergency Shelters. This Ordinance expands the areas where an emergency shelter can be located and updates and clarifies procedures to ensure compliance with state law. Analysis of constraints to emergency shelters has been expanded and is included in Appendix G. See also Program HE-I-14 and table B-2 in Appendix B.
B.3.10.B
• 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 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
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Packet Pg. 354 Attachment: Attachment A - Draft Resolution (5559 : 2023-2031 Housing Element Update Adoption) Exhibit B: Responses to HCD Findings – January 22, 2024 B-11 Code Section 65583 (a)(5).
City Response:
See Program HE-I-1, and HE-I-14. Further analysis has confirmed the City’s existing Zoning Ordinance does not classify transitional or supportive housing as a not-permitted use, nor does it impose any specific restrictions on these housing types. These programs commit to update the zoning code with respect to Transitional and Supportive Housing to conform to the Government Code requirements regarding the classification of these uses as permitted uses in all appropriate zoning districts. Further, Program HE-I-1 (13.b) commits to revise use and density descriptions regarding the term “Family” within the zoning regulations to ensure this is not a barrier to the creation of transitional or supportive housing.
B.3.10.C
• 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.
City Response:
See Housing Element Programs HE-I-4, HE-I-14. Housing Element Programs HE-I-4, HE-I-14 have been revised to include commitments for conformance with enacted legislation, at least 15 ADU planning applications per year, timeline specifics, and specific backup actions to kick in at a mid-cycle review if key metrics are not met.
B.3.10.D
• 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
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Packet Pg. 355 Attachment: Attachment A - Draft Resolution (5559 : 2023-2031 Housing Element Update Adoption) Exhibit B: Responses to HCD Findings – January 22, 2024 B-12 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-community- development/housingelements/building-blocks/zoning-variety-of-housing-types.
City Response:
See Housing Element Programs HE-I-9 and HE-I-14 and appendices C and G. The programs have been revised to include specific commitments related to SROs, and terminology definitions within the zoning code, including updating the definition of “boardinghouse” to explicitly indicate that it includes the SRO use, See also expanded analysis included in Appendices C (Section 18) and G (Section 2).
B.4
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).) City Response:
Additional analysis has been provided in Appendix G, Section 2, regarding the types of uses described in the code sections referenced by HCD. Additional discussion on how the Element incorporates public comments on this topic has been added to Appendix A, Section 3. The programs below have also been revised:
1. Persons with disabilities, including developmental disabilities: See Policy HE-P-11, Programs HE-I-1, HE-I-5, HE-I-6, HE-I-9, and HE-I-12.
2. Multifamily rental housing: See revised Programs HE-I-2, HE-I-3 and additional analysis in Appendix C, Section 2.
3. Factory-built housing: See Program HE-I-14.
4. Mobile homes: See Policy HE-P-12, Programs HE-I-7 and HE-I-13.
5. Housing for agricultural employees: See Programs HE-I-1, HE-I-9, HE-I-12, and HE-I-14.
6. Supportive housing: See Programs HE-I-5, HE-I-10, HE-I-11, and HE-I-14.
7. Single-room occupancy units, See Programs HE-I-9 and HE-I-14 and response to comment B.3.10.D above.
8. Emergency shelters: See Ordinance 849-C.S., and Housing Element
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Packet Pg. 356 Attachment: Attachment A - Draft Resolution (5559 : 2023-2031 Housing Element Update Adoption) Exhibit B: Responses to HCD Findings – January 22, 2024 B-13 Program HE-I-14. See also Appendix B. and response to comment B.2 above.
9. Transitional housing: See Programs HE-I-11 and HE-I-14.
B.4.1
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 one- bedroom unit).
City Response:
See Housing Element Program HE-I-1. See also HE-I-12, HE-I-14. Program commitments were revised to conform with the comment and make specific commitments to reduce parking as described in the program text.
B.4.2
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/housingelements/building- blocks/fees-and-exactions.
City Response:
See Appendix G, Section 2. Additional analysis has been added to Appendix G and demonstrates the fees and exactions are not constraints on the development of housing units.
Local Processing and Permit Procedures:
B.4.3.A
• 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
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Packet Pg. 357 Attachment: Attachment A - Draft Resolution (5559 : 2023-2031 Housing Element Update Adoption) Exhibit B: Responses to HCD Findings – January 22, 2024 B-14 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).
City Response:
See revised Programs HE-I-2, HE-I-3, and Appendix G for analysis. The Programs noted above have been revised to include: removal of subjective findings from the Site Development Permit (PSD) required for residential projects or mixed-use projects that include residential use; and removal of the requirement for approval of a Conditional Use Permit (UP) to authorize residential uses consistent with the General Plan, including but not limited to land use and density.
B.4.3.B
• 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.
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Packet Pg. 358 Attachment: Attachment A - Draft Resolution (5559 : 2023-2031 Housing Element Update Adoption) Exhibit B: Responses to HCD Findings – January 22, 2024 B-15 City Response:
See revised Programs HE-I-2, HE-I-3, and Appendix G for analysis. The programs have been revised to address potential constraints by requiring the following: the rezoning of properties that are undeveloped, designated in the General Plan for residential use, and zoned as P-D (Planned Development) to a non-P-D zoning classification aligned with their allowable use(s) and permissible densities in the General Plan in order to establish an approval process for these sites that does not require legislative approval by City Council (the Development Plan); and revisions to the criteria and findings associated with project approvals in the P-D zoning district to focus on objective standards compliance to streamline project review and approval for sites located in the HPD (Hillside Preservation District) overlay district that must be rezoned to PD.
B.4.3.C
• 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.
City Response:
See Program HE-I-2. Program text was revised to include an implementation action to initiate a standard operating procedure regarding the PSA and CEQA.
B.4.4
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.
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Packet Pg. 359 Attachment: Attachment A - Draft Resolution (5559 : 2023-2031 Housing Element Update Adoption) Exhibit B: Responses to HCD Findings – January 22, 2024 B-16 City Response:
See Appendix G, Section 2. Appendix G has been revised to include expanded analysis on the inclusionary zoning ordinance and requirements. The analysis concludes that these are not a constraint to the development of housing units at all income levels.
B.4.5
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-andcommunity-development/housing- elements/building-blocks/codes-andenforcement-and-onsite-offsite-improvement- standards.
City Response:
See Appendix G, Section 2. Appendix G has been revised to include expanded analysis of subdivision level improvement requirements. The analysis concludes that these are not a constraint to the development of housing units or affordability.
Constraints on Housing for Persons with Disabilities:
B.4.6.A
• 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.
City Response:
See Policy HE-P-4, Program HE-I-12, and Appendix G, Section 2.
Analysis on Reasonable Accommodation procedures has been expanded in Appendix G. Program text has been revised to include specific commitments and additional timelines related to reasonable
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Packet Pg. 360 Attachment: Attachment A - Draft Resolution (5559 : 2023-2031 Housing Element Update Adoption) Exhibit B: Responses to HCD Findings – January 22, 2024 B-17 accommodations.
B.4.6.B
• 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 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.
City Response:
See Program HE-I-4 and Appendix G, Section 2. Analysis on potential constraints regarding Group Homes has been expanded in Appendix G.
Program text has been revised to remove the 500-foot spacing requirement and apply the same types of zoning standards to group homes with seven or more persons as would apply to other similar housing types in the same zoning district. The amended zoning code will expand beyond recent updates to the zoning code to clarify that seven or more individuals as described above living in a home would be a permitted use and not by itself be cause for application to the City for a use permit or license. The definition of family will be revised to conform with contemporary best practice, including clarification that family be defined as, “family or single housekeeping unit.”
B.5
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).)
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Packet Pg. 361 Attachment: Attachment A - Draft Resolution (5559 : 2023-2031 Housing Element Update Adoption) Exhibit B: Responses to HCD Findings – January 22, 2024 B-18 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.
City Response:
See Program HE-I-2. Program HE-I-2 has been revised to provide additional clarity and level of commitment to streamlining and expediting of processes for housing at all income levels. The program commits to streamline CEQA processing timelines, establish objective development standards to shorten application review processing timelines, streamline processing time by removing the requirement of a Conditional Use Permit (UP) in certain instances, and support applicants throughout the submittal process with expanded hours that building division staff are available.
B.6
6. Analyze existing assisted housing developments that are eligible to change to non-low- income housing uses during the next 10 years due to termination of subsidy contracts, mortgage prepayment, or expiration of use restrictions. (Gov. Code, § 65583, subd. (a)(9) through 65583(a)(9)(D).).
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-communitydevelopment/housing- elements/building-blocks/assisted-housing-developmentsrisk-conversion.
City Response:
See Appendix C., Section 9, Program HE-I-8. An assessment of conversion risk of the property has been expanded in Section 9 of Appendix C.
Additionally, Program HE-I-8 has been revised to clarify the City's response.
There is a low likelihood of conversion risk for the 101 units indicated in the comment above. The long track record of renewal in the Section 8 program, and limits to density and senior housing use requirements as described above, indicate it is highly unlikely the owner will opt to pursue such a path. As described above and in program HE-I-8 the city is committed to proactive outreach to minimize the risk of this occurring.
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Packet Pg. 362 Attachment: Attachment A - Draft Resolution (5559 : 2023-2031 Housing Element Update Adoption) Exhibit B: Responses to HCD Findings – January 22, 2024 B-19 C.1
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, singleroom occupancy units, emergency shelters, and transitional housing. (Gov.
Code, § 65583, subd. (c)(1).)
This above introductory statement does not require a response.
C.1.1
As noted in Finding B3, the element does not include a complete site analysis; therefore, the adequacy of sites and zoning were not established.
Based on the results of a 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:
City Response:
See Housing Element Section 8. Housing Sites Inventory, Appendix F, and Program HE-I-1. The sites list organization and structuring of the sites list has been substantially revised. Analysis of the sites on the reorganized list has also been significantly expanded as discussed in Section 8 and in Appendix F. Additional program language has been added to program HE-I1 to demonstrate that each site included on the inventory in this draft is adequate for at least the number of units allocated.
C.1.2
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
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Packet Pg. 363 Attachment: Attachment A - Draft Resolution (5559 : 2023-2031 Housing Element Update Adoption) Exhibit B: Responses to HCD Findings – January 22, 2024 B-20 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/housingelement/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.
City Response:
See Program HE-I-1. The program has been revised to commit to all required rezonings and specific timelines have been added or revised.
C.1.3
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).
City Response:
See Program HE-I-4. The program has been revised and a backup action has been added. It now includes commitments for a mid-cycle review and if a gap is identified also commits to identification and rezoning of additional sites if that gap cannot already be accommodated within in the buffer sites.
C.1.4
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Packet Pg. 364 Attachment: Attachment A - Draft Resolution (5559 : 2023-2031 Housing Element Update Adoption) Exhibit B: Responses to HCD Findings – January 22, 2024 B-21 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.
City Response:
See Programs HE-I-1 and HE-I-3 and Appendix F. Program text has been revised to include additional commitments, timelines, metrics, and backup actions for publicly owned sites, including Caltrans sites remining on the inventory. Appendix F, Section 7 discusses each individual site in greater detail.
C.2
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 moderate- income 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.
See Programs HE-I-5, HE-I-9, HE-I-12, and HE-I-14 and Appendices B, C, F, and E. Program text has been revised to include additional actions related to farmworker and agricultural employee housing. Specifically, several provisions of HE-I-9 that had been proposed for further consideration are now made as commitments. A new section (18) has been added to Appendix C analyzing housing need for this important population.
Appendix F, Section 7 has been expanded to include greater detail on each relevant site in greater detail and Appendix E includes additional relevant housing resources information and analysis.
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Packet Pg. 365 Attachment: Attachment A - Draft Resolution (5559 : 2023-2031 Housing Element Update Adoption) Exhibit B: Responses to HCD Findings – January 22, 2024 B-22 C.3
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.
City Response:
See Housing Element Section 10. Fair Housing Plan and Programs HE-I-1, HE-I-4, HE-I-6, HE-I-9, and HE-I-12. The document has been revised to include additional analysis and program commitments regarding governmental constraints to the maintenance, improvement, and development of housing, including housing for all income levels and housing for persons with disabilities. Programs have also been revised to remove constraints to, and provide reasonable accommodations for housing designed for, intended for occupancy by, or with supportive services for, persons with disabilities. The actions in this plan directly respond to the updated analyses in Appendix C – Special Housing Needs and Appendix D – Assessment of Fair Housing. In addition, constraints listed above are analyzed in the Housing Element Section 9. Housing Constraints and Appendix D – Assessment of Fair Housing. Programs were also modified throughout to address potential fair housing issues for contributing factors that are described in the fair housing analysis. Program HE-I-2 (Zoning and Streamlining) affirmatively commits to changing standards and other process to the facilitate development of housing, including increasing heights, reduced parking, modifying densities standards, and changes to the City’s definition of family.
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Packet Pg. 366 Attachment: Attachment A - Draft Resolution (5559 : 2023-2031 Housing Element Update Adoption) Exhibit B: Responses to HCD Findings – January 22, 2024 B-23 C.4
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 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.
City Response:
See Housing Element Section 10. Fair Housing Plan and Programs HE-I-1, HE-I-4, HE-I-6, HE-I-9, and HE-I-12. Program language has been strengthened regarding affirmative marketing strategies for affordable housing units located within RCAAs to market units to lower income households by developing standard City-required marketing activities by housing developers for new or available BMR or low-income units to increase the chances of people, including families with children, outside the RCAA to learn about affordable housing opportunities within the RCAA. The actions in this plan directly respond to the updated analyses in Appendix C - Special Housing Needs and Appendix D – Assessment of Fair Housing.
D. Quantified Objectives
D.1
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
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Packet Pg. 367 Attachment: Attachment A - Draft Resolution (5559 : 2023-2031 Housing Element Update Adoption) Exhibit B: Responses to HCD Findings – January 22, 2024 B-24 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.
City Response:
See Housing Element Program HE-I-8. The program was modified to include an expanded rehabilitation program. The quantified objectives summary and analysis were revised to include rehabilitation as described in Section 14.
Quantified Objectives.
E. Consistency with General Plan
E.1
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 lowerand 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.
City Response:
See Housing Element Program HE-I-8. The element was revised to include a proactive property identification program whereby the City’s code enforcement staff would identify properties in need of significant maintenance to assist with property rehabilitation. The program also commits to updating its operating procedures to require income levels of occupant income levels prior to the
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Packet Pg. 368 Attachment: Attachment A - Draft Resolution (5559 : 2023-2031 Housing Element Update Adoption) Exhibit B: Responses to HCD Findings – January 22, 2024 B-25 issuance of any permit for demolition of residential units or conversion to nonresidential uses within the Coastal Zone.
End
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Packet Pg. 369 Attachment: Attachment A - Draft Resolution (5559 : 2023-2031 Housing Element Update Adoption)
EXHIBIT C
2023-2031 HOUSING ELEMENT OF THE GENERAL PLAN AS APPROVED BY
THE CITY COUNCIL
(TO BE INSERTED UPON ADOPTION OF RESOLUTION)
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Packet Pg. 434 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 435 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 436 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 437 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 438 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 439 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 440 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 441 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 442 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 443 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 444 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 445 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 446 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 447 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 448 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 449 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 450 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 451 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 452 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 453 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 454 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 455 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 456 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 457 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 458 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 459 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 460 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 461 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 462 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 463 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 464 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 465 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 466 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 467 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 468 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 469 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 470 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 471 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 472 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 473 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 474 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 475 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 476 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 477 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 478 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 479 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 480 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 481 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 482 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 483 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 484 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 485 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 486 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 487 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 488 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 489 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 490 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 491 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 492 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 493 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 494 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 495 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 496 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 497 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 498 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 499 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 500 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 501 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 502 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 503 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 504 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 505 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 506 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 507 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 508 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 509 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 510 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 511 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 512 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 513 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 514 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 515 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 516 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 517 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 518 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 519 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 520 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 521 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 522 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 523 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 524 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 525 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 526 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 527 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 528 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 529 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 530 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 531 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 532 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 533 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 534 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 535 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 536 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 537 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 538 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 539 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 540 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 541 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 542 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 543 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 544 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 545 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 546 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 547 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 548 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 549 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 550 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 551 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 552 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 553 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 554 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 555 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 556 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 557 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 558 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 559 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 560 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 561 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 562 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 563 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 564 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 565 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 566 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 567 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 568 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 569 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 570 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 571 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 572 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 573 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 574 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 575 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 576 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 577 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 578 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 579 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 580 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 581 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 582 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 583 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 584 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 585 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 586 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 587 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 588 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 589 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 590 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 591 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 592 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
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Packet Pg. 593 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
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Packet Pg. 594 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
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Packet Pg. 595 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 596 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 597 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 598 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 599 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 600 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 601 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 602 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 603 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 604 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 605 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 606 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 607 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 608 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 609 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 610 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 611 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 612 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 613 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 614 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 615 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 616 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 617 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 618 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 619 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 620 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 621 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 622 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 623 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 624 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 625 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 626 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 627 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 628 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 629 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 630 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 631 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 632 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 633 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 634 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 635 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 636 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 637 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 638 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 639 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 640 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 641 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 642 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 643 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 644 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 645 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 646 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 647 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 648 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 649 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 650 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 651 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 652 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 653 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 654 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 655 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 656 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 657 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 658 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 659 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 660 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 661 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 662 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 663 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 664 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 665 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 666 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 667 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 668 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 669 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 670 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 671 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 672 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 673 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 674 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 675 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 676 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 677 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 678 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 679 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 680 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 681 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 682 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 683 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 684 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 685 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 686 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 687 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 688 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 689 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 690 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 691 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 692 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 693 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 694 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 695 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 696 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 697 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 698 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 699 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 700 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 701 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 702 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 703 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 704 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 705 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 706 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 707 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 708 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 709 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 710 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 711 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 712 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 713 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 714 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 715 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 716 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 717 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 718 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 719 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 720 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 721 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 722 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 723 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 724 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 725 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 726 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 727 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 728 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 729 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 730 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 731 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 732 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 733 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 734 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 735 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 736 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 737 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 738 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 739 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 740 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 741 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 742 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 743 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 744 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 745 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 746 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 747 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 748 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 749 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 750 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 751 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 752 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 753 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 754 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 755 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 756 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 757 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 758 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 759 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 760 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 761 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 762 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 763 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 764 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 765 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 766 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 767 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 768 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 769 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 770 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 771 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 772 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 773 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 774 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 775 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 776 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 777 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 778 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 779 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 780 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 781 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 782 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 783 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 784 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 785 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 786 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 787 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 788 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 789 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 790 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 791 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 792 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 793 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 794 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 795 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 796 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 797 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 798 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 799 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 800 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 801 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 802 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 803 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 804 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 805 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 806 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 807 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 808 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 809 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 810 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 811 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 812 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 813 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 814 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 815 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 816 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 817 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 818 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 819 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 820 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 821 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 822 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 823 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 824 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 825 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 826 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 827 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 828 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 829 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 830 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 831 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 832 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 833 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 834 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 835 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 836 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 837 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 838 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 839 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 840 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 841 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 842 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 843 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 844 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 845 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 846 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 847 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 848 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 849 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 850 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 851 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 852 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 853 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 854 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 855 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 856 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 857 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 858 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 859 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 860 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 861 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 862 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 863 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 864 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 865 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 866 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 867 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 868 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 869 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 870 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 871 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 872 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 873 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 874 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 875 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 876 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 877 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 878 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 879 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 880 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 881 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 882 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 883 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 884 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 885 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 886 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 887 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 888 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 889 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 890 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 891 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 892 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 893 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 894 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 895 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 896 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 897 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 898 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 899 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 900 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 901 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 902 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 903 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 904 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 905 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 906 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 907 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 908 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 909 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 910 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 911 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 912 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 913 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 914 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 915 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 916 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 917 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 918 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 919 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 920 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 921 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 922 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 923 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 924 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 925 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 926 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 927 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 928 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 929 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 930 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 931 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 932 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 933 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 934 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 935 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 936 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 937 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 938 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 939 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 940 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 941 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 942 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 943 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 944 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 945 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 946 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 947 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 948 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 949 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 950 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 951 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 952 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 953 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 954 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 955 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 956 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 957 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 958 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 959 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 960 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 961 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 962 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 963 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 964 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 965 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 966 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 967 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 968 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 969 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 970 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 971 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 972 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 973 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 974 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 975 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 976 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 977 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 978 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 979 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 980 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 981 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 982 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 983 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 984 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 985 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 986 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 987 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 988 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 989 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 990 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 991 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 992 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 993 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 994 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 995 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 996 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 997 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 998 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 999 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 1000 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 1001 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 1002 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 1003 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 1004 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 1005 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 1006 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 1007 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 1008 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 1009 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 1010 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 1011 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 1012 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 1013 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 1014 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 1015 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 1016 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 1017 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 1018 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 1019 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 1020 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 1021 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 1022 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 1023 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 1024 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 1025 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 1026 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 1027 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 1028 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 1029 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 1030 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 1031 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 1032 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 1033 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 1034 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 1035 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 1036 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 1037 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 1038 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 1039 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 1040 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 1041 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 1042 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 1043 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 1044 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 1045 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 1046 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 1047 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 1048 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 1049 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 1050 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 1051 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 1052 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 1053 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 1054 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 1055 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 1056 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 1057 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 1058 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 1059 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 1060 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 1061 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 1062 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 1063 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 1064 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 1065 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 1066 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 1067 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 1068 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 1069 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 1070 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 1071 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 1072 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 1073 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 1074 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 1075 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 1076 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 1077 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 1078 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 1079 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 1080 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 1081 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 1082 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 1083 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 1084 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 1085 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 1086 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 1087 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 1088 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 1089 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 1090 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 1091 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 1092 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 1093 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 1094 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 1095 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 1096 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 1097 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 1098 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 1099 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 1100 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 1101 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 1102 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 1103 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 1104 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 1105 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 1106 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 1107 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 1108 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 1109 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 1110 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 1111 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 1112 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 1113 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 1114 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 1115 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 1116 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 1117 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 1118 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 1119 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 1120 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 1121 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 1122 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 1123 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 1124 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 1125 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 1126 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 1127 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 1128 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 1129 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 1130 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 1131 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 1132 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 1133 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 1134 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 1135 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 1136 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 1137 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 1138 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 1139 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 1140 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 1141 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 1142 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 1143 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 1144 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 1145 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 1146 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 1147 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 1148 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 1149 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 1150 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 1151 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 1152 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 1153 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 1154 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 1155 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 1156 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 1157 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 1158 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 1159 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 1160 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 1161 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 1162 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 1163 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 1164 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 1165 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 1166 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 1167 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 1168 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 1169 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 1170 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 1171 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 1172 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 1173 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 1174 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 1175 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 1176 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 1177 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 1178 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 1179 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 1180 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 1181 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 1182 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 1183 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 1184 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 1185 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 1186 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 1187 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 1188 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 1189 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 1190 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 1191 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 1192 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 1193 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 1194 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 1195 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 1196 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 1197 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 1198 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 1199 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 1200 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 1201 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 1202 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 1203 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 1204 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 1205 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 1206 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 1207 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 1208 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 1209 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 1210 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 1211 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 1212 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 1213 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 1214 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 1215 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 1216 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 1217 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 1218 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 1219 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 1220 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 1221 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 1222 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 1223 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 1224 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 1225 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 1226 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 1227 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 1228 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 1229 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 1230 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
Packet Pg. 1231 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update
5.b
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Packet Pg. 1245 Attachment: Attachment B - Draft Housing Element 2023-2031 - Adoption Version (Jan 22, 2024) (5559 : 2023-2031 Housing Element Update 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
B.3.4
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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
B.3.8
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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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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
B.4
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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
B.4.3.B
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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
B.4.5
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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).)
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Packet Pg. 1256 Attachment: Attachment C - HCD Comment Letter on First Draft Housing Element (with numbering) (5559 : 2023-2031 Housing Element Update 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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Packet Pg. 1257 Attachment: Attachment C - HCD Comment Letter on First Draft Housing Element (with numbering) (5559 : 2023-2031 Housing Element Update 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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Packet Pg. 1258 Attachment: Attachment C - HCD Comment Letter on First Draft Housing Element (with numbering) (5559 : 2023-2031 Housing Element Update City of Pacifica’s 6th Cycle (2023-2031) Draft Housing Element Page 12 August 8, 2023
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.
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Packet Pg. 1259 Attachment: Attachment C - HCD Comment Letter on First Draft Housing Element (with numbering) (5559 : 2023-2031 Housing Element Update RESOLUTION NO. 2024-001
A RESOLUTION OF THE PLANNING COMMISSION OF THE CITY OF PACIFICA
RECOMMENDING THAT THE CITY COUNCIL OF THE CITY OF PACIFICA ADOPT
AN INITIAL STUDY/NEGATIVE DECLARATION, AND THE HOUSING ELEMENT UPDATE OF THE GENERAL PLAN FOR THE 6TH CYCLE 2023-2031 AS PROVIDED IN STATE LAW.
_______________________________________________________________ WHEREAS, State Housing Element Law (Government Code Sections 655580 et seq.) requires that the City Council adopt a Housing Element for the eight-year period 2023-2031 to accommodate the City of Pacifica’s (City) regional housing need allocation (RHNA) of 1,892 units, comprised of 269 extremely-low income units, 269 very-low income units, 310 lowincome units, 291 moderate-income units, and 753 above moderate-income units; and WHEREAS, to comply with State Housing Element Law, the City has prepared a Housing Element Update (HEU) for the period 2023-2031 in compliance with State Housing Element Law, with input from the public, and has identified sites that can accommodate housing units meeting the City’s RHNA; and
WHEREAS, the City released the first public review draft of the Housing Element Update for the period 2023-0231 for public review on February 24, 2023 and held a Joint Study Session with the City Council/Planning Commission on March 21, 2023; and WHEREAS, the City submitted the first draft to the State of California Department of Housing and Community Development (“HCD”) on May 10, 2023 and received comments from HCD on August 8, 2023; and
WHEREAS, the City held a Joint Study Session with City Council/Planning Commission on September 25, 2023 and October 16, 2023 to review HCD’s comments on the first draft of the Housing Element; and
WHEREAS, the City released a second public review draft of the Housing Element for public review on December 8, 2023; and
WHEREAS, in order to allow for flexibility in future housing development, to create additional opportunities to address the housing crisis, and to increase opportunities for affordable housing to be constructed at the benefit of lower-income households, the Housing Element update sets a target of 36 percent over the required RHNA, or approximately 2,574 total housing units, comprised of 1,271 very-low and low-income units, 437 moderate-income units, and 866 above-moderate income units; and
WHEREAS, City of Pacifica is the Lead Agency for preparing the environmental review for the Project pursuant to the California Environmental Quality Act (CEQA); and WHEREAS, the City of Pacifica Planning Division issued a Notice of Intent to adopt a Negative Declaration on November 16, 2023, for the Housing Element Update for the period of 2023-2031, which was distributed in compliance with CEQA Guidelines Section 15072; and WHEREAS, on November 16, 2023, the City of Pacifica distributed copies of the Negative Declaration to public agencies which have jurisdiction by law with respect to the
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Packet Pg. 1260 Attachment: Attachment D - Planning Commission Resolution No. 2024-001 (5559 : 2023-2031 Housing Element Update Adoption) Housing Element Update 2023-2031
January 4, 2024