February 14, 2024
Paul McDougall, Senior Program Manager
State Department of Housing and Community Development
C/O Land Use and Planning Unit
651 Bannon Street, Suite 400
Sacramento, CA 95811
RE: Submission ofthe City of Pacifica’s Revised 6th Cycle Draft Housing Element for HCD Review Dear Paul McDougall,
I am pleased to transmit the City of Pacifica’s Revised 6th Cycle Draft Housing Element of the General Plan for your review.
The City posted the revised draft Housing Element on its website on February 6, 2025, and emailed a link to all individuals and organizations that previously requested notices relating to Housing Element adoption and has met the seven-day public review requirement. To aid your review, I have attached a consolidated version of the revised draft Housing Element (Attachment 1) and a redline comparison version showing changes since the City’s January 2024 Housing Element (Attachment 2). Also included are Attachments to the Pacifica Housing Element including public comments (Attachment 3).
As you may already recognize, preparation of the Housing Element has been a major undertaking for the City of Pacifica. However, the City has embraced the challenge and boldly established capacity for housing development far in excess of its RHNA obligations, creating more than 2,000 units of new housing capacity.
The revised draft Housing Element incorporated significant revisions required to address comments in the Department of Housing& Community Development’s (HCD’s) comment letter dated March 29, 2024, and Affirmatively Furthering Fair Housing (AFFH) comment matrix dated October 15, 2024, in addition to revisions in response to HCD’s August 8, 2023, comment letter. The City appreciatesthe thoughtful commentsfrom HCD staff which have resulted in an improved Housing Element. We also appreciate the dialogue with HCD staff preceding and following the comment letters. A detailed description of how the draft Housing Element was revised to comply with State Law and addresses HCD’s comments is attached (Attachment 4). Additional tables accompanying the submittal are included (Attachment 5).
Key revisions following the January, 2024 adopted Housing Element:
CITY OF PACIFICA
Community Development Department
170 Santa Maria Ave • Pacifica, California 94044-2506
(650) 738-7341 • www.cityofpacifica.org
MAYOR
Sue Beckmeyer
MAYOR PRO TEM
Christine Boles
COUNCIL
Mary Bier
Mayra Espinosa
Greg Wright
Scenic Pacifica
Incorporated Nov.
22, 1957
• Added analysis supporting the selection of opportunity sites • Added program implementation actions to further affirmatively further fair housing • Expanded program actions to encourage the development of housing on publicly owned sites The City has increasingly invested in Housing Element implementation and a package of policies to implement the rezoning program and associated environmental review are well underway.
I look forward to your review and this major step towards HCD certification. Please contact me at any time should questions arise during your review. You can reach me by email [email protected] or by phone at (650) 446-4698.
Thank you,
Samantha Updegrave
Community Development Director
Mailing Address: 170 Santa Maria Avenue, Pacifica, CA 94044 Office Address: 1800 Francisco Boulevard, Pacifica, CA 94044 Planning: (650) 738-7341 / Direct: (650) 446-4698
[email protected]
cc: City Manager
City Attorney
Melinda Coy, Proactive Housing Accountability Chief
Attachments (All documents available on HCD Connect and via hard copy)
1. Revised City of Pacifica Draft Housing Element (dated February 6, 2025)
2. Redline comparison of Pacifica’s Adopted Housing Element (January 2024) and Revised City of Pacifica Draft Housing Element (dated February 6, 2025)
3. Attachments to the Revised City of Pacifica Draft Housing Element (dated February 6, 2025)
4. HCD Comments and City of Pacifica Responses: March 2024 – February 2025 (dated February 14, 2025)
5. HCD Sites Inventory, Tables A through C
1 CITY OF PACIFICA
Community Development Department
170 Santa Maria Ave • Pacifica, California 94044-2506
(650) 738-7341 • www.cityofpacifica.org
MAYOR
Sue Beckmeyer
MAYOR PRO TEM
Mary Bier
COUNCIL
Christine Boles
Mayra Espinosa
Greg Wright
Scenic Pacifica
Incorporated Nov. 22, 1957
City of Pacifica Housing Element
HCD Comments and City of Pacifica Responses: March 2024 – February 2025 February 14, 2025
Notes:
1. An Affirmatively Furthering Fair Housing (AFFH) Review Matrix was provided to the City on October 15, 2024. The matrix, and city responses, are included as Attachment A to this document.
2. Additional guidance was provided by HCD for many of the below topics.
HCD Comment Letter – March 29, 2024
Note: Additional guidance provided by HCD for many of the below topics.
City Response – February 14, 2025
A.1.1
A. Housing Needs, Resources, and Constraints
1. 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 toward the Regional Housing Need Allocation (RHNA): The element identified 227 units including 52 units for lower-income households as credit towards the RHNA. HCD’s prior review found that the element must analyze and demonstrate the availability of these units during the planning period. The element was revised to indicate that 107 units are pending but likely to be built during the planning period.
However, the element needs to provide support for the assertion that pending units will likely be built during the planning period. As found in HCD’s prior review, 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 Expanded the analysis of completion rates for pipeline projects, namely projects that have been approved or in the final stages of land use approvals (see Appendix F, p. F4-F8), indicated units in the pipeline by affordability level and by which step the project is in the permitting or construction process, and added a pipeline monitoring and outreach program to HE-I-1.
Added a mid-cycle review of progress toward achieving RHNA and added metrics to program HE-I-1 to be completed by 2027, and added back-up actions, including rezoning of additional sites to be completed by June 2028, if production metrics are not met.
(Response to HCD comment A1.1. and further guidance provided by HCD.) City of Pacifica Housing Element
HCD Comments and City of Pacifica Responses: March 2024 – February 2025 February 14, 2025
2 expiration dates on entitlements, anticipated timelines for final approvals, and any remaining steps for projects to receive final entitlements. Lastly, the element should also add or modify programs committing to monitoring, facilitating and encouraging the development of these units.
A.1.2
Realistic Capacity (Sites in Zones that Allow 100 Percent Nonresidential Uses): The element was revised to state that the City will require a certain percentage of residential and will not allow 100 percent nonresidential projects (p. F-47). However, the element did not include any corresponding programs to implement this action. As found in HCD's prior review, 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.
Added a requirement in Program HE-I-1.13 to amend the Zoning Code to clarify that all sites on the inventory will include a required minimum residential component in accordance with state law.
(Response to HCD Comment A.1.2.)
A.1.3
Suitability of Nonvacant Sites: The element was revised to indicate various criteria utilized when identifying the redevelopment potential on nonvacant sites. In addition, the element includes a listing of local and regional projects that share similar characteristics. However, while the element indicates which factors apply to different sites, as found in HCD’s prior review, the element must quantify these factors for each site (e.g., building age, LIR, etc.,). Based on a complete analysis, the element may need to add or revise programs to encourage redevelopment.
In addition, 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.
Provided additional site-level quantitative data points (i.e., age of structure, lot coverage, size of site above 1 acre, and the Improvement to Land Value) to demonstrate that it is realistic to expect these sites to be redeveloped within the planning period. (See Appendix F narrative (F-23) and tables F2, F11, and F12.). Updated and expanded Appendix A to include discussion of recent public comments. See pages A-13, A16-A19 for expanded discussion of comments. As discussed in additional analysis included on p. F-23, the data show it is realistic to expect these sites to be redeveloped within the planning period.
Note:
1. Provided the above referenced analysis for sites that are also being rezoned to increase residential capacity.
2. Previous reductions to the developable area for sites with physical constraints were already included in prior drafts indicated on Table F-11 in the column titled “Partial Site for Residential Balance for Existing Use” for sites with physical constraints.
City of Pacifica Housing Element
HCD Comments and City of Pacifica Responses: March 2024 – February 2025 February 14, 2025
3 Revised the element to add additional data points to Tables F-11 and F-12 and include additional explanation regarding sites 27A and 27B. Revised Appendix F to clarify that site G has no structure on site. Restored Figure 10 which had previously been inadvertently deleted from the prior draft. (Response to HCD Comment A.1.3. and B.1.1 and further guidance provided by HCD)
A.1.4
Availability of Infrastructure: HCD's prior review found that the element must include additional discussion regarding the adequacy of sewer and water capacity (existing or planned) during the planning period to accommodate the RHNA. The element was revised to indicate that certain water pump stations will need to be improved to accommodate the City's capacity and the City's Capital improvement plan includes a commitment to implement these changes. First, the element still should indicate accessibility of infrastructure to identified sites and whether there is sufficient water and sewer capacity (planned or existing) to accommodate the entire RHNA.
Second, the element must include a program committing to actions such as the water pump improvements and a timeline to make sufficient infrastructure available to accommodate the RHNA.
Added additional analysis of the capacity of the Rockaway Beach Pump Station (see Appendix G: Housing Constraints p. 37--38, and p. 32 of the Housing Element) to indicate the capacity within the catchment area after completion of scheduled rehabilitation and replacement Capital Improvement Projects (CIP) is estimated to be sufficient for at least 200 additional units, presenting no constraint to the units included in the sites inventory within the catchment area, and added a backup action to program HE-I-13 for the City to rezone any necessary sites within one year if the CIP projects are not initiated by July 2026 (Vallemar) and July 2027 (Rockaway Beach).
(Response to HCD Comment A.1.4. and further guidance provided by HCD.)
Zoning for a Variety of Housing Types:
A.1.5.1
Emergency Shelters – Emergency Shelters parking requirements should be updated pursuant to AB 139 (Chapter 335, Statutes of 2019) which requires only 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. The element should demonstrate compliance with this requirement and include or modify programs as appropriate.
Revised program HE-I-10 to commit to update section 9-4.2818 of the Pacifica Municipal Code to modify the parking standard for emergency shelters to be consistent with AB 139 by requiring one space per staff member.
(Response to HCD comment A.1.5.1.)
A.1.5.2
Transitional and Supportive Housing –While the element includes Program HE 1- 14 (State and Federal Law Conformance), this Expanded the required zoning updates in program HE-I-14 to include a requirement that transitional housing and supportive housing shall be considered a residential use and subject only to those restrictions that City of Pacifica Housing Element
HCD Comments and City of Pacifica Responses: March 2024 – February 2025 February 14, 2025
4 Program only commits to complying with Government Code section 65651 which is intended for a specific type of supportive housing.
The element must also add or modify programs to permit
transitional and supportive housing 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.
apply to other residential dwellings and that supportive housing will be a use by right in all zones where multifamily and mixed uses are permitted. (Response to HCD comment A.1.5.2.)
A.1.5.3
Single-Room Occupancy (SRO) Units: HCD's prior review found that the City defines SROs as boardinghouses and must include a complete analysis to evaluate any constraints on this housing type.
The element was revised with Program HE-1-14 (State and Federal Law Conformance) indicating that the City will "consider" explicitly defining and permitting SROs. However, as found in HCD's prior review, SROs provide a valuable source of affordable housing especially for persons experiencing homelessness and extremely low-income households. As such, the element should go beyond "consider" and include a specific commitment to defining, permitting and facilitating the development of SROs.
Added a commitment to explicitly define SROs in the code to Program HEI-14 to codify the current practice that SRO applications are treated as an allowed use.
(Response to HCD comment A.1.5.3.)
A.2
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).)
Constraints on Housing for Persons with Disabilities (Reasonable Accommodation): HCD's prior review found that the City must analyze all decision-making criteria including approval findings for potential constraints on housing persons with disabilities. The revised element noted several Added a commitment to Program HE-I-12 to revise Article 51 to remove or significantly change potentially subjective finding 3 regarding reasonable accommodation for persons with disabilities and architectural compatibility, revise finding 4 to objectively define undue financial or administrative burden, and revise finding 7 to more objectively define how a nonconformity due to a reasonable accommodation request will be treated. (Response to HCD comment A.2 and to further guidance provided by HCD.) City of Pacifica Housing Element
HCD Comments and City of Pacifica Responses: March 2024 – February 2025 February 14, 2025
5 subjective approval findings including whether the request would have adverse impacts on coastal resources, architectural compatibility or adverse effect on people working or residing in that area. The element further indicated that it is not common for reasonable accommodation requests to be denied due to these findings and therefore it is not considered a constraint. However, several of these findings are subjective and similar to a conditional use permit finding. Reasonable accommodation should be a unique exception process from a conditional use permit, especially given its importance in addressing barriers to housing for persons with disabilities.
The element should include a program to amend the reasonable accommodation ordinance and remove constraints, namely subjective approval findings.
A.3
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).).
HCDs prior review found the element should evaluate the risk of conversion and analyze the cost for replacing versus preserving the units. The element was revised to include some general statements regarding conversion risk.
However, as found in HCD’s prior review, the element must estimate and analyze the cost for replacing versus preserving the units. For more information on the analysis, please visit: https://www.hcd.ca.gov/planningand-community-development/housing- elements/building-blocks/assistedhousing-developments-risk-conversion.
Added analysis to Appendix C-Housing Needs regarding the cost for replacing versus preserving units and provided quantified estimates regarding the tradeoffs associated with replacement vs preserving at risk units that show preservation to be more cost effective. (Response to HCD comment A.3.)
B.1.1
B. 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 Added additional sites analysis. See response to comment A.1.3. (Response to HCD comment. B.1.1.)
City of Pacifica Housing Element
HCD Comments and City of Pacifica Responses: March 2024 – February 2025 February 14, 2025
6 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, factorybuilt housing, mobilehomes, housing for agricultural employees, supportive housing, single-room occupancy units, emergency shelters, and transitional housing. (Gov. Code, § 65583, subd. (c)(1).)
As noted in Finding A1, 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.
B.1.2
Program HE – 1-1 (General Plan and Zoning Amendments) – The element shows a shortfall of 1,356 units including 660 units for lower-income households to accommodate the RHNA. While the element included programs committing to rezoning, these programs must specifically commit to all of the rezone requirements 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 lowerincome 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.
Revised program HE-I-1.8 to require rezoning of certain sites to allow approval of residential developments “by-right” and establish 16 units minimum and 20 units/acre minimum, consistent with Government Code sections 65583(c)(1) and 65583.2 (c), (h) and (i). See also program text of HE-I-1.12.
(Response to HCD comment B.1.2. and to further guidance provided by HCD.)
B.1.3
Program HE – 1-4 (Accessory Dwelling Units (ADUs)): While the element was revised to include a commitment to monitoring ADU development and implementing alternative actions, the element must include a timeline for when the City will implement any required alternative actions.
Program HE-I-4 was significantly expanded with commitments to several Housing Mobility actions and the addition of a specific completion date of December 2028 for backup action 1 (rezoning additional sites if specified targets are not met). See also response to HCD comment B.3. and Affirmatively Furthering Fair Housing (AFFH) comment 1-4 below.
City of Pacifica Housing Element
HCD Comments and City of Pacifica Responses: March 2024 – February 2025 February 14, 2025
7 (Response to HCD comment B.1.3. and further guidance
provided by HCD)
B.1.4
Program HE – 1-2 (Zoning Modernization and Streamlining): The element is assuming that several parcels will be consolidated into larger sites to accommodate the lower-income RHNA. This assumption is based on ownership patterns and adjacency of parcels. This program indicates that the City will consider lot merger incentives. However, the element must also include a program with a specific commitment to establishing incentives and other actions to facilitate consolidation and development on small sites.
Revised program HE-I-2 to include a commitment to establish a site consolidation incentive to facilitate consolidation and development on small sites. Added an ombuds/liaison program to provide technical assistance to shopping center owners to facilitate the production of more housing and added a metric to conduct outreach to at least 50% of owners of at least two shopping centers.
(Response to HCD comment B.1.4 and further guidance provided by HCD.) B.1.5
Publicly Identified Sites: The element included Program 1-1 (General Plan and Zoning Amendments) and 1-3 (Public Land Planning) to address development on publicly identified sites. However, as found in HCD’s prior review, this Program must be revised with additional actions, firm commitments, discrete timelines, and quantifiable metrics. Additional actions to facilitate development should include frequent outreach with developers, any necessary rezoning, incentives such as financial assistance, issuing requests for proposals, facilitating any subsequent entitlements, and numerical objectives by affordability
Revised program HE-I-3 to include additional actions including outreach, test fits, creation of a development toolkit to support the reduction of barriers to undertaking development for public sites and hiring a consultant to bring forward recommendations to the Council. Added specific numerical targets and affordability levels regarding each of the publicly identified sites. Revised Program HE-I-1.6 to include specific timelines, commitments, and quantifiable metrics.
(Response to HCD comment B.1.5. and further guidance provided by HCD.) B.2
2. 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).)
See responses to HCD comments A.2. and A.3. above. Added further related analysis to Appendices A, F, and G.
(Response to HCD comment B.2. and further guidance provided by HCD.) City of Pacifica Housing Element
HCD Comments and City of Pacifica Responses: March 2024 – February 2025 February 14, 2025
8 As noted in Findings A2 and A3, 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.
B.3
3. 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).)
The element was revised with some changes to affirmatively furthering fair housing (AFFH) programs including further clarification on how these actions relate to addressing fair housing issues. However, as found in HCD’s prior review, actions should generally 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, given the City’s patterns of being largely affluent and highest resource, the element must include significant and robust actions (not limited to the RHNA) to promote housing mobility and increasing housing choices and affordability throughout the City, including lower-density neighborhoods. Actions should be added and revised with significant and meaningful numeric targets and geographic targets throughout the City, including lower-density neighborhoods.
Examples include creating more housing choices and affordability in singlefamily neighborhoods beyond complying with law (e.g., SB 9, ADUs) such as missing middle housing types, targeting affordable housing funding, homesharing, more than one unit of converted space within a single-family structure, increased multifamily capacity, enhanced efforts on religious institutional sites and other alternative land use and financing strategies.
Revised program HE-I-4 to further promote housing mobility, housing choice and affordability in high-opportunity areas, place-based strategies, and targeted outreach programs. Revised Program HE-I-4 to include specific commitments to:
• Home Sharing: Participate in a home sharing program, such as HIP Housing’s Home Sharing Program, to improve housing
opportunities for lower-income seniors and extremely low-income residents.
• Objective Development Standards (ODS): Develop ODS to facilitate missing middle housing in certain low density residential zones and improve housing mobility in a variety of neighborhoods including RCAAs.
• Bike/Ped Prioritization: Prioritize the safety and accessibility mobility improvements included in the Bike/Ped Master Plan in the northern areas of the city as part of a place-based initiative to better serve residents who have lower mobility options and economic opportunity.
• Conduct proactive outreach with higher education and religious institutions to develop deed-restricted affordable housing, including a provision to waive associated fees.
• Geographic Information Systems (GIS) tool: Establish a publicly accessible land use and GIS tool intended to facilitate the production of ADUs and missing middle housing,
• Mid-Cycle Review: Added a mid-cycle review of progress toward achieving RHNA and added metrics to programs HE-I-4 to be completed by 2027, and added back-up actions, including rezoning of additional sites, if production metrics are not met. • Geographic Targeting of Housing Supports: Establish specific geographic targets and metrics within the highest-resource City of Pacifica Housing Element
HCD Comments and City of Pacifica Responses: March 2024 – February 2025 February 14, 2025
9 (See also: ATTACHMENT A: AFFH REVIEW COMMENTS (Provided 10/15/2024) AND RESPONSES) neighborhoods in R1 and other predominantly single-family residential districts southwest of Fassler Ave.
See also Attachment 1: AFFH review comments provided 10/15/2024 and responses (below).
(Response to HCD comment. B.3. and further guidance provided by HCD.) City of Pacifica Housing Element
HCD Comments and City of Pacifica Responses: March 2024 – February 2025 February 14, 2025
10 ATTACHMENT A: AFFH REVIEW COMMENTS (Provided 10/15/2024) AND RESPONSES PB- Paced based strategies; SC- specific commitment; HM- housing mobility; NO- New opportunity; D- displacement; GT- geographic targeting; T-timing; M- metrics; Y- yes; N-No; ~- maybe
# Description Type SC T GT M HCD Notes City Response – February 14, 2025 1 -
1 General Plan
and Zoning
Amendment
s to Achieve
RHNA (R)
HM Y Y Y Y Revised program language to require that several components of program HE-I-1 be completed to achieve housing mobility goals, in addition to achieving RHNA. Revised program language to make it more explicit that programs apply citywide except as noted. Added specific deadline to a backup action.
(Response to HCD comment AFFH-1-1 and further guidance provided by HCD.)
1 -
2 Zoning
Modernizati
on and
Streamlining
NO Y Y Y ~ Add geographic
targeting and a
metric
Large Units: Established a metric for the large unit parking incentive in program HE-I-2 that the incentive should assist at least 25 units and additional metrics for actions 12 and 13. Revised program language to make it more explicit that programs apply citywide except as noted. (Response to HCD comment AFFH-1-2 and further guidance provided by HCD.)
1 -
3 Master
Planning
and
Implementat
ion for
Public Sites
NO Y Y ~ Y A specific deadline was added to a backup action. (Response to HCD comment AFFH-1-3 and further guidance provided by HCD.)
1 -
4 Support for
Developmen
t of
Accessory
Dwelling
Units and
HM,
NO
Y Y N ~ Increase metric,
increase housing
mobility actions, add
RI action
Revised HE-I-4 program language to include:
1. Religious and Educational Institutions: Adopt an ordinance to expand the feasibility of deed-restricted housing development on nonprofit higher education and religious institution sites and set specific City of Pacifica Housing Element
HCD Comments and City of Pacifica Responses: March 2024 – February 2025 February 14, 2025
11 # Description Type SC T GT M HCD Notes City Response – February 14, 2025 Housing
Mobility
targets for expansion of deed-restricted affordable housing at nonprofit educational and religious institutions.
2. Manufactured Home Parks: Offer and provide technical assistance to manufactured home park owners or resident associations regarding the Manufactured Housing Opportunity & Revitalization Program (MORE). The MORE program helps fund a variety of activities intended to keep mobile home parks a safe and affordable housing option.
3. ADU Tracking and Outreach: Track use and rental rates. Targeted outreach, and increased metric for processing of ADU applications were also increased from 15 to 25 planning applications per year.
4. Targeting: Establishing specific geographic targets within the highestresource neighborhoods in R1 and other predominantly single-family residential districts southwest of Fassler Ave applicable to ADU programs, home-share programs, ODS development, and supports for housing development on religious and educational institution land.
5. Requiring program commitments HE-I-1.1, 1.2, 1.4, 1.6, 1.10-a, 1.10-b, 1-13, and 1-14 be completed as housing mobility actions in addition to achieving broader RHNA goals.
Metrics: Increased from 15 to 25 ADU applications processed per year and from 15 to 20 units being affordable during the planning period. An overall metric for Housing mobility units was already established at 100 units, but specific geographic targeting metrics were added.
Backup actions: Revised backup actions to include additional outreach to nonprofit higher education and religious institutions and affordable housing developers to determine policies that would better encourage these projects and address government constraints, including expanding the incentives to be available to mixed-income projects. Backup actions have also been revised to City of Pacifica Housing Element
HCD Comments and City of Pacifica Responses: March 2024 – February 2025 February 14, 2025
12 # Description Type SC T GT M HCD Notes City Response – February 14, 2025 include a target to complete implementation of backup actions and increase the current limits of ADUs on parcels in R1 and other majority single family residential districts.
(Response to HCD comment AFFH-1-4 and further guidance provided by HCD.)
1 -
5 Fund a
Housing
Action Fund
NO Y Y N N Add geographic
targeting (e.g.,
throughout the City)
and a metric
Grant Applications: Added a requirement to HE-I-5 that funding applications are required beginning in 2025.
Revised program language to make it more explicit that programs apply citywide except as noted.
(Response to HCD comment AFFH-1-5 and further guidance provided by HCD.)
1 -
6 Strengthen
Inclusionary
Housing
Program
NO Y Y ~ N Add metric and add
action to evaluate
changes as potential
constraints and make
adjustments as
appropriate
Inclusionary Housing: Added a commitment to HE-I-6 to evaluate the changes to the inclusionary housing program as potential constraints to development and a metric regarding a report on this evaluation. Revised program language to make it more explicit that programs apply citywide except as noted. (Response to HCD comment AFFH-1-6 and further guidance provided by HCD.)
1 -
7 Preserve
Existing
Affordable
Housing
Units
D Y Y Y Y N/A
1 -
8 Rehabilitatio
n of Homes
in Lower
Resource
and Coastal
Areas
D ~ Y Y N Revised HE-I-8 to require completion of Program: HE-I-4.7 (support for manufactured home park owners and/or resident groups regarding the MORE program). See also Program HE-I-4 for associated metrics. (Response to HCD comment AFFH-1-8 and further guidance provided by HCD.)
City of Pacifica Housing Element
HCD Comments and City of Pacifica Responses: March 2024 – February 2025 February 14, 2025
13 # Description Type SC T GT M HCD Notes City Response – February 14, 2025 1 -
9 Housing for
Extremely
Low-Income,
Special, and
Disproportio
nate Needs
HM,
NO
Y Y Y N Add geographic
targeting and metric
Housing for Extremely Low-Income, Special, and Disproportionate Needs:
Added to HE-I-9 the prioritization of incentives to support development of extremely low-income housing not only within the RCAA but also within R1 and other majority single family residential districts south of Fassler Ave. and adjacent areas to increase access to opportunity for extremely low-income residents in higher resource areas.
Geographic Targeting of Housing Supports: Established specific geographic targets and metrics within the highest-resource neighborhoods in R1 and other predominantly single-family residential districts southwest of Fassler Ave.
(Response to HCD comment AFFH-1-9 and further guidance provided by HCD.)
1 -
1 0
Strengthen
Services for
Homelessne
ss
D Y Y Y Y N/A
1 -
1 1
Support Fair
Housing
Enforcement
and
Outreach
Capacity
HM N N NA N Substantial Renovation Evictions: Require the adoption of an ordinance consistent with Government Code Section 1946.2(b)(2)(D)(iv)(III) that requires a building permit be issued, if otherwise required under state and local law, as a prerequisite to serving a substantial renovation eviction notice by June 2025. Revised program language to make it more explicit that programs apply citywide except as noted. Added additional timing targets. See also revisions to program HE-I-4, including housing mobility and outreach commitments. (Response to HCD comment AFFH-1-11 and further guidance provided by HCD.)
1 -
1 2
Fair Housing
Affirmative
Marketing
Strategy
HM ~ Y ~ N Fair Housing Affirmative Marketing Strategy: Require completion of associated fair housing marketing actions included within program HE-I-4 as a requirement of the part of program HE-I-12 (Fair Housing Affirmative Marketing Strategy).
City of Pacifica Housing Element
HCD Comments and City of Pacifica Responses: March 2024 – February 2025 February 14, 2025
14 # Description Type SC T GT M HCD Notes City Response – February 14, 2025 Per conversation with HCD on 10/24/24, further revisions are not required to program 12.
(Response to HCD comment AFFH-1-12 and further guidance provided by HCD.)
1 -
1 3
Infrastructur
e Capacity
Improvemen
ts
PB Y Y Y ~ Revised metrics to reflect the individual deadlines of July 2026 (Vallemar) and July 2027 (Rockaway Beach)
(Response to HCD comment AFFH-1-13 and further guidance provided by HCD.)
1 -
1 4
State and
Federal Law
Conformanc
e
NO Y N NA N
A
Revised program language to include additional specific completion targets. (Response to HCD comment AFFH-1-14 and further guidance provided by HCD.)
END