City Council
Staff Report
From: City Manager
Report Type: CONSENT CALENDAR
Lead Department: Planning and Development Services
Meeting Date: August 5, 2024
Report #:2407-3239
TITLE
PUBLIC HEARING/QUASI-JUDICIAL. Buena Vista Mobile Home Park Redevelopment/3980 El Camino Real [24PLN-00041; 24PLN-00129] Approval of a Vesting Tentative Map to Subdivide One Existing 4.5-acre Parcel into Two Parcels and to Approve a Streamlined Housing Development Review Application for a 61-unit Apartment Building. The Project Also Includes 44 Mobile Homes, which are Regulated by the State, and Authorization for the City Manager to Execute Amended Regulatory Agreements. Environmental Assessment: Exempt from the Provisions of the California Environmental Quality Act in Accordance with CEQA Guidelines Section 15332 (In-fill Development). Zoning District: RM-20.
RECOMMENDATION
Staff recommends that Council take all of the following actions:
1. Consider the project exempt from CEQA in accordance with CEQA Guidelines Section 15332 (Infill development);
2. Approve the Streamlined Housing Development Review application to develop a 61- unit apartment building pursuant to the findings and subject to conditions of approval set forth in Attachment B;
3. Approve the associated Vesting Tentative Map application pursuant to findings and subject to conditions of approval set forth in Attachment B; and
4. Authorize the City Manager to execute the amended regulatory agreements and related documents in Attachment D.
EXECUTIVE SUMMARY
On February 15, 2024, the Santa Clara County Housing Authority (SCCHA) submitted a formal application for Streamlined Housing Development review. The proposed project includes an affordable 61-unit apartment development on a portion of the subject parcel located at 3980 El Camino Real (see Attachment A, Location Map). On April 30, 2024, SCCHA submitted a separate, associated, Vesting Tentative Map application to subdivide the existing lot into two parcels. The apartment building would be developed on one of the resulting parcels, while the second lot would be rehabilitated with 44 mobiles homes. Rehabilitation of the mobile homes
parcel is processed through the State Department of Housing and Community Development (HCD).
The project is a housing development project in accordance with the Housing Accountability Act and qualifies for a Density Bonus and associated concessions, waivers, and allowances under state law (California Government Code §65915) and PAMC Chapter 18.15. To align with the proposed redevelopment, the project also includes modifications to an existing 2017 regulatory agreement between the City, County, and County Housing Authority (see Attachment D, Existing 2017 Regulatory Agreement).1 The project plans are included in Attachment G and the proposed Regulatory Agreements as well as the Termination Agreement for the existing Regulatory Agreement are included in Attachment C.
On June 18, 2024, Council reviewed the proposed Streamlined Housing Development review application and proposed amendments to the regulatory agreement.2 Council provided feedback on these actions. This report summarizes modifications that were made in response to that direction. Additionally, this report includes information on the Vesting Tentative Map application, which has been incorporated into the proposed actions and which was not discussed in the previous Council report. It also includes a link to the documentation supporting a Class 32 (infill development) exemption in accordance with the California Environmental Quality Act (CEQA), which was not yet available prior to the last hearing. On July 10, 2024 the Planning and Transportation Commission unanimously recommended approval of the Vesting Tentative Map application.
SCCHA must submit an application for tax credit funding in August, following Council approval.
This funding is critical for the project. In order to be competitive for this funding, which is critical to the project financing, completion of the entitlements is needed prior to the tax credit application submittal. Upon review of this report, if the Council wishes to further discuss the report and to remove this item from the Consent Calendar, it will be scheduled for action on August 12, 2024 in order to keep to the funding application deadline.
BACKGROUND
Additional background information on the project is provided in the June 18, 2024 Council report. On June 18, Council directed staff to return to Council in August 2024, following the 1 City Attorney Report to City Council September 11, 2017, https://www.cityofpaloalto.org/files/assets/public/v/1/agendas-minutes-reports/reports/city-manager- reportscmrs/year-archive/2017/staff-report-8493-buena-vista-mou-amendment.pdf 2 June 18, 2024 City Council Meeting Staff Report
https://cityofpaloalto.primegov.com/meetings/ItemWithTemplateType?id=4918&meetingTemplateType=2&comp iledMeetingDocumentId=10522
completion of the environmental analysis, for a decision on the proposed Buena Vista redevelopment project, and consideration of the following:
1. Whether any trees can be preserved on Los Robles Avenue;
2. Whether a surface treatment on the pavement can reduce heat island concerns;
3. Whether larger trees or additional trees can be planted in the Mobile Home Park;
4. Whether color choices may be returned to the resident preference;
5. Pursue a Palo Alto worker resident preference; and
6. That all reasonable efforts to resolve disputes should be made to resolve disputes standing in the way of housing decisions.
The analysis section of this report summarizes SCCHA’s response and modifications to the plans in accordance with Council’s direction.
Planning and Transportation Commission Recommendation
The Vesting Tentative Map application associated with the proposed redevelopment requires a recommendation from the Planning and Transportation Commission (PTC) and Council approval. The PTC reviewed the Vesting Tentative Map on July 10, 2024, and unanimously recommended approval of the map based on findings and subject to conditions of approval set forth in the Record of Land Use Action.
Project Description
SSCHA submitted a formal application for Streamlined Housing Development review for a 61- unit apartment development on a portion of the existing Buena Vista Mobile home site (Application 24PLN-00041). The proposed apartments are located within a single, four-story (37 feet), 63,736 square feet building (0.89:1 Floor area ratio). Seventy-nine (79) parking stalls and one car loading space would be provided in accordance with code requirements. Attachment A includes a location map showing the zoning designation of the site and surrounding areas. A location map is included in Attachment A. The project description and justification of requested concessions and waivers is included in Attachment F and Attachment G shows the project plans for this development.
On April 30, 2024, SCCHA submitted the application for a Vesting Tentative Map (Map) to subdivide the existing parcel into two parcels (24PLN-00129). Under the existing Regulatory Agreement, the property must maintain, at minimum, 100 affordable units. However, the existing spacing of mobile homes does not meet current state rules regarding spacing and setbacks. The introduction of an apartment building allows the property to both maintain the minimum number of affordable units, while allowing enough space to retain 44 mobile homes.
The Map subdivides the existing parcel to better finance the 61 apartments and 44 mobile homes separately. The total development, between the apartment building and mobile home units, would be 105 units; 40% of units will be provided at a rate affordable to households earning 30% of Area Median Income (AMI), 40% of the units would be provided at a rate affordable to households earning 50% AMI and the remaining 20% would be provided at a rate affordable to households earning 80% AMI.3,4
Revisions to the existing regulatory agreement are necessary in conjunction with the redevelopment to reflect the two individual parcels and their respective ownership entities as well as to reflect the necessary affordability requirements for their respective funding sources.
ANALYSIS
Staff from all relevant departments reviewed the Streamlined Housing Development review application for consistency with the municipal code and all other relevant state and federal regulations. The project plans in Attachment G have been reviewed and recommended for approval by all relevant City departments; draft conditions of approval have been incorporated into the draft Record of Land Use Action (Attachment B). Overall, staff finds that the project conforms to plans, policies and guidelines relevant to the proposed project or otherwise requests concessions and waivers in accordance with state regulations.
An analysis of consistency with the Comprehensive Plan, zoning, state density bonus regulations for the proposed SHD application is included in the previous staff report to Council.
This report focuses on the SCCHA’s responses to Council’s direction from June 18, 2024 and provides additional information related to the subdivision map application, which was not summarized in the previous report. The documentation to support a categorical exemption is also complete and a link to this documentation has been provided in Attachment G.
Responses to Council Direction
SCCHA considered modifications to the plans and took actions in response to Council’s direction, as summarized herein. In some cases, SCCHA considered tradeoffs and presents a preferred option based on these tradeoffs. However, in its discretion, the Council may choose to explore these considerations further in a public hearing, which would be scheduled for August 12, 2024.
Tree Preservation Along Los Robles Avenue
An existing Valley Water easement runs along the project frontage on Los Robles Avenue and prohibits planting new trees within the easement. New tree plantings cannot be provided along this portion of the frontage without removing common open space area and/or mobile homes from the mobile home portion of the site. Council therefore asked the SCCHA to further 3 Income limits are based on annual published limits from HCD 4 To avoid displacement of existing tenants, three tenants that currently have an income level that exceeds 80% of AMI will be allowed to continue to rent at the site. Those units are considered as restricted low-income units because the tri-party regulatory agreement requires that future units will be made available to lower income households at affordable rents after any initial moderate or high-income households voluntarily vacate their units.
After any initial moderate or high income households vacate their units, those units will continue be restricted as low-income units with affordable rents for at least an additional 55 years or greater. evaluate whether any of the existing trees could be preserved in order to retain greenery along this frontage.
SCCHA identified the trees along this frontage for removal due to impacts associated with utility trenching and the proposed sidewalk. Although sidewalks are not typical in the Barron Park neighborhood, a sidewalk is provided along this frontage to align with the existing conditions on either side of the property and across the street along Los Robles Avenue. Additionally, the sidewalk provides an ADA accessible path to transit to accommodate residents with mobility issues. This is a current issue that was raised by residents at the park.
Through evaluation of the trees and the tradeoffs in response to the Council direction, the SCCHA determined that a total of five trees along the project frontage could be retained through revisions in the design; however, in evaluating the costs, likelihood of survival and other considerations raised by stakeholders, two of these five trees are now shown on the plan for retention.
Specifically, two on-site trees along the project frontage could be retained with revisions to the sidewalk design around the trees. Revisions to the design to accommodate these two trees would result in the loss of two parking spaces within the right-of-way and add approximately $12,500 in cost. Although the protection of these two trees results in a minor increase in cost for the project and the loss of two parking spaces, staff and the SCCHA determined that these revisions were reasonable and feasible to help address competing concerns to retain mature trees where feasible.
The other three trees are street trees. The three street trees (trees 22-24) are located on top of a City sewer line just outside the Valley Water easement and were identified as being in poor health. Revisions to the design to retain these trees would cost approximately $20,000 and would result in the loss of an additional five street parking spaces. Parking at Buena Vista has always been a resident priority and providing these new street parking spaces in addition to the on-site spaces was a way to ease concerns.
Given the current health of the street trees, the City’s arborist believes that the trees may not withstand the work within their tree protection zone even if the project is designed around them. Due to the utility lines running below the tree, which limits growth options and soil volume beneath the tree, it is unlikely that the health of these trees would improve over time.
Therefore, in weighing this understanding with increased project costs and loss of parking spaces the plans have not been revised to retain these three trees.
Increasing the Tree Canopy
The project plans have been updated with several modifications to the arborist report and landscaping plan. In reviewing the plans in more detail following the Council hearing, it was determined that several of the trees that were identified as being removed from the site were not actually planted at the site; rather they were in resident owned planter boxes and were identified for removal as they were being removed by the residents themselves during the relocation period. The arborist report was therefore revised to only reflect trees that are planted at- or surrounding the site. The total number of trees planned for removal at the site (or along the frontage) is 43. To meet the City’s requirements across the entire site, 122 total 24-inch box trees are required to be planted to replace the canopy of these 43 trees. The plans show that 130 total 24-inch box trees would be planted across the site (net increase of 87), exceeding the code requirements and the City‘s no net loss of canopy policy.
Council asked the SCCHA to consider whether additional trees could be planted on the mobile home portion of the site. In response to this request, the landscape architect and the SCCHA reviewed the plans again. Although in most cases trees had already been proposed wherever they could feasibly be planted, the plans have been revised to add one additional tree in the mobile home portion of the site. Two trees that were originally planned for removal will also now be preserved along the frontage, as noted above. The project plans in Attachment G now show a planting plan for the mobile home portion of the site.
The SCCHA also considered whether larger trees could be planted or revisions to the proposed species may result in better shading. The landscape architect indicated that the tree planting sizes and species that were proposed were selected based on their professional opinion on the tree size and species that would be best suited for the growing conditions of that space and therefore most likely to establish quickly and grow well. This took into account considerations such as soil volume as well as the proposed tree’s location with respect to adjacent utilities and planned structures.
In response to a comment raised during the last hearing, the SCCHA also explored adding a tree in the center of the ingress/egress aisle and having the vehicular aisles go around it. However, this option was not feasible because the aisles either serve as emergency vehicle access and cannot have trees in them or are too narrow to allow for two-way traffic and a tree planting area in the middle.
The SCCHA also indicated that they anticipate mobile home residents will plant on their new lots. Each individual mobile home lot includes pervious area intended for planting by residents.
Reducing Heat Island Effect
Council requested consideration of treatments to the surface pavement to reduce the heat island effect, which at least one member of the public noted to be a concern currently at the site. The SCCHA stated that pavement treatments would be prohibitively expensive, anticipating that it would add over $500,000 to the project cost.
However, the proposed site design reduces the amount of impervious area compared to existing conditions (186,732 sf of impervious surface currently is being reduced to 159,679 sf), which also reduces the heat island effect. Pervious areas (e.g., planting and biotreatment areas) and new trees are more evenly distributed across the site and improve the canopy over paved areas, which will reduce the heat island effect. Additionally, the new mobile home units and apartment complex will have cool roofs, as required in accordance with green building code requirements, which require the roofs of structures to meet the minimum solar reflectance and thermal emittance efficiencies or solar reflectance index requirements. These new green building code standards will be met for the proposed project, thus further reducing the heat island effect.
Plan Set Sheet A0.16 in Attachment G includes a graphic showing the proposed impervious areas reductions, improved tree canopy, and cool roof areas.
Reinstating Resident Color Preference
In response to Council direction, the SCCHA revised the apartment building color palette to be more consistent with the residents’ selected preference, as shown in the plan set in Attachment G.
Pursuing Palo Alto Preference
The SCCHA explored the Code of Federal Regulations, relevant case law, and relevant regulations to determine whether a Palo Alto live/work preference for Buena Vista is allowable.
It was determined that due to federal funding on the project, the Department of Housing and Urban Development would require a disparate impact study to be completed in order to determine whether this language could be added to the regulatory agreement. This study could not be fully completed prior to this hearing; therefore, the following tentative language has been added to the regulatory agreement. Prior to executing and recording the regulatory agreement, a disparate impact study would be prepared and, if allowable, this language would remain in Section 7.3 of the regulatory agreement:
Preference for Palo Alto Residents and Employees. In order to ensure that there is an adequate supply of affordable housing within the City of Palo Alto for residents and employees of businesses within the City, to the extent permitted by law and consistent with the program regulations for funding sources used for development of the Project, Owner shall give a preference in the rental of the residential units in the [Apartment Project] [Redeveloped Park] to Eligible Households that include at least one member who lives or works in the City of Palo Alto. Notwithstanding the foregoing, in the event of a conflict between this provision and rules and regulations applicable to the [Apartment Project] [Redeveloped Park], the provisions of such rules and regulations shall control, including, if applicable, any prohibition of preferences for units receiving Section 8 assistance. Owner shall comply with City’s affirmative marketing policies or other rental policies and procedures as they may be amended from time to time to ensure that City residents and people who work in the City of Palo Alto are provided reasonable notice and opportunity to rent units in the Project.
Making Reasonable Efforts Resolving Disputes Impeding Housing Decisions The SCCHA has engaged with residents to resolve disputes involving housing decisions in a number of ways, including:
•Reconsidering options and looking for ways to equitably meet residents’ preferences and requests;
•Providing updated appraised values to all owners as well as reviewing and considering appraisals that owners obtain from other appraisers;
•Investing in regular multichannel communication, consisting of five large townhall meetings with Spanish translation services), in-person individual meetings with each household where 3rd parties were welcomed (e.g., Law Foundation representative, local pastor, relatives), small workshops on specific topics (e.g., the below-market-rate program, appraisals, the relocation plan, and the annual inspection process), five Q&A documents, holding 16 different open office hours at Buena Vista, and having an ”open door” policy with many emails and phone calls with residents; and •Considering each of the main reasons households do not make a housing selection and meeting with the specific households as well as providing parkwide communication and/or responses in writing to the household on a specific topic.
The SCCHA shared with staff that since the June 18 City Council Study Session, the following progress has been made to provide clear information to Buena Vista residents:
•Final offers, along with updated appraisals have been prepared in both English and Spanish and will be sent out on July 26, 2024 and are expected to be delivered to households by July 29, 2024. Preparation of these packages included, among other efforts, a third-party review
•The SCCHA will begin scheduling one-on-one meetings as soon as residents receive these packages. By the August 5th Council meeting, the SCCHA’s relocation consultant has committed to meeting with as many households as they can to review their offers.
This includes targeted outreach to the 23 undecided households. •Additionally, SCCHA has contacted a third party and is waiting to confirm their ability to support residents of Buena Vista with communication related to disputes standing in the way of decisions.
SCCHA has noted that there are four main reasons some households have not made a housing selection. These include:
1. Wanting larger financial offers,
2. Wanting larger units/more bedrooms,
3. Wanting to split up a single household into multiple households occupying several dwelling units; and
4. Disagreement within the household on the decision and/or wanting to wait until required to make a decision in writing.
Additional Information:
Larger Financial Offers: The SCCHA is limited in its ability to offer more than the appraised fair market value for a home. The offer needs to be based on an appraisal to ensure equitable treatment of all residents. Offering larger financial offers for certain homes and not others is unfair to the balance of the residents who have accepted their offers based on the appraisals.
Efforts to respond to this have also included:
•Hosting a workshop explaining how the appraisals are done (methodology, use of comparables, etc.) and how, as a government agency, SCCHA is required to use a third- party appraisal to ensure just compensation and fairness. •Considered resident appraisals when provided.
Larger Units: The SCCHA reports that households are counting spaces as bedrooms that are not actual bedrooms in form or function (e.g., hallways and closets) or are adding bedrooms to their units after the initial housing options have been presented. It must treat households equitably and cannot provide some households with larger units without providing other households the same opportunity. Another constraint to providing larger units is cost. On average, each additional bedroom adds about $100,000 to each home’s purchase price, for which the SCCHA notes it has no additional funding.
On a related note, relocation law requires the SCCHA to provide comparable replacement housing. Its program is fully in compliance and in many areas exceeds requirements. The SCCHA efforts to respond to this have also included:
•Touring units to confirm square footage and bedroom count. •Providing data that shows in many cases new units will have more square footage than current units. On average families are receiving more square footage:
o1-bedroom households on average are receiving 66 more square feet. o2-bedroom households on average are receiving 247 more square feet. o3-bedroom households on average are receiving 279 more square feet. •Providing the opportunity, relating to certain requests for reasonable accommodation, for a household to receive a larger unit in the apartment building (e.g., a 2-bedroom owner converting to a 3-bedroom renter).
Splitting into Multiple Households: The SCCHA has remained open to exploring splitting households into multiple new homes because there are several multi-generational households that would like to have grandparents or extended family reside in their own unit. However, the SCCHA did an analysis of all households who have an adult member of the household who is not the head-of-household plus an assumed spouse or partner. The analysis found that the number of extra adults in each household exceeded the number of apartments available. Therefore, a program for splitting households could not be developed fairly. Each household will have the option to apply for a new apartment when they become available although the SCCHA has noted that due to Fair Housing Law, the new household would need to participate in a lottery with other future applicants. The SCCHA efforts to respond to this have also included:
•Explaining how providing additional units for split households is not possible, given the site constraints and the number of households who find themselves in similar situations. •Encouraging residents to apply for vacant apartments once complete.
Decision Disagreement or Delay: The SCCHA has remained in contact with and offered additional support and information to households experiencing internal disagreements or waiting until required to make a decision in writing. Additionally, the SCCHA reports they have urged these households to reconcile their differences, make an informed and balanced decision and to put their decision in writing.
Overall, the SCCHA has communicated their efforts to resolve these outstanding concerns.
These efforts have included outreach to each household to encourage dialogue and trust building as well as to acknowledge their outstanding issue. In each case, the SCCHA has provided detailed explanations and documentation as to why the housing offer cannot be revised both verbally and in written communications. As of the writing of this staff report, the SCCHA continues to meet with residents on their final individual housing plans, to either affirm housing decisions or assist undecided households in selecting their decisions. The SCCHA expects additional housing decisions to be made as households are presented with their final individual housing plans and offers of compensation.
Vesting Tentative Map
A previous report to the Planning and Transportation Commission summarizes the consistency of the proposed subdivision map with the Comprehensive Plan and municipal code requirements. A copy of that report without attachments is included in Attachment E and the full report is available online.5 The PTC unanimously recommended approval of the Vesting Tentative Map on July 10, 2024. The findings and conditions for approval of the map are included in the draft Record of Land Use Action in Attachment B.
As noted in staff’s presentation during the previous Council hearing, the plans have been revised to reflect the main drive aisle as an ingress/egress easement versus a private street.
Because private streets are deducted from the net lot area, the net lot area used for the purposes of calculating floor area ratio has now increased. Accordingly, the requested concession for additional floor area decreased from 1.0:1 to 0.89:1.
FISCAL/RESOURCE IMPACT
As noted in prior reports, in June 2016, Council authorized expenditure of $14.5 million in affordable housing funds to support the SCCHA’s acquisition of the Buena Vista Mobile Home 5 July 10, 2024 City Council Meeting Staff Report file:///S:/PLAN/PLADIV/Current%20Planning/0%20- %20Application%20Types%20and%20Approvals/Housing%20-
%20Streamlined%20Projects/2024/3980%20El%20Camino%20Real/2024-0710%20PTC%20hearing/ptc-7.10- public-agenda.pdf
Park for deed-restricted affordable housing. The redeveloped Buena Vista will have two separate development budgets, one for the mobile home park and one for the proposed apartments. With the State's award of nearly $25 million in Manufactured Housing Opportunity and Revitalization funds, the mobile home park is fully funded. The SCCHA is continuing to work on the financing plan and funding applications for the apartment building and applied for Preservation & Reinvestment Initiative for Community Enhancement funds in June and intends to submit an application for tax credits in late August. In order to be competitive for tax credits, entitlements for the project must be complete.
No additional funding is requested from the City at this time. The formal application is a cost recovery project and the SCCHA has paid the required deposit fee in accordance with the municipal fee schedule for processing of this application. Staff is presenting this report for Council approval at this time to help the SCCHA meet their funding deadline. The additional items requested by Council in June 2024 do not result in funding requests for the City though some have added costs to the SCCHA project budget.
STAKEHOLDER ENGAGEMENT
As detailed in prior reports, community engagement has included workshops, tours, newsletters FAQS, website updates, and community-building events. Additionally, resident engagement has had a direct influence on design of the redevelopment.
Public Comments
Previous comments on the project were summarized in the Council staff report. At the Council hearing in June 2024, four members of the public provided additional comments on the proposed project. Key comments from these four commenters included:
•One resident who lived on site encouraged changing the design to be exclusively rental •The owner of the property across Los Robles requested access driveway be moved to a different location
•One resident raised a question of a conflict of interest from an individual councilmember and asked for additional protections to ensure that the mobile homes are not removed
•One resident spoke on behalf of a group of herself and five other residents expressing support for the project, asking for a Palo Alto live work preference, asked for more trees, expressed disappointment that the color palette did not reflect the resident’s preference, stated that street naming is important. She also questioned the hard deadline for declaring a choice and about transport during relocation.
Council’s disclosures and discussion on June 18, 2024 touched on the comments raised during the public comment period and Council’s motion reflected a request for further consideration of trees, the color palette, a Palo Alto live work preference, and further outreach efforts related to relocation choices accordingly.
Valley Water
Given the existing infrastructure and easement along the project frontage, Valley Water is an important stakeholder in this project as well. Staff has discussed the proposed plans with Valley Water as they relate to work within their easement. Ultimately, refinements to the utility laterals across their easement may be needed at the building permit stage. As a condition of approval, the City’s waste-gas-water division will require potholing to confirm the in-field, as- built conditions of the infrastructure. This pre-construction work will require an encroachment permit from Valley Water. The results of the potholing will better inform the final design of the laterals, which will need to comply with Valley Water’s requirements. As outlined in the planning conditions of approval, an encroachment permit from Valley Water is required prior to any temporary or permanent work within their easement, including all above and below grade work.
ENVIRONMENTAL REVIEW
The project has been assessed in accordance with the Authority and the criteria of the California Environmental Quality Act. Specifically, the City, acting as the lead agency, finds the project to be exempt from CEQA in accordance with CEQA Guidelines Section 15332, which provides an exemption for infill development. Documentation to support the class 32 exemption is provided in Attachment G. The CEQA analysis considers the whole of the action, including the subdivision and redevelopment of both resulting parcels.
Because this project involves federal programs, it must also be evaluated under the National Environmental Policy Act (NEPA). The City is serving as the Responsible Entity (RE) for NEPA in accordance with federal requirements. The Department of Housing and Urban Development will serve as the lead agency under NEPA. As the RE, the City is responsible for preparing the NEPA evaluation. An Environmental Assessment is being prepared in accordance with NEPA and is required to be complete prior to the release of any federal funds for the project. NEPA is not required for approval of planning entitlements.
ATTACHMENTS
Attachment A: Location Map
Attachment B: Draft Record of Land Use Action
Attachment C: 2017 Regulatory Agreement
Attachment D: Proposed Regulatory Agreements and Termination Agreement for Existing Regulatory Agreement
Attachment E: Staff Report to Planning and Transportation Commission for Subdivision Map Attachment F: Project Description and Waiver Justification Attachment G: Project Plans and Environmental
APPROVED BY:
Jonathan Lait, Planning and Development Services Director