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City Council
Supplemental Report
From: Jonathan Lait, Planning and Development Services Director Meeting Date: April 20, 2026
Item Number: 6
Report #:2604-6260
TITLE
Adopt a Resolution Authorizing the Director of Planning and Development Services to Make Minor Modifications to the 2023-2031 Housing Element Site Inventory. CEQA Status: The City Council adopted a Revised Addendum to the Comprehensive Plan Final Environmental Impact Report on December 18, 2023, that, in conjunction with the Comprehensive Plan Final EIR, fully analyzes the impacts of the 6th Cycle Housing Element, including minor modifications to the site inventory.
RECOMMENDATION
Staff recommends that the City Council adopt a resolution to authorize the Director of Planning and Development Services to make modifications to the 2023-2031 Housing Element site inventory that are consistent with the adopted Housing Element.
BACKGROUND
This transmittal provides additional information on the objective criteria that will be used to identify new Housing Element opportunity sites to replace Regional Housing Needs Allocation (RHNA) capacity. If the City Council adopts the resolution, the Director of Planning and Development Services will apply these criteria to evaluate site suitability. Approving this process for minor modifications to the 2023–2031 Housing Element Site Inventory will help the City maintain compliance with state law and the Housing Element’s Adequate Sites Program.
Evaluation Criteria
Staff will evaluate candidate Housing Element opportunity sites using the same objective criteria used to identify the City’s existing opportunity sites. The California Department of Housing and Community Development (HCD) accepted these criteria as part of the City’s approach to meeting RHNA requirements, and they are described in the Housing Element (pp. 3-25 to 3-33). Examples include:
Improvement to land value ratio
Vacant buildings
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Structure age
Developer interest
Existing use/current zoning
Staff will also consider additional criteria in response to changing circumstances, including implementation of SB 79, and re-evaluate previously studied sites. These tools will be used to screen sites and assess redevelopment potential.
Selection Criteria
Prior to making any determination of whether a site will be added to the Housing Element site inventory, the Director will review candidate sites based on the following selection criteria:
Exclusions:
oR1 zones
oSites immediately adjacent to R1
oEnvironmentally sensitive areas, such as the foothills or Baylands Prioritized locations:
oSites within ½ mile of Caltrain stations
oLocations within commercial or mixed-use corridors, particularly in locations with transit or bike facilities
oLocations within area plans or planning focus areas
The Director will add sites to the inventory as necessary to meet state requirements for RHNA at each income level and to maintain an adequate buffer.
Reporting
The Director will submit a report to the City Council when changes are made to the Housing Element site inventory. In addition, changes will be reported to HCD annually as part of the state-mandated reporting requirements.
APPROVED BY:
Jonathan Lait, Planning and Development Services Director