Attachment 4
HCD Comments and Responses
City of Placentia
HCD Comment
Revised Draft
(Lefler of 12/20/2021)
Housing Element Response/ Revision
Page No.
A. Review and revision
Appendix C
Appendix C has been revised to provide additional explanation of the effectiveness of goals, policies, and related actions in meeting the housing needs of special needs 12opulations.
B.1 Affirmatively furthering fair
Appendix D
The element has been revised to include additional analysis of fair housing. In housing
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addition, Program 2.1 has been revised to describe additional actions the City will take to affirmatively further fair housing.
B.2 Extremely -low-income
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The element has been revised to provide additional analysis of ELI households
households, including cost burden and severe cost burden by tenure.
B.3 Household characteristics
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Overpayment. The analysis contained in the draft element (Table II -7) included overpayment for lower-income households by income category.
This analysis has been expanded to also quantify overpaying households by tenure i.e., renter and owner).
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Housing stock conditions. The element has been revised to include data sources and an estimate of the number of housing units in need of replacement.
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Median rent. The element has been revised to include the estimated average rent in the city.
B.4 Sites inventory
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RHNA: Table 2-3 has been revised to reflect RHNA modifications approved by SCAG on 7/1/2021.
Appendix B
Sees inventory. The inventory has been revised to include additional information regarding existing uses.
Appendix B
Realistic Capacity. Additional analysis of the realistic capacity of the sites inventory has been provided.
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ATTACHMENT 4
HCD Comment
Revised Draft
(Letter of 12/20/2021)
Housing Element
Response/Revision
Page No.
Appendix B
Suitability of nonvacant sites. Additional analysis has been provided 4-4 1
regarding the potential capacity for additional housing on nonvacant sites.
In addition, Program 1.8 has been revised to include a replacement requirement pursuant to Gov. Code §65583.2(g)(3) if this property is rezoned to accommodate a RHNA shortfall and any existing residential units in this project would be demolished.
Appendix B
Sites identified in a prior planning period. The sites inventory has been 4-4
expanded to identify sites used in a prior planning period. In addition, Program 1.8 has been revised in conformance with State law. 3-20
Infrastructure: The original draft element included analysis of sewer and dry utilities.
3-17 to 20
Environmental Constraints: The original draft element included analysis of environmental constraints, including seismic, flooding, hazardous waste, transportation of hazardous materials, fire hazards and noise. The analysis has been expanded to clarify that these potential constraints are not expected to preclude development commensurate with the City's assigned share of regional housing needs.
Appendix D
AFFH. Analysis of how the sites inventory addresses fair housing goals has been provided in Appendix D.
Appendix B
Sites mon. Maps showing the locations of parcels in the sites inventory have been added in Appendix B.
Electronic sites inventoa. An electronic sites inventory is being submitted with the adopted element as required by State law.
B-3
ADUs. The analysis of ADU production has been expanded to address this comment.
B.4 Zoning for a Variety of Housing
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Emergency Shelters: The element has been revised to provide additional Types
analysis of the City's available sites and development standards for emergency shelters. In addition, Program 1.4 has been revised to include an amendment to emergency shelter parking requirements consistent with AB 139 fGovernmenf Code sec 65583 a 4 A .
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ATTACHMENT 4
HCD Comment
Revised Draft
(Letter of 12/20/2021)
Housing Element
Response/ Revision
Page No.
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Employee housing: The element has been revised to demonstrate 4-4
consistency with the Employee Housing Act (Health and Safety Code, § 17000 et seq.) and Program 1.4 has been revised to include a Code amendment consistent with current law.
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Manufactured housing_: The element has been revised to demonstrate consistency with Government Code section 65852.3.
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Permanent supportive housing. The element has been revised to 4-3
demonstrate consistency with Government Code section 65651. 3-6
ADUs. The element has been revised to reflect current City ADU regulations 3-34
and Program 1.19 has been revised to include additional measures to 4-10
encourage ADU production.
B.5 Governmental constraints
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Land use controls. The element has been revised to include additional 4-10
analysis of the cumulative impacts of land use controls on the cost and supply of housing, including the ability to achieve maximum densities. The analysis includes multifamily height and parking requirements, including requirements for garages and impacts on 1 -bedroom and studio units, as well as development standards for the Old Town (OT) and Transit Oriented Development (TOD) zones, including all subdistricts. In addition, Program 1.17 has been revised to include a Code amendment to reduce required parking for studio and 1 -bedroom units in the R-3 district to 1 space in either a garage or a carport.
3-36 to 39
Development Ian review: The element has been revised to provide additional analysis of the DPR process and approval procedures. 3-36
Fees. The element has been revised to include all development fees for typical residential projects. It should be recognized that some fees (e.g., General Plan amendment, specific plan, zone change) are not required unless an applicant Is seeking to change land use regulations. Therefore, they are not relevant to the analysis of typical fees.
3-27 to 29
Housing for persons with disabilities. The element has been revised to provide additional information regarding the reasonable accommodation process and the recent approval of a use permit for a large residential care facility.
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ATTACHMENT 4
HCD Comment
Revised Draft
(Letter of 12/20/2021)
Housing Element
Response/ Revision
Page No.
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Codes and enforcement. The element has been revised to provide additional analysis of codes and enforcement, including local amendments to the Building Code and the enforcement process.
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Other Local Ordinances: The element has been revised to analyze any locally adopted ordinances that directly impacts the cost and supply or residential development, including growth limits, inclusionary requirements and short- term rentals.
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SB 35 Streamlined Ministerial Approval Process. Program 1.6 has been revised to include preparation of written procedures for the SB 35 Streamlined Ministerial A2proval Process.
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Zoning, Development Standards, and Fees. Program 1.6 has been revised to address new transparency laws requiring fees and zoning requirements to be provided on a jurisdiction's website.
B.6 Non-governmental constraints
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Approval Time and Reauesfs Lesser Densities: The element has been revised to include additional analysis of requests to develop housing at densities below those identified, the length of time between receiving approval for a housing development and submittal of an application for building permits.
B.7 Special housing needs
2-12 to 19
The housing needs assessment has been expanded to provide additional analysis of special housing needs.
C.1 Programs that set forth a
Chapter 4
Housing programs have been revised to include more specific timing and schedule of actions during the
description of the City's role in implementation.
planning period
C.2 Programs to make sites
Chapter 4
Shortfall of sites. Program 1.8 (Adequate Sites for Housing Development) has available during the planning
been revised to include specific commitments for rezoning including period
acreage, allowable densities, and anticipated units, as well as compliance with Government Code section 65583.2, subdivisions (h) and (i).
Sites identified in multiple ralannina periods. Program 1.8 (Adequate Sites for Housing Development) has also been revised to include a requirement that for any non -vacant sites identified in Appendix B that were listed in a previous Housing Element sites inventory, or vacant sites that were listed in two previous consecutive inventories, residential development will be allowed by - right when a housing project provides at least 20% of the units affordable to March 2022 -4-
ATTACHMENT 4
HCD Comment
Revised Draft
(Letter of 12/20/2021)
Housing Element
Response/ Revision
Page No.
lower-income households in compliance with Government Code Sec. 65583.2(c).
Replacement Provisions. Program 1.8 (Adequate Sites for Housing Development) has also been revised to include a requirement that development on any site listed in Appendix B that proposes to demolish existing housing units shall be subject to a policy requiring the replacement of affordable units as a condition of any development on the site pursuant to Government Code Sec. 65583.2(g) (3). Replacement requirements shall be consistent with those set forth in Section 65915(c)(3).
Infrastructure. Program 1.5 has been revised to include annual review of infrastructure grant opportunities and application submittal based on eligibility.
C.3 Programs to assist development
Chapter 4
Programs 1.3 (Pursue Funding), 1.8 (Adequate Sites) and 1.14 (Housing for of housing for extremely -low-
Persons with Special Needs) have been revised to include specific and income households
proactive outreach efforts with developers of affordable housing on an annual basis.
CA Programs to remove
This comment is addressed in B5 and B6 above.
governmental and
nongovernmental constraints to the
maintenance, improvement, and
development of housing
C.5 Affirmatively furthering fair
Appendix D
Additional analysis of AFFH issues is provided in Appendix D and Program 2.1 housing
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has been expanded to include additional actions the City will take to further fair housing.
C.6 Programs to preserve low-
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Program 3.5 (Monitoring At -Risk Units) has been revised to include income housing
compliance with noticing requirements, provide education and assistance to tenants, assist with funding, and promptly reach out to qualified entities to reserve at -risk housing units.
C.7 ADUs
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Program 1.19 (Accessory Dwelling Units) has been revised to include additional incentives to promote the creation and affordability of ADUs.
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ATTACHMENT 4
HCD Comment
(Letter of 12/20/2021)
D. Public Participation
Revised Draft !
Housing Element Response/ Revision
Page No.
Appendix A The element has been revised to provide additional information regarding the public participation process.
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ATTACHMENT 4