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.aov
January 26, 2024
Joe Lambert, Director
Development Services Department
City of Placentia
401 E Chapman
Placentia, CA 92870
Dear Joe Lambert:
RE: City of Placentia's 6th Cycle (2021-2029) Revised Draft Housing Element Thank you for submitting the City of Placentia's (City) revised draft housing element received for review on November 28, 2023, along with revisions received on January 26, 2024. Pursuant to Government Code section 65585, the California Department of Housing and Community Development (HCD) is reporting the results of its review.
The revised draft element addresses many statutory requirements described in HCD's October 27, 2023 review; however, revisions will be necessary to substantially comply with State Housing Element Law (Gov. Code, § 65580 et seq), as follows:
1. 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, Actions, Metrics, and Milestones: While Program HE -2.6 (Affirmatively Further Fair Housing (AFFH)) now provides further detail on actions to AFFH, the element must add actions that promote housing mobility (increasing housing choices and affordability) in relatively higher opportunity, higher median income and racially concentrated areas of affluence (RCAA). For example, given the presence of a RCCA and the presence of income disparities within the community, the element must also provide a significant and robust suite of actions (not limited to meeting the regional housing needs allocation (RHNA)) to promote housing mobility and increase housing choices. Additional actions to promote housing mobility include promoting more housing choices and affordability in lower density areas, religious institutional sites, publicly -owned sites, and enhancing accessory dwelling units (ADU), junior accessory dwelling units (JADU), and home sharing strategies. Lastly, these additional actions must
Joe Lambert, Director
have a specific commitment, timing, metrics or numeric objectives, and geographic targeting, as appropriate.
2. 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).) 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...(Gov. Code, § 65583, subd. (c)(1).) Suitability of Nonvacant Sites: While the element provides additional information on the suitability of nonvacant sites, it should provide analysis on the likelihood of redevelopment on sites with existing residential uses. While the element includes statements (p. B-22) regarding the density and incentives are sufficient to encourage redevelopment, the element should still provide supporting analysis.
For example, the element should discuss how recent trends relate to identified sites and if necessary remove or add sites. The element should add or modify programs based on the outcomes of a complete analysis.
In addition, while the element includes Program HE -1.15 (Transit Oriented Development) to monitor redevelopment and sites inventory assumptions, the Program should commit to when adjustments will occur and identifying suitable sites for redevelopment.
Finally, as noted in the prior review, the housing element appears to rely upon nonvacant sites to accommodate more than 50 percent of the RHNA for lower- income households. For your information, the housing element must demonstrate existing uses are not an impediment to additional residential development and will likely discontinue in the planning period. (Gov. Code, § 65583.2, subd. (g)(2).) Absent findings (e.g., adoption resolution) based on substantial evidence, the existing uses will be presumed to impede additional residential development and will not be utilized toward demonstrating adequate sites to accommodate the RHNA. Based on a review of the adoption resolution, this requirement was not addressed, and any future re -adoption must make the appropriate findings.
Joe Lambert, Director
Electronic Sites Inventory: For your information, pursuant to Government Code section 65583.3, the City must submit an electronic sites inventory with its adopted housing element. The City must utilize standards, forms, and definitions adopted by HCD. While the City has submitted the electronic sites inventory, it should re -submit the inventory, including any changes, as part of future re - adoption and submittal. Please see HCD's housing element webpage at https://www.hcd.ca.gov/planning-and- community-development/housing- elements for a copy of the form and instructions. The City can reach out to HCD at sitesinventorv( hcd.ca.gov for technical assistance.
Zoning for a Variety of Housing Types (Emergencv Shelters): While the element provides additional information regarding emergency shelters, the element must also describe the M zone and proximity to amenities and services.
The element will meet the statutory requirements of State Housing Element Law once it has been revised, adopted, submitted, and reviewed by HCD to comply with the above requirements pursuant to Government Code section 65585.
Pursuant to Assembly Bill 1398 (Chapter 358, Statutes of 2021), a jurisdiction that did not adopt a compliant housing element within one year from the statutory deadline cannot be found in compliance until rezones to make prior identified sites or accommodate a shortfall of sites (e.g., Program HE -1.8 — Adequate Sites for Housing Development) are completed pursuant to Government Code sections 65583, subdivision (c)(1)(A) and section 65583.2, subdivision (c). For example, as this year has passed and Program HE -1.8 (Adequate Sites for Housing Development) has not been completed, the housing element will remain out of compliance until the rezoning have been completed.
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 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.
Joe Lambert, Director
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/quidelines.html .
HCD appreciates the hard work, responsiveness, and dedication the City's housing element team provided during the course of our review. We are committed to assisting the City in addressing all statutory requirements of State Housing Element Law. If you have any questions or need additional technical assistance, please contact Jose Ayala, of our staff, at Jose.Avala(a�hcd.ca.gov.
Sincerely,
Paul McDougall
Senior Program Manager