City of Pleasant Hill
Planning Division
MEMORANDUM
TO: General Plan Advisory Committee
FROM: Troy Fujimoto, Planning Division
DATE: April 12, 2023
SUBJECT: Pleasant Hill Draft Housing Element – HCD Comment Letter Background
In December 2022, the City of Pleasant Hill submitted a Draft Housing Element to the State of California Housing and Community Development Department (HCD) as part of the required Housing Element review process. Subsequently, on March 22, 2023, the City received the HCD comment letter on the Draft Housing Element (Attachment B).
Since this time, the City has been reviewing the comments and making revisions to the Draft Housing Element in response to HCD’s letter. City staff and the consultant team recognized HCD’s concerns regarding the proposed location of the Housing Opportunity Sites, as related to consistency with Affirmatively Furthering Fair Housing (AFFH). Thus, this meeting is primarily related to the General Plan Advisory Committee’s (GPAC) consideration of the proposed revisions to the Housing Opportunity Sites inventory offered in response to HCD’s comment letter.
Overview of HCD Comment Letter
The following provides an overview of HCD comments on the Draft Housing Element. To obtain certification from HCD, the City must revise the Draft Housing Element to address HCD’s comments, generally summarized in the points below:
Requested additional information related to AFFH provisions, including City response to, and history of housing issues, additional consideration of relevant factors that contribute to certain fair housing conditions, and how to better promote housing choices and mobility. Commented on the location of City RHNA low and moderate income level housing opportunity sites in low and moderate resources areas of the City, while the City RHNA moderate and above moderate income level housing are in higher resource areas of the City (further discussion of proposed revisions in response to these comments are provided in Attachment A).
Requested additional information related to household characteristics, including household overpayment information and housing stock conditions.
Requested additional information on the feasibility of “pipeline” projects (projects that have received City entitlements but not yet built) to be completely during the eight year planning cycle. In addition, HCD has requested additional information on non-vacant sites as housing sites, when more than 50% of RHNA lower income units are located on non-vacant site. Questioned the feasibility of counting 40 Accessory Dwelling Units (ADU’s) per year, particularly when recent historical totals fall short of this number. Provided additional comments related to water and sewer priority for lower income households, and zoning updates required by State law related to emergency shelters, supportive housing, group homes, reasonable accommodations and ADU’s. Provided additional information related to potential governmental constraints, including: land use controls (building height, parking, lot coverage) and related fees and exactions for housing development; building code compliance, permit timelines and procedures and related on- and off-site improvements.
Commented on proposed programs of the Draft Housing Element, including: incorporating a program for timing of necessary rezoning; replacement housing; revising programs that may have constraints on housing production; and incorporating necessary AFFH goals, policies, and programs to ensure fair housing for all income levels.
As noted previously, staff is working with the consultant to respond and revise the Draft Housing Element in response to HCD comments. In addition, staff is requesting the GPAC’s consideration of the information provided in Attachment A, and direction on the proposed revisions to the Housing Opportunity Sites inventory.
Summary of Public Comments
Since receipt of the comment letter from HCD, staff has received public comments and is contained in Attachment C.
Recommendation
Staff recommends that the Committee receive all public input, review the proposed revisions to the Housing Opportunity Sites inventory offered in direct response to State HCD comments, and provide direction on the proposed modifications.
Attachments
Attachment A Discussion on Housing Opportunity Sites, including Map of Housing Opportunity Sites
Attachment B State HCD Comment Letter
Attachment C Draft Housing Element (Version Submitted to HCD in December 2022) Policy Document
Needs Assessment
Attachment D Public Comments
Attachment A
Pleasant Hill 2040 General Plan
Housing Element Response to HCD Comments | Material for GPAC Meeting, April 12 1 Summary of HCD Comments on the Sites Inventory and
Capacity to Meet the Lower-Income RHNA
1 | HCD Comments Related to the Sites Inventory
The City received three comments from the California Department of Housing and Community Development (HCD) that require revisions to the sites inventory. Each is included and summarized below.
Comment #1
“Suitability of Nonvacant Sites: The element included a description of each nonvacant site including a discussion of size, type of existing uses, improvement to land value (ILV), building age, etc., However, the analysis should address how these factors are indicative of redevelopment potential. For example, the element referenced ILV and building age for most sites. To support the assumption that ILV and building age can demonstrate redevelopment potential, the element can provide examples of local or regional projects that have redeveloped with similar ILV and building age. Additionally, the element noted that the City conducted property owner outreach; the element can indicate which sites have seen owner interest. Additionally, while the element discussed site characteristics and trends, it must specifically address whether the existing uses impede additional development. Finally, specific analysis and actions are necessary when the housing element relies 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.”
Summary
HCD is asking for additional justification to prove that redevelopment of the City’s underutilized sites is feasible within the planning period. The Project Team can provide much of this justification. However, in cases where jurisdictions rely on underutilized sites and cannot provide at least 50 percent of the lowerincome RHNA capacity through current projects, ADU projections, and vacant sites, the bar for justification is raised (see the bold text above). The current sites inventory identifies 106 lower-income units, which is just12 percent of the 892-unit lower-income RHNA, through pending and approved projects; however, there are zero lower-income units identified through ADU assumptions or located on vacant sites.
Recommendations
• Revise the sites inventory to include additional lower-income sites on vacant land. These sites must currently allow for 30 du/ac, or be rezoned to allow a minimum of 30 du/ac, in order to satisfy the lower-income RHNA requirement.
Pleasant Hill 2040 General Plan
Housing Element Response to HCD Comments | Material for GPAC Meeting, April 12 2 o Two vacant sites, identified as Morello Terraces (APN 154-140-015) and Paso Nogal (APN 152-010-004) are recommended for rezoning from R20 (Single Family - 20,000 sq ft Lots) and R15 (Single Family - 15,000 sq ft Lots), respectively, to MRH (Multiple-family - High Density), which allows 30-40 du/ac.
• Disperse ADU projections by income level based on the methodology established by the Association of Bay Area Governments (ABAG), which suggests a distribution of 30% very-low, 30% low-, 30% moderate-, and 10% above moderate-income.
Comment #2
“Identified Sites and Affirmatively Furthering Fair Housing (AFFH): The element analyzed the identified sites for various fair housing components including race, income, access to opportunity and disproportionate housing needs and generally concluded that sites do not exacerbate current fair housing conditions. The analysis indicates that the City is generally higher resourced with few neighborhoods that are considered low and moderate resourced areas specifically on the far north-east edge of the City and neighborhoods on the eastern side of the City bordering Concord and Walnut Creek.
While the City is generally higher resourced, the element identified the majority of its lower-income Regional Housing Needs Allocation (RHNA) in low and moderate resource areas that also corresponds with other fair housing coincidences including higher concentrations of low moderate-income households, higher environmental hazards and higher rates of individuals that are part of a protected class. Additionally, the element identifies most of the City’s moderate and above moderate income RHNA in higher resourced areas. The element must include a significant analysis and reasoning about the location of sites and impact on current fair housing conditions. Based on the outcomes of this analysis, the element should add or modify programs with specific commitment, metrics, milestones and geographic targeting that is commensurate with the level of isolation of the RHNA to promote inclusive communities and equitable quality of life.”
Summary
HCD notes that the lower-income capacity appears concentrated in low and moderate resource areas within the eastern portion of the City, an area of the City where fair housing issues are more pronounced, and that moderate- and above-moderate income capacity is concentrated in high resource areas and areas with fewer fair housing issues.
Recommendations
• Revise the sites inventory to include more lower-income units within high resource areas, as well as in moderate resource areas with higher incomes, fewer environmental hazards (e.g., farther away from the freeway), and lower concentrations of protected classes. o The Morello Terraces site is located in a high resource area; the Paso Nogal site is located in a moderate resource area on the western portion of the City where fair housing issues are less pronounced.
▪ By rezoning these two sites to MRH (30-40 du/ac), as recommended above, the City can provide additional lower-income capacity that addresses the fair housing issues raised by HCD.
Pleasant Hill 2040 General Plan
Housing Element Response to HCD Comments | Material for GPAC Meeting, April 12 3 • Revise income assumptions on housing opportunity sites near the freeway from lower-income to moderate- or above moderate-income, where possible. This addresses HCD’s concern regarding the equitable dispersal of moderate- and above moderate-income capacity throughout the City.
• Remove the former JCPenney site from the sites inventory to address the State’s concern regarding the concentration of lower-income housing opportunity sites within low resource areas.
• Additionally, staff recommends removal of the southernmost parcel of Housing Opportunity Site G, (1.44-acre property at the northwest corner of Contra Costa Boulevard and Gregory Lane) given HCD comments related to housing units concentrated closer to the freeway and its location at the edge of Site G (not bisecting Site G).
• Following revisions to the sites inventory, additional program actions may be required to further the City’s efforts to overcome fair housing issues, particularly related to air quality issues in areas in proximity to the freeway.
Comment #3
“Accessory Dwelling Units (ADU): The element is projecting 320 ADUs for an average of 40 ADUs per year over the eight-year planning period to accommodate a portion of its RHNA. The element notes that while the City has permitted an average of 25 ADUs per year, the City will be projecting 40 ADUs each year throughout the planning period. Furthermore, the element notes that the projection is based on trends from 2019-2021. However, HCD’s records indicate through the City’s Annual Progress Reports (APR) that between 2019-2021, the City permitted an average of 11 ADUs per year. The City’s past performance does not support a four-fold increase. The element should reconcile these figures and adjust assumptions based on a realistic estimate of the potential for ADUs or provide stronger analysis and supporting information for more aggressive assumptions. Lastly, the element should include significant policies and programs that commit to incentivizing ADUs. Depending on the analysis, the element must commit to monitor ADU production and affordability throughout the planning period and implement additional actions if not meeting target numbers anticipated in the housing element. If necessary, additional actions should be taken in a timely manner (e.g., within six months). The degree of additional actions should be in stride with the degree of the gap in production and affordability. For example, if actual production and affordability of ADUs is far from anticipated trends, then rezoning or something similar would be an appropriate action. If actual production and affordability is near anticipated trends, then measures like outreach and marketing might be more appropriate.” Summary
HCD has challenged the City’s assumption of 320 ADUs, or approximately 40 ADUs per year, over the eight-year cycle and has stated that its data indicates an average of just 11 ADUs per year between 2019 and 2021. HCD has also asked for additional program actions to promote and incentivize ADU production.
Recommendations
The Project Team believes that HCD has undercounted the number of ADUs the City permitted in 2020.
The Team met with HCD staff on April 4, 2023, to discuss an appropriate ADU projection. HCD staff Pleasant Hill 2040 General Plan
Housing Element Response to HCD Comments | Material for GPAC Meeting, April 12 4 suggested that the City use 2019, 2021, and 2022 to establish ADU trends. City staff expressed an interest in setting a goal of 25 ADUs/year, based on established, verified upward trends. HCD staff indicated that an assumption of 25 ADUs per year is acceptable if the City includes program actions to monitor development trends and provide additional incentives to encourage ADU development. • Revise the ADU projection to 25 ADUs/year, and, as previously stated, distribute these units by income category based on ABAG’s distribution methodology. o Based on a projection of 25 ADU/year, the City can count 200 ADUs toward the RHNA.
Of these units, 120 can be assumed toward lower-income capacity. • Revise the Policy Document to include additional program actions to monitor ADU development and further incentivize production.
2 | Impacts on the City’s Ability to Meet the Lower-Income RHNA As discussed, the City’s lower-income RHNA is 892 units. If the City cannot provide capacity for 50 percent of this total (446 units) through pipeline projects, ADU projections, and vacant sites, HCD will automatically presume that the existing uses on nonvacant sites impede residential development.
Pending Projects
The sites inventory includes 106 lower-income units in pending and approved projects. These will not change.
ADU Projections
• Based on a projection of 25 ADUs/year (200 total units), the City can assume 120 ADUs toward lower-income capacity.
Recommended Rezones of Vacant Sites
If rezoned to MRH (30-40 du/ac), the Morello and Paso Nogal sites can be assumed as lower-income capacity.
The two sites discussed below, Morello Terraces and Paso Nogal, are suggested for rezone to provide lower income capacity. While they accounted for 15 and 7 units, respectively, in the Draft Housing Element, if rezoned, these sites could provide realistic capacity of 298 lower-income units toward the RHNA.
An Explanation of Realistic Capacity Calculation Requirements The City must calculate maximum capacity [(acreage) x (maximum density)], as well as realistic capacity.
Realistic capacity, which is the unit total that can be counted toward the RHNA, can be calculated in one of two ways:
• The City can calculate realistic capacity based on maximum capacity but must apply adjustment factors that consider reductions to total capacity based on recent trends as well as development standards, such as setbacks. (acreage x maximum density x adjustment factors) • The City can calculate realistic capacity based on the minimum allowed density. (acreage x minimum density).
Pleasant Hill 2040 General Plan
Housing Element Response to HCD Comments | Material for GPAC Meeting, April 12 5 o Please note: When minimum density is used, HCD states that “the general plan or zoning must require the specified minimum number of residential units on the identified sites regardless of overlay zones, zoning allowing nonresidential uses, or other factors potentially impacting the minimum density.”
Morello Terraces (6.55 acres) | Maximum capacity: 262 units [6.55ac x 40du/ac] • Realistic capacity based on maximum density method: 174 units • Realistic capacity based on minimum density method: 196 units Paso Nogal (3.4 acres) | Max capacity: 136 units [3.4ac x 40du/ac] • Realistic capacity based on maximum density formula: 90 units • Realistic capacity based on minimum density formula: 102 units To better ensure future housing development provides the number of units required per the City’s RHNA, staff recommends that in both cases the City calculate realistic capacity using the minimum density method.
Summary Calculations
Table 1 calculates realistic capacity based on the recommendations discussed above. As shown, these revisions meet the goal of providing at least 50 percent of the lower-income RHNA through pending projects, ADU’s, and vacant sites.
Table 1: Realistic Capacity Summary - Pending, ADUs, and Vacant Lower-income Sites Realistic Capacity in Units
Pending Projects* 106
ADUs** 120
Morello Terraces** 196
Paso Nogal Hillside** 102
Total 524
50% of Lower Income RHNA (goal) 446
Capacity beyond Goal +78
*Capacity counted in the Draft Housing Element
** Additional lower-income capacity not previously counted While the 106 pending and approved units were included in the Draft Housing Element, the ADU projections and vacant sites in Table 1 represent new lower-income capacity beyond what was previously counted. Combined these suggested revisions provide additional capacity for 418 units toward the lower-income RHNA.
Pleasant Hill 2040 General Plan
Housing Element Response to HCD Comments | Material for GPAC Meeting, April 12 6 3 | Impact to Total RHNA Capacity
Table 2 below calculates changes to the sites inventory summary table, shown in track changes, as follows:
• Assumed Accessory Dwelling Units has been revised from 320 total units dispersed completely among moderate and above moderate, to 200 units dispersed among all income categories, as discussed above.
• Based on comments provided by HCD regarding the proposed location of lower income units within lower resource areas and the concentration of opportunity sites within proximity to environmental hazards (i.e., I-680 freeway), staff recommends removal of the JCPenney’s site from the Housing Opportunity Site inventory. In addition, staff recommends removal of the southernmost parcel of Housing Opportunity Site G, (1.44-acre parcel on the northwest corner of Contra Costa Boulevard and Gregory Lane) given HCD comments related to housing units concentrated closer to the freeway and its location at the edge of Site G (not bisecting Site G).
Removing both sites in response to HCD’s stated concerns represents a total of 225 lowerincome units that must be relocated elsewhere. o In the Draft Housing Element, the JCPenney site accounted for 175 lower-income units and the southernmost parcel of Site G accounted for 50 lower-income units. • Vacant Sites has been revised to reflect the proposed rezoning of the Morello Terraces and Paso Nogal sites, as discussed above. These sites account for 196 and 102 lower-income units respectively, for a total of 298 new lower-income units, but a reduction of 22 units of above moderate-income capacity previously counted in the Draft Housing Element.
As shown in Table 2, the proposed revisions to the sites inventory provide surplus capacity of 280 units in the lower income category, but shortfalls of 217 units in the moderate- and 41 units in the above moderate-income categories. These shortfalls are due to the reduction in the ADU assumption, as well as the loss of 22 above-moderate units originally counted on the Morello Terraces and Paso Nogal sites.
Table 2: Summary of 6th Cycle RHNA Capacity - Revised
Lower Moderate Above
Moderate Total
Sixth Cycle RHNA 892 254 657 1,803
CREDITS
Assumed Accessory Dwelling Units 0 120 280 60 40 20 320 200 Pending and Approved Projects 106 14 260 259* 380 379*
SITES
Housing Opportunity Sites 1,051 826 14 127 1,192 967
Vacant Sites 0 298 0 232 210 232 508
Total Planned Sixth Cycle Units 1,157 1,350 308 88 658 616 2,123 2,054 RHNA with 20 percent buffer (lower and moderate) 1,070 305 657 2,032 Surplus (beyond RHNA with buffer) 87 280 3 (-217) 1 (-41) 91 22 Percentage of RHNA Planned 130% 151% 121% 35% 100% 94% 118% 114% * This revision was made to correct an error in the calculation of Pending and Approved Projects. The Draft Housing Element showed the gross units to be developed, rather than the net-new units.
Pleasant Hill 2040 General Plan
Housing Element Response to HCD Comments | Material for GPAC Meeting, April 12 7 Table 2 shows surplus lower-income capacity of 280 units beyond the 20 percent buffer. Because of this surplus, 280 lower-income units from the Housing Opportunity Sites can be redistributed to the moderate- and above moderate-income categories to help reach those goals. This redistribution is shown in track changes in Table 3 below. As shown in Table 3, after redistributing these units, the City has reached its goal within each income category.
Table 3: Summary of 6th Cycle RHNA Capacity – Revised and Redistributed Lower Moderate
Above
Moderate Total
Sixth Cycle RHNA 892 254 657 1,803
CREDITS
Assumed Accessory Dwelling Units 120 60 20 200
Pending and Approved Projects 106 14 259 379
SITES
Housing Opportunity Sites 826 546 14 231 127 190 967
Vacant Sites 298 0 210 508
Total Planned Sixth Cycle Units 1,350 1,070 88 305 616 679 2,054 RHNA with 20 percent buffer (lower and
moderate) 1,070 305 657 2,032
Surplus (beyond RHNA with buffer) 280 0 -217 0 -41 22 22 Percentage of RHNA Planned 151% 120% 35% 120% 94% 103% 114% Pleasant Hill 2040 General Plan
Housing Element Response to HCD Comments | Material for GPAC Meeting, April 12 8 Pleasant Hill 2040 General Plan
Housing Element Response to HCD Comments | Material for GPAC Meeting, April 12 9 Sites inventory – All Sites, Inset
Former
JCPenney
Pleasant Hill 2040 General Plan
Housing Element Response to HCD Comments | Material for GPAC Meeting, April 12 10 Pleasant Hill 2040 General Plan
Housing Element Response to HCD Comments | Material for GPAC Meeting, April 12 11 Attachment B
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.gov
March 22, 2023
Ethan Bindernagel, Director
Planning Division
City of Pleasant Hill
100 Gregory Lane
Pleasant Hill, CA 94523
Dear Ethan Bindernagel:
RE: City of Pleasant Hill’s 6th Cycle (2023-2031) Draft Housing Element Thank you for submitting the City of Pleasant Hill’s (City) draft housing element received for review on December 27, 2022. Pursuant to Government Code section 65585, subdivision (b), the California Department of Housing and Community Development (HCD) is reporting the results of its review. In addition, HCD considered comments from East Bay for Everyone, Derek Sagehorn, David Kellogg and Anne Paulson pursuant to Government Code section 65585, subdivision (c).
The draft element addresses many statutory requirements; however, revisions will be necessary to comply with State Housing Element Law (Article 10.6 of the Gov. Code).
The enclosed Appendix describes the revisions needed to comply with State Housing Element Law.
As a reminder, the City’s 6th cycle housing element was due January 31, 2023. As of today, the City has not completed the housing element process for the 6th cycle. The City’s 5th cycle housing element no longer satisfies statutory requirements. HCD encourages the City to revise the element as described above, adopt, and submit to HCD to regain housing element compliance.
For your information, pursuant to Assembly Bill 1398 (Chapter 358, Statutes of 2021), if a local government fails to adopt a compliant housing element within 120 days of the statutory deadline (January 31, 2023), then any rezoning to make prior identified sites available or accommodate the regional housing needs allocation (RHNA) (Program F) shall be completed no later than one year from the statutory deadline pursuant to Government Code sections 65583, subdivision (c) and 65583.2, subdivision (c). Please be aware, if the City fails to adopt a compliant housing element within one year from the statutory deadline, the element cannot be found in substantial compliance until these rezones are completed.
Ethan Bindernagel, Director
Chapter 654, Statutes of 2022 (AB 2339), adds specificity on how cities and counties plan for emergency shelters and ensure sufficient and suitable capacity. Future submittals of the housing element may need to address these statutory requirements.
For additional information and timing requirements, please see HCD’s memo at https://www.hcd.ca.gov/sites/default/files/docs/planning-and-community/ab2339- notice.pdf.
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.
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/guidelines.html.
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 Strategic Growth Council and HCD’s Affordable Housing and Sustainable Communities programs; 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.
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 Jamillah Williams, of our staff, at [email protected].
Sincerely,
Paul McDougall
Senior Program Manager
Enclosure
City of Pleasant Hill’s 6th Cycle Draft Housing Element Page 1 March 22, 2023
APPENDIX
CITY OF PLEASANT HILL
The following changes are necessary to bring the City’s housing element into compliance with Article 10.6 of the Government Code. Accompanying each recommended change, we cite the supporting section of the Government Code.
Housing element technical assistance information is available on HCD’s website at https://www.hcd.ca.gov/planning-and-community-development/hcd-memos. Among other resources, the housing element section contains HCD’s latest technical assistance tool, Building Blocks for Effective Housing Elements (Building Blocks), available at https://www.hcd.ca.gov/planning-and-community-development/housing-elements/buildingblocks and includes the Government Code addressing State Housing Element Law and other resources.
A. Housing Needs, Resources, and Constraints
1. Affirmatively further[ing] fair housing in accordance with Chapter 15 (commencing with Section 8899.50) of Division 1 of Title 2…shall include an assessment of fair housing in the jurisdiction. (Gov. Code, § 65583, subd. (c)(10)(A).) Enforcement and Outreach: While the element included a summary of fair housing complaints on a county-wide basis, it should include information on fair housing complaints specific to the City and analyze those complaints for trends and impact on protected classes. The element must also evaluate any findings, lawsuits, or judgements related to enforcement actions regarding fair housing. In addition, the analysis must describe compliance with existing fair housing laws and regulations and include information on fair housing outreach capacity. For additional information, please see pages 28-30 on HCD’s Affirmatively Furthering Fair Housing (AFFH) Guidance Memo at https://www.hcd.ca.gov/community-development/affh/docs/AFFH_Document_Final_4-27- 2021.pdf.
Racially Concentrated Areas of Affluence (RCAA): The element does not analyze census tracts or neighborhoods that are considered an RCAA. Additionally, HCD’s fair housing data viewer indicates that majority of the City is considered an RCAA. The element must evaluate the census tracts considered RCAA, including trends, neighborhood conditions relative to other neighborhoods, local data and knowledge and other relevant factors.
Based on the outcomes of this analysis, the element should include significant and meaningful programs to promote housing mobility (not limited to the regional housing need allocation (RHNA)). For more information, please visit: https://affh-data-resourcescahcd.hub.arcgis.com.
Local Data, Knowledge and Other Relevant Factors: The element included some information about regional history, referenced stakeholder comments and discussed the location of assisted projects and housing choice vouchers. However, the element needs to provide information and analysis that relates, supports, or supplements the existing analysis, fair housing conclusions and contributing factors. The element must consider City of Pleasant Hill’s 6th Cycle Draft Housing Element Page 2 March 22, 2023
other relevant factors that have contributed to certain fair housing conditions. This analysis must consider information that is unique to the City, such as governmental and nongovernmental actions, historical land use and zoning practices (e.g., past redlining/greenlining, restrictive covenants, planning documents, etc.), disparities in investment to specific communities including transportation investments, seeking investment or lack thereof, efforts to promote affordability and inclusion, local initiatives, or other information that may have impeded housing choices and mobility. The element should complement federal, state, and regional data with local data and knowledge where appropriate to capture emerging trends and issues, including utilizing knowledge from local and regional advocates, public comments, and service providers.
Contributing Factors: The element includes contributing factors to fair housing issues but should re-evaluate and prioritize these factors based on a complete analysis to better respond to the fair housing issues.
Identified Sites and Affirmatively Furthering Fair Housing (AFFH): The element analyzed the identified sites for various fair housing components including race, income, access to opportunity and disproportionate housing needs and generally concluded that sites do not exacerbate current fair housing conditions. The analysis indicates that the City is generally higher resourced with few neighborhoods that are considered low and moderateresourced areas specifically on the far north-east edge of the City and neighborhoods on the eastern side of the City bordering Concord and Walnut Creek. While the City is generally higher resourced, the element identified majority of its lower-income Regional Housing Needs Allocation (RHNA) in low and moderate resource areas that also corresponds with other fair housing coincidences including higher concentrations of lowmoderate-income households, higher environmental hazards and higher rates of individuals that are part of a protected class. Additionally, the element identifies most of the City’s moderate and above moderate income RHNA in higher resourced areas. The element must include a significant analysis and reasoning about the location of sites and impact on current fair housing conditions. Based on the outcomes of this analysis, the element should add or modify programs with specific commitment, metrics, milestones and geographic targeting that is commensurate with the level of isolation of the RHNA to promote inclusive communities and equitable quality of life.
2. Include an analysis and documentation of household characteristics, including level of payment compared to ability to pay, housing characteristics, including overcrowding, and housing stock condition. (Gov. Code, § 65583, subd. (a)(2).) Overpayment: While the element identifies the total number of households overpaying for housing, it must quantify and analyze the number of lower-income households overpaying for housing by tenure (i.e., renter and owner) and add or modify policies and programs as appropriate.
Housing Stock Conditions: The element utilized housing age to determine number of units likely needing major rehab or replacement. However, the element should supplement this analysis with other data sources to better reflect the number of units in need of rehabilitation and replacement.
City of Pleasant Hill’s 6th Cycle Draft Housing Element Page 3 March 22, 2023
For example, the analysis could include estimates from a recent windshield survey or sampling, estimates from the code enforcement agency, or information from knowledgeable builders/developers, including nonprofit housing developers or organizations. For additional information, see the Building Blocks at https://www.hcd.ca.gov/planning-and-community-development/housing-elements/buildingblocks/housing-stock-characteristics.
3. 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 in Meeting the RHNA: The element identifies 380 units as progress towards the RHNA. Of the 380 units, 109 units currently have approved entitlements or pending approvals. The element must demonstrate the availability of these units during the planning period. For example, the element could discuss and analyze any outreach with the applicants, anticipated timelines for final approvals, remaining steps for projects to request building permits, any known barriers, the City’s past completion rates on pipeline projects, or any other information to demonstrate the availability or likelihood of development in the planning period.
Suitability of Nonvacant Sites: The element included a description of each nonvacant site including a discussion of size, type of existing uses, improvement to land value (ILV), building age, etc., However, the analysis should address how these factors are indicative of redevelopment potential. For example, the element referenced ILV and building age for most sites. To support the assumption that ILV and building age can demonstrate redevelopment potential, the element can provide examples of local or regional projects that have redeveloped with similar ILV and building age. Additionally, the element noted that the City conducted property owner outreach; the element can indicate which sites have seen owner interest. Additionally, while the element discussed site characteristics and trends, it must specifically address whether the existing uses impede additional development.
Finally, specific analysis and actions are necessary when the housing element relies upon nonvacant sites to accommodate more than 50 percent of the RHNA for lowerincome 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.
Replacement Housing Requirements: Absent a replacement housing program, nonvacant sites with residential uses meeting specified criteria are not adequate sites to accommodate lower-income households. The replacement housing program has the same requirements as set forth in Government Code section 65915, subdivision (c)(3).
City of Pleasant Hill’s 6th Cycle Draft Housing Element Page 4 March 22, 2023
The housing element must be revised to include such analysis and a program, if necessary.
AB 725: For jurisdictions that are considered Metropolitan, the element must identify at least 25 percent of the remaining moderate and above-moderate RHNA on sites that allow at least four units of housing (e.g., four plex or greater) (Gov. Code, § 65583.2, subd. (c)(4)).
Accessory Dwelling Units (ADU): The element is projecting 320 ADUs for an average of 40 ADUs per year over the eight-year planning period to accommodate a portion of its RHNA. The element notes that while the City has permitted an average of 25 ADUs per year, the City will be projecting 40 ADUs each year throughout the planning period.
Furthermore, the element notes that the projection is based on trends from 2019-2021.
However, HCD’s records indicate through the City’s Annual Progress Reports (APR) that between 2019-2021, the City permitted an average of 11 ADUs per year. The City’s past performance does not support a four-fold increase. The element should reconcile these figures and adjust assumptions based on a realistic estimate of the potential for ADUs or provide stronger analysis and supporting information for more aggressive assumptions.
Lastly, the element should include significant policies and programs that commit to incentivizing ADUs. Depending on the analysis, the element must commit to monitor ADU production and affordability throughout the planning period and implement additional actions if not meeting target numbers anticipated in the housing element. If necessary, additional actions should be taken in a timely manner (e.g., within six months). The degree of additional actions should be in stride with the degree of the gap in production and affordability. For example, if actual production and affordability of ADUs is far from anticipated trends, then rezoning or something similar would be an appropriate action. If actual production and affordability is near anticipated trends, then measures like outreach and marketing might be more appropriate.
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. Please see HCD’s housing element webpage at https://www.hcd.ca.gov/planning-and-communitydevelopment/housing-elements for a copy of the form and instructions. The City can reach out to HCD at [email protected] for technical assistance.
Water Sewer Priority: Water and sewer service providers must establish specific procedures to grant priority water and sewer service to developments with units affordable to lower-income households. (Gov. Code, § 65589.7.) Local governments are required to immediately deliver the housing element to water and sewer service providers. The element should discuss compliance with these requirements and if necessary, add or modify programs to establish a written procedure by a date early in the planning period.
For additional information and sample cover memo, see the Building Blocks at https://www.hcd.ca.gov/planning-and-community-development/housing-elements/buildingblocks/priority-water-and-sewer.
City of Pleasant Hill’s 6th Cycle Draft Housing Element Page 5 March 22, 2023
Zoning for a Variety of Housing Types:
• Emergency Shelters: The element discusses parking requirements for emergency shelters and includes Program O to address the capacity requirements of AB 139 (Statutes 2019). However, in addition to the capacity requirements, the element must also address the new parking provisions under this requirement. Specifically, Pursuant to Government Code section 65583, subdivision a)(4)(A), also referred to as AB 139, parking for emergency shelters should only be the number of spaces necessary for staff working in the shelter and no more than other uses in the same zones. The element should demonstrate compliance with this requirement or include a program, if necessary.
• By-right Permanent Supportive Housing: The element indicated that pursuant to AB 2162, the element allows transitional and supportive housing in all residential zones in the same manner as similar uses. However, by-right permanent supportive housing has unique requirements and shall be a use by-right (without discretionary action) in zones where multifamily and mixed uses are permitted, including nonresidential zones permitting multifamily uses pursuant to Government Code section 65651. The element must demonstrate compliance with these requirements and include programs as appropriate.
• Accessory Dwelling Units : While the element generally discussed the City’s process to permit ADUs, it must specifically discuss whether ADUs are allowed in all zones that permit residential uses and include or modify program, if necessary.
Additionally, after a cursory review of the City’s ordinance, HCD discovered several areas which were not consistent with State ADU Law. This includes, but is not limited to, timing and process, maximum sizes and set-back requirements. The element must include a program to update the City’s ADU ordinance in compliance with state law. Lastly, the City should submit a copy of the most recent adopted and executed ADU ordinance. For questions, please contact the ADU team through the following: https://calhcd.servicenow.com/csp?id=csm_sc_cat_item_public&sys_id=19d0846297794910edea398c1 253af2a.
• Employee Housing: The element must demonstrate zoning is consistent with the Employee Housing Act (Health and Safety Code, § 17000 et seq.)> Specifically, section 17021.5 requires employee housing for six or fewer employees to be treated as a single-family structure and permitted in the same manner as other dwellings of the same type in the same zone. For additional information and sample analysis, see the Building Blocks at https://www.hcd.ca.gov/planning-andcommunity-development/housing-elements/building-blocks/farmworkers.
4. 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 City of Pleasant Hill’s 6th Cycle Draft Housing Element Page 6 March 22, 2023
developers, and local processing and permit procedures... (Gov. Code, § 65583, subd. (a)(5).)
Land Use Controls: The element must identify and analyze all relevant land use controls impacts as potential constraints on a variety of housing types. The analysis should evaluate land use controls independently and cumulatively with other land use controls, address any impacts on cost, supply, housing choice, affordability, timing, approval certainty and ability to achieve maximum densities and include programs to address identified constraints. The analysis must specifically address heights, parking, lot coverage, scenic route setback requirements and minimum unit size requirements, as follows:
• For heights, the element notes that the City has a maximum height requirement of 35 feet and only 2.5 stories. Further, the element has also identified sites that allow for up to 70 du/ac. The element should describe how height requirements impacts the ability to achieve maximum densities and add or modify programs as appropriate.
• For parking, the element indicated that studio units are required to provide 1.5 parking spaces and multifamily units must provide one guest space for every two units. The element should evaluate the impacts of 1.5 spaces on smaller bedroom units (e.g., studios) and guest parking requirements.
• For lot coverage, the element notes that maximum lot coverage is 40 percent. The element should analyze how this requirement impacts the ability to achieve maximum densities.
• For scenic routes, setbacks must be 50 feet. The analysis should specifically address how this impacts supply, cost, feasibility and ability to achieve maximum densities.
• For minimum unit sizes, the element address the impact of these requirements on smaller bedroom types, housing choices, cost of development and ability to achieve maximum density.
Fees and Exaction: The element indicated that while there is some variation between fees for multifamily and single-family housing, they are generally the same. Additionally, the analysis shows that fees for multifamily are 24 percent of total development costs. Fees that are more than 10-15 percent of the total cost of a unit and requiring multifamily housing to incur the same costs of fees as single family may be considered a constraint.
The element should analyze this constraint for impacts on the cost and supply for housing and include programs that specifically address and mitigate this constraint. For additional information and a sample analysis and tables, see the Building Blocks at http://www.hcd.ca.gov/community-development/building-blocks/constraints/fees-andexactions.shtml.
Code Enforcement: While the element indicates that building codes are verified through the plan check process, it should describe and analyze how the City enforces building codes (e.g., complaint versus proactive based).
Local Processing and Permit Procedures: The element should address public comments on this draft submittal and discuss compliance with the Permit Streamlining Act and City of Pleasant Hill’s 6th Cycle Draft Housing Element Page 7 March 22, 2023
intersections with CEQA and timing requirements, including streamlining determinations and add or modify programs as appropriate.
On/Off-Site Improvements: While the element lists generally on/off-site improvements, it must identify subdivision level improvement requirements, such as minimum street widths (e.g., 40-foot minimum street width), and analyze their impact as potential constraints on housing supply and affordability.
For additional information and a sample analysis, see the Building Blocks at https://www.hcd.ca.gov/planning-and-community-development/housing-elements/buildingblocks/codes-and-enforcement-and-onsite-offsite-improvement-standards.
Constraints on Housing for Persons with Disabilities:
The element must include analysis of potential constraints on housing for persons with disabilities, as follows:
• Group homes (Residential Care Facilities) – The element notes that unlicensed small facilities (6 or fewer persons) are allowed in residential zones with a use permit and that parking requirements are also determined by the use permit. The element also notes that licensed facilities for seven or more persons are only conditionally permitted multifamily zones and thus excluded from several zones that allow for residential uses. Lastly, the element indicates that the City imposes a minimum spacing requirement of 300 feet.
For your information, zoning should simply implement a barrier-free definition of family instead of subjecting, potentially persons with disabilities, to special regulations such as the number of persons, population types and licenses. These housing types should not be excluded from residential zones, most notably lowdensity zones, which can constrain the availability of housing choices for persons with disabilities. Requiring these housing types to obtain a special use or conditional use permit (CUP) could potentially subject housing for persons with disabilities to higher discretionary standards, unlike other residential uses.
The element should evaluate these requirements as constraints and include specific commitment to amend zoning and permit procedures to allow these uses in all zones allowing residential uses with objectivity to facilitate approval certainty similar to other residential uses of the same form. For more information, please see HCD’s guidance at https://www.hcd.ca.gov/sites/default/files/docs/planning-andcommunity/group-home-technical-advisory-2022.pdf. • Other Requirements – The element must describe the City’s reasonable accommodation procedure including the process and decision-making criteria such as approval findings and analyze any potential constraints on housing for persons with disabilities. Additionally, the element must identify and analyze the City’s definition of family used in zoning and land use.
5. An analysis of potential and actual nongovernmental constraints upon the maintenance, improvement, or development of housing for all income levels, including… …the length of time between receiving approval for a housing development and submittal of an application for building permits for that housing development that hinder the construction City of Pleasant Hill’s 6th Cycle Draft Housing Element Page 8 March 22, 2023
of a locality’s share of the regional housing need in accordance with Government Code section 65584... (Gov. Code, § 65583, subd. (a)(6).)
Permit Times: The element must be revised to analyze the length of time between receiving approval for a housing development and submittal of an application for building permits that potentially hinder the construction of a locality’s share of the regional housing need.
6. Analyze any special housing needs such as elderly; persons with disabilities, including a developmental disability; large families; farmworkers; families with female heads of households; and families and persons in need of emergency shelter. (Gov. Code, § 65583, subd. (a)(7).)
Analysis of Special Housing Needs: The element quantifies the City’s special needs populations and broadly discusses the challenges faced by the population. However, a complete analysis should also evaluate the existing resources to meet those needs (availability senior housing units, number of large units, number of deed restricted units, etc.,), an assessment of any gaps in resources, and proposed policies and programs to help address those gaps.
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 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, factory-built 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 A3, 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. In addition, the element should be revised as follows:
Shortfall of Sites – Program F (Increase Allowable Densities): The element demonstrates that most sites for lower-income require rezoning with new designations or up-zoning to accommodate the RHNA. For your information, if zoning is not in place by beginning of the planning period (January 31, 2023) to approve projects at the densities and uses as identified in the inventory, the element must include a program to commit to adopting the zoning changes. Additionally, for sites that are expected to accommodate the City’s lowerincome RHNA, programs must commit to housing element rezone requirements pursuant to Government Code section 65583.2 (h) and (i).
City of Pleasant Hill’s 6th Cycle Draft Housing Element Page 9 March 22, 2023
While the element included Program F to comply with some of the requirements to address a shortfall of sites, the program must also commit to:
• acreage and anticipated units; and
• at least 50 percent of the lower-income need must be accommodated on sites designated for residential use only or on sites zoned for mixed uses that accommodate all of the very low and low-income housing need, if those sites:
o allow 100 percent residential use, and
o require residential use occupy 50 percent of the total floor area of a mixeduse project.
Replacement Housing Requirements: The housing element must include a program to provide replacement housing. (Gov. Code, § 65583.2, subd. (g)(3).) The replacement housing program must adhere to the same requirements as set forth in Government Code section 65915, subdivision (c), paragraph (3).
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).)
As noted in Findings A4 and A5, 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.
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).)
Goals, Priorities, Metrics, and Milestones: As noted in Finding A1, the element requires a complete AFFH analysis. Depending upon the results of that analysis, the City may need to revise or add programs. Specifically, while the element included programs and actions related to increasing housing choices and affordability in high resourced areas, the element must also include strong actions related to enhancing housing mobility and placebased strategies for neighborhoods considered low and moderate resource and have coincidences of fair housing issues such as higher concentration of lower-income households and more disparate access to opportunities compared to other parts of the City. Additionally, based on a complete analysis the element must be revised to add or modify goals and actions. Goals and actions must specifically respond to the analysis and to the identified and prioritized contributing factors to fair housing issues and must be significant and meaningful enough to overcome identified patterns and trends. Lastly, actions must have specific commitment, metrics, milestones and geographic targeting to promote inclusive community and equitable quality of life.
Attachment C
Not Included
Attachment D
From: Kevin Overstreet
To: Troy Fujimoto
Subject: City Council and GPAC
Date: Friday, April 7, 2023 9:10:16 AM
CAUTION: This email originated from outside of the organization. Do not click links or open attachments unless you recognize the sender.
I am writing to provide my input to the City Council and GPAC on the response the city will provide to HCD on Pleasant Hill’s Housing Element and General Plan.
On numerous occasions the GPAC has said “The city plans and developers build”.
The statement is simple but all too true. The city can envision a plan but if developers do not think it will sell, they will not build it.
The state asked Pleasant Hill to develop a plan that would provide 1803 new housing units in the city. The city spent over two years envisioning how best to accommodate that growth, documented it in the General Plan, and explained the first eight years of execution in the Housing Element. The state HCD has now come back with questions and asked the city to clarify that plan.
Now is not the time to change the plan. The city and the GPAC spent over two years developing this plan and we, the city residents, have faithfully journeyed together with you in providing input and refining that vision. Now, as we near the end of the planning phase and prepare to begin its execution, it is not the time to change the plan. Rather it is time to better clarify and explain it. The plan is sound. Last minute changes will only sow confusion and distrust.
If HCD is asking questions, we need to clarify the vision and execution plan for them.
We should not be changing the plan at the last minute.
Kevin Overstreet
19 William Henry Court
Pleasant Hill, CA 94523
From: David Blau
To: Troy Fujimoto
Subject: Comments on Draft Housing Element & HCD’s Response Date: Thursday, April 6, 2023 4:12:03 PM
CAUTION: This email originated from outside of the organization. Do not click links or open attachments unless you recognize the sender.
We are writing to provide our input to the City Council and GPAC on the response the city will provide to HCD on Pleasant Hill’s Housing Element and General Plan.
On numerous occasions the GPAC has said “The city plans and developers build”.
The statement is simple but all too true. The city can envision a plan but if developers do not think it will sell, they will not build it.
The state asked Pleasant Hill to develop a plan that would provide 1803 new housing units in the city. The city spent over two years envisioning how best to accommodate that growth, documented it in the General Plan, and explained the first eight years of execution in the Housing Element. The state HCD has now come back with questions and asked the city clarify that plan.
Now is not the time to change the plan. The city and the GPAC spent over two years developing this plan and we, the city residents, have faithfully journeyed together with you in providing input and refining that vision. Now, as we near the end of the planning phase and prepare to begin its execution, it is not the time to change the plan. Rather it is time to better clarify and explain it. The plan is sound. Last minute changes will only sow confusion and distrust.
If HCD is asking questions, we need to clarify the vision and execution plan for them.
We should not be changing the plan at the last minute.
David & Jennifer Blau
75 Exeter Lane
Pleasant Hill (home owners for 43 yrs)
From: Danielle Drier
To: Troy Fujimoto
Subject: GPAC
Date: Thursday, April 6, 2023 8:49:25 PM
CAUTION: This email originated from outside of the organization. Do not click links or open attachments unless you recognize the sender.
To whom it may concern:
I am writing to provide my input to the City Council and GPAC on the response the city will provide to HCD on Pleasant Hill’s Housing Element and General Plan.
On numerous occasions the GPAC has said “The city plans and developers build”.
The statement is simple but all too true. The city can envision a plan but if developers do not think it will sell, they will not build it.
The state asked Pleasant Hill to develop a plan that would provide 1803 new housing units in the city. The city spent over two years envisioning how best to accommodate that growth, documented it in the General Plan, and explained the first eight years of execution in the Housing Element. The state HCD has now come back with questions and asked the city clarify that plan.
Now is not the time to change the plan. The city and the GPAC spent over two years developing this plan and we, the city residents, have faithfully journeyed together with you in providing input and refining that vision. Now, as we near the end of the planning phase and prepare to begin its execution, it is not the time to change the plan. Rather it is time to better clarify and explain it. The plan is sound. Last minute changes will only sow confusion and distrust.
If HCD is asking questions, we need to clarify the vision and execution plan for them.
We should not be changing the plan at the last minute.
Thank you,
Danielle Drier
Erin Court, Pleasant Hill
--
From: Jack Prosek
To: Troy Fujimoto
Cc: Sue Noack
Subject: Re: EXTERNAL: Fwd: Upcoming: General Plan Advisory Committee Meeting, 4/12! Date: Wednesday, April 5, 2023 6:45:43 AM
1. Troy -
2. 3. WOW - that is a whole lot of legal mumbo-jumbo in the HCD response dated March 22nd !!
4. 5. BUT it looks like the City DOES need to address BOTH the building HEIGHT issue & the PARKING issue NOW in the Housing Element of the General Plan rather than LATER in the more detailed documents . . . . per the Land Use Controls in part A-4 on page 6 of the Appendix. Add in the Lot Coverage restrictions as well !!!
Jack Prosek
PH Resident / Homeowner
zz
On Tue, Apr 4, 2023 at 5:23 PM Jack Prosek <[email protected]> wrote:
Thanks Troy -
It was not there yet when I looked a while earlier !
Jack Prosek
---------- Forwarded message ---------
From: Troy Fujimoto <[email protected]>
Date: Tue, Apr 4, 2023 at 4:35 PM
Subject: RE: EXTERNAL: Fwd: Upcoming: General Plan Advisory Committee Meeting, 4/12! To: Jack Prosek <[email protected]>
Jack,
We just posted the City website, and it has a link to the HCD letter in the announcement of the meeting.
The link to the webpage can be found at the link below, and on the webpage is a link to the HCD letter.