Salinas City Council
December 5, 2023

Housing Element Update
CEQA Exemption
Technical Memorandum
City of Salinas

Prepared for:

City of Salinas
City of Salinas
Community Development Department
65 West Alisal Street, 2nd Floor
Salinas, CA 93901

Prepared by:

PlaceWorks
Contact: Steve Noack, Principal
2040 Bancroft, Suite 400
Berkeley, California 94704
(510) 848-3815
[email protected]
www.placeworks.com

November 2023

HOUSING ELEMENT UPDATE CEQA EXEMPTION TECHNICAL MEMORANDUM

CITY OF S ALINAS
Table of Contents

Section Page

1. INTRODUCTION ............................................................................................................. 3

1.1 PURPOSE ........................................................................................................... 3

1.2 STATUTORY AUTHORITY AND REQUIREMENTS ............................................. 3

2. PROJECT DESCRIPTION .............................................................................................. 4

2.1 REGIONAL LOCATION........................................................................................ 4

2.2 PROPOSED PROJECT ....................................................................................... 4

3. FINDINGS CONCERNING CEQA EXEMPTION ............................................................. 9

3.1 SECTION 15061(B)(3): COMMON SENSE EXEMPTION .................................... 9

3.2 ANALYSIS IN SUPPORT OF FINDINGS ............................................................. 9

Tables
Table 3-1 Proposed Housing Element Implementing Programs and Actions ......................11

Figures
Figure 2-1 Housing Sites Inventory .................................................................................................. 8

November 2022 Page 3

1. I ntroduction

1.1 PURPOSE
This Technical Memorandum serves as an evaluation of the City of Salinas 2023-2031 (6th cycle) Housing Element (proposed project) for California Environmental Quality Act (CEQA) compliance.

This Technical Memorandum was prepared to present: 1) the findings resulting from the CEQA compliance review, as described below; and 2) the recommendations concerning the appropriate CEQA compliance documentation.

1.2 STATUTORY AUTHORITY AND REQUIREMENTS
Once it is determined that an activity is a project subject to CEQA, it is then determined whether the project is exempt from CEQA. State CEQA Guidelines Section 15061(b) outlines the ways in which a project may be exempt as follows:

A project is exempt from CEQA if:
1) The project is exempt by statute (see, e.g., Article 18, commencing with Section 15260). 2) The project is exempt pursuant to a categorical exemption (see Article 19, commencing with Section 15300) and the application of that categorical exemption is not barred by one of the exceptions set forth in Section 15300.2.
3) The activity is covered by the common-sense exemption that CEQA applies only to projects which have the potential for causing a significant effect on the environment.

Where it can be seen with certainty that there is no possibility that the activity in question may have a significant effect on the environment, the activity is not subject to CEQA. 4) The project will be rejected or disapproved by a public agency. (See Section 15270(b)). 5) The project is exempt pursuant to the provisions of Article 12.5 of Chapter 3.

The proposed project would be exempt as a “common sense” exemption under State CEQA Guidelines Section 15061(b)(3) because implementation of the 2023- 2031 Housing Element would not have the potential to cause a significant effect on the environment, as further discussed below in Section 3, Findings Concerning CEQA Exemption.

2. Project Description

2.1 REGIONAL LOCATION
The City of Salinas (City) is located approximately 105 miles south of San Francisco in Monterey County and at the north end of the Salinas Valley. The City is surrounded by unincorporated rural and agricultural land. Unincorporated communities nearby include Bolsa Knolls and Natividad to the north, Speckles to the south, and Boronda to the west. U.S. Highway 101 (Highway 101), State Route (SR) 183, and SR 68 run through the city.

2.2 PROPOSED PROJECT

2.2.1 Project Background
The City of Salinas is preparing a comprehensive update to its existing Housing Element. The update is expected to be completed in December 2023 and will guide the City’s housing development through January 2031.

The 6
th Cycle Housing Element is a State-mandated, eight-year policy document that is an element of the Salinas General Plan. The overall purpose of the 2023-2031 Housing Element is to identify current and projected housing needs; show locations where housing can be built; and set goals, policies, programs, and actions to meet the community’s housing needs. The foundation of the Housing Element is the Regional Housing Needs Allocation (RHNA), which begins with a determination of housing needs issued by the California Housing and Community Development Department (HCD) and is allocated by the Association of Monterey Bay Area Governments (AMBAG). A jurisdiction is required to demonstrate whether it has sufficient capacity to achieve its RHNA. The RHNA for Salinas for the 2023-2031 Housing Element is 6,674 units; this includes 460 Extremely Low-income units, 460 Very Low-income units, 600 Low income units, 1,692 Moderate income units, and 3,462 Above Moderate income units. 1 The
current Area Median Income (AMI) of Monterey County is $90,100.2 The current income thresholds for the RHNA categories are listed below.
 Extremely Low and Very low Income are 0 to 50 percent of the AMI  Low Income is 51 to 80 percent of the AMI
 Moderate Income is 81 to 120 percent of the AMI
 Above Moderate Income is over 121 percent of the AMI

1 City of Salinas, September 2023, Draft 2023-2031 Housing Element, https://www.visionsalinas.org/_files/ugd/4efb7a_72d498da612b42799448953a03af23b2.pdf, accessed on October 18, 2023.
2 City of Salinas, September 2023, Draft 2023-2031 Housing Element, https://www.visionsalinas.org/_files/ugd/4efb7a_72d498da612b42799448953a03af23b2.pdf, accessed on October 18, 2023.

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Project Description
November 2023 Page 5

2.2.2 Proposed Sites
State law requires that the 2023- 2031 Housing Element identify adequate sites for housing by including an inventory of land suitable for residential development. This includes vacant and non- vacant sites that have potential for redevelopment, and an analysis of the development capacity that can realistically be achieved for each site. The purpose of the Sites Inventory is to evaluate whether there are sufficient sites with appropriate zoning density to meet the RHNA. Based on market trends observed in the city, and property owner and developer interests , the City has developed a Sites Inventory that includes properties most likely to be redeveloped to provide new housing over the next eight years. Inclusion of a site in the Sites Inventory and identification of the site’s capacity does not “preclear” any development, nor does it guarantee that construction will occur on that site. The actual construction of units is market driven and would occur as a result of a development application from a private or non- profit developer and would be subject to its own project-level CEQA review, as applicable.

The City of Salinas Sites Inventory for future housing identifies housing sites spread throughout the city that could be developed with up to 8,629 new housing units, exceeding the RHNA assigned to the City. Figure 1, Housing Sites Inventory, shows a map of where each site is located within the city.

The housing capacities for the sites in the Sites Inventory are based on the City’s current land use designations and no land use designation changes would be necessary in order to achieve the housing production to meet the City’s RHNA . Rezoning is not necessary to meet the City’s assigned RHNA.

One housing site in the Sites Inventory is a pipeline project (the El Rey Motel Conversion project at 443 West Market Street) for which rezoning is proposed in order to convert the building to permanent housing. Because the project would repurpose the existing building, the City determined at the October 24, 2023 Council Meeting that the project is exempt under CEQA Guidelines Section 15378 and Section 15061. This project was initiated by the City independently of the 2023-2031 Housing Element and the propo sed rezoning is not dependent on adoption of the proposed Housing Element or this CEQA review. Furthermore, the land use change for this site is anticipated to occur as part of the 2040 General Plan Update, for which an Environmental Impact Report is currently being prepared. The rezoning would occur following the General Plan Update and any subsequent environmental analysis required for the rezoning would tier from the General Plan Update EIR.

2.2.3 Proposed Housing Plan
In addition to providing an inventory of sites with the capacity to accommodate housing to achieve the City’s RHNA, the Housing Element includes an assessment of fair housing issues.

Assembly Bill (AB) 686 (2017) requires housing elements to analyze barriers that restrict access to opportunity and to include a commitment to specific, meaningful actions to affirmatively

HOUSING ELEMENT UPDATE CEQA EXEMPTIO N TECHNICAL MEMORANDUM

CITY OF SALINAS
Project Description

furthering fair housing (AFFH). AB 686 requires local governments to identify meaningful goals to address the effects of systemic issues–such as residential segregation, housing cost burden, and unequal educational or employment opportunities–to the extent these issues create or perpetuate discrimination against protected classes.

The City has identified six goals to guide the 2023-2031 Housing Element policies, programs, and actions. Goals 1 through 3 address the region’s housing needs through a combination of production, rehabilitation, and protection. Goal 4 affirmatively furthers fair housing, Goal 5 promotes collaboration and preservation, and Goal 6 seeks to improve the City’s homeless response. The specific goals and policies are outlined below, and the implementation programs for these goals and policies are in Table 3-1, Proposed Housing Element Implementing Programs and Actions.
 Goal 1: Increase Housing Supply and Opportunities for All.  HE Policy 1.1: Incentivize and support the production of new housing units.  HE Policy 1.2: Develop and formalize partnerships that support the long- term supply of housing.
 HE Policy 1.3: Encourage and facilitate the construction of Accessory Dwelling Units (ADUs).
 HE Policy 1.4: Encourage a mix of diverse housing types.  HE Policy 1.5: Update the Zoning Code regularly to ensure consistency with state law and alignment with community vision.
 HE Policy 1.6: Encourage developers to maximize energy conservation and sustainability through green building techniques and materials.
 HE Policy 1.7: Develop high-density and mixed-use housing in areas with existing public and active transportation, and create additional safe bike and pedestrian infrastructure.  HE Policy 1.8: Work with Monterey-Salinas Transit to ensure the Future Growth Area and all future areas with low- income housing have access to high quality transit as they develop.
 Goal 2: Provide Tenant Protections
 HE Policy 2.1: Pursue policies and programs that prevent displacement.  HE Policy 2.2: Advance rent stabilization.
 HE Policy 2.3: Develop additional programs and policies to support tenants’ rights and uphold fair housing/landlord laws.
 HE Policy 2.4: Provide education on fair housing and connect tenants to related legal services.
 Goal 3: Access to Safe and Healthy Housing for all Residents  HE Policy 3.1: Improve the quality and condition of rental housing.  HE Policy 3.2: Continue to promote the rehabilitation of existing housing units.

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 HE Policy 3.3: Support programs for maintenance and retrofits that include energy, heat, and water conservation, and greenhouse gas emission reductions. Focus public funding on lower income residents to decrease economic and health disparities in the transition to green housing.
 HE Policy 3.4: Through public-private partnerships and collaborative efforts, rehabilitate substandard housing where feasible.
 HE Policy 3.5: Require Code Enforcement to work with property owners to address substandard housing violations before pursuing other enforcement options with the goal of preventing loss of housing.
 HE Policy 3.6: Support the elimination of health risks in the home through programs to remove lead-based paint, mold, and other contaminants.
 Goal 4: Advance Housing Affordability and Opportunity at all Income Levels  HE Policy 4.1: Facilitate the production of affordable housing.  HE Policy 4.2: Preserve and expand the existing affordable housing stock.  HE Policy 4.3: Promote housing opportunities for existing residents.  HE Policy 4.4: Connect residents to financial resources.  HE Policy 4.5: Provide assistance to special populations to ensure equitable access to housing.
 HE Policy 4.6: Support seniors aging in place in the community.  Goal 5: Stabilize and Support Neighborhoods
 HE Policy 5.1: Collaborate with residents to improve neighborhoods.  HE Policy 5.2: Leverage code enforcement strategies to improve neighborhoods.  HE Policy 5.3: Encourage the preservation and restoration of residential and neighborhood resources that possess historic, cultural or architectural value  HE Policy 5.4: Take proactive steps to reverse patterns of discrimination by investing in disadvantaged neighborhoods through implementing the Alisal Vibrancy Plan (including ANRSA), Chinatown Revitalization Plan, and Downtown Vibrancy Plan, to ensure they have the resources to reverse the effects of historic neglect.  Goal 6: Improve City Homeless Response
 HE Policy 6.1: Collaborate with the local Continuum of Care (Coc #506-CA) to implement the Lead Me Home Plan.
 HE Policy 6.2: Improve the quality of homeless services and coordination with community providers.
 HE Policy 6.3: Pursue funding opportunities to support existing and new homeless services programs.
 HE Policy 6.4: Seek to address the urgent health and safety needs of unhoused residents.

November 2023 Page 9

3. Findings Concerning CEQA
Exemption

3.1 SECTION 15061(B)(3) : COMMON SENSE EXEMPTION
The proposed project is exempt as a “common sense” exemption under State CEQA Guidelines Section 15061(b)(3) because the project involves goals, policies, programs, and actions to meet the City’s RHNA and affirmatively furthering fair housing (AFFH) goals but does not involve any physical changes with the potential to create an adverse effect on the environment. As described above, the 2023-2031 Housing Element creates a roadmap on how to achieve its RHNA and AFFH goals through identification of suitable sites for development and identification of programs and corresponding actions that could remove constraints to and promote affordable housing. The 2023-2031 Housing Element does not grant any development entitlements or authorize development beyond what is allowed under the City’s current General Plan and Zoning Code (Municipal Code Title 37.) All future housing development pursuant to the 2023- 2031 Housing Element would be subject to further development review, which may require supporting technical reports. As further described above, no regulatory changes, rezoning, or physical improvements are required for the City to adopt the Housing Element and meet its RHNA obligations; therefore, it can be seen with certainty that there is no possibility that adopting the 2023-2031 Housing Element would result in a significant effect on the environment. Thus, the City of Salinas finds that the 2023-2031 Housing Element is exempt from CEQA under the common-sense exemption.

3.2 ANALYSIS IN SUPPORT OF FINDINGS
The 2023- 2031 Housing Element is strictly a policy guidance document that does not entail entitlement of any specific development project and would not result in any direct or indirect physical changes to the environment. As discussed in Section 2.2.2, Proposed Sites, the Housing Sites Inventory is based on existing General Plan land use designations and zoning standards.

No changes to the City’s land use plan are proposed as part of the 2023-2031 Housing Element.

The City plans to accommodate its RHNA through a combination of proposed pipeline projects currently undergoing planning and building permit review; future Accessory Dwelling Unit (ADU) development under current zoning regulations; focusing development on identified vacant and underutilized sites; and development within the entitled portions of the North of Boronda Future Growth Area (FGA).

As described above, rezoning is required to allow permanent housing at the El Rey Motel Conversion project at 443 West Market Street, however, since the proposed project is to repurpose the existing building, the City determined at the October 24, 2023 Council Meeting, that the project is exempt under CEQA Guidelines Section 15378 and Section 15061. This project

HOUSING ELEMENT UPDATE CEQA EXEMPTION TECHNICAL MEMORANDUM

CITY OF SALINAS
Findings Concerning CEQA Exemption

was initiated by the City independently of the 2023- 2031 Housing Element and the proposed rezoning is not dependent on adoption of the proposed Housing Element or this CEQA review.

Furthermore, the rezoning is anticipated to occur following the 2040 General Plan Update, for which an EIR is currently being prepared.

Goals, policies, programs, and actions included in the 2023-2031 Housing Element encourage housing production and outline steps for future implementation of certain programs. As discussed in Section 2.2.3, Proposed Housing Plan, Goal 1 of the proposed Housing Element Update is to increase housing supply and opportunities for all, with a focus on diversifying the mix of housing types in Salinas. Policy 1.1 incentivizes and supports the production of new housing units. Policy

1.3 encourages and facilitates the construction of Accessory Dwelling Units (ADUs). Policy 1.4 encourages a mix of diverse housing types. Policy 1.5 specifies future updates to the Zoning Code to ensure consistency with S tate law and community vision, but does not specify amendments resulting in increased densities. Policy 1.7 seeks to develop high-density and mixed-use housing in areas with existing public and active transportation and create additional safe bike and pedestrian infrastructure. These policies encourage and promote housing production under existing land use regulations but do not increase the amount of development allowed in the city when compared to existing land use regulations.

The policies described above—and their corresponding implementing programs and actions — under Goal 1 are intended to encourage future housing development that meets all housing needs. However, none of these policies require any land use or zoning changes that could increase the amount of housing allowed in the city or otherwise result in physical impacts on the environment. These policies are structured to incentivize housing development within the framework of existing density and buildout provisions envisioned in the City’s existing General Plan.

The City is currently in the process of preparing an update to its General Plan ( Visión Salinas 2040 General Plan Update), through which the City is reimagining its land use plan and switching from traditional land use designations to a place -type based system. These draft Place Types would offer greater land use flexibility and density, with less emphasis on strict use classifications.

In accordance with Policy 1.5, once the General Plan is adopted and the EIR is certified, the Zoning Ordinance would be updated to comply with the new General Plan policies and implementation directives.

Future implementation actions to implement the programs in the proposed 2023- 2031 Housing Element would include amendments to zoning and other regulations to fac ilitate housing development consistent with State housing law. These future amendments are discussed in detail below. Implementation of the proposed programs and actions would not have any significant environmental effects beyond those already contemplated by existing land use policies and zoning regulations. Please see Table 3-1, Proposed Housing Element Implementing Programs and Actions, for a full listing and analysis of proposed programs and actions.

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Table 3-1 Proposed Housing Element Implementing Programs and Actions Implementing Programs
and Corresponding Actions
Summary of Determination that
Program and Actions are Exempt under
CEQA Guidelines Section 15061(b)(3)
Program 1: Provision and Monitoring of Adequate Sites for RHNA
Actions:
a. Maintain a site inventory of adequate densities and
appropriate development standards to facilitate a range of housing opportunities. - Ongoing
b. Establish a formal procedure by end of 2024 to annually review sites and ensure no net loss of sites to
accommodate remaining RHNA and to identify additional
sites or rezone within six months when net loss would
occur.
c. To ensure completion of pipeline projects identified in Table 59: Credits Toward the RHNA, the City will monitor progress of these projects and will coordinate with
applicants to facilitate remaining approvals and permits.

The City will work with applicants to ensure entitlements do not expire and assist with expedition and funding
assistance if the project is eligible under state law and applicable Housing Element Programs. If a pipeline project is not approved, the City will ensure adequate capacity for the remaining RHNA is provided through monitoring of no net loss and rezoning if necessary (see Action b. above). d. Maintain a minimum of 30 du per acre in the zoning code as a non-discretionary permitted use requirement on
previously identified sites located in the Focused Growth Overlay district which can accommodate residential and
mixed-use developments. – Ongoing
e. To ensure continued AB 1397 compliance, require non- discretionary review for any housing projects with at least 20-percent of units affordable to lower-income households on:
i. Vacant sites identified in two consecutive previous
Housing Element cycles, or
ii. Nonvacant sites identified in the previous cycle, or iii. Sites to be rezoned past the statutory deadline.
f. Continue compliance with Surplus Lands Act requirements and actively market available Surplus Land to affordable housing developers, particularly Consolidated Sites ‘C’ and ‘E’ of Appendix B, which could accommodate 129 Very
Low-Low income units. If additional surplus land is
necessary to accommodate a shortfall of sites/net loss
identified through Action b. above, ensure any necessary rezone is completed within six months.
g. Consult annually with affordable housing developers to identify any additional sites (including surplus public land), which may be considered appropriate for affordable
housing development.
h. Work with the developers to facilitate WASP and CASP development on identified sites by 2031.
i. Coordinate with Monterey-Salinas Transit to increase transit access to new housing sites.

This program and its associated actions
outline steps that the City intends to take to
maintain the housing sites inventory on an
ongoing basis. In general, these actions
describe how the City will monitor sites,
identify new sites (when needed),
coordinate with developers to identify sites
and facilitate development, and monitor
development projects. Certain actions (c,
d, e, f, and g) identify that future rezonings
may be implemented. No specific
rezonings are identified in these actions,
and no rezonings are required in order for
the proposed Housing Element to be
adopted. These actions would not cause
land use or zoning changes to occur that
could increase the amount of housing
allowed in the city beyond levels permitted
by existing land use policies or zoning
regulations. Future rezonings would be
subject to their own project-level CEQA
review, as applicable. This program and its
associated actions would not result in
direct housing development or physical
improvements; therefore, this program
would not result in physical environmental
impacts.

HOUSING ELEMENT UPDATE CEQA EXEMPTION TECHNICAL MEMORANDUM

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Findings Concerning CEQA Exemption

Table 3-1 Proposed Housing Element Implementing Programs and Actions Implementing Programs
and Corresponding Actions
Summary of Determination that
Program and Actions are Exempt under
CEQA Guidelines Section 15061(b)(3)
Program 2: Financial Assistance and Gap Financing
Actions:

Annually
a. Proactively pursue and leverage governmental and non- governmental funds to increase the inventory of affordable housing.
b. Commit federal pass-through funds to the production and preservation of affordable housing.
c. Continue to promote density bonus, inclusionary units, and other incentives to facilitate affordable housing
development.
d. Continue collaborating with existing or potential
Community Housing Development Organizations (CHDOs)
and local or regional stakeholder organizations to create new affordable housing projects and to enhance
neighborhood conditions.

Short Term (1-3 Years)
e. Explore the creation of a Community Revitalization and Investment Authority for Downtown, Chinatown and the
Alisal as a tool to finance affordable housing.
f. Explore parcel taxes for affordable housing that would tax land rather than new development.
g. Explore community land trusts as another avenue for
developing and preserving affordable housing.
h. Explore allocating a portion of Cannabis Business Taxes to foster affordable housing production including funding of planning staff to sustain projects through the process. i. Explore the possibility of a Monterey County Housing Bond and continue to discuss this possibility among Monterey County Stakeholders.
j. Explore the development of commercial/industrial linkage fee for the provision of affordable housing.
k. Maximize local funding resources to leverage conventional non-local grants.

This program and its associated actions
identify several funding mechanisms for
increasing, preserving, and supporting
affordable housing. This program and its
associated actions would not result in
direct housing development or physical
improvements; therefore, this program
would not result in physical environmental
impacts.

Program 3: Prohousing Designation
Actions:
a. Annually pursue PIP funding.
b. Maintain the PDP by adhering to applicable State Housing Law, The Affirmatively Furthering Fair Housing obligation and the Principles of Prohousing, and by implementing the proposed Prohousing policies within the time frame
specified in the City’s application for Prohousing
Designation.

Under this program, the City would
annually pursue funds under HCD’s
Prohousing Incentive Pilot (PIP) Program,
which is intended to increase participation
in HCD’s Prohousing Designating Program
(PDP). In March 2023, the City Council
approved a Resolution authorizing the
submission of a PIP application. If
awarded, the City intends to allocate its
awarded funds towards the
predevelopment, development, acquisition,
rehabilitation, and preservation of
multifamily, residential live-work, rental
housing that is affordable to extremely low,
very low, low-, and moderate-income
households, including necessary operating

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Table 3-1 Proposed Housing Element Implementing Programs and Actions Implementing Programs
and Corresponding Actions
Summary of Determination that
Program and Actions are Exempt under
CEQA Guidelines Section 15061(b)(3)
subsidies and funds towards
homeownership opportunities, including,
but not limited to, down payment
assistance. While this action calls for the
City to pursue PIP funding on an annual
basis, this action would not result in direct
housing development. Therefore, this
program would not result in physical
environmental impacts.

Program 4: Accessory Dwelling Units
Actions:
a. Promote the City’s pre-approved ADU plans and provide guidance and educational materials for building ADUs on the City's website, including permitting procedures and construction resources.
b. Monitor and pursue state grants and financial incentives in connection with the planning, construction, and operation of affordable ADUs.
c. Establish loan program for the financing of new ADUs and provide subsidies for owners willing to provide affordable ADUs.
d. Extend existing ordinance amending Chapter 9 of the
Salinas Municipal Code (Building) to exempt accessory
dwelling units from Development Impact Fees for an
additional 5 years.
e. Complete ADU/JADU ordinance update by May 2024, to
incorporate state requirements and any other relevant
legislation.
f. Monitor program every other year and adopt necessary additional zoning code or other changes within six months of identification of need.
g. Conduct annual outreach and education.

The actions associated with this program
outline how the City intends to promote
and incentivize accessory dwelling units
(ADUs) and junior accessory dwelling units
(JADUs). Actions involve funding,
development process updates, outreach,
and education. Certain actions (d, e, and f)
identify that future amendments to the
City’s Municipal Code and zoning
regulations may be implemented. No
specific amendments are identified in these
actions, and no amendments are required
in order for the proposed Housing Element
to be adopted. Future code amendments
would be subject to their own project-level
CEQA review, as applicable. These actions
would not result in direct development of
ADUs or JADUs. Therefore, this program
would not result in physical environmental
impacts.

Program 5: East Area Specific Plan Development
Actions:
a. Issue a Request for Proposals and select a planning
consultant.
b. Initiate community engagement.
c. Develop draft Specific Plan and environmental documents. d. Adopt East Area Specific Plan.

These actions provide a basic outline of
the steps the City intends to take to
develop the East Area Specific Plan. The
City has already initiated this process by
issuing a Request for Proposals. The East
Area Specific Plan will be subject to its own
environmental review. This program does
not involve direct development under this
forthcoming plan. Therefore, this program
would not result in physical environmental
impacts.

Program 6: General Plan, Zoning Code, and Approval Process Updates
Actions:
a. Adopt the General Plan Update.
b. Amend Zoning Code to implement Place Type
designations and revised Land Use Element. Establish or modify development standards to facilitate achieving
The actions associated with this program
outline several updates to the City’s plans
and procedures, as well as future
amendments to the City’s Municipal Code
and other regulations. No amendments are
required in order for the proposed Housing
Element to be adopted. Future code
amendments would be subject to their own

HOUSING ELEMENT UPDATE CEQA EXEMPTION TECHNICAL MEMORANDUM

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Findings Concerning CEQA Exemption

Table 3-1 Proposed Housing Element Implementing Programs and Actions Implementing Programs
and Corresponding Actions
Summary of Determination that
Program and Actions are Exempt under
CEQA Guidelines Section 15061(b)(3)
maximum densities, encourage small lot consolidation, and remove constraints to housing.
c. Develop and adopt Objective Design Standards for
residential and mixed-use development consistent with the Housing Accountability Act and increase opportunities for ministerial review.
d. Expand the Adaptive Reuse Ordinance to Citywide by
2026.
e. Amend Municipal Code Chapter 15 Housing to remove
subjective findings from Article IV – Reasonable
Accommodation for Persons with Disabilities.
f. Amend CUP requirements in zoning code to remove
subjective required finding (Sec. 37-60.520.(b)) on non- impacts to the surrounding neighborhood/properties for
housing projects and mixed use projects that include
housing.
g. Change the zoning code definition of family (in Sec. 37-

10.300) to remove language that may exclude unrelated
individuals from living together. Remove phrase “based on personal relationships”.
h. Amend zoning code to remove garage and covered
parking requirements.
i. Amend zoning code to make Employee Housing, Small
Project, a Permitted-by-right (P) use in the R-M-3.6 and R- M-2.9 residential zones.
j. Amend Emergency Shelter section (Sec. 37-50.305) to
meet all requirements pursuant to AB 2339, including
eliminating the restrictions on the number of beds,
expanding the definition, ensuring proximity to services, bringing parking and distance requirements into
compliance with AB 139, making Emergency Shelters,
Type A, a permitted use (no discretionary action) in the Mixed-Use District.
k. Streamline approval process to comply with AB 2162
(2018) for Supportive Housing (as defined in the California Health and Safety Code Section 50675.14) in zones where multifamily and mixed uses are permitted, treat as use by right, with no minimum parking requirements if the
development is located within ½ mile of a public transit stop.
l. Establish a written policy to ensure streamlined ministerial review of eligible affordable housing projects as provided by SB 35 (2017) and Government Code, Section 65913.4.
m. Amend zoning code to comply with AB 101 (2019) to allow Low Barrier Navigation Centers (LBNC, as defined in
Government Code Section 65660) by right in areas zoned
for mixed use and nonresidential zones permitting
multifamily uses if it meets specified requirements,
including:
i. Access to permanent housing.
project-level CEQA review, as applicable.

This program and its associated actions
would not result in direct housing
development or physical improvements;
therefore, this program would not result in
physical environmental impacts.

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Table 3-1 Proposed Housing Element Implementing Programs and Actions Implementing Programs
and Corresponding Actions
Summary of Determination that
Program and Actions are Exempt under
CEQA Guidelines Section 15061(b)(3)
ii. Use of a coordinated entry system (Homeless
Management Information System).
iii. Use of Housing First according to Welfare and
Institutions Code section 8255 (Government Code
Section 65662).
n. Review and revise the required findings for CUP approval for large residential care facilities to ensure the findings do not constrain the redevelopment of such facilities.

Program 7: Reduce Housing Production Constraints
Actions:
a. Annually review the City’s planning and development fees to ensure they are appropriate and do not unduly constrain affordable housing development. Compare fees with other local jurisdictions to determine if they are within a
reasonable range for similar projects, based on fees per unit, square footage, total development cost, or other
appropriate metrics.
b. Revise and reduce fees to remove constraints on housing. c. Update the impact fee schedule to reduce minimum net land area per unit requirements.
d. As funding permits, assist in gap financing affordable development by nonprofit developers to help offset the cost of development through deferred impact fees.
e. Periodically review the effectiveness of the Inclusionary Housing Ordinance and Density Bonus Program to
implement revisions as appropriate to incentivize additional housing development.
f. Continue efforts on streamlining and enhancing the
efficiency of the planning and permit approval process as well as building inspection services. Additionally continue supporting affordable housing developers through the
entitlement and development process. Track the average
processing time for housing planning and permit approvals and reduce time by 10 percent by the end of 2026.

The actions associated with this program
outline several ways in which the City
intends to update its development
procedures and fees. No specific
amendments to the City’s development
requirements are identified in these
actions, and no amendments are required
in order for the proposed Housing Element
to be adopted. Future amendments would
be subject to their own project-level CEQA
review, as applicable. This program and its
associated actions would not result in
direct housing development or physical
improvements; therefore, this program
would not result in physical environmental
impacts.

Program 8: Residential Rental Registration & Rent Stabilization Actions:
a. Make educational material and resources available in English, Make educational material and practical resources available in English, Spanish and other languages as
appropriate.
b. Referrals to local service providers.
c. Examine the possibility of developing a Rental Assistance and Navigation program component.
d. Examination, exploration and consideration of a rent stabilization and inspection components.

This program and its associated actions
address the City’s intent to provide
educational material and resources,
coordinate with local service providers, and
explore the development of future
programs to support rental housing. This
program and its associated actions would
not result in direct housing development or
physical improvements; therefore, this
program would not result in physical
environmental impacts.

Program 9: Fair Housing Education, Outreach, and Services Actions:
a. Provide fair housing resources information through City social media, printed materials, and workshops.

This program and its associated actions
address the City’s intent to provide
resources, coordinate with stakeholders
and agency staff, identify funding, support
existing programs, and explore the

HOUSING ELEMENT UPDATE CEQA EXEMPTION TECHNICAL MEMORANDUM

CITY OF SALINAS
Findings Concerning CEQA Exemption

Table 3-1 Proposed Housing Element Implementing Programs and Actions Implementing Programs
and Corresponding Actions
Summary of Determination that
Program and Actions are Exempt under
CEQA Guidelines Section 15061(b)(3)
b. Distribute informational materials to community
organizations and neighborhood gathering spots in areas with higher rates of protected groups.
c. Collaborate with local and regional stakeholders to reach linguistically isolated and underserved populations.
d. Meet quarterly with the City’s contracted housing rights and tenant protection agency staff, beginning in 2023-
2024.
e. Through the HUD Consolidated Plan and Annual Action
Plan, identify and allocate funding for fair housing services as a continued priority.
f. Evaluate and support the implementation of a tenant
relocation assistance program.
g. Consider the implementation of a just cause for eviction ordinance.
h. Support the implementation of a Residential Rental
Registration Program.
development of a future ordinance related
to just cause for evictions. This program
and its associated actions would not result
in direct housing development or physical
improvements; therefore, this program
would not result in physical environmental
impacts.

Program 10: Housing Services Program
Actions:
a. Develop new Housing Services Program and hire new staff to support the services to be provided to the community. b. Promote an adequate, safe, and decent housing stock
through conservation and rehabilitation activities.
c. Market and promote the program through various social media, printed material, and workshops.

This program and its associated actions
describe how the City intends to develop a
new program to provide housing services
through the conservation and rehabilitation
of adequate, safe, and decent housing. No
specific activities are identified in these
actions. Future housing rehabilitation
projects would be subject to their own
project-level CEQA review, as applicable.

This program and its associated actions
would not result in direct housing
development or physical improvements;
therefore, this program would not result in
physical environmental impacts.

Program 11: Code Enforcement
Actions:

Complete 200 code corrections annually and address
substandard housing conditions for 80 units annually.
a. Use Code Enforcement Strategically. Reduce blight by using code enforcement, nuisance abatement, and
receivership to address significant problem properties. b. Educate Residents and Community partners on Code
Enforcement through a variety of platforms such as social media, printed materials and workshops.
c. Continue periodic analysis of code enforcement data to enhance program effectiveness, especially for housing
violations that warrant inspection
d. Seek/research funding, such as HUD HOME lead-based
paint and rehabilitation programs, as it becomes available.

This program and its associated actions
pertain to the enforcement of the City’s
existing codes. No code amendments are
proposed as part of this program. Any
future improvement projects required to
address substandard housing conditions
would be subject to their own project-level
CEQA review, as applicable. This program
and its associated actions would not result
in direct housing development or physical
improvements; therefore, this program
would not result in physical environmental
impacts.

Program 12: Housing Vouchers
Actions:
a. By 2024, establish a closed-loop referral and navigation support system with service provider for those seeking
This program and its associated actions
address the City’s intent to provide
resources and coordinate with service
providers, nonprofits, and landlords to
support housing voucher programs. This

HOUSING ELEMENT UPDATE CEQA EXEMPTION TECHNICAL MEMORANDUM

CITY OF SAN MATEO
Findings Concerning CEQA Exemption
November 2023 Page 17
Table 3-1 Proposed Housing Element Implementing Programs and Actions Implementing Programs
and Corresponding Actions
Summary of Determination that
Program and Actions are Exempt under
CEQA Guidelines Section 15061(b)(3)
information about Housing Voucher program and Utilities Assistance Programs to service providers.
b. Collaborate with nonprofits and landlords to promote and increase participation of rental properties in voucher
housing programs.
c. Continue to support annual Fair Market Rental Rate
studies to ensure Voucher valuations receive necessary
cost of living increases.
d. Continue to partner and seek Vouchers to support the current and emerging development of affordable housing
projects.
e. Support HACM’s petition to HUD for increased Section 8 funding as requested.
f. Continue to support the nonprofits efforts to educate landlords about SB 329 and SB 222. Under these two
laws, all landlords in California will be required to accept Section 8 and VASH vouchers and other forms of rental
assistance and to consider them as part of an applicant’s income. Both laws came into effect on January 1, 2020.
program and its associated actions would
not result in direct housing development or
physical improvements; therefore, this
program would not result in physical
environmental impacts.

Program 13: Homebuyer Resources
Actions:
a. Reassess and Reinstate First Time Homebuyer Program
(FTHB Program) by the end of the 2023 and assist five (5) households within incomes up to moderate income.
b. Investigate and pilot innovative housing ownership model by the end of 2025.
c. Promote CalFHA programs to local loan officers and refer residents to CalFHA homebuyer assistance programs to
increase participation.
d. Continue to support first-time homebuyer education and foreclosure prevention services.

This program and its associated actions
address the City’s intent to provide
resources in support of homebuyers. This
program and its associated actions would
not result in direct housing development or
physical improvements; therefore, this
program would not result in physical
environmental impacts.

Program 14: Housing and Services for Persons with
Disabilities
Actions:
a. Reinstating the Housing Services Program (HSP) and HAA Grant for disabled residents by the end of 2025 and the target the program for low-income households.
b. Through the Annual Action Plan (AAP) of the CDBG,
HOME, and ESG entitlement funds, evaluate and allocate
funding for supportive services and housing for persons with disabilities.
c. Continue to provide individuals with disabilities “reasonable accommodation” in land use, zoning and building
regulations, as required per Ordinance and evaluate and adjust the ordinance as needed to ensure its effectiveness. d. Seek funding sources to incorporate ADA improvements under the ADA Transition Plan to bring older community
facilities up to compliance standards.

This program and its associated actions
address the City’s intent to provide
resources, programs, and funds in support
of housing and services for persons with
disabilities. No code amendments are
proposed as part of this program. Any
future improvement projects required to
bring older facilities up to compliance
standards would be subject to their own
project-level CEQA review, as applicable.

This program and its associated actions
would not result in direct housing
development or physical improvements;
therefore, this program would not result in
physical environmental impacts.

HOUSING ELEMENT UPDATE CEQA EXEMPTION TECHNICAL MEMORANDUM

CITY OF SALINAS
Findings Concerning CEQA Exemption

Table 3-1 Proposed Housing Element Implementing Programs and Actions Implementing Programs
and Corresponding Actions
Summary of Determination that
Program and Actions are Exempt under
CEQA Guidelines Section 15061(b)(3)
Program 15: Allocate Funding for Housing First Homeless Programs
Actions:
a. Proactively evaluate areas of growth to ensure Housing First programs are provided with no/low barrier access to supportive housing
b. Review and analyze street outreach, emergency shelter, and rapid rehousing policies and make recommendations
of best practices including housing first approaches.
c. Provide sub-recipients with technical assistance and support in modifying policies and procedures, either
directly or through a HUD TA provider.
d. Continue to fund and support the City’s three housing navigation centers – SHARE Center, Chinatown
Navigation Center and the Emergency Motel Program –
using ARPA and other City Funds.
e. Continue to pursue acquisition of motel/hotels for potential rapid conversion to non-congregate shelter, transitional housing, or permanent affordable housing for extremely
low, very low and low income individuals.
f. Explore the development of a safe parking program with an emphasis on unsheltered families.

This program and its associated actions
address the City’s intent to provide
resources, programs, and services in
support of unhoused persons. Any future
improvement projects to convert
motels/hotels into shelters or housing
would be subject to their own project-level
CEQA review, as applicable. This program
and its associated actions would not result
in direct housing development or physical
improvements; therefore, this program
would not result in physical environmental
impacts.

Program 16: Local Education Workforce Housing
Actions:
a. Periodically review City zoning codes and regulations to facilitate a variety of housing types conducive to employee housing multifamily rental housing, factory-built housing, mobile homes, supportive housing, single-room occupancy units, accessory dwelling units (ADUs), emergency
shelters, and transitional housing).
b. Identify and eliminate barriers for the development of employer-sponsored housing while ensuring that the
development is built to allow for future conversion to multi- family should the employer sell the property.
c. City to engage quarterly/annually with local/regional employers regarding the production of local workforce
housing.

The actions associated with this program
outline several ways in which the City
intends to update its development
regulations and promote the development
of workforce housing. No specific
amendments to the City’s development
requirements are identified in these
actions, and no amendments are required
in order for the proposed Housing Element
to be adopted. Future amendments would
be subject to their own project-level CEQA
review, as applicable. This program and its
associated actions would not result in
direct workforce housing development or
physical improvements; therefore, this
program would not result in physical
environmental impacts.

Program 17: Farmworker Housing Production & Financing
Actions:
a. Continue to seek federal and state housing finance
programs that are occupationally restricted or advantage farmworker housing (including, for example, the Joe Serna, Jr. Farmworker Housing Grant Program, USDA Section
514,516,521,523 grants). City to financially support all affordable housing projects within City limits pursuing Joe Serna, Jr. funding.
b. Facilitate private sector development of farmworker
housing with unrestricted funding sources to allow flexibility This program and its associated actions
outline steps that the City intends to take to
support the production of farmworker
housing. In general, these actions describe
how the City will obtain and provide
funding, coordinate with stakeholders and
organizations, monitor farmworker housing
production, identify new potential
farmworker housing sites, coordinate with
property owners and the County, and
facilitate the development of farmworker
housing projects. This program and its

HOUSING ELEMENT UPDATE CEQA EXEMPTION TECHNICAL MEMORANDUM

CITY OF SAN MATEO
Findings Concerning CEQA Exemption
November 2023 Page 19
Table 3-1 Proposed Housing Element Implementing Programs and Actions Implementing Programs
and Corresponding Actions
Summary of Determination that
Program and Actions are Exempt under
CEQA Guidelines Section 15061(b)(3)
in providing housing for farmworkers regardless of
documentation.
c. Continue to work with and engage farmworker
stakeholders, farmworker housing proponents and the
nonprofit community bi-annually to implement the Regional Farmworker Housing Study and Action Plan.
d. To date the City has approved the conversion of 8
hotels/motel into temporary farmworker housing through an Extended Stay Conditional Use Permit (CUP). Currently
there are 7 additional hotels/motels pending approval of an Extended Stay CUP. City to continue to approve 1-2 of
these CUPs a year to increase the supply of temporary
farmworker housing.
e. The City has assisted the County of Monterey and several temporary farmworker housing projects in the periphery of the City by allowing them to tie into City infrastructure. The City to continue to assist 1-2 of these new temporary
farmworker housing projects.
f. City to update map identifying potential farmworker
housing sites within the City every two years.
g. Incentivize growers with marginal agricultural land
contiguous to and surrounded by urban uses to dedicate, discount, or lease land for farmworker housing, including no-cost release from Williamson Act Contracts.
h. Facilitate the development of intergenerational farmworker housing for multiple generations of farmworkers (retirees, working adults, and children) to create opportunities for mutual self-reliance, such as provision of childcare and elder care.
i. Enable property owners with contiguous sites appropriate for farmworker housing to parcellate the land or create new lot lines to accommodate larger, more economically
feasible projects.
associated actions would not result in
direct housing development or physical
improvements; therefore, this program
would not result in physical environmental
impacts.

Program 18: Farmworker Housing Regulatory and Land Use
Changes
Actions:
a. Continue to implement and improve the Conditional Use Permit (CUP) for Extended Stay for Hotel/Motel use by H- 2A or Other Seasonal Farmworkers, through a City Council ordinance passed on August 10, 2021, allowing
hotels/motels in certain zoning districts to obtain a CUP to fully operate as an Extended Stay with occupancy up to 10 months in a year.
b. Continue to comprehensively update the Greater Salinas Areas Memorandum of Understanding between the City of
Salinas and the County of Monterey to reflect current land use development plans, current planned or contemplated
development project’s including farmworker housing and
associated services and facilities (relative to sewer, roads.

Etc).

This program and its associated actions
outline steps that the City intends to take to
support the production of farmworker
housing through regulatory and land use
methods. Through these actions, the City
would allow the use of motel/hotel
properties for extended stays, maintain and
up-to-date Memorandum of Understanding
with the County, identify suitable
farmworker housing sites, and utilize
available housing stock for farmworker
housing. This program and its associated
actions would not result in direct housing
development or physical improvements;
therefore, this program would not result in
physical environmental impacts.

HOUSING ELEMENT UPDATE CEQA EXEMPTION TECHNICAL MEMORANDUM

CITY OF SALINAS
Findings Concerning CEQA Exemption

Table 3-1 Proposed Housing Element Implementing Programs and Actions Implementing Programs
and Corresponding Actions
Summary of Determination that
Program and Actions are Exempt under
CEQA Guidelines Section 15061(b)(3)
c. Update as needed a map that identifies specific sites that are suitable for farmworker housing within City limits in collaboration with local jurisdictions in the region.

Whenever possible continue streamlining the approval
processes for farmworker housing projects.
d. Explore opportunities to utilize H2A and other farmworker housing that is vacant off-season for rapid rehousing or other short-term housing uses.

Program 19: Implementation of the Lead Me Home Plan
Actions:
a. I ncrease participation in homeless solutions by leaders and key stakeholders from across the region
b. I mprove the overall performance, capacity, and outcomes of the homelessness response system, and
c. Expand service-oriented responses to unsheltered
homelessness.

This program and its associated actions
address the City’s intent to provide
resources and services in support of
unhoused persons. This program and its
associated actions would not result in
direct housing development or physical
improvements; therefore, this program
would not result in physical environmental
impacts.

Program 20: Expand Leadership and Advocacy Role through CoC CA-506
Actions:
a. Continue to participate as a member of the Coalition of Homeless Services Providers
b. Continue to participate in the Coordinated Access Referral System (CARS) and Homeless Management Information
System (HMIS) oversight Committees to engage in
planning and implementation of the local Coordinated
Entry system.
c. Continue to serve on the CoC CA-506 Leadership Council and Coalition of Homeless Services Providers Board of
Directors and Committees to proactively participate in
further incremental and annual assessments, updates and refinement of the Lead Me Home Plan and advocate for
and support the universal implementation of evidenced-
based best practices and programs.
d. Continue to pursue and apply for existing, emerging
supportive funding opportunities to further expand and
support housing solutions and services.

This program and its associated actions
address the City’s intent to provide
resources, services, and funding as part of
its participation in the local Continuum of
Care (CoC #506-CA). This program and its
associated actions would not result in
direct housing development or physical
improvements; therefore, this program
would not result in physical environmental
impacts.

Program 21: Street Outreach Program
Actions:
a. Develop an annual homeless report to capture housing and service-related outcomes.
b. Implement an online SORT referral system for community members, service providers, and City Staff.
c. Continue to collaborate and refer unsheltered residents with community providers, housing authority, and other
housing and emergency-based programs.
d. Strive to reduce existing and mitigate emergence of
homeless encampments through Cal ICH Encampment
Resolution Grants by continuing to provide a supportive pathway and model of transition for unhoused individuals to permanent housing.

This program and its associated actions
address the City’s intent to provide
outreach, resources, and services in
support of unhoused persons. This
program and its associated actions would
not result in direct housing development or
physical improvements; therefore, this
program would not result in physical
environmental impacts.

HOUSING ELEMENT UPDATE CEQA EXEMPTION TECHNICAL MEMORANDUM

CITY OF SAN MATEO
Findings Concerning CEQA Exemption
November 2023 Page 21
Table 3-1 Proposed Housing Element Implementing Programs and Actions Implementing Programs
and Corresponding Actions
Summary of Determination that
Program and Actions are Exempt under
CEQA Guidelines Section 15061(b)(3)
e. Support the City of Salinas Public Works Department with coordinated emergency shelter referrals and services to encampment residents prior to Health & Safety Days.
f. Continue to seek funding to sustain and expand the
Salinas Street Outreach and Response Team to include
additional housing navigation and case management
services.

Program 22: Engage In Regional Coordination Of Homeless Issues
Actions:
a. Continue to lead and coordinate multi-agency response to reduce encampments and facilitate access to services for unhoused persons and families.
b. Respond and support the CoC in regional encampment
response to address potential safety concerns due to
weather inclement, or other natural disasters.
c. Identify and assess existing and emerging barriers to housing access and propose strategies and the
implementation of best practices, standards, policies, and procedures to expand and sustain access to available
services, programs and housing.
d. Continue to collaborate with the Coalition of Homeless Service Providers and the Housing Authority of the County of Monterey to ensure that the Emergency Housing
Vouchers (EHV)s are leased by September 2023.
e. Advocate for the implementation of a Homeless Care Court in Monterey County that would consider the dismissal of criminal records and other justice-system barriers
experienced by unhoused individuals seeking permanent
housing.

This program and its associated actions
address the City’s intent to provide
outreach, resources, and services in
support of unhoused persons. This
program and its associated actions would
not result in direct housing development or
physical improvements; therefore, this
program would not result in physical
environmental impacts.

Program 23: Housing Navigation and Stabilization Program Actions:
a. Implement a housing navigation program that collaborates with the Salinas Outreach and Response Team to address
barriers to housing and increases successful outcomes.
b. Monitor and track outcomes in the local CoC HMIS.
c. Engage with property management companies and private landlords to minimize stigma and offer support through
incentive and retention services.
d. Consider providing financial incentives such as holding fees for vacant units, damage mitigation funds, and
offsetting potential legal fees to encourage landlords to rent their available units to persons experiencing
homelessness.
e. Support housing retention through a home-based, care coordination model of case management providing
individual support to access and retain benefits and
services and identify and resolve emergent issues.

This program and its associated actions
address the City’s intent to provide
outreach, resources, and services in
support of unhoused persons as part of its
participation in Homeless Management
Information System (HMIS). This program
and its associated actions would not result
in direct housing development or physical
improvements; therefore, this program
would not result in physical environmental
impacts.

HOUSING ELEMENT UPDATE CEQA EXEMPTION TECHNICAL MEMORANDUM

CITY OF SALINAS
Findings Concerning CEQA Exemption

Table 3-1 Proposed Housing Element Implementing Programs and Actions Implementing Programs
and Corresponding Actions
Summary of Determination that
Program and Actions are Exempt under
CEQA Guidelines Section 15061(b)(3)
Program 24: Develop Permanent Supportive Housing Units
Actions:
a. Complete Step Up in Salinas, Step Up on Fairview, and Step Up on Sanborn motel/hotel conversions.
b. Purchase five single-family units and add five
ADUs/JADUs for unhoused families.

The actions associated with this program
outline how the City intends to complete
motel/hotel conversions and purchase
housing units for occupancy by unhoused
persons. Any future improvement projects
to convert motels/hotels into shelters or
housing would be subject to their own
project-level CEQA review, as applicable.

This program and its associated actions
would not result in direct housing
development or physical improvements;
therefore, this program would not result in
physical environmental impacts.

Program 25: Preservation of Affordable Housing At-Risk of Conversion
Actions:
a. Prioritize the status of at-risk units through contacts with the property owner(s).
b. Encourage participation of nonprofit housing developers to acquire and preserve at-risk units.
c. Explore and identify potential funding and other
mechanisms, such as community land trusts, to support
and encourage the rehabilitation and retention of
affordable units.
d. Work with property owner(s) intending to opt out of the affordability covenants and work with potential purchasers to ensure tenants are educated on their rights and
responsibilities, and available housing options, within the required notice of intent to convert at-risk units to market rate rents.
e. Pursuant to new State law, ensure tenants are notified of the potential conversion to market rate housing three years prior to the conversion.
f. City to conduct public hearing on tenant rights at least one year prior to project’s conversion to market rate housing.

This program and its associated actions
outline steps that the City intends to take to
prevent the conversion of at-risk units.

Through these actions, the City would
coordinate with property owners and
developers, identify funding, and conduct
outreach. This program and its associated
actions would not result in direct housing
development or physical improvements;
therefore, this program would not result in
physical environmental impacts.

Program 26: Invest in Disadvantaged Neighborhoods
Actions:
a. Pursue recertification of the Alisal NRSA every five years and update the implementation strategies to reflect
housing and community development needs.
b. Expand marketing efforts in the Alisal NRSA, Chinatown Revitalization Plan and Downtown Vibrancy Plan to
promote housing and community development programs to
residents.
c. Pursue additional local, state, and federal funding that focus on addressing distressed conditions in
disadvantaged communities.
d. Pursue additional local, state, and federal funding and strive to exceed the objectives outlined in the Alisal
Vibrancy Plan, Chinatown Revitalization Plan and
Downtown Vibrancy Plan:

This program and its associated actions
address the City’s intent to provide
outreach, resources, funding, programs,
and services to invest in disadvantaged
neighborhoods. The City would also
improve parks and/or public facilities, and
collaborate with the County to develop
housing. Future improvement projects
would be subject to their own project-level
CEQA review, as applicable. This program
and its associated actions would not result
in direct housing development or physical
improvements; therefore, this program
would not result in physical environmental
impacts.

HOUSING ELEMENT UPDATE CEQA EXEMPTION TECHNICAL MEMORANDUM

CITY OF SAN MATEO
Findings Concerning CEQA Exemption
November 2023 Page 23
Table 3-1 Proposed Housing Element Implementing Programs and Actions Implementing Programs
and Corresponding Actions
Summary of Determination that
Program and Actions are Exempt under
CEQA Guidelines Section 15061(b)(3)
Public Services:
e. Establish a CBDO focused on youth services
f. Provide funding for fair housing services and
tenant/landlord counseling to a CBDO
g. Establish a CBDO to provide and fund small business
counseling, education, and technical assistance services Housing:
h. Maintain and preserve affordable units prior to expiration of affordability agreement 30 to 55-year term
i. Provide funding for housing acquisition, demolition and clearance, and new construction (CBDO).
j. Partner with qualified organizations for acquisition, demolition and clearance, new construction (CBDO) on
City-owned properties.

Economic Development:
k. Recapitalize the Grow Salinas Fund and establish a
microloan program for businesses with five or fewer
employees.
l. Establish one (1) CBDO to provide and fund small
business counseling, education, and technical assistance services.

Public Facilities and Infrastructure Improvements:
m. Improvements at three (3) parks and/or public facilities locations.
n. Continue to collaborate with the County of Monterey and Housing Authority of the County of Monterey to acquire
and develop existing adjacent owned Division Street
properties to provide housing and serve as a hub for public services.

Program 27: Historic Resources
Actions:
a. Reassess and reinstate Miller Act Program by 2024-2025. b. Promote tax credits available for historic preservation through a Mills Act program.
c. Provide technical assistance to property owners, and help identify grant and funding opportunities, when available for preservation and rehabilitation activities.
d. Lead by example in the rehabilitation and renovation of City-owned historic Chinatown Soledad Street properties to serve as a model of considerate, progressive renovation inclusive of mixed-use housing.

This program and its associated actions
address the City’s intent to provide funding
and services for the preservation of historic
resources. The City would also rehabilitate
and renovate City-owned historic
resources. Future improvement projects
would be subject to their own project-level
CEQA review, as applicable. This program
and its associated actions would not result
in direct housing development or physical
improvements; therefore, this program
would not result in physical environmental
impacts.

Source: City of Salinas, PlaceWorks, 2023.

As described in Table 3- 1, several programs involve implementing actions that specify future amendments to certain regulations. For example, some actions involve developing and adopting Objective Design Standards, making amendments to the Salinas Municipal Code, reviewing regulations to facilitate a variety of housing types, and continuing to implement and improve the

HOUSING ELEMENT UPDATE CEQA EXEMPTION TECHNICAL MEMORANDUM

CITY OF SALINAS
Findings Concerning CEQA Exemption

Conditional Use Permit for Extended Stay for Hotel/Motel use. In addition, some actions refer to future development projects or activities, such as historic preservation renovations, improvements to improve accessibility for persons with disabilities, rehabilitation of substandard housing.

Undergoing these actions would not cause land use or zoning changes to occur that could increase the amount of housing allowed in the city beyond levels permitted by existing land use policies or zoning regulations, or otherwise result in physical impacts on the environment. Much like the policies in the proposed 2023- 2031 Housing Element , these regulation modifications would incentivize housing development within the framework of existing density and buildout provisions envisioned in the City’s existing General Plan. In addition, any physical improvements undertaken in the future in support of these programs and actions would be subject to their own project-level CEQA review, as applicable.

The 2023-2031 Housing Element does not include specific amendments to any land use regulations currently, but rather provides a timeline for future amendments. Subsequent amendments to the City’s municipal code would be subject to separate CEQA review at the time those amendments are prepared, if required.

In summary, as described above, the proposed project establishes a policy framework for achieving consistency with applicable State requirements within the city’s existing General Plan buildout projections. Adoption of the proposed 2023-2031 Housing Element does not require any General Plan land use changes or changes to the City’s land use zoning regulations. No physical improvements would directly occur as a result of implementing the proposed project. Therefore, it can be seen with certainty that the adoption of City of Salinas 2023-2031 Housing Element would not result in significant effects on the environment and is therefore exempt from CEQA review.