3. Identify the existing percentage of LMI households in each block group where there is a residential capacity targeted to accommodate the RHNA for LMI households.
4. A. Calculate the total percentage of housing units counted towards satisfaction of the RHNA for lower income households where the existing block group percentage of LMI households exceeds the overall average for the jurisdiction.
B. Calculate the total percentage of housing units counted towards satisfaction of the RHNA for LMI households where the existing block group percentage of LMI households exceeds the secondary standard for concentration of LMI households that is significantly higher than the overall jurisdiction average.
5. If the percentage of housing units from #4 A. is significantly higher than the percentage from #2 A., and/or if the percentage of housing units from #4 B. is significantly higher than the percentage from #2 B., then this is an indicator that the site inventory for development of housing for lower income households is overly concentrated in areas that the housing sites would tend to encourage over-concentration of lower income households and sites targeted for lower income housing development should be better located among tracts or block groups where the percentage of lower income households is below the exiting citywide average.
6. Analyze local and regional data and knowledge, policies, practices and investments, demographic trends and other factors.
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Racially and Ethnically Concentrated Areas of Poverty and Affluence The analysis must evaluate both the location of identified sites and the location of capacity (number of units) by income group relative to racially and ethnically concentrated areas of poverty and affluence. The analysis should address whether sites are located in or near areas of concentrated poverty and race and affluence, and whether the identified sites significantly concentrate capacity (number of units) to accommodate lower income households in or near racially and ethnically concentrated areas of poverty. The analysis should also evaluate the relationship between the location where the capacity for the lower-income housing need is accommodated in comparison to the housing need for above moderate income households. For example, whether sites to accommodate above moderate income households are significantly concentrated in areas of affluence. This analysis of R/ECAPs and RCAAs should include looking at neighborhoods of the jurisdiction where there are no identified sites in the site inventory and evaluating if the absence of sites in those neighborhoods perpetuates patterns of R/ECAPs or RCAAs.
Disparities in Access to Opportunity
The analysis must address the location of identified sites and the location of capacity (number of units) by income group relative to overall access to opportunity and various categories of access to opportunity (e.g., education, transportation, employment, environment). The analysis should not only address an overall score value of access to opportunity, but must also individually address access to education, transportation, economic prosperity, areas with low rates of violent crime, parks and recreation areas, environmentally healthy neighborhoods and other important opportunities. This is an important place to include local data, such as school performance and enrollment boundaries, local bicycle and pedestrian data, and access to critical local and cultural institutions if available, although the analysis should extend beyond the jurisdiction’s boundaries when considering access to opportunity. This analysis should be quantitative where possible and qualitative at least to guide appropriate goals and actions resulting from the analysis. Even where information about these indicators of opportunity is more qualitative or anecdotal than quantitative, it is a valuable and necessary component of developing appropriate actions.
Local jurisdictions using the TCAC/HCD Opportunity Maps should note that rural areas are scored relative to other rural areas in the same county, meaning they are not scored on the same scale as non-rural areas. This is important to note in jurisdictions that include a mix of rural and non-rural areas. While the TCAC/HCD Opportunity Maps provide data at a block group level in rural areas, data tools for rural areas and lower population areas sometimes do not fully capture the nuance of the socio-economic patterns, which highlights the importance of using local data and knowledge as a complement.
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Disproportionate Housing Needs, including Displacement Risk The identification of sites should be informed by the findings of the disproportionate housing needs section of the assessment of fair housing. To analyze sites relative to disproportionate housing needs, including displacement risk, a locality must identify and evaluate sites according to cost burdens, overcrowding and substandard housing. This analysis must also address displacement risks as well as any other disproportionate housing needs addressed in the assessment of fair housing based on local data and knowledge. Factors of disproportionate housing need (e.g., overpayment, overcrowding, displacement, etc.) may be considered together to the extent there is a significant coincidence. The analysis must also address ways in which development of the identified sites will impact displacement risk. Where development of the identified sites is likely to increase displacement risk, then the element must include programs to mitigate the risks and impacts of displacement.
Identification and Prioritization of Contributing
Factors
The housing element must include an identification and prioritization of significant contributing factors to segregation, racially or ethnically concentrated areas of poverty, disparities in access to opportunity, and disproportionate housing needs. Fair housing contributing factor (or contributing factor) means a factor that creates, contributes to, perpetuates, or increases the severity of one or more fair housing issues. See “Part 3: Resources” for examples of contributing factors by fair housing issue area. Contributing factors should be based on all the prior efforts and analyses: outreach, assessment of fair housing, and site inventory. Contributing factors must also be prioritized in terms of needed impact on fair housing choice and strongly connect to goals and actions.
The identification and evaluation of contributing factors must:
● Identify fair housing issues and significant contributing factors; ● Prioritize contributing factors, including any local information and knowledge, giving highest priority to those factors that most limit or deny fair housing choice or access to opportunity or negatively impact fair housing or civil rights compliance; and ● Discuss strategic approaches to inform and strongly connect to goals and actions.
For more information, see “Part 3: Resources” (Sample Contributing Factors and Action Matrix) ITEM 3- ATTACHMENT 4
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Chart 2: Contributing Factors Relationship Between Assessment of Fair Housing and Goals and Actions
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The Importance of Prioritization
In any given community, there will be several contributing factors. However, listing contributing factors without analysis will not result in meaningful actions. For example, a list of 50 contributing factors that are not analyzed will likely result in less guided and impactful goals and actions.
Instead, the housing element must prioritize contributing factors and should consider a manageable list (e.g., 4-6) to strongly connect to goals and actions, focus resources and maximize impact in the planning period. Further, the element should consider regular evaluation of the effectiveness of goals and actions and adjust and re-prioritize contributing factors and goals and actions as necessary.
Contributing factors are not limited to public actions. Private actions can also contribute to patterns of segregation, racially or ethnically concentrated areas of poverty, disparities in access to opportunity, and disproportionate housing needs. While public agencies do not directly control private actions or contributing factors beyond a locality’s boundaries, the actions of public agencies can influence private action and have impacts beyond local boundaries. As a result, regardless of whether contributing factors are public or private or local, region, state or federal, the housing element must recognize a broader social and legal obligation to affirmatively further fair housing and still identify and prioritize those contributing factors to commit to commensurate goals and actions.
Using Other Consolidated Plan Documents
Localities may utilize an assessment of fair housing or analysis of impediments created pursuant to past federal requirements to identify and prioritize contributing factors to fair housing issues. Also, the statewide analysis of impediments and, if available, a regional analysis of impediments may be useful. While these documents may be a sufficient starting point, in all cases, contributing factors must be tailored to local conditions or must be re-evaluated and prioritized based on the assessment of fair housing in the housing element. Note that information in an AFH or AI may also be outdated or incomplete depending on how recently that information was prepared and may need to be updated.
Goals, Policies, and Actions
The housing element must include goals, policies and most specifically, a schedule of actions during the planning period. Actions must be specific with timelines, discrete steps and measurable outcomes to have a “beneficial impact” during the planning period. The schedule of actions must reflect the results of analyses and is intended to be adequate to address the housing needs of all economic segments of the community. The schedule of actions must address the following statutory areas:
● Identify adequate sites, with appropriate zoning and development standards and services to accommodate the locality’s share of the regional housing needs for each income level; ● Assist in the development of adequate housing to meet the needs of extremely low-, very low-, low-, and moderate-income households;
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● Address and, where possible, remove governmental and non-governmental constraints to the maintenance, improvement, and development of housing, including housing for people at all income levels, as well as housing for people with disabilities and providing reasonable accommodation; ● Conserve and improve the condition of the existing affordable housing stock; ● Preserve assisted housing developments at risk of conversion to market rate; ● Promote housing opportunities 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; and
● Develop a plan that incentivizes and promotes the creation of accessory dwelling units that can be offered at an affordable rent.
What is “Beneficial Impact”
Programs in the element must have specific commitment to deliverables, measurable metrics or objectives, definitive deadlines, dates, or benchmarks for implementation. Deliverables should occur early in the planning period to ensure actual housing outcomes. For example, programs to “explore” or “consider” on an “ongoing” basis are inadequate to demonstrate a beneficial impact in the planning period. Conversely, a program with clear and specific commitment and numerical objectives such as “rezone 50 acres to high density by June 2022” is adequate to demonstrate a beneficial impact. This specific and clear commitment combined with numerical objectives and timelines is called “beneficial impact.” Similarly, programs to affirmatively furthering fair housing must have specific and clear commitment, milestones, and metrics or numerical and anticipated outcomes.
Goals and Policies
Goals and policies typically are utilized to determine a direction in the implementation of a schedule of actions. Through this direction, actions can be interpreted, prioritized, adjusted and carried out to best achieve the necessary outcomes to address the identified needs without re-evaluating over-arching principles or re-starting legislative or complex policy-making processes. To affirmatively further fair housing, goals and policies must have a specific connection to outreach, the assessment of fair housing, the analysis of the site inventory and most importantly, the prioritization of contributing factors to fair housing issues. Goals, policies and actions must be aggressively set to overcome those contributing factors to meet the “meaningful impact” requirement in statute and to avoid actions that are materially inconsistent with the obligation to affirmatively further fair housing. Goals and policies must be created with the intention to have a significant impact, well beyond a continuation of past actions, and to provide direction and guidance for meaningful action.
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What If Goals Are Outside of Local Control?
Goals should be set regardless of whether a locality directly controls all the factors involved in achieving that goal. A locality’s ability to influence may be a consideration in development of actions but should not limit setting goals. Instead, recognizing the ability or inability to influence a goal should be a starting point for forming appropriate policies and actions. For example, a locality might have limited financial and staff resources. Instead of setting goals and actions at an inadequate level due to limited resources, localities should recognize this constraint and form policies and actions accordingly, such as building partnerships with non-profits to explore all private and public funding available, creating coalitions, working with legislators, exploring all private and public funding available, collaborating with nearby localities and seeking technical assistance.
Goals and policies to affirmatively further fair housing do not need to be independent or isolated on a contributing factor. Instead, goals and policies can be integrated with other goals and policies required by the housing element. For example, a housing element could have a program to “Improve housing supply.” On the other hand, an integrated program could “Improve and integrate housing supply, choices and affordability throughout the community.” Goals and policies intended to affirmatively further fair housing should be described as such. By integrating goals and policies, a locality can leverage efforts for a broader and more significant impact while better reflecting more inclusive values.
Actions
Actions implement goals and consist of concrete steps, timelines and measurable outcomes. Actions should be considered a part of the schedule of actions or programs required by Housing Element Law and must affirmatively further fair housing pursuant to Government Code section 8899.50. Specifically, Government Code section 8899.50 requires “meaningful actions” well beyond combating discrimination to overcome patterns of segregation and foster inclusive communities. These actions, as a whole, must:
● Address significant disparities in housing needs and in access to opportunity; ● Replace segregated living patterns with truly integrated and balanced living patterns; ● Transform racially and ethnically concentrated areas of poverty into areas of opportunity; and ● Foster and maintain compliance with civil rights and fair housing laws.
Further, local agencies shall not take any action materially inconsistent with the obligation to affirmatively further fair housing. This requirement should apply to all actions in the housing element and the rest of the general plan as well as any actions, policies or practices outside of the general plan.
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Action Areas
Actions to affirmatively further fair housing may include, but are not limited to:
● Enhancing housing mobility strategies;
● Encouraging development of new affordable housing in high resource areas; ● Improving place-based strategies to encourage community conservation and revitalization, including preservation of existing affordable housing; and ● Protecting existing residents from displacement.
While the goals, policies and actions may select from the above areas (e.g., mobility, housing in high resource areas, place-based, protection from displacement), actions must be formulated in a manner to address the full scope of outreach, assessment of fair housing, analysis of site inventory and overcome contributing factors to fair housing. As a result, a schedule of actions generally must address all four categories.
For examples of affirmatively furthering fair housing actions by each of the action areas, see “Part 3:
Resources.”
Using a Variety of Actions
To address the full scope of outreach, complete the assessment of fair housing, and overcome contributing factors to fair housing and affirmatively further fair housing, actions must consider a wide range of actions across all action areas (e.g., mobility, housing in high resource areas, place-based and protection from displacement). The number and scale of actions will depend on the severity of the needs but regardless of need, a cohesive and effective program will consider multiple action areas. For example, a place-based approach might improve infrastructure or invest in active transportation, but those efforts would be ineffective in addressing needs without complementary anti-displacement measures.
Further, a balanced and effective approach will consider different types of actions utilizing: (1) human resources: outreach, education, marketing, collaboration, (2) land use resources: planning documents such as general plans, zoning, specific plans, ordinances and procedures, and (3) financial resources.
A balanced and effective approach will consider and combine each of these areas. For example, an approach could include marketing and collaboration as part of increasing mobility, zoning to increase housing choices in high resource areas, and investing financial resources in place-based and displacement action areas. An effective approach will also seek to combine these types within an action area.
For example, a locality might take a zoning and financial resources approach to displacement risks or creating new housing choices in high resource areas. By combining these action areas, a program will be more balanced and more effective in achieving the goals to affirmatively further fair housing.
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Milestones, Objectives, Monitoring and Making Adjustments Specific actions with timelines and measurable or numerical objectives are essential to an effective approach. Successful outcomes will not be achievable and discernable without specificity. For example, a program to “explore feasibility on an ongoing basis” does little to achieve tangible results but a commitment to “rezone 50 acres to the high density district by October 2021” has a far more likelihood of producing results. In addition, measurable or numerical objectives clarify goals and serve as a reference point for monitoring the effectiveness of programs. As part of the annual progress report (Gov. Code, § 65400), localities, through a community process, should evaluate actions for progress toward goals and objectives and effectiveness to make regular adjustments as necessary.
Integrating Affirmatively Furthering Fair Housing into Existing Housing Element Programs
Housing elements must include actions to address statutory areas, such as identifying adequate sites to accommodate the regional housing need, assisting in the development of housing for lower income households and households with special needs, and conserving and improving the existing housing stock. 80 These statutory program areas can be modified to complement the statutorily required affirmatively furthering fair housing programs. 81 Examples include:
● Adequate Sites: In some cases, housing elements will include programs to rezone to address a shortfall of sites to accommodate the regional housing need. These types of programs should be carried out where possible to promote more inclusive communities. In addition, in some cases, a locality might find circumstances warranting rezoning above and beyond the regional housing need to promote more housing choices and affordability. Examples include long held patterns of isolation in higher income areas, or other factors, or when identifying sites to accommodate the housing need for lower income households exacerbates segregation. ● Assist in Development of Housing for Lower Income Households and Households with Special Needs: Housing elements will include programs to encourage affordable development, such as utilizing, seeking or supporting funding, building partnerships with non-profit developers and incentives for affordability. These programs can be targeted to high resource areas or other similar areas to promote inclusive communities.
● Addressing Governmental and Non-governmental Constraints: Land use and zoning can be a key barrier to inclusive communities. Zoning, permit processing, fees and other land use reforms can be targeted geographically to promote more inclusive communities. Non-governmental constraints can include factors such as local opposition to affordable housing. Education and other programs can be geographically targeted to build campaigns for more integrated land use patterns.
80 Gov. Code, §§ 65583, subd. (a)(3) , 65583.2; see also HCD, Building Blocks at https://www.hcd.ca.gov/community-development/buildingblocks/index.shtml. 81 Gov. Code, §§ 8899.50, 65583, subd. (c).
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● Conserve and Improve the Existing Affordable Housing Stock: Elements must have actions to conserve and improve the existing affordable housing stock. Typical actions include programs for rehabilitation (renter, owner), acquisition and rehabilitation, infrastructure investment, conservation of mobilehome parks, housing choice vouchers, and administrative actions like zoning or displacement policies. These types of programs can be geographically targeted as place-based strategies to revitalize and improve communities or as new opportunities in high opportunity areas.
● Incentivize Accessory Dwelling Units (ADUs): Programs to incentivize ADUs can be targeted as new opportunities in high resource areas or as place-based revitalization strategies.
Integrating Goals, Policies and Actions across Multiple Planning Objectives
Various policy topics can be integrated where more than one objective is considered at a time to promote more balanced approaches and multiple benefits. The intent is to align objectives and set clearer direction to avoid future conflict. Various policy topics can be considered within the housing element and also across the general plan. For example, a goal or policy could be set to both identify adequate sites to accommodate the regional housing need and affirmatively furthering fair housing.
Also, a housing issue could be considered at the same time as a circulation or safety issue. Through more integrated approaches, the general plan becomes a more cohesive, internally consistent and implementable plan. For examples of integrated concepts in the general plan, please review resources developed by the Governor’s Office of Planning and Research. In addition, See “Part 3: Resources” for a matrix of policy topics and integrated planning approaches.
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Part 3:
Resources
Statute (strikeout/underline)
Division 1 of Title 2 of the Government Code, Chapter 15 Government Code Section 8899.50 (Additions and Deletions in Strikeout/Underline) Section 8899.50. (a) For purposes of this section, the following terms have the following meanings:
(1) “Affirmatively furthering fair housing” means taking meaningful actions, in addition to combating discrimination, that overcome patterns of segregation and foster inclusive communities free from barriers that restrict access to opportunity based on protected characteristics. Specifically, affirmatively furthering fair housing means taking meaningful actions that, taken together, address significant disparities in housing needs and in access to opportunity, replacing segregated living patterns with truly integrated and balanced living patterns, transforming racially and ethnically concentrated areas of poverty into areas of opportunity, and fostering and maintaining compliance with civil rights and fair housing laws. The duty to affirmatively further fair housing extends to all of a public agency’s activities and programs relating to housing and community development. (2) “Public agency” means all of the following:
(A) The state, including every state office, officer, department, division, bureau, board, and commission, including the California State University. (B) A city, including a charter city, county, including a charter county, city and county, and a redevelopment successor agency. (C) A public housing authority created pursuant to the Housing Authorities Law (Chapter 1 (commencing with Section 34200) of Part 2 of Division 24 of the Health and Safety Code). (D) A public housing agency, as defined in the United States Housing Act of 1937 (codified at 42 U.S.C. Sec. 1437 et seq.), as amended.
(E) Any other political subdivision of the state that is a grantee or subgrantee receiving funds provided by the United States Department of Housing and Urban Development under the Community Development Block Grant program, the Emergency Solutions Grants program, the HOME Investment Partnerships program, or the Housing Opportunities for Persons With AIDS program. (b) A public agency shall administer its programs and activities relating to housing and community development in a manner to affirmatively further fair housing, and take no action that is materially inconsistent with its obligation to affirmatively further fair housing.
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(c) This section shall be interpreted consistent with the Affirmatively Furthering Fair Housing Final Rule and accompanying commentary published by the United States Department of Housing and Urban Development contained in Volume 80 of the Federal Register, Number 136, pages 42272 to 42371, inclusive, dated July 16, 2015. Subsequent amendment, suspension, or revocation of this Final Rule or its accompanying commentary by the federal government shall not impact the interpretation of this section.
(d) In selecting meaningful actions to fulfill the obligation to affirmatively further fair housing, this section does not require a public agency to take, or prohibit a public agency from taking, any one particular action.
Division 1 of Title 7 of the Government Code, Chapter 3 Government Code Section 65583 (Additions and Deletions in Strikeout/Underline) Section 65583. The housing element shall consist of an identification and analysis of existing and projected housing needs and a statement of goals, policies, quantified objectives, financial resources, and scheduled programs for the preservation, improvement, and development of housing. The housing element shall identify adequate sites for housing, including rental housing, factory-built housing, mobilehomes, and emergency shelters, and shall make adequate provision for the existing and projected needs of all economic segments of the community. The element shall contain all of the following:
(a) An assessment of housing needs and an inventory of resources and constraints relevant to the meeting of these needs. The assessment and inventory shall include all of the following:
(1) through (9) Omitted – No substantive changes.
(b) (1) through (2) Omitted – No substantive changes.
(c) A program which that sets forth a schedule of actions during the planning period, each with a timeline for implementation, which that may recognize that certain programs are ongoing, such that there will be beneficial impacts of the programs within the planning period, that the local government is undertaking or intends to undertake to implement the policies and achieve the goals and objectives of the housing element through the administration of land use and development controls, the provision of regulatory concessions and incentives, the utilization of appropriate federal and state financing and subsidy programs when available, and the utilization of moneys in a low- and moderate-income housing fund of an agency if the locality has established a redevelopment project area pursuant to the Community Redevelopment Law (Division 24 (commencing with Section 33000) of the Health and Safety Code). In order to make adequate provision for the housing needs of all economic segments of the community, the program shall do all of the following:
(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 ITEM 3- ATTACHMENT 4
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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 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. (A) Where the inventory of sites, pursuant to paragraph (3) of subdivision (a), does not identify adequate sites to accommodate the need for groups of all household income levels pursuant to Section 65584, rezoning of those sites, including adoption of minimum density and development standards, for jurisdictions with an eight-year housing element planning period pursuant to Section 65588, shall be completed no later than three years after either the date the housing element is adopted pursuant to subdivision (f) of Section 65585 or the date that is 90 days after receipt of comments from the department pursuant to subdivision (b) of Section 65585, whichever is earlier, unless the deadline is extended pursuant to subdivision (f). Notwithstanding the foregoing, for a local government that fails to adopt a housing element within 120 days of the statutory deadline in Section 65588 for adoption of the housing element, rezoning of those sites, including adoption of minimum density and development standards, shall be completed no later than three years and 120 days from the statutory deadline in Section 65588 for adoption of the housing element. (B) Where the inventory of sites, pursuant to paragraph (3) of subdivision (a), does not identify adequate sites to accommodate the need for groups of all household income levels pursuant to Section 65584, the program shall identify sites that can be developed for housing within the planning period pursuant to subdivision (h) of Section 65583.2. The identification of sites shall include all components specified in Section 65583.2.
(C) Where the inventory of sites pursuant to paragraph (3) of subdivision (a) does not identify adequate sites to accommodate the need for farmworker housing, the program shall provide for sufficient sites to meet the need with zoning that permits farmworker housing use by right, including density and development standards that could accommodate and facilitate the feasibility of the development of farmworker housing for low- and very low income households. (2) Assist in the development of adequate housing to meet the needs of extremely low, very low, low-, and moderate-income households.
(3) 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. (4) Conserve and improve the condition of the existing affordable housing stock, which may include addressing ways to mitigate the loss of dwelling units demolished by public or private action. (5) Promote housing opportunities 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. disability, and ITEM 3- ATTACHMENT 4
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other characteristics protected by the California Fair Employment and Housing Act (Part 2.8 (commencing with Section 12900) of Division 3 of Title 2), Section 65008, and any other state and federal fair housing and planning law.
(6) Preserve for lower income households the assisted housing developments identified pursuant to paragraph (9) of subdivision (a). The program for preservation of the assisted housing developments shall utilize, to the extent necessary, all available federal, state, and local financing and subsidy programs identified in paragraph (9) of subdivision (a), except where a community has other urgent needs for which alternative funding sources are not available. The program may include strategies that involve local regulation and technical assistance. (7) Include an identification of the agencies and officials responsible for the implementation of the various actions and the means by which consistency will be achieved with other general plan elements and community goals.
(8) Include a diligent effort by the local government to achieve public participation of all economic segments of the community in the development of the housing element, and the program shall describe this effort.
(9) (A) Affirmatively further fair housing in accordance with Chapter 15 (commencing with Section 8899.50) of Division 1 of Title 2. The program shall include an assessment of fair housing in the jurisdiction that shall include all of the following components:
(i) A summary of fair housing issues in the jurisdiction and an assessment of the jurisdiction’s fair housing enforcement and fair housing outreach capacity. (ii) An analysis of available federal, state, and local data and knowledge to identify integration and segregation patterns and trends, racially or ethnically concentrated areas of poverty, disparities in access to opportunity, and disproportionate housing needs within the jurisdiction, including displacement risk.
(iii) An assessment of the contributing factors for the fair housing issues identified under clause (ii). (iv) An identification of the jurisdiction’s fair housing priorities and goals, giving highest priority to those factors identified in clause (iii) that limit or deny fair housing choice or access to opportunity, or negatively impact fair housing or civil rights compliance, and identifying the metrics and milestones for determining what fair housing results will be achieved. (v) Strategies and actions to implement those priorities and goals, which may include, but are not limited to, enhancing mobility strategies and encouraging development of new affordable housing in areas of opportunity, as well as place-based strategies to encourage community revitalization, including preservation of existing affordable housing, and protecting existing residents from displacement.
(B) A jurisdiction that completes or revises an assessment of fair housing pursuant to Subpart A (commencing with Section 5.150) of Part 5 of Subtitle A of Title 24 of the Code of Federal Regulations, as published in Volume 80 of the Federal Register, Number 136, page 42272, dated July 16, 2015, or an analysis of impediments to fair housing choice in accordance with the requirements of ITEM 3- ATTACHMENT 4
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Section 91.225 of Title 24 of the Code of Federal Regulations in effect prior to August 17, 2015, may incorporate relevant portions of that assessment or revised assessment of fair housing or analysis or revised analysis of impediments to fair housing into its housing element. (C) The requirements of this paragraph shall apply to housing elements due to be revised pursuant to Section 65588 on or after January 1, 2021.
(d) through (f) omitted – No substantive changes.
Division 1 of Title 7 of the Government Code, Chapter 3 Government Code Section 65583.2 (Additions and Deletions in Strikeout/Underline) 65583.2. (a) A city’s or county’s inventory of land suitable for residential development pursuant to paragraph (3) of subdivision (a) of Section 65583 shall be used to identify sites throughout the community, consistent with paragraph (9) of subdivision (c) of Section 65583, that can be developed for housing within the planning period and that are sufficient to provide for the jurisdiction’s share of the regional housing need for all income levels pursuant to Section 65584. As used in this section, “land suitable for residential development” includes all of the sites that meet the standards set forth in subdivisions (c) and (g):
(1) Vacant sites zoned for residential use.
(2) Vacant sites zoned for nonresidential use that allows residential development. (3) Residentially zoned sites that are capable of being developed at a higher density, including the airspace above sites owned or leased by a city, county, or city and county. (4) Sites zoned for nonresidential use that can be redeveloped for residential use, and for which the housing element includes a program to rezone the site, as necessary, rezoned for, to permit residential use, including sites owned or leased by a city, county, or city and county. (b) Through (l) omitted – No substantive changes.
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AB 686 Housing Element Compliance Checklist
Part 1 Outreach:
Does the element describe and incorporate meaningful engagement that represents all segments of the community into the development of the housing element, including goals and actions (e.g., language access, accessibility for persons with disabilities, resident engagement, including low income residents and residents in subsidized housing programs, description of comments and whether incorporated, and outreach to fair housing agencies, legal services and public housing agencies)?
Part 2 Assessment of Fair Housing:
Does the element include a summary of fair housing enforcement and capacity in the jurisdiction? Does the element include an analysis of these five areas: Fair housing and enforcement capacity? Integration and segregation patterns and trends? Racially or ethnically concentrated areas of poverty? Disparities in access to opportunity? And disproportionate housing needs within the jurisdiction, including displacement risk? Each of these four areas must have its own analysis.
Each analysis on the four fair
housing issue areas should include
the following:
Fair Housing
Enforcement
and Capacity
Segregation and
Integration R/ECAP Access to
opportunity
Disp. Housing
needs
+displacement
risk
Patterns and trends – local and
regional
Local data and knowledge
Other relevant factors
Conclusions and summary of issues
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Part 3 Site Inventory:
Did the element identify and evaluate (e.g., maps) the number of units, location and assumed affordability of identified sites throughout the community (i.e., lower, moderate, and above moderate income RHNA) relative to all components of the assessment of fair housing? Did the element analyze identified sites related to improving or exacerbating conditions for each of the fair housing areas (integration and segregation, racially and ethnically concentrated areas of poverty, areas of opportunity, disproportionate housing needs, including displacement)? Part 4 Identification of Contributing Factors
Did the element identify, evaluate and prioritize the contributing factors to fair housing issues? Did the element prioritize those factors that limit or deny fair housing choice or access to opportunity, or negatively impact fair housing or civil rights compliance? Part 5 Goals and Actions
Did the element identify goals and actions based on the identified and prioritized contributing factors?
Do goals and actions address mobility enhancement, new housing choices and affordability in high opportunity areas, place-based strategies for preservation and revitalization, displacement protection, and other program areas?
Are actions significant, meaningful and sufficient to overcome identified patterns of segregation and affirmatively further fair housing?
Did the element include metrics and milestones for evaluating progress on programs/actions and fair housing results, including concrete timelines?
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Definitions
Affirmatively Furthering Fair Housing
Meaningful actions, in addition to combating discrimination, that overcome patterns of segregation and foster inclusive communities free from barriers that restrict access to opportunity based on protected characteristics. Specifically, affirmatively furthering fair housing means taking meaningful actions that, taken together, address significant disparities in housing needs and in access to opportunity, replacing segregated living patterns with truly integrated and balanced living patterns, transforming racially and ethnically concentrated areas of poverty into areas of opportunity, and fostering and maintaining compliance with civil rights and fair housing laws. The duty to affirmatively further fair housing extends to all of a public agency’s activities and programs relating to housing and community development.82
Assessment of Fair Housing (AFH)
An analysis undertaken pursuant to 24 CFR § 5.154 that includes an analysis of fair housing data, an assessment of fair housing issues and contributing factors, and an identification of fair housing priorities and goals, and is conducted and submitted to HUD using the Assessment Tool. The AFH may be conducted and submitted by an individual program participant (individual AFH), or may be a single AFH conducted and submitted by two or more program participants (joint AFH), or two or more program participants, where at least two of which are consolidated plan program participants (regional AFH).83
Community Participation
As required in 24 CFR § 5.158, means a solicitation of views and recommendations from members of the community and other interested parties, a consideration of the views and recommendations received, and a process for incorporating such views and recommendations into decisions and outcomes. For HUD regulations implementing the Housing and Community Development Act of 1974, the statutory term for ‘‘community participation’’ is ‘‘citizen participation.’’84 Contributing Factor
A factor that creates, contributes to, perpetuates, or increases the severity of one or more fair housing issues. Goals in an AFH are designed to overcome one or more contributing factors and related fair housing issues as provided in 24 CFR § 5.154.85
Disparities in Access to Opportunity
Defined by the AFFH Final Rule as “substantial and measurable differences in access to educational, transportation, economic, and other opportunities in a community based on protected class related to housing.”86
82 Gov. Code, § 8899.50, subd. (a)(1).
83 24 C.F.R. §5.152 (2016).
84 bid.
85 Ibid.
86 Ibid.
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Disproportionate Housing Needs
Generally refers to a condition in which there are significant disparities in the proportion of members of a protected class experiencing a category of housing need when compared to the proportion of members of any other relevant groups, or the total population experiencing that category of housing need in the applicable geographic area. For purposes of this definition, categories of housing need are based on such factors as cost burden, severe cost burden, overcrowding, tenure (own vs. rent), homelessness, and substandard housing conditions.
Fair Housing Choice
Under the AFFH Final Rule, fair housing choice means that individuals and families have the information, opportunity, and options to live where they choose without unlawful discrimination and other barriers related to race, color, religion, sex, familial status, national origin, or disability. Fair housing choice encompasses:
● Actual choice, which means the existence of realistic housing options; ● Protected choice, which means housing that can be accessed without discrimination; ● Enabled choice, which means realistic access to sufficient information regarding options so that any choice is informed. For persons with disabilities, fair housing choice and access to opportunity include access to accessible housing and housing in the most integrated setting appropriate to an individual’s needs, as required under Federal civil rights law, including disability-related services that an individual needs to live in such housing.
Fair Housing Issue
A condition in a program participants geographic area of analysis that restricts fair housing choice or access to opportunity, and includes such conditions as ongoing local or regional segregation or lack of integration, racially or ethnically concentrated areas of poverty, significant disparities in access to opportunity, disproportionate housing needs, and evidence of discrimination or violations of civil rights law or regulations related to housing.87
Integration
A condition within the program participants geographic areas of analysis, as guided by the AFFH Data Viewer, in which there is not a high concentration of persons of a particular race, color, religion, sex, familial status, national origin, or having a disability or a type of disability in a particular geographic area when compared to a broader geographic area.” 88
Land Value Recapture
A policy approach by which communities can recover and reinvest land value increases that result from public investment and other government actions, including re-zoning. This can include things such as requiring community benefits from landowners and developers whose land has increased in value due to government actions, public benefit zoning, incentive zoning, density bonuses, housing overlay zoning, tax increment financing, community benefits agreements, special assessment districts, transferable development rights, linkage or impact fees, and others. 87 Ibid.
88 Ibid.
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Meaningful Action
Significant actions that are designed and can be reasonably expected to achieve a material positive change that affirmatively furthers fair housing by, for example, increasing fair housing choice or decreasing disparities in access to opportunity.89 Public Agency
Means all of the following:
A. The state, including every state office, officer, department, division, bureau, board, and commission, including the California State University.
B. A city, including a charter city, county, including a charter county, city and county, and a redevelopment successor agency.
C. A public housing authority created pursuant to the Housing Authorities Law (Chapter 1 (commencing with Section 34200) of Part 2 of Division 24 of the Health and Safety Code).
D.A public housing agency, as defined in the United States Housing Act of 1937 (codified at 42 U.S.C.
Sec. 1437 et seq.), as amended.
E. Any other political subdivision of the state that is a grantee or subgrantee receiving funds provided by the United States Department of Housing and Urban Development under the Community Development Block Grant program, the Emergency Solutions Grants program, the HOME Investment Partnerships program, or the Housing Opportunities for Persons With AIDS program.90 Segregation
A condition within the program participant’s geographic area of analysis....in which there is a high concentration of persons of a particular race, color, religion, sex, familial status, national origin, or having a disability or a type of disability in a particular geographic area when compared to a broader geographic area.91
89 Ibid.
90 Gov. Code, § 8899.50, subd. (a)(2).
91 24 C.F.R. §5.152 (2016).
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Dissimilarity and Isolation Index Formulas
Dissimilarity Index: This index measures the evenness with which two groups (frequently defined on racial or ethnic characteristics) are distributed across the geographic units, such as block groups within a community. The index ranges from 0 to 100, with 0 meaning no segregation and 100 indicating complete segregation between the two groups. The index score can be understood as the percentage of one of the two groups that would need to move to produce an even distribution of racial/ethnic groups within the specified area. An index score above 60 is considered high (i.e.:
60 percent of people would need to move to eliminate segregation), while 30 to 60 is considered moderate, and below 30 is considered low.92
The formula for calculating the dissimilarity index, by Census block group, is as follows:
● Pig is the population of group g in Census block group i ● Pih is the population of group h in Census block group i ● Pg is the total population of group g in the City
● Ph is the total population of group h in the City
Isolation Index: Ranging from 0 to 100, the isolation index represents the percentage of residents of a given race or ethnicity in a block group where the average resident of that group lives, correcting for the fact that this number increases mechanically with that group’s share of the overall citywide population. Using Hispanic or Latino residents as an example, an aggregate isolation index of 40 indicates that the average Hispanic or Latino resident lives in a block group where the Hispanic share of the population exceeds the overall citywide average by roughly 40 percent. Isolation index values that equal close to zero indicate that members of that BIPOC group live in relatively integrated neighborhoods.93 94
The formula for calculating the isolation index, by Census block group, is as follows:
● Pig is the population of group g in Census block group i ● Pit is the total population in Census block group i
● Pg is the total population of group g in the City
● Pt is the total population in the City
92 Massey, D.S. and N.A. Denton. (1993). American Apartheid: Segregation and the Making of the Underclass. Cambridge, MA: Harvard University Press.
93 HUD. (2013). AFFH Data Documentation. Available at: http://www.huduser.org/portal/publications/pdf/FR-5173-P-01_AFFH_data_ documentation.pdf
94 Glaeser, E. and Vigdor, J. (2001). Racial Segregation in the 2000 Census: Promising News. Washington, DC: The Brookings Institution, Center on Urban and Metropolitan Policy. Available at: https://www.brookings.edu/wp-content/uploads/2016/06/glaeser.pdf ITEM 3- ATTACHMENT 4
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Local jurisdictions should use the dissimilarity index and/or isolation index tools as part of the needs assessment to help to understand where there are areas of segregation in the community and highlight needs for housing element policies and programs to help reduce segregation. Dissimilarity index and Isolation index values for census tracts within the jurisdiction can be mapped thematically to highlight areas with high levels of segregation. This will highlight locations within the community where there are needs for housing element policies and programs to promote better racial and ethnic integration and reduce segregation.
Examples of Contributing Factors to Fair
Housing Issues by Area
Outreach
● Lack of a variety of media (e.g., meetings, surveys, stakeholder interviews) ● Lack of marketing community meetings
● Lack of meetings at various times
● Lack of accessibility to draft documents
● Lack of language access
● Lack of accessible forums (e.g., webcast, effective communication, reasonable accommodation procedures)
Fair Housing Enforcement and Outreach Capacity
● Lack of local private fair housing outreach and enforcement ● Lack of local public fair housing enforcement
● Lack of resources for fair housing agencies and organizations ● Lack of state or local fair housing laws to support strong enforcement ● Unresolved violations of fair housing or civil rights law (including challenges to protect the constitutional and statutory rights of unhoused people) Segregation and Integration
● Community opposition
● Displacement of residents due to economic pressures
● Lack of community revitalization strategies
● Lack of private investments in specific neighborhoods ● Lack of public investments in specific neighborhoods, including services or amenities ● Lack of regional cooperation
● Land use and zoning laws
● Lending discrimination
● Location and type of affordable housing
● Occupancy codes and restrictions
● Private discrimination
● Source of income discrimination
● Lack of tenant protections
● Harassment
● Lack of supportive housing in community-based settings ● Policing and criminalization
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Racially and Ethnically Concentrated Areas of Poverty
● Community opposition
● Deteriorated and abandoned properties
● Displacement of residents due to economic pressures
● Lack of community revitalization strategies
● Lack of private investments in specific neighborhoods ● Lack of public investments in specific neighborhoods, including services or amenities ● Lack of regional cooperation
● Land use and zoning laws
● Location and type of affordable housing
● Occupancy codes and restrictions
● Private discrimination
● Lending discrimination
● Policing and criminalization
Disparities in Access to Opportunity
● Access to financial services
● The availability, type, frequency, and reliability of public transportation ● Lack of private investments in specific neighborhoods ● Lack of public investments in specific neighborhoods, including services or amenities ● Lack of regional cooperation
● Land use and zoning laws
● Lending discrimination
● Location of employers
● Location of environmental health hazards
● Location of proficient schools and school assignment policies ● Location and type of affordable housing
● Occupancy codes and restrictions
● Private discrimination
● Policing and criminalization
Disparities in Access to Opportunity for Persons with Disabilities ● Access to proficient schools for persons with disabilities ● Access to publicly supported housing for persons with disabilities ● Access to transportation for persons with disabilities ● Inaccessible government facilities or services
● Inaccessible sidewalks, pedestrian crossings, or other infrastructure ● Lack of affordable in-home or community-based supportive services ● Lack of affordable, accessible housing in range of unit sizes ● Lack of affordable, integrated housing for individuals who need supportive services ● Lack of assistance for housing accessibility modifications ● Lack of assistance for transitioning from institutional settings to integrated housing ● Land use and zoning laws
● Lending discrimination
● Location of accessible housing
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● Occupancy codes and restrictions
● Lack of effective accommodations for unhoused people with disabilities ● Regulatory barriers to providing housing and supportive services for persons with disabilities ● State or local laws, policies, or practices that discourage individuals with disabilities from being placed in or living in apartments, family homes, and other integrated settings ● Policing and criminalization (especially people with mental disabilities or neurodivergent individuals) Disproportionate Housing Needs, Including Displacement Risks ● The availability of affordable units in a range of sizes ● Displacement of residents due to economic pressures
● Lack of private investments in specific neighborhoods ● Lack of public investments in specific neighborhoods, including services or amenities ● Lack of renter protections
● Lack of protections for mobilehome park residents
● Land use and zoning laws
● Lending discrimination
● Lack of rental relief programs for people at risk of homelessness Site Inventory
● Community opposition
● Lack of community revitalization strategies
● Lack of private investments in specific neighborhoods ● Lack of public investments in specific neighborhoods, including services or amenities ● Lack of regional cooperation
● Land use and zoning laws
● Local policies or practices (e.g., councilmember veto) ● Location and type of affordable housing
● Private discrimination
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Sample Contributing Factors & Actions Matrix
Identified Fair
Housing Issue
Contributing
Factor
Priority
(high, medium, low) Meaningful Action
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Examples of Affirmatively Furthering Fair
Housing Actions
Housing Mobility Strategies consist of removing barriers to housing in areas of opportunity and strategically enhancing access. Examples include:
● Voucher mobility
● Housing mobility counseling
● City-wide affordable rental registries
● Landlord outreach to expand the location of participating voucher properties ● Landlord education and outreach on source of income discrimination and voucher programs ● Assistance with security deposits and moving expenses for voucher holders and other low-income tenants ● Extend search times for particular groups with housing choice vouchers, such as larger families with children or persons with disabilities
● Regional cooperation and administration of vouchers (such as through portability and shared waiting lists);
● Affirmative marketing can be targeted at promoting equal access to government-assisted housing or to promote housing outside the immediate neighborhood to increase awareness and the diversity of individuals in the neighborhood
● Collaborate with high performing school districts to promote a diversity of students and staff to serve lower income students
● Developing multifamily housing opportunities95
● Encouraging the development of four or more units in a building ● Encouraging collaboration between local governments and community land trusts as a mechanism to develop affordable housing in higher-opportunity areas.96 ● Accessibility programs focus on improving access to housing, transit, public buildings and facilities, sidewalks, pedestrian crossings, and businesses New Housing Choices and Affordability in Areas of Opportunity means promoting housing supply, choices and affordability in areas of high opportunity and outside of areas of concentrated poverty. Examples include:
● Zoning, permit streamlining, fees, incentives and other approaches to increase housing choices and affordability (e.g., duplex, triplex, multifamily, accessory dwelling units, transitional and supportive housing, group homes) in high opportunity areas ● Target housing creation or mixed income strategies (e.g., funding, incentives, policies and programs, density bonuses, land banks, housing trust funds) ● Inclusionary requirements
95 The federal FHA includes design and construction requirements for all residential buildings with four or more attached units. In buildings with stairs, all ground floor units must be accessible, and in buildings with elevator access, all units must have minimum access. There is no federally mandated standard for accessibility in single family homes. Government Code section 12955.1, subdivision (b), requires 10 percent of units in multifamily buildings without elevators consisting of 3 or more rental units or 4 or more condominium units are subject to accessibility building standards.
96 See Community Land Trusts and Stable Affordable Housing, available at https://www.huduser.gov/portal/pdredge/pdr-edge-featdarticle-110419.html, last visited on March 19, 2021.
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● Scattered site affordable development
● Targeted investment and programs, including sweat equity, down payment assistance, new rental construction
● Accessibility modification programs and other measures that proactively enhance accessibility ● Increase accessible number of units above state law through incentives, policies, funding and other similar measures
● Developing waiting lists for persons with disabilities, such as coordination with regional centers for developmental services and targeting those lists to property owners or homeowners making units (e.g., ADUs) available
● Leveraging in-home or community based supportive services ● Develop a campaign to combat local opposition
● Increase number of ADUs allowed per site
● Increasing opportunities for community ownership of housing Place-based Strategies to Encourage Community Conservation and Revitalization Involves approaches that are focused on conserving and improving assets in areas of lower opportunity and concentrated poverty such as targeted investment in neighborhood revitalization, preserving or rehabilitating existing affordable housing, improving infrastructure, schools, employment, parks, transportation and other community amenities. Examples include:
● Targeted investment in areas of most need focused on improving community assets such as schools, recreational facilities and programs, social service programs, parks, streets, active transportation and infrastructure ● Develop a proactive code enforcement program that targets areas of concentrated rehabilitation needs, results in repairs and mitigates potential cost, displacement and relocation impacts on residents
● Dedicate or seek funding to prioritize basic infrastructure improvements (e.g., water, sewer) in disadvantaged communities
● Address negative environmental, neighborhood, housing and health impacts associated with siting and operation of land uses such as industrial, agricultural, waste storage, freeways, energy production, etc. in disadvantaged communities
● Address negative impacts from climate change through investments in adaptation measures such as urban forestry, flood prevention measures, etc. in disadvantaged communities ● Target acquisition and rehabilitation to vacant and blighted properties in neighborhoods of concentrated poverty
● Inter-governmental coordination on areas of high need ● Prioritized capital improvement programs
● Develop new financing
● Recruit residents from areas of concentrated poverty to serve on boards, committees, task forces and other local government decision-making bodies
● Catalyze leadership and future community wide decision-makers, including affirmative recruitment in hiring practices ● Leverage private investment for community revitalization, including philanthropic ● Expand access to community meetings, including addressing language barriers, meeting times ITEM 3- ATTACHMENT 4
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Protecting Existing Residents from Displacement comprises strategies that protects residents in areas of lower or moderate opportunity and concentrated poverty and preserves housing choices and affordability. Examples include:
● First right of return to existing residents and policies that include moving expenses ● Multi-lingual tenant legal counseling
● Affirmative marketing strategies or plans targeting nearby neighborhoods, a Disadvantaged Community or a Low-Income Community
● Replacement requirements in targeted growth areas such as transit stations, transit corridors, job and housing rich areas, downtowns and revitalization areas or policies on sites identified to accommodate the housing needs of lower income households ● Rent stabilization programs beyond what is required by California Civil Code 1946.2 ● Just cause eviction or other efforts improving tenant stability beyond what is required by California Civil Code 1946.2 ● Policies to preserve Single Room Occupancy (SRO) housing or mobilehome parks ● Condominium conversion restrictions
● Land banking programs actively receiving funding
● Community benefit zoning and/or other land value recapture strategy ● Rent review board and/or mediation, foreclosure assistance, or multilingual tenant legal counseling services ● Density bonus ordinances that expand on state replacement requirements ● Implementation of an overlay zone to protect and assist small businesses ● Establishment of a small business advocate office and single point of contact for every small business owner;
● Creation and maintenance of a small business alliance; ● Increased visibility of the jurisdiction’s small business assistance programs; ● Formal program to ensure that some fraction of a jurisdiction’s purchases of goods and services come from local businesses
● Prioritization of Minority and Women Business Enterprises (MWBE) for public contracting ● Environmental contamination mitigation and hazard mitigation measures such as seismic retrofits, flood adaptation measures, etc. to prevent displacement from disasters ● Eliminating crime-free or nuisance ordinances or programs that result in penalties to landlords and evictions of tenants
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Sample Tables
Regional Comparisons
Population by Race/Ethnicity
City County Region/State
2010 2018 2010 2018 2010 2018
White (Non-Hispanic)
Hispanic/Latino
Black or African American
Native American
Asian
Native Hawaiian and Other Pacific Islander
Other
Two or More Races
Population by Disability Type
City County Region/State
2010 2018 2010 2018 2010 2018
Total with a Disability
» Hearing Difficulty
» Vision Difficulty
» Cognitive Difficulty
» Ambulatory Difficulty
» Self-care Difficulty
» Independent Living
Source: XXXXXXXXX
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76 California Department of Housing and Community Development Affirmatively Furthering Fair Housing
Housing Units by Type
City County Region/State
2010 2018 2010 2018 2010 2018
Single Family-Detached
Single Family-Attached
2-4 Units
5+ Units
Mobilehomes
Other
Source: XXXXXXXXX
Population by Familial Status
City County Region/State
2010 2018 2010 2018 2010 2018
Family Households
» Married-Couple Family Households
• With Children
• Without Children
» Other Family Households
• With Children
• Without Children
Non-family Households
Source: XXXXXXXXX
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California Department of Housing and Community Development 77 Affirmatively Furthering Fair Housing
Households by Income
City County Region/State
2010 2018 2010 2018 2010 2018
Less than $10,000
$10,000-$14,999
$15,000-$24,999
$25,000-$34,999
$35,000-$49,999
$50,000-$74,999
$75,000-$99,999
$100,000-$149,999
$150,000-$199,999
$200,000 or More
Median Income
Source: XXXXXXXXX
Households by Overpayment
City County Region/State
2010 2018 2010 2018 2010 2018
Owner Households (All Low Income
Levels 0-80% AMI)
Paying >30%
Paying >50%
Renter Households (All Low Income
Levels 0-80% AMI)
Paying >30%
Paying >50%
Owner Households (Extremely Low
Income Levels 0-30% AMI)
Paying >30%
Paying >50%
Renter Households (Extremely Low
Income Levels 0-30% AMI)
Paying >30%
Paying >50%
Source: XXXXXXXXX
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78 California Department of Housing and Community Development Affirmatively Furthering Fair Housing
Households by Tenure
City County Region/State
2010 2018 2010 2018 2010 2018
Owner Households
Renter Households
Total Households
Source: XXXXXXXXX
Households by Overcrowding
City County Region/State
2010 2018 2010 2018 2010 2018
Owner Households
» 1.01 to 1.50 occupants per room
» 1.51 to 2.00 occupants per room
» 2.01 or more occupants per room
Renter Households
» 1.01 to 1.50 occupants per room
» 1.51 to 2.00 occupants per room
» 2.01 or more occupants per room
Total Households
Source: XXXXXXXXX
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California Department of Housing and Community Development 79 Affirmatively Furthering Fair Housing
List of Fair Housing Assistance Organizations
Name Service Area Address Phone Website
California
Department of Fair
Employment and
Housing
California 2218 Kausen Dr. Ste. 100
Elk Grove, CA 95758
916-478-7251 https://www.dfeh.
ca.gov/
Greater Bakersfield
Legal Assistance, Inc.
Kern County, CA 615 California Ave.
Bakersfield, CA 93304
661-325-5943 http://www.gbla.org/
Fair Housing Council of
Central California
Alpine, Amador, Butte, Calaveras,
Colusa, El Dorado, Fresno, Glenn,
Inyo, Kern, Kings, Lassen, Madera,
Mariposa, Merced, Modoc, Mono,
Nevada, Placer, Plumas, Sacramento,
San Joaquin, San Luis Obispo,
Shasta, Siskiyou, Solano, Stanislaus,
Sutter, Tehama, Trinity, Tulare,
Tuolumne, Yolo, Yuba
333 W. Shaw Ave. Ste. 14
Fresno, CA 93704
559-244-2950 http://www.fhc-cc.org/
index.html
Mental Health
Advocacy
Services, Inc.
Los Angeles area 3255 Wilshire Blvd. Ste. 902
Los Angeles, CA 90010
213-389-2077 http://mhas-la.org/
Southern California
Housing Rights Center
The City of Los Angeles, Los
Angeles County, Antelope Valley, &
Ventura County
3255 Wilshire Blvd. 1150 Los
Angeles, CA 90010
213-387-8400 http://www.hrc-la.org/
default.asp?id=6
Housing and Economic
Rights Advocates
State of California 1814 Franklin St. Ste. 1040
Oakland, CA 94612
510-271-8443 http://www.heraca.org/
Bay Area Legal Aid San Rafael, Napa, Richmond,
Oakland, San Francisco, Redwood
City, & San Jose
1735 Telegraph Ave.
Oakland, CA 94612 510-663-4755 https://baylegal.org/
1025 Macdonald Ave,
Richmond, CA 94801 510-233-9954
575 Lincoln Ave., Ste. 210,
Napa, CA 94558 707-259-0579
1800 Market St., 3rd Floor,
San Francisco, CA 94102 415-982-1300
1038 El Camino Real, Ste. A,
Redwood City, CA 94063 650-358-0745
4 N. Second St., Ste. 600,
San Jose, CA 95113 408-283-3700
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80 California Department of Housing and Community Development Affirmatively Furthering Fair Housing
Name Service Area Address Phone Website
California Rural Legal
Assistance
California 1430 Franklin St., Ste. 103
Oakland, CA 94612 1-800-337-0690 https://www.crla.org/
141 A Street, Suite D. Arvin,
CA 93203 661-854-3839
1460 6th Street, P.O. Box
35Coachella, CA 92236 760-398-7261
601 High St., Ste. C Delano,
CA 93215 661-725-4350
449 Broadway St. El Centro,
CA 92243 760-353-0220
3747 E. Shields Ave. Fresno,
CA 93726 559-441-8721
126 North "B" St. Madera,
CA 93638 559-674-5671
511 "D" St. Marysville, CA
95901 530-742-5191
1020 15th St, Ste. 20,
Modesto, CA 95354 209-577-38811
338 "A" St. Oxnard, CA
93030 805-486-1068
3 Williams Rd. Salinas, CA
93905 831-757-5211
175 Santa Rosa St. San Luis
Obispo, CA 93405 805-544-7994
2050 South Broadway Ste. G
Santa Maria, CA 93454 805-922-4564
1160 N. Dutton Ave., Ste. 105
Santa Rosa, CA 95401 707-528-9941
145 E. Weber Ave. Stockton,
CA 95202 209-946-0605
640 Civic Ctr. Dr. #108, Vista,
CA 92084 760-966-0511
21 Carr St. Watsonville, CA
95076 831-724-2253
CSA San Diego County San Diego County, CA 131 Avocado Ave. El Cajon, CA 92020
619-444-5700 https://www.c4sa.org/
Eden Council of Hope
& Opportunity
Alameda, Contra Costa, and
Monterey Counties, and the Cities
of Alameda, Antioch, Concord,
Hayward, Livermore, Monterey,
Oakland, Pleasanton, Richmond,
Salinas, San Leandro, Seaside, Union
City, and Walnut Creek
770 A Street, Ste. 204,
Hayward, CA 94541 510-581-9380 www.echofairhousing.
org
301 W. 10th St. Antioch, CA
94509 925-732-3919
141 N. Livermore Ave.
Livermore, CA 94550 925-583-5992
1305 Franklin St. #305
Oakland, CA 94612 510-496-0496
570 Pacific St. Monterey, CA
93940 831-566-0824
168 W. Alisal St. Salinas, CA
93901 831-566-0824
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California Department of Housing and Community Development 81 Affirmatively Furthering Fair Housing
Name Service Area Address Phone Website
Fair Housing
Advocates of Northern
California
Marin County and Sonoma Counties;
cities of Fairfield and Vallejo
1314 Lincoln Ave. Ste. A San
Rafael, CA 94901
415-457-5025 http://www.
fairhousingnorcal.org/
Fair Housing Council of
Orange County
Orange County, CA 1516 Brookhollw Dr., Ste. A
Santa Ana, CA 92705
714-569-0823 https://www.
fairhousingoc.org/
Fair Housing Council of
Riverside County
Riverside County (all jurisdictions),
Moreno Valley, Corona, Temecula,
Palm Springs, Palm Desert, Perris,
Jurupa Valley, Hemet, Menifee
4164 Brockton Ave. Riverside,
CA 92501
951-682-6581 https://fairhousing.net/
23890 Alessandro Blvd.,
Suite A1 Moreno Valley, Ca
92553
190 W. Amado Rd. Palm
Springs, CA 92262
650 Main St. Corona, CA
92882
Fair Housing Council of
San Diego
San Diego Region 9845 Erma Rd., Ste. 300 San
Diego, CA 92131
619-699-5888 https://fhcsd.com/
Fair Housing Council of
the San Fernando Valley
Los Angeles County, primarily in the
San Fernando Valley
14621 Titus St., Ste. 100
Panorama City, CA 91402
818-373-1185 http://www.fhcsfv.com/
Fair Housing
Foundation
Aliso Viejo, Bellflower, Buena Park,
Compton, Costa Mesa, Downey,
Fullerton, Garden Grove, Garden,
Huntington Beach, Huntington
Park, Irvine, La Habra, Long
Beach, Lynwood, Mission Viejo,
Newport Beach, Norwalk, Orange,
Paramount, San Clemente, South
Gate, Tustin, Westminster
3605 Long Beach Blvd.,
Ste 302 Long Beach, CA
90807
(800) 446 - FAIR
(3247) Deaf or
hard of Hearing
TTY (800)
855-7100
https://fhfca.org/
2300 E Katella Ave., Ste 405
Anaheim, CA 92806
Fair housing Napa
Valley
Napa County, CA 1804 Soscol Avenue, Ste.
203, Napa, CA 94559
707-224-9720 https://napafairhousing.
org/
Fair Housing of Sonoma
County at Petaluma
Petaluma 1500 Petaluma Blvd., South
Ste A Petaluma, CA 94952
707-765-8488 https://petalumapeople.
org/housing/
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82 California Department of Housing and Community Development Affirmatively Furthering Fair Housing
Name Service Area Address Phone Website
Housing Equity Law
Project
Northern California 180 S. Spruce Ave., Ste. 250
San Francisco, CA 94080
415-434-9400 http://www.
housingequality.org/
Housing Rights Center Los Angeles County, Antelope
Valley, & Ventura County
3255 Wilshire Blvd. 1150 Los
Angeles, CA 90010
213-387-8400 https://www.
housingrightscenter.org/
6320 Van Nuys Blvd., Ste. 311
Van Nuys, CA 91402
Jackie Robinson Center 1020
N. Fair Oaks Ave. Pasadena,
CA 91103
1015 N. Lake Ave., Ste. 100
Pasadena, CA 91104
Inland Fair Housing and
Mediation Board
San Bernardino, Riverside, and
Imperial Counties
1500 S. Haven Ave., Ste. 100
Ontario, CA 91761
800-321-0911 https://www.ifhmb.com/
225 W. Hospitality Ln.,
Ste. #207 San Bernardino, CA
92408
15248 Civic Dr., Ste. #225
Victorville, CA 92392
82921 Indo Blvd. Indio, CA
92201
444 S. 8th St., Ste. #C-1A El
Centro, CA 92243
Legal Aid Society of
San Diego
San Diego County, CA 110 S. Euclid Ave. San Diego,
CA 92114
1-844-449-3500 https://www.lassd.org/
1764 San Diego Ave., Ste.
100 San Diego, CA 92110
216 S. Tremont St.
Oceanside, CA 92054
Project Sentinel Northern California 1490 El Camino Real, Santa Clara, CA 95050
408-470-3739 https://www.housing.
org/
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Bibliography
AFFH Rule and Assessments
Assembly Bill 686
California State Legislature. September 30, 2018 Bill text for California’s Affirmatively Furthering Fair Housing law. HCD AB 686 Summary of Requirements in Housing Element Law Memorandum (April 2020)
Affirmatively Furthering Fair Housing: California’s New Law (PDF) National Housing Law Project. 2019. 2 pp.
Summarizes Assembly Bill 686, California’s Affirmatively Furthering Fair Housing Law.
Affirmatively Furthering Fair Housing Final Rule (PDF)
Federal Register. 2015. 101 pp.
AFFH Rule Guidebook (PDF)
U.S. Dept of Housing and Urban Development (HUD). 2015. 222 pp.
California Department of Housing and Community Development Final 2020 Analysis of Impediments to Fair Housing Choice (PDF)
Executive Summary. June 2020. 10 pp.
California Department of Housing and Community Development Final 2020 Analysis of Impediments to Fair Housing Choice – Final AI 425 Chapter 13: Impediments to Fair Housing Choice (PDF)
June 2020. 9 pp.
Furthering Fair Housing
National Fair Housing Alliance
Summarizes the Obama administration’s AFFH Rule and provides update on the rule change.
Furthering Fair Housing
Massachusetts Institute of Technology, Department of Urban Studies and Planning. This website provides a clearinghouse of assessments of fair housing completed during the implementation of the HUD AFFH Rule, sample goals, and articles detailing research on implementation of the HUD AFFH Rule and related topics.
Policy Objective: Affirmatively Furthering Fair Housing Local Housing Solutions.
This web article provides suggestions for improving access to opportunity through place-based strategies, mobility strategies (including inclusionary zoning), and specific policies detailed in a housing policy toolkit.
National Housing Law Project (NHLP)
These resources provide context regarding the Obama administration’s implementation of the 2015 federal AFFH rule.
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● AFFH Implementation: An Update for Advocates (PDF) 2016. ● AFFH Glossary (PDF) 2016.
● Assessment of Fair Housing Advocate Participation Checklist (PDF) 2016.
Assessment of Fair Housing Plan (PDF)
City of Los Angeles & The Housing Authority of the City of Los Angeles.
Prepared by Enterprise Community Partners and the Lawyers Committee. Nov. 6, 2017. 434 pp.
NLIHC: Assessment Tools
National Low-Income Housing Coalition.
NLIHC makes available assessment tools from the Obama administration’s AFFH rule. Included are Assessment Tools for Localities and PHAs as well as a Proposed Assessment Tool for States.
PRRAC: Affirmatively Furthering Fair Housing
Poverty & Race Research Action Council (PRRAC) provides multiple samples and tools for conducting an Analysis of Impediments/Assessment to Fair Housing Choice. Also includes background information on AFFH plus comment letters and news stories regarding the termination of the rule.
Preserving Community and Neighborhood Choice (PDF)
HUD. 2020. 57 pp.
This presents HUD’s new rule, which replaces the 2015 Affirmatively Furthering Fair Housing rule, terminated by HUD in 2020.
Federal Guidance
Joint Statement of HUD and DOJ on State and Local Land Use Laws and Practices and the Application of the Fair Housing Act (PDF)
U.S. Dept. of Justice (DOJ). November 10, 2016. 20pp.
Office of General Counsel Guidance on Application of Fair Housing Act Standards to the Use of Criminal Records by Providers of Housing and Real Estate-Related Transactions (PDF) HUD. April 4, 2016. 10 pp.
Joint Statement of HUD and DOJ on Reasonable Accommodations Under the Fair Housing Act (PDF)
HUD. May 17, 2004. 15 pp.
Fair Housing Enforcement – Occupancy Standards; Notice of Statement of Policy (PDF) Federal Register. December 22, 1998. 7 pp.
Office of General Counsel Guidance on Fair Housing Act Protections for Persons with Limited English Proficiency (PDF)
HUD. September 15, 2016. 9 pp.
The guidance clarifies that discrimination against people in housing transactions based on the language they speak can be considered discrimination under the Fair Housing Act.
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Equal Access in Accordance with an Individual’s Gender Identity in Community Planning and Development Programs; Final Rule
Federal Register. September 21, 2016.
Equal Access to Housing in HUD Programs Regardless of Sexual Orientation or Gender Identity; Final Rule
Federal Register. February 3, 2012.
Olmstead: Community Integration for Everyone
DOJ, Civil Rights Division. Information and Technical Assistance on the Americans with Disabilities Act
This is an overview of the 1999 Supreme Court decision regarding Title II of the Americans with Disabilities Act. The decision requires states to place qualified people with mental disabilities in community settings rather than institutional ones.
Joint Statement of HUD and DOJ on Reasonable Modifications Under the Fair Housing Act (PDF)
HUD. March 5, 2008. 18 pp.
Joint Letter to Local Colleagues (PDF)
U.S. Departments of Education; Transportation; and Housing and Urban Development. June 3, 2016. 3 pp.
This joint letter calls on “local education, transportation, and housing leaders to work together on issues at the intersection of our respective missions in helping to guarantee full access to opportunity across the country.” It lays out the original vision of the AFFH rule as being one of coordination among agencies that provide access to opportunity.
Data & Maps
CalEnviroScreen
California Office of Environmental Health Hazard Assessment.
This mapping tool helps identify California communities that are most affected by several sources of pollution.
California Health Interview Survey
University of California, Los Angeles, Center for Health Policy Research. “The California Health Interview Survey (CHIS) is the nation's largest state health survey and a critical source of data on Californians as well as on the state's various racial and ethnic groups.” California Healthy Places Index
This site maps by zip code the following conditions: economic, education, housing, healthcare access, neighborhood, and clean environment.
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California Neighborhood Change Maps
Urban Displacement Project. Text, data, and color-coded maps. ● Mapping Displacement, Gentrification, and Exclusion in the San Francisco Bay Area Updated in 2018.
● Mapping Neighborhood Change in Southern California: Los Angeles, Orange, and San Diego Counties Updated in 2020 with new layers reflecting COVID-19 vulnerabilities.
Data and Tools for Fair Housing Planning
Urban Institute. July 2020.
Provides downloadable files of Affirmatively Furthering Fair Housing data and guidelines pertaining to the 2015 rule, thus offering assistance for states still pursuing these goals.
Mapping Inequality: Redlining in New Deal America
University of Richmond Digital Scholarship Lab.
Provides historic Home Owners Loan Corporation (HOLC) maps that were color coded to reflect the mortgage security potential of various neighborhoods. These maps and their coding provided a tool for redlining that made it difficult or impossible for people in certain areas to access mortgage financing to become homeowners. The maps “allow and encourage you to grapple with this history of government policies contributing to inequality.”
National Equity Atlas
“America's most detailed report card on racial and economic equity. We equip movement leaders and policymakers with actionable data and strategies to advance racial equity and shared prosperity.” Opportunity Insights: The Economic Tracker
Harvard University.
Data, research, and policy recommendations. “Our mission is to identify barriers to economic opportunity and develop scalable solutions that will empower people throughout the United States to rise out of poverty and achieve better life outcomes.” This data is currently focused on the economic impacts of the COVID-19 pandemic.
TCAC/HCD Opportunity Maps - California
HCD, Treasurer of the State of California | California Tax Credit Allocation Committee, and The Institute of Othering and Belonging, U.C. Berkeley.
PolicyMap
PolicyLink. 2017.
Uses 2010 Census to map a variety of measurements, including demographics, income, and housing.
Race Counts
Race Counts measures the overall performance, amount of racial disparity, and impact by population size of counties and cities in California.
Urban Displacement Project
Articles, reports, and policy briefs; gentrification and displacement maps of several metropolitan areas; UCLA and UC Berkeley case studies of Los Angeles and San Francisco Bay Area neighborhoods.
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Using Data to Assess Fair Housing and Improve Access to Opportunity: A Guidebook for Community Organizations (PDF)
L. Hendey & M. Cohen. Urban Institute. 2017. 64 pp.
Videos
Affirmatively Furthering Fair Housing in California: Prioritizing Fair Housing Goals in Planning for the State’s Housing Needs
(Opens to page with embedded recording of Webinar. Run time: 1 hour 27 min.) Terner Center for Housing Innovation, U.C. Berkeley. 2020.
Webinar panel discussion featuring Gillian Adams, Arthur Gailes, and Annelise Osterberg, moderated by Terner Center Managing Director Ben Metcalf, with opening remarks by HCD’s Director, Gustavo Velasquez.
Segregated by Design
M. Lopez, Director. Silkwood Studios. 2019. Run time: 17 min. 42 sec.
This animated video, narrated by Richard Rothstein, “examines the forgotten history of how our federal, state and local governments unconstitutionally segregated every major metropolitan area in America through law and policy.”
Books
The Color of Law: A Forgotten History of How Our Government Segregated America R. Rothstein. New York: Liveright Publishing Corp., 2017. 345 pp.
Examines the historical segregation of housing due to governmental policies and real estate and mortgage industry practices. Analyzes the impact this has on neighborhoods today regarding environmental justice and access to quality schools, public transportation, jobs, parks, and other opportunities.
The One-way Street of Integration: Fair Housing and the Pursuit of Racial Justice in American Cities.
E.G. Goetz. Ithaca, NY: Cornell University Press, 2018. 228 pp.
From the bookseller’s website: “Goetz traces the tensions involved in housing integration and policy to show why he doesn't see the solution to racial injustice as the government moving poor and nonwhite people out of their communities.”
Race for Profit: How Banks and the Real Estate Industry Undermined Black Homeownership Keeanga-Yamahtta Taylor. Chapel Hill: University of North Carolina Press, 2019. 368 pp.
From the publisher’s website: “Race for Profit uncovers how exploitative real estate practices continued well after housing discrimination was banned. The same racist structures and individuals remained intact after redlining’s end, and close relationships between regulators and the industry created incentives to ignore improprieties.”
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Segregation by Design: Local Politics and Inequality in American Cities J. Trounstine. Cambridge: Cambridge University Press, 2018. 277 pp.
From the publisher’s website: “Segregation by Design draws on more than 100 years of quantitative and qualitative data from thousands of American cities to explore how local governments generate race and class segregation.”
Research Articles & Reports
Affirmatively Furthering Fair Housing: A Reckoning with Government-Sponsored Segregation in the 21st Century
(Links to page with free PDF download.)
S. Menendian. National Civic Review 106(3): 20-27. 2017.
Affirmatively Furthering Fair Housing for People with Disabilities: Recommendations and Best Practices for Municipalities (PDF)
A. Ballard. Access Living of Metropolitan Chicago. n.d.
This 18-slide presentation defines barriers to housing for people with disabilities and provides solutions.
“Affirmatively Further Fair Housing: California’s Response to a Changing Federal Landscape” R. Williams. Journal of Affordable Housing & Community Development Law 28(3): 387-396. 2019.
America’s Formerly Redlined Neighborhoods Have Changed, and So Must Solutions to Rectify Them
(Links to page with button for free PDF download.)
A.M. Perry & D. Harshbarger. Brookings. 2019. 20 pp.
The population currently living in what were once HOLC “redlined” neighborhoods is majority-BIPOC but not majority-Black, and, contrary to conventional perceptions, Black residents also do not form a plurality in these areas overall.
Antisubordination Planning
(Links to page with full-text download.)
J. Steil. Journal of Planning Education and Research. 2018. “Beyond People Versus Place: A Place-Conscious Framework for Investing in Housing and Neighborhoods”
M.A. Turner. Housing Policy Debate 27(2), 306-314. 2017.
This paper offers five principles for ongoing experimentation and knowledge building: (a) develop citywide strategies that promote both inclusion and redevelopment; (b) anticipate and plan for residential mobility and neighborhood change; (c) connect residents of poor neighborhoods to city and regional opportunities; (d) capitalize on the coming rental housing boom; and (e) use data for continuous learning and accountability.
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Building a National Narrative of Anti-Displacement Strategies: Key Takeaways From SPARCCC Regions Cash, Anna, et al. Urban Displacement Project. University of California, Berkeley.
This article reviews recent gentrification and displacement literature, outlines the need for a broader neighborhood change narrative that acknowledges the role of cultural and political displacement as well as neighborhood decline in perpetuating diverse impacts in vulnerable communities. The article presents cross-site themes that emerged during site visits in dialogue with recent literature and policy initiatives focused on investment and disinvestment driven displacement, race and displacement, access to resources in communities receiving displaced residents, and the impact of climate change on neighborhoods. Finally, the article draws upon lessons from the sites to offer a national narrative of anti-displacement approaches for action across local, regional, state, and national levels.
Creating Moves to Opportunity: Experimental Evidence on Barriers to Neighborhood Choice (PDF)
P. Bergman, R. Chetty, S. DeLuca, N. Hendren, L. F. Katz, & C. Palmer. 2020. 97 pp.
The authors conclude that redesigning affordable housing policies to provide customized assistance in a housing search could reduce residential segregation and increase upward mobility substantially.
Developing Opportunity: Innovative Models for Strategic Housing Acquisition (PDF) P. Kye, M. Mouton & M. Haberle. Poverty & Race Research Action Council. 2018. 26 pp.
New initiatives provide pathways to mobility and create affordable housing by acquiring existing market-rate housing in areas of high opportunity. Authors detail programs and provide examples from Baltimore, Dallas, Chicago, and King County, Washington.
Disparate Impact and an Antisubordination Approach to Civil Rights and Urban Policy (PDF) J. Steil. Poverty & Race 28(2). 2019.
The Effects of the 1930s HOLC "Redlining" Maps
D. Aaronson, D. Hartley & B. Mazumder. Federal Reserve Bank of Chicago. 2020. 100 pp.
This working paper, begun in 2017 and revised in 2020, examines “the effects of the 1930s-era HOLC ‘redlining’ maps on the long-run trajectories of neighborhoods.” Fair Housing in Jeopardy: Trump Administration Undermines Critical Tools for Achieving Racial Equity (PDF)
National Fair Housing Alliance. 2020. 87 pp.
Annual Fair Housing Trends report.
Forced Relocation and Residential Instability Among Urban Renters.
Desmond, M., Gershenson, C., & B. Kiviat. Social Science Review 89(2). 237-262. 2015.
From the abstract: This article reveals mechanisms of residential mobility among low-income renters, identifies previously undocumented consequences of forced displacement, and develops a more comprehensive model of residential instability and urban inequality.
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The Geography of Inequality: How Land Use Regulation Produces Segregation (PDF) J. Trounstine. American Political Science Review 114(2): 443-455. 2020.
From the abstract: “I provide evidence that more stringent land use regulations are supported by whiter communities and that they preserve racial homogeneity.” Home Equity: A Vision of Housing Security, Health and Opportunity (PDF) Colorado Health Institute. 2019. 56 pp.
This paper explores the interdependence of health outcomes; healthful, quality housing; and access to better schools, jobs, and other opportunities. It offers multiple strategies for change.
HUD’s Affirmatively Furthering Fair Housing Rule: A Contribution and Challenge to Equity Planning for Mixed Income Communities (PDF)
K.M. O’Regan & K. Zimmerman. Case Western Reserve University. 2020. 23 pp.
From the abstract: “This essay explains the framework and theory behind the rule, and how a rule aimed at overcoming racial segregation can support the creation and preservation of mixed-income communities. …We conclude with a discussion of implications for action (or at least attention) with respect to the rule, particularly with respect to mixed-income strategies.” Making Every Neighborhood a Place of Opportunity: 2018 Fair Housing Trends Report (PDF) Shanti Abdein et al. National Fair Housing Alliance. 2018. 100 pp.
From the abstract: “If everyone had access to affordable housing, fair credit, a good school, healthy food, a decent job, green space, and quality health care, how would our nation and our economy look then? How do we ensure that future generations of all backgrounds live in neighborhoods rich with opportunity? Fair housing.”
Neighborhoods for All: Expanding Housing Opportunity in Seattle’s Single-Family Zones (PDF)
City of Seattle, Planning Commission. 2018. 52 pp.
This white paper presents Seattle’s strategies for increasing access to affordable housing, transportation, and jobs for those living outside of the urban core.
A Place-Conscious Approach Can Strengthen Integrated Strategies in Poor Neighborhoods M.A. Turner. Brookings. 2015. 7 pp.
This short article is the forerunner of Turner’s Housing Policy Debate piece, above.
Place and Opportunity: Using Federal Fair Housing Data to Examine Opportunity across US Regions and Populations (PDF)
R. Gourevitch, S. Greene, and R. Pendall. Urban Institute. 2018. 24 pp.
This research brief highlights new connections between place and access to opportunity across regions and populations. The authors analyze data on neighborhood-level exposure to opportunity that the U.S. Department of Housing and Urban Development originally released in 2015 to help local communities reduce segregation and comply with the Fair Housing Act.
Pricing Roads, Advancing Equity (PDF)
TransForm. 2019. 64 pp.
Fair housing and access to opportunity are advanced when efficient, affordable transportation is available.
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Promoting Opportunity through Equitable Transit-Oriented Development (eTOD): Navigating Federal Transportation Policy (PDF)
A. Abu-Khalaf. Enterprise Community Partners. 2018. 28 pp.
This report provides stakeholders involved in achieving eTOD guidance on understanding and benefitting from federal transportation policies and programs.
Promoting Opportunity through Equitable Transit-Oriented Development (eTOD): Barriers to Success and Best Practices for Implementation
(Links to page where full-text article is available via the Open Resource button.) M. Spotts. Enterprise Community Partners. 2015. 74 pp.
This report demonstrates that numerous barriers inhibit low- and moderate-income families’ ability to find housing in communities with access to robust, multi-modal transportation options. The report also makes recommendations for overcoming those barriers and highlights numerous best practices from regions across the U.S.
Promoting Opportunity through Equitable Transit-Oriented Development (eTOD): Making the Case
(Links to page where full-text article is available via the Open Resource button.) J. Hersey & M. Spotts. Enterprise Community Partners. 2015. 21 pp.
Equitable transit-oriented development (eTOD) is one tool to ensure that high-opportunity neighborhoods are inclusive despite the property value increases that often result from such investments.
Racial Disparities in Home Appreciation: Implications of the Racially Segmented Housing Market for African Americans’ Equity Building and the Enforcement of Fair Housing Policies M. Zonta. Center for American Progress. 2019. 39 pp.
“Segregation and racial disparities in home appreciation put African Americans at a disadvantage in their ability to build equity and accumulate wealth.”
Removing Barriers to Accessing High-Productivity Places (PDF) D. Shoag. The Hamilton Project: Policy Proposal 2019-02. 2019. 30 pp.
Workers without a college education are moving away from the places that offer them the highest wages and their children the best later-life outcomes. The author offers strategies that policymakers at various levels of government can use to combat this relatively new problem, including case studies of cities that have successfully expanded access at the local level.
Segregation and Neighborhood Health
J. Richardson et al. NCRC. 2020. 50 pp.
“This report examined [historically] redlined areas and how they are associated with adverse public health outcomes for a range of diseases and conditions that make people particularly susceptible to the worst effects of COVID-19.”
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Supply Skepticism: Housing Supply and Affordability
Been, V., Ingrid, E., & K. O’Regan. Housing Policy Debate 29(1), 25-40. 2019.
From the abstract: “Growing numbers of affordable housing advocates and community members are questioning the premise that increasing the supply of market-rate housing will result in housing that is more affordable. This article is meant to bridge the divide, addressing each of the key arguments supply skeptics make and reviewing what research has shown about housing supply and its effect on affordability.”
“Survival of the Fairest: Examining HUD Reviews of Assessments of Fair Housing” J.P. Steil & N. Kelly. Housing Policy Debate 29(5), 736-751. 2019.
From the abstract: “Our analysis shows that HUD engaged in detailed reviews of municipalities’ Assessments of Fair Housing and provided constructive feedback. The most common issues with which municipalities struggled were setting realistic goals that would actually advance fair housing and creating measurable metrics and milestones to gauge progress.” What Would It Take to Ensure Quality, Affordable Housing for All in Communities of Opportunity? (PDF) M.A. Turner, S. Greene, C. P. Scally, K. Reynolds & J. Choi. Urban Institute. 2019. 40 pp.
If everyone could afford quality housing, and every neighborhood offered a diversity of housing options, people up and down the income ladder could enjoy housing security and build wealth through homeownership. Achieving this calls for bold action at all levels of government and in the private and nonprofit sectors.
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Housing & Community Development
2020 W. El Camino Avenue | Sacramento, CA 95833
Phone: 916-743-2244
State Housing and Community Development Department | Housing Policy Division ITEM 3- ATTACHMENT 4
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Site Street No. Street Name Current Zoning Existing Density Proposed Zoning Proposed Density Existing Units New Net Units Realistic Capacity/Lot Realistic DU/Acre Land Area- SQ FT Acreage 24 76 Tamalpais R-1 1-6 Units R-2 12 1 2 3 7.5 17424 0.4 25 43 San Rafael R-1 1-6 Units R-2 12 2 2 4 7.5 23086.8 0.53 24 71 San Rafael R-1 1-6 Units R-2 12 1 3 4 8 21344.4 0.49 25 55 San Rafael R-1 1-6 Units R-2 12 1 2 3 8.8 14810.4 0.34 36 73 Magnolia R-1 1-6 Units R-3 30 1 1 2 15.3 5662.8 0.13 49 88 Ross R-2 6-12 Units R-3 30 1 1 2 15.38 5662.8 0.13 51 61 Woodland R-1 1-6 Units R-3 30 0 2 2 15.38 5662.8 0.13 32 63 Tamalpais R-1 1-6 Units R-3 30 1 2 3 16.66 7840.8 0.18 42 140 Pine R-1 1-6 Units R-3 30 1 1 2 16.66 5227.2 0.12 50 68 Ross R-2 6-12 Units R-3 30 1 1 2 16.66 5227.2 0.12 33 47 Tamalpais R-1 1-6 Units R-3 30 2 1 3 17.64 7405.2 0.17 33 41 Tamalpais R-1 1-6 Units R-3 30 1 2 3 17.64 7405.2 0.17 49 80 Ross R-2 6-12 Units R-3 30 2 1 3 17.64 7405.2 0.17 32 72 Magnolia R-1 1-6 Units R-3 30 1 1 2 18.18 4791.6 0.11 37 43 Magnolia R-1 1-6 Units R-3 30 1 1 2 18.18 4791.6 0.11 37 41 Magnolia R-1 1-6 Units R-3 30 1 1 2 18.18 4791.6 0.11 42 144 Pine R-1 1-6 Units R-3 30 1 1 2 18.18 4791.6 0.11 42 150 Pine R-1 1-6 Units R-3 30 1 1 2 18.18 4791.6 0.11 42 154 Pine R-1 1-6 Units R-3 30 1 1 2 18.18 4791.6 0.11 42 158 Pine R-1 1-6 Units R-3 30 1 1 2 18.18 4791.6 0.11 42 160 Pine R-1 1-6 Units R-3 30 1 1 2 18.18 4791.6 0.11 42 154 Pine R-1 1-6 Units R-3 30 1 1 2 18.18 4791.6 0.11 42 170 Pine R-1 1-6 Units R-3 30 1 1 2 18.18 4791.6 0.11 42 174 Pine R-1 1-6 Units R-3 30 1 1 2 18.18 4791.6 0.11 42 178 Pine R-1 1-6 Units R-3 30 1 1 2 18.18 4791.6 0.11 42 182 Pine R-1 1-6 Units R-3 30 1 1 2 18.18 4791.6 0.11 42 184 Pine R-1 1-6 Units R-3 30 1 1 2 18.18 4791.6 0.11 44 155 Pine R-1 1-6 Units R-3 30 1 1 2 18.18 4791.6 0.11 47 131 Pine R-1 1-6 Units R-3 30 1 1 2 18.18 5227.2 0.12 47 129 Pine R-1 1-6 Units R-3 30 1 1 2 18.18 4791.6 0.11 49 87 Woodland R-2 6-12 Units R-3 30 1 1 2 18.18 4791.6 0.11 33 43 Tamalpais R-1 1-6 Units R-3 30 1 2 3 18.75 6969.6 0.16 36 63 Magnolia R-1 1-6 Units R-3 30 2 1 3 18.75 6969.6 0.16 39 196 Tunstead R-2 6-12 Units R-3 30 1 2 3 18.75 6969.6 0.16 50 1 Cedar R-2 6-12 Units R-3 30 2 1 3 18.75 6969.6 0.16 32 77 Tamalpais R-1 1-6 Units R-3 30 1 3 4 20 8712 0.2
34 54 Magnolia R-3 20 Units R-3 30 0 3 3 20 6534 0.15
34 58 Magnolia R-1 1-6 Units R-3 30 1 2 3 20 6534 0.15
37 47 Magnolia R-1 1-6 Units R-3 30 1 1 2 20 4356 0.1
38 172 Tunstead R-2 6-12 Units R-3 30 2 1 3 20 6534 0.15 43 177 Pine R-1 1-6 Units R-3 30 1 1 2 20 4356 0.1
45 147 Pine R-1 1-6 Units R-3 30 1 1 2 20 4356 0.1
46 141 Pine R-1 1-6 Units R-3 30 1 1 2 20 4356 0.1
49 102 Ross R-2 6-12 Units R-3 30 1 3 4 20 8712 0.2
52 50 Ross R-1 1-6 Units R-3 30 1 1 2 20 4356 0.1
54 70 Mariposa R-2 6-12 Units R-3 30 1 2 3 20 6534 0.15 55 51 Ross R-1 1-6 Units R-3 30 2 2 4 21.05 8276.4 0.19 54 73 Ross R-2 6-12 Units R-3 30 1 2 3 21.4 6098.4 0.14 32 67 Tamalpais R-1 1-6 Units R-3 30 1 2 3 21.42 6098.4 0.14 35 30 Magnolia R-1 1-6 Units R-3 30 1 2 3 21.42 6098.4 0.14 54 64 Mariposa R-2 6-12 Units R-3 30 2 1 3 21.42 6098.4 0.14 32 69 Tamalpais R-1 1-6 Units R-3 30 1 4 5 21.7 10018.8 0.23 36 69 Magnolia R-1 1-6 Units R-3 30 1 3 4 22.22 7840.8 0.18 43 171 Pine R-1 1-6 Units R-3 30 1 1 2 22.22 3920.4 0.09 44 165 Pine R-1 1-6 Units R-3 30 1 1 2 22.22 3920.4 0.09 44 161 Pine R-1 1-6 Units R-3 30 1 1 2 22.22 3920.4 0.09 51 59 Woodland R-1 1-6 Units R-3 30 1 1 2 22.22 3920.4 0.09 52 48 Ross R-1 1-6 Units R-3 30 1 1 2 22.22 3920.4 0.09 54 71 Ross R-2 6-12 Units R-3 30 2 2 4 22.22 7840.8 0.18 56 97 Mariposa R-2 6-12 Units R-3 30 1 7 8 22.22 15681.6 0.36 48 110 Ross R-2 6-12 Units R-3 30 2 7 9 22.5 17424 0.4
35 36 Magnolia R-2 6-12 Units R-3 30 2 2 4 28.5 6098.4 0.14 71 103 174
ITEM 3- ATTACHMENT 5
ITEM 3- ATTACHMENT 5
673
SAN ANSELMO PUBLIC REVIEW DRAFT OF THE HOUSING ELEMENT
is Released and Available for Review, Comment, and Participation
ATTEND A MEETING AND/OR EMAIL COMMENTS ATTEND A MEETING AND/OR EMAIL COMMENTS DECEMBER 15, 2022
Housing Element Advisory
Committee Meeting
DECEMBER 19, 2022
Planning Commission
Meeting
JANUARY 10, 2023
Town Council
Meeting
COMMENTS
https://hla.fyi/q2i
The 30-day Public Comment Period is a vital step in the Housing Element Update process. This is an opportunity to participate and have a meaningful role in the planning process. Please take a moment to review the Public Review Draft of the Housing Element and provide feedback at https://www.townofsananselmo.org/1517/Housing-Element-Update or by scanning the QR Code.
SAN ANSELMO PUBLIC REVIEW DRAFT OF THE HOUSING ELEMENT
is Released and Available for Review, Comment, and Participation
ATTEND A MEETING AND/OR PROVIDE COMMENTS ATTEND A MEETING AND/OR PROVIDE COMMENTS DECEMBER 15, 2022
Housing Element Advisory
Committee Meeting
DECEMBER 19, 2022
Planning Commission
Meeting
JANUARY 10, 2023
Town Council
Meeting
COMMENTS
https://hla.fyi/q2i
The 30-day Public Comment Period is a vital step in the Housing Element Update process. This is an opportunity to participate and have a meaningful role in the planning process. Please take a moment to review the Public Review Draft of the Housing Element and provide feedback at https://www.townofsananselmo.org/1517/Housing-Element-Update or by scanning the QR Code.
ITEM 3- ATTACHMENT 6
ITEM 3- ATTACHMENT 6
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The initial Public Review Draft of the 2023-2031 Housing Element for the Town of San Anselmo is available for
30-days of public comment beginning December 12,
2022 and ending on January 10, 2023. The Public
Review Draft can be accessed on the Town’s Housing
Element Update Website and a copy of the Draft is
available at the San Anselmo Library.
This 30-day period is intended to provide the
community with an opportunity to voice their desires
and concerns for how San Anselmo can plan for housing
and meet the State’s mandate for 833 new housing
units over the next 8 years.
Attend a virtual or regular meeting
and/or share your thoughts. Scan the
QR Code for more information.
STAY INVOLVED!
SAN ANSELMO HOUSING ELEMENT
GET ENGAGED!
Town of San Anselmo
525 San Anselmo Avenue
San Anselmo, CA 94960
RESIDENT
6B BANK ST
SAN ANSELMO, CA 94960-2505
BERKELEY MEDEVICES, INC.
1330 South 51st Street, Richmond, CA 94804 U.S.A.
PRSRT STD
US POSTAGE
PAID
Hayward, CA
PERMIT No. 232
ITEM 3- ATTACHMENT 6
ITEM 3- ATTACHMENT 6
675
From: Jenny Silva
To: Heidi Scoble
Cc: [email protected]; [email protected] Subject: Town of San Anselmo Housing Element
Date: Sunday, January 8, 2023 8:27:08 AM
CAUTION: External Sender
Dear Director Scoble,
I am writing to submit my comments on the draft San Anselmo Housing Element.
Marin, like most counties in California, is suffering due to our housing shortage.
It is important that all jurisdictions do their part to help address this issue.
San Anselmo’s Housing Element includes some promising programs. However, the current draft Housing Element is insufficient in its analysis and for Affirmatively Furthering Fair Housing. I have included my comments below. They are also available in this document, which may be easier to review.
Thank you for all the hard work that went into the Housing Element. I'm especially pleased to see the inclusion of Missing Middle Housing and Objective Design and Development Standards.
I will provide some comments on the housing element as a whole, and then more detailed comments.
Sincerely,
Jennifer Silva
Volunteer, Campaign for Fair Housing Elements
Overall comments on the housing element:
San Anselmo is taking a big step forward by legalizing “missing middle” housing, including pre-approved plans, in R1 zoned areas.
Since most of San Anselmo is zoned R1, this will open up multi-family housing to much of the town. Although this is a significant and important change, we do not expect it to dramatically change the housing stock this cycle, as the rate of redevelopment of single family homes is low. I’d encourage San Anselmo to monitor the update of this program and to amend set-backs, lot sizes and/or building heights if the program is underutilized.
Objective Design and Development Standards. San Anselmo commits to 676
move to Objective Design and Development Standards for all housing types. This is a very positive response to the public comments on permitting times. This has the potential to significantly streamline the building of housing. Since this is a very different way of permitting projects, San Anselmo should monitor the program to ensure that the standards set will support the housing that is financially feasible to build.
The Site Inventory is incomplete and is missing analysis. HCD requires a site inventory list, with prescribed data points. San Anselmo has a map book, but no site list is included. There is no place that states how many units by income category are planned for on the sites. City staff has confirmed that a site inventory is being prepared for the HCD draft.
However, the lack of a site inventory makes the review of the public draft much more challenging. I’d encourage city staff to release this as soon as possible. There are two additional site inventory issues that need to be addressed:
It appears that over 50% of sites planned for lower income housing are on sites with existing uses. As such, San Anselmo must provide analysis that the existing use is likely to discontinue during the 6th housing cycle. Alameda is the only jurisdiction with a HCD-approved housing plan. Their analysis was in-depth, including conversations with land-owners, entitlements and substantial evidence that projects would happen. San Anselmo has no detailed information on its sites.
It’s possible that San Anselmo has done this analysis. If so, it needs to be included in the Housing Element. If not, it needs to be completed.
It appears that all of the sites intended for lower income housing are located either on Sir Francis Drake or Red Hill Avenue. These are major, four lane thoroughfares with
significant, fast moving traffic. This is not a distribution of affordable housing throughout the community. While
convenient to transit, living on a busy street contributes to childhood asthma and has other proven negative health effects.
Most families with small children are averse to living directly on a busy street. San Anselmo should target some affordable housing off these arterial streets.
More Detailed Comments
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prescribed zoning”. This statement is true, but it is incomplete as the prescribed zoning is a community choice. Downzoning in the 60’s and 70’s was a decision based on Supreme Court laws prohibiting explicit racial segregation. San Anselmo, along with the other Marin jurisdictions, can readily address all RHNA regulations by liberalizing its prescribed zoning. We do commend that San Anselmo moves in the right direction by upzoning multi-family areas and permitting missing-middle housing. We’d encourage San Anselmo to more clearly identify the impact of zoning on development and its roles in segregation.
stronger than many jurisdictions. According to this data, the town built more than its required units, and only missed building sufficient low-income units.
However, on Page 60, the element states that San Anselmo had 20 less housing units in 2020 than in 2010. It would be useful for San Anselmo to provide clarity here. It would also be helpful for San Anselmo to break out ADUs from nonADUs to get a stronger understanding of development trends.
San Anselmo notes the decline in lower-income households, but asserts that because population has remained stable, it’s most likely that incomes have risen rather than lower income households being pushed out. This interpretation of the data is not supported by research on gentrification.
Stable populations with rising home prices is a prime condition for displacement of low income people.
San Anselmo states strong reasoning for incentivizing larger affordable rental units. I’m really glad to see this. When I was a single mom with young children, there were very few options for 3+ bedroom housing options in Marin.
San Anselmo notes that the growing population of seniors will increase demand for senior living. All Marin jurisdictions have aging populations, and most are planning for it with ADUs and assisted living. The seniors I know that have chosen to downsize don’t want an ADU or assisted living.
They want a high end multi-family housing option, with amenities and service. Many residents complain about the development of “luxury” apartments, but this is a very good option for seniors looking to downsize.
This should be incorporated into the Housing Plan.
constraint to housing and the adoption of Objective Design and Development 678
Standards, especially for all building types, to address this.
It definitely does not reflect housing units for 2010 - 2020.
permitting process, and this explanation shows how complicated it is. While the permitting process explanation is clear, it is not clear how San Anselmo calculated the “typical” permitting times. Are these staff estimates or based on a review of permits processed? San Anselmo should provide data based on actual projects, including for projects with or without variances. If San Anselmo cannot provide this data, it should implement programs that can provide real data on how long permitting takes.
intended to be objective. This is an inaccurate description. Different people would reasonably have very different opinions on what is “functionally and aesthetically compatible with existing improvements…” San Anselmo should correctly identify these standards as subjective. The move to Objective Design and Development Standards is a significant improvement.
are included on the site inventory, by income level, compared to the RHNAs.
the site inventory across census tracts. Based on this analysis, it would appear that housing is distributed. However, the picture of the housing tells a different story. It appears that 100% of the affordable housing is on Sir Francis Drake or Red Hill Avenue. These are major, four lane thoroughfares with significant, fast moving traffic. This is not a distribution of affordable housing throughout the community. Living on a busy street contributes to asthma and has other negative health effects. Most families with small children are averse to living directly on a busy road. San Anselmo should target some affordable housing off these roads.
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saying that 5% rental vacancy rates and 2% own housing vacancy rates are healthy? Those rates sound very low. My personal experience is that the housing market in Marin is extremely tight. The Zillow data seems to support that it is a tight housing market, but the percentages provided seem to suggest that it is a healthy market. It is indisputable that housing costs have increased far more quickly than inflation over the past 20 years. The vacancy rate discussion seems to downplay our very serious housing issues.
population and that even seniors in fully owned homes are at risk for displacement if they cannot afford costly repairs. There is very little about San Anselmo’s plans for seniors going forward. There is mention that increased seniors increases demand for assisted living, but no discussion on how that demand will be met. Just as importantly, seniors need options for downsizing beyond ADUs and assisted living. Most seniors wish to live in mixed age communities until they truly need hands-on care that they cannot get at home.
But many seniors cannot afford the costs or challenges of a single family home. I know a number of seniors who prefer to downsize into “luxury” multi-family housing - that is, developments with amenities, services and a doorman/coincerge. This provides security, assistance, and far less maintenance work.
of community resistance, particularly the inclusion that the stated resistance does not necessarily reflect the reality of development.
Program 2.2 to encourage Public Engagement is not a solution to this issue.
Increasing public engagement does not solve the problem of public engagement being unrepresentative of the community, biased against change and uninformed in how to address the problems facing the community. Specifically, action 2.2a is likely to worsen the situation, not improve it.
San Anselmo needs to build political will and to bring community sentiment in line with current knowledge on community planning and development. Some more effective solutions might include:
Community education, including hosting public speakers and hosting documentaries on building strong towns and reducing car dependency. Many residents wrongly believe that suppressing housing will solve traffic and improve sustainability. This is objectively wrong, and education may be a better tactic.
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Bringing experts into public meetings to discuss how common concerns can be addressed. Refusing to build housing cannot fix traffic, water and fire issues.
Objective Design and Development Standards and pre-approved plans are excellent solutions to the constraint of community resistance.
San Anselmo states that “the Town’s development standards and requirements are intended to protect the long-term health, safety, and welfare of the community”. This white-washes the reality that much of the downzoning of Marin and other Bay Area communities was for the purpose of economically (and racially) segregating communities. There is no health, safety or welfare benefit of segregating single family housing from multi-family housing. And the segregation of housing from everyday retail (such as markets and cafes) has increased our car dependency, increased pollution and harmed our quality of life. People are willing to pay a large premium to be within walking distance of downtown. The above statement should be stricken from the Housing Element.
San Anselmo claims that current density limits aren’t a constraint, but then proposes to add housing by loosening limits in the housing overlay. It’s extremely unlikely that development standards aren’t a constraint. But if San Anselmo truly believes they aren’t, then it should be pursuing other solutions.
Lastly, San Anselmo claims that various development requirements don’t limit density because the lots can all accommodate their single family homes. This is not true. San Anselmo can enact many changes that would increase density in single family zoned areas. Set-backs, height limits, lot coverage, FAR and minimum lot sizes all combine to reduce density in single family zoned areas. If all of these development standards were eliminated, far more housing could be built. I’m not advocating for the elimination of all of these standards, but San Anselmo could do more to promote housing through the community by loosening these standards.
The legalization of middle market housing is a good first step. If housing does not materialize, San Anselmo should commit to adjusting these other constraints.
for this district - require design review, reduce development - sound far more 681
geared to propping the home values of these home-owners than furthering a public interest. I would question the existence of this zoning category.
There is no health or safety reason to require an architectural design review.
Architectural design review is most frequently used for neighbors to extract concessions to homeowners making improvements to their homes. It rarely, if ever, results in better design. It should be discontinued.
more density in C-1 and C-2 zoned land. C-1 is intended to be neighborhood scale commercial. Additional pedestrian traffic via slightly more dense housing (30 units/acre is not very dense) will help these businesses thrive. More dense housing and building up in the C-2 area is not in conflict with maintaining the cute, old-town charm of downtown San Anselmo. There is far less noise and traffic here than on Sir Francis Drake and Red Hill. Historically, downtowns have grown higher as they have achieved commercial success, and many very attractive downtowns are 4-5 stories high. There is no conflict between density and charm.
households. Yet, most housing units require 2 or more parking spaces. San Anselmo should reduce parking standards. A reduction in parking standards does not eliminate spaces or prevent needed future spaces from being built. It just allows land that is not needed for parking to be used for better purposes.
Action 1.1b - Establishing a database of units with restrictions is a very important first step in monitoring these housing units. I would encourage San Anselmo to expand this program to include all rentals, or at a minimum, all affordable rentals. San Anselmo is projecting a significant percentage of affordable housing to be provided by ADUs. As such, it needs a mechanism to monitor that these are being rented as expected.
This is particularly true as San Anselmo’s survey showed that only 48% of ADU owners planned to rent their ADUs, and of those renting, 47% planned to rent to a family member.
Action 1.3a - No net loss monitoring - San Anselmo acknowledges the need for a monitoring mechanism. A rental registry would be an important component of monitoring for No Net Loss.
Action 1.3b - A dashboard would be great, and even better if San Anselmo makes it public.
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Program 2.2
San Anselmo identifies community resistance as a problem. Program
2.2a primarily serves as a vehicle to increase community resistance and to make it easier for opponents to organize against projects.
Program 2.2b is a step in the right direction, but an annual newsletter article isn’t nearly sufficient to change the political will to build housing. I would suggest making this a community education plan that includes the following:
The invitation of various experts to contentious meetings to discuss how frequently cited issues are most successfully addressed. For example:
transit and traffic experts to discuss how communities
have successfully reduced traffic. (As a note, Seattle
reduced traffic 4% while increasing housing 20%. Traffic is not related to the volume of housing).
The fire department or other fire-safety experts to
contentious meetings to discuss how fire risks can be
mitigated.
Members of the Water Board to explain why new
development has only a trivial impact on water usage
Broader public programs that educate the population on
modern planning, including speakers from Strong Towns, Marin Bike Coalition, and other groups working to create more integrated, less car-dependent communities. If San Anselmo has funds for climate-action, these sorts of programs should qualify for funding.
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Program 2.2c is necessary to help counterbalance the small minority of residents who strongly fight housing. San Anselmo lists this on a case-by-case basis. It should commit to a minimum usage of this tactic and some guidelines of when it will be deployed.
Anselmo should include a plan to evaluate the effectiveness of the rezoning and to loosen restrictions if it doesn’t generate the expected level of development.
6-12, so this does not feel like an upzoning. We would suggest a true upzoning, perhaps 12-18 units/acre.
of ADUs for its low income housing, we believe it needs a program for monitoring ADU rentals and affordability.
Public Outreach
San Anselmo’s public outreach was most successful in its ADU survey, which received 320 responses. It is important that San Anselmo acknowledge that most ADUs built will not be rented to the general public (48% will not be rented, 47% of rented will be to a family member). San Anselmo’s housing plan should reflect this knowledge.
Sites inventory - Additional comments
As mentioned above, the San Anselmo Housing inventory is missing a consolidated sites inventory and has not completed the analysis that HCD requires for a compliant housing element. The absence of a consolidated list makes analysis of the inventory much more difficult. I’ve pulled out a few of the issues below, but it is exhaustive. I will do a complete review when the list is available.
Sites with existing uses need analysis that the site is likely to be redeveloped during the period. While San Anselmo describes its general process and mentions that some owners are interested, there is no site specific analysis provided.
The Sites inventory does not state whether rezoning will be done, even on commercial sites.
The Sites Inventory description of existing use is insufficient - it must be more detailed than “industrial - improved”
684
The Sites inventory has just one income level (low income, moderate income, etc.) per inventory site. This is atypical and unlikely to reflect how development will happen. San Anselmo should provide a more detailed assessment of income levels of the sites. A thorough site analysis requires that San Anselmo determine that sites with existing uses are likely to redevelop. Given the low rate of development in recent years, this will likely require conversations with property owners on what zoning changes will make the development of housing feasible. Given the current presentation of housing sites, it does not appear that San Anselmo has done this.
Site 6 - 300 Sunny Hills Drive - this is listed for 117 low income units. If a development is more than 20% affordable, subsidies must be offered. This is not done. There is no evidence of analysis that this will happen.
Site 13 - 100 Center Drive - This states that an Andronico’s will be converted to 100% affordable housing. San Anselmo would need to provide analysis that the existing use will be discontinued, and to confirm it would subsidize this 100% affordable project.
Site 22 - 100 Red Hill Avenue - This states that an United Markets will be converted to 44 lower income units. This appears financially infeasible. San Anselmo will need to provide analysis that the existing use will be discontinued, and to confirm it would subsidize this 100% affordable project.
Site 26 - 9 parcels at the intersection of RedHill/Greenfield and Sir Francis Drake for 36 moderate income units. San Anselmo will need to provide analysis that the existing use will be discontinued. But beyond that, this seems like a particularly bad place for residential construction. It’s at the intersection of two large, busy thoroughfares. Maybe the back half of these lots could be developed, but few people would like their houses to face out on these roads.
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Please provide your feedback on Section 1: Introduction While the general plan is largely the same, society has changed and we should do more on theme 5:
accommodate the housing needs of a socially and economically diverse population (take an aggressive approach to AB 686). SA should lead Marin on diversity
Please provide your feedback on Section 2: Housing Needs and Constraints Executive Summary
Climate change problems are reduced when people live near work. SA should prioritize housing affordable for those doing low paid service jobs. Overnight parking should be allowed: its hard for families who become homeless to stay in their community/cars Please provide your feedback on Section 3: Housing Needs Many homeless people aren't counted in the PIT - SA has more than people realize. We should be doing more to create shelter, transitional housing, and permanent supportive housing here, even if bed counts are low it makes a difference
Please provide your feedback on Section 4: Housing Constraints Community resistance is an important barrier. We should use innovative approaches to counter this, in addition to what is outlined here. It's also important to do all we can to attract nonprofit developers.
Innovative incentives beyond what we see here?
Please provide your feedback on Section 5: Housings Resources Could poorly used commercial buildings be put forward for Project Homekey? Can we do more to encourage landlords to work with MHA to take Housing Choice vouchers/Shelter+Care?? Please provide your feedback on Section 6: Housing Opportunities The ADU program seems like a great opportunity. Do we fully understand why uptake hasn't been greater? Is it just awareness or could we do more?
Please provide your feedback on Section 7: Affirmatively Furthering Fair Housing
The poor Fair Housing Testing results mirror lived experience of people of color and other groups. I don't get a clear picture of transformational change plans from the housing element. We should do more.
Please provide your feedback on Section 8: Policies, Programs, and Actions
Actions 1.1a-c are important. Are regular planning calls enough? This doesn't sound like strong leadership for change. Actions 1.2a-c should be more frequent 686
Please provide your feedback on Appendix A: Public Participation I appreciated the varied forms the public's participation was solicited - from informal tabling at community events to email and paper mail
Please provide your feedback on Appendix B: Map Book
The map layout is easy to read - I like the map and aerial photo views 687
From: Ali Kia Shabahangi
To: Heidi Scoble
Cc: Amir Kia
Subject: Re: RHNA Allocation San Anselmo
Date: Tuesday, January 3, 2023 5:50:14 PM
Attachments: Screen Shot 2023-01-03 at 5.38.09 PM.png
Screen Shot 2023-01-03 at 5.37.39 PM.png
Screen Shot 2023-01-03 at 5.35.03 PM.png
CAUTION: External Sender
Hello Heidi,
Do we still have time to comment on the latest draft San Anselmo RHNA housing report? After reading the latest draft, we note that the issue around number of stories was raised in one of the sessions, i.e. 2 vs. 3 stories and we wanted to see what the public's and Commission's reaction was to allowing 3 stories in some areas such as 233 San Anselmo Ave? We would like to advocate for 3 stories in this area, instead of just 2, because we feel this one change would really help break things open around this area and make it much easier and more efficient to produce new housing and also energize the street level. Also, the existing height is 30', the street is wide, the location is at the bottom of the valley and there are existing 30' tall and taller buildings on the same and adjacent blocks. As such, there will be no or negligible impact on massing, views and shadows.
Attached are some pictures of the area where our building is located (the small light blue building with "233" on it) to give you a visual perspective of the area.
We would be happy to have our architect present a 3 story building schematic elevation in this location to further illustrate our point if it would help build consensus around increasing the number of stories from 2 to 3.
Please let us know your thoughts.
Thank you,
Ali
Ali Kia Shabahangi
Spirit Living Group, LLC
101 Larkspur Landing Circle, Suite 220
Larkspur, CA 94939
T: 415-480-6160
C:415-465-2905
F:415-480-6177
www.spiritlivinggroup.com
688
On Wed, Oct 12, 2022 at 3:29 AM Ali Kia Shabahangi <[email protected]> wrote:
Thanks Heidi
Ali Kia Shabahangi
Spirit Living Group, LLC
101 Larkspur Landing Circle, Suite 220
Larkspur, CA 94939
T: 415-480-6160
C:415-465-2905
F:415-480-6177
www.spiritlivinggroup.com
On Tue, Oct 11, 2022 at 8:53 PM Heidi Scoble <[email protected]> wrote:
Hi Ali:
I wanted to let you know that the next meeting that I would suggest you attend would be the November 3, 2022 Housing Element Advisory Committee meeting. Information on the meeting can be found at the Town’s Housing Element Update Website.
The meeting will discuss policies and programs to help facilitate and streamline housing, such as possible density increases, etc.
Sincerely,
Heidi
Heidi Scoble, AICP
Planning Director
Town of San Anselmo | 525 San Anselmo Ave | San Anselmo, CA 94960 (415) 258-4636 | townofsananselmo.org
689
From: Ali Kia Shabahangi <[email protected]>
Sent: Friday, October 7, 2022 9:34 AM
To: Heidi Scoble <[email protected]>
Cc: Amir Kia <[email protected]>
Subject: Re: RHNA Allocation San Anselmo
CAUTION: External Sender
Hi Heidi,
Please let me know when the next process/meeting is and/or include me in e-mail updates/events schedule.
Thank you,
Ali
Ali Kia Shabahangi
Spirit Living Group, LLC
101 Larkspur Landing Circle, Suite 220
Larkspur, CA 94939
690
T: 415-480-6160
C:415-465-2905
F:415-480-6177
www.spiritlivinggroup.com
On Fri, Oct 7, 2022 at 7:54 AM Heidi Scoble <[email protected]> wrote:
Hi Ali:
Through the next steps in the Housing Element Update process, in addition to the proposed density changes, the Town will be developing Policies and Programs to help facilitate additional housing units, such a possibly allowing additional height, densities, etc. As the Town is still in the process of developing the policies for consideration by the Town Council, I am not able to provide a definitive response to you density question related to 233 San Anselmo. I would encourage you to participate in the next process and advocate for more flexibility in the Town’s policies to help allow you to develop four units on your property.
Regarding your property at 63-67 Kensington, the density for an R-1 property would still remain as single family residential with an average density of 6 units to the acre.
Given the parcel already contains three units, there would be limited room for adding additional density. It does look like you may be able to add one Junior accessory dwelling units to one of the primary residences. The click on the Town’s Junior Accessory regulations for more information.
Sincerely,
Heidi
Heidi Scoble, AICP
Planning Director
Town of San Anselmo | 525 San Anselmo Ave | San Anselmo, CA 94960 (415) 258-4636 | townofsananselmo.org
691
From: Ali Kia Shabahangi <[email protected]>
Sent: Thursday, October 6, 2022 7:12 PM
To: Heidi Scoble <[email protected]>
Cc: Amir Kia <[email protected]>
Subject: Re: RHNA Allocation San Anselmo
CAUTION: External Sender
Hi Heidi,
Our property at 233 San Anselmo Ave. is 4,750 square feet (.11 acre) and is in a "C2" zoning district.
At 30 units an acre that would mean we could do 3.3 units (.11 x 43,560). We would like to build up to 4 units.
Can we do that, round up or find another way to add more density? Would the Town still be limiting the number of stories to 2 along San Anselmo Avenue or would a 3 story structure be considered?
Our property at 63 - 67 Kensington is 14,000 square feet (.32 of an acre) and is in an R1 zoning district.
692
Would that mean we could do 9.6 units or 10 units (.32 x 43,560).
Thank you for your feedback,
Ali
Ali Kia Shabahangi
Spirit Living Group, LLC
101 Larkspur Landing Circle, Suite 220
Larkspur, CA 94939
T: 415-480-6160
C:415-465-2905
F:415-480-6177
www.spiritlivinggroup.com
On Thu, Oct 6, 2022 at 5:45 PM Heidi Scoble <[email protected]> wrote:
Hi Ali:
Thank you for providing the information. Your property is currently on the proposed Housing Opportunity Sites list and the Town is considering upzoning the residential density on your property from 20 units to the acre to 30 units to the acre. The Town will also being working on policies and programs that will help facilitate residential development. The Town’s housing Element Advisory Committee will be conducting a public meeting on November 5 to discuss programs and the Town Council will be conducting a public meeting on October 11 to confirm the proposed Housing Opportunity Sites. I encourage you to participate in the Housing Element Update 693
process if you are interested. Information on the Housing Element Update can be found at the following link: San Anselmo Housing Element Update | San Anselmo, CA - Official Website (townofsananselmo.org).
Please do not hesitate to email me if you have any additional information.
Sincerely,
Heidi
Heidi Scoble, AICP
Planning Director
Town of San Anselmo | 525 San Anselmo Ave | San Anselmo, CA 94960 (415) 258-4636 | townofsananselmo.org
From: Ali Kia Shabahangi <[email protected]>
Sent: Thursday, October 6, 2022 1:32 PM
To: Heidi Scoble <[email protected]>
Cc: Amir Kia <[email protected]>
Subject: RHNA Allocation San Anselmo
CAUTION: External Sender
694
Hello Heidi,
Attached, please find two properties that we would like to include for additional housing density per your letter RE: 6th Cycle Housing Element Update - Property Development Capacity.
Please let me know if you have any questions.
We are local developers and would love the opportunity to add to San Anselmo's housing stock.
Thank you,
Ali
Ali Kia Shabahangi
Spirit Living Group, LLC
101 Larkspur Landing Circle, Suite 220
Larkspur, CA 94939
T: 415-480-6160
C:415-465-2905
F:415-480-6177
www.spiritlivinggroup.com
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REVIEW OF THE 6TH
CYCLE DRAFT
HOUSING ELEMENT
January 10, 2023
San Anselmo Town Council
698
Purpose: ■ Housing Element Update
Overview
■ Public Review Draft Housing
Element Overview
■ Next Steps ■ Provide Comments on the Draft
Housing Element and Accept
Public Comment
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HOUSING ELEMENT
PURPOSE AND UPDATE
PROCESS
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What is a Housing
Element?
■ Provides an assessment of the City’s housing needs
and identifies how to accommodate the housing needs
of existing and future residents.
■ Sets citywide policies, programs, and actions for
housing, and identifies housing conditions and needs
within the community.
■ Must be reviewed for compliance by State Department
of Housing and Community Development (HCD).
■ Housing Element is a Town-wide planning tool to
remove barriers to housing.
– The Town cannot mandate the Housing be
constructed. 701
Why are Housing Elements Updated?
■ Ensure the City complies with State housing
laws
■ Demonstrate San Anselmo’s ability to meet
future housing growth needs
■ To adopt and implement policies addressing
local housing issues
■ Allow the community to further engage in the
planning process
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What is "RHNA"?
■ Regional Housing Needs Allocation
– Assigned by State via ABAG
– Projected number of new units needed in
the region over 8 years
– Broken into four income categories
– Currently in Cycle 5 or “RHNA 5"
– Planning for Cycle 6 or "RHNA 6"
■ RHNA 5: 2014-2022 (106 Units)
■ RHNA 6: 2023-2031 (833 Units)
Association of Bay Area
Governments
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San Anselmo’s RHNA 6 Allocation
Income Level RHNA 6 Allocation
Very Low Income (0-50% AMI) 253
Low Income (51-79% AMI) 145
Moderate Income (80-119% AMI) 121
Above Moderate Income (120% AMI+) 314
TOTAL: 833
AMI = Area Median Income
AMI for Marin County = $166,000/year for a family of four ***Housing Element is a Town-wide planning tool that applies to all properties in San Anselmo 704
Units Already
Accounted For
■ ADUs - 160
■ Pipeline Projects - 43
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San Anselmo’s RHNA 6 Allocation
Income Level RHNA 6
Allocation
RHNA 6
Allocation
After ADUs
RHNA 6
Allocation
After ADUs
& Pipeline
Very Low Income 253 205 194
Low Income 145 97 88
Moderate Income 121 73 69
Above Moderate Income 314 298 279
TOTAL: 833 673 630
AMI = Area Median Income
AMI for Marin County = $166,000/year for a family of four 706
20% No Net Loss Buffer
■ 630 units remaining after subtracting ADUs and pipeline projects
■ 630 x .20 = 126
■ Total remaining RHNA and 20% no net loss buffer: 754
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Update Process To Date
■ 6/4/2022 – Town Council Introduction
■ 7/11/2022 – HEAC Meeting No. 1
■ 7/21/2022 – Town Hall Meeting No.1
■ 7/25/2022 – HEAC Meeting No. 2
■ 8/25/2022 – Town Hall Meeting No. 2
■ 9/1/2022 – HEAC Meeting No. 3
■ 9/26/2022 – HEAC Meeting No. 4
■ 10/11/2022 – Town Council Meeting
■ 11/3/2022 – HEAC Meeting No. 5
■ 12/15/2022 – HEAC Meeting No. 6
Introductory and Informational Meetings
Housing Opportunity Sites Identification
and Discussion
Finalize Housing Opportunity Sites and
Discuss Policies, Programs, and Actions
Public Review Draft HE Overview
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PUBLIC REVIEW DRAFT
HOUSING ELEMENT
OVERVIEW
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Housing Element Outline
1. Introduction
2. Housing Needs and Constraints Executive Summary
3. Housing Needs
4. Housing Constraints
5. Housing Resources
6. Housing Opportunities
7. Affirmatively Furthering Fair Housing
8. Policies, Programs, and Actions
***Housing Element is a Town-wide planning tool that applies to all properties in San Anselmo Housing Opportunity Sites demonstrate where the assigned RHNA units may be accommodated
Policies, Programs, and Actions apply to applicable properties, including both Housing Opportunity Sites and non-housing opportunity sites 710 Housing Element Outline
1. Introduction
2. Housing Needs and Constraints Executive Summary
3. Housing Needs
4. Housing Constraints
5. Housing Resources
6. Housing Opportunities
7. Affirmatively Furthering Fair Housing
8. Policies, Programs, and Actions
SETTING THE STAGE: Background and
Identification of Housing Conditions, Needs,
Barriers, and Resources
THE MAIN ACT: Identification of Housing
Opportunity Sites and Plan for Accommodating
Additional Housing in San Anselmo
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Main Housing Element Pieces
■ Housing Opportunity Sites
– Parcels that have been identified as feasibly developing or redeveloping with housing over the next 8 years
– Property owners are not required to redevelop/build housing on identified parcels – Town of San Anselmo is required to remove barriers to redeveloping/building housing on identified parcels
■ Policies, Programs, and Actions
– Steps the Town will take to remove barriers to redeveloping/building housing on identified parcels and throughout the community
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Housing Opportunity Sites Identification
Methodology
Site Suitability Factors
■ Current Zoning
■ General Land Use Plan Designation
■ Vacancy
■ Residual Lot Coverage
■ Fire Hazard or Severity Zones
■ Slope
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Housing Opportunity Sites Identification
Process
1. Preliminary housing opportunity sites
were identified by Town staff.
2. Staff identified sites were brought to
the HEAC for review and consideration
during HEAC meeting two for initial
consideration.
3. Staff identified sites were brought to
the public at a virtual workshop for
initial consideration.
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Housing Opportunity Sites Identification
Process
1. After HEAC Meeting, revised
housing opportunity sites were
identified by Town staff.
2. Staff identified revised sites were
brought to the HEAC for review
and consideration during HEAC
meeting two for initial
consideration.
3. Staff identified revised sites were
brought to the public at a virtual
workshop for initial consideration. Existing Zoning Map Housing Opportunity Sites 715
Housing Opportunity Sites Identification
Process
4. Staff identified sites were refined based on the feedback from the HEAC and the public. For example, staff identified sites in the R-1H and R-1C zoning districts were eliminated based on community concerns regarding environmental degradation and wildfire hazard.
5. The refined sites were brought back to the HEAC for further consideration and revision.
6. An objective sites inventory analysis was conducted to determine whether the revised sites were appropriate for new housing, balancing a variety of factors as detailed in the Sites Inventory Analysis in the Housing Element.
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Housing Opportunity Sites Identification
Process
7. The results of the sites inventory analysis were presented to the HEAC at HEAC meeting No. 4 for further review and refinement.
Necessary zoning ordinance amendments to accommodate the density will be needed and listed as either a policy, program, or action.
HEAC meeting made a motion to recommend the sites to the Town Council.
8. The Town Council considered the sites recommended by the HEAC and made a motion to move forward with all sites with the exception of the dog park.
9. Town staff conducted meetings with the schools to discuss the potential of housing on the portion of their sites included in the Town Council approved list of housing opportunity sites. Based on the feedback received from these meetings, the school sites were removed from the list of housing opportunity sites.
***Final Housing Opportunity Sites List shows the Dog Park, Ross Valley School District parcel, Wade Thomas and Archie Williams have been REMOVED from list of sites. 717
Housing Opportunity Sites Identification
Process
10. To make up for the deficit from eliminating the school sites, additional site added to Side by Side parcel.
Side by Side had originally proposed affordable housing be constructed on a portion of their site in RHNA Cycle 5 but were met with barriers to development approval.
Side by Side expressed continued interest if the Town
worked to eliminate the barriers to development
approval it had previously faced. Policy 5. Eliminate Barriers to the Development of Market Rate and Affordable Housing includes programs and actions
to eliminate said barriers thus the additional site
was included.
11. The updated Housing Opportunity Sites were brought to the HEAC for final review and consideration at HEAC meeting No. 5.
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Final Draft Housing
Element Opportunity
Sites ■ Total Housing Opportunity Sites: 62 ■ Total Parcels: 172 ■ Total Projected Units: 837 – Lower Income: 354 – Moderate Income: 271 – Above Moderate Income: 212 ■ Proposed Zoning Amendments to Accommodate Development of Projected
Units: increase maximum density in the R-3,
C-3, C-L, and SPD districts from 20 dwelling
units an acre to 30
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San Anselmo’s RHNA 6 Allocation
Income Level
RHNA 6 Less
ADUs
& Pipeline, Plus
20% Buffer
Housing
Opportunity Site
Units
Unit Surplus /
Deficit
Very Low Income 233
354 15-unit surplus Low Income 106
Moderate Income 83 271 188-unit surplus
Above Moderate Income 335 212 123-unit deficit
TOTAL: 756 837 80-unit surplus
AMI = Area Median Income
AMI for Marin County = $166,000/year for a family of four 720
Policies, Programs, and Actions
■ Policies: Statements that declare the Town’s goals for increasing housing availability and affordability in the next 8 years.
■ Programs: Programs the Town will employ to realize policy. ■ Actions: Specific actions the Town will take to complete programs and realize policy.
■ Action Matrix:
– Town Lead
– Completion Time Frame
– Quantifiable Metric
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PUBLIC COMMENT TO DATE
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Public Comment Received
■ Down payment assistance program
■ Concerns with proposed rezonings and density west of San Anselmo Blvd. ■ Comment regarding various sections of the Housing Element- Late Mail ■ Comment requesting height increase for commercial properties in the C-3 Zoning District- Late Mail
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NEXT STEPS
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Next Steps
■ January 10: Town Council Public Meeting
– Preliminary consideration of public comment
■ January 12: Public Comment Period Closes
– Feedback incorporated into document per Town Council
direction
■ January 23: Planning Commission Public Meeting
– Update on any revised Housing Element
■ January 25: Submit Adopted Housing Element to HCD
– 90-day review period begins
■ Late April-Early May: Town Council considers adoption of the Housing Element and approval of the environmental document. 725
Recommendation:
■ January 10: Town Council Public Meeting
– Preliminary consideration of public comment
■ January 12: Public Comment Period Closes
– Feedback incorporated into document per Town Council
direction
■ January 23: Planning Commission Public Meeting
– Update on any revised Housing Element
■ January 25: Submit Adopted Housing Element to HCD
– 90-day review period begins
■ Late April-Early May: Town Council considers adoption of the Housing Element and approval of the environmental document. 726
QUESTIONS
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