San Carlos City Council
January 23, 2023

Action LU-1.8: Amend the Zoning Ordinance to address the new multiple-family and mixed-use designations as part of the 2023 Focused General Plan Update.

Policy LU-9.14: Legally nonconforming multi-family residential structures located within multifamily residential zoning districts may be replaced, restored, or rebuilt, or repaired and used consistent with the Zoning Ordinance in effect at the time the structure was originally constructed only upon issuance of a conditional use permit approved by the Planning Commission at the time of the replacement, restoring, or rebuilding.

policy):

One policy is being updated to specifically reference the San Carlos Bicycle and Pedestrian Master Plan:

Policy CSH-2.2: Provide for adequate pedestrian and bicycle facilities as viable transportation modes in San Carlos, as recommended in the San Carlos Bicycle and Pedestrian Master Plan.

• Policy LU-9.10: In the event of closure of a school, the primary planned use of these sites re- mains for school and associated recreation purposes, or housing. The school site should be considered for acquisition by the City. On school and formerly school sites, allow low and moderate income rental housing units made available to local educational employees, local public employees, and then the general public at densities and development standards in accordance with AB2295, 2022.
• Policy LU-9.21: Consider allowing public school districts and local private schools to provide affordable housing units on school or school-related sites concurrent with continued school operations.

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Chapter 4. Errata and Revisions
4-2 San Carlos Focused General Plan Update Administrative Draft EIR December 2022
• Action LU-9.3: Update development standards to allow for single family attached, multiple family detached, and/or multiple family attached affordable housing units to be constructed and maintained concurrent with school operations.

General Plan policy):

One policy is being updated to specifically reference the San Carlos Bicycle and Pedestrian Master Plan.

Policy EM-11.4: Provide an integrated network of bicycle and pedestrian thoroughfares that connects jobs and housing to other city destinations, as recommended in the City’s Bicycle and Pedestrian Master Plan.

Plan policy):

Policy EM-11.4: Coordinate with neighborhing jurisdictions, the County and regional agencies to expand bicycle connections to regional destinations. Provide an integrated network of bicycle and pedestrian thoroughfares that connects jobs and housing to other city destinations, as recommended in the City’s Bicycle and Pedestrian Master Plan.

Action ESPS-5.6: Prepare regulations that address biosafety levels (BSL) for new life science, biotechnology, or other scientific developments to ensure a healthy and safe San Carlos community.

Action ESPS-3.7: Adopt a formal written policy Periodically re-evaluate the City’s policy regarding the City’s policy allowing rebuilding in the VHFHSZ. Periodically, re-evaluate the policy to assure consistency with State law and local preferences. allowing rebuilding in the VHFSHZ. If the policy is unwritten, adopt a formal written policy.

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San Carlos Focused General Plan Update Project
Appendix A: Mitigation Monitoring and
Reporting Program

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MITIGATION MONITORING AND REPORTING PROGRAM
CEQA Statute Section 21081.6 and State CEQA Guidelines Section 15097 require a public agency to adopt a reporting or monitoring program (MMRP) to ensure compliance with the mitigation measures adopted by the agency at the time of project approval. A mitigation monitoring program would therefore be required for the San Carlos Focused General Plan Update EIR to ensure compliance with the mitigation measures that are adopted and incorporated into the project.

Adoption of the MMRP would occur at the time of project approval.

This Mitigation Monitoring and Reporting Program (MMRP) has been prepared pursuant to the CEQA Guidelines, which state:
“When adopting a final EIR with findings as required under 14 CCR section 15091(a)(1) the lead agency shall also adopt a program for reporting on or monitoring the changes which it has either required in the project or made a condition of approval to mitigate or avoid significant environmental effects” (§15097(a)); and
“The Lead Agency may choose whether its program will monitor mitigation, report on mitigation, or both. “Reporting” generally consists of a written compliance review that is presented to the decision-making body or authorized staff person. A report may be required at various stages during project implementation or upon completion of the mitigation measure. “Monitoring” is generally an ongoing or periodic process of project oversight. There is often no clear distinction between monitoring and reporting and the program best suited to ensuring compliance in any given instance will usually involve elements of both.” (§15097(c)) The table beginning on the next page lists the impacts, mitigation measures, and timing of the mitigation measure (when the measure will be implemented) related to the Project. The “Impact” column lists each significant impact, by resource topic, that is identified in the EIR and for which mitigation measures are recommended. The “Mitigation Measure” column provides the full text of each mitigation measure identified in the EIR. The “Monitoring” column describes (1) the “implementation entity” responsible for carrying out each mitigation measure (such a “project applicant” or “City of San Carlos Planning Division and Building Division”); (2) mitigation implementation timing requirements (e.g., at the completion of a particular future individual project development review or construction phase, prior to occupancy, or when some other specific threshold is reached); and (3) the entity responsible for performing the monitoring of each mitigation measure (the “monitoring and verification entity;” e.g., a City department or agency, another public agency, or some other entity).

According to CEQA Guidelines Section 15126.4(a)(2), “Mitigation measures must be fully enforceable through permit conditions, agreements, or other legally-binding instruments. In the case of the adoption of a plan, policy, regulation, or other public project, mitigation measures can be incorporated into the plan, policy, regulation, or project design.” Therefore, all mitigation measures as listed in this MMRP will be adopted by the City of San Carlos when the project is approved.

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IDENTIFIED IMPACT RELATED MITIGATION MEASURE

MONITORING VERIFICATION
Implementation
Entity
Monitoring and
Verification
Entity
Timing
Requirements Signature Date
Air Quality Impact AIR-1: The project would conflict with or obstruct implementation of the applicable air quality plan. This impact would be considered significant and unavoidable even with the incorporation of feasible mitigation measures. (Significant and Unavoidable Impact) Mitigation Measure AIR-2: Require a Project-level Construction Assessment for New Discretionary Development Projects.

The City shall require applicants to submit a quantitative project-level construction criteria air pollutant and toxic air contaminant emissions analysis for future discretionary development projects that are not exempt under CEQA and do not meet the BAAQMD screening criteria. The estimated construction criteria air pollutant and toxic air contaminant emissions shall be compared against the thresholds of significance maintained by the Bay Area Air Quality Management District (BAAQMD) and, if emissions are shown to be above BAAQMD thresholds, the City shall require the imposition and implementation of mitigation measures to reduce emissions below the thresholds that have been exceeded. Mitigation measures to reduce emissions could include, but are not limited to: • Selection of specific construction equipment (e.g., specialized pieces of equipment with smaller engines or equipment that will be more efficient and reduce engine runtime); • Requiring equipment to use alternative fuel sources (e.g., electric-powered and liquefied or compressed natural gas), meet cleaner emission standards (e. g., U.S. EPA Tier
Project Applicant City of San
Carlos Planning
Division and
Building
Division
Prior to
discretionary
project approval.

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IDENTIFIED IMPACT RELATED MITIGATION MEASURE

MONITORING VERIFICATION
Implementation
Entity
Monitoring and
Verification
Entity
Timing
Requirements Signature Date
IV Final emissions standards for equipment greater than 50-horsepower), and/or utilizing added exhaust devices (e.g., Level 3 Diesel Particular Filter); • Minimizing the idling time of dieselpowered construction equipment to two minutes; and • Application of Low-VOC paints to interior and/or exterior surfaces (e.g., paints that meet BAAQMD Regulation 8 Rule 3 requirements).

Impact AIR-2: The project would result in a cumulatively considerable net increase of criteria pollutants for which the project region is nonattainment under an applicable federal or state ambient air quality standard. Implementation of Mitigation Measure AIR-2 would reduce construction criteria air pollutant and toxic air contaminant emissions to a level that is below the BAAQMDrecommended threshold of significance. However, it cannot be definitivel y
See Mitigation Measure AIR-2, above Project Applicant City of San Carlos Planning
Division and
Building
Division
Prior to
discretionary
project approval.

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IDENTIFIED IMPACT RELATED MITIGATION MEASURE

MONITORING VERIFICATION
Implementation
Entity
Monitoring and
Verification
Entity
Timing
Requirements Signature Date
known or stated at this time that all future development projects occurring under implementation of the proposed project would be able to reduce potential criteria air pollutant emissions to levels that are below BAAQMD thresholds. This impact would be considered significant and unavoidable even with the incorporation of feasible mitigation measures. (Significant and Unavoidable Impact) Impact AIR-3: The project could expose sensitive receptors to substantial pollutant concentrations. Implementation of Mitigation Measure AIR-2 would reduce construction criteria air pollutant and toxic air contaminant emissions to a level that is below the BAAQMDrecommended threshold of significance. However, with regard to localized criteria air pollutant and See Mitigation Measure AIR-2, above. Project Applicant City of San Carlos Planning
Division and
Building
Division
Prior to
discretionary
project approval.

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IDENTIFIED IMPACT RELATED MITIGATION MEASURE

MONITORING VERIFICATION
Implementation
Entity
Monitoring and
Verification
Entity
Timing
Requirements Signature Date
TAC emissions generated during future construction activities it cannot be definitively known or stated at this time that all future development projects occurring under implementation of the proposed project would be able to reduce potential criteria air pollutant and TAC emissions to levels that are below BAAQMD thresholds. This impact would be considered significant and unavoidable even with the incorporation of feasible mitigation measures. (Significant and Unavoidable Impact) Impact AIR-5: The project could cause substantial adverse cumulative impacts with respect to Air Quality. Because future construction activities could result in ozone precursor and PM emissions that exceed BAAQMD thresholds, the project could increase the See Mitigation Measure AIR-2, above. Project Applicant City of San Carlos Planning
Division and
Building
Division
Prior to
discretionary
project approval.

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IDENTIFIED IMPACT RELATED MITIGATION MEASURE

MONITORING VERIFICATION
Implementation
Entity
Monitoring and
Verification
Entity
Timing
Requirements Signature Date
frequency and/or severity of air quality violations in the Bay Area Basin or otherwise impede attainment of air quality standards. (Significant and Unavoidable Impact)Biological Resources Impact BIO-1: The project could have a significant adverse effect, either directly or through habitat modifications, on any species listed as candidate, sensitive or special status species in local or regional plans, policies, or regulations by the California Department of Fish and Game or U. S. Fish and Wildlife.

Mitigation Measure BIO-1: Project-Specific Biological Resources Evaluation. Prior to construction of new housing on sites that are on or adjacent to natural vegetation or aquatic habitat, and/or vegetation thinning or creation of fuel breaks, a project-specific biological resources evaluation shall be conducted by a qualified biologist. The biologist shall utilize relevant resources such as the California Natural Diversity Database (CNDDB) and the National Wetlands Inventory (NWI) as well as a field survey covering the project site and adjacent areas. A biological resources report or memo shall be prepared documenting the results of the evaluation, to a level of detail appropriate for the project. At a minimum, the report or memo shall include a description of existing vegetation, habitats, and aquatic features on the project site; an evaluation of special-status species and sensitive habitats that could occur on the site; and suitable mitigation measures as needed to avoid project-related impacts to biological resources. Mitigation measures from the biological resources evaluation shall be incorporated into the CEQA Project Applicant City of San
Carlos Planning
Division and
Public Works
Department
Prior to Issuance
of any Demolition,
Grading, or Tree
Removal Permits.

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IDENTIFIED IMPACT RELATED MITIGATION MEASURE

MONITORING VERIFICATION
Implementation
Entity
Monitoring and
Verification
Entity
Timing
Requirements Signature Date
document for the project and/or adopted as project conditions of approval. Applies To: New housing development on sites that are on or adjacent to natural vegetation or aquatic habitat, vegetation thinning and creation of fuel breaks.

Impact BIO-2: The project could have a substantial adverse effect on any riparian habitat or other sensitive natural community identified in local or regional plans, policies, regulations or by the California Department of Fish and Game or U.S. Fish and Wildlife Service.

Mitigation Measure BIO-2: Nesting Birds. To avoid impacts to nesting birds and avoid potential violation of state and federal laws pertaining to birds, all construction of new housing (including but not limited to mobilization and staging, clearing, grubbing, tree removal, fence installation, demolition, and grading) and/or vegetation thinning and creation of fuel breaks should occur outside the avian nesting season (that is, prior to February 1 or after September 15) if possible. If construction and/or vegetation thinning or creation of fuel breaks occurs within the avian nesting season (from February 1 to September 15), all suitable habitats located within the project’s area of disturbance including staging and storage areas plus a 250-foot (passerines) and 1,000-foot (raptor nests) buffer around these areas shall be thoroughly surveyed, as feasible, for the presence of active nests by a qualified biologist no more than five days before commencement of any site disturbance activities and equipment mobilization. If project activities are delayed by more than five days, an additional nesting bird survey shall be performed. Active nesting is present if a bird is building a nest, sitting in a nest, a nest has eggs or chicks in it, or adults are Project Applicant City of San
Carlos Planning
Division and
Public Works
Department
Prior to Issuance of any Demolition, Grading, or Tree Removal Permits.

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IDENTIFIED IMPACT RELATED MITIGATION MEASURE

MONITORING VERIFICATION
Implementation
Entity
Monitoring and
Verification
Entity
Timing
Requirements Signature Date
observed carrying food to the nest. The results of the surveys shall be documented. If pre-construction nesting bird surveys result in the location of active nests, no site disturbance and mobilization of heavy equipment (including but not limited to equipment staging, fence installation, clearing, grubbing, vegetation removal, fence installation, demolition, and grading), shall take place within 250 feet of nonraptor nests and 1,000 feet of raptor nests, or as determined by a qualified biologist, until the chicks have fledged. Monitoring shall be required to ensure compliance with Migratory Bird Treaty Act (MBTA) and relevant California Fish and Game Code requirements. Monitoring dates and findings shall be documented. Applies To: All housing construction and/or vegetation thinning and creation of fuel breaks during the nesting bird season (February 1 through September 15). Mitigation Measure BIO-3a: Bat Habitat Assessment. Prior to removal of trees or structures for housing development or fire hazard reduction, a qualified biologist shall conduct a bat habitat assessment of trees and structures to be removed, as well as surrounding trees and structures. The biologist shall search for large cavities and crevices in trees and structures that could support maternity roosts as well as habitat for specialstatus bat species. Si gns of bats such as
guano

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IDENTIFIED IMPACT RELATED MITIGATION MEASURE

MONITORING VERIFICATION
Implementation
Entity
Monitoring and
Verification
Entity
Timing
Requirements Signature Date
or the smell of bats shall also be noted. Results of the bat habitat assessment shall be documented. If no suitable roosting habitat or signs of bats are found, then no further action is required, and the project may proceed as planned. If suitable roosting habitat or signs of bats are found, then Mitigation Measure 3b shall be implemented. Mitigation Measure BIO-3b. Dusk Emergence Bat Survey: If suitable roosting habitat or signs of bats are found in trees or structures to be removed on a new housing site or fire fuel reduction area, a qualified biologist shall conduct a dusk emergence survey for roosting bats within 14 days prior to the removal of the tree(s) or structure(s). The biologist shall monitor all suitable roosting trees and structures at dusk for emerging bats, using acoustic equipment to identify the species. Results of the survey shall be documented. If no roosting bats are found during the survey, then no further action is required, and the project may proceed as planned. If roosting bats are found during the survey, a disturbancefree buffer zone shall be established around the roost site during the maternity season (April 15-September 15), as determined by a qualified biologist until the maternity season is over. Outside the maternity season, roosting bats may be excluded from the tree(s) or structure(s) prior to tree removal as directed b y

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IDENTIFIED IMPACT RELATED MITIGATION MEASURE

MONITORING VERIFICATION
Implementation
Entity
Monitoring and
Verification
Entity
Timing
Requirements Signature Date
a qualified biologist. If a special-status bat is found, the roosting site shall be preserved if feasible and CDFW shall be consulted prior to exclusion. Applies To: Any housing project or fuel reduction project that requires removal of trees or structures.

Impact BIO-3: The project could have a substantial adverse effect on state or federally protected wetlands (including, but not limited to, marsh, vernal pool, coastal, etc.) through direct removal, filling, hydrological interruption, or other means.

See Mitigation Measure BIO-1, above. Project Applicant City of San Carlos Planning
Division and
Public Works
Department
Prior to Issuance of any Demolition, Grading, or Tree Removal Permits.

Impact BIO-4: The project would not interfere substantially with the movement of any native resident or migratory fish or wildlife species, or with established native resident or migratory wildlife corridors, or impede the use of native wildlife nursery sites.

See Mitigation Measure BIO-1, above. Project Applicant City of San Carlos Planning
Division and
Public Works
Department
Prior to Issuance of Grading Permits.

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IDENTIFIED IMPACT RELATED MITIGATION MEASURE

MONITORING VERIFICATION
Implementation
Entity
Monitoring and
Verification
Entity
Timing
Requirements Signature Date
Impact BIO-5: The project would not conflict with any local policies or ordinances protecting biological resources, such as a tree preservation policy or ordinance.

See Mitigation Measures BIO-1, BIO-2, and BIO-3a & 3b, above.

Project Applicant City of San
Carlos Planning
Division and
City of San
Carlos Building
Division and
Public Works
Department
Prior to
discretionary
project approval.

Prior to Issuance
of any Demolition,
Grading, or Tree
Removal Permits.

Tribal Cultural Resources Impact TRIB-1: The project could cause a substantial adverse change in the significance of a Tribal Cultural Resource.

Mitigation Measure TRIB‐1: Consider all Native American Archaeological Discoveries to be Significant Resources. All Native American artifacts (tribal finds) shall be considered as a significant Tribal Cultural Resource, pursuant to PRC 21074 until the lead agency has enough evidence to make a determination of significance. The City shall coordinate with an archaeologist who meets the U.S. Secretary of the Interior’s Professional Qualifications, as well as an appropriate tribe or tribes, as determined by the NAHC, to develop an appropriate treatment plan for the resources. The plan may include implementation of archaeological data recovery excavations to address treatment of the resource along with subsequent laboratory processing and analysis. An archaeological report shall be written detailin g all
Project
Applicant
City of San
Carlos Planning
Division and
Public Works
Department
Immediately
following the
discovery of
subsurface
archaeological
materials.
.

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IDENTIFIED IMPACT RELATED MITIGATION MEASURE

MONITORING VERIFICATION
Implementation
Entity
Monitoring and
Verification
Entity
Timing
Requirements Signature Date
archaeological finds and submitted to the City and the Northwest Information Center.

NOTES: S = Significant Impact LTS = Less than Significant Impact SU = Si gnificant Unavoidable Impact

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City of San Carlos Focused General Plan
Update Final EIR Amendment
SCH# 2021120442
Lead Agency:

City of San Carlos
Community Development Department
Planning Division
600 Elm Street
San Carlos, CA 94070
www.cityofsancarlos.org
January 2023
Prepared with the assistance of MIG, Inc.

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City of San Carlos
Focused General Plan Update Project
Final EIR Amendment

1. Introduction
The City of San Carlos prepared a Program environmental impact report (“EIR”) for the Focused General Plan Update Project, and circulated the Draft EIR for the Project for a 45-day public review period starting on October 14, 2022 and ending on November 28, 2022. The City then prepared the Final EIR volume, which was published on December 15, 2022, and includes revisions to the Draft EIR text, response to public comments received on the Draft EIR during the public comment period, and responses to late comments. The Final EIR for the project consists of the October 2022 Draft EIR, the December 2022 Final EIR volume, this Final EIR Amendment, and all documents incorporated therein.

On December 15, 2022, the City od San Carlos Focused General Plan Update Project Final EIR and Notice of Availability of the Final EIR and Notice of Public Hearings by the Planning Commission to be held on January 3, 2023 and by the City Council on January 23, 2023 were transmitted to the State Clearinghouse, members of the Planning Commission, City Council, agencies, commenters on the Draft EIR including agencies that commented on the Draft EIR, and other interested groups and individuals, as well as being published on the project webpage.

The Planning Commission held a public hearing on January 3, 2023 to consider the Final EIR and voted unanimously to recommend that the San Carlos City Council certify the Final EIR for the Focused General Plan Update Project as adequate and complete in compliance with the California Environmental Quality Act (“CEQA”), the State CEQA Guidelines, and the City’s Environmental Review Procedures, and as adequate and complete for consideration in making a decision on the merits of the Project.

Subsequent to the release of the Final EIR on December 15, 2022 and the January 3, 2023 Planning Commission hearing, minor changes were made to the Housing Element Housing Sites list, which is part of the EIR Project Description. Thus, this Final EIR Amendment is presenting information that addresses these items to be included in the Final EIR of the proposed Focused General Plan Update Project.

2. Additional Revisions to Draft EIR Text
Chapter 3 of the Final EIR contains text revisions to the Draft EIR in response to comments and to clarify or amplify the information provided in the Draft EIR. Section 2 of this Final EIR Amendment includes additional text revisions to either the Draft EIR text or the Final EIR text revisions presented in Chapter 5 of the Final EIR, as indicated below. The changes shown in the text revisions correct inaccuracies and clarify the analysis in the EIR. Text removed from the EIR is marked with strike-out. New text is indicated by underline. All of the revised text supersedes the corresponding text in the October 14, 2022 Draft EIR and the December 2022 Final EIR volume, as shown below.

None of the criteria listed in CEQA Guidelines section 15088.5 (Recirculation of an EIR Prior to Certification) indicating the need for recirculation of the Draft EIR has been met as a result of the revisions. In particular:
 no new significant environmental impact due to the project or due to a new mitigation measure has been identified;
 no substantial increase in the severity of a significant environmental impact has been identified; and

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 no additional feasible project alternative or mitigation measure considerably different from others analyzed in the Draft EIR has been identified that would clearly lessen the environmental impacts of the project.

The additional text revisions in this Final EIR Amendment are described and shown below.

Action HOU-1.2:

Below is an additional text edit that revises the language contained in Policy HOU-5.1 of the Housing Element Update, consistent with the changes made in response to the State Department of Housing and Community Development’s (HCD) comments.

Draft EIR Chapter 4.15, page 4.15-22:

Action HOU-1.2 - Residential Rehabilitation Programs. As CDBG funds are available through San Mateo County Consortium, provide grants or loans to Low and moderate-income households for the rehabilitation of residences. Examples of eligible repairs and improvements include but are not limited to energy efficiency and water conservation improvements, removal of impediments and material barriers that obstruct accessibility, roofing, plumbing repairs, electrical repairs, exterior painting, window replacement, seismic and flooding safety repairs/adaptations, and climate resiliency adaptations.  Promote the availability of home repair services for low-income and special needs households available from private agencies in the county.
 The City will proactively outreach to low- and moderate-income households regarding available grants or loans for residential rehabilitation throughout the planning period.

3. Draft EIR Figure Revision
Figure 3-6 Opportunity Sites Inventory contained in the Draft EIR has been updated to more accurately show the actual Opportunity Sites described in the Draft EIR. The updated Figure 3-6 is shown below.

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Source: San Carlos General Plan 2020; MIG 2022
Focused General Plan Update
Figure 3-6 Opportunity Sites Inventory

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4. Appendix B
Appendix B of the Draft EIR contains complete copies of the Housing Element Update and Environmental Safety and Public Services Element Update. The revised Housing Element Update containing revisions made in response to the HCD’s comments is attached in the Appendix to this Amendment.

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APPENDIX

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San Carlos Focused General Plan Update
Project: Land Use, Housing, Safety Element
Updates and Accompanying Zoning Ordinance
Amendments
Appendix B: Housing Element Update and
Environmental Safety and Public Services
Element Update

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2023

HOUSING
ELEMENT: HOUSING
PLAN
4 GENERAL
PLAN 13
Contents 113 Housing Goals, Policies, and Actions 3652 Summary of Quantified Objectives Housing Goals, Policies, and Actions San Carlos’ mission is to provide high-quality services and facilities to its residents in an equitable, sustainable, transparent, responsive, and friendly manner to foster an inclusive, safe, and healthy community now and in the future. San Carlos takes its mission to heart in developing and implementing its Housing Element. San Carlos is committed to actively encouraging, supporting, and facilitating the creation of a safe, inclusive, diverse, and affordable supply of housing for all income levels. This includes implementing housing policies that expand and preserve its affordable housing stock, encourages greater access to housing, and minimizes the displacement of vulnerable residents. To that end, this Housing Element outlines an implementation plan through goals, policies, and implementing actions. Goals are long-range, broad, and comprehensive targets. They may not necessarily be measurable nor achievable in the lifespan of this General Plan; rather, they describe an intention for the future outcome the community would like to achieve. Policies are focused and specific instructional guidelines and are resources to draw upon during the City’s decision-making process. The goals and policies are implemented through a series of housing actions. Actions identify specific programs the City will undertake toward putting each policy into action as a means to achieve goals. The goals, policies, and actions were intentionally developed and written in response to identified housing needs in the community, constraints confronting the city, and resources

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4 2023

HOUSING
ELEMENT: HOUSING
PLAN
14 GENERAL
PLAN
available to address the housing needs. This Housing Element will guide San Carlos housing policy through the 2023-2031 planning period. San Carlos’ housing goals, policies, and actions address the major housing needs identified by State law (Government Code §65583[c]):
 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 moderateincome households;  Address and, where possible, remove 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;  Preserve and improve the condition of the existing
affordable housing stock and preserve assisted (i.e., subsidized) housing developments at risk of conversion to market-rate housing; and  Promote equal housing opportunities for all people,
regardless of race, religion, sex, marital status, ancestry, national origin, color, familial status, or disability.

In addition, San Carlos’ two guiding principles supporting San Carlos’ mission statement for housing are:
 Housing in San Carlos supports an economically and
socially diverse population.
 Housing in San Carlos creates and supports vibrant
neighborhoods and a cohesive sense of community.

GOAL HOU-1: PRESERVATION AND IMPROVEMENT OF THE QUALITY AND LIVABILITY OF EXISTING HOUSING AND NEIGHBORHOODS. POLICIES POLICY HOU-1.1 Existing Residential Neighborhoods. Preserve and improve the quality and livability of existing residential neighborhoods through neighborhood improvements and housing rehabilitation programs. POLICY HOU-1.2 Lower Income Residents Displacement. Minimize potential displacement of existing lower income residents due to increasing housing prices and rents.

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2023

HOUSING
ELEMENT: HOUSING
PLAN
4 GENERAL
PLAN 15
POLICY HOU-1.3 Climate Mitigation and Adaptation Plan. Pursue strategies identified in the Climate Mitigation and Adaptation Plan to be support housing that is resilient to climate change. ACTIONS ACTION HOU-1.1 Rental Inspection Program. Continue the Rental Inspection Program to preserve and improve existing housing stock and neighborhood quality. Timeframe: Ongoing; annually conduct approximately 240 inspection visits Responsible Agency: Building Division Funding Sources: Community Development Department Budget ACTION HOU-1.2 Residential Rehabilitation Programs.  As CDBG funds are available through San Mateo County
Consortium, provide grants or loans to low- and
moderate-income households for the rehabilitation of residences. Examples of eligible repairs and improvements include but are not limited to energy efficiency and water conservation improvements, removal of impediments and material barriers that obstruct accessibility, roofing, plumbing repairs, electrical repairs, exterior painting, window replacement, seismic and flooding safety repairs/adaptations, and climate resiliency adaptations.  Promote the availability of home repair services for lowincome and special needs households available from private agencies in the county.
 The City will proactively outreach to low- and moderateincome households regarding available grants or loans for residential rehabilitation throughout the planning period.

Timeframe: Continue to participate in the San Mateo County Consortium; add information on home repair organizations to the City’s website in 2024, meet with affordable housing developers in 2024 to discuss rehabilitation opportunities; engage in proactive outreach to low-and-moderate income households annually.. Responsible Agency: Housing and Planning Divisions Funding Sources: Community Development Department Budget, CDBG, San Mateo County Consortium ACTION HOU-1.3 Preservation of At-Risk Housing. Retention of subsidized (i.e., assisted) housing is a critical part of maintaining the supply of affordable housing in San Carlos. San Carlos will continue to monitor the affordability of existing deed-restricted units and coordinate with property owners to encourage the retention of affordability of these units. At this time, San Carlos has no units

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HOUSING
ELEMENT: HOUSING
PLAN
16 GENERAL
PLAN
at-risk of converting to market rate in the next ten years; however, programs are included in the unforeseen event that affordable units become at-risk during or immediately following the Housing Element period.  Annually monitor the affordability status of at-risk rental units.
 Maintain and update the City’s list of nonprofit and
community-based organizations to contact regarding possible ownership and management of the at-risk units if they are in imminent risk of conversion.  In the event a project becomes at risk of converting to market-rate housing, work with property owners or other interested non-profit housing providers to preserve the units as affordable housing.

Timeframe: Ongoing; Annually monitor/report the affordability status of at-risk rental units as part of the Annual Progress Report process; Contact owners with expiring covenants two years in advance of the expiring covenant Responsible Agency: Economic Development and Housing Divisions Funding Sources: Community Development Department Budget ACTION HOU-1.4 Code Enforcement. San Carlos encourages the maintenance and improvement of housing for all income levels through its Code Enforcement Program. The goal of code enforcement is to minimize deferred maintenance and eliminate health and safety problems.  Continue to implement the Code Enforcement program to bring substandard housing units into compliance with City building and property maintenance codes.  Continue to refer eligible households to the available resources provided by nonprofits in the region, and as feasible connect with local volunteer groups for rehabilitation support.  Continue to evaluate staffing and funding to ensure
adequate resources for the Code Enforcement Program.

Timeframe: Ongoing Responsible Agency: Building Division Funding Sources: Community Development Department Budget

8.b
January 23, 2023 Packet Pg. 1162 
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HOUSING
ELEMENT: HOUSING
PLAN
4 GENERAL
PLAN 17
GOAL HOU-2: HIGH QUALITY, HIGHERDENSITY, MULTI-FAMILY HOUSING LOCATED CLOSE TO TRANSIT, IN DOWNTOWN, AND ALONG SAN CARLOS AVENUE AND EL CAMINO REAL POLICIES POLICY HOU-2.1 Design Quality. Promote well-designed multi-family housing and mixed-use projects in the Downtown area and along San Carlos Avenue and El Camino Real. POLICY HOU-2.2 Complete Streets. Promote development that supports the City’s Complete Streets Policy, Bicycle and Pedestrian Master Plan, and a pedestrian- and bicycle-friendly environment.ACTIONS ACTION HOU-2.1 Small Lot Development and Lot Consolidation Incentives—Citywide. As taller and denser housing developments are constructed as a result of the City Density Bonus and revisions to the Zoning Ordinance, determine whether additional incentives are necessary for the development of small and odd-shaped lots and/or lot consolidation. Incentives could include:
 Rounding up when calculating allowable units to
encourage lot consolidation.
 Providing technical assistance, such as land development counseling by Community Development staff, with consolidation or development of small and odd-shaped lots.  Conduct proactive outreach by advertising lot
consolidation and potential site opportunities to existing property owners and prospective developers. Advertising efforts may include the preparation and distribution of a brochure with information about program incentives and an invitation to attend a working session to discuss opportunities for lot consolidation or the development of small and odd-shaped lots.  Providing priority processing for affordable housing and projects that exceed minimum BMR requirements.
 Continue to provide fee deferrals and waivers for 100% affordable housing projects.

Timeframe: Ongoing; conduct a review to assess the City Density Bonus and density, height, and parking standards in the Zoning Ordinance in 2025; as needed identify additional incentives and present options to Council in 2026; review this action item on an annual basis to evaluate its effectiveness and make recommendations as needed; conduct proactive outreach annually.

8.b
January 23, 2023 Packet Pg. 1163 
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HOUSING
ELEMENT: HOUSING
PLAN
18 GENERAL
PLAN
Responsible Agency: Planning Division
Funding Sources: Community Development Department Budget ACTION HOU-2.2 Small Lot Development and Lot Consolidation Incentives— Downtown. As part of the 2022-2024 Downtown Specific Plan project, identify new incentives for small lot development and/or lot consolidation. The program may include incentives for small lots such as:
 Increasing allowable zoning density  Relaxed development standards (including parking reductions for small lots)
 Streamlined permitting process  City financial contributions, as well as other density bonuses, incentives and concessions that are otherwise required by State density bonus law for the provision of higher levels of affordable housing.  Rounding up when calculating allowable units to
encourage lot consolidation.
 Providing technical assistance, such as land development counseling by Community Development staff, with consolidation or development of small and odd-shaped lots.  Conduct proactive outreach by advertising lot
consolidation and potential site opportunities to existing property owners and prospective developers. Advertising efforts may include the preparation and distribution of a brochure with information about program incentives and an invitation to attend a working session to discuss opportunities for lot consolidation or the development of small and odd-shaped lots.  Providing priority processing for affordable housing and projects that exceed minimum BMR requirements.
 Continue to provide fee deferrals and waivers for 100% affordable housing projects.

Timeframe: Adopt a new Downtown Specific Plan with small lot development incentives by Decemberin 2025; review this action item on an annual basis to evaluate its effectiveness and make recommendations as needed; conduct proactive outreach annually Responsible Agency: Planning Division Funding Sources: Community Development Department Budget

8.b
January 23, 2023 Packet Pg. 1164 
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ELEMENT: HOUSING
PLAN
4 GENERAL
PLAN 19
GOAL HOU-3: ASSIST IN THE DEVELOPMENT OF NEW HOUSING THAT IS AFFORDABLE AT ALL INCOME LEVELS. POLICIES POLICY HOU-3.1 Housing Choices. Encourage a diversity of high-quality housing in various types, locations, and price ranges for present and future residents. POLICY HOU-3.2 Affordable Housing. Provide financial and technical assistance or referrals to facilitate the development of affordable housing. POLICY HOU-3.3 Home Ownership. Encourage home ownership opportunities for households of all income levels. POLICY HOU-3.4 Rental and Owner Housing Balance. Encourage an even distribution of rental and ownership properties throughout the city and ensure developers are aware of the City Density Bonus provisions that encourage rental housing developments.

POLICY HOU-3.5 Income Distribution of Lower Income Affordable Housing. Encourage housing units affordable to extremely low, very low and low-income households, consistent with the identified regional housing need for San Carlos. POLICY HOU-3.6 Housing Preferences. Provide housing policies and programs that give preferences, where allowable by law, to households with members who live or work in San Carlos or are employees of the City of San Carlos, and school, fire, and police districts that serve San Carlos.

ACTIONS ACTION HOU-3.1 Housing Options for Special Needs and Extremely-Low Income Households. Extremely low-income households and households with special needs have limited housing options. To meet the needs of special needs groups, innovative housing options should also be implemented.  Funding Low, Very Low, and Extremely Low-Income
and Special Needs Housing. Continue to apply the commercial/housing linkage fee to fund affordable housing and monitor fee amount to ensure it reflects market conditions. Encourage concurrent production of on or off-site affordable housing, in lieu of fee payment.

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January 23, 2023 Packet Pg. 1165 
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HOUSING
ELEMENT: HOUSING
PLAN
20 GENERAL
PLAN
Collaborate with existing and new major employers to encourage the development and funding of more affordable housing. Monitor and pursue county, state, and federal funding programs and sources for the creation of affordable housing.  Offer financial and technical assistance for housing
development projects for persons with special needs.
 As part of the Housing Element Annual Progress Report, track and report the number of new affordable housing units providing a preference for people with special needs, including seniors, homeless, people with developmental disabilities, etc. that are added to the housing stock each year.  Monitor and pursue county, state, and federal funding programs and sources for the creation of affordable housing. Prioritize available housing funding to assist in the development of housing affordable to extremely lowincome households and other special needs populations. Conduct annual proactive outreach to identify development opportunities and funding and incentives for special needs housing.  Proactively contact non-profit service providers and
developers for persons with disabilities and other special needs groups and notify them about funding opportunities, as they become available.  Continue to consult with the San Mateo County Center on Homelessness to further align efforts and coordinate homeless services.

Timeframe: Ongoing; re-evaluate opportunities for construction in-lieu of fee payment in 2024; collaborate with city’s 10 largest employers at least every other year; annually monitor and pursue funding and pursue opportunities through county, state, and federal funding programs and sources to leverage City funds; offer funding and technical assistance to projects as they are proposed, acquire property, or issue a Notice of Funding Availability when sufficient funds are acquired; conduct proactive outreach to identify development opportunities, funding, and incentives for housing affordable to extremely lowincome and other special needs households and report annually through the Housing Element Annual Report. Responsible Agency: Planning, Economic Development, and Housing Divisions Funding Sources: Community Development Department Budget, San Carlos Housing Authority, City of San Carlos BMR Funds ACITON HOU-3.2Below Market Rate (BMR) Ordinance.  Continue to implement the City’s Below Market Rate
(BMR) Ordinance requirements for rental and ownership development.

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ELEMENT: HOUSING
PLAN
4 GENERAL
PLAN 21
 Establish a process for granting priority permit processing status for approved housing projects that exceed the City’s minimum BMR requirement.  Evaluate the BMR Ordinance’s density bonuses,
incentives, and concessions to determine they continue to make the production of affordable housing feasible. As part of this process, consult with local non-profit affordable housing developers to identify potential revisions that would better support development of affordable housing, and especially Low-Income Housing Tax Credit financed housing. Revise as necessary.

Timeframe: Ongoing; establish priority permit processing in 2024; re-evaluate the BMR Ordinance in 2024 and update as needed Responsible Agency: Planning, Economic Development, and Housing DivisionsFunding Sources: Community Development Department Budget, San Carlos Housing Authority, City of San Carlos BMR Funds ACTION HOU-3.3Facilitate the Legalization and Construction of Accessory Dwelling Units (ADUs).  Support the development of accessory dwelling units
during the planning period and as new State laws modify accessory dwelling unit requirements, update the City’s ordinance to comply. The City last updated its ADU ordinance in August 2022. The City will draft amendments to address laws passed in 2022, including AB 2221 and SB 897 to reflect an up-to-date ordinance compliant with Government Code Section 65852.2.  Collaborate with surrounding jurisdictions through the 21 Elements working group to determine best approach for tracking affordability throughout the planning period.  Encourage the legalization of unpermitted accessory
dwelling units to better ensure that they are safe and habitable. As sunset date of San Carlos Municipal Code Section 18.23.210(H) approaches, consider an extension, based on history of use of this provision and anticipated ongoing need.  Work with other regional/agencies countywide
partnerships to identify potential funding sources for ADU construction.  Meet with three or four ADU builders to discuss needs and best practices. Review best practices from other cities for “pre-approved” ADUs and expedited review. Create submittal materials with documentation to facilitate expedited review. Update the City’s website and include links to “pre-approved” plans. Conduct ongoing outreach with community.

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January 23, 2023 Packet Pg. 1167 
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ELEMENT: HOUSING
PLAN
22 GENERAL
PLAN
 Review and as new information is available, update
public education materials on accessory dwelling units, including planning and building requirements, streamline processing, funding possibilities, and other resources.  Encourage local agencies, districts, and utility providers to reduce hook-up or other fees to facilitate the development of accessory dwelling units.  Prioritize ADU applications to be consistent with
Government Code Section 65852.2(a)(3) requirements for approval/denial within 60 days from the date a completed application is received.

Timeframe: Ongoing; update the ADU ordinance by June 2023; as new State laws modify accessory dwelling unit requirements, update the City’s ordinance within a timely manner (i.e., within six months); San Carlos Municipal Code Section 18.23.210(H) - 2028; work with 21 Elements – 2023; funding and pre-approved plans - 2024; establish priority process in development review in 2023 all others - Ongoing Responsible Agency: Planning and Building Divisions Funding Sources: Community Development Department Budget ACTION HOU-3.4 First-time Homebuyer Programs. Direct prospective first-time homebuyers to HEART or other County programs intended for first time homebuyers. Encourage the use of these programs though annual outreach and education. Maintain and provide information on local BMR ownership units that are resold. Timeframe: Ongoing; update information on the City’s website at least annually; conduct outreach annually to direct prospective first-time homebuyers to available resources. Responsible Agency: Economic Development and Housing DivisionsFunding Sources: Community Development Department Budget ACTION HOU-3.5 Rental Voucher Program.  Continue to implement the BMR ordinance, which
specifies Housing Choice Voucher (Section 8) eligibility in the BMR program.  Continue to work with the San Mateo County Department of Housing and nonprofit organizations to implement Housing Choice Voucher Rental Assistance programs. Continue to provide information on the Housing Choice Voucher program, including new legal requirements pursuant to SB 329, which prohibits housing discrimination on the basis of source of income (including Housing Choice Vouchers).  Continue to collaborate with other cities in San Mateo County, regional organizations, and/or nonprofit

8.b
January 23, 2023 Packet Pg. 1168 
2023

HOUSING
ELEMENT: HOUSING
PLAN
4 GENERAL
PLAN 23
organizations to evaluate and quantify potential discrimination against Housing Choice Voucher users or other rental assistance voucher programs. Continue to develop and act upon measures to address these issues.

Timeframe: Ongoing; update the City’s website annually Responsible Agency: Economic Development and Housing Divisions Funding Sources: HUD ACTION HOU-3.6 State Density Bonus Law Consistency.  Monitor State legislation as changes are made to
Government Code §65915; update the City’s density bonus programs accordingly.

Timeframe: Ongoing; annually monitor State legislation and update the City’s ordinances as needed Responsible Agency: Planning and Economic Development and Housing DivisionsFunding Sources: Community Development Department Budget ACTION HOU-3.7 No Net Loss. Government Code §65863 states that no jurisdiction shall “reduce, or require, or permit the reduction of, the residential density for any parcel to, or allow development of any parcel at, a lower residential density, or allow development at a lower residential density than projected” for properties identified in the Housing Element sites inventory unless the jurisdiction makes written findings that the reduction is consistent with the General Plan, and that the remaining sites identified in the Housing Element are adequate to accommodate the jurisdiction’s need.  Develop and maintain a sites inventory throughout the planning period.
 Evaluate residential development proposals for
consistency with goals and policies of the General Plan and the 2023-2031 Housing Element sites inventory and make written findings that any density reduction is consistent with the General Plan and that the remaining sites identified in the Housing Element are adequate to accommodate the RHNA by income level.  If a proposed reduction of residential density will result in the residential sites inventory failing to accommodate the RHNA by income level, identify and make available additional adequate sites to accommodate its share of housing need by income level within 180 days of approving the reduced density project.

Timeframe: Sites Inventory – 2023, All Others - Ongoing Responsible Agency: Planning Division Funding Sources: Community Development Department Budget

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January 23, 2023 Packet Pg. 1169 
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HOUSING
ELEMENT: HOUSING
PLAN
24 GENERAL
PLAN
ACTION HOU-3.8 Replacement of Units on Sites. Pursuant to Government Code §65583.2(g)(3), require the replacement of units affordable to the same or lower income level as a condition of any development on a nonvacant site identified in the Housing Element consistent with those requirements set forth in Government Code §65915(c)(3). Replacement requirements shall be required for sites identified in the inventory that currently have residential uses, or within the past five years have had residential uses that have been vacated or demolished, and:
 Were subject to a recorded covenant, ordinance, or law that restricts rents to levels affordable to persons and families of low- or very low-income; or  Subject to any other form of rent or price control through a public entity’s valid exercise of its police power; or  Occupied by low- or very low-income households
For the purpose of this program “previous five years” is based on the date the application for development was submitted. Pursuant to Government Code §66300(d) (Chapter 654, Statutes of 2019 (SB 330)), the City shall not approve a housing development project that will require the demolition of residential dwelling units regardless of whether the parcel was listed in the inventory unless a) the project will create at least as many residential dwelling units as will be demolished, and b) certain affordability criteria are met. To provide clarity in the development process, the City will modify the Zoning Ordinance to reference these requirements. Timeframe: OngoingRoutinely as part of the housing development approval process, require replacement of any of units if (a) they are planned to be demolished for purposes of building new housing, and (b) they are determined to be occupied by low-income households, require the provision of assistance to prevent displacement of lower-income households due to loss of affordable units. Draft an amendment to the Zoning Ordinance to implement/reference replacement requirements of State law and bring to hearings by 2024. Responsible Agency: Planning Division Funding Sources: Community Development Department Budget ACTION HOU-3.9 Development on Nonvacant Sites. Promote residential development on nonvacant sites by:
 Targeting nonvacant sites identified in the Housing
Element as priorities for fund allocation as funds are available.  Building on outreach conducted during the Housing
Element update, continue to proactively outreach to

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January 23, 2023 Packet Pg. 1170 
2023

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ELEMENT: HOUSING
PLAN
4 GENERAL
PLAN 25
property owners with a survey on how the city can support redevelopment/new housing efforts.

Timeframe: Ongoing; proactively outreach to property owners in 2023 and, in response to any additional identified constraints, draft amendments to existing policies and procedures and bring to hearings by 2024. Responsible Agency: Planning Division Funding Sources: Departmental Budget ACTION HOU-3.10Anti-Displacement Strategies. The City will take the following actions to reduce displacement risk due to discriminatory actions:
 Fair Housing Counseling. Ensure all tenants have access to legal counseling, and landlords are aware of their rights and responsibilities. Support coordination of biannual workshops for landlords and property managers on discriminatory practices, reasonable accommodation requirements, and resources and an annual presentation to staff on fair housing practices, beginning in 2023.  Rental Audits. Provide support to fair housing providers to continue to conduct annual audits of housing providers to ensure compliance with fair housing laws.  Fair Housing Case Monitoring. In 2027, upon completion of 2 iterations of biannual landlord and property manager workshops and 4 consecutive rental audits, meet with local fair housing providers, including Project Sentinel, to assess effectiveness of fair housing programs and identify additional strategies if needed.  Fair Housing Outreach Program. Include information or links to information on the City’s website in 2023 (with annual updates) and provide printed informational materials in City buildings with information on the fair housing counseling program, tenant protections, and other resources to reduce displacement risk.  Additional Strategies. Based on the above efforts, if additional strategies are required, conduct a study to Eexplore the following strategies to minimize resident displacement: implementing  Additional tTenant protection policies and  Ssupport local efforts to create a community land trust or a housing preservation fund
Timeframe: Refer to individual bullets for specific timeframes.

Consult with tenants’ rights advocates and stakeholders, complete analysis, and hold a hearing with City Council to adopt anti-displacement strategies by 2026 Responsible Agency: Planning, Economic Development, and Housing Divisions Funding Sources: Community Development Department Budget ACTION HOU-3.11

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January 23, 2023 Packet Pg. 1171 
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HOUSING
ELEMENT: HOUSING
PLAN
26 GENERAL
PLAN
Access to Opportunity. Noting historical inequities amplified/perpetuated by single family zoning, encourage small units in residential neighborhoods through development of ADUs, JADUs, and SB 9 units.  See Action HOU-3.3 for specific measures to incentivize ADUs in San Carlos.
 Review the City’s Zoning Ordinance and Subdivision
Ordinance and implement updatesamend as needed to
provide clarity and facilitate housing development under SB 9 in compliance with State law. These include adopting updated definitions, use regulations, development standards, and ministerial processes based on the outcome of a complete SB 9 analysis. As revisions to State law occur in the future, update the City’s Zoning Ordinance and Subdivision Ordinance accordingly.

Timeframe: Bring SB 9 ordinance for consideration by City Council in Fall 2023. Production and affordability will be monitored every two years thereafter and alternative actions will be implemented if necessary to meet the RHNA. Conduct proactive outreach to housing developers and property owners to promote the SB 9 ordinance through information on the City’s website, the Good City newsletter (mailed to all property owners and renters), at least two times during the planning period. Responsible Agency: Planning Division Funding Sources: Community Development Department Budget ACTION HOU-3.12 Reduce Costs Associated With The Development Of Affordable and Special Needs Housing. The City defers and waives fees for affordable housing developments to provide local match contributions and facilitate projects. The City will continue to rReduce or waive development impact fees to facilitate 100% affordable and special needs housing, including housing for extremely low-income and persons living with disabilities (including persons with developmental disabilities). Timeframe: Ongoing Responsible Agency: Planning Division Funding Sources: Community Development Department BudgetACTION HOU 3.13 Reevaluate the City Density Bonus Provisions. In 2022, the City amended its City Density Bonus program to allow rental projects to add bonus market rate units at a ratio of 4:1 for each very-low Income unit and 2:1 for each low-income unit that is included in a development project. This City Density Bonus program currently applies citywide to rental housing developments, where multi-units and mixed-use projects are a permitted land use. In conjunction with the Housing Element update to meet the RHNA, modifications to allowable density, building height, and number of stories are proposed (see Action HOU-4.2), and it is understood that the State Density Bonus allows developments to

8.b
January 23, 2023 Packet Pg. 1172 
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HOUSING
ELEMENT: HOUSING
PLAN
4 GENERAL
PLAN 27
go beyond the City’s height limits to fit all the units to which the project is entitled by the bonus. Under this action, staff will evaluate the City Density Bonus biannually to review use and implementation of the revised City Density Bonus and, as needed, to identify if the City Density Bonus should be revised to target particular areas rather than apply the Bonus uniformly throughout the City, based on place and in areas that are least impactful. Use an equity lens to ensure affordable housing and density bonuses are not concentrated in any one particular area of the community. Timeframe: Ongoing; conduct a review to assess the City Density Bonus based on place and present options to Council in 2024; reevaluate biannually thereafter. Responsible Agency: Economic Development, Housing, and Planning Divisions Funding Sources: Community Development Department Budget GOAL HOU-4: REMOVE OR MITIGATE GOVERNMENTAL CONSTRAINTS INHIBITING THE PROVISION OF ADEQUATE, AFFORDABLE HOUSING THROUGHOUT SAN CARLOS POLICY POLICY HOU-4.1 Remove and/or mitigate potential governmental constraints to the provision of housing at all income levels. ACTIONS ACTION HOU-4.1 Adequate Sites to Meet Regional Fair Share of Housing Growth. The 2009 General Plan and accompanying 2011 Zoning Ordinance allows a variety of housing types, with densities ranging from one to six units per acre in single-family zoning districts, up to 59 units per acre along San Carlos Avenue, and up to 50 units to the acre in downtown San Carlos. In support of this 6th cycle Housing Element update, the City:
 proposes to create a new multifamily residential zoning category allowing a net density of up to 100 units per acre and proposes to increase mixed use densities up to 120 units per acre, and  developed a parcel-specific inventory of sites suitable for future residential development

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January 23, 2023 Packet Pg. 1173 
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HOUSING
ELEMENT: HOUSING
PLAN
28 GENERAL
PLAN
The City will:
 Continue to provide appropriate land use designations and zoning districts consistent with regional housing needs.  Maintain an inventory of potential sites to provide to developers in conjunction with information on development incentives for affordable units.  As part of the Housing Element annual reporting process, evaluate project development against the sites inventory to ensure compliance with Government Code §65863.  Continue to pursue implementation of the General Plan through completion and adoption of implementing zoning regulations and specific plans.  Encourage senior housing and housing suitable for
persons with disabilities and other special needs (including assisted living). See Action HOU-3.1 for specific commitments to encourage senior and other special needs housing.

Timeframe: Ongoing; Establish new multifamily residential zones and upzoning of mixed-use zones as part of the Zoning Ordinance revisions to be adopted by January 2023 Responsible Party: Planning Division Funding Sources: Community Development Department Budget ACTION HOU-4.2 Zoning Ordinance Revisions. Enact the following zoning changes: 1) Create new zones; increase density, FAR, heights, number of stories; and provide minimum densities as shown in Table 4.2-1. Height limits maximum include both feet and stories (i.e. a three-story building must not exceed the height limit of 35 feet). A 35-foot height limit is considered ample to accommodate a three-story multi-family structure (floor-tofloor stories are generally 10 feet for residential). 2) Continue to allow ground floor residential uses in the MU-D100, MU-SC-120, and MU-SB-100 zones. Evaluate, as part of the new Downtown Specific Plan process, additional areas (on side streets and outside of the Downtown Core) where ground-floor residential uses may also be allowed. 3) Remove minimum private open space requirement for
residential in Mixed Use and Multi-unit zoning districts (retaining only the common/public open space requirement). 4) For residential only development, remove additional
required setbacks (i.e., removing requirement to follow RM-59 zoning setbacks) in Mixed Use zones. 5) Remove guest parking in all RM and Mixed-Use zones.

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January 23, 2023 Packet Pg. 1174 
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ELEMENT: HOUSING
PLAN
4 GENERAL
PLAN 29
6) Remove Section 18.05.030.C side and rear yard building wall stepback requirements for mixed use and multi-family housing developments, specifically provisions pertaining to stepbacks associated with portions of the building wall containing and extending three feet on either side of any window in living rooms, primary rooms, sleeping rooms, and any other walls containing windows. 7) Allow multi-family residential use in the Public (P) zoning district as an accessory use to allowed uses such as onsite religious institutions and schools according to the development standards of the RM-20 zone, but without minimum density. 8) Strengthen incentives for transit-oriented development by updating the Zoning Ordinance to reference/incorporate the minimum parking prohibitions associated with AB 2097, effective January 1, 2023, within 0.5 miles of public transit (as defined in AB 2097) in all zoning districts.

Timeframe: Identify areas appropriate for ground-floor residential uses within the Downtown Specific Plan area and bring to City Council for consideration by summer 2024; all others January 2023; if the City is not on track to achieve housing goals by 2026, identify and bring to City Council for hearing additional revisions necessary to the Zoning Ordinance or other measures to encourage housing development Responsible Agency: Planning Division Funding Sources: Community Development Department Budget Table 4.4-5: Proposed Changes to Zoning Densities and Heights (2023) Zone Maximum Density (du/ac)
Minimum Density
(du/ac)2
FAR Building Height (feet) Building Stories
(stories)
Existing Proposed Existing Proposed Existing Proposed Existing Proposed Existing Proposed Proposed Existing Proposed MU-N MU-N-40 20 40 n/a 30 2.0 2.5 50; 30 along East
San
Carlos
Avenue in
MU-N
District
50 35 along
East San
Carlos
Avenue in
MU-N
District
4 4(1)
MU-N MU-N-50 20 50 n/a 38 2.0 2.5 50 4 4 MU-N MU-N-120 20 120 n/a 90 2.0 3.0 75 4 6 MU-DC MU-DC100 50 100 n/a 75 2.5 2.5 50 4 4 MU-D MU-D-100 50 100 n/a 75 2.5 3.0 60 4 5

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PLAN
Table 4.4-5: Proposed Changes to Zoning Densities and Heights (2023) Zone Maximum Density (du/ac)
Minimum Density
(du/ac)2
FAR Building Height (feet) Building Stories
(stories)
MU-D MU-D-120 50 120 n/a 90 2.5 3.0
30 within
40 ft of
an RS
district
40 within
50 ft of
an RS
district
75 35 within
40 ft of an
RS district
40 within
50 ft of an
RS district
4 6
MU-SC MU-SC120 59 120 n/a 90 3.0 3.0 75 4 6 MU-NB MU-NB120 50 120 n/a 90 2.5 3.0 75 4 6 MU-SB MU-SB100 50 100 n/a 75 2.5 3.0 60 4 5 MU-SB MU-SB120 50 120 n/a 90 2.5 3.0 75 4 6 RM-20 RM-20 20 20 n/a 15 0.75 0.75 35 35 3 3 RM-59 RM-59 59 59 n/a 45 2.0 2.0 50 50 4 4 -- RM-100 n/a 100 n/a 75 N/A 3.0 n/a 60 n/a 5 (1) 3 stories along E. San Carlos Ave. in MU-N-40 district(2) The City of San Carlos Zoning Ordinance does not have a minimum density requirement; with this update, a minimum density threshold is proposed.

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January 23, 2023 Packet Pg. 1176 
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ACTION HOU-4.3 Outreach: New Development Standards. Prepare, publicize, and provide applicants and developers with materials highlighting the City’s revised zoning standards (Action HOU-4.2) intended to encourage the production of housing at all income levels. Timeframe: New Zoning Standards’ Materials Preparation – 2023 Responsible Agency: Planning Division Funding Sources: Community Development Department Budget ACTION HOU-4.4 Objectivity and Streamlining in Development Regulations.

Reduce the cost of building housing through, streamlining and clear and objective standards in development regulations.  Review the Zoning Ordinance and craft revisions that
support objective design standards consistent with the Housing Accountability Act. Adoption of objective design standards will facilitate high-quality residential development and compliance with State objectives.  Revise the Design Review Criteriacriteria and findings to be fully objective and to provide local guidance on design and standards for by-right projects as allowed by state law, removing subjectivity from findings and approval processes, thereby reducing permit review timeframes.  Revise the Conditional Use Permit findings for any special residential uses that require a CUP but are also covered by the Housing Accountability Act to be fully objective and to provide local guidance on design and standards for by-right projects as allowed by state law, removing subjectivity from findings and approval processes.  Reduce the permitting time for residential projects
(especially 100% affordable projects) through consideration of by-right approvals, reduced number of hearings, and objective design standards.  To accommodate future SB 35 applications and inquiries, create and make available an informational packet that explains SB 35 streamlining provisions in San Carlos and provides SB 35 eligibility information.

Timeframe: Objective Design Standards – citywide, by end of 2023; Objective Design Standards - within the Downtown Specific Plan boundary, by spring 2024; develop informational materials on SB 35 in 2025by end of 2023; re-evaluate permit review times biennially; if review times do not decrease, implement additional measures to reduce processing time. Responsible Agency: Planning Division Funding Sources: Community Development Department Budget

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January 23, 2023 Packet Pg. 1177 
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32 GENERAL
PLAN
ACTION HOU-4.5 Water and Sewer Service Providers. Immediately upon adoption, deliver the Housing Element to all providers of sewer and water service serving San Carlos, in accordance with Government Code §65589.7.  As the local sewer provider, establish procedures to grant priority sewer service to developments with units affordable to lower-income households.

Timeframe: Within one month of the Housing Element adoption deliver the Housing Element to providers; establish priority policy for sewer provision in 2024 Responsible Agency: Planning and Engineering Divisions Funding Sources: Community Development Department Budget ACTION HOU-4.5 Noise. Align City noise policies in accordance with federal and State law. Timeframe: Review citywide noise standards and ordinances to identify any necessary changes to reduce constraints to housing development; based on analysis, bring any necessary revisions to hearings by December 2024. Responsible Agency: Housing and Planning Divisions Funding Sources: Community Development Department Budget GOAL HOU-5: ADEQUATE HOUSING FOR SPECIAL NEEDS POPULATIONS. POLICIES POLICY HOU-5.1 Special Needs Population Housing. Promote the development and rehabilitation of housing to meet the needs of special needs groups, including seniors, persons with disabilities, the homeless, people with illnesses, people in need of mental health care, single parent families, large families, farmworkers, and others. POLICY HOU-5.2 Single-Room Occupancy and Efficiency Apartments. Support the inclusion of Single Room Occupancy (SRO) units and efficiency apartments in higher density neighborhoods and mixed-use areas. POLICY HOU-5.3 Emergency Shelters, Transitional, and Supportive Housing. Support programs to provide for a continuum of care for persons who are homeless including emergency shelters, transitional housing, and supportive housing. POLICY HOU-5.4

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January 23, 2023 Packet Pg. 1178 
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HOUSING
ELEMENT: HOUSING
PLAN
4 GENERAL
PLAN 33
Universal Design. Encourage the use of universal design principles to develop housing that is accessible to households with special needs. POLICY HOU-5.5 Senior Housing. Provide for a variety of housing options and affordability levels for seniors, including independent living, assisted living, and nursing home care facilities, especially within walking distance of services and transit routes and in multifamily areas. Encourage senior housing that provides on-site recreational activities, medical care, and personal services that enhance the quality of life for residents.POLICY HOU-5.6 Home Sharing. Support home sharing as a viable option to make efficient use of existing housing and as an alternative to building more housing in some areas to help address the housing needs of seniors, people living with disabilities, people at risk of homelessness, and homes with a female head of household. ACTIONS ACTION HOU-5.1 Emergency Shelters, Supportive and Transitional Housing.  Implement standards contained in the Zoning Ordinance to accommodate the need for emergency shelters, supportive housing, and transitional housing.  Review and modify the Zoning Ordinance as needed to
comply with AB 101 requirements. AB 101 requires that Low-Barrier Navigation Centers be allowed by right in areas zoned for mixed-use and nonresidential zones permitting (by right or conditionally) multi-family uses.  Review and modify the Zoning Ordinance as needed to
comply with AB 2162 requirements to allow for modifications for required parking for units occupied by supportive housing residents that are located within onehalf mile of a public transit stop.  Review and modify the Zoning Ordinance as needed to
comply with Government Code Section 65583(4)(a) to subject emergency shelters only to those development and management standards that apply to residential or commercial development within the same zone. Revise the Zoning Ordinance to require emergency shelter parking only to be sufficient to accommodate all staff working in the emergency shelter, provided that the standards do not require more parking for emergency shelters than other residential or commercial uses within the same zone.

8.b
January 23, 2023 Packet Pg. 1179 
4 2023

HOUSING
ELEMENT: HOUSING
PLAN
34 GENERAL
PLAN
 Review and modify Zoning Ordinance development
standards related to the number of residents that can be accommodated at an emergency shelter facility, which shall in no case be less than 20 beds.

Timeframe: Ongoing; review and amend the Zoning Ordinance in 2024 Responsible Agency: Planning Division Funding Sources: Community Development Department Budget ACTION HOU-5.2 Large Rental Units and Supportive Services. Discuss with developers the ability to provide larger rental units appropriate for families with children, including the provision of supportive services.Timeframe: Ongoing (as projects are proposed) Responsible Agency: Planning Division Funding Sources: Community Development Department Budget ACTION HOU-5.3 Residential Care Facilities and Group Homes. San Carlos encourages the development of residential care facilities and group homes. Consistent with State law, the City permits group homes with six or fewer residents in all residential zoning districts by right.  Amend the Zoning Ordinance code to allow group homes
with seven or more residents as a permitted use in all zones that allow multi-unit or single-unit dwellings.  Facilitate discussions with neighborhoods and adjacent uses so that good neighbor relationships are fostered and impacts to adjacent uses are mitigated.  Seek opportunities to assist nonprofit housing providers to acquire and/or rehabilitate residential housing for group homes.  Review and modify development standards for
residential care facilities and group homes to ensure the same standards apply for these uses as other residential uses of the same type in the same zone, specifically standards related to parking requirements and distancing between similar facilities. No additional parking shall be required for group residential and residential care facilities above what is required for residential uses. Remove any subjectivity in any standards or required findings to ensure residential care facilities and group homes are allowed objectively with approval certainty similar to other residential uses.

Timeframe: Amend the Zoning Ordinance in 2023 to allow group homes as a permitted use; coordinate with neighborhoods and nonprofit housing providers on an ongoing basis; amend the Zoning Ordinance by the end of 2023 to modify development

8.b
January 23, 2023 Packet Pg. 1180 
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HOUSING
ELEMENT: HOUSING
PLAN
4 GENERAL
PLAN 35
standards for residential care facilities in conjunction with Action 4.4. Responsible Agency: Planning Division Funding Sources: Community Development Department Budget ACTION HOU-5.4 Special Needs Service Providers Contributions.  On an annual basis, provide financial contributions to non-profit organizations and outside agencies that serve the housing needs of special needs households in and around San Carlos. These organizations and agencies may include but are not limited to: The Center for Independence of the Disabled (CID), HIP Housing, Shelter Network, Samaritan House, CALL Primrose, San Mateo County Children’s Fund, and HEART, among others.  Evaluate City contributions to outside agencies to assess whether to continue funding and/or adjust funding amounts or to consider other agencies for funding, particularly those organizations and agencies that provide housing with support services for persons with disabilities. As part of the evaluation, require outside agencies receiving City contributions to submit annual reports detailing how funds have been used and how programs have benefited San Carlos residents.

Timeframe: Ongoing; provide contributions on an annual basis through the CDBG funding process Responsible Agency: Economic Development and Housing Divisions Funding Sources: Community Development Department Budget, CDBG ACTION HOU-5.5 Revised Development Standards to Support Special Needs Housing.  Consider amending the Zoning Ordinance to clarify that development standards that allow for separate cooking and/or bathroom facilities in home sharing programs, and universal design (including “visitability”) in all new residential development and significant remodeling projects.  Encourage the development of well-designed new
accessory dwelling units in existing neighborhoods by implementing objective standards for the approval of accessory units. Include an ADA accessible design option in pre-approved ADU plans.  Encourage unhoused service or navigation centers to be located within or near SROs, transitional, and or/supportive housing.

8.b
January 23, 2023 Packet Pg. 1181 
4 2023

HOUSING
ELEMENT: HOUSING
PLAN
36 GENERAL
PLAN
 Review the Zoning Ordinance and identify amendments
to ensure findings for reasonable accommodation requests are limited to health and safety considerations and those allowed by State law.

Timeframe: Ongoing; complete a study on zoning needs for home sharing and universal design and bring to City Council for consideration in 2025; review/revise the Reasonable Accommodation Ordinance and bring appropriate amendments to the City Council for hearing by December 2024 Responsible Agency: Planning Division Funding Sources: Community Development Department Budget ACTION HOU-5.6 Equal Access to City Services. Adopt an accessibility policy establishing standards and procedures for providing equal access to City services and programs to all residents, including persons with limited proficiency in English, and persons with disabilities. Timeframe: Hold a hearing with City Council to consider the accessibility policy in 2024 Responsible Agency: Administration Division Funding Sources: Administrative Services Budget ACTION HOU-5.7
Community Governance. Conduct public meetings at suitable times, accessible to persons with disabilities, and near public transit. Resources will be invested to provide interpretation and translation services when requested at public meetings. Timeframe: Ongoing Responsible Agency: City Clerk and Administration Division Funding Sources: Administrative Services Budget ACTION HOU-5.8 Furthering Integration. Promote fair housing by allowing multifamily residential uses on all sites in the P (Institutional Use) zone as an accessory use to allowed uses such as onsite religious institutions and schools. Reference/incorporate the minimum parking prohibitions associated with AB 2097, effective January 1, 2023, within 0.5 miles of public transit (as defined in AB 2097). Timeframe: Amend the Zoning Ordinance in 2023 Responsible Agency: Planning Division Funding Sources: Community Development Department Budget GOAL HOU-6: ELIMINATE DISCRIMINATION IN THE PROVISION OF HOUSING AND AFFIRMATIVELY FUTHER FAIR HOUSING. POLICY

8.b
January 23, 2023 Packet Pg. 1182 
2023

HOUSING
ELEMENT: HOUSING
PLAN
4 GENERAL
PLAN 37
POLICY HOU-6.1 Fair Housing Law Enforcement and Discrimination Complaints.  Enforce fair housing laws to ensure that households
seeking housing are not discriminated against on the basis of race, color, religion, sex, disability, age, martial status, family composition, national origin, sexual orientation or other arbitrary factors, consistent with the Fair Housing Act.  Refer discrimination complaints to the appropriate legal service, County, or State agency.
 Ensure that housing programs maximize choice and avoid unlawful discrimination.

ACTIONS ACTION HOU-6.1 Affirmatively Furthering Fair Housing. Fair housing laws prohibit housing discrimination based on race, color, religion, sex, or national origin. San Carlos has identified the following objectives/meaningful actions to affirmatively further fair housing (Table 4.2-2):

8.b
January 23, 2023 Packet Pg. 1183 
4 2023

HOUSING
ELEMENT: HOUSING
PLAN
38 GENERAL
PLAN
Table 4.2-2: Affirmatively Furthering Fair Housing Issues, Contributing Factors, and Actions Identified Fair Housing Issue
and Priority
(Hi
gh, Medium, Low)
Contributing Factors Meaningful Actions
Insufficient and Inaccessible Housing Options in High Opportunity AreaCitywide for people who identify with any protected class (Fair Housing Education, Housing Mobility) Priority: [High]  Location and type of affordable housing  Lack of access to opportunity due to high housing cost
 Lack of fair housing outreach and enforcement  Availability of affordable housing  Availability of affordable units in a range of sizes.

Fair Housing Education
 Continue to support local agencies and organizations that provide fair housing services to San Carlos residents. Geographic Target: Citywide Timeframe: Annually through the San Mateo County Consortium, which distributes CBDG funding. 2023-2031 Metrics: Track funding support to fair housing providers through the County’s Annual Action Plan  Include a fair housing presentation in City Council meetings. and continue to educate and train City staff regarding fair housing laws. As appropriate, partner with organizations such as Project Sentinel to provide resources. Timeframe: at least once every other year. Geographic Target: Citywide 2023-2031 Metrics: Provide an annual fair housing presentation to Council and biennially provide fair housing training for staff involved in housing  Ensure that all development applications are considered, reviewed, and approved without prejudice to the proposed residents, contingent on the development application’s compliance with all entitlement requirements. Timeframe: Ongoing Geographic Target: Citywide 2023-2031 Metrics: At random audit two applications per year to ensure compliance  Require non-discrimination clauses in rental agreements and deed restrictions for affordable housing. Timeframe: Ongoing Geographic Target: Citywide 2023-2031 Metrics: Each new and continued affordable housing rental agreement/deed restriction  Promote public awareness of federal, State, and local regulations regarding equal access to housing. Provide information to the public on various state and federal housing programs and fair housing law. Maintain referral

8.b
January 23, 2023 Packet Pg. 1184 
2023

HOUSING
ELEMENT: HOUSING
PLAN
4 GENERAL
PLAN 39
Table 4.2-2: Affirmatively Furthering Fair Housing Issues, Contributing Factors, and Actions Identified Fair Housing Issue
and Priority
(Hi
gh, Medium, Low)
Contributing Factors Meaningful Actions
information on the City’s website and at a variety of other locations such as community and senior centers, local social service offices, in City utility bills, and at other public locations including City Hall and the library. Add resources and information in Spanish and make available to the public.Continue to coordinate with other agencies and organizations, including 21 Elements, to identify other means of informing residents about fair housing laws. Timeframe: four times per year as part of fair housing workshops by Project Sentinel and other housing related events. Geographic Target: Citywide with focus on areas northwest of El Camino Real and along San Carlos Avenue with higher proportions of non-White residents and north of Cherry Street and along El Camino Real with higher proportions of people with disabilities.2023-2031 Metrics: Provide counseling and services to at least four San Carlos residents during the planning period The three identified fair housing issues are closely related, as such, the meaningful action items address all issues. Housing Mobility  Require affordable housing developers receiving public funds to prepare an affirmative marketing plan, and encourage private developers with affordable units in their projects to prepare affirmative marketing plans. The plan shall ensure marketing materials for new developments are designed to attract renters and buyers of diverse demographics, including persons of any race, ethnicity, sex, handicap, and familial status. Timeframe: As part of the entitlement process Geographic Target: Residential and Mixed Use neighborhoods citywide 2023-2031 Metrics: All affordable housing developers receiving public funds should prepare an affirmative marketing plan

8.b
January 23, 2023 Packet Pg. 1185 
4 2023

HOUSING
ELEMENT: HOUSING
PLAN
40 GENERAL
PLAN
Table 4.2-2: Affirmatively Furthering Fair Housing Issues, Contributing Factors, and Actions Identified Fair Housing Issue
and Priority
(Hi
gh, Medium, Low)
Contributing Factors Meaningful Actions
 Action 3.2: Continue to implement the City’s Below Market Rate (BMR) Ordinance requirements for rental and homeownership development; establish a process for granting priority permit processing status for approved housing projects that exceed the City’s minimum BMR requirement; Evaluate the BMR Ordinance’s density bonuses, incentives, and concessions to determine they continue to make the production of affordable housing feasible. As part of this process, consult with local nonprofit affordable housing developers to identify potential revisions that would better support development of affordable housing, and especially Low-Income Housing Tax Credit financed housing. Revise as necessary. Timeframe: Ongoing; establish priority permit processing in 2024; re-evaluate the BMR Ordinance in 2024 and update as needed Geographic Target: Citywide, particularly in the City’s highest income areas 2023-2031 Metrics: Increase the development of affordable housing units through the BMR Ordinance by 15% of the baseline  Action HOU-3.3 (ADUs): Offer pre-approved plans, which support streamlining the permit review process; Promote additional pre-approved plans on the City’s website; Provide homeowner/ applicant assistant tools by including and promoting State funding resources including the CalHFA ADU grant program and Casita Coalition financing guide on the City’s website, and by promoting home sharing programs to connect ADU owners and renters, and offering counseling with a City staff-ADU specialist; Explore and pursue funding options to support ADU construction for lower-income homeownersTimeframe: Offer pre-approved plans no later than 2024; ongoing ADU development support; monitor ADUs annually and

8.b
January 23, 2023 Packet Pg. 1186 
2023

HOUSING
ELEMENT: HOUSING
PLAN
4 GENERAL
PLAN 41
Table 4.2-2: Affirmatively Furthering Fair Housing Issues, Contributing Factors, and Actions Identified Fair Housing Issue
and Priority
(Hi
gh, Medium, Low)
Contributing Factors Meaningful Actions
implement alternative strategies within one year of the annual report if assumptions are not met. Geographic Target: Single-family residential neighborhoods citywide 2023-2031 Metric: Achieve 203 ADUs during the planning cycle  Action HOU-3.4: Proactively outreach to developers and homebuyers regarding available homeownership financing options. Timeframe: Annually conduct outreach and education efforts Geographic Target: Areas with residents who have historically faced barriers to homeownership such as areas in the northwest of El Camino Real and along San Carlos Avenue with higher proportions of non-White residents; north of Cherry Street and along El Camino Real with higher proportions of people with disabilities; and south of El Camino Real between Holly Street and Arroyo Avenue with higher proportions of low-to-moderate income households.2023-2031 Metric: Provide homeownership financing options and resource information to at least 10 residents annually  Action 3.11: Noting historical inequities
amplified/perpetuated by single family zoning, encourage small units in residential neighborhoods through development of ADUs, JADUs, and SB 9 units. Timeframe: Bring SB 9 ordinance for consideration by City Council in Fall 2023. Production and affordability will be monitored every two years thereafter. Geographic Target: Single-family neighborhoods citywide 2023-2031 Metrics: Achieve 203 ADUs and 160 SB 9 duplex construction during the planning period  Action 5.2: Discuss with developers the ability to provide larger rental units appropriate for families with children, including the provision of supportive services. Timeframe: Ongoing (as projects are proposed) Geographic Target: Multi-family residential neighborhoods

8.b
January 23, 2023 Packet Pg. 1187 
4 2023

HOUSING
ELEMENT: HOUSING
PLAN
42 GENERAL
PLAN
Table 4.2-2: Affirmatively Furthering Fair Housing Issues, Contributing Factors, and Actions Identified Fair Housing Issue
and Priority
(Hi
gh, Medium, Low)
Contributing Factors Meaningful Actions
2023-2031 Metrics: Complete at least one project that includes these types of units and services during the planning period  Action 5.8: Promote fair housing by allowing multi-family residential uses on all sites in the P (Institutional Use) zone as an accessory use to allowed uses such as onsite religious institutions and schools. Reference/incorporate the minimum parking prohibitions associated with AB 2097, effective January 1, 2023, within 0.5 miles of public transit (as defined in AB 2097). Timeframe: Amend Zoning Ordinance by 2023 Geographic Target: Institutional Use Zone 2023-2031 Metrics: Complete at least one multi-family project in the Institutional Use Zone during the planning period Action Outcomes: An increased variety of housing options available to San Carlos residents throughout the city, including areas that have traditionally only had single-family ownership housing. Provide adequate sites for over 1,164 lower income households, over 438 moderate income households, and over 1,133 above moderate income households, exceeding the City’s RHNA requirements.Continue to support local agencies and organizations that provide fair housing services to San Carlos residents. Timeframe: Annually through the San Mateo County Consortium, which distributes CBDG funding.Require non-discrimination clauses in rental agreements and deed restrictions for affordable housing. Timeframe: ongoing for each new and continued affordable housing rental agreement/deed restrictionPromote public awareness of federal, State, and local regulations regarding equal access to housing. Provide information to the public on various state and federal housing programs and fair housing law. Maintain referral information on the City’s website and at a variety of other locations such as community and senior centers, local social service offices, in City utility bills, and at other public locations including City Hall and the library. Add resources and information in Spanish and make available to the public. Continue to coordinate

8.b
January 23, 2023 Packet Pg. 1188 
2023

HOUSING
ELEMENT: HOUSING
PLAN
4 GENERAL
PLAN 43
Table 4.2-2: Affirmatively Furthering Fair Housing Issues, Contributing Factors, and Actions Identified Fair Housing Issue
and Priority
(Hi
gh, Medium, Low)
Contributing Factors Meaningful Actions
with other agencies and organizations, including 21 Elements, to identify other means of informing residents about fair housing laws. Timeframe: four times per year as part of fair housing workshops by the Fair Housing Foundation and other housing related events.Include a fair housing presentation in City Council meetings. Continue to educate and train City staff regarding fair housing laws. As appropriate, partner with organizations such as Project Sentinel to provide resources. Timeframe: at least once every other year.Implement an accessibility policy that establishes standards and procedures for providing equal access to City services and programs to all residents, including persons with limited proficiency in English, and persons with disabilities. Timeframe: By 2024Ensure that all development applications are considered, reviewed, and approved without prejudice to the proposed residents, contingent on the development application’s compliance with all entitlement requirements. Timeframe: OngoingContinue to use the Rental Inspection Program as a tool to monitor and address fair housing issues. Timeframe: OngoingConduct public meetings at suitable times, accessible to persons with disabilities, and near public transit. Resources will be invested to provide interpretation and translation services when requested at public meetings. Timeframe: OngoingPrioritize community and stakeholder engagement during controversial development decisions. Timeframe: OngoingContinue to educate landlords on fair housing law, reasonable accommodations and disability rights, including posting reasonable accommodations on the website and at prominent location near the permit counter. Timeframe: OngoingRelated actions in this Housing Plan meet multiple needs, including affirmatively furthering fair housing, including: Action HOU-1.1: Rental Inspection Program Action HOU-1.2: Residential Rehabilitation Programs Action HOU-1.3: Preservation of At-Risk Rental Housing Action HOU-3.1: Funding Low, Very Low-, and Extremely LowIncome and Special Needs Housing

8.b
January 23, 2023 Packet Pg. 1189 
4 2023

HOUSING
ELEMENT: HOUSING
PLAN
44 GENERAL
PLAN
Table 4.2-2: Affirmatively Furthering Fair Housing Issues, Contributing Factors, and Actions Identified Fair Housing Issue
and Priority
(Hi
gh, Medium, Low)
Contributing Factors Meaningful Actions
Action HOU-3.2: BMR Ordinance Action HOU-3-3: Accessory Dwelling Units Action HOU-3.4: First-Time Homebuyer Programs Action HOU-3.5: Rental Voucher Program Action HOU-3.10: Anti-Displacement Strategies Action HOU-3.11: Access to Opportunity Action HOU-3.12: Affordable and Special Needs Incentives Action HOU-4.1: Adequate Sites to Meet the RHNA Action HOU-4.2: Zoning Ordinance Revisions Action HOU-4.3: Outreach: New Development Standards Action HOU-5.2: Large Rental Units and Supportive Services Action HOU-5.3: Residential Care Facilities and Group Homes Action HOU-5.4: Special Needs Service Providers Contributions Action HOU-5.5: Revised Development Standards to Support Special Needs Housing Action HOU-5.6: Equal Access to City Services Action HOU-5.7: Community Governance Action HOU-5.8: Furthering Integration Action HOU-6.1: Fair Housing Law Enforcement and Discrimination Complaints Action HOU-8.1: Partnership Programs Protecting Existing Residents from Displacement (Displacement/Housing Affordability) Priority: [Moderate]  Due to economic pressures  Availability of affordable housing  Availability of affordable units in a range of prices
Displacement/Housing Affordability
 Action 1.1: Continue the Rental Inspection Program to preserve and improve existing housing stock and neighborhood quality. Timeframe: Annually Geographic Target: Multi-family residential neighborhoods 2023-2031 Metric: Conduct 240 inspection visits annually  Action 1.2: As CDBG funds are available through San Mateo County Consortium, provide grants or loans to low- and moderate-income households for the rehabilitation of residences; Promote the availability of home repair services for low-income and special needs households available from private agencies in the county.

8.b
January 23, 2023 Packet Pg. 1190 
2023

HOUSING
ELEMENT: HOUSING
PLAN
4 GENERAL
PLAN 45
Table 4.2-2: Affirmatively Furthering Fair Housing Issues, Contributing Factors, and Actions Identified Fair Housing Issue
and Priority
(Hi
gh, Medium, Low)
Contributing Factors Meaningful Actions
Timeframe: Annually or as funding becomes available Geographic Target: Multi-family residential neighborhoods and south of El Camino Real between Holly Street and Arroyo Avenue with higher proportions of low-to-moderate income households. 2023-2031 Metrics: Assist 2 low-to-moderate-income households annually.  Action 1.3: San Carlos will continue to monitor the
affordability of existing deed-restricted units and coordinate with property owners to encourage the retention of affordability of these units. Timeframe: Annually monitor/report the affordability status of atrisk rental units as part of the Annual Progress Report process; Contact owners with expiring covenants two years in advance of the expiring covenant. Geographic Target: Multi-family residential neighborhoods and areas south of El Camino Real between Holly Street and Arroyo Avenue with higher proportions of low-to-moderate income households. 2023-2031 Metric: Retain affordability of 137 units at 17 housing complexes  Action 3.1: Continue to apply the commercial/housing
linkage fee to fund affordable housing and monitor fee amount to ensure it reflects market conditions. Encourage concurrent production of on or off-site affordable housing, in lieu of fee payment. Collaborate with existing and new major employers to encourage the development and funding of more affordable housing. Timeframe: Re-evaluate opportunities for construction in-lieu of fee payment in 2024; collaborate with city’s 10 largest employers at least every other year; annually monitor and pursue funding opportunities through county, state, and federal funding programs and sources to leverage City funds Geographic Target: Citywide

8.b
January 23, 2023 Packet Pg. 1191 
4 2023

HOUSING
ELEMENT: HOUSING
PLAN
46 GENERAL
PLAN
Table 4.2-2: Affirmatively Furthering Fair Housing Issues, Contributing Factors, and Actions Identified Fair Housing Issue
and Priority
(Hi
gh, Medium, Low)
Contributing Factors Meaningful Actions
2023-2031 Metric: Contribute to the production and/or preservation of at least 60 affordable housing units over the planning period  Action 3.5: Continue to work with the San Mateo County Department of Housing and nonprofit organizations to implement Housing Choice Voucher Rental Assistance programs. Continue to provide information on the Housing Choice Voucher program, including new legal requirements pursuant to SB 329, which prohibits housing discrimination on the basis of source of income (including Housing Choice Vouchers). Continue to collaborate with other cities in San Mateo County, regional organizations, and/or nonprofit organizations to evaluate and quantify potential discrimination against Housing Choice Voucher users or other rental assistance voucher programs. Continue to develop and act upon measures to address these issues. Timeframe: Annually Geographic Target: Citywide 2023-2021 Metrics: Annually reach 100 individuals, as measured in website hits, providing information about Housing Choice Vouchers Action 3.10: Take actions to reduce displacement, including fair housing counseling, rental audits, fair housing case monitoring, outreach, and additional tenant protection policies; Support local efforts to create a community land trust or a housing preservation fund Timeframe: Consult with tenants’ rights advocates and stakeholders, complete analysis, and hold a hearing with City Council to adopt anti-displacement strategies by 2026 Geographic Target: Multi-family residential neighborhoods and areas south of El Camino Real between Holly Street and Arroyo Avenue with higher proportions of low-to-moderate income households. 2023-2031 Metric: Partner with a community-based organization to provide residents with informational materials

8.b
January 23, 2023 Packet Pg. 1192 
2023

HOUSING
ELEMENT: HOUSING
PLAN
4 GENERAL
PLAN 47
Table 4.2-2: Affirmatively Furthering Fair Housing Issues, Contributing Factors, and Actions Identified Fair Housing Issue
and Priority
(Hi
gh, Medium, Low)
Contributing Factors Meaningful Actions
and workshops on latest anti-displacement strategies at least three times soon after adoption.  Action 8.1: Continue to work with housing services
organizations, or other similar organizations, to increase housing opportunities in San Carlos. Explore partnerships with housing operators, non-profit organizations, and developers to rehabilitate and convert existing market rate rental housing into affordable housing for extremely low, very low, low and moderate-income households.  Timeframe: Discuss opportunities with developers that contact the City annually
 Geographic Targeting: Multi-family residential neighborhoods and areas south of El Camino Real between Holly Street and Arroyo Avenue with higher proportions of low-to-moderate income households.  2023-2031 Metric: Develop at least one new partnership with housing organizations annually.

Action Outcomes: Strategic tenant protection policy recommendations will slow the pace and mitigate the impacts of displacement, and development of partnerships and strategies will preserve unsubsidized affordable housing (non-deed restricted).

Provide Access and Inclusion for Persons with Disabilities (Access to Housing and Resources) Priority: [Moderate]i  Lack of supportive services for persons with
disabilities
 Lack of access to resources, such as schools,
transportation, and other in home or community resources for persons with disabilities  Implement an accessibility policy that establishes standards and procedures for providing equal access to City services and programs to all residents, including persons with limited proficiency in English, and persons with disabilities. Timeframe: By 2024Geographic Target: Areas with high proportions of non-native English speakers and north of Cherry Street and Along El Camino Real with higher proportions of people with disabilities 2023-2021 Metric: Upon adoption of accessibility policy, assist at 20 persons annually with disability needs  Conduct public meetings at suitable times, accessible to persons with disabilities, and near public transit. Resources

8.b
January 23, 2023 Packet Pg. 1193 
4 2023

HOUSING
ELEMENT: HOUSING
PLAN
48 GENERAL
PLAN
Table 4.2-2: Affirmatively Furthering Fair Housing Issues, Contributing Factors, and Actions Identified Fair Housing Issue
and Priority
(Hi
gh, Medium, Low)
Contributing Factors Meaningful Actions
will be invested to provide interpretation and translation services when requested at public meetings. Timeframe: Ongoing Geographic Target: Citywide 2023-2021 Metric: Provide at least one person at public meetings that can provide translation services.  Continue to educate landlords on fair housing law,
reasonable accommodations and disability rights, including posting reasonable accommodations on the website and at prominent location near the permit counter. Timeframe: Ongoing Geographic Target: Citywide 2023-2031 Metric: Outreach to at least five landlords annually.  Action 3.12: Continue to reduce or waive development
impact fees to facilitate 100% affordable and special needs housing, including housing for extremely low-income and persons living with disabilities (including persons with developmental disabilities). Timeframe: Ongoing Geographic Target: Citywide 2023-2031 Metric: Waive or reduce development impact fees for at least one special needs project during the planning period.  Action 5.3: Continue to encourage the development of
residential care facilities and group homes. Timeframe: Ongoing Geographic Target: Citywide 2023-2031 Metric: Assist at least one nonprofit housing provider to acquire and/or rehabilitate residential housing with supportive services during the planning period.  Action 5.4: On an annual basis, provide financial
contributions to non-profit organizations and outside agencies that serve the housing needs of special needs households in and around San Carlos. These organizations and agencies may include but are not limited to: The Center for Independence of the Disabled (CID), HIP Housing,

8.b
January 23, 2023 Packet Pg. 1194 
2023

HOUSING
ELEMENT: HOUSING
PLAN
4 GENERAL
PLAN 49
Table 4.2-2: Affirmatively Furthering Fair Housing Issues, Contributing Factors, and Actions Identified Fair Housing Issue
and Priority
(Hi
gh, Medium, Low)
Contributing Factors Meaningful Actions
Shelter Network, Samaritan House, CALL Primrose, San Mateo County Children’s Fund, and HEART, among others. Timeframe: Annually Geographic Target: Citywide 2023-2031 Metric: Provide financial contributions to at least one non-profit organization as funding becomes available.

Action Outcomes: Increased options for safe, high quality, accessible, and affordable housing for people with disabilities throughout the City that are located near critical community resources and infrastructure. Will help dissipate any existing concentrations of people with disabilities in the city and promote integration.

Timeframe: Identified in Table above for each Action Responsible Agency: Economic Development, Housing, and Planning Divisions Funding Sources: Community Development Department Budget GOAL HOU-7: INCREASED ACCESS TO CHILDCARE. POLICY Policy HOU-7.1 Access to Childcare. Increase access to childcare by including childcare facility siting opportunities and reducing regulatory and financial barriers to the creation and expansion of childcare facilities in San Carlos. ACTIONS ACTION HOU-7.1 Childcare development impact fee. Study and hold a hearing with City Council to consider establishing a childcare
development impact fee for new nonresidential developments.

8.b
January 23, 2023 Packet Pg. 1195 
4 2023

HOUSING
ELEMENT: HOUSING
PLAN
50 GENERAL
PLAN
Timeframe: Complete study and hold a hearing with City Council by spring 2023 Responsible Agency: Economic Development and Housing Divisions Funding Sources: Community Development Department Budget ACTION HOU-7.2 Childcare Zoning.  Allow by-right the siting and development of family
childcare homes in all residential, mixed-use, and other zones where residences are permitted, for the convenience of families. Consider modified zoning standards, modified review procedures, and other incentives to facilitate childcare centers’ development in mixed-use and commercial zones and as an accessory use to religious/community facilities in residential zones.  Encourage the inclusion of space for childcare in new housing developments, including affordable housing developments, as feasible.  Ensure that zoning code and permitting practices are
consistent with State law that prohibits use permits, business licenses, etc. for Large Family Child Care Homes.  In addition to the traffic impact fee exemption already provided, continue the discussion with decision makers to consider potential incentives for developers to provide childcare facilities or services as part of new residential, commercial, and industrial developments, including but not limited to: density bonuses, increases in floor area ratios, parking reduction, community benefits credit, expedited entitlements, or other modifications to zoning regulations.

Timeframe: Complete study and hold a hearing with City Council in 2025 Responsible Agency: Planning Division Funding Sources: Community Development Department Budget GOAL HOU-8: INCREASING COMMUNITY PARTNERSHIPS AND PUBLIC EDUCATION POLICY POLICY HOU-8.1 Partnerships. Further housing opportunities, affordability, and access throughout San Carlos and the region by partnering with other jurisdictions, community organizations, and jurisdictions while educating San Carlos residents, business community, and service providers about housing issues and opportunities. ACTIONS ACTION HOU-8.1

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2023

HOUSING
ELEMENT: HOUSING
PLAN
4 GENERAL
PLAN 51
Partnership Programs Continue to work with the following organizations, or other similar organizations, to increase housing opportunities in San Carlos:
 HIP Housing – home sharing programs including
potential owners and renters matching;
 21 Elements – funding sources for low-, very low-, and extremely low- income housing, funding sources for special needs housing; rental voucher discrimination claims, among others; funding sources for ADU construction or remodels and best practices to encourage ADUs  San Mateo County Consortium  San Mateo Department of Housing – Section 8 housing assistance
 HEART – first time home buyers programs  Others as opportunities arise Explore partnerships with housing operators, non-profit organizations, and developers to rehabilitate and convert existing market rate rental housing into affordable housing for extremely low, very low, low and moderate-income households. Timeframe: Ongoing; discuss opportunities with developers that contact the City annually Responsible Agency: Economic Development, Housing, and Planning Divisions
Funding Sources: Community Development Department Budget

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4 2023

HOUSING
ELEMENT: HOUSING
PLAN
52 GENERAL
PLAN
Summary of Quantified Objectives Table 4.2-3 summarizes San Carlos’ quantified objectives for the 2023-2031 Housing Element planning period.  The Construction Objective represents the City’s 2023- 2031 RHNA.
 The Rehabilitation Objective represents the objective for the Rental Inspection Program over the eight-year planning period; of the 240 annual inspection visits, approximately one-third (80 units) require a correction/rehabilitation annually.  The Conservation/Preservation objective refers to the preservation of the existing affordable housing stock throughout the planning period (as listed in Table 4.3-8: Below Market Rate Housing Inventory in the Housing Needs Assessment chapter).

Table 4.2-3: Housin
g Element Quantified Objectives
Income Level
Extremely Total
Low
Very
Low
Low Moderate Above Moderate
Construction Objective (RHNA) 370 739369 425 438 1,133 2,735 Rehabilitation Objective 107 640107 213 213 -- 640 At-Risk Affordable Housing Units to Preserve 4020 20 57 32 -- 137

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RESOLUTION NO. 2023-___

A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF SAN CARLOS REPEALING THE CITY OF SAN CARLOS 2015-2023 HOUSING ELEMENT AND ADOPTING THE CITY OF SAN CARLOS 2023-2031 HOUSING ELEMENT. ____________________________________________________________________________ WHEREAS, the City of San Carlos’ Strategic Objective is to actively encourage and support the creation of housing to provide a safe, inclusive, diverse, and affordable supply by facilitating development for all income levels; and
WHEREAS, the City of San Carlos has undertaken a process to update the City of San Carlos Housing Element 2015-2023 in accordance with State law; and WHEREAS, State Housing Element Law (Government Code Sections 65580 et seq.) requires that the City of San Carlos adopt a housing element for the eight-year period 2023- 2031 to accommodate the regional housing need allocation (RHNA) assigned to the County City by the Association of Bay Area Governments of 2,735 housing units, comprised of 739 units affordable to very-low income households, 425 units affordable to low-income households, 438 units affordable to moderate-income households, and 1,133 units affordable to above moderateincome households; and WHEREAS, on May 26, 2020 the City Council authorized the City Manager to enter into a Professional Services Agreement with MIG for consulting services to prepare a Focused General Plan Update (Land Use, Housing, and Safety Elements), corresponding Zoning Ordinance Amendments and an Environmental Impact Report in response to the City Council’s Strategic Objective to study land use and other regulatory options to increase all types of housing pursuant to the State mandate to update the San Carlos Housing Element consistent with State law; and
WHEREAS, the preparation, adoption, and implementation of a housing element requires a diligent effort to include all economic segments of the community and to take actions to affirmatively further fair housing; and
WHEREAS, the City solicited public input through community surveys from midOctober through early December 2020 and again from early January 2021 through midFebruary 2021; and WHEREAS, the City held public outreach workshops with the community on November 30, 2020; January 20, 2021; May 26, 2021; and August 11, 2021 to discuss housing and environmental safety; community values, issues, and concerns; key housing priorities; land use strategies; housing changes and solutions; and housing changes and zoning strategies; and
WHEREAS, prior to the workshops and surveys, City of San Carlos staff conducted robust community outreach to encourage maximum participation. This included social media posts on San Carlos’ Facebook, NextDoor, Instagram, and Twitter accounts. Announcements about the project and workshops were made at public meetings including City Council, Planning and Transportation Commission, Economic Development Advisory Council, and Youth Advisory Council meetings. In addition, the workshops were promoted through the City of San Carlos’ Spotlight Newsletter, Good Living Newsletter, City Council Newsletter, Adult Community Center

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Newsletter, Chamber of Commerce Newsletter, and San Carlos’ E-notify (email) communication system. Grassroots efforts included booths at the San Carlos Farmer’s Market and flyers throughout the Downtown; and
WHEREAS, on September 27, 2021 the City Council held a study session to receive a status report on the Housing Element Update process for the 2023-2031 planning period, including proposed zoning density and building height increases; and WHEREAS, on January 12, 2022 the City of San Carlos staff and MIG consulting team held a scoping session at a regular meeting of the Planning Commission to solicit input on the project’s forthcoming Environmental Impact Report for the Housing Element Update and other associated amendments to the San Carlos General Plan and Zoning Ordinance; and WHEREAS, in accordance with Government Code Section 65585(b), on August 30, 2022 the City posted the Preliminary Draft Housing Element and requested public comment for a 30-day review period; and
WHEREAS, on September 19, 2022 the Planning Commission reviewed the Preliminary Draft Housing Element and provided comments to staff prior to submitting the Element to the State Department of Housing and Community Development for review; and WHEREAS, on September 26, 2022 the City Council reviewed a Preliminary Draft Housing Element and provided comments to staff prior to submitting the Element to the State Department of Housing and Community Development (HCD) for review; and WHEREAS, the City of San Carlos referred the 2023-2031 Housing Element to all California Native American tribes on the contact list provided by the Native American Heritage Commission and to other entities listed; and
WHEREAS, no California Native American tribe requested consultation; and WHEREAS, the Draft 2023-2031 Housing Element directs new housing growth to areas previously designated for residential uses, which is consistent with the Comprehensive Airport Land Use Compatibility Plan for the Environs of San Carlos Airport (“ALUCP”) Safety Compatibility Policy 2 – Residential Development Criteria, stating that in Safety Zone 6 (Exhibit 4-3 of the ALUCP) new residential development is compatible and not restricted for safety reasons; and
WHEREAS, on October 14, 2022, after responding to public comments, City staff submitted the Draft 2023-2031 Housing Element to HCD for its initial 90-day review period; and WHEREAS, on January 6, 2023, the City received a letter from HCD providing its findings regarding the Draft 2023-2031 Housing Element, and on January 13, 2023 the City published a revised Draft 2023-2031 Housing Element responding to HCD’s findings; and WHEREAS, the Draft 2023-2031 Housing Element has been prepared in compliance with State Housing Element Law and contains all of the elements mandated by State Housing Element Law, as shown in Exhibit A – Housing Element Statutory Provisions Checklist, attached hereto and incorporated by this reference; and
WHEREAS, parcels with existing uses that were not likely to be discontinued during the

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planning period were not examined for suitability, as follows: parcels in the PK (Park) and OS (Open Space) Zoning Districts; parcels with existing designated historic resources; parcels that are under construction, or have recently completed projects, approved entitlements, or pending entitlements for commercial uses only; parcels that have unique land uses, such as City Hall, parks, and libraries; parcels developed with affordable housing; and all remaining parcels with existing uses that would allow residential redevelopment were examined for suitability; and, WHEREAS, Parcels with existing uses were selected for the inventory based on the following factors and evidence:
(a)Property owner has expressed interest in redevelopment; in December 2022, the City surveyed property owners of sites included in the inventory as well as owners of potential sites not included. Several property owners indicated that they were not interested in redevelopment, and those sites have been removed from the inventory. As a result of the survey, several sites that had been previously identified as potential but not included as a site to meet the RHNA, were added to the inventory based on property owner interest. (b) There is a marked increase in inquiries and expressed interest by property owners to redevelop sites into higher density residential uses, a trend seen in the surrounding region.

Based on a survey of development projects proposed, approved, and constructed in San Carlos since 2015, uses most likely to redevelop were identified. These uses that have since redeveloped mirror that of the City’s current inventory. In the Downtown and along major corridors, historically non-residential areas, the sites have a mix of older stand-alone commercial uses some with surface parking areas. Mixed-use sites are characterized by having a variety of commercial uses, but the site selection focused on smaller scale uses such as small stores or buildings. Large multi-story buildings and sites that showed signs of improvement were not included. Where the existing uses are multi-family residential (condominiums or apartments), they are included in the inventory only if the additional potential capacity is at least three times the existing number of uses and no developments with more than 10 units. (c) Characteristics of existing uses such as older or declining uses or uses developed significantly below potential realistic capacity.
(d) Land values vs. improvement values. In some cases, a parcel is included with a higher improvement value if the structure is older or shows obvious signs of deferred maintenance or if the site is underutilized (characterized by large surface parking or unused surface area on the site or have a significant increase in capacity potential). On residential sites, most sites with higher improvement values are developed with single-family homes on properties designated for multi-family uses at densities of 45 to 59 units per acre. These sites have the potential for at least a seven-fold increase in capacity. (e) No recent, significant enhancements have been made (exempt enhancements include site cleanup or paint); and
WHEREAS, on January 3, 2023 the Planning and Transportation Commission held a duly and properly noticed public hearing and considered the Draft 2023-2031 Housing Element, received public comments, and adopted Resolution PTC No. 2023-02 recommending that the City Council repeal the 2015-2023 Housing Element and adopt the Draft 2023-2031 Housing Element, and further recommended that the City Council approve a revised version of the 2023- 2031 Housing Element to allow for minor amendments pursuant to the State of California Housing and Community Development Department’s requirements in order to meet the January 31, 2023 state deadline for Housing Element adoption; and WHEREAS, on January 18, 2023 the City/County Association of Governments of San Mateo County’s (C/CAG) Airport Land Use Commission staff requested a minor revision to the

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Draft Housing Element (as referenced in Exhibit D) and of which is hereby incorporated into the Housing Element; and
WHEREAS, on January 23, 2023 the City Council conducted a duly and properly noticed public hearing to take public testimony and consider this Resolution regarding the proposed Draft 2023-2031 Housing Element, and reviewed the Draft 2023-2031 Housing Element and all pertinent maps, documents and exhibits, including HCD’s findings, the City’s response to HCD’s findings, the staff report and all attachments, and oral and written public comments; and WHEREAS, the City Council has certified the Final Environmental Impact Report prepared for the Draft 2023-2031 Housing Element as adequate and complete in compliance with the California Environmental Quality Act (CEQA) and the State CEQA Guidelines and as adequate and complete for consideration in making a decision on the merits of the Draft 2023- 2031 Housing Element.

NOW, THEREFORE, BE IT RESOLVED that the San Carlos City Council, hereby finds that, based on substantial evidence in the record:

1. The foregoing recitals are true and correct and are incorporated by reference into this action.

2. The City Council, having independently heard, considered, and weighed all the evidence in the record present on behalf of interested parties and being fully informed of the Housing Element Update project, finds that City of San Carlos 2023- 2031 Draft Housing Element’s goals, policies, and actions are required to meet San Carlos’ Regional Housing Needs Allocation (RHNA) of 2,735 new housing units, is consistent with the applicable policies of the City of San Carlos General Plan, has been prepared in conformance with State Housing Element Law, and contains all provisions required by State Housing Element Law, as shown in Exhibit A to this Resolution.

3. Based on substantial evidence in the record, including the characteristics of sites zoned for mixed use that have converted to residential use, including condition of property, type of use, record of recent improvements, and ratio of building value to land value; residential development densities in mixed-use zones; and proposed substantial increases in permitted density to 100 to 120 units/acre, as discussed in detail in Chapter 4 of the 2023-2031 Draft Housing Element, the existing uses on the non-vacant sites identified in the site inventory to accommodate the RHNA are likely to be discontinued during the planning period and therefore do not constitute an impediment to planned residential development on the identified sites during the planning period. Such substantial evidence includes, but is not limited to:
a. Property owner expressed interest in redevelopment of the sites b. Documented increase in inquiries and interest in redevelopment of the sites; c. Existing older and declining uses on sites;
d. Existing uses on sites significantly below their potential realistic capacity; e. Sites with greater improved value than land value;

3.f. No recent significant enhancements to the improvements on sites have been made.
a. Parcels with existing uses that were not likely to be discontinued during the

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planning period were not examined for suitability, as follows:
i. Parcels in the PK (Park) and OS (Open Space) Zoning Districts; ii. Parcels with existing designated historic resources; iii. Parcels that are under construction, or have recently completed projects, approved entitlements, or pending entitlements for commercial uses only;
iv. Parcels that have unique land uses, such as City Hall, parks, and libraries;
v. Parcels developed with affordable housing.
b. All remaining parcels with existing uses that would allow residential redevelopment were examined for suitability. Parcels with existing uses were selected for the inventory based on the following factors and evidence:
i. Property owner has expressed interest in redevelopment. In December 2022, the City surveyed property owners of sites included in the inventory as well as owners of potential sites not included.

Several property owners indicated that they were not interested in redevelopment, and those sites have been removed from the inventory. As a result of the survey, several sites that had been previously identified as potential but not included as a site to meet the RHNA, were added to the inventory based on property owner interest. ii. There is a marked increase in inquiries and expressed interest by property owners to redevelop sites into higher density residential uses, a trend seen in the surrounding region. Based on a survey of development projects proposed, approved, and constructed in San Carlos since 2015, uses most likely to redevelop were identified.

These uses that have since redeveloped mirror that of the City’s current inventory. In the Downtown and along major corridors, historically non-residential areas, the sites have a mix of older standalone commercial uses some with surface parking areas. Mixed-use sites are characterized by having a variety of commercial uses, but the site selection focused on smaller scale uses such as small stores or buildings. Large multi-story buildings and sites that showed signs of improvement were not included. Where the existing uses are multifamily residential (condominiums or apartments), they are included in the inventory only if the additional potential capacity is at least three times the existing number of uses and no developments with more than 10 units.
iii. Characteristics of existing uses such as older or declining uses or uses developed significantly below potential realistic capacity. iv. Land values vs. improvement values. In some cases, a parcel is included with a higher improvement value if the structure is older or shows obvious signs of deferred maintenance or if the site is underutilized (characterized by large surface parking or unused surface area on the site or have a significant increase in capacity potential). On residential sites, most sites with higher improvement values are developed with single-family homes on properties designated for multi-family uses at densities of 45 to 59 units per acre.

These sites have the potential for at least a seven-fold increase in capacity.
v. No recent, significant enhancements have been made (exempt enhancements include site cleanup or paint).

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4. As required by Government Code Section 65585(e), the City Council has considered the findings made by HCD included in HCD’s letter to the City dated January 12, 2023, and consistent with Government Code Section 65585(f), and as described in Exhibit B to this Resolution, incorporated herein, the City Council has changed the 2023-2031 Draft Housing Element in response to HCD’s findings as required to substantially comply with the requirements of State Housing Element Law as interpreted by HCD.

5. The 2015-2023 Housing Element is hereby repealed in its entirety, and the 2023- 2031 Draft Housing Element, as shown in Exhibit C to this Resolution, incorporated herein, is adopted.

6. This Resolution shall become effective upon adoption by the City Council.

7. The Community Development Director or designee is hereby directed to file all necessary material with the Department of Housing and Community Development for the Department to find that the 2023-2031Housing Element is in conformance with State Housing Element Law and is further directed and authorized to make all nonsubstantive changes to the 2023-2031 Housing Element to make it internally consistent or to address any non-substantive changes or amendments requested by the Department to achieve certification.

8. The Community Development Director or designee is hereby directed to distribute copies of the Housing Element in the manner provided in Government Code Sections 65357 and 65589.7.
****
I, City Clerk Crystal Mui, hereby certify that the foregoing Resolution was duly and regularly passed and adopted by the City Council of the City of San Carlos at a scheduled meeting thereof held on the 23rd day of January 2023, by the following vote:

AYES, COUNCILMEMBERS: ________________________
NOES, COUNCILMEMBERS: ________________________
ABSENT, COUNCILMEMBERS: ________________________
_______________________________
CITY CLERK of the City of San Carlos
APPROVED:

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___________________________
MAYOR of the City of San Carlos
Exhibits:

A. Housing Element Statutory Provisions Checklist.

B. Findings Responding to Letter from Department of Housing and Community Development dated January 6, 2023.

C. 2023 – 2031 Housing Element
C.D. Edits for Consistency with the Airport Land Use Compatibility Plan for the Environs of San Carlos Airport

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EXHIBIT A
Housing Element Statutory Provisions Checklist
Government Code Provision Housing Element Compliance
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.

Identification and analysis of existing
housing needs are on p. 51-78
Statement of goals, policies, and
quantified objectives are on p. 13-53
Financial resources are discussed on
p. 129-170
Scheduled programs for the
preservation, improvement, and
development of housing are
discussed on p. 13-53
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 Housing Resource Chapter on p
129-170 discusses the sites inventory
that can accommodate a variety of
housing types for all income levels.

The Housing Constraints Chapter on
p 75-130 discusses the zoning
available for a variety of housing
types.

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:

The Housing Resource Chapters on p
129-170 discusses the sites inventory
that can accommodate a variety of
housing types for all income levels.
(a)(1) An analysis of population and employment trends and documentation of projections
P. 51-54 provide a summary of
current changes to the population
size, age, and racial/ethnic
composition, as well as current
employment conditions of the City of
San Carlos. This analysis draws from
data sources such as the Association
of Bay Area Governments (ABAG)
population growth forecasts, CA
Department of Finance Population
and Housing Estimates, 2018
American Community Survey 5-year
Estimates, and the City of San Carlos
Comprehensive Annual Financial
Report.
(a)(1) A quantification of the locality’s existing and projected housing needs for all income levels, including extremely low income households, as defined in subdivision (b) of Section 50105 and Section 50106 of the Health and Safety Code. These existing and projected needs shall include the locality’s share of Table 4.3-4 on p. 56 provides a
breakdown of household
characteristics by Tenure. This table
quantifies the total number of
households and the number of

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Government Code Provision Housing Element Compliance
the regional housing need in accordance with Section 65584.

Local agencies shall calculate the subset of very low income households allotted under Section 65584 that qualify as extremely low income households. The local agency may either use available census data to calculate the percentage of very low income households that qualify as extremely low income households or presume that 50 percent of the very low income households qualify as extremely low income households. The number of extremely low income households and very low
income households shall equal the jurisdiction’s allocation of very low income households pursuant to Section 65584.
households by income category and
tenure. It also provides the RHNA
number of projected extremely lowincome households. The City calculated that 50 percent of 739 very
low income households qualify as
extremely low income; 370 extremely
low income and 369 very low income.

Table 4.3-11 on p. 75 summarizes the
City’s Regional Housing Needs
Allocation for the 2023-2031 planning
period.
(a)(2) An analysis and documentation of household
characteristics, including level of payment compared to ability to pay,
P. 55-64 provide an analysis of
household characteristics in the City.

This analysis includes a discussion of
the following:
• Number of households
between 2010 and 2018
• Breakdown of tenure
• Median income, including
median income by tenure,
percent of households and
racial/ethnic populations in
poverty, breakdown of area
median income by renter and
owner households
• Housing overpayment
including, by lower income
households and tenure
• Median home price in the City
and comparison to the County
• Median gross rents and
comparison to HUDdetermined fair market rate
rents for San Mateo County
(a)(2) housing characteristics, including overcrowding, and P.59-64 discusses the composition of the City’s housing stock. This analysis
includes a discussion of the following:
• Housing stock by housing
type and tenure
• Vacancy rates
• Percentage of overcrowded
and severely overcrowded
units and overcrowding by
tenure, income categories,
race/ethnicity
(a)(2) housing stock condition. P.62 discussion the condition of housing stock in the City. This
analysis includes a discussion of the
following:
• Age of housing stock
• Substandard housing issues
• Estimates by the San Carlos

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Government Code Provision Housing Element Compliance
Building Official of units in
severe need of replacement
or rehabilitation due to
housing conditions
• Resources to address
substandard housing
conditions
(a)(3) An inventory of land suitable and available for residential development, including vacant sites and sites having realistic and demonstrated potential for redevelopment during the planning period to meet the locality’s housing need for a designated income level, and an analysis of the relationship of zoning and public facilities and services to these sites, and an analysis of the relationship of the sites identified in the land inventory to the jurisdiction’s duty to affirmatively further fair housing. Note: Please see Section 65583.2 regarding the land inventory.

P. 129-170 are the Housing
Resources Chapter of the Housing
Element.

It provides an analysis of land suitable
and available for residential
development using realistic capacity
calculations based on past trends in
the City, criteria used to identify
underutilized sites, infrastructure
capacity. And consistency with
affirmatively further fair housing. Units
have been estimated for all income
categories.
[Note that AB 2339 (Chapter 654, Statutes of 2022) amended Section 65583(a)(4). It does not apply to ABAG-area housing elements unless the first draft of the housing element is submitted to ABAG after January 31, 2023 or a draft is
submitted after April 1, 2023. Therefore the sections below include the statutory provisions of Section 65583(a)(4) effective in 2022. Jurisdictions adopting their housing element after January 1, 2023 should describe why AB 2339 is not applicable to them.]
See paragraphs below.
(a)(4)(A) The identification of a zone or zones where emergency shelters are allowed as a permitted use without a conditional use or other discretionary permit. The identified zone or zones shall include sufficient capacity to accommodate the need for emergency shelter identified in paragraph (7), except that each local government shall identify a zone or zones that can accommodate at least one year-round emergency shelter.

Table 4.4-3, on p.83, summarizes
where emergency shelters are
allowed as a permitted use. Further
discussion is provided on p.99. The
city allows emergency shelters without
discretionary review in the Mixed Use
North Boulevard (MU-NB) and Mixed
Use South Boulevard (MU-SB) zoning
districts. The element also identifies

6.2 acres of land in MU-NB and 17.4
acres in MU-SB. These areas are
located at the north and south
gateways of the El Camino Real
(State Route 82) corridor in San
Carlos. Both zoning districts allow for
a variety of uses and are located in
close proximity to local services and
transit. The zoning districts presents
redevelopment and adaptive reuse
opportunities of existing buildings.

These zones have sufficient capacity
to accommodate the City’s 30
homeless individuals identified in the
2019 point-in-time count.

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Government Code Provision Housing Element Compliance
(a)(4)(A) If the local government cannot identify a zone or zones with sufficient capacity, the local government shall include a program to amend its zoning ordinance to meet the
requirements of this paragraph within one year of the adoption of the housing element. The local government may identify
additional zones where emergency shelters are permitted with a conditional use permit.

The City has established it has
sufficient capacity accommodate
emergency shelters.
(a)(4)(A) The local government shall also demonstrate that existing or proposed permit processing, development, and management standards are objective and encourage and
facilitate the development of, or conversion to, emergency shelters.

P. 99 lists and analyzes the
development and management
standards for emergency shelters in
the Zoning Ordinance (Sec.

18.23.110). The standards regulate
the number of residents, length of
occupancy, outdoor activities, hours of
operation, on-site supervision,
provision of bathroom facilities, and a
management plan.

These standards are common across
many cities in California and do not
constrain the production of emergency
shelters.
(a)(4)(A) Emergency shelters may only be subject to those development and management standards that apply to
residential or commercial development within the same zone except that a local government may apply written, objective standards that include all of the following:
(i) The maximum number of beds or persons permitted to be served nightly by the facility.
(ii) Sufficient parking to accommodate all staff working in the emergency shelter, provided that the standards do not require more parking for emergency shelters than other residential or commercial uses within the same zone.
(iii) The size and location of exterior and interior onsite waiting and client intake areas.
(iv) The provision of onsite management.
(v) The proximity to other emergency shelters, provided that emergency shelters are not required to be more than 300 feet apart.
(vi) The length of stay.
(vii) Lighting.
(viii) Security during hours that the emergency shelter is in operation.

See above for the standards applied
to emergency shelters.

Table 4.4-6 on p. 90 lists the
residential parking standards.

Emergency shelters are required to
provide one parking space per 200
square feet of floor area. This is
sufficient to accommodate all staff
working at the shelter and is no more
than what is required for other
residential or commercial uses within
the same zone. In Mixed-Use districts
parking is required at 1 space per unit
for studios/one-bedroom units and 1.5
spaces per unit for two or more
bedrooms.
(a)(4)(B) The permit processing, development, and management standards applied under this paragraph shall not be deemed to be discretionary acts within the meaning of the California Environmental Quality Act (Division 13 (commencing with Section 21000) of the Public Resources Code).

The standards listed above are
objective and not discretionary.
(a)(4)(C) A local government that can demonstrate to the satisfaction of the department the existence of one or more emergency shelters either within its jurisdiction or pursuant to a multijurisdictional agreement that can accommodate that jurisdiction’s need for emergency shelter identified in paragraph (7) may comply with the zoning requirements of subparagraph (A) by identifying a zone or zones where new emergency
There are no homeless shelters within
the City. The closest resources are in
Redwood city, which is about three
miles away. Action HOU-5.1 is
included in the Housing Plan to
facilitate additional emergency and
transitional housing in San Carlos

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Government Code Provision Housing Element Compliance
shelters are allowed with a conditional use permit. through changes in the zoning ordinance. This includes reviewing
and modifying the Zoning Ordinance
as need to:
• comply with AB 2162 requirements
to allow for modifications for
required parking for units occupied
by supportive housing residents
that are located within one-half mile
of a public transit stop
• subject emergency shelters only to
those development and
management standards that apply
to residential or commercial
development within the same zone
• standards related to the number of
residents that can be
accommodated at an emergency
shelter, which shall in no case be
less than 20 beds
(a)(4)(D) A local government with an existing ordinance or ordinances that comply with this paragraph shall not be required to take additional action to identify zones for emergency shelters. The housing element must only describe how existing ordinances, policies, and standards are consistent with the requirements of this paragraph.

The Housing Element has described
how ordinances, policies, and
standards are consistent with the
requirements of this paragraph as
discussed in the sections above.
(a)(5) An analysis of potential and actual governmental constraints upon the maintenance, improvement, or
development of housing for all income levels, including the types of housing identified in paragraph (1) of subdivision (c), and [Note: The types of housing identified in Section 65583(c)(1) include multifamily rental housing, factory-built housing, mobilehomes, housing for agricultural employees,
supportive housing, single-room occupancy units,
emergency shelters, and transitional housing.]
See paragraphs below.
(a)(5) for persons with disabilities as identified in the analysis pursuant to paragraph (7),
P.102-105 provides an analysis of
potential and actual governmental
constraints upon housing for persons
with disabilities. The analysis includes
a discussion of the following:

Residential care facilities. Small Statelicensed residential care facilities for six or fewer persons must be
permitted in all zoning districts that
allow single- or multi-family uses,
subject to the same permit processing
requirements and development
standards; San Carlos is compliant
with the Lanterman Act. Residential
care facilities of more than six persons
and senior facilities are permitted with
a minor use permit in RM-20, RM-59,

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MU-D-100 and 120, and MU-SC-120
zoning districts. Requiring a
Conditional (or Minor) Use Permit for
residential care facilities for seven or
more persons is viewed by the State
as a potential constraint to housing for
persons with disabilities.

Action HOU-5.3 is included in the
Housing Plan to:
• remove the requirement for a
Minor Use Permit and allow
residential care facilities for
seven or more persons (both
senior and limited) in all zoning
districts where multi-family uses
are allowed (Action HOU-5.3)
• review and modify development
standards for residential care
facilities to ensure the same
standards apply for these uses
as other residential uses of the
same type in the same zone,
such as parking and removing
subjectivity in standards and
required findings
Definition of a family. “Family”, as
defined in the San Carlos Municipal
Code, means: one or more persons
occupying a dwelling unit and living
together as a single nonprofit
housekeeping unit and sharing
common living, sleeping, cooking and
eating facilities. Members of a family
need not be related by blood but are
distinguished from a group occupying
a hotel, club, fraternity, or sorority
house. This definition does not
discriminate nor limit access to
housing for persons with disabilities or
other household types.

Reasonable Accommodation. The
City adopted a reasonable
accommodation ordinance in 2011
(Chapter 18.33 - Waivers of the San
Carlos Municipal Code). This chapter
outlines applicability, procedures,
required findings, conditions of
approval, and appeals in the process
of applicants obtaining a reasonable
accommodation. Applications are
reviewed for approval by the Planning

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Director. Required findings are listed
on p.81. Action HOU-5.5 is included in
the housing plan to review and modify
as necessary to remove subjectivity
within the approval findings.
(a)(5) including land use controls, P. 80-93 provides an analysis of land use controls. The analysis includes a
discussion of the following:
• Summary of land use
designations and zoning
districts as shown in Table

4.4-1
• Density bonus, which was
comprehensively updated in
2022 provide additional
incentives for rental projects
to provide affordable housing,
exceeding the bonuses
provided by the State Density
Bonus law. Section 18.17.040
(State Density Bonus) was
also updated in 2022 and is
consistent with State law.
• Summary and discussion of
permitted land uses by zoning
district (Table 4.4-3),
residential development
standards (Table 4.4-4),
analysis of heights, lot
coverage, and density limits,
parking requirements (Table

4.4-6), and open space
requirements.
• Discussion of the proposed
General Plan and zoning
district changes that are
occurring in conjunction with
Housing Element update
process with scheduled
adoption in January 2023.

The City’s standards for minimum lot
sizes, setbacks, lot coverage, and
floor area ratio were not identified as
constraints to housing development.

However, while the City’s zoning
regulations are not considered overly
excessive and are on par with those
being used by surrounding
jurisdictions and to a great extent
throughout San Mateo County, the
City has identified significant changes
that will further encourage housing

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and affordable housing development
in the community in response to the
RHNA requirement. In order to
provide additional opportunities to
meet the City’s regional housing
needs, the City initiated a
comprehensive update to the Land
Use Element and Zoning Ordinance in
2020 (culminating in 2023), instituting
new zoning districts and allowing
significant increases in density, as
well as new required minimum
densities. Table 4.4-5 summarizes the
changes, including new zoning
districts, maximum densities,
minimum densities, and height limits.

Another important change to the
Zoning Ordinance is to remove the
private open space and guest parking
requirements for all multi-family uses
in residential and mixed-use zones.
(a)(5) building codes and their enforcement, P. 97-98 provides a description of the City’s building code procedures and
analyzes its impact on housing supply
and affordability. The City’s
procedures are not considered a
constraint and are common in various
cities across the State.
(a)(5) site improvements, P. 93-94 describes typical on-/off-site improvements and analyzes their
impact on housing. The on- and offsite improvement standards imposed by the City are typical for most
communities and do not pose unusual
constraints for housing development.
(a)(5) fees and other exactions required of developers, P. 105-112 provides a list/description of development fees, entitlement fees,
building permit fees, and in-liue fees
required by the City’s Below Market
Rate Ordinance. It also quantifies the
total amount of fees per unit type. The
analysis compares fees to other local
jurisdictions.

Compared to other jurisdictions in San
Mateo County, San Carlos’ fees were
found to be comparable and do not to
pose a significant constraint to
housing development in the
community.

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(a)(5) local processing and permit procedures, P. 112-120 provide an analysis of processing and permit procedures.

The analysis includes a discussion of
the following:

Processing Timeline. The processing
times in San Carlos are comparable to
surrounding jurisdictions (Table 4-

4.14). The City has worked to
establish transparent and streamlined
procedures for processing and
permitting development applications.

Ministerial Review. Planning review of
routine over the counter permits
includes zoning clearances,
interpretations, modifications to
existing permits, and accessory
dwelling units.

Design Review. Most development
projects in San Carlos are subject to
Design Review, either by the Director,
the Residential Design Review
Committee, or the Planning
Commission. In order to ensure
compliance with the Housing
Accountability Act, Action HOU-4.4 is
included to ensure compliance with
the Housing Accountability Act
requirements, through a study of the
City’s Design Review process,
procedures, findings, and standards,
ensuring that subjectivity is removed
from the process for those projects
that comply with objective standards..

Conditional Use Premits. A CUP is not
required for multi-family development
in San Carlos. CUPs are only required
for single-room occupancy
developments and for bungalow
court/small lot subdivisions in the RM59 and RM-100 zones, with the intent of preserving these zones for higher
intensity development. Action 4.4 is
included in the Housing Plan to
amend the Zoning Ordinance to
include CUP findings for any
applicable special residential uses to
ensure that findings are objective and
result in project approval certainty,
consistent with Housing Accountability
Act requirements.

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Environmental Review. State
regulations require environmental
review of discretionary project
proposals (e.g., subdivision maps,
design review, use permits, etc.).

Design review of residential projects
generally result in exemptions for
single-unit dwellings and accessory
dwelling units. Most multi-unit and
mixed-use projects are found exempt
based on the Infill exemption allowed
by State law. In rare circumstances for
complex projects, an Initial Study (and
related Negative Declaration or
Mitigated Negative Declaration) or
even an Environmental Impact Report
may be warranted. The timeframes
associated with environmental review
are regulated by CEQA. In
compliance with the Permit
Streamlining Act, City staff ensures
that non-legislative proposals are
heard at the Planning Commission
within 60 days of receipt of an
application being deemed complete
SB 35 Approval Process.

As of 2022, the City of San Carlos
was determined to be subject only to
SB 35 streamlining for proposed
developments with 50 percent or
greater affordability. The City has not
received any applications or inquires
for SB 35 streamlining. To
accommodate any future SB 35
applications or inquiries, Action HOU4.4 calls for the City to create and make available to interested parties
an informational packet that explains
the SB 35 streamlining provisions in
San Carlos and provides SB 35
eligibility information. The
development standards and
regulations in the Zoning Ordinance
are objective; however, Design
Review Criteria are subjective. Action
HOU-4.4 also specifies that City will
revisit the Design Review Criteria to
provide local guidance on design and
standards for by-right projects as
allowed by state law.
(a)(5) and any locally adopted ordinances that directly impact the cost and supply of residential development.

P. 94-97 provide an analysis of locally
adopted ordinance impact the
production of housing. The only locally

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adopted ordinance that directly
impacts the cost and supply of
housing is the City of San Carlos
Below Market Rate Housing Program.

The City does not have a short-term
rental ordinance, growth controls,
crime free ordinances, or similar
programs and regulations.

A thorough analysis on the City’s
Below Market Rate Housing Program
is included on p.94-97.
(a)(5) The analysis shall also demonstrate local efforts to remove governmental constraints that hinder the locality from meeting its share of the regional housing need in accordance with Section 65584
See sections above for analysis
provided in the Housing Element and
the efforts to remove any identified
constraints based on this analysis.

Additionally the following actions in
the Housing Plan are meant to
remove governmental constraints
where identified.

Action HOU-4.1 Adequate Sites to
Meet Regional Fair Share of Housing
Growth.

Action HOU-4.2 Zoning Ordinance
Revisions.

Action HOU-4.3 Outreach: New
Development Standards.

Action HOU-4.4 Objectivity and
Streamlining in Development
Regulations.

Action HOU-5.1 Emergency Shelters,
Supportive and Transitional Housing.

Action HOU-5.3 Residential Care
Facilities and Group Homes.

Action HOU-5.5 Revised
Development Standards to Support
Special Needs Housing.
(a)(5) and from meeting the need for housing for persons with disabilities, supportive housing, transitional housing, and emergency shelters identified pursuant to paragraph (7).

See sections above for meeting the
housing needs and disabilities,
supportive housing, transitional
housing, and emergency shelters
identified pursuant to paragraph (7).

P.78-79 detail additional efforts, such
as:

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Low Barrier Navigation Centers, which
the City is revising its Zoning
Ordinance to ensure that the City
meets the requirements of AB 101
(Action HOU-5.1).

Transitional and Supportive Housing.

In San Carlos, transitional and
supportive housing are considered
single-family or multi-family uses and
are permitted by right in all residential
and mixed-use zoning districts. The
City is revising its Zoning Ordinance
to ensure compliance with 2162.

Single-Room Occupancy (SRO).

Single-room occupancy hotels and/or
boarding homes are collectively
referred to as SROs. Buildings that
provide SRO dwellings are
conditionally permitted in Residential
Multifamily and Mixed-Use zoning
districts, but may not be located on
the ground floor along Laurel Street
and San Carlos Avenue frontages.
(a)(6) An analysis of potential and actual nongovernmental constraints upon the maintenance, improvement, or
development of housing for all income levels, including the availability of financing,
P. 75-80 provides an analysis of
potential and actual non-governmental
constraints.

P.77-78 specifically discusses the
availability of financing.
(a)(6) the price of land, P.75-76 discuss the price of land for single-family and multi-family
residential construction based on an
independent countywide study
prepared by Century Urban for 21
Elements.
(a)(6) the cost of construction, P.76-77 discuss the cost of construction according to data from
the California Construction Cost Index
and Building Valuation Data compiled
by the International Code Council.
(a)(6) the requests to develop housing at densities below those anticipated in the analysis required by subdivision (c) of Section 65583.2,
P. 78-79 discuss and analyze the
process for requests to develop
housing at densities below those
anticipated.
(a)(6) and the length of time between receiving approval for a housing development and submittal of an application for building permits for that housing development that hinder the
construction of a locality’s share of the regional housing need in accordance with Section 65584.

P. 79 discusses and analyzes the
turnaround time between receiving
entitlement approvals for a housing
development and submittal of an
application for building permit varies
widely.

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(a)(6) The analysis shall also demonstrate local efforts to remove nongovernmental constraints that create a gap between the locality’s planning for the development of housing for all income levels and the construction of that housing.

P.79-80 discusses local efforts to
remove nongovernmental constraints.

The City has two Housing Funds that
can support affordable housing: the
Housing Asset Fund (Housing
Successor) and the Housing In-Lieu
Fund. The Housing Asset Funds has
an approximate cash balance of $3
million in June 2022, which is fully
encumbered to support future housing
projects. The Housing In-Lieu Fund
has an approximate cash balance of
$12.4 million in June 2022, of which
$3.6 million is encumbered. The main
sources of this funding are
commercial linkage fees and to a
lesser extent Below Market Rate
(BMR) in-lieu fees. These funds help
support gap financing for affordable
housing projects; however, the City’s
ability to support projects is limited by
available funds. For example, the
Walnut Studios (817 Walnut) 100%
affordable project was made possible
by a sizeable investment of $7.3
Million from the City of San Carlos,
and a generous partnership with
Charities Housing, the local nonprofit
organization that developed the
property and will continue to manage
the 23-unit building. The City of San
Carlos will continue to facilitate
housing development by providing
funding from both Housing Funds to
support additional affordable housing
(Action HOU-3.1).
(a)(7) An analysis of any special housing needs, such as those of the
Table 4.3-9 on p.65 provides a
summary of special needs groups in
San Carlos based on data from the
2018 American Community Survey 5-
year estimates and California
Department of Development Services.
(a)(7) elderly; P.69 provides analysis for elderly
residents. This analysis includes a
discussion of the following:
• Number of elderly residents
• Poverty status of elderly
residents
• Proportion of elderly headed
households
• Programs and services
available to assist in the
housing needs of elderly

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residents
• Uses data from the 2018
American Community Survey
5-year estimates
(a)(7) persons with disabilities, including a developmental disability, as defined in Section 4512 of the Welfare and Institutions Code;
P. 65-69 provides analysis for persons
with disabilities. This analysis includes
a discussion of the following:
• Number of residents with
disabilities
• Prevalence of disabilities
amongst elderly residents
• Poverty status of people with
disabilities and comparison to
non-disabled residents
• Number of persons with
developmental facilities
• Programs and services
available to persons with
disabilities, including
developmental disabilities and
how many people are served
or have the capacity to be
served
• Trends affecting the housing
needs of people with
developmental disabilities
• Existing housing provisions
• Uses data from the 2018
American Community Survey
5-year estimates and the
California Department of
Development Services
(a)(7) large families; P.69-70 provides analysis for large households (5+). This analysis
includes a discussion of the following:
• Number of large households
• Large households by tenure
and poverty status
• Programs included in the
Housing Plan to
accommodate large
households
• Uses data from the 2018
American Community Survey
5-year estimates
(a)(7) farmworkers; P.70-71 provides analysis for
farmworkers. This analysis includes a
discussion of the following:
• Proportion of residents
assumed to be farmworkers
based on Census Bureau
data

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• Discussion on available
farmland in the City based on
Maps from the State
Department of Conservation
Farmland Mapping and
Monitoring Program
(a)(7) families with female heads of households; P.71 provides analysis for single parent, e.g. female headed
households. This analysis includes a
discussion of the following:
• Number of female headed
households
• Female headed households
by tenure and poverty status
• Programs included in the
Housing Plan to
accommodate the housing
needs of female headed
households
• Uses data from the 2018
American Community Survey
5-year estimates
(a)(7) and families and persons in need of emergency shelter. P.71 provides analysis for people experiencing homelessness. This
analysis includes a discussion of the
following:
• Number of people
experiencing homeless
between 2017, 2019, and
2022 based on point-in-time
counts
• Available shelters and
resources
• Programs included in the
Housing Plan to facilitate the
production of emergency and
transitional housing
(a)(7) The need for emergency shelter shall be assessed based on the capacity necessary to accommodate the most recent homeless point-in-time count conducted before the start of the planning period, the need for emergency shelter based on number of beds available on a year-round and seasonal basis, the number of shelter beds that go unused on an average monthly basis within a one-year period, and the percentage of those in emergency shelters that move to permanent housing solutions.

The City has already identified zones
that allow for emergency shelters
without discretionary review in the
Mixed Use North Boulevard (MU-NB)
and Mixed Use South Boulevard (MUSB) zoning districts. The element also identifies 6.2 acres of land in MU-NB
and 17.4 acres in MU-SB. These
areas are located at the north and
south gateways of the El Camino Real
(State Route 82) corridor in San
Carlos. Both zoning districts allow for
a variety of uses and are located in
close proximity to local services and

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transit. The zoning districts presents
redevelopment and adaptive reuse
opportunities of existing buildings.

These zones have sufficient capacity
to accommodate the City’s 30
homeless individuals identified in the
2019 point-in-time count.
(a)(7) The need for emergency shelter may be reduced by the number of supportive housing units that are identified in an adopted 10-year plan to end chronic homelessness and that are either vacant or for which funding has been identified to allow construction during the planning period.

See above.
(a)(7) An analysis of special housing needs by a city or county may include an analysis of the need for frequent user
coordinated care housing services.

Each special housing needs groups
discusses the available or planned
programs/services to meet their
needs, as discussed above.
(a)(8) An analysis of opportunities for energy conservation with respect to residential development. Cities and counties are encouraged to include weatherization and energy efficiency improvements as part of publicly subsidized housing
rehabilitation projects. This may include energy efficiency measures that encompass the building envelope, its heating and cooling systems, and its electrical system.

P.72 provides analysis for energy
conservation. This analysis includes a
discussion of the following:
• Policies addressing climate
change and energy
conservation in the General
Plan
• Resources that support
energy efficiency and
renewable energy for
residents to add to their
homes
• Regional coordination for
energy conservation efforts
(a)(9) An analysis of existing assisted housing developments that are eligible to change from low-income housing uses during the next 10 years due to termination of subsidy contracts, mortgage prepayment, or expiration of restrictions on use. “Assisted housing developments,” for the purpose of this section, shall mean multifamily rental housing that receives governmental assistance under federal programs listed in subdivision (a) of Section 65863.10, state and local multifamily revenue bond programs, local redevelopment programs, the federal Community Development Block Grant Program, or local in-lieu fees. “Assisted housing developments” shall also include multifamily rental units that were developed pursuant to a local inclusionary housing program or used to qualify for a density bonus pursuant to Section 65915.

P.74 mentions that no housing
development is at risk of losing
affordability levels based on City
records and information from the
California Housing Partnership
Corporation. There is also the
discussion of one housing
development, Cherry Street
Apartments, which has an expired
covenant. The City is working with
HIP Housing which owns the property
to develop new affordable housing.
(a)(9)(A) The analysis shall include a listing of each
development by project name and address, the type of
governmental assistance received, the earliest possible date of change from low-income use, and the total number of elderly and nonelderly units that could be lost from the locality’s lowincome housing stock in each year during the 10-year period.

For purposes of state and federally funded projects, the analysis required by this subparagraph need only contain information available on a statewide basis.

P.73, Table 4.3-10, provides an
inventory of below market rate
housing in the City, this includes
name/address of development,
number of affordable units, unit mix,
building type, and expiration date

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(a)(9)(B) The analysis shall estimate the total cost of producing new rental housing that is comparable in size and rent levels, to replace the units that could change from low-income use, and an estimated cost of preserving the assisted housing
developments. This cost analysis for replacement housing may be done aggregately for each five-year period and does not have to contain a project-by-project cost estimate.

No housing developments are at risk
of losing affordability levels.

However, on p. 74, the element lists a
number of affordable housing units in
the pipeline, which will increase the
local inventory by 50 percent. The City
will continue to monitor and track the
affordability of these units.
(a)(9)(C) The analysis shall identify public and private nonprofit corporations known to the local government that have legal and managerial capacity to acquire and manage these housing developments.

See p. 74. While no housing
developments are at risk of losing
affordability levels, pursuant to
Government Code Section 65863.11,
the state maintains a list of “Entities
Interested in Participating in
California's First Right of Refusal
Program” at
https://www.hcd.ca.gov/policyresearch/docs/HPD-00-01.xlsx. This list includes various entities working in
San Mateo County and several
entities interested in properties
located in any county. If a
development becomes at risk of
conversion to market-rate housing,
the City will maintain contact with local
organizations and housing providers
who may have an interest in acquiring
at-risk units and will assist other
organizations in applying for funding
to acquire at-risk units.
(a)(9)(D) The analysis shall identify and consider the use of all federal, state, and local financing and subsidy programs that can be used to preserve, for lower income households, the assisted housing developments, identified in this paragraph, including, but not limited to, federal Community Development Block Grant Program funds, tax increment funds received by a
redevelopment agency of the community, and administrative fees received by a housing authority operating within the community. In considering the use of these financing and subsidy programs, the analysis shall identify the amounts of funds under each available program that have not been legally obligated for other purposes and that could be available for use in preserving assisted housing developments.

No housing developments are at risk
of losing affordability levels.
(b) (1) A statement of the community’s goals, quantified objectives, and policies relative to affirmatively furthering fair housing and to the maintenance, preservation, improvement, and development of housing.

P. 13-14 provides a statement of the
City’s mission statement, goals, and
guiding principles for the Housing
Element.

P.52, Table 4.2-3 provides a summary
of quantified for the 2023-2031
planning period
P.36-49 discussed the goals, policies,

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Government Code Provision Housing Element Compliance
and actions to affirmatively further fair
housing
P. 14-51 discuss several goals,
policies, and actions regarding the
maintenance, preservation,
improvement, and development of
housing.
(2) It is recognized that the total housing needs identified pursuant to subdivision (a) may exceed available resources and the community’s ability to satisfy this need within the content of the general plan requirements outlined in Article 5 (commencing with Section 65300). Under these circumstances, the quantified objectives need not be identical to the total housing needs. The quantified objectives shall establish the maximum number of housing units by income category, including extremely low income, that can be constructed, rehabilitated, and conserved over a five-year time period.

P.52, Table 4.2-3 provides a summary
of quantified for the 2023-2031
planning period. This summary
provides three main quantified
objectives: construction objective
(RHNA), rehabilitation objective, and
at-risk affordable housing units to
preserve. These three categories are
broken down by each income
category.
(c) A program that sets forth a schedule of actions during the planning period, each with a timeline for implementation, 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
Each action listed on p. 14-51 lists an
implementation timeframe,
responsible agency, and funding
sources.
(c) through the administration of land use and development controls,
Goal HOU-4 of the Housing Plan
states: “REMOVE OR MITIGATE

GOVERNMENTAL CONSTRAINTS

INHIBITING THE PROVISION OF

ADEQUATE, AFFORDABLE

HOUSING THROUGHOUT SAN
CARLOS”
The following programs are included
under this goal:

ACTION HOU-4.1
Adequate Sites to Meet Regional Fair
Share of Housing Growth.

ACTION HOU-4.2
Zoning Ordinance Revisions.

ACTION HOU-4.3
Outreach: New Development
Standards.

ACTION HOU-4.4
Objectivity and Streamlining in
Development Regulations.

ACTION HOU-4.5
Water and Sewer Service Providers.

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ACTION HOU-4.5
Noise. Align City noise policies in
accordance with federal and State
law.
(c) the provision of regulatory concessions and incentives, See above. (c) the utilization of appropriate federal and state financing and subsidy programs when available,
See above.
(c) 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).

See above.

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:

See above.
(c)(1) Identify actions that will be taken to make sites available during the planning period with appropriate zoning and
development standards and with services and facilities to accommodate that portion of the city’s or county’s share of the regional housing need for each income level that could not be accommodated on sites identified in the inventory completed pursuant to paragraph (3) of subdivision (a) without rezoning, and to comply with the requirements of Section 65584.09.

See above.
(c)(1) Sites shall be identified as needed to affirmatively further fair housing
P. 161-163 describes how the
inventory is consistent with
Affirmatively Furthering Fair Housing.
(c)(1) and to facilitate and encourage the development of a variety of types of housing for all income levels, including multifamily rental housing,
p.98-102 discusses how the City
facilitates and encourages a range of
housing types for all economic
segments of the community, including
multifamily rental housing and
accessory dwelling units.

Multi-family developments are
permitted by-right in the Residential
Multifamily (RM) and Mixed-Use (MU)
zoning districts. Stand-alone multifamily residential developments located in mixed-use zoning districts
are subject to RM-59 development
standards for building setbacks and
the maximum allowed density
permitted by the MU zoning district.

Mixed-use developments (the
integration of residential and
commercial uses on one site) are
allowed by-right in all MU zoning
districts. As part of the Zoning
Ordinance amendments (Action HOU4.2), stand-alone residential development will no longer require a
Conditional Use Permit in some areas

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along El Camino Real and objective
development standards (including
modifications to required setbacks)
will be crafted to allow developments
to achieve maximum densities.

An Accessory Dwelling Unit (ADU).

The City updated the ADU ordinance
to comply with recent changes to
State law in November 2020. In San
Carlos, consistent with the
Government Code Section 65852.2,
ADUs are permitted by right in all
single-family, multi-family, and mixeduse zoning districts. Action HOU-3.3 is included in the Housing Element to
ensure continued compliance with
State laws as they may change over
the course of the planning period and
identifies additional measures to
encourage and incentivize ADUs in
the community.
(c)(1) factory-built housing, p.101 discusses how the City facilitates and encourages factorybuilt housing.

In San Carlos, manufactured housing
can be subject to design review, the
same single-unit dwellings, as shown
in Table 4.4-12 (Timelines for Permit
Procedures).. The San Carlos Zoning
Ordinance includes individual
manufactured housing units installed
on a foundation system pursuant to
Section 18551 of the California Health
and Safety Code under the definition
of a single-unit dwelling, in
compliance with State law.

Manufactured homes are subject to
the same development standards as
conventional single-unit dwellings,
and are allowed in the same manner
and in the same zones as
conventional or stick-built structures
through the common definition of
“dwelling”.
(c)(1) mobilehomes, See above.
(c)(1) housing for agricultural employees, p.98 discusses how the City facilitates and encourages housing for
agricultural employees.

The City complies with State Health
and Safety Code Sections 17021.5,
which concerns employee housing
that serves six or fewer employees,

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which would include farmworkers.
(c)(1) supportive housing, p.98-101 discusses how the City facilitates and encourages supportive
housing.
(c)(1) single-room occupancy units, p.101 discusses how the City facilitates and encourages singleroom occupancy units
(c)(1) emergency shelters, p.98-101 discusses how the City facilitates and encourages emergency
shelters.
(c)(1) and transitional housing. p.98-101 discusses how the City facilitates and encourages supportive
housing.
(c)(1)(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 that the department has found to be in substantial compliance with this article 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 one year from the statutory deadline in Section 65588 for adoption of the housing element.

The City has undertaken a
comprehensive zoning update
(anticipated adoption in January
2023), whereby the City will increase
housing capacity by revising zoning
standards for mixed-use areas to
allow up to 120 units per acre and
minimum densities at approximately
75 percent of maximum. All mixed-use
sites are in zones that will have
adopted minimum densities that range
from 30 units per acre to 90 units per
acre.

The City has identified adequate site
to accommodate the needs for all
household income levels. The sites
inventory has identified a 128%
surplus of sites.
(c)(1)(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. Note: Please see Section 65583.2 regarding the land inventory and conformance with subdivision (h).

The sites inventory has identified an
adequate number of sites to
accommodate the need for groups of
all household income. The sites
inventory has identified 790 more
units than required by the RHNA,
which results in a 128% surplus of
units.
(c)(1)(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 lowand very low income households.

The element has identified a surplus
of 301 low-income units and 291 very
low income households, which could
meet the housing needs of
farmworkers.
(c)(2) Assist in the development of adequate housing to meet the needs of extremely low, very low, low-, and moderateincome households.

See p. 19-27. Goal HOU-3 of the
Housing Plan states: “ASSIST IN THE

DEVELOPMENT OF NEW HOUSING

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THAT IS AFFORDABLE AT ALL
INCOME LEVELS”
The following programs are included
under this goal:

ACTION HOU-3.1
Housing Options for Special Needs
and Extremely-Low Income
Households.

ACITON HOU-3.2
Below Market Rate (BMR) Ordinance.

ACTION HOU-3.3
Facilitate the Legalization and
Construction of Accessory Dwelling
Units (ADUs).

ACTION HOU-3.4
First-time Homebuyer Programs.

ACTION HOU-3.5
Rental Voucher Program.

ACTION HOU-3.6
State Density Bonus Law
Consistency.

ACTION HOU-3.7
No Net Loss.

ACTION HOU-3.8
Replacement of Units on Sites.

ACTION HOU-3.9
Development on Nonvacant Sites.

ACTION HOU-3.10
Anti-Displacement Strategies.

ACTION HOU-3.11
Access to Opportunity.

ACTION HOU-3.12
Reduce Costs Associated With The
Development Of Affordable and
Special Needs Housing.

ACTION HOU 3.13
Reevaluate the City Density Bonus
Provisions.
(c)(3) Address and, where appropriate and legally possible, remove governmental and nongovernmental constraints to the maintenance, improvement, and development of housing,
See p. 27-32. Goal HOU-4 of the
Housing Plan states: “REMOVE OR

MITIGATE GOVERNMENTAL

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including housing for all income levels CONSTRAINTS INHIBITING THE

PROVISION OF ADEQUATE,

AFFORDABLE HOUSING
THROUGHOUT SAN CARLOS”
The following programs are included
under this goal:

ACTION HOU-4.1
Adequate Sites to Meet Regional Fair
Share of Housing Growth.

ACTION HOU-4.2
Zoning Ordinance Revisions.

ACTION HOU-4.3
Outreach: New Development
Standards.

ACTION HOU-4.4
Objectivity and Streamlining in
Development Regulations.

ACTION HOU-4.5
Water and Sewer Service Providers.

ACTION HOU-4.5
Noise. Align City noise policies in
accordance with federal and State
law.
(c)(3) 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.

See p. 32-36. Goal HOU-5 of the
Housing Plan states: “ADEQUATE

HOUSING FOR SPECIAL NEEDS
POPULATIONS.”
The following programs are included
under this goal:

ACTION HOU-5.1
Emergency Shelters, Supportive and
Transitional Housing.

ACTION HOU-5.2
Large Rental Units and Supportive
Services.

ACTION HOU-5.3
Residential Care Facilities and Group
Homes.

ACTION HOU-5.4
Special Needs Service Providers
Contributions.

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ACTION HOU-5.5
Revised Development Standards to
Support Special Needs Housing.

ACTION HOU-5.6
Equal Access to City Services.

ACTION HOU-5.7
Community Governance.

ACTION HOU-5.8
Furthering Integration.
(c)(3) Transitional housing and supportive housing shall be considered a residential use of property and shall be subject only to those restrictions that apply to other residential dwellings of the same type in the same zone.

In San Carlos, transitional and
supportive housing are considered
single-family or multi-family uses and
are permitted by right in all residential
and mixed-use zoning districts.
(c)(3)Supportive housing, as defined in Section 65650, shall be a use by right in all zones where multifamily and mixed uses are permitted, as provided in Article 11 (commencing with Section 65650).

In San Carlos, transitional and
supportive housing are considered
single-family or multi-family uses and
are permitted by right in all residential
and mixed-use zoning districts.
(c)(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.

See p. 14-16. Goal HOU-1 of the
Housing Plan states:
“PRESERVATION AND

IMPROVEMENT OF THE QUALITY

AND LIVABILITY OF EXISTING
HOUSING AND NEIGHBORHOODS.

The following programs are included
under this goal:

ACTION HOU-1.1
Rental Inspection Program
ACTION HOU-1.2
Residential Rehabilitation Programs.

ACTION HOU-1.3
Preservation of At-Risk Housing.

ACTION HOU-1.4
Code Enforcement.
(c)(5) Promote and affirmatively further fair housing opportunities and promote housing throughout the community or communities for all persons regardless of race, religion, sex, marital status, ancestry, national origin, color, familial status, or disability, and other characteristics 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.

See p. 37-49. Goal HOU-6 of the
Housing Plan states: “GOAL HOU-6:

ELIMINATE DISCRIMINATION IN

THE PROVISION OF HOUSING AND

AFFIRMATIVELY FUTHER FAIR
HOUSING.”
The following programs are included
under this goal:

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ACTION HOU-6.1
Affirmatively Furthering Fair Housing.

Fair housing laws prohibit housing
discrimination based on race, color,
religion, sex, or national origin. San
Carlos has identified the following
objectives/meaningful actions to
affirmatively further fair housing
(Table 4.2-2).
(c)(6) Preserve for lower income households the assisted housing developments identified pursuant to paragraph (9) of subdivision (a).

ACTION HOU-1.3
Preservation of At-Risk Housing.

Retention of subsidized (i.e., assisted)
housing is a critical part of maintaining
the supply of affordable housing in
San Carlos. San Carlos will continue
to monitor the affordability of existing
deed-restricted units and coordinate
with property owners to encourage the
retention of affordability of these units.

At this time, San Carlos has no units
at-risk of converting to market rate in
the next ten years; however,
programs are included in the
unforeseen event that affordable units
become at-risk during or immediately
following the Housing Element period.
• Annually monitor the
affordability status of at-risk
rental units.
• Maintain and update the
City’s list of nonprofit and
community-based
organizations to contact
regarding possible ownership
and management of the atrisk units if they are in
imminent risk of conversion.
• In the event a project
becomes at risk of converting
to market-rate housing, work
with property owners or other
interested non-profit housing
providers to preserve the
units as affordable housing.

Timeframe: Ongoing; Annually
monitor/report the affordability status
of at-risk rental units as part of the
Annual Progress Report process;
Contact owners with expiring
covenants two years in advance of the
expiring covenant
Responsible Agency: Economic
Development and Housing Divisions

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Funding Sources: Community
Development Department Budget
(c)(6) 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.

See above
(c)(6) The program may include strategies that involve local regulation and technical assistance.

See above
(c)(7) Develop a plan that incentivizes and promotes the creation of accessory dwelling units that can be offered at affordable rent, as defined in Section 50053 of the Health and Safety Code, for very low, low-, or moderate-income households. For purposes of this paragraph, “accessory dwelling units” has the same meaning as “accessory dwelling unit” as defined in paragraph (4) of subdivision (i) of Section 65852.2.\
Facilitate the Legalization and
Construction of Accessory Dwelling
Units (ADUs).
• Support the development of
accessory dwelling units
during the planning period
and as new State laws modify
accessory dwelling unit
requirements, update the
City’s ordinance to comply.

The City last updated its ADU
ordinance in August 2022.

The City will draft
amendments to address laws
passed in 2022, including AB
2221 and SB 897 to reflect an
up-to-date ordinance
compliant with Government
Code Section 65852.2.
• Collaborate with surrounding
jurisdictions through the 21
Elements working group to
determine best approach for
tracking affordability
throughout the planning
period.
• Encourage the legalization of
unpermitted accessory
dwelling units to better ensure
that they are safe and
habitable. As sunset date of
San Carlos Municipal Code
Section 18.23.210(H)
approaches, consider an
extension, based on history of
use of this provision and
anticipated ongoing need.
• Work with other
regional/agencies countywide
partnerships to identify
potential funding sources for
ADU construction.
• Meet with three or four ADU
builders to discuss needs and

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Government Code Provision Housing Element Compliance
best practices. Review best
practices from other cities for
“pre-approved” ADUs and
expedited review. Create
submittal materials with
documentation to facilitate
expedited review. Update the
City’s website and include
links to “pre-approved” plans.

Conduct ongoing outreach
with community.
• Review and as new
information is available,
update public education
materials on accessory
dwelling units, including
planning and building
requirements, streamline
processing, funding
possibilities, and other
resources.
• Encourage local agencies,
districts, and utility providers
to reduce hook-up or other
fees to facilitate the
development of accessory
dwelling units.
• Prioritize ADU applications to
be consistent with
Government Code Section
65852.2(a)(3) requirements
for approval/denial within 60
days from the date a
completed application is
received.

Timeframe: Ongoing; update the ADU
ordinance by June 2023; as new State
laws modify accessory dwelling unit
requirements, update the City’s
ordinance within a timely manner (i.e.,
within six months); San Carlos
Municipal Code Section 18.23.210(H)
- 2028; work with 21 Elements – 2023;
funding and pre-approved plans -
2024; establish priority process in
development review in 2023 all others
- Ongoing
Responsible Agency: Planning and
Building Divisions
Funding Sources: Community
Development Department Budget
(c)(8) 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 Under each program a responsible
agency is listed as well as applicable
funding source.

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plan elements and community goals.
(c)(9) 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.

ACTION HOU-5.7
Community Governance. Conduct
public meetings at suitable times,
accessible to persons with disabilities,
and near public transit. Resources will
be invested to provide interpretation
and translation services when
requested at public meetings.

Timeframe: Ongoing
Responsible Agency: City Clerk and
Administration Division
Funding Sources: Administrative
Services Budget
Programs are also included in
ACTION HOU-6.1 to increase
community participation in planning
processes.

(c)(10)(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:

See paragraphs below.
(c)(10)(A)(i) A summary of fair housing issues in the jurisdiction P.168-171 provides a summary of the primary findings of the of the fair
housing analysis.
(c)(10)(A)(i) and an assessment of the jurisdiction’s fair housing enforcement and fair housing outreach capacity.

P. 171-178 provides an assessment
of the jurisdiction’s fair housing
enforcement and fair housing
outreach capacity. The analysis
includes:
• Information on fair housing
legal cases and inquiries
using data from the San
Mateo County Regional
Assessment of Fair Housing,
US Department of Housing
and Urban Development, and
National Fair Housing
Alliance.
• Details on local organizations
active in fair housing law.
• Housing specific policies
enacted locally to promote
housing production,
affordability, and
neighbhorhood stablization
(c)(10)(A)(ii) An analysis of available federal, state, and local P.178-196 provides a geospatial

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data and knowledge to identify integration and segregation patterns and trends,
analysis of integration and
segregation patterns and trends. The
analysis examines the following:
• Race/ethnicity
• Dissimilarity index
• Persons with disabilities
• Familial status
• Household income
Each indicator uses data from HCD’s
AFFH Data Viewer and ABAG’s
Housing Needs Data Workbook. The
data has also been mapped and
included in the element. A regional
comparison is also included for each.

Data is also supplemented with local
knowledge that explains existing
patterns and trends.
(c)(10)(A)(ii)racially or ethnically concentrated areas of poverty and affluence,
P.196 and 222 discuss that there are
no areas of racially or ethnically
concentrated areas of poverty and
that the entire City has racially or
ethnically concentrated areas of
affluence.
(c)(10)(A)(ii) disparities in access to opportunity, P197-222 provides a geospatial analysis of disparities in access to
opportunity. The analysis examines
the following:
• Education; discussion on
school performance, location
of high performing schools,
spatial distribution of TCAC
education score, and
educational disparities
amongst race/ethnicity and
income
• Employment; discussion on
unemployment rates, job to
household ratio, major
employers; TCAC jobs index
and economic opportunity
score and economic
disparities amongst
race/ethnicity and income
• Transportation; summary of
transit system in the City;
programs offered to seniors
and disabled residents for
reduced fares or specialized
transit service
• Environment; discussion of
CaliEnviroScreen 3.0

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indicators
Each area of opportunity uses data
from HCD’s AFFH Data Viewer and
ABAG’s Housing Needs Data
Workbook. The data has also been
mapped and included in the element.

A regional comparison is also
included for each. Data is also
supplemented with local knowledge
that explains existing patterns and
trends.
(c)(10)(A)(ii) and disproportionate housing needs, P.227-243 provides a geospatial analysis of disproportionate housing
needs. The analysis examines the
following:
• Cost burden by tenure, race,
and income
• Overcrowding by tenure and
race
• Substandard housing
• Homelessness by race
Each indicator uses data from HCD’s
AFFH Data Viewer and ABAG’s
Housing Needs Data Workbook. The
data has also been mapped and
included in the element. A regional
comparison is also included for each.

Data is also supplemented with local
knowledge that explains existing
patterns and trends.
(c)(10)(A)(ii) including displacement risk. P.224-226 and 244 provides a geospatial analysis of displacement.

The analysis largely builds off findings
from UC Berkeley’s Urban
Displacement Project.
(c)(10)(A)(ii) The analysis shall identify and examine such patterns, trends, areas, disparities, and needs, both within the jurisdiction.

Each fair housing areas was
examined geospatially locally and
regionally.
(c)(10)(A)(ii) and comparing the jurisdiction to the region in which it is located, based on race and other characteristics protected by the California Fair Employment and Housing Act (Part 2.8 (commencing with Section 12900) of Division 3 of Title 2) and Section 65008.

Each fair housing areas was
examined geospatially locally and
regionally.
(c)(10)(A)(iii) An assessment of the contributing factors, including the local and regional historical origins
P.247-249 provides an assessment of
the contributing factors, including the
local and regional historical origins.

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(c)(10)(A)(iii) and current policies and practices, for the fair housing issues identified under clauses (i) and (ii).

P. 250-258 summarizes policies and
actions in the Housing Plan that
pertain to fair housing. Affirmatively
furthering fair housing practices and
principles have been incorporated into
a variety of actions included in the
housing plan.
(c)(10)(A)(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,
Table 4.2-2, on p. 37-49, lists the fair
housing issue by priority, the
contributing factors, meaningful
actions to address each fair housing
issue, and related program already in
the Housing Plan
(c)(10)(A)(iv) and identifying the metrics and milestones for determining what fair housing results will be achieved.

Table 4.2-2, on p. 37-49, provides
specific a specific timeframe from
implementation under each
meaningful action.
(c)(10)(A)(v) Strategies and actions to implement those priorities and goals, which may include, but are not limited to, enhancing mobility strategies
Table 4.2-2, on p. 37-49, listed the
following mobility strategies:

Action HOU-3.2: BMR Ordinance
Action HOU-3-3: Accessory Dwelling
Units
Action HOU-3.4: First-Time
Homebuyer Programs
Action HOU-3.10: Anti-Displacement
Strategies
Action HOU-3.11: Access to
Opportunity
Action HOU-5.2: Large Rental Units
and Supportive Services
Action HOU-5.8: Furthering
Integration
(c)(10)(A)(v) and encouraging development of new affordable housing in areas of opportunity,
Table 4.2-2, on p. 37-49, listed the
following development of new
affordable housing in high opportunity
areas:

Action HOU-3.2: BMR Ordinance
Action HOU-3.4: First-Time
Homebuyer Programs
Action HOU-3.11: Access to
Opportunity
HOU-5.8: Furthering Integration
(c)(10)(A)(v) as well as place-based strategies to encourage community revitalization, including preservation of existing affordable housing,
Table 4.2-2, on p. 37-49, listed the
following development of new
affordable housing in high opportunity
areas:

Action HOU-1.1: Rental Inspection
Program
Action HOU-1.2: Residential
Rehabilitation Programs
Action HOU-1.3: Preservation of AtRisk Rental Housing
Action HOU-3.1: Housing Options for

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Special Needs and Extremely-Low
Income Households.
(c)(10)(A)(v) and protecting existing residents from
displacement.

Table 4.2-2, on p. 37-49, listed the
following policies to protect existing
residents from displacement.

Action HOU-1.1: Rental Inspection
Program
Action HOU-1.2: Residential
Rehabilitation Programs
Action HOU-1.3: Preservation of AtRisk Rental Housing
Action HOU-3.1: Housing Options for
Special Needs and Extremely-Low
Income Households.

Action HOU-3.2: BMR Ordinance
Action HOU-3-3: Accessory Dwelling
Units
Action HOU-3.5: Rental Voucher
Program
Action HOU-3.10: Anti-Displacement
Strategies
(c)(10)(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 Section 91.225 of Title 24 of the Code of Federal Regulations in effect before 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.

Portions of The San Mateo County
Regional Assessment of Fair Housing
(AFH) has been used throughout the
AFFH analysis where appropriate.
(c)(10)(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.

The elements includes the
requirements of this paragraph.
(d)(1) A local government may satisfy all or part of its requirement to identify a zone or zones suitable for the development of emergency shelters pursuant to paragraph (4) of subdivision (a) by adopting and implementing a
multijurisdictional agreement, with a maximum of two other adjacent communities, that requires the participating jurisdictions to develop at least one year-round emergency shelter within two years of the beginning of the planning period.

The City has already identified zones
that allow for emergency shelters
without discretionary review in the
Mixed Use North Boulevard (MU-NB)
and Mixed Use South Boulevard (MUSB) zoning districts. The element also identifies 6.2 acres of land in MU-NB
and 17.4 acres in MU-SB. These
areas are located at the north and
south gateways of the El Camino Real
(State Route 82) corridor in San
Carlos. Both zoning districts allow for
a variety of uses and are located in
close proximity to local services and
transit. The zoning districts presents
redevelopment and adaptive reuse
opportunities of existing buildings.

These zones have sufficient capacity
to accommodate the City’s 30

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homeless individuals identified in the
2019 point-in-time count.
(d)(2) The agreement shall allocate a portion of the new shelter capacity to each jurisdiction as credit toward its emergency shelter need, and each jurisdiction shall describe how the capacity was allocated as part of its housing element.

See above.
(d)(3) Each member jurisdiction of a multijurisdictional agreement shall describe in its housing element all of the following:

See above.
(d)(3)(A) How the joint facility will meet the jurisdiction’s emergency shelter need.
(d)(3)(B) The jurisdiction’s contribution to the facility for both the development and ongoing operation and management of the facility.
(d)(3)(C) The amount and source of the funding that the jurisdiction contributes to the facility.

See above.
(d)(4) The aggregate capacity claimed by the participating jurisdictions in their housing elements shall not exceed the actual capacity of the shelter.

See above.
(e) Except as otherwise provided in this article, amendments to this article that alter the required content of a housing element shall apply to both of the following: [Note that this provision is applicable to AB 2339 (Chapter 654, Statutes of 2022), which amended Section 65583(a)(4). Jurisdictions adopting their housing element after January 1, 2023 should describe why this amendment is not applicable to them.]
See above
(1) A housing element or housing element amendment prepared pursuant to subdivision (e) of Section 65588 or Section 65584.02, when a city, county, or city and county submits a draft to the department for review pursuant to Section 65585 more than 90 days after the effective date of the amendment to this section.

See above
(2) Any housing element or housing element amendment
prepared pursuant to subdivision (e) of Section 65588 or Section 65584.02, when the city, county, or city and county fails to submit the first draft to the department before the due date specified in Section 65588 or 65584.02.

See above
(f) – (j): Not applicable See above.

Section 65583.1(a)
(a) The Department of Housing and Community Development, in evaluating a proposed or adopted housing element for
substantial compliance with this article, … may also allow a city or county to identify sites for accessory dwelling units based on the number of accessory dwelling units developed in the prior housing element planning period whether or not the units are permitted by right, the need for these units in the community, the resources or incentives available for their development, and any other relevant factors, as determined by the department. p. 142-143 provide a methodology for
projecting ADU production during the
planning period based on the City
issuance of ADU building permits
between 2018 and 2021.
(b) Sites that contain permanent housing units located on a military base undergoing closure or conversion as a result of action pursuant to the Defense Authorization Amendments and Base Closure and Realignment Act (Public Law 100-526), the No sites located on a military based
have been identified.

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Defense Base Closure and Realignment Act of 1990 (Public Law 101-510), or any subsequent act requiring the closure or conversion of a military base may be identified as an adequate site if the housing element demonstrates that the housing units will be available for occupancy by households within the planning period of the element. No sites containing housing units scheduled or planned for demolition or conversion to
nonresidential uses shall qualify as an adequate site.

Note: If communities are using the provisions of Section 65583.1(c), which allow RHNA credit for conversion of nonaffordable to affordable housing and for preservation of existing affordable housing at risk of loss, the applicable provisions need to be added to this table.

The Housing Element is not using the
provisions of Section 65583.1(c)
Section 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 (10) of subdivision (c) of Section 65583,
The sites inventory has identified
suitable land citywide in residential
single-family and multi-family zoning
districts as well as mixed use zoning
districts.
(a) 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 following sites that meet the standards set forth in subdivisions (c) and (g):

See paragraphs below.
(a)(1) Vacant sites zoned for residential use. P.159 identifies vacant sites zoned for residential uses.

A total of 13.1 acres of vacant and
underutilized parcels in residential
zones were identified.

Combined, there is the potential to
yield 368 new dwelling units on vacant
and underutilized land in residential
zones (Table 4.5-7).
(a)(2) Vacant sites zoned for nonresidential use that allows residential development.

P.160 identifies available sites zoned
for nonresidential uses that allows for
residential development.

Nearly all of San Carlos is developed;
there is an extremely limited amount
of vacant land within City limits. The
City’s Mixed Use zoning districts
facilitate the redevelopment of
underutilized properties to create
vibrant, walkable centers and
corridors. New housing in these areas
is an integral part of the vision for San
Carlos; a balance of housing
opportunities for both affordable and
market-rate housing is essential to
meet this goal. A survey of land was
conducted in areas that permit mixed8.b
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Government Code Provision Housing Element Compliance
use development, and a total of 33.4
acres of underutilized parcels in
mixed-use zones was identified, with
the potential to yield 2,602 new
dwelling units (Table 4.5-8).
(a)(3) Residentially zoned sites that are capable of being developed at a higher density, including sites owned or leased by a city, county, or city and county
p. 159 discusses residentially zoned
sites capable of being developed at a
higher density. All but one site zoned
for lower density (RS-3 and RS-6) are
vacant. In the multifamily zones, three
quarters of the parcels are currently
developed with single family homes
and the zoning allows for an increase
in units that ranges from 600 to 2,600
percent.
(a)(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.

P.160 identifies available sites zoned
for nonresidential uses that allows for
residential development.

Nearly all of San Carlos is developed;
there is an extremely limited amount
of vacant land within City limits. The
City’s Mixed Use zoning districts
facilitate the redevelopment of
underutilized properties to create
vibrant, walkable centers and
corridors. New housing in these areas
is an integral part of the vision for San
Carlos; a balance of housing
opportunities for both affordable and
market-rate housing is essential to
meet this goal. A survey of land was
conducted in areas that permit mixeduse development, and a total of 33.4 acres of underutilized parcels in
mixed-use zones was identified, with
the potential to yield 2,602 new
dwelling units (Table 4.5-8).
(b) The inventory of land shall include all of the following: See below. (b)(1) A listing of properties by assessor parcel number. Appendix A lists each property by assessor parcel number, address,
General Plan designation, zoning,
acreage, maximum and minimum
density, potential for lot consolidation,
common ownership, realistic capacity
by income, and existing use.
(b)(2) The size of each property listed pursuant to paragraph (1), and the general plan designation and zoning of each property.

Appendix A lists each property by
assessor parcel number, address,
General Plan designation, zoning,
acreage, maximum and minimum
density, potential for lot consolidation,
common ownership, realistic capacity
by income, and existing use.

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Government Code Provision Housing Element Compliance
(b)(3) For nonvacant sites, a description of the existing use of each property.

Appendix A lists each property by
assessor parcel number, address,
General Plan designation, zoning,
acreage, maximum and minimum
density, potential for lot consolidation,
common ownership, realistic capacity
by income, and existing use.
(b)(3) If a site subject to this paragraph is owned by the city or county, the description shall also include whether there are any plans to dispose of the property during the planning period and how the city or county will comply with Article 8 (commencing with Section 54220) of Chapter 5 of Part 1 of Division 2 of Title

5. No site identified is owned by the city
or county.
(b)(4) A general description of any environmental constraints to the development of housing within the jurisdiction, the documentation for which has been made available to the
jurisdiction. This information need not be identified on a sitespecific basis.

P.123-131 discusses any
environmental constraints associated
with the sites identified in the
inventory and policies and program to
address these constraints.
(b)(5)(A) A description of existing or planned water, sewer, and other dry utilities supply, including the availability and access to distribution facilities.

P.167-169 describe the infrastructure
capacity available for the identified
sites, including water, wastewater,
and dry utilities.

San Carlos is fully developed, and full
urban-level services are available to
each site in the inventory. Specifically,
water, sewer, and dry utility services
are available for all the sites included
in the inventory.

As part of the environmental analysis
completed for the Housing Element
update, the availability of sufficient
water supply and wastewater
treatment capacity to meet the
demand for San Carlos’ General Plan
projections and the current RHNA will
be analyzed.
(b)(5)(B) Parcels included in the inventory must have sufficient water, sewer, and dry utilities supply available and accessible to support housing development or be included in an existing general plan program or other mandatory program or plan, including a program or plan of a public or private entity providing water or sewer service, to secure sufficient water, sewer, and dry utilities supply to support housing development. This paragraph does not impose any additional duty on the city or county to construct, finance, or otherwise provide water, sewer, or dry utilities to parcels included in the inventory.

See above.
(b)(6) Sites identified as available for housing for above moderate-income households in areas not served by public sewer systems. This information need not be identified on a sitespecific basis.

No sites for above moderate-income
households not served by public
sewer systems have been identified.

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Government Code Provision Housing Element Compliance
(b)(7) A map that shows the location of the sites included in the inventory, such as the land use map from the jurisdiction’s general plan, for reference purposes only.

P. 164 shows a map of the sites
inventory.
(c) Based on the information provided in subdivision (b), a city or county shall determine whether each site in the inventory can accommodate the development of some portion of its share of the regional housing need by income level during the planning period, as determined pursuant to Section 65584. The inventory shall specify for each site the number of units that can realistically be accommodated on that site and whether the site is adequate to accommodate lower income housing, moderateincome housing, or above moderate-income housing.

Appendix A lists each property by
assessor parcel number, address,
General Plan designation, zoning,
acreage, maximum and minimum
density, potential for lot consolidation,
common ownership, realistic capacity
by income, and existing use.
(c) A nonvacant site identified pursuant to paragraph (3) or (4) of subdivision (a) in a prior housing element and a vacant site that has been included in two or more consecutive planning periods that was not approved to develop a portion of the locality’s housing need shall not be deemed adequate to accommodate a portion of the housing need for lower income households that must be accommodated in the current housing element planning period unless the site is zoned at residential densities consistent with paragraph (3) of this subdivision and the site is subject to a program in the housing element requiring rezoning within three years of the beginning of the planning period to allow residential use by right for housing developments in which at least 20 percent of the units are affordable to lower income households.

An unincorporated area in a nonmetropolitan county pursuant to clause (ii) of subparagraph (B) of paragraph (3) shall not be subject to the requirements of this subdivision to allow residential use by right.

P. 160-162 discusses the reuse of
sites.

AB 1397 also requires that specific
parameters be placed on sites that
were used in previous planning cycles
but did not develop and are now used
in the current Housing Element to
meet the lower income RHNA.

However, as noted in HCD guidance
documents, due to updates in the
prior planning period to the general
plan or other planning activities, such
as the creation of a specific plan,
some sites previously identified in the
housing element may have been
rezoned allowing a higher density,
and therefore increasing the potential
housing capacity of the site. Because
the zoning characteristics of this site
have changed, it can be considered a
new site for the purposes of the
housing element inventory. All of the
lower-income sites in the Housing
Element have been rezoned to
significantly increase densities and
thus none are subject to the reuse
provisions of AB 1397.
(c) Notwithstanding the foregoing, for a local government that fails to adopt a housing element that the department has found to be in substantial compliance with state law within 120 days of the statutory deadline in Section 65588 for adoption of the housing element, rezoning pursuant to this subdivision shall be completed no later than one year from the statutory deadline in Section 65588 for adoption of the housing element.

The City will be adopting revisions to
its Zoning Ordinance January 2023.
(c) The analysis shall determine whether the inventory can provide for a variety of types of housing, including multifamily rental housing,
The inventory has more than sufficient
land to accommodate a variety of
housing types. It has a surplus of
128% ounits that could be used to
accommodate:
• factory-built housing,
mobilehomes,

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Government Code Provision Housing Element Compliance
• housing for agricultural
employees, supportive
housing,
• single-room occupancy units,
• emergency shelters, and
• transitional housing
(c) factory-built housing, mobilehomes, See above
(c) housing for agricultural employees, supportive housing, See above (c) single-room occupancy units, See above
(c) emergency shelters, and See above
(c) transitional housing See above
(c) and whether the inventory affirmatively furthers fair housing . P. 165-167 describes how the inventory is consistent with
Affirmatively Furthering Fair Housing.
(c) The city or county shall determine the number of housing units that can be accommodated on each site as follows:

See below.
(c)(1) If local law or regulations require the development of a site at a minimum density, the department shall accept the planning agency’s calculation of the total housing unit capacity on that site based on the established minimum density. If the city or county does not adopt a law or regulation requiring the development of a site at a minimum density, then it shall demonstrate how the number of units determined for that site pursuant to this subdivision will be accommodated.

P.146-160 discusses the methodology
for calculating realistic capacity based
on trends from recent, past, and
active projects.
(c)(2) The number of units calculated pursuant to paragraph (1) shall be adjusted as necessary, based on the land use controls and site improvements requirement identified in paragraph (5) of subdivision (a) of Section 65583,
The methodology on p.146-160 also
take into account land use controls
and other site improvement
requirements into the calculation of
realistic capacity.
(c)(2) the realistic development capacity for the site, Based on the data and information on p. 146-160 a realistic capacity
assumption was developed and
applied to the maximum permitted
densities.
(c)(2) typical densities of existing or approved residential developments at a similar affordability level in that jurisdiction, P. 146-160 discusses density and
affordability for similar affordability
levels.
(c)(2) and on the current or planned availability and accessibility of sufficient water, sewer, and dry utilities.

All sites have sufficient infrastructure
capacity.
(c)(2)(A) A site smaller than half an acre shall not be deemed adequate to accommodate lower income housing need unless the locality can demonstrate that sites of equivalent size were successfully developed during the prior planning period for an equivalent number of lower income housing units as projected for the site or unless the locality provides other evidence to the department that the site is adequate to accommodate lower income housing.
p. 160-162 discusses the site
suitability of identified sites.

In the inventory, several sites include
multiple parcels that are less than
one-half acre in size, however when
consolidated with adjacent parcels are
more than 0.5 acres. Small lot
development is very common in San
Carlos, and Actions HOU-2.1 and
HOU-2.2 are included to identify
additional incentives as needed. Small
sites (less than one-half acre) are
credited toward the moderate- and
above-moderate income categories to

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Government Code Provision Housing Element Compliance
account for a potential variety of
types, sizes, and amenity levels in
future higher-density development
projects. For very low-income sites, all
but two of theparcels in the inventory
are at least 0.5 acres in size. The two
parcels that are smaller are included
only because they have the potential
for lot consolidation with an adjoining
parcel that is under common
ownership and make up a site over

0.5 acres in size.
(c)(2)(B) A site larger than 10 acres shall not be deemed adequate to accommodate lower income housing need unless the locality can demonstrate that sites of equivalent size were successfully developed during the prior planning period for an equivalent number of lower income housing units as projected for the site or unless the locality provides other evidence to the department that the site can be developed as lower income housing.

See above.
(c)(2)(B) For purposes of this subparagraph, “site” means that portion of a parcel or parcels designated to accommodate lower income housing needs pursuant to this subdivision.

See above.
(c)(2)(C) A site may be presumed to be realistic for development to accommodate lower income housing need if, at the time of the adoption of the housing element, a development affordable to lower income households has been proposed and approved for development on the site.

P. 160-162 provide a summary of
realistic development assumptions
AB 1397 also adds specific criteria for
assessment of the realistic availability
of non‐vacant sites during the
planning period. If non-vacant sites
accommodate half or more of the
lower-income need, the Housing
Element must present “substantial
evidence” that the existing use does
not constitute an impediment for
additional residential use on the site.

Due to the built-out nature of San
Carlos, most sites have existing uses.

Non-vacant sites included in the
inventory have been chosen due to
their location, existing uses, and
potential for intensification. To ensure
that appropriate sites have been
chosen, properties that show recent
investments or updates or that contain
uses of local importance are not
included, and clear criteria were used
to evaluate all sites within San Carlos,
as described above. In addition,
through the public engagement
process, sites identified to have
additional constraints were removed.
(c)(3) For the number of units calculated to accommodate its share of the regional housing need for lower income households See below.

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Government Code Provision Housing Element Compliance
pursuant to paragraph (2), a city or county shall do either of the following:
(c)(3)(A) Provide an analysis demonstrating how the adopted densities accommodate this need. The analysis shall include, but is not limited to, factors such as market demand, financial feasibility, or information based on development project experience within a zone or zones that provide housing for lower income households.

P. 146-160 discusses density and
affordability and these allow the City
to meet its RHNA for all income levels
(c)(3)(B) The following densities shall be deemed appropriate to accommodate housing for lower income households:
(i) For an incorporated city within a nonmetropolitan county and for a nonmetropolitan county that has a micropolitan area: sites allowing at least 15 units per acre.
(ii) For an unincorporated area in a nonmetropolitan county not included in clause (i): sites allowing at least 10 units per acre. (iii) For a suburban jurisdiction: sites allowing at least 20 units per acre.
(iv) For a jurisdiction in a metropolitan county: sites allowing at least 30 units per acre.

San Carlos is in a metropolitan county
and has only identified sites that allow
at least 30 units per acres as
appropriate for accommodating the
lower income RHNA.
(4)(A) For a metropolitan jurisdiction:
(4)(A)(i) At least 25 percent of the jurisdiction’s share of the regional housing need for moderate-income housing shall be allocated to sites with zoning that allows at least 4 units of housing, but not more than 100 units per acre of housing.

P. 162 discusses the Housing
Element’s compliance with AB 725.

Of the 169 parcels in the sites
inventory, 138 are used to address
the moderate- and above moderateincome RHNA. Of those 138 parcels, 116 (or 84 percent) allow for
development of 4 or more units.
(4)(A)(ii) At least 25 percent of the jurisdiction’s share of the regional housing need for above moderate-income housing shall be allocated to sites with zoning that allows at least 4 units of housing.

P. 162 discusses the Housing
Element’s compliance with AB 725.

Of the 169 parcels in the sites
inventory, 138 are used to address
the moderate- and above moderateincome RHNA. Of those 138 parcels, 116 (or 84 percent) allow for
development of 4 or more units.
(B) The allocation of moderate-income and above moderateincome housing to sites pursuant to this paragraph shall not be a basis for the jurisdiction to do either of the following:
(i) Deny a project that does not comply with the allocation. (ii) Impose a price minimum, price maximum, price control, or any other exaction or condition of approval in lieu thereof. This clause does not prohibit a jurisdiction from imposing any price minimum, price maximum, price control, exaction, or condition in lieu thereof, pursuant to any other law.
(iii) The provisions of this subparagraph do not constitute a change in, but are declaratory of, existing law with regard to the allocation of sites pursuant to this section.

The City has included Action HOU-4.1
to ensure adequate site are
maintained throughout the planning
period.
(C) This paragraph does not apply to an unincorporated area. San Carlos is not an unincorporated area.

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Government Code Provision Housing Element Compliance
(D) For purposes of this paragraph:
(i) “Housing development project” has the same meaning as defined in paragraph (2) of subdivision (h) of Section 65589.5.

The City complies with this definition.
(ii) “Unit of housing” does not include an accessory dwelling unit or junior accessory dwelling unit that could be approved pursuant to Section 65852.2 or Section 65852.22 or through a local ordinance or other provision implementing either of those sections. This paragraph shall not limit the ability of a local government to count the actual production of accessory dwelling units or junior accessory dwelling units in an annual progress report submitted pursuant to Section 65400 or other progress report as determined by the department.

The City complies with this definition.
(E) Nothing in this subdivision shall preclude the subdivision of a parcel, provided that the subdivision is subject to the Subdivision Map Act (Division 2 (commencing with Section 66410)) or any other applicable law authorizing the subdivision of land.

The City understands the
requirements of this paragraph.
(d) For purposes of this section, a metropolitan county, nonmetropolitan county, and nonmetropolitan county with a micropolitan area shall be as determined by the United States Census Bureau. A nonmetropolitan county with a micropolitan area includes the following counties: Del Norte, Humboldt, Lake, Mendocino, Nevada, Tehama, and Tuolumne and other counties as may be determined by the United States Census Bureau to be nonmetropolitan counties with micropolitan areas in the future.

San Carlos does not belong to a
nonmetropolitan county with a
micropolitan area.
(e) (1) Except as provided in paragraph (2), a jurisdiction shall be considered suburban if the jurisdiction does not meet the requirements of clauses (i) and (ii) of subparagraph (B) of paragraph (3) of subdivision (c) and is located in a Metropolitan Statistical Area (MSA) of less than 2,000,000 in population, unless that jurisdiction’s population is greater than 100,000, in which case it shall be considered metropolitan. A county, not including the City and County of San Francisco, shall be considered suburban unless the county is in an MSA of
2,000,000 or greater in population in which case the county shall be considered metropolitan.

San Carlos is not suburban and is
located within a metropolitan county.
(2)(A)(i) Notwithstanding paragraph (1), if a county that is in the San Francisco-Oakland-Fremont California MSA has a
population of less than 400,000, that county shall be considered suburban. If this county includes an incorporated city that has a population of less than 100,000, this city shall also be considered suburban. This paragraph shall apply to a housing element revision cycle, as described in subparagraph (A) of paragraph (3) of subdivision (e) of Section 65588, that is in effect from July 1, 2014, to December 31, 2028, inclusive.

San Carlos is not suburban and is
located within a metropolitan county.
(2)(A)(ii) A county subject to this subparagraph shall utilize the sum existing in the county’s housing trust fund as of June 30, 2013, for the development and preservation of housing
affordable to low- and very low income households.

San Mateo County is not subject to
this subparagraph.
(2)(B) A jurisdiction that is classified as suburban pursuant to this paragraph shall report to the Assembly Committee on Housing and Community Development, the Senate Committee on Housing, and the Department of Housing and Community Development regarding its progress in developing low- and very San Carlos is not suburban and is
located within a metropolitan county.

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Government Code Provision Housing Element Compliance
low income housing consistent with the requirements of Section 65400. The report shall be provided three times: once, on or before December 31, 2019, which report shall address the initial four years of the housing element cycle, a second time, on or before December 31, 2023, which report shall address the subsequent four years of the housing element cycle, and a third time, on or before December 31, 2027, which report shall address the subsequent four years of the housing element cycle and the cycle as a whole. The reports shall be provided consistent with the requirements of Section 9795.
(f) A jurisdiction shall be considered metropolitan if the jurisdiction does not meet the requirements for “suburban area” above and is located in an MSA of 2,000,000 or greater in population, unless that jurisdiction’s population is less than 25,000 in which case it shall be considered suburban.
(g)(1) For sites described in paragraph (3) of subdivision (b) [non-vacant sites], the city or county shall specify the additional development potential for each site within the planning period and shall provide an explanation of the methodology used to determine the development potential.

San Carlos is metropolitan and is
located within a metropolitan county.
(g)(1) The methodology shall consider factors including the extent to which existing uses may constitute an impediment to additional residential development,
See below.
(g)(1) the city’s or county’s past experience with converting existing uses to higher density residential development, P. 150-155 and Tables 4.5-5 and 4.5-
6 summarize recent or active projects
in residential or mixed use zones with
previous uses that were redeveloped
to high density residential
developments.
(g)(1) the current market demand for the existing use, P. 150-155 provide an analysis on how the existing uses is not an
impediment to redevelopment, that
includes:
• The demand for higher
density housing in San Carlos
• How the city is encouraging
higher density construction
through its zoning
• Density Bonus projects
• Criteria used to identify
underutilized sites
(g)(1) an analysis of any existing leases or other contracts that would perpetuate the existing use or prevent redevelopment of the site for additional residential development,
See above.
(g)(1) development trends, See above.
(g)(1) market conditions, See above.
(g)(1) and regulatory or other incentives or standards to encourage additional residential development on these sites.

See above.
(g)(2) In addition to the analysis required in paragraph (1), when a city or county is relying on nonvacant sites described in paragraph (3) of subdivision (b) to accommodate 50 percent or The City is using nonvcant sites to
accommodate 50 percent or more of
its housing need for lower income

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Government Code Provision Housing Element Compliance
more of its housing need for lower income households, the methodology used to determine additional development potential shall demonstrate that the existing use identified pursuant to paragraph (3) of subdivision (b) does not constitute an impediment to additional residential development during the period covered by the housing element. An existing use shall be presumed to impede additional residential development, absent findings based on substantial evidence that the use is likely to be discontinued during the planning period.
households. The analysis prepared in
the pages listed above provide a
thorough screening of sites that have
been deemed appropriate to
accommodate the lower income
RHNA and that the existing use has
clearly been demonstrated not to
impede residential development.
(g)(3) Notwithstanding any other law, and in addition to the requirements in paragraphs (1) and (2), sites that currently have residential uses, or within the past five years have had residential uses that have been vacated or demolished, that are or were subject to a recorded covenant, ordinance, or law that restricts rents to levels affordable to persons and families of low or very low income, subject to any other form of rent or price control through a public entity’s valid exercise of its police power, or occupied by low or very low income households, shall be subject to a policy requiring the replacement of all those units affordable to the same or lower income level as a condition of any development on the site. Replacement requirements shall be consistent with those set forth in paragraph (3) of subdivision (c) of Section 65915.

Program HOU-3.8 has been provided
in the housing plan for the
replacement of units on sites.

Replacement of Units on Sites.

Pursuant to Government Code
§65583.2(g)(3), require the
replacement of units affordable to the
same or lower income level as a
condition of any development on a
nonvacant site identified in the
Housing Element consistent with
those requirements set forth in
Government Code §65915(c)(3).

Replacement requirements shall be
required for sites identified in the
inventory that currently have
residential uses, or within the past five
years have had residential uses that
have been vacated or demolished,
and:
• Were subject to a recorded
covenant, ordinance, or law that
restricts rents to levels affordable to
persons and families of low- or very
low-income; or
• Subject to any other form of
rent or price control through a public
entity’s valid exercise of its police
power; or
• Occupied by low- or very lowincome households
For the purpose of this program
“previous five years” is based on the
date the application for development
was submitted.

Pursuant to Government Code
§66300(d) (Chapter 654, Statutes of
2019 (SB 330)), the City shall not
approve a housing development
project that will require the demolition
of residential dwelling units regardless
of whether the parcel was listed in the
inventory unless a) the project will
create at least as many residential
dwelling units as will be demolished,

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Government Code Provision Housing Element Compliance
and b) certain affordability criteria are
met.

To provide clarity in the development
process, the City will modify the
Zoning Ordinance to reference these
requirements.

Timeframe: OngoingRoutinely as part
of the housing development approval
process, require replacement of any
of units if (a) they are planned to be
demolished for purposes of building
new housing, and (b) they are
determined to be occupied by lowincome households, require the provision of assistance to prevent
displacement of lower-income
households due to loss of affordable
units. Draft an amendment to the
Zoning Ordinance to
implement/reference replacement
requirements of State law and bring to
hearings by 2024.

Responsible Agency: Planning
Division
Funding Sources: Community
Development Department Budget
(h) The program required by subparagraph (A) of paragraph (1) of subdivision (c) of Section 65583 shall accommodate 100 percent of the need for housing for very low and low-income households allocated pursuant to Section 65584 for which site capacity has not been identified in the inventory of sites pursuant to paragraph (3) of subdivision (a) on sites that shall be zoned to permit owner-occupied and rental multifamily
residential use by right for developments in which at least 20 percent of the units are affordable to lower income households during the planning period.

See above.
(h) These sites shall be zoned with minimum density and development standards that permit at least
See above.
(h) 16 units per site at a density of at least 16 units per acre in jurisdictions described in clause (i) of subparagraph (B) of paragraph (3) of subdivision (c),
See above.
(h) shall be at least 20 units per acre in jurisdictions described in clauses (iii) and (iv) of subparagraph (B) of paragraph (3) of subdivision (c)
See above.
(h) and shall meet the standards set forth in subparagraph (B) of paragraph (5) of subdivision (b).

See above.
(h) At least 50 percent of the very low and low-income housing need shall be accommodated on sites designated for residential use and for which nonresidential uses or mixed uses are not permitted, except that a city or county may accommodate all of the very low and low-income housing need on sites designated for mixed uses if those sites allow 100 percent residential use and require that residential use occupy 50 percent of the total floor area of a mixed-use project.

Mixed use zoning districts allow for
100 percent residential use.

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Government Code Provision Housing Element Compliance
(i) For purposes of this section and Section 65583, the phrase “use by right” shall mean that the local government’s review of the owner-occupied or multifamily residential use may not require a conditional use permit, planned unit development permit, or other discretionary local government review or approval that would constitute a “project” for purposes of Division 13 (commencing with Section 21000) of the Public Resources Code. Any subdivision of the sites shall be subject to all laws, including, but not limited to, the local government ordinance implementing the Subdivision Map Act.

The City complies with this definition.
(i) A local ordinance may provide that “use by right” does not exempt the use from design review. However, that design review shall not constitute a “project” for purposes of Division 13 (commencing with Section 21000) of the Public Resources Code.

The City complies with this definition.
(i) Use by right for all rental multifamily residential housing shall be provided in accordance with subdivision (f) of Section 65589.5.

The City complies with this paragraph.
(j) Notwithstanding any other provision of this section, within one-half mile of a Sonoma-Marin Area Rail Transit station, housing density requirements in place on June 30, 2014, shall apply.

There is no Sonoma-Marin Rail
Transit station in San Carlos
Section 65583.3
(a) For a housing element or amendment adopted on or after January 1, 2021, the planning agency shall submit to the department an electronic copy of its inventory of land suitable for residential development developed pursuant to paragraph (3) of subdivision (a) of Section 65583 and subdivision (b) of this section with the copy of its housing element or amendment submitted pursuant to subdivision (g) of Section 65585. The local government shall ensure, to the best of its knowledge, that the inventory of land submitted to the department is true and correct.

An electronic copy, using HCD’s
templates, has been prepared and will
be submitted along with the Housing
Element.
(b) Notwithstanding subdivision (a) of Section 65301, each local government shall prepare the inventory required under
paragraph (3) of subdivision (a) of Section 65583 using standards, forms, and definitions adopted by the department.

An electronic copy, using HCD’s
templates, has been prepared and will
be submitted along with the Housing
Element.

8.b
January 23, 2023 Packet
Pg. 1250

EXHIBIT B
Findings Responding to Letter from Department of Housing and Community Development Dated January 6, 2023 HCD
Questions/Comments
from January 6, 2023
Response
A. Housing Needs, Resources, and Constraints

1. Affirmatively further[ing] fair housing in accordance with Chapter 15 (commencing with Section 8899.50) of Division 1 of Title 2…shall include an assessment of fair housing in the jurisdiction. (Gov. Code, § 65583, subd. (c)(10)(A).)
Income and Racial Concentration
of Affluence (RCAA): The element
briefly mentions incomes in the
City compared to the region and
includes a map showing the
entire City as a RCAA; however,
the element should include
specific analysis of income and
RCAA at a regional level (City
compared to the broader region).

The analysis should at least
address trends, conditions,
coincidence with other fair
housing factors (e.g., race,
highest resource, overpayment),
effectiveness or absence of past
strategies (e.g., lack of publicly
assisted housing), local data and
knowledge and other relevant
factors.

A thorough analysis of RCAAs has been added to p. 188
Racially/Ethnically Concentrated Areas of Affluence
Racially Concentrated Areas of Affluence (RCAAs) are defined by the HUD as, communities with a large proportion of affluent and non-Hispanic White residents. According to a policy paper published by the HUD, non-Hispanic Whites are the most racially segregated groups in United States. In the same way neighborhood disadvantage is associated with concentrated poverty and high concentrations of people of color, distinct advantages are associated with residence in affluent, White communities. Figure 4.6-23 demonstrates that the entire city of San Carlos is considered an RCAA, given its predominantly White population, as well as its median income level above $125,000. Among the various cities in San Mateo County, San Carlos is among the few cities that are entirely comprised of RCAAs, along with Woodside, Menlo Park, and Portola Valley.

San Carlos and other predominantly RCAA communities in San Mateo County have a history of being known as affluent communities. These communities also translate into areas of high resource/opportunity, with high performing schools, low crime rates, and low levels of housing problems such as substandard housing and overpayment.

San Carlos has a very limited number (137 units) of deed-restricted or publicly assisted affordable units (see Table 4.3-10 in the Needs Assessment). To address a history of a lack of affordable housing, the City instituted a Below Market Rate Ordinance to require provision of on-site affordable housing units for new construction projects, along with a Commercial Linkage fee to fund future affordable housing development. In 2022, the City updated the Below Market Rate Ordinance to remove loopholes and effectuate more affordable housing development. The Commercial linkage fee was adopted in 2017 and as of 2023 the City has collected over $6.5 million to support affordable housing.

N e w f i g u r e a d d e d :

8.b
January 23, 2023 Packet Pg. 1251

EXHIBIT B
Findings Responding to Letter from Department of Housing and Community Development Dated January 6, 2023 The element must add or modify
meaningful programs based on
the outcomes of this analysis,
including actions to improve
housing mobility within and
beyond City boundaries.

F I G U R E 4 . 6 - 2 B R e g i o n a l R a c i a l l y C o n c e n t r a t e d A r e a s o f A f f l u e n c e ( R C A A s ) , 2 0 1 5 - 2 0 1 9
Disproportionate Housing Needs
Including Displacement: The
element includes some general
information on persons
experiencing homelessness and
housing conditions but should
also evaluate those needs,
impacts and patterns within the
City, such as areas of higher need.

For homelessness, the element
should examine patterns of need
or areas with higher
concentrations of persons
experiencing homelessness,
including access to transportation
and services. For housing
conditions, the element should
discuss any areas of potentially
higher needs of rehabilitation and
replacement.

The element may utilize local data
and knowledge such as service
Additional details have been added regarding the homeless population in the City p. 204 Homelessness
In 2019, 30 unsheltered individuals were identified in San Carlos during the point-in-time count, which is 3.3 percent of the total number of unsheltered individuals in San Mateo County. In 2019A total of , 1,512 people were experiencing homelessness in the county during the One-Day Count, with 40% of people in emergency or transitional shelter while the remaining 60% were unsheltered. Throughout the county, the majority of unsheltered people experiencing homelessness were in households without children. The majority of people in transitional housing were in households with children.

People who identify as American Indian or Alaskan Native (six percent of the homeless population compared to less than one percent of the total population), Black (13 percent, 2 percent), White (67 percent, 51 percent), and Hispanic (38 percent, 28 percent) are overrepresented in the homeless population compared to their share of the general population. People struggling with chronic substance abuse (112 people), severe mental illness (305), and domestic violence (127) represented a substantial share of the homeless population in 2019. In San Carlos, 30 persons experiencing homelessness were identified as unsheltered in 2019. Demographic information on these persons individuals is not available.

The 2022 One-Day Count reported a 21 percent increase in the number of unsheltered persons experiencing homelessness countywide (1,092 persons) as compared to the 2019 One-Day Count and an increase in 17 percent in the number of individuals living in group shelters and hotels that have been converted to interim housing (716 persons) for a total of 1,808 persons.

However, in San Carlos, the number of homeless individuals decreased to an estimated 14 persons in 2022. Additional geographic and demographic information is not yet available for 2022.

Most homeless individuals are generally located near Highway 101, in Downtown or in vacant open space areas, but are not concentrated in any one location. Downtown provides ample access to transportation and services.

The City of San Carlos is working collaboratively with the Home for All San Mateo County initiative to promote more housing in San Mateo County. Housing and shelter resources are provided on the City’s website and upon request from interested individuals.

8.b
January 23, 2023 Packet Pg. 1252

EXHIBIT B
Findings Responding to Letter from Department of Housing and Community Development Dated January 6, 2023 providers and code enforcement
officials to assist this analysis.

Affirmatively Furthering Fair
Housing (AFFH) and Identified
Sites: The element must analyze
how the identified sites
contribute to or mitigate fair
housing issues. The element must
identify and analyze sites
throughout the community to
foster inclusive communities and
AFFH. An analysis should address
all the income categories of
identified sites with respect to
location, the number of units by
all income groups and how that
affects the existing patterns for all
components of the assessment of
fair housing (e.g., segregation and
integration, access to
opportunity).

The analysis on AFFH and Identified sites has been revised to address all AFFH factors with respect to location, number of units by all income groups and how this impacts AFFH. P 130-133
Table 4.5-10: Sites and TCAC/HCD Opportunity Areas
Affordability Level
TCAC/HCD Opportunity Areas
Lower Income Units Moderate Income Units
Above Moderate
Income Units
Total Units
High Resource 1,217 75% 159 43% 402 41% 1,778 60%
Highest Resource 402 25% 215 57% 575 59% 1,192 40%
Total Sites 1,619 100% 374 100% 977 100% 2,970 100%
55% 13% 33% 100%
Table 4.5-11: Sites and Segregation/Integration and Disproportionate Housing Needs Affordability Level
Census Tracts Lower
Income
Units
Moderate
Income
Units
Above
Moderate
Income
Units Total Units
% Low/
Mod
HH
%
NonWhite
Pop
% Persons
with
Disabilitie
s
%
Rente
r HHs
%
Children
in
FemaleHeaded
HHs
% Overcrowde
d HHs
Census Tract 6091 73 5% 17 5% 42 4% 132 4% 45% 42% 10% 25% 4% 9% Census Tract 6092.01 353 22% 146 39% 364 37% 863 29% 31% 30% 7% 42% 6% 1% Census Tract 6092.02 1,110 69% 140 37% 356 36% 1,606 54% 45% 39% 12% 73% 7% 0% Census Tract 6093 83 5% 71 19% 178 18% 332 11% 25% 24% 7% 17% 12% 0% Census Tract 6094 - - - - - - - - 16% 23% 5% 10% 18% 0% Census Tract 6095 - 0% - 0% 5 1% 5 0% 18% 35% 5% 14% 6% 0%

8.b
January 23, 2023 Packet Pg. 1253

EXHIBIT B
Findings Responding to Letter from Department of Housing and Community Development Dated January 6, 2023 Census Tract 6096.01 - 0% - 0% 29 3% 29 1% 34% 32% 3% 32% 17% 3% Census Tract 6096.02 - - - - - - - - 14% 31% 8% 7% 5% 0% Census Tract 6096.03 - 0% - 0% 3 0% 3 0% 19% 26% 6% 9% 12% 0% Total 1,619 100% 374 100% 977 100% 2,970 100% 27% 31% 7% 27% 8% 2% Segregation and Integration
Most census tracts in San Carlos are largely comprised of White, non-Hispanic residents (68%). However, one tract, census tract 6092.02, indicates a relatively higher concentration of non-White residents (43%); this tract is located between Magnolia Ave and Cherry St. Sites included in the inventory located within this region are largely lower-income housing with a 1,061-unit capacity (low and very low income), a moderate-income capacity of 140 units, and an above moderate-income capacity of 356 units. These new housing sites help further an integrated mixed-income community, which helps address overconcentration of affordable housing in areas with lower income housing.

Any concerns of displacement as a result of the integration of high-income housing could be addressed with anti-displacement strategies. For this, the City will implement the following program, Action HOU-3.10 Anti-Displacement Strategies. The program will adopt tenant protection policies, as well as support local efforts to establish land trusts, or housing preservation funds.

Persons with Disabilities
In San Carlos, there is a generally low percentage of the population living with disabilities (7%). Of all tracts in the City, tract 9062.02 has a relatively higher concentration of residents living with disabilities (12%). The housing sites identified in the inventory are similar to that which were described in the previous ‘Segregation and Integration’ section of the Constraints chapter of the Housing Element. The abundance of housing options located primarily in a high density/ multi-family area of the Ccity that is concentrated around public transit makes it easier for those with disabilities (namely independent living disabilities) to access services and resources.

Access to Opportunity
Most of the City is designated as a high to highest resource areas, according to the TCAC Composite Score map shown in Figure 4.5-2. A greater portion of the sites identified in the site inventory are located within the area of “highest resource”, while the remainder can be found in “high resource” areas.

Of all the new sites considered in the “highest resource” areas, a total of 485 units are designated as lower income sites (very low and low income), most of which are located in mixed-use zones, with good access to local transit and services. These sites provide opportunities for low-income housing in predominantly high-income areas, which helps to create more economically integrated areas citywide. The inclusion of lower income sites in higher income areas also helps improve housing mobility and access to opportunity for low-income households.

8.b
January 23, 2023 Packet Pg. 1254

EXHIBIT B
Findings Responding to Letter from Department of Housing and Community Development Dated January 6, 2023 Disproportionate Housing Needs
Compared to surrounding cities, San Carlos has relatively lower rates of cost burden for both homeowners and renters, however some tracts see a greater percentage of renters experiencing housing cost burden. The majority of the City also has overcrowding rates that are lower than the California average (8.2%), with the exception of the tract located northeast of El Camino Real (Tract 6091.00), where nine percent of the population experiences overcrowding. Additionally, 60 percent of renter-households within this tract experience cost burden. The sites identified in the inventory within this tract are largely very-low to lowincome units (73 units). The increase availability of affordable housing could potentially alleviate the housing problems associated with overcrowding and overpayment for some residents. The addition of affordable rental units does not present an overconcentration or significant addition of lower-income housing to the area, where the median income is upwards of $126,000.

If sites exacerbate conditions, the
element should identify further
program actions that will be
taken to promote equitable
quality of life throughout the
community (e.g., antidisplacement and place-based
community revitalization
strategies). For more information,
See HCD’s guidance at
https://www.hcd.ca.gov/planning
-and-communitydevelopment/affirmativelyfurthering-fair-housing.

See above for where sites exacerbate conditions and actions taken to promote equitable housing opportunities.

8.b
January 23, 2023 Packet Pg. 1255

EXHIBIT B
Findings Responding to Letter from Department of Housing and Community Development Dated January 6, 2023 Local Data and Knowledge: The
element must include local data,
knowledge, and other relevant
factors to discuss and analyze any
unique attributes about the City
related to fair housing issues. The
element should complement
federal, state, and regional data
with local data and knowledge
where appropriate to capture
emerging trends and issues,
including utilizing knowledge
from local and regional advocates
and service providers, City staff
and related local and County
planning documents.

Throughout the Fair Housing Assessment Chapter local data and knowledge has been added from service providers, city staff, and local planning document. See below for examples of this information.

Information on housing specific policies enacted locally:

Reduced parking requirements. Constraints associated with parking requirements in mixed use and residential zones are addressed through Program HOU-4.2 to remove guest parking requirements. Affordable housing projects can request the jurisdiction reduce parking requirements for projects near qualifying transit areas that are applying for a density bonus.

Inclusionary housing ordinance. The City has a Below Market Rate Housing Ordinance that requires developers to set aside a share of units in new housing developments for affordable housing. The ordinance was updated in 2022 to encourage the development of more affordable housing.

Condominium Conversion. Regulates conversion of apartment buildings into condominiums and generally provides tenant protections.

City Density Bonus. The City Density Bonus was updated in 2022 to provide additional incentives for affordable rental housing with density bonuses that exceed the State Density Bonus.

Uniform Relocation Policy. The City requires a minimum one-to-one replacement of any housing units demolished due to public action.

Objective Design Standards. The City has initiated the process to complete objective design and development standards for all multifamily residential and mixed-use development, to streamline review and provide certainty in the development process.

Financial Assistance. Funds from the Housing in-lieu fee and the Commercial Linkage fee are pooled to support affordable housing construction in the city.

Commercial development impact fee. Levies a per square foot development fee levied on non-residential development that is used to develop or preserve affordable housing.

Reduced fees of waivers. Reduces fees or permit waivers for 100% affordable housing development.

Acquisition/Preservation. The City has acquired existing affordable housing to preserve long-term affordability.

More local knowledge has been added to factors of integration and segregation explaining patterns in the data from the HCD’s AFFH Data Viewer.

8.b
January 23, 2023 Packet Pg. 1256

EXHIBIT B
Findings Responding to Letter from Department of Housing and Community Development Dated January 6, 2023 A larger percentage of non-White residents can be seen concentrated adjacent to El Camino Real and San Carlos Ave, largely due to the fact that the area has higher concentration of multi-family housing units, with median gross rents that are less than $2,000 a month (relatively lower rates than majority of the City). This area also includes census tracts where the median household income is roughly $74,000 (according to 2018 ACS data), despite the majority of the City having median household incomes that are greater than $125,000. The greater availability of multi-family housing, that is relatively affordable compared to other areas of San Carlos, could possibly lead to a greater concentration of non-White residents, who typically tend to be of lower income brackets. Residents living in this area also were more likely to be using housing vouchers. …..

While the concentration of residents in this area living with a disability is not significant, compared to the rest of the City, it is worth considering some of the factors which may contribute to the concentration of disabilities. In San Carlos, majority of residents living with disabilities are 75 years of age or older; among the various classifications of disabilities, majority of residents in the City living with disabilities have either an ambulatory or independent living disability. The area identified in Figure 4.6-11 also includes San Carlos Elms and Retirement Plus-San Carlos, both of which are assisted living/senior living facilities. Which can infer that the concentration of disabilities in the area, could be due to residents living in assisted living facilities, due to their independent living disabilities. The concentration of residents living with disabilities is consistent at a regional level, the various tracts across San Mateo county have similar levels of residents living with disabilities (10 to 20 percent). ….

The household income distribution by percent of area median income (AMI) skews higher in San Carlos than in the county. Sixteen percent of San Carlos households earn less than 50 percent AMI compared to 24 percent in the Ccounty (Figure 4.6-18). Nearly all block groups within the City have a median income that is greater than $125,000, with the exception of two block groups that are in the $91,000 - $112,000 range.All but one block group in the city has a median income of less than $125,000 (Figure 4.6-19 and Figure 4.6-20). These block groups, located in the central part of the city, also correspond with census tracts where 30 to 40 percent of households are of low to moderate income levels (LMI). As previously mentioned, residents living in this area have a median income that is lower compared to the rest of the city, however, the median incomes are still well above the median state income of 2020 ($78,672). The relatively higher percentage of low to moderate income levels across these tracts can also be attributed to the higher availability of multifamily housing, which generally attracts lower income residents, due to its affordability. At a regional level, San Carlos has less tracts that are of low to moderate income levels, in comparison to other large cities such as Redwood City, San Mateo, East Palo Alto, San Bruno, and South San Francisco. Still, nNo areas of the city have concentrated poverty (Figure 4.6-21).

8.b
January 23, 2023 Packet Pg. 1257

EXHIBIT B
Findings Responding to Letter from Department of Housing and Community Development Dated January 6, 2023 ….

More local knowledge and information from transit services providers has been added to factors of access to opportunity explaining patterns in the data from the HCD’s AFFH Data Viewer.

TCAC’s economic opportunity score is comprised of poverty, adult educational attainment, employment, job proximity, and median home value. The vast majority of the city ranks very high on economic opportunity, with the areas around Highway 101 offering moderate opportunity (Figure 4.6-27).

The jobs proximity index quantifies the accessibility of a neighborhood to jobs in the region by measuring the physical distances between jobs and places of residence. This index varies from 0-100 as demonstrated in Figure 4.6-28, with higher scores point to better accessibility to employment opportunities. The areas abutting Highway 101, however, offer the best job proximity (Figure 4.6-28). Located within this high proximity region is also the downtown area, which spans along Laurel St. The downtown area is home to a diverse set of retail and commercial centers, serving as a very prominent employment center for the various residents of San Carlos, as well as residents from other cities. At a regional level, cities throughout San Mateo county (namely those along the San Francisco Bay), have similar proximity index levels, where cities like Burlingame, Redwood City, South San Francisco, and East Palo Alto have a very close proximity index. Cities with the furthest proximity include Pacifica and Daly City. ….

Transportation. This section provides a summary of the transportation system that serves the broader region including emerging trends and data relevant to transportation access. The San Mateo County Transit District acts as the administrative body for transit and transportation programs in the county including SamTrans and the Caltrain commuter rail. SamTrans provides bus services in San Mateo County, including Redi-Wheels paratransit service.

In 2018, the Metropolitan Transportation Commission (MTC), which covers the entire Bay Area, adopted a coordinated public transit and human services transportation plan. While developing the coordinated plan, the MTC conducted extensive community outreach about transportation within the area. That plan—which was developed by assessing the effectiveness of how well seniors, persons with disabilities, veterans, and people with low incomes are served—was reviewed to determine gaps in services in San Mateo County. Pertinent feedback in that plan included:
“San Mateo’s [Paratransit Coordinating Council] PCC and County Health System, as well as the Peninsula Family Service Agency provided feedback. The most common themes expressed had to do with pedestrian and bicycle needs at specific locations throughout the county, though some covered more general comments such as parked cars blocking sidewalk right-of-way and a desire for bike lanes to accommodate motorized scooters and wheelchairs.

Transportation information, emerging mobility providers, and transit fares were other common themes.

While some comments related to the use of car share, transportation network companies (TNCs), or autonomous vehicles as potential As part of the TRACS outreach process, respondents were asked to share their compliments or good experiences with MTC transit. One respondent who had used multiple services said, “it is my sense that SamTrans is the best Bay Area transit provider in terms of overall disability accommodation.”

8.b
January 23, 2023 Packet Pg. 1258

EXHIBIT B
Findings Responding to Letter from Department of Housing and Community Development Dated January 6, 2023 The San Mateo County Transit District updated their Mobility Plan for Older Adults and People with Disabilities in 2018. According to the district, the county’s senior population is expected to grow more than 70% over the next 20 years and the district is experiencing unprecedented increases in paratransit ridership. The plan is targeted at developing effective mobility programs for residents with disabilities and older adults including viable alternatives to paratransit, partnerships, and leveraging funding sources.1 MTC also launched Clipper START—an 18-month pilot project— in 2020 which provides fare discounts on single transit rides for riders whose household income is no more than double the federal poverty level.2 Access to transportation is extremely important to households affected by low incomes and rising housing prices, especially because lower income households are often public transit dependent. Public transit should strive to link lower income residents to major employers where job opportunities exist. Access to employment via public transportation can reduce welfare usage and increase housing mobility, which enables residents to locate housing outside of traditionally low-income neighborhoods.

Public transit in the City of San Carlos is somewhat accessible, given that public transit such as bus routes are limited to routes along major roads such as Brittan Ave., and Alameda de las Pulgas. Other transit routes include the Bay Area Rapid Transit (BART) routes, as well as the Cal Train systems which run parallel to the El Camino Real. These methods of transit allow residents of the City of San Carlos to ride beyond the city limits, to other major economic centers. It is worth mentioning that some areas of the city, or areas that can best be characterized as single-family neighborhoods see less public transit accessibility compared to those living in high density corridors. The lack of route coverage is possibly due to there being more access to private modes of transportation (i.e., personal vehicles) among residents living in these areas, as they tend to be homeowners with higher incomes.

Though given that some residents experience disability in the form of independent living, the lack of public transportation availability can make it difficult for these residents to travel away from home to visit grocery stores or other services. ….

Environment. TCAC’s opportunity areas environmental scores are based on the CalEnviroScreen 3.0 indicators, which identify areas disproportionately vulnerable to pollution sources such as ozone, PM2.5, diesel PM, pesticides, toxic release, traffic, cleanup sites, groundwater threats, hazardous waste, impaired water bodies, and solid waste sites. In addition to environmental factors (pollutant exposure, groundwater threats, toxic sites, and hazardous materials exposure) and sensitive receptors (seniors, children, persons with asthma, and low birth weight infants), CalEnviroScreen also takes into consideration socioeconomic factors. These factors include educational attainment, linguistic isolation, poverty, and unemployment. Research has shown a heightened vulnerability of people of certain ethnicities and lower socioeconomic status to environmental pollutants. In San Carlos, there are more significant disparities in environmental outcomes than in other opportunity indicators (Figure 4.6-29). The neighborhoods aligning Highway 101 have low to moderate outcomes, while the balance remainder of the city has moderate outcomes (but for two census tracts with more positive 1 https://www.samtrans.com/Planning/Planning_and_Research/Mobility_Plan_for_Older_Adults_and_People_with_Disabilities.html 2 https://mtc.ca.gov/planning/transportation/access-equity-mobility/clipperr-startsm

8.b
January 23, 2023 Packet Pg. 1259

EXHIBIT B
Findings Responding to Letter from Department of Housing and Community Development Dated January 6, 2023 outcomes). Other cities throughout the region receive similar environmental scores; tracts that are in close proximity to Highway 101 also have less positive environmental scores. Once again, possibly due to the exposure to air pollutants from vehicle emissions. The east end of the 101 also tends to be more industrial and commercial in its uses, as can be seen in cities such as Redwood City, Burlingame, San Mateo, and South San Francisco. …
Racially/Ethnically Concentrated Areas of Affluence
Racially Concentrated Areas of Affluence (RCAAs) are defined by the HUD as, communities with a large proportion of affluent and non-Hispanic White residents. According to a policy paper published by the HUD, non-Hispanic Whites are the most racially segregated groups in United States. In the same way neighborhood disadvantage is associated with concentrated poverty and high concentrations of people of color, distinct advantages are associated with residence in affluent, White communities. Figure 4.6-23 demonstrates that the entire city of San Carlos is considered an RCAA, given its predominantly White population, as well as its median income level above $125,000. Among the various cities in San Mateo County, San Carlos is among the few cities that are entirely comprised of RCAAs, along with Woodside, Menlo Park, and Portola Valley.

San Carlos and other predominantly RCAA communities in San Mateo County have a history of being known as affluent communities. These communities also translate into areas of high resource/opportunity, with high performing schools, low crime rates, and low levels of housing problems such as substandard housing and overpayment.

San Carlos has a very limited number (137 units) of deed-restricted or publicly assisted affordable units (see Table 4.3-10 in the Needs Assessment). To address a history of a lack of affordable housing, the City instituted a Below Market Rate Ordinance to require provision of on-site affordable housing units for new construction projects, along with a Commercial Linkage fee to fund future affordable housing development. In 2022, the City updated the Below Market Rate Ordinance to remove loopholes and effectuate more affordable housing development. The Commercial linkage fee was adopted in 2017 and as of 2023 the City has collected over $6.5 million to support affordable housing. In 2022, the City completed a city-sponsored 100% affordable project at 817 Walnut. In 2023, the City is pursuing a second 100% affordable project at 1232 Cherry Street, exemplifying the City’s recent meaningful efforts to increase the historically low number of BMR units in San Carlos. ….

More local knowledge and information from transit services providers has been added to factors of disproportionate housing need explaining patterns in the data from the HCD’s AFFH Data Viewer.

According to the 2016 San Mateo County Hazard Mitigation Plan, the City of San Carlos has seen two major hazard events since 1989. In October of 1989, residents experienced the 6.9 magnitude Loma Prieta earthquake, and in January of 2010, the city experienced a significant flooding event which impacted the cities airport.

8.b
January 23, 2023 Packet Pg. 1260

EXHIBIT B
Findings Responding to Letter from Department of Housing and Community Development Dated January 6, 2023 These disasters pose a substantial safety risk to residents, and threaten vital infrastructure and property throughout the city. For this reason, the city and county have implemented a variety of measures that aim to help residents effectively respond and prepare for any such disasters.

As mitigation actions addressing these issues are included in the County Hazard Mitigation Plan, as well as the City’s Climate Action Plan, the risk of displacement due to disaster is expected to be minimal. The risks of displacement due to disinvestment are also anticipated to be minimal or nonexistent. San Carlos is experiencing demand for non-residential and residential development throughout the city, with no significant areas of disinvestment or concern.
…
The Comprehensive Housing Affordability Strategy (CHAS) developed by the Census for HUD provides detailed information on housing needs by income level for different types of households in San Mateo County. Severe Housing problems considered by CHAS include:
• Severe housing cost burden, including utilities, exceeding 50 percent of gross income; • Overcrowded conditions (housing units with more than 1.5 persons per room); and • Units with physical defects (lacking complete kitchen or bathroom/plumbing facilities) According to the 2015-19 CHAS data, less than 15 percent of all households (homeowners and renters) in the City of San Carlos experience any of the four previously mentioned severe housing problems. At a county-level, 23 percent of households experience severe housing problems.

There is no concentration of substandard housing issues or areas where housing is more likely to need rehabilitation. Given the general affluence of the community, substandard housing is not a significant issue. However, when there is a report of a substandard housing concern, the issue is readily addressed and resolved by the City's Code Enforcement Officer. …
Other Relevant Factors: While the
element includes some general
background on exclusionary
practices, it should relate these
situations to the City and
complement data and mapping
with other relevant factors that
contribute to fair housing issues
in the City. For instance, the
element can analyze historical
More information has been provided regarding historical land use practices and policies p. 134 Redlining is the process used by lenders to restrict certain land areas from ownership by Black residents primarily, but also by Black, indigenous and people of color (BIPOC) generally. Although currently illegal, redlining was historically practiced throughout the Bay Area, including in San Mateo County. Specifically, it was a federally backed process that denied creditworthy applicants loans for housing in certain neighborhoods due to their ethnicity. The term was coined from the red or “hazardous” areas of cities that were deemed risky to invest in, due to their specific racial demographics.

Redlining led to cycles of disinvestment even after the Fair Housing Act of 1968, which officially banned redlining.

Local realtors report that such redlining practices were limited to cities of over 40,000 in population. Although few cities in San Mateo County were that size when redlining was rampant (notably Redwood City, San Mateo and Daly City may have been large enough), there were plenty of other ways in which cities could restrict who lived where. For example, a real estate appraiser could mention that a certain house being considered for a mortgage was in an area of “hazard” (code for non-white areas), which had the same impact as redlining.

8.b
January 23, 2023 Packet Pg. 1261

EXHIBIT B
Findings Responding to Letter from Department of Housing and Community Development Dated January 6, 2023 land use; zoning and barriers to
housing choices; investment
practices; seeking investment or
lack of seeking investment to
promote affordability and
inclusion; information about
redlining/greenlining, restrictive
covenants and other
discriminatory practices; land use
related lawsuits; local land use
initiatives; demographic trends,
or other information that
complements the state and
federal data.

A new section has been added summarizing other relevant factors impacting fair housing p. 213-21 Other Relevant Factors
Early attempts to develop San Carlos began in the late 1800s. These early efforts were generally not successful until 1917, when the Mercantile Trust Company hired Fred Hugh Drake, a prominent real estate and business promoter to oversee the development of the city. Drake expanded infrastructure, established a chamber of commerce, encouraged the development of housing and gave the city the motto “The City of Good Living.”
The Devonshire Hills subdivision was one of the first neighborhoods in San Carlos and was established by Drake in 1924, one year before the City’s incorporation in 1925. This subdivision used principles from the Garden City urban planning movement, establishing dog-leg cul-desacs and pass-through walkways.

Commercial development followed soon after the establishment of residential neighborhoods. Support businesses, such as gas stations, grocery stores and a pharmacy were established by 1926 along El Camino Real. Industrial activity also came to San Carlos at this time when Fred Hugh Drake helped to bring about a Southern Pacific spur track between San Francisco and Sunnyvale. This rail connection led to the creation of the city’s first industrial area, located east of the railroad.

After World War II, the population in San Carlos rapidly expanded, especially after the establishment of the Dalmo Victor and Eitel McCullough electronics plants in 1944. The population quadrupled between 1940 and 1950, largely due to the presence of these two electronics plants. The electronics industry grew and by 1958 it comprised a substantial portion of the industrial area.

Also in the late 1940s, the San Carlos Airport moved from its former location between Brittan and San Carlos Avenues to its present site, east of Highway 101. Additional residential development in areas east of El Camino Real and north and south of Holly Street also occurred at this time.

As the city grew in the 1950s, residential growth was focused in the western hills, above Arguello Park and west of both Alameda de las Pulgas and San Carlos Avenue. In 1956, the City annexed 500 acres west of the Alameda so that the area could be subdivided to provide an additional 1,300 homes, including apartments. In the East Side of San Carlos, growth in the service, supply and electronics industries fueled the City’s economic development. More

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EXHIBIT B
Findings Responding to Letter from Department of Housing and Community Development Dated January 6, 2023 recently, high-tech and biotechnology firms have contributed to economic growth and transformation in San Carlos. A more recent trend (within the past 20 years) has been the redevelopment of infill parcels with mixeduse and multi-family family housing in areas near Downtown and the El Camino Real transit corridor.

The City’s historic zoning regulations have resulted in a community where the vast majority of residential units are single-family detached units (72 percent), with only 28 percent multi-family housing. However, multi-family housing is the fastest growing housing type in San Carlos. Between 2010 and 2020, multi-family housing units increased more rapidly than single-family units, with single-family detached units increasing by only one percent while single-family attached (townhomes) increased by two percent, small multi-family housing complexes (2-4 units) increased by three precent, and multi-family units (5+ units) increased by 10 percent over the same period. The percentage of multifamily housing units is expected to continue to increase due to infill development.

Like most communities throughout California, San Carlos’s historical policies, zoning, and investment strategies did not prioritize affordable housing. Today, the San Carlos City Council values diversity in our community and recognizes that the housing crisis is a barrier that must be overcome to ensure the community remains diverse and thriving. The Council established a number of strategic objectives addressing affordable housing and diversity. To begin overcoming the housing crisis, we all need to understand the forces driving the rise in housing prices, examine the San Carlos housing market, and recognize the persistent need for more affordable housing.

Contributing Factors to Fair
Housing Issues: The currently
listed contributed factors do not
appear significantly related to the
assessment of fair housing. For
example, the element notes the
City as a whole is highest
resource, highest median income,
a concentrated area of affluence
The contributing factors have been updated to provide a clearer connection to the AFFH analysis p. 214-215 As such, the following issues of concern, priority contributing factors, and actions are established:

Insufficient and Inaccessible Housing Options in High Opportunity AreaCitywide The County’s 2020 AI and the Fair Housing Assessment found there was a need to expand access to opportunity for people who identify with any protected classes. The analysis described in this chapter also found that the City as a whole is highest resource, high median income, and a concentrated area of affluence, which lacks affordable housing options. Contributing factors affecting the lack of sufficient and accessible housing options housing choices and affordability in high opportunity areas include: the City include:
• Location and type of affordable housing [High]

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EXHIBIT B
Findings Responding to Letter from Department of Housing and Community Development Dated January 6, 2023 and does not have publicly
assisted housing. Yet, the element
does not identify the lack of
housing choices and affordability
as a contributing factor to fair
housing issues. Based on the
outcomes of a complete analysis,
the element should re-assess
contributing factors and prioritize
those factors then formulate
appropriate policies and
programs.
• Lack of access to opportunity due to high housing cost [High] • Lack of fair housing outreach and enforcement [High]
• Availability of affordable housing [High]
• Availability of affordable units in a range of sizes [High] The City of San Carlos is nearly entirely an area of opportunity. In order to address historic growth patterns and allow additional access to areas of opportunity for people of color and other protected classes, the City identified a multi-faceted approach to provide additional opportunities. The Housing Plan contains multiple13 program actions specifically targeted to encourage and facilitate housing mobility and the development of affordable housing units in the city, including a significant upzoning of higher density neighborhoods and corridors. This effort will increase the number of affordable housing units thereby alleviating the lack of housing choice and affordability. These programs include the following:

ACTION HOU-3.1: Funding Low-, Very Low-, and Extremely Low- Income; and Special Needs Housing. • Continue to apply the commercial/housing linkage fee to fund affordable housing. Identify ways to encourage on- or off-site production of affordable housing, in lieu of fee payment.
• Collaborate with existing and new major employers to encourage the development of more affordable housing to balance the jobs:housing ratio. • Monitor and pursue funding for housing that meets the needs of low-, very low-, and extremely low- income households. Monitoring of funding availability will be done on an ongoing basis through coordination with 21 Elements and by City staff. • Offer financial and technical assistance for housing development projects for persons with special needs. • Continue to apply the commercial/housing linkage fee to fund affordable housing and monitor fee amount to ensure it reflects market conditions.

Encourage concurrent production of on or off-site affordable housing, in lieu of fee payment. Collaborate with existing and new major employers to encourage the development and funding of more affordable housing. • Offer financial and technical assistance for housing development projects for persons with special needs. • As part of the Housing Element Annual Progress Report, track and report the number of new affordable housing units providing a preference for people with special needs, including seniors, homeless, people with developmental disabilities, etc. that are added to the housing stock each year. • Monitor and pursue county, state, and federal funding programs and sources for the creation of affordable housing. Prioritize available housing funding to assist in the development of housing affordable to extremely low-income households and other special needs populations. Conduct annual proactive outreach to identify development opportunities and funding and incentives for special needs housing.

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EXHIBIT B
Findings Responding to Letter from Department of Housing and Community Development Dated January 6, 2023 • Proactively contact non-profit service providers and developers for persons with disabilities and other special needs groups and notify them about funding opportunities, as they become available.
• Continue to consult with the San Mateo County Center on Homelessness to further align efforts and coordinate homeless services.

ACTION HOU-3.2: Below Market Rate (BMR) Ordinance.
• Continue to implement the City’s Below Market Rate (BMR) Ordinance requirements for rental and ownership development. • Establish a process for granting priority permit processing status for approved housing projects that exceed the City’s minimum BMR requirement. • Evaluate the BMR Ordinance’s density bonuses, incentives, and concessions to determine they continue to make the production of affordable housing feasible. As part of this process, consult with local non-profit affordable housing developers to identify potential revisions that would better support development of affordable housing, and especially Low-Income Housing Tax Credit financed housing. Revise as necessary.

ACTION HOU-3.3: Accessory Dwelling Units Construction Facilitation. • Support the development of 203 accessory dwelling units during the planning period and as new State laws modify accessory dwelling unit requirements, update the City’s ordinance to comply. The City last updated its ADU ordinance in August 2022. The City will draft amendments to address laws passed in 2022, including AB 2221 and SB 897 to reflect an up-to-date ordinance compliant with Government Code Section 65852.2 • Collaborate with surrounding jurisdictions through the 21 Elements working group to determine best approach for tracking affordability throughout the planning period.
• Encourage the legalization of unpermitted accessory dwelling units to better ensure that they are safe and habitable. As sunset date of Section

18.23.210(H) approaches, consider an extension, based on history of use of this provision and anticipated ongoing need. • Work with 21 Elements to identify potential funding sources for ADU construction and offer pre-approved construction plans. • Review and as new information is available, update public education materials on accessory dwelling units, including planning and building requirements, streamline processing, funding possibilities, and other resources. • Encourage local agencies, districts, and utility providers to reduce hook-up or other fees to facilitate the development of accessory dwelling units. • Prioritize ADU applications to be consistent with Government Code Section 65852.2(a)(3) requirements for approval/denial within 60 days from the date a completed application is received.

ACTION HOU-3.4: First-time Homebuyer Programs. Direct prospective first-time homebuyers to HEART or other County programs intended for first time homebuyers. Encourage the use of these programs though outreach and education. Maintain and provide information on local BMR ownership units that are resold.

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EXHIBIT B
Findings Responding to Letter from Department of Housing and Community Development Dated January 6, 2023 ACTION HOU-3.5: Rental Voucher Program.
• Continue to implement the BMR ordinance, which specifies Housing Choice Voucher (Section 8) eligibility in the BMR program. • Continue to work with the San Mateo County Department of Housing and nonprofit organizations to implement Housing Choice Voucher Rental Assistance programs. Continue to provide information on the Housing Choice Voucher program, including new legal requirements pursuant to SB 329, which prohibits housing discrimination on the basis of source of income (including Housing Choice Vouchers). • Continue to work with 21 Elements, other regional organizations, and/or nonprofit organizations to evaluate and quantify potential discrimination against Housing Choice Voucher users or other rental assistance voucher programs. Continue to develop and act upon measures to address these issues.

ACTION HOU-3.9: Development on Nonvacant Sites. Promote residential development on nonvacant sites by:
• Targeting nonvacant sites identified in the Housing Element as priorities for fund allocation as funds are available. • Building on outreach conducted during the Housing Element update, continue to proactively outreach to property owners with a survey on how the city can support redevelopment/new housing efforts.

ACTION HOU-3.11: Access to Opportunity. Noting historical inequities amplified/perpetuated by single family zoning, encourage small units in residential neighborhoods through development of ADUs, JADUs, and SB 9 units. • See Action HOU-3.3 for specific measures to incentivize ADUs in San Carlos. • Review the City’s Zoning Ordinance and Subdivision Ordinance and implement updatesamend as needed to provide clarity and facilitate housing development under SB 9 in compliance with State law. These include adopting updated definitions, use regulations, development standards, and ministerial processes based on the outcome of a complete SB 9 analysis. As revisions to State law occur in the future, update the City’s Zoning Ordinance and Subdivision Ordinance accordingly.

ACTION HOU-3.12: Reduce Costs Associated With The Development Of Affordable and Special Needs Housing. The City defers and waives fees for affordable housing developments to provide local match contributions and facilitate projects. The City will continue to rReduce or waive development impact fees to facilitate 100% affordable and special needs housing, including housing for extremely low-income and persons living with disabilities (including persons with developmental disabilities).

ACTION HOU-4.1 Adequate Sites to Meet Regional Fair Share of Housing Growth.

The City will:
• Continue to provide appropriate land use designations and zoning districts consistent with regional housing needs for mixed-use and infill development near transit and other amenities.
• Maintain an inventory of potential sites to provide to developers in conjunction with information on development incentives for affordable units. • As part of the Housing Element annual reporting process, evaluate project development against the sites inventory to ensure compliance with Government Code Section 65863.

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EXHIBIT B
Findings Responding to Letter from Department of Housing and Community Development Dated January 6, 2023 • Continue to pursue implementation of the General Plan through completion and adoption of implementing zoning regulations and specific plans. • Encourage senior housing and housing suitable for persons with disabilities and other special needs (including assisted living). See Action HOU3.1 for specific commitments to encourage senior and other special needs housing.

ACTION HOU-4.2: Zoning Ordinance Revisions. Enact the following zoning changes:
1) Create new zones; increase density, FAR, heights, number of stories; and provide minimum densities as shown in Table 4.2-1. 2) Continue to allow ground floor residential uses in the MU-D-100, MU-SC-120, and MU-SB-100 zones. Evaluate, as part of the new Downtown Specific Plan process, additional areas (on side streets and outside of the Downtown Core) where ground-floor residential uses may also be allowed. 3) Remove minimum private open space requirement for residential in Mixed Use and Multi-unit zoning districts (retaining only the common/public open space requirement).
4) For residential only development, remove additional required setbacks (i.e., removing requirement to follow RM-59 zoning setbacks) in Mixed Use zones.
5) Remove guest parking in all RM and Mixed-Use zones.

Table 4.4-5: Proposed Changes to Zoning Densities and Heights (2023) Zone
Maximum Density
(du/ac)
Minimum Density
(du/ac)2
FAR
Building Height (feet)
Building Stories
(stories)
Existing Proposed Existing Proposed Existing Proposed Existing Proposed Existing Proposed Proposed Existing Proposed MU-N MU-N-40 20 40 n/a 30 2.0 2.5 50 4 4
(1)
MU-N MU-N-50 20 50 n/a 38 2.0 2.5 50 4 4
MU-N MU-N120 20 120 n/a 90 2.0 3.0 75 4 6
MU-DC MU-DC10050 100 n/a 75 2.5 2.5 50 4 4
MU-D MU-D10050 100 n/a 75 2.5 3.0 60 4 5
MU-D MU-D12050 120 n/a 90 2.5 3.0 75 4 6
MU-SC MU-SC12059 120 n/a 90 3.0 3.0
50; 30
along
East San
Carlos
Avenue
in MU-N
District
30 within
40 ft of
an RS
district 75
35 along
East San
Carlos
Avenue
in MU-N
District
35 within
40 ft of
an RS
district 4 6

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EXHIBIT B
Findings Responding to Letter from Department of Housing and Community Development Dated January 6, 2023 MU-NB MU-NB12050 120 n/a 90 2.5 3.0 75 4 6
MU-SB MU-SB10050 100 n/a 75 2.5 3.0 60 4 5
MU-SB MU-SB12050 120 n/a 90 2.5 3.0
40 within
50 ft of
an RS
district 75
40 within
50 ft of
an RS
district
4 6
RM-20 RM-20 20 20 n/a 15 0.75 0.75 35 35 3 3
RM-59 RM-59 59 59 n/a 45 2.0 2.0 50 50 4 4
-- RM-100 n/a 100 n/a 75 N/A 3.0 n/a 60 n/a 5
(1) 3 stories along E. San Carlos Ave. in MU-N-40 district (2) The City of San Carlos Zoning Ordinance does not have a minimum density requirement; with this update, a minimum density threshold is proposed.

ACTION HOU-4.3: Outreach: New Development Standards. Prepare, publicize, and provide applicants and developers with materials highlighting the City’s revised zoning standards (Action HOU-4.2) intended to encourage the production of housing at all income levels.

ACTION HOU-4.34: Objectivity and Streamlining in Development Regulations. Reduce the cost of building housing through, streamlining and clear and objective standards in development regulations.
• Review the Zoning Ordinance and craft revisions that support objective design standards consistent with the Housing Accountability Act. Adoption of objective design standards will facilitate high-quality residential development and compliance with State objectives. • Revisit the Design Review Criteria criteria and findings to provide local guidance on design and standards for by-right projects as allowed by state law, removing subjectivity from findings and approval processes. • Revise the Conditional Use Permit findings for any special residential uses that require a CUP but are also covered by the Housing Accountability Act to be fully objective and to provide local guidance on design and standards for by-right projects as allowed by state law, removing subjectivity from findings and approval processes.
• Reduce the permitting time for residential projects (especially 100% affordable projects) through consideration of by-right approvals, reduced number of hearings, and objective design standards.

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EXHIBIT B
Findings Responding to Letter from Department of Housing and Community Development Dated January 6, 2023 • To accommodate future SB 35 applications and inquiries, create and make available an informational packet that explains SB 35 streamlining provisions in San Carlos and provides SB 35 eligibility information.

ACTION HOU-5.8: Furthering Integration. Promote fair housing by allowing multi-family residential uses on all sites in the P (Institutional Use) zone as an accessory use to allowed uses such as onsite religious institutions and schools. Reference/incorporate the minimum parking prohibitions associated with AB 2097, effective January 1, 2023, within 0.5 miles of public transit (as defined in AB 2097).

Protecting Existing Residents from Displacement
San Carlos has become a town that is largely affluent and has limited existing affordable housing. As of 2021, the city is mostly experiencing stages of advanced exclusion, as a result of rapidly increasing housing costs. Efforts listed above to provide more affordable housing in San Carlos are intended to increase access to opportunity. The analysis found no Census tracts in the city with concentrations of households vulnerable to displacement. However, households that are most vulnerable to displacement are where more rental housing is located. Overpayment by renters is identified in areas north of U.S. 101 and in the southeastern portion of the city. Contributing factors affecting potential displacement include:
• Displacement of residents due to economic pressures [Moderate] • Availability of affordable housing [High]
• Availability of affordable units in a range of sizes [Moderate] In order to address the potential displacement of existing lower income households, the City identified 12 program actions to provide additional housing opportunities and further encourage more affordable housing in the community, as described above. The Housing Plan also contains Program HOU-3.10 specifically targeted to identify anti-displacement strategies for San Carlos:

ACTION HOU-3.10: Anti-Displacement Strategies. EThe City will take the following actions to reduce displacement risk due to discriminatory actions:
• Fair Housing Counseling. Ensure all tenants have access to legal counseling, and landlords are aware of their rights and responsibilities. Support coordination of biannual workshops for landlords and property managers on discriminatory practices, reasonable accommodation requirements, and resources and an annual presentation to staff on fair housing practices, beginning in 2023. • Rental Audits. Provide support to fair housing providers to continue to conduct annual audits of housing providers to ensure compliance with fair housing laws.
• Fair Housing Case Monitoring. In 2027, upon completion of 2 iterations of biannual landlord and property manager workshops and 4 consecutive

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EXHIBIT B
Findings Responding to Letter from Department of Housing and Community Development Dated January 6, 2023 rental audits, meet with local fair housing providers, including Project Sentinel, to assess effectiveness of fair housing programs and identify additional strategies if needed.
• Fair Housing Outreach Program. Include information or links to information on the City’s website in 2023 (with annual updates) and provide printed informational materials in City buildings with information on the fair housing counseling program, tenant protections, and other resources to reduce displacement risk.
• Additional Strategies. Based on the above efforts, if additional strategies are required, conduct a study to explore implementing Additional tenant protection policies and support local efforts to create a community land trust or a housing preservation fund xplore the following strategies to minimize resident displacement:

Tenant protection policies
Support local efforts to create a community land trust or a housing preservation fund Access and Inclusion for Persons with Disabilities
In San Mateo County, the most common fair housing complaint cited disability status as the bias (56 percent of complaints). Contributing factors affecting access and inclusion for persons with disabilities include:
• Lack of supportive services for persons with disabilities [Moderate] • Lack of access to resources, such as schools, transportation, and other in-home or community resources, for persons with disabilities [Low] In 2011, the City adopted a Reasonable Accommodation Ordinance to provide persons with disabilities equal access to housing opportunities. The City identified six implementation programs in the Housing Plan to increase services, housing, and support for persons with disabilities, including:

ACTION HOU-5.2: Large Rental Units and Supportive Services. Discuss with developers the ability to provide larger rental units appropriate for families with children, including the provision of supportive services.

ACTION HOU-5.3: Residential Care Facilities and Group Homes. San Carlos encourages the development of residential care facilities and group homes.

Consistent with State law, the City permits group homes with six or fewer residents in all residential zoning districts by right. • Amend the Zoning Ordinance code to allow group homes with seven or more residents as a permitted use in all zones that allow multi-unit or single-unit dwellings.
• Facilitate discussions with neighborhoods and adjacent uses so that good neighbor relationships are fostered and impacts to adjacent uses are mitigated.
• Seek opportunities to assist nonprofit housing providers to acquire and/or rehabilitate residential housing for group homes.

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EXHIBIT B
Findings Responding to Letter from Department of Housing and Community Development Dated January 6, 2023 • Review and modify development standards for residential care facilities and group homes to ensure the same standards apply for these uses as other residential uses of the same type in the same zone, specifically standards related to parking requirements and distancing between similar facilities. No additional parking shall be required for group residential and residential care facilities above what is required for residential uses.

Remove any subjectivity in any standards or required findings to ensure residential care facilities and group homes are allowed objectively with approval certainty similar to other residential uses.

ACTION HOU-5.4: Special Needs Service Providers Contributions. • On an annual basis, provide financial contributions to non-profit organizations and outside agencies that serve the housing needs of special needs households in and around San Carlos. These organizations and agencies may include but are not limited to: The Center for Independence of the Disabled (CID), HIP Housing, Shelter Network, Samaritan House, CALL Primrose, San Mateo County Children’s Fund, and HEART, among others. • Evaluate City contributions to outside agencies to assess whether to continue funding and/or adjust funding amounts or to consider other agencies for funding, particularly those organizations and agencies that provide housing with support services for persons with disabilities. As part of the evaluation, require outside agencies receiving City contributions to submit annual reports detailing how funds have been used and how programs have benefited San Carlos residents.

ACTION HOU-5.5: Revised Development Standards to Support Special Needs Housing. • Consider amending the Zoning Ordinance to clarify that development standards that allow for separate cooking and/or bathroom facilities in home sharing programs, and universal design (including “visitability”) in all new residential development and significant remodeling projects. • Encourage the development of well-designed new accessory dwelling units in existing neighborhoods by implementing objective standards for the approval of accessory units. Include an ADA accessible design option in pre-approved ADU plans. • Encourage unhoused service or navigation centers to be located within or near SROs, transitional, and or/supportive housing. • Review the Zoning Ordinance and identify amendments to ensure findings for reasonable accommodation requests are limited to health and safety considerations and those allowed by State law.

ACTION HOU-5.6: Equal Access to City Services. Adopt an accessibility policy establishing standards and procedures for providing equal access to City services and programs to all residents, including persons with limited proficiency in English, and persons with disabilities.

ACTION HOU-5.7: Community Governance. Conduct public meetings at suitable times, accessible to persons with disabilities, and near public transit.

Resources will be invested to provide interpretation and translation services when requested at public meetings.

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EXHIBIT B
Findings Responding to Letter from Department of Housing and Community Development Dated January 6, 2023 In addition, Housing Action HOU-6.1 outlines the City’s Fair Housing Plan. The City has identified multiple actions to implement that will increase affordable housing in the community, curtail displacement, and provide opportunities for special needs households, achieving multiple goals and simultaneously affirmatively furthering fair housing. See page 35 37 for more information.

2. Include an analysis of population and employment trends and documentation of projections and a quantification of the locality's existing and projected needs for all income levels, including extremely low-income households. (Gov. Code, § 65583, subd. (a)(1).) Include an analysis and documentation of household characteristics, including level of payment compared to ability to pay, housing characteristics, including overcrowding, and housing stock condition. (Gov. Code, § 65583, subd. (a)(2).)
Analyze any special housing needs such as elderly; persons with disabilities, including a developmental disability; large families; farmworkers; families with female heads of households; and families and persons in need of emergency shelter. (Gov. Code, § 65583, subd. (a)(7).) Extremely Low-Income (ELI)
Households: While the element
quantifies existing and projected
ELI households, it must also analyze
their housing needs.

The analysis of ELI housing needs
should consider tenure,
overpayment, overcrowding,
resources and the effectiveness of
strategies and the magnitude of
housing need.

The following analysis has been added further discussing ELI housing needs, including tenure, overpayment, overcrowding, resources and the effectiveness of strategies and the magnitude of housing need (p. 41 to 43):

The number and percentage of residents within each of these categories is listed in Table 4.3-4. In San Carlos, above moderate-income households represent the largest share of all households (52 percent) and low-income households comprise the second largest category (11 percent). Moderate-, very low-, and extremely low-income households comprise 8 percent each of all households. Renters tend to be from lower-income households. Nearly half (45 percent) of renter households are in the lower income categories (0-80 percent AMI) versus just; 20 percent of owners are lower income.

Extremely Low-Income Households
Households and individuals with extremely low incomes may experience the greatest challenges in finding suitable, affordable housing. Extremely lowincome households often have a combination of housing challenges related to income, credit status, disability or mobility status, family size, household characteristics, supportive service needs, or a lack of affordable housing opportunities. These households typically include seniors on Social Security, individuals with disabilities, single parents, and low-wage workers. Some extremely low-income individuals and households are homeless. Many extremely low-income households seek rental housing and most likely face overpayment, overcrowding, or substandard housing conditions. Some extremely low-income households could have members with mental or other disabilities and special needs. Extremely low-income households generally have the highest incidence of housing problems and tend to overpay for housing (paying 30 percent or more of their monthly income toward housing costs). Households that earn 30 percent or less than the county’s median income (up to $55,900 for a family of four in 2022) are considered “extremely low-income.”

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EXHIBIT B
Findings Responding to Letter from Department of Housing and Community Development Dated January 6, 2023 HUD’s 2013-2017 CHAS data set provides information on households by income group for the City of San Carlos. According to the CHAS data, in 2017, approximately 900 households (eight percent of total households) in San Carlos earned extremely low incomes (see Table 4.3-5). Of the extremely lowincome households, 66 percent were owner-occupied, and 44 percent were renter-occupied households, or 4.4 percent and 3.5 percent, respectively, of all households.

Table 4.3-5: Extremely Low-Income Households
Households Number
Percent of
Total
Households
Total occupied units (households) 11,327 100%
Total lower income (0-80% AMI) 3,055 27%
Extremely low income (0-30% AMI)
households
900 8%
Extremely low-income renters 400 3.5%
Extremely low-income owners 500 4.4%
Lower income households paying more than
50%
1180 10%
Extremely Low Income paying more than
50%
580 5%
ELI Renter HH severely overpaying 260 2%
ELI Owner HH severely overpaying 325 3%
Lower income households paying more than
30%
2040 18%
Extremely Low Income paying more than
30%
695 6%

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EXHIBIT B
Findings Responding to Letter from Department of Housing and Community Development Dated January 6, 2023 To address the needs of extremely low-income housing, the City has included Program Actions HOU-3.1, HOU-3.12, and HOU-8.1. Additionally, the City permits single-room occupancy units, in compliance with Government Code Section 65583(c)(1).

Overpayment: While the element
quantifies the number of
households overpaying, it must
also provide an analysis of their
housing needs.

The following has been added analyzing the housing needs of cost-burdened households (p. 44):

Housing Overpayment
State and federal standards specify that households spending more than 30 percent of gross annual income on housing experience a housing cost burden. Housing cost burdens occur when housing costs increase faster than household income. When a household spends more than 30 percent of its income on housing costs, it has less disposable income for other necessities such as health care, childcare, and food. Housing overpayment and overcrowding most often occur when a household cannot afford suitably sized and priced rental and ownership housing. In other cases, life changes (retirement, children moving back home, loss of job, etc.) can also cause housing problems. In these situations, a household can choose to either overpay for housing or double up with others into too small a unit in order to afford housing, which can result in overcrowding. In San Carlos, 28 percent of all households are overpaying for housing. Overpayment (also known as cost burden) is more prevalent in renter households than owner households; 38 percent of renter households are cost burdened versus 24 percent of owner households. However, because the average income San Carlos is significantly higher than other places in the state, overpayment among higher income households (especially homeowners) leaves a significant amount of money for other essential needs and is not an identified concern.

On the other hand, iIn the event of unexpected circumstances such as loss of employment or health problems, lower-income households with a housing cost burden are more likely to become homeless or double up with other households. In San Carlos, In San Carlos, 28 percent of households are overpaying for housing. overpaymentThe situation is much starker for lower income households, where 67 percent are overpaying for housing. Of these lower income households, extremely low-income households have the most prevalence of overpayment (77 percent), followed by very low-income households (73 percent), and low-income households (54 percent). Almost three-quarters (73 percent) of lower income renters are overpaying for housing, and 61 percent of lower income owners are overpaying for housing.

Farmworkers: The element must
quantify and analyze the number of
permanent and seasonal
farmworkers within the County and
analyze their special housing
needs. For a complete analysis of
this population group, the element
should discuss challenges this
The following has been added to include County data for permanent and seasonal farmworkers, specific housing needs of farmworkers. The analysis also discusses housing challenges they face and the available resources and strategies to provide more housing accessible to farmworkers (p. 56-57):

Farmworkers
Due to the high cost of housing and low wages, a significant number of migrant farm workers have difficulty finding affordable, safe, and sanitary housing. In San Carlos, 15 residents work in agriculture, forestry, fishing and hunting, and mining occupations, and can be assumed to be farmworkers.

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EXHIBIT B
Findings Responding to Letter from Department of Housing and Community Development Dated January 6, 2023 population faces, the existing
resources to meet those needs, an
assessment of any gaps in
resources, and proposed policies,
programs, and funding to help
address those gaps.

This represents only 0.09 percent of the workforce. Maps from the State of California Department of Conservation Farmland Mapping and Monitoring Program show no farmland in San Carlos.

The United States Department of Agriculture periodically completes a census of farms and their characteristics. The most recent data (2017) provides an overview of farm operations in San Mateo County.
• There are 241 farm operations with hired workers in San Mateo County. • Two thirds (67.22 percent) of these farms are owned by individuals or families, while 17.43 percent are owned by corporations. • A total of 1,321 farmworkers were estimated to live and work in San Mateo County, including 978 permanent workers and 343 seasonal workers. • The vast majority (88.38 percent) of farm operations have access to internet. • In 2017, 58.52 percent of all hired farm workers were working less than 150 days, while 41.48 percent of all farm workers worked more than 150 days out of the year.
• The average age of a farm producer in San Mateo County in 2017 was 59 years of age.

Farmworkers in San Carlos are actually more similar to very low or extremely low-income households than traditional migrant workers. This is because today’s farmworkers are more settled and typically live in one location, rather than following the crops. As noted above, almost 75 percent of farmworkers in San Mateo County are permanent workers. They are also more likely to have families and are looking for schools, employment for a spouse/partner, and a location to live in that provides a community. Because of this, they will benefit from the existing and proposed affordable housing program and actions in San Carlos. Due to the low number of agricultural workers in the city, the housing needs of migrant and/or farm worker housing need can be met through general affordable housing programs.

Throughout the county, the housing needs of farmworkers can be supported with additional affordable housing. The State and Community Development Department administers more than 20 programs that award loans and grants to local public agencies, private non-profit and for-profit housing developers, and service providers every year. This money supports the construction, acquisition, rehabilitation and preservation of affordable rental and ownership housing, childcare facilities, homeless shelter and transitional housing, public facilities and infrastructure, and the development of jobs for low-income workers. Many of these programs and funding sources can be utilized to provide housing for farmworkers.

3. An inventory of land suitable and available for residential development, including vacant sites and sites having realistic and demonstrated potential for redevelopment during the planning period to meet the locality’s housing need for a designated income level, and an analysis of the relationship of zoning and public facilities and services to these sites. (Gov. Code, § 65583, subd. (a)(3).)
Progress Toward the Regional
Housing Need Allocation (RHNA):

The City’s RHNA may be reduced by
the number of new units built,
Additional information is included analyzing the likelihood the proposed projects will be built during the planning period. P.106-107 The City’s development trends provide additional assurance regarding the likelihood of redevelopment. The City has seen a significant increase in housing development over the past decade, with projects both large and small. With the upcoming increase in allowable density associated with the

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January 23, 2023 Packet Pg. 1275

EXHIBIT B
Findings Responding to Letter from Department of Housing and Community Development Dated January 6, 2023 approved, or pending since June
30, 2022; however, the element
must demonstrate their
affordability and availability in the
planning period. The availability or
likelihood the units will be built in
the planning period should account
for any barriers to development,
phasing, anticipated buildout
horizons, market conditions, and
other relevant factors.

The analysis should also specifically
clarify that the units counting
toward meeting the RHNA have not
completed construction prior to
June 30, 2022.

Zoning Ordinance amendment (Action HOU-4.2), the City anticipates demand to continue to increase. With regard to smaller projects, very few projects “drop out” of the development process without being constructed. In general, nearly all small projects proposed have developed. Those few small projects that are not completed have less experienced developers or are owner builders, and when construction costs are realized, the applicant withdraws. With regard to large projects, the vast majority of these types of projects, when they are at a formal application or approval phase (like the projects in Table 4.5-2) come to fruition. For example, of the four projects listed with Planning Approval in Table 4.5-2, all are moving forward. One is under construction as of January 2023 (782 Elm), one is for sale with the entitlements included (626 Walnut) by a developer who has multiple other active projects in San Carlos, one is requesting a condominium map, which will result in activating the requirement for on-site affordable housing (1257 Magnolia), and one has building permit approval and partial fees paid (616 Cedar). All proposed projects in Table 4.5-2 are moving forward as well.

The units are expected to be available during the planning period. If any of any of the following units are not constructed, the site inventory reflects a generous surplus to ensure that adequate sites are available and the RHNA can be met. The City will continue to support housing development projects through technical assistance and will track progress toward the RHNA on these sites through Action HOU-3.7 (No Net Loss).

The analysis also now clarifies for each proposed project that construction has not been completed prior to June 30, 2022. P. 102 As of 2021, the City is in the process of reviewing applications and preliminary plans for over 350 new units in San Carlos (Table 4.5-2). These units have not completed construction prior to June 30, 2022.

Table 4.5-2 Approved and Proposed Projects
Project Project Status
Extremely/
Very LowIncome (0-
50% AMI)
LowIncome
(50-
80%
AMI)
ModerateIncome
(80-120%
AMI)
Above
ModerateIncome
(+120%)
Total
626 Walnut Planning Approval 0 3 1 35 39
782 Elm Planning Approval 0 0 0 4 4
1257 Magnolia Planning Approval 0 0 0 9 9
616 Cedar Planning Approval 0 0 0 4 4
560 El Camino Real Under Construction (2023) 0 1 2 21 24

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January 23, 2023 Packet Pg. 1276

EXHIBIT B
Findings Responding to Letter from Department of Housing and Community Development Dated January 6, 2023 1525 San Carlos Ave Under Construction (2023) 0 1 2 15 18 1240 El Camino Real Under Construction (2023) 0 0 1 7 8 1232 Cherry City Project/Design Phase 0 35 0 0 35
155-160 Vista Del Grande Submitted/Under Review 0 11 0 78 89 308 Phelps Submitted/Under Review 1 2 1 10 14
808 Alameda de las Pulgas Submitted/Under Review 0 10 0 77 87 1360 Cherry Submitted/Under Review 0 0 0 6 6
1383 Laurel Submitted/Under Review 2 0 0 13 15
Total 3 63 7 279 352
Remaining RHNA 736 362 431 854 2,383
All approved and proposed projects are either approved, proposed, or under construction as of 2023. None of these projects have completed construction prior to June 30, 2022.

Realistic Capacity: While the
element provides assumptions of
buildout for sites included in the
inventory, it must also provide
support for these assumptions. For
example, the element should
demonstrate what specific trends,
factors, and other evidence led to
the assumptions. The estimate of
the number of units for each site
must be adjusted as necessary,
based on the land use controls and
More details been provided for the buildout of residential zoned sites included in the inventory on p. 110 The Housing Element sites inventory surveyed large-scale residential and mixed-use development projects approved since 2015 to develop estimates related to potential development. Combined, all approved residential and mixed-use projects since 2015 had an average density of 86 percent of the maximum allowable density (Table 4.5-4). Residential zones had a lower average, of 53 percent of allowed capacity. Two significant initiatives are anticipated to revise the trend in residential zoning districts which resulted in production of housing that was less than the maximum allowable density.

First, previously, the City’s Below Market Rate Ordinance required compliance for all residential developments of seven or more units. For mid-sized projects where the maximum allowed densities would result in between seven units to approximately 12 units, most developers (estimated at 90 percent) were opting to stay below seven units, providing six units instead and sometimes substantially below density (but with much larger units). In 2022, the City updated the BMR Ordinance to lower the threshold for constructing affordable units from a minimum of seven units to a minimum of five units for all ownership projects; the threshold for rental projects remains at seven units. Second, Action HOU-4.2 implements Zoning Ordinance amendments which will include not only an increase in density for higher density residential neighborhoods and mixed-use areas, but also will institute

8.b
January 23, 2023 Packet Pg. 1277

EXHIBIT B
Findings Responding to Letter from Department of Housing and Community Development Dated January 6, 2023 site improvements, typical
densities of existing or approved
residential developments at a
similar affordability level in that
jurisdiction, and on the current or
planned availability and
accessibility of sufficient water,
sewer, and dry utilities.

The element also should analyze
the likelihood that the identified
units will be developed as noted in
the inventory in zones that allow
100 percent nonresidential uses
(e.g., mixed-use). This analysis
should consider the likelihood of
100 percent nonresidential
development, performance
standards, and development trends
supporting residential
development.

While the element assumes a
realistic capacity assumption of 85
percent maximum buildout in
mixed-use zones, it must include an
analysis to support these
assumptions including project
examples with similar affordability
levels, as well as a description of
whether 100 percent commercial
a new minimum density requirement (approximately 75 percent of maximum density) to ensure anticipated housing densities are achieved. As such, to provide a conservative estimate of realistic capacity for the sites inventory, minimum densities are used to calculate realistic capacity in the RM-59 and RM-100 zones. Due to the already low intensity of single-family zones, maximum density is used to calculate realistic capacity in the RS-3 and RS-6 zones.

Action HOU-3.8 is included in the Housing Plan requiring the replacement of units affordable to the same or lower income level as a condition of any development on a nonvacant site consistent with those requirements set forth in Government Code section 65915(c)(3). These assumptions are considered realistic and based on trends, evidence, and minimum density requirements.

Due to the predominantly built-out nature of San Carlos, most development occurs as infill development and replaces less intense uses. The scarcity of land makes higher-density development highly cost effective in the RM-59 and RM-100 zones. Recycling to higher intensity uses is expected to continue.

Even so, the City acknowledges that small lot development in residential areas may be more difficult and thus has only identified properties that have the potential for sufficient added capacity to make recycling of land economically feasible.

In the multifamily zones, 19 of the 26 24 parcels (73 79 percent) are currently developed with single family homes and the zoning allows for an increase in units that ranges from 600 800 percent to 2,600 500 percent. The calculations presented in Tables 4.5-7 and 4.5-8 do not include potential density bonus units. Many of the sites identified in the RM-59 and RM-100 zone offer opportunities for lot consolidation. For lower income sites identified to meet the lower income RHNA, consolidation is only assumed if the properties are under common ownership.

Residential Sites Inventory
State law requires that jurisdictions demonstrate in the Housing Element that the land inventory is adequate to accommodate that jurisdiction’s share of the region’s projected growth. As a fully built-out community, very little vacant land remains in the city. A total of 13.56 1 acres of vacant and underutilized parcels in residential zones were identified.

Combined, there is the potential to yield 368 new dwelling units on vacant and underutilized land in residential zones (Table 4.5-7). All but one site zoned for lower density (RS-3 and RS-6) are vacant. In the multifamily zones, 19 of the 24 parcels (79 percent) are currently developed with single family homes and the zoning allows for an increase in units that ranges from 800 percent to 2,500 percent.

Table 4.5-7: Vacant and Underutilized Residential Land
General Plan
Designation Zoning Density
# of
Parcels Acres
Potential Dwelling
Units
Affordability
Level*
Single Family - 3 RS-3 3 du/acre 3 4.1 13 Above Moderate Single Family - 6 RS-6 6 du/acre 108 4.410 2524 Above Moderate

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January 23, 2023 Packet Pg. 1278

EXHIBIT B
Findings Responding to Letter from Department of Housing and Community Development Dated January 6, 2023 or residential developments are
allowed in mixed-use zones.

In addition, the element could
analyze average development
buildout without including density
bonus units within the realistic
capacity calculation.

Multiple Family -
59 RM-59
45 to 59
du/acre
41 1.491 6749
Above Moderate/
Moderate/Very Low/Low
Multiple Family - 100 RM-100
75 to 100
du/acre
2023 3.59 263282
Above Moderate/
Moderate/Very Low
Total 3735 13.561 368
*Note: Based on state law (Government Code Government Code Section 65583.2(c)(3)), sites that allow development densities of at least 30 units per acre are credited toward the lower-income RHNA. Sites that can qualify for 100 percent affordable units based on the allowed density but do not meet the size parameters established by AB 1397 (0.5-10 acres) are split evenly between the moderate- and above moderate-income RHNA categories.

Additional analysis has been included analyzing the likelihood of non-residential development. p.116 To determine average densities, a review of all approved projects in mixed use zones since 2015 was conducted. Residential and mixed-use projects in Mixed Use Zones averaged 107 percent of the allowed capacity for the zone, due to extensive use of the State Density Bonus law. Even when analyzing the average development buildout without including density bonus units, projects in Mixed Use Zones averaged 92 percent of the allowed capacity for the zone (See Table 4.5-4.). To consider the potential for nonresidential development, the City reviewed all projects (residential and nonresidential) in mixed-use zones since 2015. During that time, 20 projects were developed (Table 4.5-6), of which three (15 percent) were nonresidential. The remaining 17 projects (85 percent) were residential or mixed-use. To provide a conservative estimate of realistic capacity for the sites inventory, an 85 percent multiplier is applied in mixed-use zones to account for the potential redevelopment with nonresidential uses.

Additional analysis has been included supporting the realistic capacity assumption of 85 percent on p.116-117 Of the fifteen mixed-use projects in Table 4.5-4, twelve (or 80 percent of mixed-use projects) had actual densities that exceeded 85 percent of maximum allowable density. Larger mixed-use projects were able to achieve the highest densities. Only three (of fifteen total mixed-use projects since 2015) had densities less than 85 percent of maximum allowable density. The average size of those projects was 6 units. In the inventory, 84 of 134 sites (parcels) or 63 percent had a realistic capacity higher than six units. In fact, the average size of mixed-use sites was 19 units.

These higher density trends are a result of the extensive use of density bonus provisions. In addition to the State’s density bonus law, the City has enacted a local density bonus program. The City’s zoning code (18.17.030) allows residential owner-occupied developments with one or more on-site below market rate units that are affordable to low-income households, or to a lower income category to be granted one additional unit for each unit

8.b
January 23, 2023 Packet Pg. 1279

EXHIBIT B
Findings Responding to Letter from Department of Housing and Community Development Dated January 6, 2023 affordable to low-income households or to a lower income category. Residential rental developments with one or more on-site below market rate units that are affordable to low-income households may be granted two additional units for each unit affordable to low-income households. Residential rental developments with one or more on-site below market rate units that are affordable to very low-income households, or to a lower income category, may be granted four additional units for each unit affordable to very low-income households or to a lower income category. More than half (60 percent or nine) mixed use projects in Table 4.5-4 include affordable (below market rate) units. Realistic capacity assumption in this Element do not reflect the potential use of density bonus programs but the availability of the state and local programs ensures that a high proportion of future development will reach actual densities higher than what is assumed in the inventory (85 percent of maximum). Based on the City’s strong history of mixed-use developments exceeding maximum allowable densities (and recent amendments to the City’s Below Market Rate Ordinance to reduce the threshold of compliance from seven units to five units for ownership product (the majority of projects), the use of 85 percent of maximum densities for mixed use sites is realistic, reasonable, and attainable.

Suitability of Nonvacant Sites: The
element identifies nonvacant sites
to accommodate the regional
housing need for households of all
incomes. A complete analysis
should describe the methodology
used to determine the additional
development potential within the
planning period. The methodology
must consider factors including the
extent to which existing uses may
impede additional residential
development, development trends,
market conditions, and regulatory
or other incentives or standards to
encourage additional residential
development on these sites. (Gov.

Code, § 65583.2, subd. (g).)
For sites with residential uses, the
inventory could also describe
More details on the sites methodology have been provided for the suitability of non-vacant sites to accommodate the RHNA. P.119-121 Site Selection
To identify additional sites with potential for new development or recycling opportunities, the following criteria were used:
• Parcel is currently vacant; or
• If parcel is not vacant:
o Property owner has expressed interest in redevelopment. In December 2022, the City surveyed property owners of sites included in the inventory as well as owners of potential sites not included. Several property owners indicated that they were not interested in redevelopment, and those sites have been removed from the inventory. As a result of the survey, several sites that had been previously identified as potential but not included as a site to meet the RHNA, were added to the inventory based on property owner interest. Overwhelmingly site owners showed varying degrees of interest and many inquired about the extent of residential development that could be allowed. …
Existing Uses on Non-Vacant Sites and Development of Non-Residential Uses Much of the City’s housing capacity is on sites with zoning that allows both residential and non-residential uses. It is difficult for the City to forecast how properties with zones that permit both stand-alone residential uses, mixed use with a residential component, and stand-alone non-residential uses, such as commercial or office, will develop. However, the City has seen significant numbers of development projects in the City that mirror many of the characteristics of development opportunities in the site inventory.

San Carlos is a primarily built out community. However, the City recognizes that it must provide opportunities for new residential uses throughout the City. The City has seen an increased interest in residential development in non-residential and mixed-use zoning districts due to the scarcity of

8.b
January 23, 2023 Packet Pg. 1280

EXHIBIT B
Findings Responding to Letter from Department of Housing and Community Development Dated January 6, 2023 structural conditions or other
circumstances and trends
demonstrating the redevelopment
potential to more intense
residential uses.

For nonresidential sites, the
inventory could also describe
whether the use is operating,
marginal or discontinued, and the
condition of the structure or could
describe any expressed interest in
redevelopment.

In addition, as noted in the housing
element, the housing element
relies upon nonvacant sites to
accommodate more than 50
percent of the RHNA for lowerincome households. For your information, the housing element
must demonstrate existing uses are
not an impediment to additional
residential development and will
likely discontinue in the planning
period. (Gov. Code, § 65583.2,
subd. (g)(2).) Absent findings (e.g.,
adoption resolution) based on
substantial evidence, the existing
uses will be presumed to impede
additional residential development
and will not be utilized toward
redevelopable residential land and the acute demand for new residential which has made residential development more lucrative. Residential uses in proximity to services and transportation corridors will also be in demand due to AB 2097, a new state law that prohibits parking minimums near transit corridors and transit stops.

The City anticipates increased residential developments in the City’s mixed-use zones for the following reasons:
• There is a general lack of developable residential land in the City. • There has been a significant level of development of residential uses in mixed-use zoning districts. Table 4.5-4 shows that since 2015 among the 27 approved or in process residential projects, more than half (15 or 55 percent) are in mixed-use zoning districts. Table 4.5-6 shows that most of the recent mixed-use projects involve the conversion of non-residential uses. Uses on the projects identified in Table 4.5-6 are similar and consistent with uses on sites allowing a mix of uses identified in the sites inventory as well as similar size (greater than half an acre), and locations. • There is a marked increase in inquiries and expressed interest by property owners to redevelop non-residential sites into residential uses, a trend seen in the surrounding region. In December 2022, the City surveyed property owners of sites included in the inventory as well as owners of potential sites not previously included. Several property owners indicated that they were not interested in redevelopment, and those sites have been removed from the inventory. As a result of the survey, several sites previously identified as potential but not included, were added to the inventory based on property owner interest. Overwhelmingly site owners showed varying degrees of interest and many inquired about the extent of residential development that could be allowed.
• Revisions to the General Plan land use categories and Zoning Ordinance amendments (Action HOU-4.2) will significantly incentivize mixed use development by allowing more intense residential development. Due to the significantly higher housing costs in San Carlos relative to other San Mateo County communities, the City has decided to increase housing capacity by revising zoning standards for mixed-use areas to allow up to 120 units per acre and minimum densities at approximately 75 percent of maximum. • The City is strengthening incentives for transit-oriented development by updating the Zoning Ordinance to reference/incorporate the minimum parking prohibitions associated with AB 2097, effective January 1, 2023, within 0.5 miles of public transit (as defined in AB 2097) in all zoning districts. Over 80 percent of parcels in the site inventory are located within 0.5 miles of public transit, including bus service on El Camino Real (State Route 82) and the Caltrain regional rail line.
• For residential only development in Mixed Use zones, the City will remove additional required setbacks (i.e., removing requirement to follow RM-59 zoning setbacks), which will remove constraints to development. • The City will remove guest parking in Mixed-Use zones. • The City has committed to building on outreach conducted during the Housing Element update and will continue to proactively outreach to property owners with a survey on how the city can support redevelopment/new housing efforts.

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January 23, 2023 Packet Pg. 1281

EXHIBIT B
Findings Responding to Letter from Department of Housing and Community Development Dated January 6, 2023 demonstrating adequate sites to
accommodate the RHNA.
• Existing uses: The existing site uses in Table 4.5-6 mirror that of the City’s current inventory. In the Downtown and along major corridors, historically non-residential areas, the sites have a mix of older stand-alone commercial uses some with surface parking areas. Mixed-use sites are characterized by having a variety of commercial uses, but the site selection focused on smaller scale uses such as small stores or buildings. Large multi-story buildings and sites that showed signs of improvement were not included. • Size: Mixed-use sites (most are stand-alone parcels) in the inventory have an average size of 0.25 acres. Table 4.5-6 shows that most mixed-use projects with residential components on sites with existing uses and with the potential for development of non-residential uses, have a median size of 0.23 acres. Close to two-thirds of mixed-use projects are 0.25 acres in size or smaller. Sites that are less than 0.5 acres in size are identified to meet the moderate and above moderate-income RHNA.
• Location: The example projects resemble the sites included in the inventory in that they are located along major commercial corridors or in areas that have historically been developed with non-residential uses. In response to increased interest in residential development along this corridor, the City has decided to increase housing capacity by revising zoning standards for mixed-use areas to allow up to 120 units per acre and minimum densities at approximately 75 percent of maximum. More than three-quarters of parcels in the site inventory are located within 0.25 mile of El Camino Real.

In general, the market in San Carlos and the surrounding region supports housing as the highest and best use of property, yielding highest returns for property owners, especially in existing neighborhoods, along corridors, and in Downtowns with access to goods, services, and high-quality transit. Based on this analysis and future efforts undertaken through the Housing Plan, the City concludes that likelihood that the identified units will be developed as noted in the inventory in zones that allow 100 percent nonresidential uses is high and that existing uses will not impede additional residential development.

SB 9 Sites: The element identifies
SB 9 as a strategy to accommodate
the part of the City’s need of
above-moderate RHNA. To support
these assumptions, the analysis
must include experience, trends
and market conditions that allow
lot splits. The analysis must also
include a nonvacant sites analysis
demonstrating the likelihood of
The Element has been revised to remove SB 9 units in the inventory and the associated discussion. p.107-110 Sites Inventory
The Housing Element Sites Inventory consists of accessory dwelling unit (ADU) projections , SB 9 duplex construction projections, and vacant and underutilized sites in residential and mixed-use areas. Together, these sites ensure that the remaining RHNA can adequately be accommodated during the planning period. The sites have no identified constraints that would prevent development or reuse during the Housing Element period. The addition of minimum density requirements also ensures that sites will develop to their fullest potential. Table 4.5-3 summarizes the sites inventory, which is graphically represented in Figures 4.5-1. Appendix A includes site specific information for each identified site.

8.b
January 23, 2023 Packet Pg. 1282

EXHIBIT B
Findings Responding to Letter from Department of Housing and Community Development Dated January 6, 2023 redevelopment and the existing
use will not constitute as an
impediment for additional
residential use. The analysis should
describe how the City determined
eligible properties, whether the
assumed lots will have turnover, if
the properties are easy to
subdivide, and the condition of the
existing structures. The analysis
should also describe interest from
property owners as well as
experience. The analysis should
provide support for the assumption
of eligible properties being
developed within the planning
period. Based on the outcomes of
this analysis, the element should
add or modify programs to
establish zoning and development
standards early in the planning
period and implement incentives to
encourage and facilitate
development as well as monitor
development every two years with
and identify additional sites within
six months if assumptions are not
being met. The element should
support this analysis with local
information such as local developer
or owner interest to utilize zoning
Table 4.5-3: Sites to Meet the RHNA
Project
Extremely/
Very LowIncome (0-
50% AMI)
Low-Income
(50-80%
AMI)
ModerateIncome
(80-120%
AMI)
Above
ModerateIncome
(+120%)
Total
RHNA After Approved/Proposed Projects are
credited (Table 4.5-2) 736 362 431 854 2,383
Projected ADU construction 10 61 102 30 203
Projected SB 9 duplex construction -- -- -- 160 160
Vacant/Underutilized Residential Sites 3149 180 81147 238172 368368 Vacant/Underutilized Mixed-Use Sites 9861,490 5840 293481 739520 2,6022,491 Total Sites 10271,549 66361 476730 1007882 3,1733,222
RHNA Status (+surplus/-deficit) +813291 -+301 +29945 +28153 +839790 Redistributed RHNA Status (+surplus/-deficit) +512 +299 +28 +839 Notes:

AMI: Area Median Income
Estimated ADU production is credited toward the RHNA consistent with HCD guidelines and ABAG affordability distribution assumptions (ABAG Affordability of Accessory Dwelling Units, 2021) Sites identified to meet the very low-income RHNA are also qualified to meet the low-income RHNA. As such, the redistributed RHNA is intended to show how the City is meeting the lower income RHNA, inclusive of both the very-low and low-income RHNA.

SB 9 Projections
In September 2021, Governor Newsom signed Senate Bill (SB) 9 into law, with an effective date of January 1, 2022. SB 9 (1) mandates ministerial approval of duplexes on lots zoned for a single-family residence and (2) requires ministerial approval of subdivisions of a single-family lot into two lots, creating the theoretical possibility of four units on each single-family parcel in the state (with some exceptions). The Terner Center for Housing

8.b
January 23, 2023 Packet Pg. 1283

EXHIBIT B
Findings Responding to Letter from Department of Housing and Community Development Dated January 6, 2023 and incentives established through
SB 9.

Innovation at UC Berkeley conducted extensive analysis statewide to determine how many parcels could feasibly utilize the provisions of SB 93 and found that approximately seven percent of single-family parcels throughout the State may redevelop in this way. In San Carlos, the Terner Center identified 8,100 single-family parcels, of which 6,400 are eligible for SB 9 development. The Terner Center eliminated parcels where market feasibility would deter SB 9 use and concluded that approximately 500 new units were market feasible under SB 9 regulations (rounded to nearest 100). The Terner analysis does not set a horizon year for this buildout. A GIS analysis shows that there are 8,229 parcels zoned for single family development (RS-3 and RS-6). Assuming that larger parcels would be easier to develop with additional units or split lots, the City identified 2,136 parcels greater than or equal to 0.2 acres (greater than the average lot size for the RS-3 and RS-6 zones of 0.18 acres). Removing parcels that contain any use other than a single-family home or vacant, and removing parcels located in fire severity zones yields 1,068 remaining parcels, shown on Figure 4.5-2. Conservatively estimating that 15 percent of this ultimate projection could occur in the next eight years, a projection for an additional 160 housing units through SB 9 lot splits and duplex provisions are assumed for the next planning period. Because the affordability of such units is unknown at this time, they are allocated to the above-moderate income category. In 2022, the City adopted an urgency ordinance to align with State law for SB 9 units and lot splits and has initiated the drafting of objective design standards.

Table 4.5-9: Comparison of Sites, Pipeline Projects, and RNHA Project
Extremely/
Very LowIncome (0-
50% AMI)
LowIncome
(50-80%
AMI)
ModerateIncome (80-
120% AMI)
Above
ModerateIncome
(+120%) Total
2023-2031 RHNA 739 425 438 1,133 2,735
Approved and Proposed Projects 3 63 7 279 352
Projected ADU construction 10 61 102 30 203
Projected SB 9 duplex construction -- -- -- 160 160
Vacant/Underutilized Residential Sites 3149 180 81147 238172 368368 Vacant/Underutilized Mixed-Use Sites 9861,490 5840 293481 739520 2,6022,491 3 Ben Metcalf, David Garcia, Ian Carlton, Kate MacFarlane. “Will Allowing Duplexes and Lot Splits on Parcels Zoned for Single-Family Create New Homes? Assessing the Viability of New Housing Supply Under California’s Senate Bill 9.” A Terner Center Report, July 2021.

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January 23, 2023 Packet Pg. 1284

EXHIBIT B
Findings Responding to Letter from Department of Housing and Community Development Dated January 6, 2023 Total 1,0301,552 726124 483737 1,2861,161 3,5253,574
RHNA Status (+surplus/-deficit) +813291 +-301 +29945 +28153 +839790 Redistributed RHNA Status (+surplus/-deficit) +512 +299 +28 +839 Sites identified to meet the very low-income RHNA are also qualified to meet the low-income RHNA. As such, the redistributed RHNA is intended to show how the City is meeting the lower income RHNA, inclusive of both the very-low and low-income RHNA.

Small Sites: While the element
includes an analysis of small sites
and describes programs to address
small lot development, it must
analyze and support assumptions
for small lot consolidation. Sites
smaller than a half-acre in size are
deemed inadequate to
accommodate housing for lowerincome households unless it is demonstrated, with sufficient
evidence, that sites are suitable to
accommodate housing for lowerincome households.

The element must also provide
specific examples with the
densities, affordability and, if
applicable, circumstances leading
to consolidation.

The element should relate these
examples to the sites identified to
accommodate the RHNA for lowerincome households to demonstrate More details have been added to the development of small lots and lot consolidation. The element provides more narrative on how these examples relate to the sites identified in the RHNA on p.119 Small Sites
The scarcity of land makes higher-density development very cost-effective, and development most often occurs on small lots in San Carlos. As indicated in Table 4.5-4, very few projects occur on sites that are over 0.50 acres. Of the 26 major development projects that have occurred in recent years, half occurred on lots that were 0.19 acres or less, with projects occurring on lots as small as 0.11 or 0.12 acres. 100-percent affordable housing developments have also been constructed/are being proposed on small lots, including 817 Walnut (23 affordable units on 0.24 acres) and 1232 Cherry (34 affordable units on 0.32 acres). In the inventory, 65 percent of parcels used to meet the lower-income RHNA are greater than 0.5 acres and can be stand-alone sites (no consolidation needed). Eleven of the 31 lower income sites are smaller than 0.5 acres, but these sites are included because combined with adjacent, commonly-owned parcels the sites exceed the 0.5 acre threshold. With common ownership, the parcels function together as one site without consolidation constraints.

8.b
January 23, 2023 Packet Pg. 1285

EXHIBIT B
Findings Responding to Letter from Department of Housing and Community Development Dated January 6, 2023 that these sites can adequately
accommodate the City’s lowerincome housing need. Based on a complete analysis, the City should
add or revise programs to include
incentives for facilitating
development on small sites.

Shortfall of Adequate Sites: If the
element does not identify
adequate sites to accommodate
the regional housing need for
lower-income households, it must
include a program(s) to identify
sites with appropriate zoning to
accommodate the regional housing
need within the planning period.

The program should identify the
shortfall by income group, acreage,
allowable densities, appropriate
development standards and meet
all by right requirements pursuant
to Government Code section
65583.2, subdivisions (h) and (i),
including but not limited to
permitting multifamily uses byright for developments in which 20 percent or more of the units are
affordable to lower-income
households.

Currently, the element is utilizing
assumptions that sites will be
The Zoning Ordinance revisions will be adopted prior to the start of the planning period. Action HOU-4.2 clarifies that rezoning will be adopted by January 2023.

8.b
January 23, 2023 Packet Pg. 1286

EXHIBIT B
Findings Responding to Letter from Department of Housing and Community Development Dated January 6, 2023 rezoned prior to the start of the
planning period. The revised zoning
must be adopted by City Council
prior to the start of the planning
period, or the City must identify
additional sites or meet by-right
requirements listed above.

AB 725: For jurisdictions that are
considered Metropolitan, the
element must identify at least 25
percent of the remaining moderate
and above moderate RHNA on sites
that allow at least four units of
housing (e.g., four plex or greater).
(Gov. Code, § 65583.2, subd.
(c)(4).)
An analysis on AB 725 requirements has been on p. 126
Moderate-Income and Above Moderate-Income Housing (AB 725) For jurisdictions that are considered Metropolitan, the element must identify at least 25 percent of the remaining moderate and above moderate RHNA on sites that allow at least four units of housing (e.g., four plex or greater). (Gov. Code, § 65583.2, subd.(c)(4).) Of the 169 parcels in the sites inventory, 138 are used to address the moderate- and above moderate-income RHNA. Of those 138 parcels, 116 (or 84 percent) allow for development of 4 or more units.

Environmental Constraints: While
the element generally describes a
few environmental conditions
within the City, it must relate those
conditions to identified sites and
describe any other known
environmental or other constraints
(e.g., shape, easements,
contamination) that could impact
housing development on identified
sites in the planning period.

An analysis relating environmental constraints to the sites inventory has been added to p.101-109 The most serious constraints would be related to the City’s proximity to major earthquake faults and liquefaction potential. Unfortunately, this constraint is common to most urban areas in the State of California. The San Francisco Bay Area contains numerous active faults and is considered seismically active. Numerous small earthquakes occur every year in the San Francisco Bay Region, and larger earthquakes have been recorded and can be expected to occur in the future. The Monte Vista – Shannon, San Andreas, and Pilarcitos are the major faults in the vicinity of San Carlos. The San Andreas Fault System, which is located about one mile west of the western border of the City, is the closest active fault system to the City. Other major earthquake faults in the San Francisco Bay Area include: the Hayward Fault, which is approximately 14 miles to the northeast, the Calaveras Fault, which is approximately 21 miles to east, and the San Gregorio Fault, approximately 10 miles to the west. There are no Alquist-Priolo earthquake fault zones within the City. The City has added various goals, policies and actions in the new Environmental Safety and Public Services Element related to seismic safety for the City.

The potential impacts from slope instability in San Carlos is low. Most of the capacity on identified sites is located on relatively flat areas of the City and as such has a low risk of landslides and liquefaction. Liquefaction potential in the western hilly areas is low, while the flatlands and bay margins area have high liquefaction potential. Landslides occur on some of the upper hilly slopes, more commonly in the northwestern area of the City.

Flooding can be caused by heavy rainfall, long periods of moderate rainfall, or clogged storm drains during periods of rainfall. In rare instances, a break in a water pipe or water tank can also cause flooding. Storm drainage systems throughout San Carlos collect stormwater runoff from streets and convey

8.b
January 23, 2023 Packet Pg. 1287

EXHIBIT B
Findings Responding to Letter from Department of Housing and Community Development Dated January 6, 2023 flows to discharge points at local receiving waters to prevent flooding, although the capacity of these systems is designed based the frequency interval of a typical heavy winter storm (i.e., a 10-year storm) and may not be designed to accommodate more intense storms anticipated under climate change conditions. The inland flood hazard areas are primarily located along the Bay shore, Pulgas Creek, Cordilleras Creek, and Belmont Creek. Localized flooding can occur during peak flow times, mainly in the industrial/commercial areas of town which are located within the 100-year flood zone. Flooding in the 100-year flood zone would not be expected to be more than a few feet deep. The City has identified specific flooding issues associated with Pulgas, Cordilleras, and Brittan Creeks. Some of the prior flooding problems near Pulgas Creek may have been solved by improvements at the Pulgas Creek culvert under the railroad track. Upstream erosion from Cordilleras Creek deposited at El Camino Real is a major contributor to flooding. The new Environmental Safety and Public Services Element (2023) contains goals, policies, and actions that would reduce potential flooding impacts. Chapter

15.56 of the Code (Floodplain Management) establishes construction requirements for development that would minimize flood hazard risks, including anchoring, elevation, and flood-proofing, and standards for utilities, subdivisions, residential, and non-residential construction. Environmental Management Element Action EM-5.10 requires implementation of the NPDES permit or preparation of a stormwater prevention plan and proposed ESPS Element Policies ESPS-2.4 and ESPS-2.10 (see Chapter 4.8 Hazards and Hazardous Materials) increase flood protection through reductions in impervious surface area and by requiring new development projects to incorporate storm drain systems that control runoff rates and volumes thereby preventing increases in downstream flooding potential.

San Carlos fire service is provided under contract by the City of Redwood City Fire Department. It provides fire protection, hazardous materials response, disaster preparedness, and emergency medical response. According to the updated Environmental Safety and Public Services Element, the foothill neighborhoods west of Alameda de las Pulgas are designated Very High Fire Hazard Severity Zones (VHFSZ) by CAL FIRE. The Heather Elementary School and many homes in the western hills are also located within the VHFSZ designation. The vast majority of proposed housing sites to meet the RHNA and properties proposed for rezoning are not located within these VHFSZ-designated areas. In fact, only 22 of the 2,970 (or 0.7 percent) units identified in the sites inventory are in potential Fire Hazard Severity Zones. The updated Environmental Safety and Public Services Element (2023) contains the following goals,, policies, and actions to address potential impacts related to wildland fires citywide.

Goal ESPS-3 Agency Coordination: A resilient San Carlos is well prepared to minimize risks associated with wildfire.

Policy ESPS-3.1 Promote and improve, as necessary, inter-jurisdictional fire prevention assessment, planning, and projection; and consultation and communication regarding disaster or emergency plans of San Carlos and Mutual Aid with adjacent agencies including but not limited to San Mateo County, Redwood City, Belmont, and CAL FIRE.

Action ESPS-3.1 Maintain participation in the Joint Powers Authority Agreement with all fire departments in San Mateo County to ensure required response times for initial emergency deployment personnel and equipment.

Action ESPS-3.2 Preserve the local government agreement with California Department of Forestry and Fire Protection (CAL FIRE) for responses in the Mutual Threat Zone (MTZ) within the Wildland Urban Interface (WUI) areas of the city. Continue to provide equipment and personnel under the mutual aid agreement, with the State of California Office of Emergency Service (OES) Region II. This continued “reverse support” enables the City of San Carlos to receive “no cost” statewide mutual aid in the event of a declared large-scale emergency.

8.b
January 23, 2023 Packet Pg. 1288

EXHIBIT B
Findings Responding to Letter from Department of Housing and Community Development Dated January 6, 2023 Action ESPS-3.3 Collaborate with the regional fire agencies on strategies available to maintain defensible space, diverse plant composition (e.g., less combustible native plants), undertake appropriate thinning of vegetation, and maintain fuel breaks without permanently damaging native habitat.

Policy ESPS-3.2 Conduct annual training for fire, emergency medical, and police staff including cross training with adjacent automatic or mutual aid emergency response departments. Regularly maintain, test, and update training and equipment to meet current standards.

Policy ESPS-3.3 Ensure adequate Fire Department resources (fire stations, personnel, and equipment) to meet response time standards, keep pace with growth, and provide a high level of service to the community Action ESPS-3.4 Continue to work with the Redwood City Fire Department to ensure that fire services are maintained at adequate levels. With subsequent Safety Element updates, assess and project future emergency service needs. Continue to monitor service area to ensure that all San Carlos areas have fire service. Monitor the City of San Carlos’ fire protection rating and work with the Redwood City and San Mateo County Fire Departments to correct deficiencies and to ensure ongoing training, including cross training is conducted.

Action ESPS-3.5 Train and educate public volunteers in basic fire safety response.

Policy ESPS-3.4 Locate essential public facilities out of high-risk, wildfire-prone areas including the VHFHSZ unless mitigation measures, above the minimum fire protection standards, are installed.

Policy ESPS-3.5 Prioritize infill development opportunities to prevent increased development in the WUI and Very High Fire Severity Zones (VHFSZ).

Policy ESPS-3.6 Minimize new development (residential and nonresidential) within the VHFSZ.

Policy ESPS-3.7 Consider the preservation of undeveloped ridgelines to reduce fire risk and improve fire protection.

Policy ESPS-3.8 Regularly review and confirm the City’s re-development policy for all structures in VHFSZs after large fires. If the City has an unwritten policy, adopt a written re-development policy.

Policy ESPS-3.9 Incorporate or require the incorporation of fire safety features in new development and re-development.

Policy ESPS-3.10 Require new residential developments to: have adequate fire protection; and be more wildfire resistant by establishing greenbelt zones for fire resistant landscaping.

Policy ESPS-3.11 Require new residential development to be designed in such a manner that reduces wildfire hazard and improves defensibility (e.g. clustering lots, managed greenbelts, water storage, fuel modification zones, and vegetation setbacks.) Action ESPS-3.6 Discourage critical facilities being in the VHFSZ.

Action ESPS-3.7 Periodically re-evaluate the City’s policy allowing rebuilding in the VHFSZ. If the policy is unwritten, adopt a formal written policy.

Action ESPS-3.8 When a fire has occurred in the VHFSZ, evaluate if street design and size can be reconfigured to improve emergency access and evacuation efficiency.

Action ESPS-3.9 If development is permitted within the VHFSZ, require:

8.b
January 23, 2023 Packet Pg. 1289

EXHIBIT B
Findings Responding to Letter from Department of Housing and Community Development Dated January 6, 2023 • a Fire Protection Plan addressing: risk analysis, fire response capabilities, fire safety requirements (defensible space, infrastructure, and building ignition resistance), mitigation measures and design considerations for non-conforming fuel modification, and wildfire education maintenance and limitations;
• landscape/fuel modification installation, incorporating open areas to complement defensible spaces, identifying possible refuge areas, and mapping and providing multiple ingress and egress routes; • resident evacuation plans and ways to effectively communicate those plans, including identifying the location and direction of evacuation routes and at least two points of ingress and egress; and • a roadside fuel reduction plan to prevent fires along public roads caused by vehicles.

Action ESPS-3.10 Enforce fire standards and regulations while reviewing building plans and conducting building inspections.

Policy ESPS-3.12 Ensure adequate water supply is available.

Action ESPS-3.12 Require new development projects have adequate water supplies to meet the fire-suppression needs of the project without compromising existing fire suppression services to existing uses.

Action ESPS-3.13 Work with water suppliers (Cal Water) to:
• maintain and ensure the long-term integrity of future water supply for fire suppression needs; • ensure that water supply infrastructure adequately supports existing and future development and redevelopment; • provide adequate water flow to combat structural and wildland fires, including during peak domestic demand periods. Water systems shall equal or exceed the standards of the latest edition of National Fire Protection Association (NFPA) 1142, “Standard on Water Supplies for Suburban and Rural Fire-Fighting.”;
• ensure water infrastructure can provide for peak fire flow; and • identify where water infrastructure does not allow for peak fire flow and develop a plan to mitigate the deficiencies.

Policy ESPS-3.13 Ensure new and existing public and privately owned properties are constructed and maintained in a manner that minimizes and reduces fire hazard threats and has adequate fire protection.

Action ESPS-3.14 Condition all new development and redevelopment to have adequate fire protection, incorporate and maintain fire safe design, including fuel modification zones, defensible space, two ingress/egress points, emergency vehicle access, and visible home addressing and street signage.

Action ESPS-3.15 Require the use of fire-retardant roofing material for all new construction and major remodels involving roof additions.

Encourage property owners with shake shingle roofs to upgrade to fire-retardant materials.

8.b
January 23, 2023 Packet Pg. 1290

EXHIBIT B
Findings Responding to Letter from Department of Housing and Community Development Dated January 6, 2023 Action ESPS-3.16 Continue to enforce the brush clearance/weed abatement program for both private and public roads as well as City-owned open spaces.

Action ESPS-3.17 Continue code enforcement programs requiring private and public property owners to maintain buildings and properties to prevent blighted conditions, remove excessive or overgrown vegetation (e.g., trees, shrubs, weeds), and remove litter, rubbish, and illegally dumped items from properties.

Action ESPS-3.18 Seek grants and other funding sources to assist low-income residents with home hardening efforts.

Action ESPS-3.19 Adopt an ordinance or update existing ordinances to require development standards that meet or exceed title 14, CCR, division 1.5, chapter 7, subchapter 2, articles 1-5 (commencing with section 1270) (SRA Fire Safe Regulations) and title 14, CCR, division 1.5, chapter 7, subchapter 3, article 3 (commencing with section 1299.01) (Fire Hazard Reduction Around Buildings and Structures Regulations) for SRAs and/or VHFHSZs.

Action ESPS-3.20 Within the VHFSZ, the City’s building and planning departments will work with local fire departments, community organizations, and other responsible organizations to require and ensure:
• the installation of fire protection water system for all new construction projects including fire hydrant instillation, fire sprinkler, or suppression systems, and providing adequate fire flow;
• the long-term maintenance of defensible space clearances around structures, subdivisions, and fire breaks; and • all structures rebuilt/re-developed after a large fire to comply with building and fire codes in effect at the time of the re-development.

Action ESPS-3.21 Conduct a survey of existing residential structures (including vegetation) within the VHFSZ identifying buildings that do not comply with fire safety standards. Consult with property owners to bring those properties into compliance with the most current building and fire safety standards.

Action ESPS-3.22 Consider developing or improving structure hardening standards for community refuges (such as schools, hospitals, evacuation centers).

Action ESPS-3.23 Evaluate the City’s roadways regarding access, alignments, etc. to facilitate fire, police, and ambulance access and resident egress in case of an emergency.

Policy ESPS-3.14 Provide adequate evacuation routes and access for fire and emergency service vehicles to all San Carlos areas.

Policy ESPS-3.15 Identify and implement measures to mitigate the single access roads and non-conforming roadways, as feasible.

Action ESPS-3.24 Identify streets and key intersections that, due to pavement width, hairpin turns, and tight curves, if not cleared of vehicles, may interfere with emergency vehicle access and/or resident evacuation during a fire.

8.b
January 23, 2023 Packet Pg. 1291

EXHIBIT B
Findings Responding to Letter from Department of Housing and Community Development Dated January 6, 2023 Action ESPS-3.25 Identify the potential for street widening and improvement during regular Capital Improvement project maintenance, e.g., emergency access, utility undergrounding, resurfacing, and American with Disabilities (ADA) compliance.

Action ESPS-3.26 Prohibit parking on one or both sides of a street identified as having the potential to interfere with emergency vehicle access and/or resident evacuation during a fire, when Red Flag alerts have been issued.

Action ESPS-3.27 In conjunction with the use of the Zonehaven system, supplement the evacuation plan as shown in Figure 8-12, with special emphasis placed on the areas that do not have sufficient access and egress identified on Figure 8-13. Recommend improvements to ensure adequate evacuation capabilities.

Action ESPS-3.28 Conduct a study to review evacuation routes, their capacity, safety, and viability under a range of emergency scenarios as set forth in AB 747. Determine remedial actions, as appropriate. Update evacuation plans with each update of the Safety Element to address changes in at-risk areas and populations.

Goal ESPS-4 Develop a community that proactively prevents wildfires and protects life, property, and infrastructure from urban and wildfire impacts.

Policy ESPS-4.1 Provide public education to promote community awareness and preparedness for self-action in the event of a major disaster or emergency.

Action ESPS-4.1 Partner with Redwood City Fire Department, San Mateo Sheriff Department, neighboring cities, regional agencies, local school districts, local businesses, and community organizations to:
• conduct emergency and disaster preparedness exercises that test operational and emergency response plans (including evacuation routes); and
• prepare and conduct public outreach regarding evacuation procedures and routes and defensible space.

Action ESPS-4.2 Identify at-risk populations that would be vulnerable during wildfire evacuations and provide information to the at-risk residents regarding defensible space and evacuation routes.

Action ESPS-4.3 Prepare and make available to the public a current map of areas subject to wildland fires as provided by the California Department of Forestry and Fire Protect (CAL FIRE).

Action ESPS-4.4 Implement a fire hazards education program to minimize risk for residential, commercial, and institutional uses. • Provide training opportunities for residents for fuel modification methods, practices, and materials. • Prepare and distribute two vegetation lists – one identifies recommended vegetation in the VHFSZ and the other identifies prohibited vegetation in the VHFSZ.

8.b
January 23, 2023 Packet Pg. 1292

EXHIBIT B
Findings Responding to Letter from Department of Housing and Community Development Dated January 6, 2023 Action ESPS-4.5 Create and promote enrollment in a San Carlos emergency reverse dial program. Work with vulnerable populations to ensure enrollment.

Action ESPS-4.6 Consider establishing an outdoor warning system in the VHFSZ designed to alert residents about possible fire danger Infrastructure: While the element
references a future study of water
and sewer capacity, it must
demonstrate sufficient existing or
planned water and sewer capacity
to accommodate the RHNA for the
planning period and add or modify
programs if necessary.

More analysis has been regarding water and sewer capacity for the planning period. P.133 Drinking water in San Carlos is provided by Cal-Water. Cal Water’s Individual Supply Guarantee (ISG) is 35.68 MGD (39,993 acre-feet per year; AFY), which is shared among its Bear Gulch, Mid-Peninsula, and South San Francisco Districts (also referred to as the “Peninsula Districts”). The 2020 UWMP estimates the Peninsula Districts’ demand will increase over time to 36,396 AF in 2045. Therefore, the Peninsula Districts are expected to have adequate water supplies during normal years to meet its projected demands through 2045 (including capacity on identified sites). However, like most districts across the State, the District is expected to experience significant shortfalls during single dry and multiple dry year conditions. Cal Water has developed a Water Shortage Contingency Plan to address potential water shortage conditions. The Water Shortage Contingency Plan (WSCP) addresses water shortage conditions resulting from any cause (e.g., droughts, impacted distribution system infrastructure, regulatory-imposed shortage restrictions, etc.). The WSCP identifies a variety of actions that Cal Water would implement to reduce demands and further ensure supply reliability at various levels of water shortage.

The San Carlos Public Works Department provides wastewater collection service for San Carlos. The City owns and operates a sanitary sewer collection system consisting of approximately 104 miles of sewer pipelines and six sewer lift stations. Wastewater originating in San Carlos is treated by the South Bayside System Authority (SBSA). Wastewater generated within the City is treated at a wastewater treatment plant (WWTP) operated by a joint powers authority called Silicon Valley Clean Water (SVCW), which serves the communities of Belmont, Redwood City, San Carlos, and the West Bay Sanitary District. The SVCW WWTP has a capacity to treat 29.5 MGD, but currently receives approximately 20.0 MGD from customers in the SVCW service area.

As described in the General Plan EIR, of the total capacity, the City of San Carlos is allocated a total treatment capacity of 4.47 MGD. The San Carlos flow wastewater projection for residential and existing non-residential uses is 3.16 MGD, which would result in 1.31 MGD of capacity remaining within San Carlos allocation. Therefore, the City’s wastewater collection system is expected to have adequate capacity to meet its projected demands through 2045 (including capacity on identified sites).

Electronic Sites Inventory: For your
information, pursuant to
Government Code section 65583.3,
the City must submit an electronic
sites inventory with its adopted
housing element. The City must
An updated electronic sites inventory form will be submitted along with the adopted housing element.

8.b
January 23, 2023 Packet Pg. 1293

EXHIBIT B
Findings Responding to Letter from Department of Housing and Community Development Dated January 6, 2023 utilize standards, forms, and
definitions adopted by HCD. Please
see HCD’s housing element
webpage at
https://www.hcd.ca.gov/planningand-communitydevelopment/housing-elements for a copy of the form and instructions.

The City can reach out to HCD at
[email protected] for
technical assistance.

Zoning for a Variety of Housing
Types:
• Emergency Shelters: While the
element lists some development
and management standards for
emergency shelters, it must clarify
the maximum number of beds
allowed, analyze it as a constraint,
and add a program as needed.
• Manufactured Housing:

Manufactured homes that are built
on a permanent foundation must
be allowed in the same manner
and in the same zones as
conventional or stick-built
structures. Specifically,
manufactured homes on a
permanent structure should only
be subject to the same
The maximum number of beds allowed and parking requirements for emergency shelters was further analyzed and identified as a constraint (p.81).

The standards listed above are common across many cities in California and do not constrain the production of emergency shelters. However, while State law does allow jurisdictions to regulate the number of beds provided at emergency shelters, the City’s current standard could limit the capacity to less than 20 beds, which is considered a constraint by the California Department of Housing and Community Development. Action HOU-5.1 is included in the Housing Plan to review and modify capacity standards for emergency shelters.

State law (Government Code Section 65583(4)(a)) requires emergency shelters to only be subject to those development and management standards that apply to residential or commercial development within the same zone, except that a local government may apply written, objective standards that include sufficient parking to accommodate all staff working in the emergency shelter, provided that the standards do not require more parking for emergency shelters than other residential or commercial uses within the same zone. The City’s parking standards for residential development are based on the type of residential land use and vary based upon the zoning district. In residential and mixed-use zoning districts, the City requires parking for emergency shelters to be provided at one space per 200 square feet of floor area. According to RentCafe, a nationwide apartment listing website, the average size of a studio in San Carlos is 260 square feet, which is of similar size to the 200 square foot minimum per person required by State law for emergency shelters. The City’s parking requirements for emergency shelters is on par with those required for similar residential uses within the same zones, which is one space per studio unit, 1.5 spaces per one- or two-bedroom unit, and 2 spaces per three- or more bedroom unit. However, the parking required for emergency shelter is more restrictive than what is required for commercial uses, which is one space per 450 square feet for office, one space per 400 square feet for retail, and one space per 250 square feet for restaurant. Action HOU-5.1 is included in the Housing Plan to comply with State law.

8.b
January 23, 2023 Packet Pg. 1294

EXHIBIT B
Findings Responding to Letter from Department of Housing and Community Development Dated January 6, 2023 development standards as a
conventional single-family
residential dwelling. The element
must demonstrate consistency with
this requirement or add or modify
programs as appropriate.

New actions were added to Action HOU-5.1 (p.30) to address this constraint • Review and modify the Zoning Ordinance as needed to comply with Government Code Section 65583(4)(a) to subject emergency shelters only to those development and management standards that apply to residential or commercial development within the same zone. Revise the Zoning Ordinance to require emergency shelter parking only to be sufficient to accommodate all staff working in the emergency shelter, provided that the standards do not require more parking for emergency shelters than other residential or commercial uses within the same zone. • Review and modify Zoning Ordinance development standards related to the number of residents that can be accommodated at an emergency shelter facility, which shall in no case be less than 20 beds.

Clarification was added that manufactured/factory-built housing is allowed in the same many as single-unit dwelling. P.82 Manufactured/Factory-built housing
State law requires that factory built/manufactured homes be considered a single-family dwelling and permitted in all zoning districts that allow singlefamily housing. Manufactured housing can be subject to design review, the same single-unit dwellings, as shown in Table 4.4-12 (Timelines for Permit Procedures).. The San Carlos Zoning Ordinance includes individual manufactured housing units installed on a foundation system pursuant to Section 18551 of the California Health and Safety Code under the definition of a single-unit dwelling, in compliance with State law. Manufactured homes are subject to the same development standards as conventional single-unit dwellings, and are allowed in the same manner and in the same zones as conventional or stick-built structures through the common definition of “dwelling”.

4. An analysis of potential and actual governmental constraints upon the maintenance, improvement, or development of housing for all income levels, including the types of housing identified in paragraph (1) of subdivision (c), and for persons with disabilities as identified in the analysis pursuant to paragraph (7), including land use controls, building codes and their enforcement, site improvements, fees and other exactions required of developers, and local processing and permit procedures... (Gov. Code, § 65583, subd. (a)(5).)
Land Use Controls: The element
must identify and analyze all
relevant land use controls impacts
as potential constraints on a variety
of housing types.

The element already provided an analysis on parking and open space requirements, More analysis was added regarding heights, lot coverage, and limits on allowable densities. As well as a discussion on the cumulative impacts of these land use controls. (p. 69-70).

The discussion on heights also analyzes the 35-foot height limit in the RM-20 zones.

8.b
January 23, 2023 Packet Pg. 1295

EXHIBIT B
Findings Responding to Letter from Department of Housing and Community Development Dated January 6, 2023 The analysis should analyze land
use controls independently and
cumulatively with other land use
controls.

The analysis should specifically
address requirements related to
parking, heights, lot coverage and
limits on allowable densities. The
analysis should address any
impacts on cost, supply, housing
choice, affordability, timing,
approval certainty and ability to
achieve maximum densities and
include programs to address
identified constraints.

The element must specifically
analyze the 35-foot height limit in
RM-20 as a potential constraint on
multifamily development.

In addition, Table 4.4-2 (page 64)
lists allowed densities associated
with each zone but appears to lack
a variety of densities and housing
types such as densities between 6
and 15 dwelling units an acre. The
element should analyze whether
the allowed densities are
considered a constraint on a
Heights
In San Carlos, the maximum building height ranges from 28 feet in low density residential zones to 50 feet with a maximum of three to four stories in high density residential zoning districts. In mixed-use zoning districts, height limits are 50 feet. To provide for appropriate transitions between zones, heights are limited to 30 feet for any portion of a building within 40 feet of an RS zoned property and 40 feet within 50 feet of an RS zoned property.

Maximum stories in mixed-use zones are four stories. To achieve neighborhood compatibility in an objective way, these transition standards are important. Where the height limit includes a number of stories as well as a height limit in feet, both standards must be achieved.

As part of the proposed Zoning Ordinance amendments scheduled for adoption in January 2023, the City has increased heights limits to further promote the production of higher density housing in conjunction with an increase in density. Heights are proposed to increase from 50 feet to 75 feet in most zones, as shown in Table 4.4-5. Transition standards between higher density areas and the RS zone remain in place.

The new heights are intended to allow residential development in these new zones to achieve close to or exceed the maximum permitted densities.

Height limits in RM-20 (35 feet) and RM-59 (50 feet) zones are not proposed to be amended, as these standards are fairly typical in zones with these types of densities (20 du/ac in RM-20 and 59 du/ac in RM-59), as seen in various cities across the Bay Area. In general, the RM-20 zoning district, with a maximum density of 20 units to the acre, facilitates the development of three-story townhomes and other three-story apartment style homes. This type of development can be achieved within a 35-foot height limit, and no constraint is identified.

For the new RM-100 zoning district proposed, building height is increased to 60 feet. These heights are intended to facilitate the increased densities.

Lot Coverage
Maximum lot coverage standards vary from 25 to 50 percent in low density residential zones to 65 to 75 percent in higher density residential zones. Mixed use zones have no maximum lot coverage standard. These standards are typical in many Bay Area cities and in San Carlos have not historically been considered restrictive to the production of housing. As an example, the City of Alameda included a program in its Housing Element to increase lot coverage from existing levels to 60 percent in higher density zones. San Carlos’s existing lot coverage standards exceed these increased standards.

The discussion on densities also analyzes how to develop housing in the 6 and 15 dwelling units per acre range.

Density
The City’s existing density maximums range from three dwelling units per acre to six dwelling units per acre for low density residential zones. Higher density residential zones have densities that range from 15 dwelling units per acre to 59 dwelling units per acre. In mixed use zones (as of 2022), densities range from 20 dwelling units per acre to 59 dwelling units per acre. As part of the Zoning Ordinance amendments scheduled for adoption in January 2023, the City will not only increase density for higher density residential neighborhoods and mixed-use areas, but also will institute a new minimum density requirement (approximately 75 percent of maximum density) to ensure anticipated housing densities are achieved. The new densities

8.b
January 23, 2023 Packet Pg. 1296

EXHIBIT B
Findings Responding to Letter from Department of Housing and Community Development Dated January 6, 2023 variety of multifamily housing
types and add a program to
address the constraint.
will have a maximum range of 40 to 120 dwelling units per acre and a minimum range of 30 to 90 dwelling units per acre. The City initiated these Zoning Ordinance amendments to achieve the necessary density to encourage housing production citywide and to meet its regional housing needs. The minimum density requirements are intended to preserve and protect multi-family zones for higher intensity housing by avoiding the development of single-family homes or large townhome project types in even the lowest-density multi-family zone. In higher income communities such as San Carlos, such provisions may limit housing variety in higher density zones (precluding single family development), but are crucial to preserve these areas for their intended use, which provides space for multi-family developments intended to increase citywide housing choice and meet the regional housing needs.

While there is no zone identified that allows densities at a range of six to 15 dwelling units per acre, it is expected that housing at these densities can be met through accessory dwelling unit (ADU) and development that will be facilitated by SB 9. In San Carlos, the median size for a residential lot is 6,600 square feet. The addition of an ADU to an existing single-family residence results in a density of 13 dwelling units per acre, allowing individuals interested in developing housing at this range to do so.

Cumulative Impacts of Land Use Controls
As a part of the Housing Element update and proposed Zoning Amendment process, prototypical development sites were analyzed to identify development standards that would support the new maximum densities, including height, open space, parking, etc. without undue cost or impacts to housing supply or housing choice. Higher density residential and mixed-use zones allow for significant variety in housing choice and type and the increased densities support additional affordability. The proposed Zoning Ordinance amendments (summarized in Action HOU-4.2) reflect that analysis and are intended to support development meeting allowed densities without constraints. In addition, Action HOU-4.4 is included in the Housing Plan to address approval certainty through objective design standards and streamlining of the approval process.

Parking: While the element lists
standard parking requirements for
single-family and multifamily
developments, it noted that
developers identify parking as a
constraint to development. The
element should analyze this
potential constraint and add or
modify programs as appropriate.

In addition, the element states that
additional parking is required for
Additional information has been include to discuss how the city is addressing and modifying parking requirements to facilitate higher density residential development. p.60-61 and p. 73.

Requests for Lower Development Densities
San Carlos has an active housing market, with development occurring at a range of densities. For mid-sized projects where the maximum allowed densities would result in between seven units to approximately 12 units, most developers have in recent years opted to stay below seven units, providing six units instead thereby avoiding the City’s requirement that all residential developments of seven or more units set aside 15 percent of the units as below market rate housing. An estimated 90 percent of these mid-size projects over recent years were proposed at less than the maximum densities, generally to avoid triggering the requirements of the BMR Ordinance. In some instances, developers also indicated that parking minimums resulted in a reduction in density below the allowed maximum densities because surface parking space was limited, and it was too expensive to construct podium or underground parking. To address this constraint, the City has initiated a Zoning Ordinance amendment (Action HOU-4.2), to

8.b
January 23, 2023 Packet Pg. 1297

EXHIBIT B
Findings Responding to Letter from Department of Housing and Community Development Dated January 6, 2023 group residential and residential
care facilities above what is
required for residential uses. The
parking requirements should not
impose additional constraints, and
a program should be added to
address the constraint.
remove the requirement for guest parking in all RM and Mixed-Use zones. In addition, with the passing of AB 2097, parking requirements will be removed for a significant component of the San Carlos community. Pursuant to AB 2097, no parking is required within a half mile of public transit in all zoning districts. Given the proximity to transit for all of Downtown and the mixed use zones, this can be seen as a significant removal of this constraint.

Action HOU-4.2 includes an update to the Zoning Ordinance to make these new regulations clear and indicate that no parking is required within a half mile of public transit.

Proposed Parking Changes
While the parking requirements in San Carlos are typical of communities in San Mateo County, developers have indicated that minor modifications to existing standards would facilitate additional housing, including removing guest parking space requirements. As such, (Action HOU-4.2 is included in the Housing Plan to remove this potential constraint and guest parking requirements for multi-family housing). In addition, Action HOU-4.2 will strengthen incentives for transit-oriented development by updating the Zoning Ordinance to reference/incorporate the minimum parking prohibitions associated with AB 2097, effective January 1, 2023, within 0.5 miles of high frequency public transit (as defined in AB 2097) in all zoning districts. In San Carlos, areas within 0.5 miles of high frequency public transit represent a significant portion of the City’s multi-family development capacity. Public transportation services include local and regional routes provided by the San Mateo Transit District and CalTrain’s commuter rail. The San Carlos Caltrain stop is located at the intersection of El Camino Real and San Carlos Avenue, and El Camino Real is served by bus routes with 15-minute headways. These public transit routes generally parallel the location of local mixed use zoning districts, which are, in turn, often adjacent to higher density multi-family zoning districts. All areas zoned mixed-use and RMF-100 are located within 0.5 mile of El Camino Real and 84 percent of the area zoned MF-59 is located within 0.5 mile of El Camino Real. As such, these areas have no parking requirements and parking is not considered a constraint to housing development. to further incentivize higher density housing and to ensure impediments are removed if they are identified, Action HOU-2.1 and Action HOU-2.2 is included in the Housing Element to continue to analyze parking standards and as needed pursue reduced parking requirements and other measures such as reductions in parking for small lot projects to ensure feasibility.

Action HOU-5.3 has been updated with the following information to remove constraints for residential care facilities. • Review and modify development standards for residential care facilities and group homes to ensure the same standards apply for these uses as other residential uses of the same type in the same zone, specifically standards related to parking requirements and distancing between similar facilities. No additional parking shall be required for group residential and residential care facilities above what is required for residential uses.

Remove any subjectivity in any standards or required findings to ensure residential care facilities and group homes are allowed objectively with approval certainty.

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January 23, 2023 Packet Pg. 1298

EXHIBIT B
Findings Responding to Letter from Department of Housing and Community Development Dated January 6, 2023 Local Processing and Permit
Procedures: While the element
includes information about
processing times, it demonstrates
that the approval process for
multifamily and mixed-use
developments take substantially
longer than approvals for singlefamily developments.

The element must analyze this as a
constraint and address impacts on
housing cost, supply, timing and
approval certainty and add or
modify programs as appropriate.

In addition, the element should
analyze the conditional use permit
(CUP) findings as a potential
constraint and add or modify
programs as appropriate.

The following has been added clarifying and further analyzing the processing times for multi-family, mixed-use and single-family developments. (p.94-95)
Single-family dwelling unit applications typically take three to five months to receive planning approval for a single residential unit on one lot; and four to six weeks for building permit issuance. Subdivisions to obtain a tentative map are typically processed within six to nine months; building permits are generally issued within three to five months. Review time always varies based upon response time of the applicant to plan review comments. Most projects typically receive Building Division Plan Review comments within 15 to 20 working days, and rechecks are always performed within 10 to 15 working days. Because planning permits are processed concurrently (i.e., Design Review is processed concurrently with any required Use Permit or Grading Certificate) the timeframe for Design Review indicated in Table 4.4-12 is essentially the same amount of time that it takes from application submittal to receive entitlement approval. As such, small mMulti-family development applications generally receive entitlements within five to eight months and large multi-family applications receive entitlements within seven to twelve months; followed by building permits which are typically issued within six to eight weeks. The processing timelines for multi-family residential and mixed-use projects are not significantly longer than what is typical for single-family residential projects; however, the longer timeframes reflect significantly more complicated projects. As shown in Table 4-4.14, the overall processing times for residential development in San Carlos are comparable to surrounding jurisdictions. To address the slightly longer relative timeframes for multi-family development, when compared with surrounding jurisdictions, the City has added Action HOU-4.4 to the Housing Plan to revise design review criteria to be fully objective, removing subjectivity from the findings and approval processes. This effort is anticipated to reduce overall permit review timeframes. Action HOU-4.4 also includes biennial evaluations to ensure processing timeframes are reduced, and calls for additional actions if necessary to reduce timelines if identified measures do not sufficiently address the constraint.

Table 4.4-13: Permitting Requirements per Development Type Single-Family Residential
Multi-Family Residential and/or Mixed-Use
District
Staff Level Design Review Design Review Permit
Residential Design Review
Committee (RDRC) Review (1)
Residential Design Review Committee
(RDRC) or Planning Commission Review
Typical Approval Requirements
Planning Commission (2) Planning Commission (2)
Est. Total Processing Time
Planning = 34-56 monthsweeks
Building Permits = 43-6 weeks
Planning = 56-128 months
Building Permits = 6-8 weeks
Notes:

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January 23, 2023 Packet Pg. 1299

EXHIBIT B
Findings Responding to Letter from Department of Housing and Community Development Dated January 6, 2023

1. New homes and projects that result in greater than 3,000 square feet in area and meets or exceeds FAR thresholds identified in Table 18.29.030-A(1)

2. Planning Commission conducts design review for projects requiring Planning Commission approval, such as conditional use permits and variances.

The following revisions have been made to Action HOU-4.4 Timeframe: Objective Design Standards – citywide, by end of 2023; Objective Design Standards - within the Downtown Specific Plan boundary, by spring 2024; develop informational materials on SB 35 in 2025by end of 2023; re-evaluate permit review times biennially; if review times do not decrease, implement additional measures to reduce processing time.

The findings for CUP have been further analyzed. P. 100 Conditional Use Permits
The Conditional Use Permit (CUP) review process is intended to apply to uses that are generally consistent with the purposes of the district where they are proposed but require special consideration to ensure that they can be designed, located, and operated in a manner that will not interfere with the use and enjoyment of surrounding properties or adversely affect the city’s infrastructure, the built or natural environment, city resources, or the City’s ability to provide public services. As indicated in Table 4.4-3 (Permitted Land Uses by Zoning District), no Conditional Use Permit is required for multifamily dwellings in residential zones (RM-20 and RM-59/100) and mixed-use zones (MU-D-100/120, MU-NB-120, MU-SC-120, MU-SB-100/120, MU-N40/50/120). Supportive and transitional housing are also uses that are allowed by right. Residential uses subject to discretionary review that require a Conditional Use Permit (reviewed by the Planning Commission) and a Minor Use Permit (reviewed by the Director) are outlined in Table 4.4-2 (Permitted Land Uses by Zoning District). Processing for CUP applications normally does not exceed six months. Required findings for approval of Use Permits include:
• The proposed use is allowed within the applicable zoning district and complies with all other applicable provisions of this title and all other titles of the municipal code;
• The proposed use is consistent with the General Plan and any applicable specific plan; • The proposed use will not be adverse to the public health, safety, or general welfare of the community, nor detrimental to surrounding properties or improvements;
• The proposed use complies with any design or development standards applicable to the zoning district or the use in question unless waived or modified pursuant to the provisions of this title;

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January 23, 2023 Packet Pg. 1300

EXHIBIT B
Findings Responding to Letter from Department of Housing and Community Development Dated January 6, 2023 • The design, location, size, and operating characteristics of the proposed activity are compatible with the existing and reasonably foreseeable future land uses in the vicinity; and
• The site is physically suitable for the type, density, and intensity of use being proposed, including access, utilities, and the absence of physical constraints.

A CUP is not required for multi-family development in San Carlos. As such, these findings do not apply. CUPs are only required for single-room occupancy developments and for bungalow court/small lot subdivisions in the RM-59 and RM-100 zones, with the intent of preserving these zones for higher intensity development. Action 4.4 is included in the Housing Plan to amend the Zoning Ordinance to include CUP findings for any applicable special residential uses to ensure that findings are objective and result in project approval certainty, consistent with Housing Accountability Act requirements.

The following revisions have been made to Action HOU-4.4 • Revise the Conditional Use Permit findings for any special residential uses that require a CUP but are also covered by the Housing Accountability Act to be fully objective and to provide local guidance on design and standards for by-right projects as allowed by state law, removing subjectivity from findings and approval processes.

Design Review: While the element
describes the design review
guidelines and process, it must
analyze their impact as potential
constraints on housing supply and
affordability. For example, the
analysis could describe required
findings and discuss whether
objective standards and guidelines
improve development certainty
and mitigate cost impacts.

In particular, the design review
process for multifamily and mixedThe findings for CUP have been further analyzed. P. 100 The review authority may only approve a design review application if it finds that the application is consistent with the purposes of the chapter (the chapter establishes the design review procedure to ensure that new development supports the General Plan’s goal of creating a vibrant pedestrian- and transit-oriented core and distinctive neighborhoods and districts with a diversity of building types that provide continuity in scale and character with appropriate transitions, where needed. The specific purposes of the design review process are to:

A. Promote excellence in site planning and design and the harmonious appearance of buildings and sites; B. Ensure that new and modified uses and development will be compatible with the existing and potential development of the surrounding area; and

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January 23, 2023 Packet Pg. 1301

EXHIBIT B
Findings Responding to Letter from Department of Housing and Community Development Dated January 6, 2023 use projects appears to take up to
an additional 12 months.

The element must evaluate the
process as a constraint, particularly
on timing and feasibility and
include a program to address
identified constraints.

C. Supplement other City regulations and standards in order to ensure control of aspects of design that are not otherwise addressed) and with the following:
• The applicable standards and requirements of the Zoning Ordinance; • The General Plan and any applicable specific plans the City Council has adopted; • Any applicable design guidelines adopted by the City Council; • Any approved tentative map, use permit, variance, or other planning or zoning approval that the project required; and • The applicable design review criteria in Section 18.29.060, Design review criteria.

Design review projects may be appealed through the City’s standard appeal process.

The Housing Accountability Act (Government Code Section 65589.5) states that local jurisdictions may not deny, reduce the density of, or make infeasible housing development projects, emergency shelters, or farmworker housing that are consistent with objective local development standards and contribute to meeting housing need unless, based on a preponderance of evidence, adverse health or safety impacts exist. Objective standards and review processes that remove subjectivity from findings improves development certainty and can mitigate cost impacts. In order to ensure compliance with the Housing Accountability Act, Action HOU-4.4 is included to ensure compliance with the Housing Accountability Act requirements, through a study of the City’s Design Review process, procedures, findings, and standards, ensuring that subjectivity is removed from the process for those projects that comply with objective standards..

The following revisions have been made to Action HOU-4.4 • Revise the Design Review Criteriacriteria and findings to be fully objective and to provide local guidance on design and standards for by-right projects as allowed by state law, removing subjectivity from findings and approval processes, thereby reducing permit review timeframes.

On/Off-Site Improvements: While
the element includes an analysis of
on/off-site improvements, it must
More details and analysis has been added regarding typical on/off-site improvements. p.74-75

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January 23, 2023 Packet Pg. 1302

EXHIBIT B
Findings Responding to Letter from Department of Housing and Community Development Dated January 6, 2023 identify typical subdivision level
improvement requirements, such
as minimum street widths (e.g., 40-
foot minimum street width).

On-/Off-Site Improvements
Due to the built-out character of San Carlos, the City typically requires only minimal on-and off-site improvements as a condition of approval for new residential development. Most new housing development occurs on existing lots that are already served by necessary infrastructure. The City of San Carlos requires that developers complete certain minimum site improvements in conjunction with new housing development. Required on-site improvements include grading and installation of water, sewer, storm drainage, storm drainage retention, gas, electricity and cable utilities. Required off-site improvements include curbs, gutters, sidewalks, sewer lateral, drainage structures, full street sections, and street lighting. The City also requires that developers install landscaping and irrigation systems when necessary.

Per the City of San Carlos subdivision ordinance, proposed new streets in subdivisions must meet the specific size standards articulated in the Subdivisions Ordinance. (Given the built-out nature of San Carlos, very few developments require construction of new streets.) The Ordinance allows for a minimum width of two lanes with sidewalks for a total width of 50 feet, to allow space for on street parking and adequate pedestrian accommodations. Alleys may be 30 feet in width. Some developers have proposed privately maintained streets and alleys as narrow as 20 feet. For example, a project is currently proposed at 308-310 Phelps that would construct nine single family homes accessed via a 20-foot wide private road. At 2811 San Carlos Avenue, 11 new single-family homes were approved and constructed with a 25-foot wide private street. 808 Alameda de las Pulgas (not yet approved) is proposed with one 50-foot-wide public roadway central to the development and several private streets ranging from 21 feet to 30 feet in width to access 87 units. The City of San Carlos will consider such proposals provided that adequate access is provided for fire safety.

The on- and off-site improvement standards imposed by the City are typical for most communities and do not pose unusual constraints for housing development. The community is entirely built-out and as such, new development is not required to complete vast infrastructure improvements. Conditions of approval to complete on- and off-site improvements are provided to applicants in a timely manner and do not have a significant impact on project timing. While these improvements may increase the cost of production, adequate sewer, water, and street infrastructure is a necessary component of a healthy and productive city. These costs are not considered excessive and often represent a small fraction of a project’s development costs. Developers have not indicated that on- or off-site improvements are a significant constraint. Based upon recent proposals submitted, approved, and constructed by the development community for a variety of housing sites throughout San Carlos, off-site improvements required for housing development are not considered a constraint on housing development.

Codes and Enforcement: While the
element describes the City’s
building code modifications, it must
analyze whether they are a
More details and analysis has been added regarding typical on/off-site improvements. p.78-79 The City has adopted minor modifications to both the California Building Code and the California Green Buildings Standards Code. The California Building Code modifications include administrative and technical modifications that are related to fences and lattice, retaining walls, and construction methods for concrete structures. Modifications to the California Green Buildings Standards Code related to one- and two-family dwellings expand the code’s

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January 23, 2023 Packet Pg. 1303

EXHIBIT B
Findings Responding to Letter from Department of Housing and Community Development Dated January 6, 2023 constraint on development. In
addition, the element must
describe the City’s building and
zoning code enforcement
processes and procedures,
including whether code
enforcement is targeted or
complaint based, and analyze the
impact as potential constraints on
housing supply and affordability.
scope to include “Residential Reconstruction projects” in addition to new projects. Developers have not indicated that these minor revisions constitute a constraint. Several affordable and market rate projects have been developed under the revised Building Code and have not been impacted by these revisions.

Enforcement of the adopted codes focuses primarily on review of new construction proposals to ensure that they comply with minimum health and safety standards. The City of San Carlos’s Building Division and the San Carlos Fire Department provide inspection and review to ensure all development projects comply with Building Codes. Like many jurisdictions, San Carlos’s resources to mount proactive code enforcement are limited.

The City achieves code compliance through complaint based measures. Residents may register suspected code violations to the Building Department for further investigation and inspection by phone, email, or through an online portal. . The Building Department also maintains a shared agreement with the County of San Mateo to address these complaints. The City’s proactive code compliance is provided through aAdditional compliance checks that are administered by the City’s Apartment Inspection Program to ensure proper maintenance and safety for occupants of residential units in San Carlos. As part of this program, building officials conduct inspections of residential rental buildings at least once every two years or whenever necessary to remedy ongoing Code violations. Typical items checked by the program include site conditions, electrical, plumbing, mechanical, water heaters, and housing code violations. If any violations are found during the inspection, the property owner will work with building officials to correct any issues within 30 days of receipt of the correction notice. The enforcement of these codes does not add significantly to the cost of housing. These regulations help guard against the deterioration of residential properties, which helps protect the condition of existing housing stock and ongoing availability.

Constraints on Housing for Persons
with Disabilities: While the element
describes the City’s reasonable
accommodation procedure and
lists required findings of approval,
several findings appear to be
constraints and the element must
analyze those findings as potential
constraints on housing for persons
with disabilities. For example, the
procedure appears to have a
variance finding as well as other
potentially burdensome findings
such as provision in the RS District.

More analysis has been added regarding reasonable accommodations p.85-86 The City adopted a reasonable accommodation ordinance in 2011 (Chapter 18.33 - Waivers of the San Carlos Municipal Code). This chapter outlines applicability, procedures, required findings, conditions of approval, and appeals in the process of applicants obtaining waivers and a reasonable accommodations. Applications are reviewed for approval by the Planning Director. The City allows for waivers of 10 percent from standards for any project that can meet required findings: Required findings include:
• The waiver is necessary due to the physical characteristics of the property and the proposed use or structure or other circumstances, including, but not limited to, topography, noise exposure, irregular property boundaries, or other unusual circumstance. • There are no alternatives to the requested waiver that could provide an equivalent level of benefit to the applicant with less potential detriment to surrounding owners and occupants or to the general public. • The granting of the requested waiver will not be detrimental to the health or safety of the public or the occupants of the property or result in a change in land use or density that would be inconsistent with the requirements of this title.

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January 23, 2023 Packet Pg. 1304

EXHIBIT B
Findings Responding to Letter from Department of Housing and Community Development Dated January 6, 2023 In addition, while the element
allows for group homes of six or
fewer residents in all zones
allowing residential uses, the City
imposes additional constraints
including, but not limited to,
spacing requirements and
licensing. The element should
evaluate these requirements as
constraints and include specific
commitment to amend zoning and
permit procedures to allow these
uses in all residential zones with
objectivity to facilitate approval
certainty.
• In the RS districts, the review authority must also make the following findings in addition to any other findings that this chapter requires:
o There are exceptional or extraordinary circumstances related to the design of the existing house or Uniform Building Code compliance or other code compliance that make it difficult of impossible to enlarge the house within the base requirements, and the addition is of superior design quality and compatible with the existing neighborhood character; o The change is only intended to increase the habitability and function of the structure; o Granting the waiver is desirable for the preservation of an existing architectural style or neighborhood character which would not otherwise be accomplished through the strict application of the provisions of the regulations; and o It can be demonstrated that the design of the proposed addition is of superior quality; compatible with the existing neighborhood character, effective in minimizing the perceived size of the dwelling, not overly intrusive to the privacy of neighboring dwellings and is in substantial compliance with the RS district regulations.

1. If the request for accommodation is to provide fair access to housing, the following findings are required:
• That the housing or other property which is the subject of the request for reasonable accommodation will be used by an individual or organization entitled to protection;

2. If the request for accommodation is to provide fair access to housing, that That the request for accommodation is necessary to make specific housing available to an individual protected under State or Federal law; • That the conditions imposed, if any, are necessary to further a compelling public interest and represent the least restrictive means of furthering that interest; and
• That denial of the requested waiver would impose a substantial burden on religious exercise or would conflict with any State or Federal statute requiring reasonable accommodation to provide access to housing.

3. The first set of findings identified above (for waivers) do not apply to reasonable accommodation requests. Only the second set of findings apply to reasonable accommodation requirements. The finding pertaining to a “compelling public interest” allows for subjectivity in the approval of a reasonable accommodation request, which could pose as a constraint for persons with disabilities. Action HOU-5.5 is included in the housing plan to review and modify as necessary to remove subjectivity within the approval findings.

The following revisions have been made to Action HOU-5.5

8.b
January 23, 2023 Packet Pg. 1305

EXHIBIT B
Findings Responding to Letter from Department of Housing and Community Development Dated January 6, 2023 • Review the Zoning Ordinance and identify amendments to ensure findings for reasonable accommodation requests are limited to health and safety considerations and those allowed by State law.

Timeframe: Ongoing; complete a study on zoning needs for home sharing and universal design and bring to City Council for consideration in 2025; review the Reasonable Accommodation Ordinance and bring appropriate amendments to the City Council for hearing by December 2024 More analysis has been added regarding group homes and residential care facilities p.83-84 Additionally, parking requirements for General and Senior Residential Care Facilities differ from those of single and multi-family residential developments as they are based on the number of employees rather than units. Limited Residential Care Facilities follow the same parking standards as the base requirement. Imposing differing development standards, such as parking or minimum distance between facilities, than those required for other similar residential uses within the same zone can be a constraint on housing for persons with disabilities. Action HOU-5.3 is included in the Housing Plan to review and revise development standards for residential care facilities and group homes to ensure the same standards are required for these uses as other residential uses of the same type in the same zone.

The following revisions have been made to Action HOU-5.3 • Review and modify development standards for residential care facilities and group homes to ensure the same standards apply for these uses as other residential uses of the same type in the same zone, specifically standards related to parking requirements and distancing between similar facilities. No additional parking shall be required for group residential and residential care facilities above what is required for residential uses.

Remove any subjectivity in any standards or required findings to ensure residential care facilities and group homes are allowed objectively with approval certainty.

Timeframe: Amend the Zoning Ordinance in 2023 to allow group homes as a permitted use; coordinate with neighborhoods and nonprofit housing providers on an ongoing basis; amend the Zoning Ordinance by the end of 2023 to modify development standards for residential care facilities in conjunction with Action 4.4.

Other Local Ordinances: While the
element analyzes the City’s
The following clarifications have been made to the discussion on locally adopted ordinances. p.75

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January 23, 2023 Packet Pg. 1306

EXHIBIT B
Findings Responding to Letter from Department of Housing and Community Development Dated January 6, 2023 affordable housing ordinance, it
must analyze any other locally
adopted ordinances that directly
impacts the cost and supply or
residential development (e.g., short
term rentals, growth controls,
crime free ordinances).

The only locally adopted ordinance that directly impacts the cost and supply of housing is the City of San Carlos Below Market Rate Housing Program.

The City does not have a short-term rental ordinance, growth controls, crime free ordinances, or similar programs and regulations.

B. Housing Programs

1. Include a program which sets forth a schedule of actions during the planning period, each with a timeline for implementation, which 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... (Gov. Code, § 65583, subd. (c).) To address the program
requirements of Government Code
section 65583, subdivision (c)(1-6),
and to facilitate implementation,
programs should include: (1) a
description of the City’s specific
role in implementation; (2)
definitive implementation
timelines (e.g., at least annually, by
2025); (3) objectives, quantified
where appropriate; and (4)
identification of responsible
agencies and officials. Programs to
be revised include the following:
• Program HOU-1.2 (Residential
Rehabilitation Programs): The
program should be revised to
include proactive outreach
throughout the planning period.

Program HOU-1.2 has been revised to include proactive outreach throughout the planning period.

ACTION HOU-1.2
Residential Rehabilitation Programs.
• As CDBG funds are available through San Mateo County Consortium, provide grants or loans to low- and moderate-income households for the rehabilitation of residences. Examples of eligible repairs and improvements include but are not limited to energy efficiency and water conservation improvements, removal of impediments and material barriers that obstruct accessibility, roofing, plumbing repairs, electrical repairs, exterior painting, window replacement, seismic and flooding safety repairs/adaptations, and climate resiliency adaptations. • Promote the availability of home repair services for low-income and special needs households available from private agencies in the county. • The City will proactively outreach to low- and moderate-income households regarding available grants or loans for residential rehabilitation throughout the planning period.

Timeframe: Continue to participate in the San Mateo County Consortium; add information on home repair organizations to the City’s website in 2024, meet with affordable housing developers in 2024 to discuss rehabilitation opportunities; engage in proactive outreach to low-and-moderate income households annually..

Responsible Agency: Housing and Planning Divisions
Funding Sources: Community Development Department Budget, CDBG, San Mateo County Consortium

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January 23, 2023 Packet Pg. 1307

EXHIBIT B
Findings Responding to Letter from Department of Housing and Community Development Dated January 6, 2023 • Program HOU-1.3 (Preservation
of At-Risk Housing): The program
timeframe should be revised to
include annual monitoring.
• Program HOU-3.4 (First-time
Homebuyer Programs): The
program should address how often
outreach and education to
residents will occur throughout the
planning period.
• Program HOU-3.8 (Replacement
of Units on Sites): The program
should be revised to specify when
the program will be implemented.
• Program HOU-3.10 (AntiDisplacement Strategies): The
program should commit to
implementation actions beyond
“explore” to ensure beneficial
impact during the planning period.
• Program HOU-3.12 (Reduce costs
of Affordable and Special Needs
Housing): The program must clarify
whether the fee waivers are in
place. If the City needs to
implement the fee waivers, a
specific timeframe for
implementation must be included.

Program HOU-1.3 has been revised to include annual monitoring.

ACTION HOU-1.3
Preservation of At-Risk Housing. Retention of subsidized (i.e., assisted) housing is a critical part of maintaining the supply of affordable housing in San Carlos. San Carlos will continue to monitor the affordability of existing deed-restricted units and coordinate with property owners to encourage the retention of affordability of these units. At this time, San Carlos has no units at-risk of converting to market rate in the next ten years; however, programs are included in the unforeseen event that affordable units become at-risk during or immediately following the Housing Element period. • Annually monitor the affordability status of at-risk rental units. • Maintain and update the City’s list of nonprofit and community-based organizations to contact regarding possible ownership and management of the at-risk units if they are in imminent risk of conversion. • In the event a project becomes at risk of converting to market-rate housing, work with property owners or other interested non-profit housing providers to preserve the units as affordable housing.

Timeframe: Ongoing; Annually monitor/report the affordability status of at-risk rental units as part of the Annual Progress Report process; Contact owners with expiring covenants two years in advance of the expiring covenant Responsible Agency: Economic Development and Housing Divisions Funding Sources: Community Development Department Budget Program HOU-3.4 has been revised to include how often outreach and education will occur.

ACTION HOU-3.4
First-time Homebuyer Programs. Direct prospective first-time homebuyers to HEART or other County programs intended for first time homebuyers.

Encourage the use of these programs though annual outreach and education. Maintain and provide information on local BMR ownership units that are resold.

Timeframe: Ongoing; update information on the City’s website at least annually; conduct outreach annually to direct prospective first-time homebuyers to available resources.

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January 23, 2023 Packet Pg. 1308

EXHIBIT B
Findings Responding to Letter from Department of Housing and Community Development Dated January 6, 2023 Responsible Agency: Economic Development and Housing Divisions Funding Sources: Community Development Department Budget Program HOU-3.8 has been revised to indicate when the program will be implemented.

ACTION HOU-3.8
Replacement of Units on Sites. Pursuant to Government Code §65583.2(g)(3), require the replacement of units affordable to the same or lower income level as a condition of any development on a nonvacant site identified in the Housing Element consistent with those requirements set forth in Government Code §65915(c)(3). Replacement requirements shall be required for sites identified in the inventory that currently have residential uses, or within the past five years have had residential uses that have been vacated or demolished, and:
• Were subject to a recorded covenant, ordinance, or law that restricts rents to levels affordable to persons and families of low- or very low-income; or
• Subject to any other form of rent or price control through a public entity’s valid exercise of its police power; or • Occupied by low- or very low-income households
For the purpose of this program “previous five years” is based on the date the application for development was submitted.

Pursuant to Government Code §66300(d) (Chapter 654, Statutes of 2019 (SB 330)), the City shall not approve a housing development project that will require the demolition of residential dwelling units regardless of whether the parcel was listed in the inventory unless a) the project will create at least as many residential dwelling units as will be demolished, and b) certain affordability criteria are met.

To provide clarity in the development process, the City will modify the Zoning Ordinance to reference these requirements.

Timeframe: OngoingRoutinely as part of the housing development approval process, require replacement of any of units if (a) they are planned to be demolished for purposes of building new housing, and (b) they are determined to be occupied by low-income households, require the provision of assistance to prevent displacement of lower-income households due to loss of affordable units. Draft an amendment to the Zoning Ordinance to implement/reference replacement requirements of State law and bring to hearings by 2024.

Responsible Agency: Planning Division
Funding Sources: Community Development Department Budget Program HOU-3.10 has been revised to go beyond exploring and commit to specific actions.

8.b
January 23, 2023 Packet Pg. 1309

EXHIBIT B
Findings Responding to Letter from Department of Housing and Community Development Dated January 6, 2023 ACTION HOU-3.10
Anti-Displacement Strategies. The City will take the following actions to reduce displacement risk due to discriminatory actions:
• Fair Housing Counseling. Ensure all tenants have access to legal counseling, and landlords are aware of their rights and responsibilities. Support coordination of biannual workshops for landlords and property managers on discriminatory practices, reasonable accommodation requirements, and resources and an annual presentation to staff on fair housing practices, beginning in 2023. • Rental Audits. Provide support to fair housing providers to continue to conduct annual audits of housing providers to ensure compliance with fair housing laws.
• Fair Housing Case Monitoring. In 2027, upon completion of 2 iterations of biannual landlord and property manager workshops and 4 consecutive rental audits, meet with local fair housing providers, including Project Sentinel, to assess effectiveness of fair housing programs and identify additional strategies if needed.
• Fair Housing Outreach Program. Include information or links to information on the City’s website in 2023 (with annual updates) and provide printed informational materials in City buildings with information on the fair housing counseling program, tenant protections, and other resources to reduce displacement risk.
• Additional Strategies. Based on the above efforts, if additional strategies are required, conduct a study to Eexplore the following strategies to minimize resident displacement: implementing
• Additional tTenant protection policies and
• Ssupport local efforts to create a community land trust or a housing preservation fund Timeframe: Refer to individual bullets for specific timeframes. Consult with tenants’ rights advocates and stakeholders, complete analysis, and hold a hearing with City Council to adopt anti-displacement strategies by 2026 Responsible Agency: Planning, Economic Development, and Housing Divisions Funding Sources: Community Development Department Budget

8.b
January 23, 2023 Packet Pg. 1310

EXHIBIT B
Findings Responding to Letter from Department of Housing and Community Development Dated January 6, 2023 Program HOU-3.12 has been revised to clarify the City already has fee waivers in place.

ACTION HOU-3.12
Reduce Costs Associated With The Development Of Affordable and Special Needs Housing. The City defers and waives fees for affordable housing developments to provide local match contributions and facilitate projects. The City will continue to rReduce or waive development impact fees to facilitate 100% affordable and special needs housing, including housing for extremely low-income and persons living with disabilities (including persons with developmental disabilities).

Timeframe: Ongoing
Responsible Agency: Planning Division
Funding Sources: Community Development Department Budget

2. Identify actions that will be taken to make sites available during the planning period with appropriate zoning and development standards and with services and facilities to accommodate that portion of the city’s or county’s share of the regional housing need for each income level that could not be accommodated on sites identified in the inventory completed pursuant to paragraph (3) of subdivision (a) without rezoning, and to comply with the requirements of Government Code section 65584.09. Sites shall be identified as needed to facilitate and encourage the development of a variety of types of housing for all income levels, including multifamily rental housing, factory-built housing, mobilehomes, housing for agricultural employees, supportive housing, single-room occupancy units, emergency shelters, and transitional housing. (Gov. Code, § 65583, subd. (c)(1).) As noted in Finding A3, the element
does not include a complete site
analysis; therefore, the adequacy
of sites and zoning were not
established. Based on the results of
a complete sites inventory and
analysis, the City may need to add
or revise programs to address a
shortfall of sites or zoning available
to encourage a variety of housing
types. In addition, the element
should be revised as follows:

Program HOU-2.1 has been revised to include specific implementation for small lot incentives.

ACTION HOU-2.1
Small Lot Development and Lot Consolidation Incentives—Citywide. As taller and denser housing developments are constructed as a result of the City Density Bonus and revisions to the Zoning Ordinance, determine whether additional incentives are necessary for the development of small and oddshaped lots and/or lot consolidation. Incentives could include:
• Rounding up when calculating allowable units to encourage lot consolidation. • Providing technical assistance, such as land development counseling by Community Development staff, with consolidation or development of small and odd-shaped lots.

8.b
January 23, 2023 Packet Pg. 1311

EXHIBIT B
Findings Responding to Letter from Department of Housing and Community Development Dated January 6, 2023 • Program HOU-2.1 (Small Lot
Development Incentives –
Citywide): The program should be
revised to include specific
implementation for small lot
incentives and list potential
incentives to be implemented. In
addition, the program should
include proactive outreach to
developers.
• Program HOU-2.2 (Small Lot
Development Incentives –
Downtown): The timeframe should
be revised to be specific (e.g., by
2025) because there is such a
strong reliance on small lot
consolidation and especially given
the apparent lack of effectiveness
in the prior planning period. In
addition, the program should
clarify whether the City will offer
incentives to consolidate small lots.
• Program HOU-3.11 (Access to
Opportunity): The program should
be revised to amend the ordinance
as necessary to comply with state
law and include proactive outreach
to owners and developers to
promote SB 9.
• Conduct proactive outreach by advertising lot consolidation and potential site opportunities to existing property owners and prospective developers. Advertising efforts may include the preparation and distribution of a brochure with information about program incentives and an invitation to attend a working session to discuss opportunities for lot consolidation or the development of small and odd-shaped lots. • Providing priority processing for affordable housing and projects that exceed minimum BMR requirements. • Continue to provide fee deferrals and waivers for 100% affordable housing projects.

Timeframe: Ongoing; conduct a review to assess the City Density Bonus and density, height, and parking standards in the Zoning Ordinance in 2025; as needed identify additional incentives and present options to Council in 2026; review this action item on an annual basis to evaluate its effectiveness and make recommendations as needed; conduct proactive outreach annually.

Responsible Agency: Planning Division
Funding Sources: Community Development Department Budget Program HOU-2.2 has been revised to indicate a specific timeframe and specific incentives for lot consolidation.

ACTION HOU-2.2
Small Lot Development and Lot Consolidation Incentives—Downtown. As part of the 2022-2024 Downtown Specific Plan project, identify new incentives for small lot development and/or lot consolidation. The program may include incentives for small lots such as:
• Increasing allowable zoning density
• Relaxed development standards (including parking reductions for small lots) • Streamlined permitting process
• City financial contributions, as well as other density bonuses, incentives and concessions that are otherwise required by State density bonus law for the provision of higher levels of affordable housing.

8.b
January 23, 2023 Packet Pg. 1312

EXHIBIT B
Findings Responding to Letter from Department of Housing and Community Development Dated January 6, 2023 • Rounding up when calculating allowable units to encourage lot consolidation. • Providing technical assistance, such as land development counseling by Community Development staff, with consolidation or development of small and odd-shaped lots.
• Conduct proactive outreach by advertising lot consolidation and potential site opportunities to existing property owners and prospective developers. Advertising efforts may include the preparation and distribution of a brochure with information about program incentives and an invitation to attend a working session to discuss opportunities for lot consolidation or the development of small and odd-shaped lots. • Providing priority processing for affordable housing and projects that exceed minimum BMR requirements. • Continue to provide fee deferrals and waivers for 100% affordable housing projects.

Timeframe: Adopt a new Downtown Specific Plan with small lot development incentives by Decemberin 2025; review this action item on an annual basis to evaluate its effectiveness and make recommendations as needed; conduct proactive outreach annually Responsible Agency: Planning Division
Funding Sources: Community Development Department Budget Program HOU-3.11 has been revised to amend the ordinance as necessary to comply with state law.

ACTION HOU-3.11
Access to Opportunity. Noting historical inequities amplified/perpetuated by single family zoning, encourage small units in residential neighborhoods through development of ADUs, JADUs, and SB 9 units.
• See Action HOU-3.3 for specific measures to incentivize ADUs in San Carlos. • Review the City’s Zoning Ordinance and Subdivision Ordinance and implement updatesamend as needed to provide clarity and facilitate housing development under SB 9 in compliance with State law. These include adopting updated definitions, use regulations, development standards, and

8.b
January 23, 2023 Packet Pg. 1313

EXHIBIT B
Findings Responding to Letter from Department of Housing and Community Development Dated January 6, 2023 ministerial processes based on the outcome of a complete SB 9 analysis. As revisions to State law occur in the future, update the City’s Zoning Ordinance and Subdivision Ordinance accordingly.

Timeframe: Bring SB 9 ordinance for consideration by City Council in Fall 2023. Production and affordability will be monitored every two years thereafter and alternative actions will be implemented if necessary to meet the RHNA. Conduct proactive outreach to housing developers and property owners to promote the SB 9 ordinance through information on the City’s website, the Good City newsletter (mailed to all property owners and renters), at least two times during the planning period
Responsible Agency: Planning Division
Funding Sources: Community Development Department Budget

3. The Housing Element shall contain programs which assist in the development of adequate housing to meet the needs of extremely low-, very low-, low- and moderate-income households. (Gov. Code, § 65583, subd. (c)(2).)
Program HOU-3.1 (Funding Low,
Very Low, and ELI and Special
Needs Housing): While the
program states it will address
special needs groups, it should
specify what actions will be taken
to assist ELI and special needs
households. In addition, the
program should commit to how
often the City will apply for funding
as well as include proactive
outreach.

Program HOU-3.1 has been revised to include specific action for different special needs groups ACTION HOU-3.1
Housing Options for Special Needs and Extremely-Low Income Households. Extremely low-income households and households with special needs have limited housing options. To meet the needs of special needs groups, innovative housing options should also be implemented. • Funding Low, Very Low, and Extremely Low-Income and Special Needs Housing. Continue to apply the commercial/housing linkage fee to fund affordable housing and monitor fee amount to ensure it reflects market conditions. Encourage concurrent production of on or off-site affordable housing, in lieu of fee payment. Collaborate with existing and new major employers to encourage the development and funding of more affordable housing. Monitor and pursue county, state, and federal funding programs and sources for the creation of affordable housing. • Offer financial and technical assistance for housing development projects for persons with special needs. • As part of the Housing Element Annual Progress Report, track and report the number of new affordable housing units providing a preference for people with special needs, including seniors, homeless, people with developmental disabilities, etc. that are added to the housing stock each year.

8.b
January 23, 2023 Packet Pg. 1314

EXHIBIT B
Findings Responding to Letter from Department of Housing and Community Development Dated January 6, 2023 • Monitor and pursue county, state, and federal funding programs and sources for the creation of affordable housing. Prioritize available housing funding to assist in the development of housing affordable to extremely low-income households and other special needs populations. Conduct annual proactive outreach to identify development opportunities and funding and incentives for special needs housing. • Proactively contact non-profit service providers and developers for persons with disabilities and other special needs groups and notify them about funding opportunities, as they become available.
• Continue to consult with the San Mateo County Center on Homelessness to further align efforts and coordinate homeless services.

Timeframe: Ongoing; re-evaluate opportunities for construction in-lieu of fee payment in 2024; collaborate with city’s 10 largest employers at least every other year; annually monitor and pursue funding and pursue opportunities through county, state, and federal funding programs and sources to leverage City funds; offer funding and technical assistance to projects as they are proposed, acquire property, or issue a Notice of Funding Availability when sufficient funds are acquired; conduct proactive outreach to identify development opportunities, funding, and incentives for housing affordable to extremely low-income and other special needs households and report annually through the Housing Element Annual Report.

Responsible Agency: Planning, Economic Development, and Housing Divisions Funding Sources: Community Development Department Budget, San Carlos Housing Authority, City of San Carlos BMR Funds

4. Address and, where appropriate and legally possible, remove governmental and nongovernmental constraints to the maintenance, improvement, and development of housing, including housing for all income levels and housing for persons with disabilities. The program shall remove constraints to, and provide reasonable accommodations for housing designed for, intended for occupancy by, or with supportive services for, persons with disabilities. (Gov. Code, § 65583, subd. (c)(3).) As noted in Finding A4, the element
requires a complete analysis of
potential governmental
constraints. Depending upon the
results of that analysis, the City
may need to revise or add
programs and address and remove
or mitigate any identified
constraints. In addition, the
element should be revised as
follows:

Program HOU-3.3 has been revised to include a specific commitment to update the City’s ADU ordinance to comply with state law.

ACTION HOU-3.3
Facilitate the Legalization and Construction of Accessory Dwelling Units (ADUs). • Support the development of accessory dwelling units during the planning period and as new State laws modify accessory dwelling unit requirements, update the City’s ordinance to comply. The City last updated its ADU ordinance in August 2022. The City will draft amendments to address laws passed in 2022, including AB 2221 and SB 897 to reflect an up-to-date ordinance compliant with Government Code Section 65852.2. • Collaborate with surrounding jurisdictions through the 21 Elements working group to determine best approach for tracking affordability throughout the planning period.

8.b
January 23, 2023 Packet Pg. 1315

EXHIBIT B
Findings Responding to Letter from Department of Housing and Community Development Dated January 6, 2023 • Program HOU-3.3 (Facilitate the
Legalization and Construction of
ADUs): HCD’s records indicate that
the City has not updated it’s
Accessory Dwelling Unit (ADU)
ordinance to comply with recent
state law from 2020-2023. The
element must include a specific
commitment to update the City’s
ADU ordinance to be compliant
with state law.
• Program HOU-4.1 (Adequate
Sites): While this program seems to
commit to actions to rezone to
accommodate the RHNA, the
program timing is ongoing. The
program must include specific
implementation dates for
establishing the new multifamily
residential zone and upzoning of
the mixed-use zones. In addition,
the program must clarify actions
that will be taken to encourage
senior housing and housing for
persons with special needs.
• Program HOU-4.2 (Zoning
Ordinance Revisions): The program
should clarify whether the
proposed building heights along
East San Carlos Avenue and in the
• Encourage the legalization of unpermitted accessory dwelling units to better ensure that they are safe and habitable. As sunset date of San Carlos Municipal Code Section 18.23.210(H) approaches, consider an extension, based on history of use of this provision and anticipated ongoing need. • Work with other regional/agencies countywide partnerships to identify potential funding sources for ADU construction. • Meet with three or four ADU builders to discuss needs and best practices. Review best practices from other cities for “pre-approved” ADUs and expedited review. Create submittal materials with documentation to facilitate expedited review. Update the City’s website and include links to “pre-approved” plans. Conduct ongoing outreach with community. • Review and as new information is available, update public education materials on accessory dwelling units, including planning and building requirements, streamline processing, funding possibilities, and other resources. • Encourage local agencies, districts, and utility providers to reduce hook-up or other fees to facilitate the development of accessory dwelling units. • Prioritize ADU applications to be consistent with Government Code Section 65852.2(a)(3) requirements for approval/denial within 60 days from the date a completed application is received.

Timeframe: Ongoing; update the ADU ordinance by June 2023; as new State laws modify accessory dwelling unit requirements, update the City’s ordinance within a timely manner (i.e., within six months); San Carlos Municipal Code Section 18.23.210(H) - 2028; work with 21 Elements – 2023; funding and pre-approved plans - 2024; establish priority process in development review in 2023 all others - Ongoing Responsible Agency: Planning and Building Divisions
Funding Sources: Community Development Department Budget Program HOU-4.1 has been revised to include a specific implementation dates and actions for senior housing and persons with special needs.

ACTION HOU-4.1
Adequate Sites to Meet Regional Fair Share of Housing Growth. The 2009 General Plan and accompanying 2011 Zoning Ordinance allows a variety of housing types, with densities ranging from one to six units per acre in single-family zoning districts, up to 59 units per acre along San Carlos Avenue, and up to 50 units to the acre in downtown San Carlos. In support of this 6th cycle Housing Element update, the City:

8.b
January 23, 2023 Packet Pg. 1316

EXHIBIT B
Findings Responding to Letter from Department of Housing and Community Development Dated January 6, 2023 RS district will allow three story
developments regardless of the 35-
foot height limit.
• Program HOU-4.4 (Objectivity
and Streamlining in Development
Regulations): The timing of this
program should be revised to
implement SB 35 requirements
earlier in the planning period.
• Program HOU-5.3 (Residential
Care Facilities and Group Homes):

While this program commits to
allowing group homes for seven or
more residents, it must include
specific commitment to amend
zoning and permit procedures to
allow these uses in all residential
zones with objectivity to facilitate
approval certainty similar to other
residential uses.
• Persons with Disabilities: as
noted in Finding A4, the City should
revise the reasonable
accommodations procedure to
mitigate identified constraints on
housing for persons with
disabilities.
• proposes to create a new multifamily residential zoning category allowing a net density of up to 100 units per acre and proposes to increase mixed use densities up to 120 units per acre, and
• developed a parcel-specific inventory of sites suitable for future residential development The City will:
• Continue to provide appropriate land use designations and zoning districts consistent with regional housing needs. • Maintain an inventory of potential sites to provide to developers in conjunction with information on development incentives for affordable units. • As part of the Housing Element annual reporting process, evaluate project development against the sites inventory to ensure compliance with Government Code §65863.
• Continue to pursue implementation of the General Plan through completion and adoption of implementing zoning regulations and specific plans. • Encourage senior housing and housing suitable for persons with disabilities and other special needs (including assisted living). See Action HOU3.1 for specific commitments to encourage senior and other special needs housing.

Timeframe: Ongoing; Establish new multifamily residential zones and upzoning of mixed-use zones as part of the Zoning Ordinance revisions to be adopted by January 2023
Responsible Party: Planning Division
Funding Sources: Community Development Department Budget Program HOU-5.5 has been revised to include updates to the City’s reasonable accommodations procedures.

ACTION HOU-5.5
Revised Development Standards to Support Special Needs Housing. • Consider amending the Zoning Ordinance to clarify that development standards that allow for separate cooking and/or bathroom facilities in home sharing programs, and universal design (including “visitability”) in all new residential development and significant remodeling projects.

8.b
January 23, 2023 Packet Pg. 1317

EXHIBIT B
Findings Responding to Letter from Department of Housing and Community Development Dated January 6, 2023 • Encourage the development of well-designed new accessory dwelling units in existing neighborhoods by implementing objective standards for the approval of accessory units. Include an ADA accessible design option in pre-approved ADU plans. • Encourage unhoused service or navigation centers to be located within or near SROs, transitional, and or/supportive housing. • Review the Zoning Ordinance and identify amendments to ensure findings for reasonable accommodation requests are limited to health and safety considerations and those allowed by State law.

Timeframe: Ongoing; complete a study on zoning needs for home sharing and universal design and bring to City Council for consideration in 2025; review/revise the Reasonable Accommodation Ordinance and bring appropriate amendments to the City Council for hearing by December 2024 Responsible Agency: Planning Division
Funding Sources: Community Development Department Budget

5. Promote and affirmatively further fair housing opportunities and promote housing throughout the community or communities for all persons regardless of race, religion, sex, marital status, ancestry, national origin, color, familial status, or disability, and other characteristics... (Gov. Code, § 65583, subd. (c)(5).) As noted in Finding A1, the element
requires a complete AFFH analysis.

Depending upon the results of that
analysis, the City may need to
revise or add or modify goals and
actions. Goals and actions must
specifically respond to the analysis
and to the identified and prioritized
contributing factors to fair housing
issues and must be significant and
meaningful enough to overcome
identified patterns and trends.

Actions must have specific
commitment, milestones,
geographic targeting and metrics or
Program HOU-6.1 has been revised to include metrics, milestones, geographic targeting, and specific timing for each action.

Table 4.2-2: Affirmatively Furthering Fair Housing Issues, Contributing Factors, and Actions

8.b
January 23, 2023 Packet Pg. 1318

EXHIBIT B
Findings Responding to Letter from Department of Housing and Community Development Dated January 6, 2023 numerical targets and, as
appropriate, address housing
mobility enhancement, new
housing choices and affordability in
higher opportunity or higher
income areas, place-based
strategies for community
preservation and revitalization and
displacement protection.

In addition, Program HOU-6.1
(Affirmatively Furthering Fair
Housing) must include specific
timing for outreach and updating
the City’s website regarding AFFH
information. The table must also
include metrics, milestones, and
geographic targeting for each
action as appropriate to address
identified fair housing constraints.

Identified Fair Housing Issue and
Priority
(High, Medium, Low)
Contributing Factors Meaningful Actions
Insufficient and Inaccessible
Housing Options in High
Opportunity AreaCitywide for
people who identify with any
protected class
(Fair Housing Education,
Housing Mobility)
Priority: [High]
• Location and type of affordable housing
• Lack of access to opportunity due to high
housing cost
• Lack of fair housing outreach and
enforcement
• Availability of affordable housing
• Availability of affordable units in a range
of sizes.

Fair Housing Education
• Continue to support local agencies and organizations
that provide fair housing services to San Carlos
residents.

Geographic Target: Citywide
Timeframe: Annually through the San Mateo County
Consortium, which distributes CBDG funding.
2023-2031 Metrics: Track funding support to fair
housing providers through the County’s Annual
Action Plan
• Include a fair housing presentation in City Council
meetings. and continue to educate and train City staff
regarding fair housing laws. As appropriate, partner
with organizations such as Project Sentinel to provide
resources.

Timeframe: at least once every other year.

Geographic Target: Citywide
2023-2031 Metrics: Provide an annual fair housing
presentation to Council and biennially provide fair
housing training for staff involved in housing
• Ensure that all development applications are
considered, reviewed, and approved without
prejudice to the proposed residents, contingent on

8.b
January 23, 2023 Packet Pg. 1319

EXHIBIT B
Findings Responding to Letter from Department of Housing and Community Development Dated January 6, 2023 the development application’s compliance with all
entitlement requirements.

Timeframe: Ongoing
Geographic Target: Citywide
2023-2031 Metrics: At random audit two applications
per year to ensure compliance
• Require non-discrimination clauses in rental
agreements and deed restrictions for affordable
housing.

Timeframe: Ongoing
Geographic Target: Citywide
2023-2031 Metrics: Each new and continued
affordable housing rental agreement/deed restriction
• Promote public awareness of federal, State, and local regulations regarding equal access to housing.

Provide information to the public on various state and
federal housing programs and fair housing law.

Maintain referral information on the City’s website
and at a variety of other locations such as community
and senior centers, local social service offices, in City utility bills, and at other public locations including City Hall and the library. Add resources and information in
Spanish and make available to the public. Continue to
coordinate with other agencies and organizations,
including 21 Elements, to identify other means of
informing residents about fair housing laws.

8.b
January 23, 2023 Packet Pg. 1320

EXHIBIT B
Findings Responding to Letter from Department of Housing and Community Development Dated January 6, 2023 Timeframe: four times per year as part of fair housing
workshops by Project Sentinel and other housing
related events.

Geographic Target: Citywide with focus on areas
northwest of El Camino Real and along San Carlos
Avenue with higher proportions of non-White
residents and north of Cherry Street and along El
Camino Real with higher proportions of people with
disabilities.
2023-2031 Metrics: Provide counseling and services to
at least four San Carlos residents during the planning
period
The three identified fair housing issues are closely related, as such, the meaningful action items address all issues.

Housing Mobility
• Require affordable housing developers receiving
public funds to prepare an affirmative marketing plan,
and encourage private developers with affordable
units in their projects to prepare affirmative marketing plans. The plan shall ensure marketing materials for
new developments are designed to attract renters
and buyers of diverse demographics, including
persons of any race, ethnicity, sex, handicap, and
familial status.

Timeframe: As part of the entitlement process

8.b
January 23, 2023 Packet Pg. 1321

EXHIBIT B
Findings Responding to Letter from Department of Housing and Community Development Dated January 6, 2023 Geographic Target: Residential and Mixed Use
neighborhoods citywide
2023-2031 Metrics: All affordable housing developers
receiving public funds should prepare an affirmative
marketing plan
• Action 3.2: Continue to implement the City’s Below
Market Rate (BMR) Ordinance requirements for rental
and homeownership development; establish a
process for granting priority permit processing status
for approved housing projects that exceed the City’s
minimum BMR requirement; Evaluate the BMR
Ordinance’s density bonuses, incentives, and
concessions to determine they continue to make the
production of affordable housing feasible. As part of
this process, consult with local non-profit affordable
housing developers to identify potential revisions that would better support development of affordable
housing, and especially Low-Income Housing Tax
Credit financed housing. Revise as necessary.

Timeframe: Ongoing; establish priority permit
processing in 2024; re-evaluate the BMR Ordinance in
2024 and update as needed
Geographic Target: Citywide, particularly in the City’s highest income areas
2023-2031 Metrics: Increase the development of
affordable housing units through the BMR Ordinance
by 15% of the baseline

8.b
January 23, 2023 Packet Pg. 1322

EXHIBIT B
Findings Responding to Letter from Department of Housing and Community Development Dated January 6, 2023 • Action HOU-3.3 (ADUs): Offer pre-approved plans,
which support streamlining the permit review process;
Promote additional pre-approved plans on the City’s
website; Provide homeowner/ applicant assistant tools
by including and promoting State funding resources
including the CalHFA ADU grant program and Casita
Coalition financing guide on the City’s website, and by promoting home sharing programs to connect ADU
owners and renters, and offering counseling with a
City staff-ADU specialist; Explore and pursue funding
options to support ADU construction for lowerincome homeowners Timeframe: Offer pre-approved plans no later than
2024; ongoing ADU development support; monitor
ADUs annually and implement alternative strategies
within one year of the annual report if assumptions
are not met.

Geographic Target: Single-family residential
neighborhoods citywide
2023-2031 Metric: Achieve 203 ADUs during the
planning cycle
• Action HOU-3.4: Proactively outreach to developers
and homebuyers regarding available homeownership
financing options.

Timeframe: Annually conduct outreach and education
efforts

8.b
January 23, 2023 Packet Pg. 1323

EXHIBIT B
Findings Responding to Letter from Department of Housing and Community Development Dated January 6, 2023 Geographic Target: Areas with residents who have
historically faced barriers to homeownership such as
areas in the northwest of El Camino Real and along
San Carlos Avenue with higher proportions of nonWhite residents; north of Cherry Street and along El Camino Real with higher proportions of people with
disabilities; and south of El Camino Real between
Holly Street and Arroyo Avenue with higher
proportions of low-to-moderate income households.
2023-2031 Metric: Provide homeownership financing
options and resource information to at least 10
residents annually
• Action 3.11: Noting historical inequities
amplified/perpetuated by single family zoning,
encourage small units in residential neighborhoods
through development of ADUs, JADUs, and SB 9
units.

Timeframe: Bring SB 9 ordinance for consideration by
City Council in Fall 2023. Production and affordability will be monitored every two years thereafter.

Geographic Target: Single-family neighborhoods
citywide
2023-2031 Metrics: Achieve 203 ADUs and 160 SB 9
duplex construction during the planning period
• Action 5.2: Discuss with developers the ability to
provide larger rental units appropriate for families

8.b
January 23, 2023 Packet Pg. 1324

EXHIBIT B
Findings Responding to Letter from Department of Housing and Community Development Dated January 6, 2023 with children, including the provision of supportive
services.

Timeframe: Ongoing (as projects are proposed)
Geographic Target: Multi-family residential
neighborhoods
2023-2031 Metrics: Complete at least one project that
includes these types of units and services during the
planning period
• Action 5.8: Promote fair housing by allowing multifamily residential uses on all sites in the P (Institutional Use) zone as an accessory use to allowed uses such
as onsite religious institutions and schools.

Reference/incorporate the minimum parking
prohibitions associated with AB 2097, effective
January 1, 2023, within 0.5 miles of public transit (as defined in AB 2097).

Timeframe: Amend Zoning Ordinance by 2023
Geographic Target: Institutional Use Zone
2023-2031 Metrics: Complete at least one multi-family
project in the Institutional Use Zone during the
planning period
Action Outcomes: An increased variety of housing options available to San Carlos residents throughout the city, including areas that have traditionally only had single-family ownership housing. Provide adequate sites for over 1,164 lower income households, over 438 moderate income households, and over

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EXHIBIT B
Findings Responding to Letter from Department of Housing and Community Development Dated January 6, 2023 1,133 above moderate income households, exceeding the
City’s RHNA requirements.Continue to support local agencies and organizations that provide fair housing services to San Carlos residents. Timeframe: Annually through the San Mateo County Consortium, which distributes CBDG funding.

Require non-discrimination clauses in rental agreements and deed restrictions for affordable housing. Timeframe: ongoing for each new and continued affordable housing rental
agreement/deed restriction
Promote public awareness of federal, State, and local
regulations regarding equal access to housing. Provide
information to the public on various state and federal housing programs and fair housing law. Maintain referral information on the City’s website and at a variety of other locations such as community and senior centers, local social service offices, in City utility bills, and at other public locations including City Hall and the library. Add resources and information in Spanish and make available to the public. Continue to coordinate with other agencies and organizations, including 21 Elements, to identify other means of informing residents about fair housing laws. Timeframe: four times per year as part of fair housing workshops by the Fair Housing Foundation and other housing related events.

Include a fair housing presentation in City Council meetings.

Continue to educate and train City staff regarding fair housing laws. As appropriate, partner with organizations such as

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January 23, 2023 Packet Pg. 1326

EXHIBIT B
Findings Responding to Letter from Department of Housing and Community Development Dated January 6, 2023 Project Sentinel to provide resources. Timeframe: at least once every other year.

Implement an accessibility policy that establishes standards and procedures for providing equal access to City services and programs to all residents, including persons with limited proficiency in English, and persons with disabilities. Timeframe:

By 2024
Ensure that all development applications are considered, reviewed, and approved without prejudice to the proposed residents, contingent on the development application’s
compliance with all entitlement requirements. Timeframe:

Ongoing
Continue to use the Rental Inspection Program as a tool to monitor and address fair housing issues. Timeframe: Ongoing Conduct public meetings at suitable times, accessible to persons with disabilities, and near public transit. Resources will be invested to provide interpretation and translation services when requested at public meetings. Timeframe: Ongoing
Prioritize community and stakeholder engagement during
controversial development decisions. Timeframe: Ongoing Continue to educate landlords on fair housing law, reasonable accommodations and disability rights, including posting reasonable accommodations on the website and at prominent location near the permit counter. Timeframe: Ongoing
Related actions in this Housing Plan meet multiple needs, including affirmatively furthering fair housing, including:

Action HOU-1.1: Rental Inspection Program

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January 23, 2023 Packet Pg. 1327

EXHIBIT B
Findings Responding to Letter from Department of Housing and Community Development Dated January 6, 2023 Action HOU-1.2: Residential Rehabilitation Programs
Action HOU-1.3: Preservation of At-Risk Rental Housing
Action HOU-3.1: Funding Low, Very Low-, and Extremely LowIncome and Special Needs Housing Action HOU-3.2: BMR Ordinance
Action HOU-3-3: Accessory Dwelling Units
Action HOU-3.4: First-Time Homebuyer Programs
Action HOU-3.5: Rental Voucher Program
Action HOU-3.10: Anti-Displacement Strategies
Action HOU-3.11: Access to Opportunity
Action HOU-3.12: Affordable and Special Needs Incentives Action HOU-4.1: Adequate Sites to Meet the RHNA
Action HOU-4.2: Zoning Ordinance Revisions
Action HOU-4.3: Outreach: New Development Standards
Action HOU-5.2: Large Rental Units and Supportive Services Action HOU-5.3: Residential Care Facilities and Group Homes Action HOU-5.4: Special Needs Service Providers
Contributions
Action HOU-5.5: Revised Development Standards to Support Special Needs Housing
Action HOU-5.6: Equal Access to City Services
Action HOU-5.7: Community Governance
Action HOU-5.8: Furthering Integration
Action HOU-6.1: Fair Housing Law Enforcement and
Discrimination Complaints
Action HOU-8.1: Partnership Programs

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January 23, 2023 Packet Pg. 1328

EXHIBIT B
Findings Responding to Letter from Department of Housing and Community Development Dated January 6, 2023 Protecting Existing Residents
from Displacement
(Displacement/Housing
Affordability)
Priority: [Moderate]
• Due to economic pressures
• Availability of affordable housing
• Availability of affordable units in a range
of prices
Displacement/Housing Affordability
• Action 1.1: Continue the Rental Inspection Program to preserve and improve existing housing stock and
neighborhood quality.

Timeframe: Annually
Geographic Target: Multi-family residential
neighborhoods
2023-2031 Metric: Conduct 240 inspection visits
annually
• Action 1.2: As CDBG funds are available through San
Mateo County Consortium, provide grants or loans to
low- and moderate-income households for the
rehabilitation of residences; Promote the availability of home repair services for low-income and special
needs households available from private agencies in
the county.

Timeframe: Annually or as funding becomes available
Geographic Target: Multi-family residential
neighborhoods and south of El Camino Real between
Holly Street and Arroyo Avenue with higher
proportions of low-to-moderate income households.
2023-2031 Metrics: Assist 2 low-to-moderate-income
households annually.
• Action 1.3: San Carlos will continue to monitor the
affordability of existing deed-restricted units and
coordinate with property owners to encourage the
retention of affordability of these units.

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EXHIBIT B
Findings Responding to Letter from Department of Housing and Community Development Dated January 6, 2023 Timeframe: Annually monitor/report the affordability
status of at-risk rental units as part of the Annual
Progress Report process; Contact owners with
expiring covenants two years in advance of the
expiring covenant.

Geographic Target: Multi-family residential
neighborhoods and areas south of El Camino Real
between Holly Street and Arroyo Avenue with higher
proportions of low-to-moderate income households.
2023-2031 Metric: Retain affordability of 137 units at
17 housing complexes
• Action 3.1: Continue to apply the commercial/housing
linkage fee to fund affordable housing and monitor
fee amount to ensure it reflects market conditions.

Encourage concurrent production of on or off-site
affordable housing, in lieu of fee payment.

Collaborate with existing and new major employers to
encourage the development and funding of more
affordable housing.

Timeframe: Re-evaluate opportunities for construction
in-lieu of fee payment in 2024; collaborate with city’s 10 largest employers at least every other year;
annually monitor and pursue funding opportunities
through county, state, and federal funding programs
and sources to leverage City funds
Geographic Target: Citywide

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EXHIBIT B
Findings Responding to Letter from Department of Housing and Community Development Dated January 6, 2023 2023-2031 Metric: Contribute to the production
and/or preservation of at least 60 affordable housing
units over the planning period
• Action 3.5: Continue to work with the San Mateo
County Department of Housing and nonprofit
organizations to implement Housing Choice Voucher
Rental Assistance programs. Continue to provide
information on the Housing Choice Voucher program,
including new legal requirements pursuant to SB 329,
which prohibits housing discrimination on the basis of
source of income (including Housing Choice
Vouchers). Continue to collaborate with other cities in San Mateo County, regional organizations, and/or
nonprofit organizations to evaluate and quantify
potential discrimination against Housing Choice
Voucher users or other rental assistance voucher
programs. Continue to develop and act upon
measures to address these issues.

Timeframe: Annually
Geographic Target: Citywide
2023-2021 Metrics: Annually reach 100 individuals, as
measured in website hits, providing information about
Housing Choice Vouchers
Action 3.10: Take actions to reduce displacement,
including fair housing counseling, rental audits, fair
housing case monitoring, outreach, and additional
tenant protection policies; Support local efforts to

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January 23, 2023 Packet Pg. 1331

EXHIBIT B
Findings Responding to Letter from Department of Housing and Community Development Dated January 6, 2023 create a community land trust or a housing
preservation fund
Timeframe: Consult with tenants’ rights advocates and
stakeholders, complete analysis, and hold a hearing
with City Council to adopt anti-displacement
strategies by 2026
Geographic Target: Multi-family residential
neighborhoods and areas south of El Camino Real
between Holly Street and Arroyo Avenue with higher
proportions of low-to-moderate income households.
2023-2031 Metric: Partner with a community-based
organization to provide residents with informational
materials and workshops on latest anti-displacement
strategies at least three times soon after adoption.
• Action 8.1: Continue to work with housing services
organizations, or other similar organizations, to
increase housing opportunities in San Carlos. Explore
partnerships with housing operators, non-profit
organizations, and developers to rehabilitate and
convert existing market rate rental housing into
affordable housing for extremely low, very low, low
and moderate-income households.
• Timeframe: Discuss opportunities with developers that contact the City annually
• Geographic Targeting: Multi-family residential
neighborhoods and areas south of El Camino Real

8.b
January 23, 2023 Packet Pg. 1332

EXHIBIT B
Findings Responding to Letter from Department of Housing and Community Development Dated January 6, 2023 between Holly Street and Arroyo Avenue with higher
proportions of low-to-moderate income households.
• 2023-2031 Metric: Develop at least one new
partnership with housing organizations annually.

Action Outcomes: Strategic tenant protection policy
recommendations will slow the pace and mitigate the impacts of displacement, and development of partnerships and
strategies will preserve unsubsidized affordable housing (nondeed restricted).

Provide Access and Inclusion for
Persons with Disabilities
(Access to Housing and
Resources)
Priority: [Moderate]i
• Lack of supportive services for persons
with disabilities
• Lack of access to resources, such as
schools, transportation, and other in
home or community resources for
persons with disabilities
• Implement an accessibility policy that establishes
standards and procedures for providing equal access
to City services and programs to all residents,
including persons with limited proficiency in English,
and persons with disabilities. Timeframe: By 2024
Geographic Target: Areas with high proportions of
non-native English speakers and north of Cherry
Street and Along El Camino Real with higher
proportions of people with disabilities
2023-2021 Metric: Upon adoption of accessibility
policy, assist at 20 persons annually with disability
needs
• Conduct public meetings at suitable times, accessible to persons with disabilities, and near public transit.

Resources will be invested to provide interpretation
and translation services when requested at public
meetings.

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EXHIBIT B
Findings Responding to Letter from Department of Housing and Community Development Dated January 6, 2023 Timeframe: Ongoing
Geographic Target: Citywide
2023-2021 Metric: Provide at least one person at
public meetings that can provide translation services.
• Continue to educate landlords on fair housing law,
reasonable accommodations and disability rights,
including posting reasonable accommodations on the
website and at prominent location near the permit
counter.

Timeframe: Ongoing
Geographic Target: Citywide
2023-2031 Metric: Outreach to at least five landlords
annually.
• Action 3.12: Continue to reduce or waive
development impact fees to facilitate 100% affordable
and special needs housing, including housing for
extremely low-income and persons living with
disabilities (including persons with developmental
disabilities).

Timeframe: Ongoing
Geographic Target: Citywide
2023-2031 Metric: Waive or reduce development
impact fees for at least one special needs project
during the planning period.
• Action 5.3: Continue to encourage the development
of residential care facilities and group homes.

Timeframe: Ongoing

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EXHIBIT B
Findings Responding to Letter from Department of Housing and Community Development Dated January 6, 2023 Geographic Target: Citywide
2023-2031 Metric: Assist at least one nonprofit
housing provider to acquire and/or rehabilitate
residential housing with supportive services during the planning period.
• Action 5.4: On an annual basis, provide financial
contributions to non-profit organizations and outside
agencies that serve the housing needs of special
needs households in and around San Carlos. These
organizations and agencies may include but are not
limited to: The Center for Independence of the
Disabled (CID), HIP Housing, Shelter Network,
Samaritan House, CALL Primrose, San Mateo County
Children’s Fund, and HEART, among others.

Timeframe: Annually
Geographic Target: Citywide
2023-2031 Metric: Provide financial contributions to at least one non-profit organization as funding becomes
available.

Action Outcomes: Increased options for safe, high quality, accessible, and affordable housing for people with disabilities throughout the City that are located near critical community resources and infrastructure. Will help dissipate any existing concentrations of people with disabilities in the city and promote integration.

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EXHIBIT B
Findings Responding to Letter from Department of Housing and Community Development Dated January 6, 2023 C. Quantified Objectives
Establish the number of housing units, by income level, that can be constructed, rehabilitated, and conserved over a five-year time frame. (Gov. Code, § 65583, subd. (b)(1 & 2).) The element must include
quantified objectives to establish
an estimate of housing units by
income category that can be
constructed, rehabilitated, and
conserved over the planning
period. While the element includes
these objectives by income group
for very low-, low-, moderate- and
above-moderate income, the
element should also disaggregate
objectives for extremely lowincome households.

Table 4.2-3 has been revised to breakdown objectives for each income category.

Table 4.2-3: Housing Element Quantified Objectives
Income Level
Extremely
Low
Very
Low
Low Moderate
Above
Moderate
Total
Construction Objective (RHNA) 370
73936
9 425 438 1,133 2,735
Rehabilitation Objective 107
64010
7 213 213 -- 640
At-Risk Affordable Housing Units
to Preserve
4020 20 57 32 -- 137
D. Public Participation
Local governments shall make a diligent effort to achieve public participation of all economic segments of the community in the development of the Housing Element, and the element shall describe this effort. (Gov. Code, § 65583, subd.(c)(9).) While the element includes a
summary of the public
participation process, it should
also demonstrate diligent efforts
were made to involve all
economic segments of the
community in the development of
the housing element. The
element could describe the
More details were added regarding how all economic segments of the community were outreached p.3-5 Throughout the process and discussion, the City of San Carlos has made a diligent effort to achieve public participation from all economic segments of the community. Invitations to all community meetings were sent to local affordable housing organizations and other special needs service providers who represent low-income and special needs populations to encourage their participation. Translation services were offered and made available upon request. All comments were considered and evaluated during the drafting of the 2023-2031 Housing Programs. Key themes from the outreach process are summarized below.
…

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January 23, 2023 Packet Pg. 1336

EXHIBIT B
Findings Responding to Letter from Department of Housing and Community Development Dated January 6, 2023 efforts to circulate the housing
element among lower- and
moderate-income households
and organizations that represent
them and to involve such groups
and persons in the element
throughout the process.

In addition, while the element
included a general statement that
public comments were
incorporated, it should describe
how the City considered and
addressed public comments in
the element.

The planning process sought to engage many key audiences: the City Council Housing Subcommittee, Planning Commission, City Council, various other Commissions, a wide variety of stakeholders (local agencies and housing groups, community organizations, housing developers, and student groups, etc.), and the general public (residents of the community) to ensure that all economic segments of the City were represented and invited to provide input.

Hundreds of residents, businesspeople, and other stakeholders participated across a series of activities. Outreach and participation for this Housing Element update was different than previous years because much of the update process occurred during the COVID-19 pandemic. Meetings were promoted through website updates, social media posts, mailers, and flyers posted in public spaces to advertise and invite the community to virtual workshops. SService organizations , such as HIP Housing and Vista Center, were directly contacted to solicit participation in the program, and included organizations representing lower- and moderate-income households, seniors, and youth, among others as a way to ensure hard to reach populations were included in the engagement process. . Through this robust outreach and engagement process, the strategies in the Housing Element were defined.

Stakeholder Interviews
At the outset of the engagement process, the City interviewed participants who represent different constituencies and various economic segments in the community to get input on housing issues and potential engagement strategies to reach the community. Stakeholders included the local Chamber of Commerce, the City’s Recreation Division, the PTA Coordinating Council, and the San Carlos School District.

The following was added to further clarify and explain how input was used to revise the draft Housing Element. p10-11 During the public comment period, the City received multiple comment letters and had discussions with local property owners, residents, and housing advocates. Based on comments from the public, the City (consistent with AB 215) took 10 business days to consider and incorporate public comments prior to submitting the Draft Housing Element to HCD. Revisions included new and revised policies and programs to protect tenants, new sites to meet the RHNA were added to the sites inventory, based on feedback from interested property owners, objectives were added to seek new funding sources for affordable housing, provide transparency in housing progress, and remove potential constraints. Specific revisions include:

Comments from the public included:
• Clarify existing and proposed City policies and procedures, including BMR Ordinance requirements, open space requirements, parking, permit processing timeframes
• Add sites as requested by property owners interested in developing housing to the sites inventory to meet the RHNA • Removal/adjusting realistic capacity of sites with additional constraints in the sites inventory • Adjusting estimated affordability of accessory dwelling units projected in the sites inventory

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EXHIBIT B
Findings Responding to Letter from Department of Housing and Community Development Dated January 6, 2023 • Retain and implement transition zones between higher density mixed-use and lower density residential zones to address privacy and neighborhood character concerns
• Incorporate climate change concerns and preserve creek preservation measures • Reduce height on E. San Carlos Avenue
• Incorporate anti-displacement and tenant protection measures • Support for upzoning and additional housing capacity
• Support for childcare development impact fees and implementation streamlining • Use an equity lens to encourage more affordable housing throughout the community • Add implementation programs to further integrate and provide opportunity for housing and remove development constraints In response to each of these comments, revisions were made to the Draft Housing Element.

The Draft Element, as revised with the public comments mentioned above, was submitted to HCD on October 13, 2022 and was madewill remain available on the City’s website for additional public review and comment during the HCD review period. As revisions are made to respond to HCD comments, this information will also be posted on the City’s website. During the HCD review period, additional comment letters were received. The following changes were made to the Housing Element in response:
• Adding new sites to the inventory from property owners who indicated they were interested in redeveloping their properties.

Following HCD’s review, the Draft Housing Element was revised to respond to the Department’s comments. The revised draft was made available to the public for a 7-day review period in January 2023 prior to adoption.

Comments Received During Call on December 22, 2022
Provide an analysis for vacancy
rates, housing costs, and housing
condition
A more detailed analysis was added regarding vacancy rates (p.45-46), housing costs (p.49-50), and housing condition. (p. 48):

8.b
January 23, 2023 Packet Pg. 1338

EXHIBIT B
Findings Responding to Letter from Department of Housing and Community Development Dated January 6, 2023 Housing Stock
In 2020, the Department of Finance reported 12,385 housing units in San Carlos. Most of the City’s housing stock is made up of single-family attached and detached homes (72 percent) with the remaining 28 percent multi-family. Census data indicates that 4 percent of all housing units are vacant.

Vacancy rates are lower for 0.2 percent of owner units (0.2 percent) thanand 3.1 percent of rental units are vacant(3.1 percent).

San Carlos was developed as a community of single-family dwelling units and has primarily remained as such. Single-family structures make up 72 percent of the City’s housing stock, with multi-family comprising 28 percent.

Vacancy Rate
The housing unit vacancy rate provides a useful indicator of the balance between housing supply and demand. As a rule of thumb, a 4.5-percent vacancy rate represents a healthy balance between supply and demand in a housing market. When there is a high vacancy rate, people searching for housing have more housing options and may be able to obtain lower rents. With a low vacancy rate, people selling or renting housing are able to raise prices and/or selectively choose their tenants. A low vacancy rate can lead to overcrowding and unsafe and unsanitary living conditions because lower-income households have fewer options and are unable to find suitable and affordable living arrangements. Low-income households, including people on a fixed income, large families with children, and households with special housing needs, are most likely to be negatively impacted by low vacancy rates. In addition, when there is high consumer demand for a limited housing supply, discrimination is more likely to occur.

Data shows that housing vacancy rates in San Carlos increased from 2010 to 2019 from 325 units to 466 units. According to the 2015-2019 ACS, 32 percent of the vacant units are for rent and two percent are for sale (Figure 4.3-1). Of the total rental housing stock (147 vacant and 3,179 occupied), approximately 4.4 percent are vacant, and of the total ownership housing stock, approximately 0.5 percent are vacant and for sale or sold but not yet occupied. Of the vacant units in San Carlos, 48 percent (approximately 224 units) are simply vacant—neither for sale, rent, seasonal, or sold and awaiting occupancy.

The rental vacancy rate of 4.4 percent indicates a healthy balance of supply and demand; however the ownership market shows limited housing supply.

Figure 4.3-1: Vacant Units

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EXHIBIT B
Findings Responding to Letter from Department of Housing and Community Development Dated January 6, 2023 Housing Cost
The cost of housing in a community is directly correlated to the number of housing problems and affordability issues. High housing costs can price lowincome families out of the market, cause extreme cost burdens, or force households into overcrowded or substandard conditions. The San Carlos median home price in October 2021 based on information provided by CoreLogic, was $2,320,000. This was 24.9 percent higher than the median price in October 2020. The October 2021 median home price was $795,000 higher than the median home price in San Mateo County at large.

More than a quarter (28 percent) of San Carlos households are renters. There are limited sources that provide median or average rents for a specific geography. The Census estimates the median gross rent between 2015 and 2019 in San Carlos was $2,251 per month. These estimates appear below current (2022) searches through search engines such as Zillow, Trulia, Zumper, etc. Zumper.com provides a median rent by month for jurisdiction by unit type and reported an average rent of $3,300 in July 2022 for a studio apartment , ($2,339 for one-bedroom units, $3,152 for two-bedroom units, $4,920 for three-bedroom units, and $5,500 for four-bedroom units) in San Carlos. Table 4.3-6 7 shows that the HUD-determined fair market rents for San Mateo County for 2022. , to establish rental subsidy limits for Section 8 housing voucher recipients. (The FMRs reflect rents for similar housing units in the uncontrolled rental market. Under the Section 8 program, Section 8 recipients may rent units that cost more than the FMR, but the subsidy will only cover up to the amount of the FMR.) Studios and larger units in San Carlos exceed the fair market rents identified by HUD.

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January 23, 2023 Packet Pg. 1340

EXHIBIT B
Findings Responding to Letter from Department of Housing and Community Development Dated January 6, 2023 Table 4.3-67: Fair Market Rents in San Mateo County
Year Efficiency One-Bedroom Two-Bedroom Three-Bedroom Four-Bedroom FY 2022 FMRFair market Rents (HUD) $2,115 $2,631 $3,198 $4,111 $4,473 Average Rents $3,300 $2,339 $3,152 $4,920 $5,500
Source: FY2022 Fair Market Rents. U.S Department of Housing and Urban Development (HUD); Zumper.com Affordability
With the recent increase in rents in the Bay Area, affordable housing has become much harder for lower and moderate-income households to find.

Table 4.3-8 identifies the maximum monthly housing costs affordable to households in San Carlos by income group. Income groups are established based on data published annually by HCD on household income for areas in the state. Affordability is calculated assuming a household can pay up to 30 percent of its monthly income toward housing.

Compared to the rental rates in Table 4.3-7, the average rent cost in San Carlos is not affordable to extremely low- and very low-income households with four persons (approximately 16 percent of all households in San Carlos). However, average rents of a studio , one-bedroom, or two-bedroom are affordable to low-income and moderate-income households with four or more persons (although this may lead to overcrowding in small units).A threebedroom average rental is affordable to a four-person moderate income family in San Carlos, but larger homes are unaffordable.

As housing prices rise in the Bay Area, homeownership becomes more elusive for many households, even those earning above-moderate incomes. Table

4.3-8 shows maximum affordable housing payments for different households (varying by income level) and their eligibility for federal housing assistance; a mortgage payment of $4,980 monthly equates to varying home prices, depending on the interest rate and amount of downpayment.

However, estimating a three percent interest rate and a minimal downpayment, a mortgage payment of $4,980 equates roughly to a home purchase price of $ 1.2 million, just over half of the 2022 median home price in San Carlos. As interest rates increase, the cost increases dramatically. At a 6.25 percent interest rate, a $4,980 monthly payment can only afford a home purchase price of $828,000.

Table 4.3-8: Housing Affordability
Income Group HCD Income Limit
Maximum Monthly Affordable
Housing Cost

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EXHIBIT B
Findings Responding to Letter from Department of Housing and Community Development Dated January 6, 2023 Extremely Low Income (4 Person Family) $55,900 $1,398
Very Low Income (4 Person Family) $93,200 $2,330
Low Income (4 Person Family) $149,100 $3,728
Moderate Income (4 Person Family) $199,200 $4,980
Source: HCD State Income Limits, 2022
Housing Condition
The age and condition of the housing stock in San Carlos is an indicator of potential rehabilitation needs. Commonly, housing over 30 years of age needs some form of major rehabilitation, such as a new roof, foundation work, plumbing, etc. The housing stock in San Carlos is aging, since a majority of the housing stock was built between 1940 and 1979 (73 percent). Only 27 percent of the City’s housing stock has been built since 1980, indicating a potential need for rehabilitation of the other 73 percent of housing units.

In the City of San Carlos, the median sales price in October 2021 was $2.32 million and the median income was estimated at approximately $170,000.4 While this income is too low to afford a new home at the median sales price without a cost burden, it is assumed that current property owners are most likely completing ongoing maintenance and repairs to maintain the values of their homes. Therefore, while the ACS reported that 73 percent of the homes in San Carlos need rehabilitation due to age, home values and resident incomes suggest that most of these units are not in need of rehabilitation.

The City estimates that a more accurate percentage of housing in need of rehabilitation is less than a quarter of housing units. Four percent of occupied housing units in San Carlos have been identified as having substandard housing issues, which includes lacking or insufficient amenities including plumbing, a kitchen, or bathroom. Based upon observations and experiences of the San Carlos Building Official, the City estimates that in 2022, fewer than two housing units are in severe need of replacement or substantial rehabilitation due to housing conditions.

While the City does not have funding to directly support home repair services, the City refers individuals to the Rebuilding Together Peninsula organization for renovation and repair services: http://rebuildingtogetherpeninsula.org. In addition, the City’s Code Enforcement is proactive in connecting various church groups, Boy Scouts, and other community groups such as the Lions Club and Kiwanis Clubs with homeowners in need.

Volunteers remove overgrown vegetation, remove trash and debris, and complete very minor repairs to structures for elderly residents. 4 Source: U.S. Census Bureau 2018 5-Year Estimates

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January 23, 2023 Packet Pg. 1342

EXHIBIT B
Findings Responding to Letter from Department of Housing and Community Development Dated January 6, 2023 Typos on projected ELI households.

P.42 projects 325 but p. 55 projects
370, also on p. 100 - provide
consistency on this
Typos have been corrected in Table 4.3-4 (p.42) and the footnote on p. 130 Table 4.3-4: Household Characteristic by Tenure
Household Characteristic
Owner
Households
Renter
Households
All Households
Number of Households1 8,148 (72%) 3,179 (28%) 11,327
Median Household Income1 $208,250 $91,250 $169,640
Household Income Categories2
Extremely Low Income (0-30% AMI) 500 (6%) 400 (12%) 900 (8%) Very Low Income (30-50% AMI) 470 (6%) 425 (13%) 895 (8%) Low Income (50-80% AMI) 610 (8%) 650 (20%) 1,260 (11%)
Moderate Income (80-100% AMI) 505 (6%) 395 (12%) 900 (8%) Above Moderate Income (100%+ AMI) 6030 (74%) 1,380 (42%) 7,410 (65%) Total number of projected Extremely LowIncome Households (RHNA)2 N/A N/A 37025
Overpayment
All Households Overpaying for Housing2 1,940 (24%) 1,225 (38%) 3,165 (28%) Lower Income Households Overpaying for
Housing2
970 (61%) 1,080 (73%) 2,050 (67%)
Note 1 Source: U.S. Census Bureau 2018 5-Year Estimates Note 2 Source: U.S. Department of Housing and Urban Development Comprehensive Housing Affordability Strategy (CHAS) Tables 2013-2017

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January 23, 2023 Packet Pg. 1343

EXHIBIT B
Findings Responding to Letter from Department of Housing and Community Development Dated January 6, 2023 1 Pursuant to AB 2634, local jurisdictions are also required to project the housing needs of extremely low-income households (0-30% AMI). In estimating the number of extremely low-income households, a jurisdiction can use 50% of the very low-income allocation or apportion the very low-income figure based on Census data. Therefore, the City’s very low-income RHNA of 650 739 units can be split into 325 370 extremely low-income and 325 369 very low-income units.

State the review authority for
ministerial actions.

The review authority for ministerial actions has been added on p. 97 Planning review of routine over the counter permits includes zoning clearances, interpretations, modifications to existing permits, and accessory dwelling units. Ministerial actions are approved by either the Zoning Administrator or the Director.

Clarify whether planned
developments are required.

Planned developments have been clarified as an option available to developers on p. 66 In addition to the residential and mixed use zoning districts, the Zoning Ordinance also has a Planned Development (PD) District, which is an option developer’s can choose that allows for deviation from development standards provided the development is superior than what could be achieved under the zoning and that it be consistent with the General Plan and any applicable specific plan. Planned Developments require a development plan and standards to be reviewed by the Planning Commission and approved by the City Council.

Provide more information on
incentives for lot consolidation.

Provided more information on incentives for lot consolidation on p.119 Lot Consolidation Potential
Many of the sites identified in the RM-59 and the new RM-100 zonein the inventory offer opportunities for lot consolidation. Nevertheless, lot consolidation assumptions in the inventory are minimal. Only adjacent parcels that are under common ownership are assumed to have lot consolidation potential. Of the 169 parcels in the inventory, only 44 (or 26 percent) assume lot consolidation potential, all of these due to common ownership.

Because of common ownership, these function as one larger site.

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January 23, 2023 Packet Pg. 1344

EXHIBIT B
Findings Responding to Letter from Department of Housing and Community Development Dated January 6, 2023 As density increases, the likelihood of lot consolidation increases as well. For example, the City has received a request for a lot consolidation for a potential residential project at 240-260 El Camino Real. For lower income sites, consolidation is only assumed if the properties are under common ownership.

Table 4.5-4 clarify whether any of
these projects included any
affordable units or were they all
market rate
Provided more information to Table4.5-4 and on affordability assumptions on p.110-113 Density, Capacity, and Affordability Assumptions
Consistent with HCD guidelines, methodology for determining realistic capacity on each identified site must account for land use controls and site improvements. To estimate of the number of units for each site, the City considered applicable the land use controls and site improvements, and trends related to market feasibility and typical densities of existing or approved residential developments at a similar affordability level in that jurisdiction. The Housing Element sites inventory surveyed large-scale residential and mixed-use development projects approved since 2015 to develop estimates related to potential development. Most recent projects have achieved built densities very near maximum densities, particularly those in mixed use areas. Some projects have exceeded maximums due to the use of density bonuses in exchange for the provision of affordable housing. Combined, all approved residential and mixed-use projects since 2015 had an average density of 86 percent of the maximum allowable density (Table 4.5-4). Residential zones had a lower average, of 53 percent of allowed capacity. Mixed use zones had an actual density of 107 percent of allowed density, due to extensive use of the State Density Bonus law.

In residential zones, many zoning changes will be implemented concurrently with the Housing Element that will encourage higher levels of density in the zones. In particular, the maximum density of multifamily zones is being increased and a minimum density requirement is being implemented. As such, for realistic capacity of future sites, the minimum required density is used for capacity calculations.

In mixed use zones, past precedence in San Carlos shows a density of 107 percent of allowed density. Because of the City’s Below Market Rate Ordinance and the high cost of land in mixed-use zones, developers have opted to maximize development potential and use the Density Bonus to achieve development beyond maximum levels, which is reflected in the development trends. In conjunction with the Housing Element, Action HOU-4.2 implements Zoning Ordinance amendments which will include not only an increase in density for mixed-use zoning districts, but also will institute a new minimum density requirement (approximately 75 percent of maximum density) to ensure anticipated housing densities are achievedthe zones are also being revised to increase the maximum densities. To be conservative, rather using 107 percent of allowed density, the realistic capacity calculations assume 100 percent of density for mixed use zones. In addition,85 percent of maximum allowable density to account for the potential that a site in a mixed-use zone may develop with nonresidential uses, and an additional multiplier of 85 percent for mixed use sites was applied to determine realistic capacity. The sections that follow provide more detail on these assumptions.

Affordability
Based on state law (California Government Code Section 65583.2[c][3]), sites that allow development densities of at least 30 units per acre are credited toward the lower-income RHNA. The Government Code states that if a local government has adopted density standards consistent with the population8.b January 23, 2023 Packet Pg. 1345

EXHIBIT B
Findings Responding to Letter from Department of Housing and Community Development Dated January 6, 2023 based criteria set by state law (at least 30 units per acre for San Carlos), HCD is obligated to accept sites with those density standards (30 units per acre or higher) as appropriate for accommodating the jurisdiction’s share of regional housing need for lower-income households. To reflect the distribution of the lower income RHNA (63 percent extremely/very low-income and 37 percent low-income), sites appropriate for accommodating the jurisdiction’s share of regional housing need for lower-income households are split between the extremely/very low- and low-income categories (63 percent and 37 percent respectively).

Table 4.5-4: Recent/Active Projects’ Density
Year
Approved
Project Name Zone
Ex/Very
LowIncome
Units
LowIncome
Units
ModerateIncome
Units
Above
ModerateIncome
Units
Units Acres
Allowed
Density
Actual
Density
% of
Allowed
Density
2015 1312 Laurel Street MU-N 0 0 0 2 2 0.11 20 18.99 95% 2015 1501 San Carlos Ave MU-SC 0 0 0 6 6 0.16 59 36.55 62% 2015
1525 San Carlos
Avenue MU-SC 0 1 2 15 18 0.30 59 60.31 102%
2015 530 Walnut Street RM-59 0 0 0 9 9 0.20 59 46.01 78% 2015 545 Walnut Street MU-D 0 0 0 9 9 0.17 50 52.04 104% 2015 657 Walnut Street PD 0 0 0 109 109 2.90 N/A 37.59 N/A 2015 977 Laurel Street MU-D 1 0 0 7 8 0.14 50 58.08 116% 2016 520 El Camino Real
MUDC 0 0 1 8 9 0.19 50 46.73 93%
2017
1667 San Carlos
Avenue MU-SC 0 0 0 6 6 0.18 59 33.91 57%
2017 500 Walnut Street RM-59 0 0 0 4 4 0.12 59 33.19 56% 2018
1040-1052 Laurel
Street MU-N 0 0 0 6 6 0.28 20 21.78 109%

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EXHIBIT B
Findings Responding to Letter from Department of Housing and Community Development Dated January 6, 2023 2018
1257 Magnolia
Avenue RM-59 0 2 0 7 9 0.22 59 41.79 71%
2018
549 Prospect
Avenue* RM-59 0 0 0 4 4 0.15 59 26.84 45%
2018
575 Prospect
Avenue* RM-59 0 0 0 3 3 0.13 59 23.93 41%
2018 782 Elm Street RM-59 0 0 0 4 4 0.16 59 24.89 42%
2019
1240 El Camino
Real MU-SB 0 0 1 7 8 0.15 50 52.14 104%
2019 560 El Camino Real
MUDC 0 1 2 22 2425 0.43 50 55.46 111%
2019 616 Cedar Street RM-59 0 0 0 4 4 0.18 59 22.50 38% 2019 817 Walnut Street
MUDC 23 0 0 1 24 0.24 50 99.15 198%
2020 626 Walnut Street
MUDC 0 3 1 31 35 0.61 50 57.52 115%
Approved Projects Total Average: 86%
Approved Projects Residential Zone Average: 53%
Approved Projects Mixed-Use Zone Average: 107%
In Review 1360 Cherry Street
MUDC 0 0 0 6 6 0.18 50 33.96 68%
In Review 1383 Laurel Street MU-SB 2 0 0 13 15 0.19 50 78.57 157% In Review 308 Phelps Road RS-3 0 0 1 13 14 3.00 3 4.67 156% In Review
808 Alameda De
Las Pulgas RS-6 0 3 7 77 87 11.24 6 7.74 129%

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January 23, 2023 Packet Pg. 1347

EXHIBIT B
Findings Responding to Letter from Department of Housing and Community Development Dated January 6, 2023 In Review Vista Del Grande RS-6 0 11 0 78 89 12.20 6 7.30 122% Anticipated
Project 11 El Camino PD-17 23 12 0 196 231 2.20 N/A 105.00 N/A Anticipated
Project 1232 Cherry
MUDC 32 0 0 1 3433

0.32 50 106.25 213%
* Projects were approved but have not applied for building permits.

Sites that can qualify for 100 percent affordable units based on the allowed density but do not meet the size parameters established by AB 1397 (0.5-10 acres) are split evenly between the moderate- and above moderate-income categories. To reflect the distribution of the upper income RHNA (28 percent moderate-income and 72 percent above moderate-income), sites identified in the moderate-income category are split between the moderateand above moderate-income categories (28 percent and 72 percent respectively).

Describe whether the City has a
process to refer complaints to
housing rights organizations
A description of how the city refers/provides housing rights resources is provided on p. 140 Outreach and Capacity
San Carlos has information about how to find affordable housing in the city on its website but there is not specific information or resources for residents experiencing discrimination in housing or the Fair Housing Act. Program HOU-6.1 is included in the Housing Plan to improve access to fair housing information by providing contact information for local fair housing organizations, legal assistance, and general information about the Fair Housing Act and discrimination.

Integration and segregation make
sure to discuss patterns over time;
o For race what
contributes to
higher
concentrations of
white residents
and concentrations
The following has been added to race/ethnicity on p. 142 Figure 4.6-5 shows the distribution of non-White residents in San Carlos. Most of the City block groups show a population that is 20 percent or less nonWhite. Overall, concentrations of non-White residents in San Carlos are minimal. Block groups northwest of El Camino Real, and along San Carlos Ave. and Cherry St. have non-White populations that are in the 41 to 60 percent. Compared to neighboring jurisdictions, San Carlos has less concentrations of non-White residents than cities of Redwood City, Belmont, San Mateo, and Foster City.

8.b
January 23, 2023 Packet Pg. 1348

EXHIBIT B
Findings Responding to Letter from Department of Housing and Community Development Dated January 6, 2023 of non-white
residents
northwest of El
Camino Real and
San Carlos Ave
areas
o Persons with
disabilities what
contributes to the
high concentration
of people with
disabilities in the
areas identified
and add additional
regional analysis
o Income an area
was identified to
have high
concentration of
LMI households,
but an analysis was
missing discussing
why this could be
and also discuss
what contributes
to the City's higher
income. Also add
additional regional
analysis
Along El Camino Real and San Carlos Ave, which has a higher concentration of multi-family units, there is a larger percentage of non-white residents, with median gross rents that are less than $2,000 a month (relatively lower rates than majority of the City). This area also includes census tracts where the median household income is roughly $74,000 (according to 2018 ACS data), despite the majority of the City having median household incomes that are greater than $125,000. The greater availability of multi-family housing that is relatively affordable compared to other areas of San Carlos, will provide additional housing opportunities at various income levels. Residents living in this area also were more likely to be using housing vouchers.

The following has been added to persons with disabilities on p. 152 In San Carlos, 1,988 residents (7 percent) are living with a disability. Many of these residents with disabilities are 75 years and older (41 percent). Figure

4.6-11 shows the population of persons with a disability by census tract (2015-2019). At a regional level, San Carlos is generally similar to neighboring cities and the county as a whole where eight percent of residents have disabilities. In the Bay area at large, 10 percent of residents have a disability.

Overall concentration of residents living with disabilities in San Carlos is minimal. In the area north of Cherry St and along El Camino Real, there is a higher percentage of residents with disabilities (10 to 20 percent of residents). While the concentration of residents in this area living with a disability is not significant, compared to the rest of the City, it is worth considering some of the factors which may contribute to the concentration of disabilities. In San Carlos, majority of residents living with disabilities are 75 years of age or older; among the various classifications of disabilities, majority of residents in the City living with disabilities have either an ambulatory or independent living disability. The area identified in Figure 4.6-11 also includes San Carlos Elms and Retirement Plus-San Carlos, both of which are assisted living/senior living facilities. Which can infer that the concentration of disabilities in the area, could be due to residents living in assisted living facilities, due to their independent living disabilities. The concentration of residents living with disabilities is consistent at a regional level, the various tracts across San Mateo county have similar levels of residents living with disabilities (10 to 20 percent).

The following has been added regarding income on p. 162 Household Income
The household income distribution by percent of area median income (AMI) skews higher in San Carlos than in the county. Sixteen percent of San Carlos households earn less than 50 percent AMI compared to 24 percent in the Ccounty (Figure 4.6-18). Nearly all block groups within the City have a median income that is greater than $125,000, with the exception of two block groups that are in the $91,000 - $112,000 range.All but one block group in the city has a median income of less than $125,000 (Figure 4.6-19 and Figure 4.6-20). These block groups, located in the central part of the city, also correspond with census tracts where 30 to 40 percent of households are of low to moderate income levels (LMI).

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January 23, 2023 Packet Pg. 1349

EXHIBIT B
Findings Responding to Letter from Department of Housing and Community Development Dated January 6, 2023 As previously mentioned, residents living in this area have a median income that is lower compared to the rest of the city, however, the median incomes are still well above the median state income of 2020 ($78,672). The relatively higher percentage of low to moderate income levels across these tracts can also be attributed to the higher availability of multi-family housing, which generally attracts lower income residents, due to its affordability. At a regional level, San Carlos has less tracts that are of low to moderate income levels, in comparison to other large cities such as Redwood City, San Mateo, East Palo Alto, San Bruno, and South San Francisco. Still, nNo areas of the city have concentrated poverty (Figure 4.6-21).

In terms of employment add to
local and regional analysis to
address if there is equal access to
employment throughout the city
and compare access to the region;
discuss discrepancies that are
illustrated in the jobs proximity
index map, which will also help
with the analysis regarding
employment access
The following has been added regarding employment on p. 179 TCAC’s economic opportunity score is comprised of poverty, adult educational attainment, employment, job proximity, and median home value. The vast majority of the city ranks very high on economic opportunity, with the areas around Highway 101 offering moderate opportunity (Figure 4.6-27).

The jobs proximity index quantifies the accessibility of a neighborhood to jobs in the region by measuring the physical distances between jobs and places of residence. This index varies from 0-100 as demonstrated in Figure 4.6-28, with higher scores point to better accessibility to employment opportunities. The areas abutting Highway 101, however, offer the best job proximity (Figure 4.6-28). Located within this high proximity region is also the downtown area, which spans along Laurel St. The downtown area is home to a diverse set of retail and commercial centers, serving as a very prominent employment center for the various residents of San Carlos, as well as residents from other cities. At a regional level, cities throughout San Mateo county (namely those along the San Francisco Bay), have similar proximity index levels, where cities like Burlingame, Redwood City, South San Francisco, and East Palo Alto have a very close proximity index. Cities with the furthest proximity include Pacifica and Daly City.

Add discussion about access to
transit geographically both locally
and regionally; do some areas have
better access than others.

The following has been added regarding transit on p. 183-184 Access to transportation is extremely important to households affected by low incomes and rising housing prices, especially because lower income households are often public transit dependent. Public transit should strive to link lower income residents to major employers where job opportunities exist. Access to employment via public transportation can reduce welfare usage and increase housing mobility, which enables residents to locate housing outside of traditionally low-income neighborhoods.

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EXHIBIT B
Findings Responding to Letter from Department of Housing and Community Development Dated January 6, 2023 Public transit in the City of San Carlos is somewhat accessible, given that public transit such as bus routes are limited to routes along major roads such as Brittan Ave., and Alameda de las Pulgas. Other transit routes include the Bay Area Rapid Transit (BART) routes, as well as the Cal Train systems which run parallel to the El Camino Real. These methods of transit allow residents of the City of San Carlos to ride beyond the city limits, to other major economic centers. It is worth mentioning that some areas of the city, or areas that can best be characterized as single-family neighborhoods see less public transit accessibility compared to those living in high density corridors. The lack of route coverage is possibly due to there being more access to private modes of transportation (i.e., personal vehicles) among residents living in these areas, as they tend to be homeowners with higher incomes.

Though given that some residents experience disability in the form of independent living, the lack of public transportation availability can make it difficult for these residents to travel away from home to visit grocery stores or other services.

Describe the differences illustrated
in the map locally and regionally
and what contributes to the
environmental scores; score are
really varied in the city and region
so adding more analysis on this
The following has been added regarding environmental health on p. 184 The neighborhoods aligning Highway 101 have low to moderate outcomes, while the balance remainder of the city has moderate outcomes (but for two census tracts with more positive outcomes). Other cities throughout the region receive similar environmental scores; tracts that are in close proximity to Highway 101 also have less positive environmental scores. Once again, possibly due to the exposure to air pollutants from vehicle emissions. The east end of the 101 also tends to be more industrial and commercial in its uses, as can be seen in cities such as Redwood City, Burlingame, San Mateo, and South San Francisco.

Disproportionate housing needs
the discussion on cost burden and
overcrowding needs a regional
analysis
The following has been added regarding disproportionate housing needs on p. 196 and 203 At a regional level, renter-occupied households living in cities all along the San Francisco Bay, experience similar levels of cost burden. With the exception of cities such as East Palo Alto, Redwood City, San Mateo, San Bruno and South San Francisco, where 40 to 80 percent of most tracts experience housing cost burden. As for homeowners within the same region, the severity of housing cost burden diminishes. The majority of tracts seen throughout these cities reach levels of up to 60 percent or less of housing overpayment. …
However, renter-occupied households are more likely to be overcrowded than owner households. Hispanic households (4.9%) and households with other or mixed races (8.4%) have the highest levels of overcrowding. San Carlos households are less likely to experience overcrowding than the county and Bay area as a whole.

At a regional level, overcrowding can be seen most significantly in cities such as Daly City, South San Francisco, San Bruno, San Mateo, Redwood City, and East Palo Alto, where more than 20 percent of several tracts experience overcrowding. These cities are much larger in population in comparison to San Carlos (with the exception of East Palo Alto). Despite the high levels it is also worth considering that in some instances the data may still be undercounted.

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January 23, 2023 Packet Pg. 1351

EXHIBIT B
Findings Responding to Letter from Department of Housing and Community Development Dated January 6, 2023 Substandard housing add a
discussion whether there is a
concentration of substandard
housing within the city and
regionally
The following has been added regarding substandard housing on p 203 The Comprehensive Housing Affordability Strategy (CHAS) developed by the Census for HUD provides detailed information on housing needs by income level for different types of households in San Mateo County. Severe Housing problems considered by CHAS include:
• Severe housing cost burden, including utilities, exceeding 50 percent of gross income; • Overcrowded conditions (housing units with more than 1.5 persons per room); and • Units with physical defects (lacking complete kitchen or bathroom/plumbing facilities) According to the 2015-19 CHAS data, less than 15 percent of all households (homeowners and renters) in the City of San Carlos experience any of the four previously mentioned severe housing problems. At a county-level, 23 percent of households experience severe housing problems.

There is no concentration of substandard housing issues or areas where housing is more likely to need rehabilitation. Given the general affluence of the community, substandard housing is not a significant issue.

Risk of displacement due to
disaster; fire, flood, earthquake
The following has been added regarding displacement related to natural disasters p. 192 According to the 2016 San Mateo County Hazard Mitigation Plan, the City of San Carlos has seen two major hazard events since 1989. In October of 1989, residents experienced the 6.9 magnitude Loma Prieta earthquake, and in January of 2010, the city experienced a significant flooding event which impacted the cities airport.

These disasters pose a substantial safety risk to residents, and threaten vital infrastructure and property throughout the city. For this reason, the city and county have implemented a variety of measures that aim to help residents effectively respond and prepare for any such disasters.

As mitigation actions addressing these issues are included in the County Hazard Mitigation Plan, as well as the City’s Climate Action Plan, the risk of displacement due to disaster is expected to be minimal. The risks of displacement due to disinvestment are also anticipated to be minimal or nonexistent. San Carlos is experiencing demand for non-residential and residential development throughout the city, with no significant areas of disinvestment or concern.

Wherever it is possible provide a
quantified outcome, it's missing
from a few programs. Where
programs are being continued be
The following has been added to add more quantified outcomes where appropriate and how programs will be updates in the new Housing Plan where relevant.

8.b
January 23, 2023 Packet Pg. 1352

EXHIBIT B
Findings Responding to Letter from Department of Housing and Community Development Dated January 6, 2023 clear about how it will be
continued or how it will be revised.

Table 4.7-1: 2015-2022 Program Accomplishments
2015-2021 Housing Element Program Progress and Continued Appropriateness Program H-1.1: Continue the Rental Inspection Program. Continue the Rental Inspection Program as provided in San Carlos Municipal Code Chapter 15.34, as implemented by the Building Division.

The City’s Rental Inspection Program supports ongoing property maintenance of critical rental housing stock and provides a process to address tenant complaints of Code violations. Approximately 110 housing units are inspected annually. The Building Division oversees and implements this program, including the mandatory deck inspection.

Continued Appropriateness: The program remains important and is updated to focus on preserving and improving existing housing stock and neighborhood quality and continued in the updated Housing Element.

Program H-1.2: Promote Home Repair Assistance. Promote the availability of free or inexpensive home repair services for low-income households, including households with special needs, provided by the most suitable organizations. Organizations providing such services may include but are not limited to:
• North Peninsula Neighborhood Services Center, Inc.
• Community Action Agency of San Mateo County, Inc. (CAA) • Center for the Independence of the Disabled (CID)
• Rebuilding Together Peninsula
• Generating Renewable Ideas for Development Alternatives (GRID Alternatives)
• Promote the preservation and improvement of the quality of existing housing and neighborhoods.

While the City does not have funding to directly support home repair services, the City refers individuals to the Rebuilding Together Peninsula organization for renovation and repair services:
http://rebuildingtogetherpeninsula.org. In addition, the City’s Code Enforcement is proactive in connecting various church groups, Boy Scouts, and other community groups such as the Lions Club and Kiwanis Clubs with homeowners in need. Volunteers remove overgrown vegetation, remove trash and debris, and complete very minor repairs to structures for elderly residents.

Continued Appropriateness: Continued residential rehabilitation ensures the longevity of the local housing stock. This program will be consolidated with existing Program H-1.3 and H-1.4 and continued in the Housing Element, with a focus on identification of new funding sources

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EXHIBIT B
Findings Responding to Letter from Department of Housing and Community Development Dated January 6, 2023 and providing clear information to the public about regionally available resources.

Program H-1.3: Identify and Implement Residential Improvement Programs. Evaluate residential improvement programs that are or could be made available and consider re-establishing and expanding the City’s Life Safety Home Repair Grant program.

The City will continue to evaluate opportunities as they arise; during the planning period, no additional funding sources were identified to support this program.

Continued Appropriateness: This program will be consolidated with existing Program H-1.2 and H-1.4 and continued in the Housing Element, with a focus on identification of new funding sources and providing clear information to the public about regionally available resources.

Program H-1.4: Publicize Rehabilitation Loan Programs. Promote the availability of any city, county, State or federal housing rehabilitation loan programs for San Carlos residents, including San Mateo County’s Housing Rehabilitation Loan Programs. As part of this outreach program, the City will identify rehabilitation opportunities linked to improving seismic safety in older multifamily housing developments in San Carlos.

San Carlos is a participating city within the San Mateo County Consortium Consolidated Plan. The 2018-2022 Consolidated Plan identified a goal to explore a multifamily rehabilitation and accessibility improvement program using CDBG revolving loan or other public funds to provide an incentive for landlords to participate in the Housing Choice Voucher program; however, CAPERs indicate this has not yet been completed.

Continued Appropriateness: This program will be consolidated with existing Program H-1.2 and H-1.4 and continued in the Housing Element, with a focus on identification of new funding sources and providing clear information to the public about regionally available resources.

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January 23, 2023 Packet Pg. 1354

EXHIBIT B
Findings Responding to Letter from Department of Housing and Community Development Dated January 6, 2023 Program H-1.5: Require Replacement Housing. Require the adoption of a minimum one-to-one replacement requirement of any
housing units demolished due to public action.

The City adopted a Uniform Relocation Policy in 2017.

Continued Appropriateness: This program is complete and removed from the Housing Element; replaced with a program to comply with Government Code Section 65583.2(g)(3), requiring the replacement of units affordable to the same or lower income level as a condition of any development on a nonvacant site identified in the Housing Element.

Program H-1.6: Publicize Weatherization and Water Conservation Programs. Promote low-income weatherization assistance and water reduction programs.

The City provides links and information on the City website pertaining to water conservation and housing rehabilitation. Water conservation is an important goal for the City and is directed by the City’s Sustainability Office and Climate Mitigation and Adaptation Plan (CMAP).

Continued Appropriateness: This program is complete and will be removed from the updated Housing Element.

Program H-1.7: Undertake Actions to Reduce the Potential for Displacement of Lower Income Residents. Quantify, develop and evaluate potential strategies to address displacement of lower income residents. Based on this evaluation, measures will be developed and the City will implement programs, as appropriate, to address the risk of displacement of existing lower income residents. Once actions are identified and actions taken by the City, the City will monitor such programs annually for effectiveness and make adjustments as necessary. If possible, the City will coordinate The City collaborates with 21 Elements, which prepared a report on displacement strategies most effective for San Mateo County jurisdictions in 2017. To address potential displacement of lower income residents, the City adopted a Uniform Relocation Policy in 2017. In 2019, the City adopted Ordinance No. 1556 to approve just

8.b
January 23, 2023 Packet Pg. 1355

EXHIBIT B
Findings Responding to Letter from Department of Housing and Community Development Dated January 6, 2023 with other jurisdictions in San Mateo County, under the umbrella of work to be undertaken by 21 Elements.
cause eviction protections in the interim before the California Tenant Protection Act of 2019 went into place.

Continued Appropriateness: This program is removed and replaced with programs to continue to identify special circumstances where existing affordable housing can be acquired and preserved and to continue collaboration with 21 Elements to enhance the exchange of information and identification of solutions to regional housing issues.

Program H-2.1: Implement the California Green Building Standards Code. Implement and promote incentive programs that encourage the use of green-building techniques in the development of all new housing and remodels, especially in affordable housing. This includes implementation of the California Green Building Standards (CALGreen) Code for new residential buildings, additions or alterations.

The City implements green-building techniques through implementation of CALGreen, consistent with State requirements. In 2021, San Carlos adopted an all-electric Reach Code Ordinance. A reach code is a local building energy code that “reaches” beyond the state minimum requirements for energy use in building design and construction, creating opportunities for local governments to lead the way on clean air, climate solutions, and the renewable energy economy.

Continued Appropriateness: This program is complete and be implemented as a matter of regular business; as such it will be removed from the Housing Element.

Program H-2.2: Funding for Green Building. Leverage federal, State and regional funding sources to subsidize incentive programs for green building.

Funding for green building opportunities remains limited. The City has focused the limited available funding to support affordable housing development, and encourages projects to implement sustainable features, seeking additional sources as opportunities are available.

Continued Appropriateness: This program is removed from the Housing Element.

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EXHIBIT B
Findings Responding to Letter from Department of Housing and Community Development Dated January 6, 2023 Program H-2.3: Implement Energy Conservation. Continue to implement, suggest and promote up-to- date energy conservation policies, energy-efficient materials and devices as part of housing development projects and remodels of existing housing stock.

The City's Zoning Ordinance offers an increase in FAR for mixed use projects that include car share, electric car facilities, green roofs, solar panels, and other green building measures. Several mixed-use projects have incorporated one or more of these in recently approved projects. In addition, the City continues to implement CALGreen and in 2021, San Carlos adopted an all-electric Reach Code Ordinance.

Continued Appropriateness: This program is complete and will be removed from the updated Housing Element.

Program H-3.1: Implement Complete Streets Policies and Programs.

Continue to implement the Complete Streets Policy of the City of San Carlos (Resolution 2012-066), including infrastructure up-grades such as streetscape improvements, and “Complete Streets” programs, to create a pedestrian-friendly environment and encourage private residential investment in Planning Areas 1, 2, and 3, including El Camino Real (Grand Boulevard Initiative).

The City adopted a complete streets policy in 2012. Successful, completed projects include El Camino Real Grand Boulevard Initiative, East Side Connect, El Camino Real Landscaping and Lighting. Ongoing projects include removal of Eucalyptus trees along San Carlos Avenue and installation of new sidewalks to facilitate safe, walkability into the downtown and Caltrain. Projects underway are contributing towards sidewalk and pedestrian enhancements. In addition, San Carlos completed and adopted on June 9, 2020 its first pedestrian plan, the Bicycle and Pedestrian Master Plan.

Continued Appropriateness: This program is complete and will be removed from the updated Housing Element.

Program H-3.2: Provide Incentives for Higher-Density, Mixed-Use Development That Include Affordable and Special Needs Units. Reduce or waive development impact fees where necessary and appropriate to make infill higher-density, mixed-use development that includes affordable and special needs housing, including housing for extremely low income and persons living with disabilities (including persons with The City provides Financial Assistance for qualifying projects through the BMR ordinance (SCMC 18.17.030, F.). In addition, funds from the Housing in-lieu fee and the Commercial Linkage fee are pooled to support affordable housing construction in the city. Cumulatively, for fiscal year 19/20 and 20/21, $4.37M and $2.37M in revenues were collected, respectively. The City also provides density bonuses and concessions to

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January 23, 2023 Packet Pg. 1357

EXHIBIT B
Findings Responding to Letter from Department of Housing and Community Development Dated January 6, 2023 developmental disabilities) to be feasible in the Downtown area and along El Camino Real. The City will strive to incentivize development, such as allowing height limit bonuses, for projects that exceed the affordability levels or number of BMR units required by the BMR Program, (2) accommodate BMR units for special needs households, or (3) include Single Room Occupancy units.
projects that include affordable housing units. For example, the affordable housing project at 817 Walnut received a density bonus and concession and the City waived all impact and processing fees. The City has also provided funding to support services for a group home for persons with disabilities.

Continued Appropriateness: This program is continued in the updated Housing Element and is updated to establish a priority permit process for projects exceeding the City’s BMR requirements.and continued in the updated Housing Element.

Program H-3.3: Develop Incentives for Lot Consolidation. Develop a lot consolidation program for owners of small and odd-shaped lots in Planning Areas 1, 2, and 3. The program may include incentives for lot consolidation such as:
• Relaxed development standards
• Streamlined permitting process
• City financial contributions, as well as other density bonuses, incentives and concessions that are otherwise required by State density bonus law for the provision of higher levels of affordable housing.

The City will review the program on an annual basis to evaluate its effectiveness and revise as needed.

The City continues to evaluate the ability to consolidate lots in the downtown and best practices and incentives for consolidation of small lots, as well as ways to support development on small lots. Since 2015, the City has approved seven residential or mixed use projects on small lots in Downtown, such as 977 Laurel Street (0.14 acres), 520 El Camino Real (0.19 acres), and 993 Laurel (0.21 acres). As part of the 2023 Housing Element update, the City increased the allowable density on parcels throughout the multi-family and mixed use zones, which is a key mechanism to encouraging/facilitating housing on small lots.

Continued Appropriateness: This program is continued in the updated Housing Element and modified to address the removal of constraints for small lot development and the City’s upcoming Downtown Specific Plan.

Program H-4.1: Develop Second Unit (Accessory Dwelling Unit) Information Materials. Develop informational materials to educate the public on second accessory dwelling units, including alternatives to the The Planning and Building Divisions provide information to the public regarding the provisions for accessory dwelling units. During this Housing Element cycle, there has been significant change to State laws

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EXHIBIT B
Findings Responding to Letter from Department of Housing and Community Development Dated January 6, 2023 affordable housing impact fee as compared to the construction of a second unit.
and resulting growth in the number of applications for ADUs. For example, in 2015 only 5 ADUs were approved; in 2016, there were 6; in 2017 there were 8; and in 2018 the numbers more than doubled to 19 ADUs permitted in San Carlos. In 2019, 14 ADUs were permitted and in 2020, 29 ADUs received building permits.

Continued Appropriateness: Accessory dwelling units remain an important component of the housing stock in San Carlos; this program will be consolidated with other ADU programs and continued in the updated Housing Element.

Program H-4.2: Modify Second Unit Development Standards. Eliminate the 400-foot distance standard currently required between secondary dwelling units and continue to review the effectiveness of second unit development standards on a periodic basis.

The 400-ft distance standard has been eliminated. In 2020, San Carlos adopted an Accessory Dwelling Unit Ordinance, permitting ADUs and JADUs consistent with State law.

Continued Appropriateness: This program is complete and will be removed from the updated Housing Element.

Program H-4.3: Identify Possible Sources of Funding for Secondary Dwelling Units. Identify potential funding sources for remodels of existing homes to create an autonomous second unit within the existing structure.

In 2020, San Carlos adopted an Accessory Dwelling Unit Ordinance, permitting ADUs and JADUs consistent with State law.

Continued Appropriateness: The City participates in regional efforts to encourage and facilitate accessory dwelling units; this program is modified accordingly and consolidated with other ADU programs in the updated Housing Element.

Program H-4.4: Legalize Existing Unpermitted Secondary Dwelling Units. Extend and promote the amnesty program to legalize existing In 2020, San Carlos adopted an Accessory Dwelling Unit Ordinance, allowing for previously constructed ADU property owners to apply for a delay of correction to building standard violations for five years, if the

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EXHIBIT B
Findings Responding to Letter from Department of Housing and Community Development Dated January 6, 2023 unpermitted second units. Encourage the legalization of unpermitted second units to better ensure that they are safe and habitable. building standard violation is not necessary to protect health and safety (Section 18.23.210, H.)
Continued Appropriateness: This program is complete and will be consolidated with other ADU programs in the updated Housing Element.

Program H-4.5: Undertake Design Review of Secondary Dwelling Units. Continue to evaluate the design of second unit applications through the minor design review process, which establishes objective standards for application review and approval of secondary dwelling units.

In 2020, San Carlos adopted an Accessory Dwelling Unit Ordinance, establishing a ministerial review process for ADUs.

Continued Appropriateness: This program is obsolete and will be removed from the updated Housing Element.

Program H-4.6: Establish a Process and Standards to Allow the Conversion of Accessory Buildings and Structures to a Secondary Dwelling Unit. Allow converted accessory buildings/structures that do not comply with the current secondary dwelling unit ordinance to be reviewed through a new process that establishes an allowance for one or more exceptions from the secondary dwelling unit development regulations. Modify the existing development regulations of accessory buildings/structures to more clearly distinguish how accessory buildings/structures can be used (such as modifying the regulations to prohibit living areas without main dwelling unit setbacks and/or the number of plumbing fixtures) and consider reduction or waiver of fees.

Reevaluate the effectiveness of this program in producing secondary dwelling units and consider other options after one year from adoption of the ordinance.

In 2020, San Carlos adopted an Accessory Dwelling Unit Ordinance, permitting ADUs and JADUs conversions consistent with State law.

Continued Appropriateness: This program is obsolete and will be removed from the updated Housing Element.

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EXHIBIT B
Findings Responding to Letter from Department of Housing and Community Development Dated January 6, 2023 Program H-5.1: Implement Below Market Rate (BMR) Requirements.

Continue to implement the City’s Below Market Rate (BMR) Ordinance and revise the ordinance to change the length of time for very low and low-income unit affordability from 30 to 55 years, as is standard practice in most BMR ordinances.

The City's BMR Ordinance requires deed restrictions of 45 years for forsale units and 55 years for rentals. In 2022, the City updated the BMR Ordinance to encourage more affordable housing in the community.

Continued Appropriateness: The BMR Ordinance remains an important component of the City’s affordable housing strategy and is included in the updated Housing Element as an ongoing program.

Program H-5.2: Implement First-time Homebuyer Programs. Direct prospective first-time homebuyers to County programs intended for first time homebuyers. Encourage the use of these programs though outreach and education.

The City continues to refer interested homeowners to HEART, which provides first-time homebuyer programs and loans. As a condition of sale for all owner-occupied below market rate units, deed restrictions are required and include the City’s purchase option, resale restrictions, and procedures and policies regarding changes in title to ensure that owneroccupied below market rate units remain affordable for not less than 45 years.

Continued Appropriateness: This program is continued in the updated Housing Element and will be updated and to include information on local BMR ownership units that are resold, and included in the updated Housing Element.

Program H-5.3: Encourage the Use of the HUD Section 8 and Other Rental Voucher Programs. Encourage the use of federal, state and local rental housing programs and encourage nonprofit service providers to refer eligible clients, especially those with extremely low incomes, to the Section 8 program for assistance.

The City refers eligible clients to appropriate resources and continues to implement its BMR Ordinance, which specifies Section 8 eligibility in BMR projects. Continued Appropriateness: This program will be continued in the updated Housing Element and consolidated with existing Program H-5.4 and H-5.5.

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EXHIBIT B
Findings Responding to Letter from Department of Housing and Community Development Dated January 6, 2023 Program H-5.4: Work with the San Mateo County Department of Housing to Publicize Available Rental Assistance and Other Programs.

Continue to publicize the availability of rental assistance and other assistance programs and work with the San Mateo County Department of Housing to implement the Section 8 Rental Assistance Programs effectively in San Carlos and, as appropriate, assist non-profit housing rental assistance efforts.

The City publicizes information on its website and partners with the County and local nonprofit housing providers.

Continued Appropriateness: This program is consolidated with existing Program H-5.3 and H-5.5 and included in the updated Housing Element.

Program H-5.5: Study and Consider Measures to Address Potential Discrimination Against Section 8 Voucher Recipients. Conduct an evaluation to quantify, develop and evaluate potential strategies to address the potential for discrimination against Section 8 or other rental assistance voucher programs. Based on this evaluation, measures will be developed and the City may implement programs, as appropriate, to address this issue. If possible, the City will coordinate with other jurisdictions in San Mateo County, under the umbrella of work to be undertaken by 21 Elements.

During the planning period, the City participated in the regional collaboration with 21 Elements. During this time, new Statewide legal requirements were enacted pursuant to SB 329, which prohibit housing discrimination on the basis of source of income (including Housing Choice Vouchers).

Continued Appropriateness: This program will be consolidated with existing Program H-5.3 and H-5.4 and included in the updated Housing Element.

Program H-5.6: Work with the Business Community to Address Workforce Housing Needs. Publicize and promote affordable workforce housing programs to the business community and to City, school and other local government employees and recruits.

On the City’s website, local affordable housing resources are publicized.

San Carlos also has in place a commercial linkage fee to support affordable housing in tandem with new nonresidential construction projects. The Linkage Fee applies to commercial projects including

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EXHIBIT B
Findings Responding to Letter from Department of Housing and Community Development Dated January 6, 2023 changes in use, additions in floor area and new development with variations in cost based on use:

Retail, Restaurant, & Personal Service: $5/SF; Hotel: $10/SF; Office, Medical Office, R&D: $20/SF.

Continued Appropriateness: This program is consolidated with programs pertaining to affordable housing funding sources and City’s commercial linkage fee, and continued in the updated Housing Element.

Program H-5.7: Explore Opportunities to Rehabilitate and Convert Existing Housing to Affordable Housing. Explore partnerships with housing operators, non-profit organizations and developers to rehabilitate and convert existing market rate rental housing into affordable housing for extremely low, very low, low and moderate income households.

The City continues to engage developers and affordable housing providers on this issue. The upcoming program at 1232 Cherry Street will redevelop six existing affordable units and, in combination with the adjacent lot housing a retail building, result in 34 affordable units.

Continued Appropriateness: This program is consolidated with programs pertaining to partnerships and collaboration and continued in the updated Housing Element.

Program H-5.8: Establish Priority Processing Procedures. Establish a process for granting priority permit processing status for approved housing projects that exceed the City’s minimum BMR requirement.

The Planning Division continues to work with applicants who propose affordable housing at deeper levels for fast tracking.

Continued Appropriateness: This program will be consolidated with a program to pursue review streamlining, especially through adoption of objective design standards, and continued in the updated Housing Element.

Program H-5.9: Maintain an Inventory of Sites Eligible for LIHTC Funding. Identify locations and encourage projects that will score well During the planning period, the City maintained an inventory of sites to meet the RHNA. Sites in the previous Housing Element were identified in

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EXHIBIT B
Findings Responding to Letter from Department of Housing and Community Development Dated January 6, 2023 based on the criteria set forth for Low Income Housing Tax Credit funding.
transit and service rich areas, consistent with LIHTC funding criteria.

During the planning period, 817 Walnut which includes 23 affordable studio units, received LIHTC funding and was constructed.

Continued Appropriateness: This program will be modified to indicate that the City will maintain the inventory of sites throughout the planning period, and address no-net loss provisions of State Housing Element law.

Program H-5.10: Update for Consistency with State Density Bonus Law.

Update the Zoning Ordinance to be consistent with the latest changes to State Density Bonus Law, including modifications to comply with AB 2222, which requires replacement of pre-existing affordable units to be eligible for the bonuses, incentives and waivers provided under State Density Bonus Law.

While the Density Bonus portion of the City’s Zoning Ordinance was not updated, the City complied with State Density Bonus law throughout the planning period. In 2022, the City updated Chapter 18.16 (Affordable Housing Programs) and Chapter 18.17 (Affordable Housing Incentives) to encourage more affordable housing in the community, including an update to provide additional incentives through the City’s density bonus ordinance. Since 2015, eight projects in mixed use zones have used the Density Bonus to produce a combined total of 132 units.

Continued Appropriateness: A program to update the City’s Density Bonus Ordinance to reflect State law is included in the updated Housing Element.

Program H-5.11: Pursue Funding for Lower Income Housing. Monitor and pursue funding for housing that meets the needs of lower income households. Monitoring of funding availability will be done on an ongoing basis through coordination with 21 Elements and by City staff.

At least annually, the City will take actions to pursue specific funding sources for lower income housing either alone or in coordination with other jurisdictions or entities involved in the provision of lower income housing.

The City has implemented a commercial linkage fee and an in-lieu fee for smaller affordable housing projects to comply with the BMR Ordinance. These funding sources are important to provide a local match for projects seeking other affordable housing funds.

Continued Appropriateness: This program will be updated and consolidated with other programs pertaining to affordable housing funding sources.

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EXHIBIT B
Findings Responding to Letter from Department of Housing and Community Development Dated January 6, 2023 Program H-6.1: Evaluate Incentives for BMR Housing. Periodically evaluate the density bonuses, incentives and concessions in the BMR Ordinance to determine whether they are adequate to make the production of affordable housing feasible.

The City updated the BMR Ordinance in 2022 to comprehensively evaluate its effectiveness and parameters.

Continued Appropriateness: This program will be continued in the updated Housing Element, with a focus on implementation and tracking of the BMR Ordinance.

Program H-6.2: Adopt Priority Procedures for Providing Water and Sewer Service to Affordable Housing Developments. Consistent with SB 1087 (Government Code Section 65589.7), the City will provide a copy of the adopted Housing Element to water and sewer providers immediately upon adoption and will work with water and sewer providers to adopt written policies and procedures that grant priority for service allocations to proposed developments that include housing units affordable to lower income households.

The City delivered a copy of the adopted Housing Element to water and sewer providers after adoption.

Continued Appropriateness: This program remains a requirement of State law and will be included in the updated Housing Element.

Program H-7.1: Contribute to Special Needs Service Providers. On an annual basis, provide financial contributions to non-profit organizations and outside agencies that serve the housing needs of special needs households in and around San Carlos. These organizations and agencies may include but are not limited to:
• The Center for Independence of the Disabled (CID)
• HIP Housing
• Shelter Network
• Samaritan House
• CALL Primrose
• San Mateo County Children’s Fund
• HEART
The City supports organizations that serve special needs persons through the allocation of Housing In-Lieu Fees. Grants to seven organizations totaled:

FY 18/19: $105,000
FY 19/20 $105,000
FY 20/21: $154,500
FY 21/22: $157,600
Continued Appropriateness: This program is an important resource and will be continued in the updated Housing Element.

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EXHIBIT B
Findings Responding to Letter from Department of Housing and Community Development Dated January 6, 2023 Program H-7.2: Evaluate the Effectiveness of City Contributions to Special Needs Service Providers. Evaluate City contributions to outside agencies to assess whether to continue funding and/or adjust funding amounts or to consider other agencies for funding, particularly those organizations and agencies that provide housing with support services for persons with disabilities.

The City tracks funding by cost/household served and units preserved/assisted.

Continued Appropriateness: This program will be updated will be and consolidated with Programs H-7.1 and H-7.3 and continued in the updated Housing Element.

Program H-7.3: Require Annual Reports from Special Needs Service Providers. Require outside agencies receiving contributions from the City to submit annual reports detailing how funds have been used and how programs have benefited San Carlos residents.

The City requires annual reports for grants issued.

Continued Appropriateness: This program will be updated and consolidated with Programs H-7.1 and H-7.3 and continued in the updated Housing Element.

Program H-7.4: Maintain an Inventory of Sites for Senior and Other Special Needs Housing. Identify locations and encourage senior housing, including assisted living facilities, in multi-family areas, and maintain an inventory of suitable sites for senior housing and for persons with disabilities or other special needs.

The Housing Element included ample sites to accommodate the RHNA and provide for a variety of housing options for special needs groups, seniors, and those with disabilities.

Continued Appropriateness: This program is consolidated with the Adequate Sites program (Program 5.9) and included in the updated Housing Element.

Program H-7.5: Provide Assistance to Projects for Persons with Special Needs Housing. Offer financial and technical assistance for housing development projects for persons with special needs. Financial support may come in the form of redevelopment housing set- aside funds, Community Development Block Grant (CDBG) funds, and other State and federal sources that the City will continue to pursue in partnership with local developers and agencies. On an annual basis, contact The City no longer has redevelopment housing set-aside funds to support local projects. The City participates in the San Mateo County Consolidated Plan and is distributed CDBG funds through the County Consortium.

Continued Appropriateness: This program will be consolidated within a funding program in the updated Housing Element.

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EXHIBIT B
Findings Responding to Letter from Department of Housing and Community Development Dated January 6, 2023 developers and agencies to discuss the City’s ability to support special needs housing development projects. Evaluate the effectiveness of this program twice within the planning period.

Program H-7.6: Facilitate Home Sharing and Tenant Matching Opportunities. Work with non-profit groups (including HIP Housing — hiphousing.org/programs/home-sharing-program) to create home sharing/matching opportunities for renters as a means of efficiently using the existing housing stock. Tasks would include:
• Assist in outreach in identifying potential owners, such as seniors who wish to remain in their home or new buyers who could afford single-family homes with the extra income
potential.
• Assist in publicizing and helping to identify potential renters interested in home sharing opportunities.
• Consider opportunities for renters who do not have vehicles to be matched at locations that have limited parking available. • Coordinate with HIP Housing and develop standards that would allow separate cooking facilities if tied to a home sharing program.

The City continues to work with HIP Housing and promotes its home sharing program with flyers and information to the public.

Continued Appropriateness: This program is combined with other partnership programs and updated/continued in the updated Housing Element.

Program H-8.1: Ensure Fair Housing in City Policies and Procedures.

Continue to review City policies and procedures to ensure that the City is promoting fair housing goals to the fullest extent possible.

The City continues to explore opportunities to promote fair housing. As part of the 2023-2031 Housing Element Update and State law requirements, the City prepared an analysis evaluating fair housing issues locally and regionally. Based on this analysis the City developed milestones and metrics to address fair housing issues and their contributing factors. The City also participates in San Mateo County’s Regional Assessment of Fair Housing, which is updated every five years.

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EXHIBIT B
Findings Responding to Letter from Department of Housing and Community Development Dated January 6, 2023 Continued Appropriateness: This program is consolidated with Programs H-8.2 – 8.6 and continued in the updated Housing Element under an Affirmatively Furthering Fair Housing program.

Program H-8.2: Provide Public Handouts on Fair Housing. Provide information to residents about service providers that assist with fair housing complaints and violations, including, but not limited to, providing materials at City Hall and the San Carlos Library, as well as links on the City’s website.

The City provides information and has links on the City'’s website pertaining to affordable housing and staff makes referrals to Project Sentinel.

Continued Appropriateness: This program is updated to provide additional information on the City’s website about fair housing and consolidated with Programs H-8.1 – 8.6 and continued in the updated Housing Element under an Affirmatively Furthering Fair Housing program.

Program H-8.3: Provide Education and Training on Fair Housing Laws.

Provide education and training on fair housing laws to City staff who interact with residents on housing matters.

Staff is educated and trained on fair housing and uses Project Sentinel as a resource to those in need.

Continued Appropriateness: This program is consolidated with Programs H-8.1 – 8.6 and continued in the updated Housing Element under an Affirmatively Furthering Fair Housing program.

Program H-8.4: Conduct Community Outreach on Fair Housing Laws.

Broaden public knowledge of fair housing laws through outreach efforts by including information in City newsletters and on the City’s website. The City will also coordinate annually with other agencies and organizations, including 21 Elements, to identify other means of informing residents about fair housing laws. The City will also provide The City provides information and has links on the City's website pertaining to affordable housing and makes referrals to Project Sentinel.

Continued Appropriateness: This program is consolidated with Programs H-8.2 – 8.6 and continued in the updated Housing Element under an Affirmatively Furthering Fair Housing program.

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EXHIBIT B
Findings Responding to Letter from Department of Housing and Community Development Dated January 6, 2023 non-English language translation of all fair housing information provided to the public on an as-needed basis.

Program H-8.5: Refer Discrimination Complaints. Refer discrimination complaints to the appropriate legal service, County or State agency.

The City provides information and has links on the City's website pertaining to affordable housing and makes referrals to Project Sentinel.

Continued Appropriateness: This program is consolidated with Programs H-8.2 – 8.6 and continued in the updated Housing Element under an Affirmatively Furthering Fair Housing program.

Program H-8.6: Provide Funding for Fair Housing Counseling Agencies. Continue to provide funding to agencies that provide free counseling to San Carlos residents on issues relating to fair housing.

The City participates in the San Mateo County Consortium, which distributes CDBG funds. Through this mechanism, Project Sentinel is provided grant funds for operation.

Continued Appropriateness: This program is consolidated with Programs H-8.2 – 8.6 and continued in the updated Housing Element under an Affirmatively Furthering Fair Housing program.

Program H-8.7: Implement Employee Housing Requirements. On an ongoing basis, ensure that the City is in compliance with State Health and Safety Code Sections 17021.5, which concerns employee housing that serves six or fewer employees.

The City treats employee housing located in single-family homes and occupied by six or fewer employees as a single-family use, consistent with State law.

Continued Appropriateness: This program is implemented and removed from the Housing Element.

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EXHIBIT C
2023-2031 Housing Element
https://www.sancarlos2040.org/documents

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San Carlos
2023-2031 Housing Element
CITY COUNCIL HEARING DRAFT JANUARY 2023

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INTRODUCTION
GENERAL PLAN 1
Contents
1 Overview of the Housing Element
2 Consistency with the San Carlos General Plan
2 State Law Requirements for Housing Element
3 Process of Preparing the Housing Element
Overview of the Housing Element
All California cities and counties are required to have a Housing Element included in their General Plan, which establishes housing goals, policies, and actions in response to community housing conditions and needs. This Housing Element has been prepared to respond to cu5rrent and near-term future housing needs in San Carlos and also provide a framework for the community’s long term approach to addressing its housing needs. The Housing Element contains goals, updated
information, and strategies (policies and implementing actions) that the City is committed to undertaking.

Housing affordability in San Mateo County and in the Bay Area as a whole is a critical issue. San Carlos’s housing conditions are reflective of many area-wide and even nation-wide trends. Over the past thirty years, housing costs have skyrocketed out of proportion to many people’s ability to pay. In addition, interest rates, construction costs, and high land costs have all increased significantly. This has a number of implications as it becomes more difficult for employers to fill vacant jobs, workers must travel longer distances into and out of San Carlos and
surrounding areas to get to work, and many young people, families, longtime residents, and people with specialized housing needs cannot find housing they can afford or that meets their needs.

The Housing Element touches many aspects of community life.

This Housing Element builds upon the goals, policies, and implementing programs contained in the City’s 2015-2023 Housing Element and other City policies and practices to address

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4 INTRODUCTION
2 GENERAL PLAN
housing needs in the community. The overall focus of the Housing Element is to enhance community life, character, and vitality through the provision of adequate housing opportunities for people at all income levels.

The Housing Element covers the planning period of January 31, 2023 through January 31, 2031.

Consistency with the San Carlos General
Plan
The San Carlos General Plan serves as the ‘constitution’ for development in the city. It is a long-range planning document that describes goals, policies and actions to guide decisionmaking. All development-related decisions must be consistent with the General Plan, of which the Housing Element is but one part. If a development proposal is not consistent with a city’s General Plan, it must be revised or the plan itself must be amended. State law requires a community’s General Plan to be internally consistent. This means that the Housing Element, although subject to special requirements and a different schedule of updates, must function as an integral part of the overall General Plan, with consistency between it and the other General Plan elements.

The 2023-2031 Housing Element was updated as part of a focused General Plan Update to address environmental safety, housing, and land use. All policies and actions in other General Plan elements were prepared to be consistent with the Housing Element. Land Use designations and densities in the Land Use Element were prepared to be consistent with this Housing Element and to accommodate San Carlos’ housing need for the 2023-2031 planning period.

The intent of the 2015-2023 Housing Element is to maintain the consistency of the Housing Element with the other General Plan Elements over time. Consistency modifications ensure that any potential impediments to implementation of the Housing
Element are addressed in the other elements of the General Plan.

State Law Requirements for Housing
Elements
State law requires each city and county to adopt a General Plan containing at certain topics (called “elements”), including a Housing Element. California State law provides more detailed requirements for the Housing Element than for any other General Plan element. This Housing Element responds to those
requirements, as well as conditions and policy directives unique to San Carlos.

Unlike the other mandatory General Plan elements, the Housing Element requires periodic updating and is subject to detailed statutory requirements and mandatory review by the State of California Department of Housing and Community
Development (HCD). According to State law, the Housing
Element must:
• Provide goals, policies, quantified objectives and
scheduled programs to preserve, improve and develop
housing.

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INTRODUCTION
GENERAL PLAN 3
• Identify and analyze existing and projected housing needs for all economic segments of the community.
• Identify adequate sites that will be zoned and available within the Housing Element planning period — between
2023 and 2031 — to meet the City’s share of regional
housing needs at all income levels.
• Undertake HCD review of the Draft Housing Element and certification of the City’s adopted Housing Element in
compliance with State law.

State law establishes detailed content requirements for Housing Elements and a regional “fair share” approach to distributing housing needs throughout all communities in California, including the Bay Area. The law recognizes that in order for the private sector and non-profit housing developers to address housing needs and demand, local governments must adopt land use plans and implement regulations that provide opportunities for, and do not unduly constrain, housing development.

The Housing Element must provide clear policies and direction for making decisions related to zoning, subdivision approval and capital improvements that relate to housing needs. The housing actions (i.e., programs) are intended to: (1) identify adequate residential sites available for a variety of housing types for all income levels; (2) focus on the provision of adequate housing to meet the needs of lower and moderate income households; (3) address potential governmental constraints to the maintenance, improvement and development of housing; (4) preserve and improve the condition of the existing affordable housing stock; and, (5) promote housing opportunities for all persons. Also in accordance with State law, the Housing Element must be
consistent and compatible with other elements (or sections) of the San Carlos 2030 General Plan.

Process of Preparing the Housing
Element
San Carlos’s history of extensive community involvement in local decision-making makes the community outreach process for the Housing Element update not only essential and highly desirable, but also a critical component of the work effort. The approach for the Housing Element update described below is consistent with State law contained in Government Code 65583(c)(7) — “The local government shall make a diligent effort 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.”
Throughout the process and discussion, the City of San Carlos has made a diligent effort to achieve public participation from all economic segments of the community. Invitations to all
community meetings were sent to local affordable housing organizations and other special needs service providers who represent low-income and special needs populations to
encourage their participation. Translation services were offered and made available upon request. All comments were considered and evaluated during the drafting of the 2023-2031 Housing Programs. Key themes from the outreach process are
summarized below.

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4 GENERAL PLAN
At its core, the Housing Element provides an opportunity to have a community conversation about how to collaboratively address local housing challenges, develop policies, and find solutions.

Engagement Process
The City’s housing engagement process was two-fold: a countywide collaboration between all jurisdictions called Let’s Talk Housing and a city-specific engagement process.
21 Elements / Let’s Talk Housing
21 Elements is a multi-year, multi-phase collaboration between all San Mateo County jurisdictions, along with partner agencies and stakeholder organizations, that aims to support jurisdictions in developing, adopting, and implementing local housing policies and programs. Let's Talk Housing is a collaborative effort between all 21 jurisdictions in San Mateo County focused on increasing awareness of and participation in the Housing Element update process.
21 Elements/Let’s Talk Housing organized a series of
countywide meetings about the Housing Element update and provided community members with an introduction of the
Housing Element update and why it matters. These meetings were attended by more than 1,000 community members. San Carlos was part of the April 13, 2021 introductory meeting.

Additionally, Let’s Talk Housing held an All About RHNA webinar and a countywide four-part webinar series to help educate and inform San Mateo County residents and
stakeholders on regional and local housing issues. The four-part series took place on Zoom in fall of 2021, focusing on the following topics and how they intersect with the Bay Area’s housing challenges and opportunities:
• Why Affordability Matters
• Housing and Racial Equity
• Housing in a Climate of Change
• Putting it All Together for a Better Future
The series included speaker presentations, audience Q&A, breakout sessions for connection and debrief discussions. The sessions were advertised and offered in Spanish, Mandarin, and Cantonese, though participation in non-English channels was limited.

Key themes that emerged included:
• Housing affordability is a public health issue: Where we live impacts our health, economic equity, environmental and racial justice
• The Three S’s: Supply, Stability and Subsidy: Increase housing supply, protect renters and vulnerable
households by providing stability, fill the gaps with
subsidies
• Implement strategies to promote climate-ready housing In addition to the discussions above, Let’s Talk Housing also sponsored four “listening sessions” with city and county staff and

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January 23, 2023 Packet Pg. 1376
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