TO: HONORABLE MAYOR FROM: Christopher Burton
AND CITY COUNCIL Jacky Morales-Ferrand
SUBJECT: SEE BELOW DATE: June 14, 2023
Approved Date
6/15/23
SUPPLEMENTAL
SUBJECT: GPT22-001/ER21-032: CITY-INITIATED GENERAL PLAN TEXT
AMENDMENT TO REVISE THE ENVISION SAN JOSE 2040 GENERAL
PLAN HOUSING ELEMENT FOR THE 2023-2031 REGIONAL HOUSING
NEED ALLOCATION (RHNA) CYCLE PROJECTION PERIOD
PURSUANT TO STATE LAW AND RELATED AMENDMENT TO
CHAPTER 7 OF THE GENERAL PLAN
REASON FOR THE SUPPLEMENTAL
The purpose of this second supplemental memorandum is to summarize the staff response to guidance from the California Department of Housing and Community Development (HCD) in its letter dated December 15, 2022, and to update the Council with a summary of the discussion and recommendations regarding the Housing Element from the June 8, 2023 Housing and Community Development Commission meeting.
BACKGROUND
On September 16, 2022, the City of San José submitted to HCD a draft 2023-2031 Housing Element. After a statutorily required 90-day review period, HCD provided a comment letter, dated December 15, 2022, detailing HCD staff’s issues with the City’s draft Housing Element.
Since December 2022, staff have worked on changes to the draft 2023-2031 Housing Element to address HCD’s comment letter. Staff held several meetings with HCD during the last six months to discuss how best to address the comments. HCD staff provided guidance on the required analysis and clarified the comments made in the letter as well. Attachment A is a detailed table COUNCIL AGENDA: 06/20/23
FILE: 23-938
ITEM: 10.2
HONORABLE MAYOR AND CITY COUNCIL
June 14, 2023
Subject: Supplemental - 2023-2031 Housing Element
with the specific comments in HCD’s December comment letter and how staff responded to the comments including the location where the changes can be found in the Housing Element document.
On June 8, 2023, the Housing and Community Development Commission discussed the draft 2023-2031 Housing Element and provided recommendations to the City Council. This followed three previous study sessions on the 2023-2031 Housing Element held on October 23, 2022, December 8, 2022, and January 12, 2023.
RESPONSES TO HCD COMMENT LETTER
As recorded in Attachment A, staff has responded to each issue raised by HCD staff and incorporated these responses into the current draft of the Housing Element. The majority of staff’s responses were technical in nature and did not materially change the substance of the draft submitted to HCD on September 16, 2022. These “technical in nature changes” included providing additional data and analysis to better explain staff’s assumptions and methodology – for example, staff clarified the methodology used to estimate site capacity and added detailed case studies of some selected sites. Other non-material changes include removal of duplicate policies/programs and consolidation of some closely related policies/programs. As examples of non-technical changes, staff removed items that had been completed or resolved in between the time staff submitted the first draft to HCD and staff’s work on the current draft – for example, item R-4 to implement a Community Opportunity to Purchase program was removed because City Council did not approve staff’s Community Opportunity to Purchase program proposal and directed staff to remove it from all City work plans. Also, per HCD’s direction, staff added several statutorily required policies and programs – for example, staff added language for monitoring progress towards Accessory Dwelling Unit production goals and measures to be taken if the City is not meeting projected production goals within the first two years of the cycle (item P-47).
COMMISSION RECOMMENDATION AND INPUT
On June 8, 2023, by a vote of six to two (6-2), the Housing and Community Development Commission recommended that City Council approve the Draft 2023-2031 Housing Element.
The vote was as follows:
Yes Finn, Dawson, Shoor, Partida, Tran, Jackson (6)
No Jasinsky, Moore (2)
Abstain None
Absent Del Buono, Vong, Navarro, Wheeler, Cardoza, Oppie (6)
As summarized in greater detail in Attachment B, Commissioners’ feedback included the following key points:
HONORABLE MAYOR AND CITY COUNCIL
June 14, 2023
Subject: Supplemental - 2023-2031 Housing Element
• Several Commissioners commented that the Housing Element represents a tremendous amount of work and expressed appreciation for staff’s efforts. • Several commissioners supported efforts by the City to document changes to the Housing Element based on HCD’s comments as well as public comments. • Several commissioners questioned the City’s ability to deliver on Housing Element goals considering the lack of staff and high rate of vacant positions, and asked about whether additional staff resources are needed.
• Two Commissioners expressed appreciation for the revisions to items related to mobilehome parks.
• Two commissioners expressed support for the City’s furthering homeownership opportunities.
• One Commissioner commented that, while the overall outreach and community engagement for the Housing Element was good, staff should have done more to solicit community feedback during the later stages of the process, as subsequent drafts of the Housing Element were being revised (i.e., after the December HCD letter). • One Commissioner expressed that part of Housing Element Chapter 3 was ill-advised and represented the City’s and the Housing Department’s ongoing overreach and over- regulation of “mom and pop” property owners.
/s/ /s/
JACKY MORALES-FERRAND, DIRECTOR CHRISTOPHER BURTON, DIRECTOR Housing Department Planning, Building and Code Enforcement
For questions, please contact Michael Brilliot, Deputy Director, Planning Division at [email protected] or Kristen Clements, Acting Deputy Director at [email protected].
ATTACHMENTS:
Attachment A: Responses to December 15, 2022 HCD Comment Letter Attachment B: Summary of Housing and Community Development Commissioner Feedback, Commission Meeting June 8, 2023
1 Attachment A:
Responses to December 15, 2022 HCD Comment Letter
HCD
Letter
(page)
HCD Comment Staff Response CSJ Chapter/
Section
Revised
A. Review and Revision
4 Review the previous element to evaluate the appropriateness, effectiveness, and progress in implementation, and reflect the results of this review in the revised element. (Gov. Code, § 65588 (a) and (b).)
As part of the evaluation of programs in the past cycle, the element must provide an explanation of the effectiveness of goals, policies, and related actions in meeting the housing needs of special needs populations (e.g., elderly, persons with disabilities, large households, female headed households, farmworkers and persons experiencing homelessness).
Staff added narrative/analysis about special needs
populations and housing.
Appendix C
(under new
heading
“Effective-
ness of goals,
policies, and
related
actions in
meeting the
housing needs
of special
needs
populations”)
B. Housing, Needs, Resources, and Constraints
4 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))
4 Contributing Factors to Fair Housing Issues: The element must identify contributing factors to fair housing issues. In addition, the element should consider prioritizing these factors to better formulate policies and programs and carry out meaningful actions to Affirmatively Furthering Fair Housing (AFFH).
Highest priority contributing factors identified and added narrative about community input for such factors.
Contributing factors were also linked to policies and
programs.
Chapter 2 (see
new heading
“Contributing
Factors to
Segregation”),
Chapter 3
4 Regional Analysis: The element describes local and regional trends and patterns in Appendix B, but must also analyze San José relative to the rest of the region for disability, familial status, Racially and Ethnically Concentrated Areas of Poverty (R/ECAPs), and Racially Concentrated Areas of Affluence (RCAAs), access to opportunity (i.e., education, economic, transportation, environmental) and some areas of disproportionate housing Staff added expanded regional analysis for R/ECAPs and
RCAAs.
Appendix B
(sub-section
III.B.1.c,
Appendix C (of
Appendix B))
2 needs (i.e., cost burden, overcrowding, substandard housing, homelessness).
4 & 5 Sites Inventory: The element includes some analysis of sites in relation to AFFH, but additional information is required to address this finding. In particular, the element should include analysis for the number of units per site by income group for each of the AFFH categories relative to the existing patterns (enforcement, all areas of access to opportunity, and impacts on patterns for all areas of access to opportunity and
disproportionate housing needs (i.e., cost burden, overcrowding, substandard housing, homelessness), and segregation and integration (i.e., disability and familial status).
Staff provided additional sites analysis requested. Chapter 5, Section 5.6
5 2. Include an analysis and documentation of household characteristics, including level of payment compared to ability to pay, housing characteristics, including overcrowding, and housing stock condition. (Gov. Code, § 65583, subd. (a)(2).)
5 Quantification of Households: The element must quantify the number of existing households by total and tenure (i.e., renter and owner), experiencing cost burden by tenure and income, and overcrowding by tenure. This information is critical as while the element provides percentages for a number of factors, these percentages without a baseline figure, do not document the scope of the potential housing problems.
Baseline numbers added, multiple locations. Appendix B
(sub-section
III, multiple
locations)
5 Housing Conditions: While the element identifies the age of the housing stock and utilizes American Community Survey (ACS) data (pages 38-39), it must also include analysis of the condition of the existing housing stock and estimate the number of units in need of rehabilitation and replacement. For example, the analysis could include estimates from a recent windshield survey or sampling, estimates from the code enforcement agency, or information from knowledgeable builders/developers, including non-profit housing developers or organizations.
Staff analyzed code enforcement data and seismic retrofit needs data and overlaid this analysis with previous age of housing stock analysis.
Appendix A
(Chapter 5.6)
3 5 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).) The City has a regional housing need allocation (RHNA) of 62,200 housing units, of which 23,775 are for lower-income households. To address this need, the element relies on approved projects, alternative adequate sites, vacant and non-vacant sites, including sites in Urban Villages, the Diridon Station and Specific Plan Area(s), and Accessory Dwelling Units (ADUs). To demonstrate the adequacy of these sites and strategies to accommodate the City’s RHNA, the element must include complete analyses:
5 & 6 Progress in Meeting the RHNA: The element indicates 20,398 units, of which 5,345 units will be affordable to lower-income households, are pending approvals, approved, or under
construction, but provides no information documenting how affordability of the units was determined (pg. 5-6; App. G). The element must describe the City’s methodology for assigning these units to the various income groups based on actual sales price or rent level of the units. In addition, to count these units as progress toward RHNA, the element must analyze and
demonstrate the likelihood and availability of these units during the planning period. The element references an estimated 60 percent of development capacity for the pipeline projects in the planning period but must include analysis to support those assumptions. For example, the element could discuss
infrastructure schedules and commitments, outreach with project developers, timelines for final approvals, and the timing of any remaining steps prior to building permits. Lastly, given the element’s reliance on pipeline projects, the element must include programs with actions that commit to facilitating development Staff provided information on how affordability levels are determined for pipeline projects (deed restrictions,
entitlement approvals, etc.); clarified that the discount rate for pipeline was based on recent study presented to City Council and included in the original 9/16/22 submittal to HCD; staff added a program (P-45 Pipeline Projects
Evaluation) in Chapter 3 as recommended by HCD.
Chapter 5,
Section 5.3.1;
Chapter 3
4 and monitoring approvals of the projects (e.g., coordination with applicants to approve remaining entitlements, supporting funding applications, commitment to expedite approvals, etc.) with a commitment to alternative actions (e.g., rezoning) if assumptions are not realized.
6 Parcel Listing: The element lists parcels by various factors such as size, zoning, and general plan designation (Appendix F). However, the description of existing use is generic (offices, retail) and must include sufficient detail to facilitate an analysis of the potential for additional development on nonvacant sites. In addition, the listing must include a calculation of the realistic capacity of each parcel. For more information, see the HCD’s Housing Element Sites Inventory Guidebook at
https://www.hcd.ca.gov/community-
development/housing-
element/housing-element-
memos/docs/sites_inventory_memo_final06102020.pdf/
Updated existing uses to provide more detail; for example, instead of “retail” used “strip mall with nail salon,
convenience store, etc.”
Appendix F
Electronic Sites Inventory: Pursuant to Government Code section 65583.3, subdivision (b), the City must utilize standards, forms, and definitions adopted by HCD when preparing the sites inventory. Please see HCD’s housing element webpage at
https://www
.hcd.ca.gov/planning-and-community-
development/housing-elements fo r a copy of the form and instructions. The City can reach out to HCD at
[email protected] for technical assistance. Please note, upon adoption of the housing element, the City must submit an electronic version of the sites inventory with its adopted housing element to
[email protected].
No changes required. Informational only. Staff will submit sites inventory as required.
N/A
6 Realistic Capacity: The element references the Tolemi Building Blocks platform, a data analysis and modeling tool that was used to calculate residential capacity on identified sites based on thirteen property attributes that are used to identify
comparables for each parcel in the inventory with similar characteristics (pgs. 5-11-12). Based on this tool, the element appears to adopt a realistic capacity assumption of 100 percent based on the comparables generated for each parcel, but the Added a substantial amount of new analysis and narrative to better describe the methods and model used to calculate a realistic residential capacity for the sites inventory. Added a discussion to explain that some sites use an “assumed maximum capacity” because the General Plan designation
of those sites do not have a maximum capacity. The
“assumed maximum capacity” was derived based on an
average of past developments with the same General Plan Chapter 5; 5-
17 to 5-22.
5 number of units for each site must be adjusted as necessary, based on the land use controls and site improvements and on the current or planned availability and accessibility of sufficient water, sewer, and dry utilities. The element should include clear supporting information on typical densities of existing or approved residential developments at a similar affordability level.
For example, the element could clearly relate the recent projects listed in Appendix K to the sites in the inventory based on zone, acreage, built density, allowable density, level of affordability, and presence of exceptions such as a density bonus. In addition, the element appears to assume residential development on sites with zoning that allows 100 percent nonresidential uses, but to support this assumption, the element must analyze the likelihood of residential development in zoning where 100 percent
nonresidential uses are allows. The analysis should be based on factors such as development trends including nonresidential, performance standards requiring residential uses, or other relevant factors such as enhanced policies and programs.
designation. Some sites capacity under this assumed
maximum exceeds 100%, but the total assigned capacity is based on past development experience.
Provided examples and discussions of selected sites to
demonstrate the capacity analysis.
Also added more discussion of the methodology used to
select properties for the inventory.
6 & 7 Suitability of Nonvacant Sites: The element includes some general discussion of non-vacant sites (pgs. 5-11-12) and references the projects in Appendix K to note that the value of land as residential and the opportunity for new housing often exceeds the value of current uses before concluding that existing prior uses such as retail or offices do not pose an impediment to additional development in the planning period. This alone is not adequate to demonstrate the potential for redevelopment of non-vacant sites in the planning period. The description of existing uses should be sufficiently detailed to facilitate an analysis demonstrating the potential for additional development in the planning period. For example, the element includes sites in Appendix F identified as single-family residences, religious institutions, mortuaries, and supermarkets, but no analysis was provided to demonstrate whether these existing uses would impede development of these sites within the planning period.
The element should also summarize past experiences converting existing uses to higher density residential development, include current market demand for the existing use, provide analysis of Rewrote this section and provided more analysis using a December 2022 survey done by the Department of Public
Works of vacant land in the City. Staff further updated Appendix K by looking at historical data and showing that many vacant sites that developed in the last site had
previous uses that were demolished prior to the last
development. Staff also added several examples of
nonvacant sites that redeveloped to market-rate and
affordable housing in the last cycle. These redeveloped sites contained multiple different uses that did not present an impediment to housing.
Chapter 5;
Section 5.4;
pg. 5-25 to 5-
27; Appendix
K
6 existing leases or contracts that would perpetuate the existing use or prevent additional residential development and include current information on development trends and market
conditions in the City and relate those trends to the sites identified. The element could also consider indicators such as age and condition of the existing structure expressed developer interest, low improvement to land value ratio, and other factors.
In addition, the housing element relies upon nonvacant sites to accommodate more than 50 percent of the RHNA for lower- income households. The element must demonstrate existing uses are not an impediment to additional residential development (Gov. Code, § 65583.2, subd. (g)(2).). Absent findings (e.g., adoption resolution) based on substantial evidence, the existing uses will be presumed to impede additional residential
development and will not be utilized toward demonstrating adequate sites to accommodate the RHNA.
7 Small Sites: Sites smaller than an half acre in size are deemed inadequate to accommodate housing for lower-income housing unless it is demonstrated 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 housing element describes other evidence to HCD that the site is adequate to accommodate lower income housing (Gov. Code, § 65583.2, subd. (c)(2)(A).). For example, a site with a proposed and approved housing
development that contains units affordable to lower income households would be an appropriate site to accommodate
housing for lower-income households. (Gov. Code, § 65583.2, subd. (c)(2)(C).). The element may need to add or modify programs based on the outcomes of the analysis.
Added a new subsection entitled “Sites smaller than 0.5- acres and lower-income housing.” This section states only eight properties in the inventory for lower-income housing are less than 0.5 acres, and discusses all eight in detail to explain why their inclusion is warranted.
Chapter 5; pg.
5-16 to 5-17.
7 Large Sites: Sites larger than ten acres in size are deemed inadequate to accommodate housing for lower-income housing unless it is demonstrated that sites of equivalent size were successfully developed during the prior planning period for an equivalent number of lower-income housing units as projected Added a new subsection entitled “Sites larger than ten acres and lower-income housing.” Only six sites in the inventory are greater than 10 acres and none are identified for lower income housing. Four sites are designated for mixed-income housing and are in North San José. These sites will be
Chapter 5; pg.
5-17.
7 for the site or unless the housing element describes other evidence to HCD that the site is adequate to accommodate lower income housing (Gov. Code, § 65583.2, subd. (c)(2)(A).). For example, a site with a proposed and approved housing
development that contains units affordable to lower income households would be an appropriate site to accommodate
housing for lower-income households. (Gov. Code, § 65583.2, subd. (c)(2)(C).). The element may need to add or modify programs based on the outcomes of the analysis.
included in the newly developed overlay (described in
Program P-3) for the area that will require a portion of the site and its units dedicated to lower-income housing.
8 Zoning for Lower-Income Households: The element indicates in Appendix F that the City is utilizing several parcels in the Residential Neighborhood (R-1-8 district) (with a maximum density 8 units per acre) to accommodate a portion of the lower- income need. While the inventory does state these sites are subject to General Plan Policy IP-5.12, it is HCD’s understanding that a project would have to be 100 percent affordable to qualify for the higher density. As the site inventory seems to assume a mix of capacity for above moderate-income households and lower-income households, it is not clear what the expected density is for the site or whether the site requires rezoning to achieve the
densities allowed. For communities with densities that meet specific standards (at least 30 units per acre for San José), no analysis is required. (Gov. Code, § 65583.2, subd.
(c)(3).) Otherwise, an analysis must demonstrate appropriate densities based on factors such as market demand, financial feasibility, and development experience within
identified zones.
The site in question was incorrectly classified as a lower- income site. This site was intended to meet above-
moderate income RHNA. Clarification made.
Appendix F
8 Publicly-Owned Sites: The element must include additional discussion on publicly-owned sites identified to accommodate the RHNA. Specifically, the analysis should address general plan designations, allowable densities, support for residential capacity assumptions, existing uses, and any known conditions that preclude development in the planning period and the potential schedule for development. If zoning does not currently allow residential uses at appropriate densities, then the element must include programs to rezone sites pursuant to Government Code Added a section on the potential for redevelopment of each of the publicly-owned sites included in the opportunity sites inventory. There are five City-owned sites and one County- owned site. There are no plans to sell the properties and the City will comply with the Surplus Land Act.
Chapter 5; pg.
5-13 to 5-16.
8 section 65583.2, subdivisions (h) and (I). In addition, the housing element must include a description of whether there are any plans to sell the property during the planning period and how the jurisdiction will comply with the Surplus Land Act (Article 8 (commencing with Section 54220) of Chapter 5 of Part 1 of Division 2 of Title 5).
8 Assembly Bill 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 should allow at least four units of housing (e.g., four plex or greater) (Gov. Code section 65583.2, subd. (c)(4)).
Staff added a new section in Chapter 5 showing compliance with provisions of AB 725.
Chapter 5,
Section 5.3.6
8 Adequate Sites Alternatives: To credit the Homekey 2.0 rehabilitation projects toward the City’s regional housing need, the element must demonstrate compliance with all the statutory requirements (Gov. Code, § 65583.1). For additional information and an Alternative Adequate Sites Checklist, see the Building Blocks at
https://www.hcd.ca.gov/planning-and-community-
development/housing-elements/building-blocks/adequate-sites- alternative.
After further discussions with HCD it was determined that Homekey sites were not eligible as alternative adequate sites because the deed-restrictions did not meet the
minimum 55 yrs. and/or the renovations to the units did not include a kitchen/bath to qualify as dwelling units.
Chapter 5
8 & 9 Accessory Dwelling Units (ADU): The element assumes an ADU build out of 3,556 ADUs and/or junior accessory dwelling unit (JADUs) over the eight-year planning period. According to HCD records, 192 units were permitted in 2018, 416 were permitted in 2019, and 331 were permitted in 2020. The trends noted in the element appear inconsistent with HCD records and, further, do not support an assumption of 445 ADUs per year. To support assumptions for ADUs in the planning period, the element should reconsider assumptions, reconcile trends with HCD records, include additional information such as resources and incentives, other relevant factors, and modify policies and programs as appropriate. In addition, after a cursory review of the City’s ordinance, HCD discovered several areas that were not
consistent with State ADU Law. This includes, but is not limited to, bedroom limitations, design requirements, and standards in the Historic District, among others. HCD will provide a complete listing of ADU non-compliance issues under a separate cover. As a result, the element should add a program to update the City’s Staff reviewed the 2018-2022 Housing Element Annual
Progress Reports submitted to HCD and amended unit
counts as required. A new program, P-47 Accessory
Dwelling Unit, Monitoring and Ordinance Compliance, was added as recommended by HCD.
Chapter 5,
Section 5.3.2;
Chapter 3
9 ADU ordinance in order to comply with state law. For more information, please consult HCD’s ADU Guidebook, published in December 2020, which provides detailed information on new state requirements surrounding ADU development.
9 Suitability and Availability of Infrastructure: The element must demonstrate sufficient existing or planned water, sewer, and other dry utilities supply capacity, including the availability and access to distribution facilities to accommodate the City’s regional
housing need for the planning period. (Gov. Code, § 65583.2, subd. (b).)
Staff provided this analysis in Chapter 5. Chapter 5,
5.3.4 9 Water and Sewer Priority: For your information, water and sewer service providers must establish specific procedures to grant priority water and sewer service to developments with units affordable to lower-income households. (Gov. Code, § 65589.7.) Local governments are required to immediately deliver the housing element to water and sewer service providers. HCD recommends including a cover memo describing the City’s housing element, including the City’s housing needs and regional housing need.
No changes required. Informational only. N/A
9 Sites with Zoning for a Variety of Housing Types:
Emergency Shelters: The element indicates that there is insufficient capacity to accommodate the identified need for shelters (pg. 4-42). (Gov. Code, § 65583, subd. (a)(4).) If the element cannot demonstrate sufficient capacity to accommodate the identified need, a program to identify a zone or zones where emergency shelters are allowed as a permitted use without a conditional use or other discretionary permit to accommodate the remaining capacity must be completed within one year of the adoption of the housing element. In addition, the element should determine whether parking requirements comply with AB 139 (Chapter 335, Statutes of 2019), which limits parking
requirements to employee parking and add or modify programs as appropriate. Lastly, the housing element must demonstrate Staff included a new program, H-14 Emergency Housing, to ensure direction from HCD is completed. There are no
minimum parking requirements for emergency shelters
since the new Parking/TDM ordinance became effective in April 2023; staff has provided the requisite analysis which shows current standards are not a constraint to emergency shelter production.
Chapter 3; pg.
3-28 to 3-29.
10 the permit processing, development, and management standards for emergency shelters are objective and encourage and facilitate the development of, or conversion to, emergency shelters.
9 Housing for Farmworkers: The element indicates that temporary farm labor camps are permitted conditionally in the Agriculture District (page 4-47). However, the element must demonstrate the zoning is consistent with the Employee Housing Act (Health and Safety Code, § 17000 t seq.), specifically, sections 17021.5 and 17021.6. Section 17021.5 requires employee housing for six or fewer employees to be treated as a single-family structure and permitted in the same manner as other dwellings of the same type in the same zone and while the element noted that no records exist on file for this type of use, it must still clarify the City’s compliance with Section 17021.6.
Staff amended program I-3 Farmworker Housing, to address changes requested by HCD.
Chapter 3; pg.
3-51.
10 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. 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 Government Code section 65584 and from meeting the need for housing for persons with disabilities, supportive housing, transitional housing, and emerge
10 Land-Use Controls: While the element included a general discussion of land use controls (pgs. 4-9-21), it must still identify all relevant land use controls for zones that accommodate housing controls (i.e., Downtown, Diridon Station, Urban Villages) and analyze the impacts as potential constraints on a variety of housing types. The analysis should analyze land use controls independently and cumulatively with other land uses. In addition, the analysis should specifically address covered parking and guest parking requirements for multifamily development, height limits of 35 feet in several mixed-use districts, and multifamily development in zones permitting multifamily development that requires a Conditional Use Permit (CUP).
Staff provided substantial new information and analysis on the requested zoning districts, standards and land-use
controls.
Chapter 4,
Sections 4.3.2
& 4.3.3
11 10 Fees and Exactions: The element must describe all required fees for single-family and multifamily housing development, including impact fees, and analyze their impact as potential constraints on housing supply and affordability. For example, the analysis could identify the total amount of fees and their proportion to the development costs for both single-family and multifamily housing. Further, the element indicates that fees for multifamily projects are significantly greater than those for single-family projects, an uncommon observation not found in other
comparable jurisdictions, as indicated on Table 4-13 (pg. 4-38).
Excessive fees for multifamily projects have significant impacts on housing affordability and production. The element should include an evaluation of these fees and add programs to address the constraint as appropriate.
Added additional analysis from the Cost of Residential
Development Update presented to Council in November
2022. The single-family housing fees in the first draft did not include parks impact fees and incorrectly calculated the City’s construction taxes. The updated amount showed a
per unit fee higher than multifamily while still lower than most other jurisdictions in the region.
Chapter 4;
Section 4.3.7;
pg. 4-50 to 4-
53; Table 4-
20. 10 & 11 Local Processing and Permit Procedures: While the element provides some discussion of processing and permit procedures required for housing developments (pgs. 4-31-35), a complete analysis must evaluate the processing and entitlement
procedures by for potential constraints on housing supply, cost, timing, financial feasibility, approval certainty, and ability to achieve maximum densities. Specifically, the element must describe the procedures for a typical single-family and multifamily development by zone (i.e. Downtown, Diridon Station, Urban Villages) and permit type (i.e. Planned
Development). As noted in the analysis, examples of processes that could constrain development include the discretionary review of the application for building permits, as the element indicates that a Site Development Permit (H) or Special Use Permit (SUP) is approved at the director-level, but also subjected to weekly public hearings to “ensure that basic health and safety, and general welfare concerns are met” and that “permits may be appealed to the Planning Commission” (pg. 4-31), which could result in impacts to the cost of the project, timing, and certainty for approval. As another example, the element identifies typical approval findings for various permits on Table 4-11 and concludes that they do not act as constraints on residential development. However, the element should analyze decision- Staff provided additional information and analysis as
requested (single-family permits, multi-family); staff also added a new program, P-41 Review and Revise Planning
Permit Conditions, to ensure standard permit findings are objective and do not cause constraints on housing.
Chapter 4;
Section 4.3.6;
Chapter 3
12 making standards such as uses that are “mutually compatible and aesthetically harmonious,” compatible with the “character of the neighborhood,” and ones that do not “impair the utility or value of property of other persons...” (pg. 4-34) for their impact as potential constraints on housing supply and affordability. Based on the outcomes of a complete analysis, the element must add or modify programs as appropriate.
11 On/Off-Site Improvements: While the element provides general discussion of on/off-site improvements (pages 4-24-25), it must also identify actual subdivision level improvement requirements, such as minimum street widths (e.g., 40-foot minimum street width) and analyze their impact as potential constraints on housing supply and affordability.
Staff provided additional information and analysis on
on/off-site improvements.
Chapter 4,
Section 4.3.3
11 Zoning, Development Standards, and Fees: The element must clarify its compliance with new transparency requirements for posting all zoning, development standards, and fees on the City’s website and include programs if appropriate.
Staff clarified that it provides the required information on the Planning Department’s website.
Chapter 4,
Section 4.3.6
11 State Density Bonus Law (SDBL): The City’s current density bonus ordinance should be reviewed for compliance with current state density bonus law (Gov. Code, § 65915) and include a program to modify or update the ordinance as necessary.
Staff added a program, P-43 Update City Density Bonus, to ensure the ordinance will be revised as required.
Chapter 3
11 Constraints on Housing for Persons with Disabilities: Reasonable Accommodation: While the element briefly described the
reasonable accommodation process (pg. 4-39), it must fully evaluate the City’s written procedures and processes, including approval findings, for potential constraints on housing for persons with disabilities and consistency with current
Department of Housing and Urban Development’s (HUD)
guidance on reasonable accommodation procedures. This is especially significant because public comment identified the City’s Reasonable Accommodation procedures, particularly for mobilehomes, as existing constraints on housing.
Supplemental analysis was provided that determined the
fees for a Reasonable Accommodation Request may be a
constraint. Staff added a program, I-19 Reasonable
Accommodation, to update the ordinance to
streamline Reasonable Accommodation review process,
provide additional clarity, and ensure consistency with State and Federal laws and Affirmatively Furthering Fair Housing (AFFH).
Chapter 4,
Section 4.3.8;
Chapter 3
13 Group Homes for Seven or More: Group homes for seven or more persons appears to be excluded from several zones
allowing residential uses (pgs. 4-16; 4-40) and subject to a conditional use permit (CUP). Zoning should simply implement a barrier-free definition of family instead of subjecting, potentially persons with disabilities, to special regulations such as the number of persons, population types and licenses, or higher discretionary standards where an applicant must demonstrate compatibility with the neighborhood, unlike other residential uses. The element should include specific analysis of these and any other constraints, including their enforcement, for impacts on housing for persons with disabilities and add or modify programs as appropriate.
Staff added a program, P-42 Group homes for seven or more persons, to update the ordinance to ensure only the
generally applicable, nondiscriminatory health, safety, and zoning laws that apply to all single family residences are applied for this type of group home.
Chapter 3
11 & 12 5. 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, the price of land, the cost of construction, the requests to develop housing at densities below those anticipated in the analysis required by subdivision (c) of Government Code section 65583.2, 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 Government Code section 65584. 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. (Gov. Code, § 65583, subd. (a)(6).)
12 Approval Times and Requests Lesser Densities: The element must include an analysis of requests to develop housing at densities below those identified in the sites inventory and address any hinderances on the jurisdiction’s ability to accommodate RHNA by income category and include programs as appropriate.
Staff provided the required analysis and determined there are no hindrances imposed by the city to achieve the
densities allowed.
Chapter 4
12 6. Analyze any special housing needs such as elderly; persons with disabilities, including a developmental disability; large families; farmworkers; families with female heads of households; and families and persons in need of emergency shelter. (Gov. Code, § 65583, subd. (a)(7).)
12 Special Needs Households: While the element includes some data, a general discussion of housing challenges faced by special needs households, and proposed programs, it must still provide an analysis of the existing needs and resources for each special need group including seniors, female-headed households, large households, extremely low-income (ELI) households, and persons Staff added narrative about special needs housing to
Chapter 2 and expanded analysis in Appendix B.
Chapter 2,
Appendix B
(Subsection
III.D.1-9)
14 with disabilities. For example, the element should discuss the existing resources to meet housing needs (availability of shelter beds, number of large units, number of deed restricted units, community services, etc.,) and an assessment of any gaps in resources. Local officials, special needs service providers, or City social and health service providers may be able to assist with information to complete the analysis. The element may need to add or revise programs and policies based on the outcomes of a complete analysis.
12 Farmworkers: While the element provided some data on the student migrant farmworker population and regional analysis utilizing USDA data (pgs. 68-69), it must still quantify the number of seasonal and permanent farmworkers in the City.
Staff added farmworker data. Appendix A
(Chapter 6.6)
12 Persons with Disabilities: While the element provides percentages for the total number of persons with disabilities (pgs. 59-60), it must specifically quantify the total number of persons with disabilities.
Staff added baseline numbers. Appendix B
(Subsection
III.D.1.a.)
12 7. Analyze the opportunities for energy conservation with respect to residential development.(Gov. Code, § 65583(a)(8).)
12 The element must include an analysis of energy conservation opportunities in residential development. The analysis should facilitate the adoption of housing element policies and programs.
For example, programs could provide incentives to promote higher density housing along transit, encourage green building techniques and materials in new construction and remodels, promote energy audits and participation in utility conservation programs, and facilitate energy conserving retrofits upon resale of homes.
Staff created a new chapter (Opportunities for Energy
Conservation) which provides the required analysis.
Chapter 6
12 & 13 8. Analyze existing assisted housing developments that are eligible to change to non-low-income housing uses during the next 10 years due to termination of subsidy contracts, mortgage prepayment, or expiration of use restrictions. (Gov. Code, § 65583, subd. (a)(9)
15 13 The element states the City has a portfolio of 1,826 affordable housing units that may be at-risk to conversion to market rate.
However, it appears as if this listing of projects may be incomplete. Pursuant to information provided to HCD from the California Housing Partnership, the following developments may also be at risk of conversion during the next 10 years: Villa Savannah Apartments (138 assisted units located on 4501 Renaissance Drive), Country Hills (62 assisted units located on 124 Rancho Drive), Conrad House (4 assisted units located on 1797 Conrad Avenue), Henry Street (5 assisted units located on 349 South Henry Avenue), San Jose Gardens (162 assisted units located on 4668 Albany Drive), Mayfair Golden Manor (210 assisted units on 2627 Madden Avenue), Capitol Manor (33 assisted units located on 175 North Capital Avenue), Homebase Homes (24 assisted units located on 1033 Lick Avenue), Milagro (15 assisted units located on 2850 Rose Avenue), unknown (4 assisted units located on 1713 Ross Circle), unknown (4 assisted units located on 1726 Ross Circle), unknown (4 assisted units located on 1731 Ross Circle), Donna (4 assisted units located on 1794 Donna Lane), Barker (4 assisted units located on 3825 Barker Drive, 4 assisted units located on 5668 Hoffman Court, 4 assisted units located on 5684 Hoffman Court, and Casa Camino (4 assisted units located on 96 South 10th Street).
In addition, while the element lists an inventory of at-risk units utilizing federal and state funding, the element must also analyze deed-restricted affordable housing units using local
governmental assistance such as density bonus or inclusionary program that are at-risk of converting to market-rate within the next ten years. The element must also identify qualified entities that could assist with maintaining affordability.
Staff compared data from the City’s internal database with the CHPC information provided by HCD and summarized
why listed sites were not included (some properties already have been extended, some have later expiration dates,
some have already expired).
Appendix B
(Subsection
III.B.4.b.)
C. Housing Programs
13 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
16 the policies and achieve the goals and objectives of the Housing Element through the administration of land use and development controls, the provision of regulatory concessions and incentives, and the utilization of appropriate federal and state financing and subsidy programs when available. The program shall include an identification of the agencies and officials responsible for the implementation of the various actions. (Gov. Code § 65583, subd. (c).)
13 & 14 Programs must demonstrate that they will have a beneficial impact within the planning period. Beneficial impact means specific commitment to deliverables, measurable metrics or objectives, definitive deadlines, dates, or benchmarks for implementation. Deliverables should occur early in the
planning period to ensure actual housing outcomes. The
element must provide quantified objectives where
appropriate, and all programs should be evaluated to ensure provision of discrete timing (e.g., month and year) to account for how the action will occur as well as to ensure a beneficial impact throughout the planning period. The element may
include aspirational and complex programs with actions and timelines beyond the planning period (“ongoing,” “research” “create a study...”). However, these programs should be ancillary and denoted in some manner. As an example,
Program N-7 (External Infrastructure Funding to Create
Complete, High-Quality Living Environments) commits the City to “prioritize” investments in lower-income
neighborhoods but does not describe how it will engage in such actions. As another example, Program S-24 (Targeted Fair Housing Outreach and Enforcement) commits the City to increasing fair housing education, monitoring, and
enforcement in target neighborhoods from 2023-2031, but does not identify which areas are to be prioritized nor does it include metrics to measure the impact(s) of targeted fair housing outreach and enforcement.
Staff added language in Chapter 2 and Chapter 3 to
demonstrate beneficial impacts of programs within the
planning period. Staff updated 50+ strategies throughout Chapter 3 to provide more discrete timing and targeted
outcomes. Staff also added an implementation table in
Chapter 3 to show strategies designated as short, medium, long and ongoing.
Chapter 2 and
Chapter 3
14 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,
17 mobilehomes, housing for agricultural employees, supportive housing, single-room occupancy units, emergency shelters, and transitional housing (Gov. Code, § 65583, subd. (c)(1).)
14 As noted in Finding B3, 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:
No need for staff to do anything at this time. N/A
14 & 15 Availability of Zoning (Program P-1): The element indicates that certain sites will need to be rezoned to allow for residential uses and the appropriate densities to
accommodate the RHNA. However, it is unclear from the
sites inventory which sites are expected to be rezoned and timing for when those rezones will occur. In addition, while the Element does include Program P-1 (Align Zoning with the General Plan) to complete this rezoning upon adoption of the housing element, please note that if zoning is not in place by the beginning of the planning period (January 31, 2023), for sites that are expected to accommodate the City’s lower- income RHNA, programs must commit to housing element
rezone requirements pursuant to Government Code section 65583.2 (h) and (i). Specifically, the program must identify acreage, allowable densities, and anticipated units to be rezoned and must commit to:
• Permit owner-occupied and rental multifamily uses by-right for developments in which 20 percent or more of the units are affordable to lower-income households. By-right means local government review must not require a CUP, planned unit development permit, or other discretionary review or approval;
• Accommodate a minimum of 16 units per site;
• require a minimum density of 20 units per acre; and
• At least 50 percent of the lower-income need must be
accommodated on sites designated for residential use only or on sites zoned for mixed uses that accommodate all of the very low and low-income housing need, if those sites:
Staff clarified rezonings with additional narrative and notes that Appendix F, Table B includes complete list of sites that require rezoning. To clarify the intent of Program P-1 Align zoning with the General Plan (that this work is not related to RHNA goals and sites inventory) the program language has been amended. Also, staff added a new program, P-46
Rezoning Program for Shortfall, low income sites, to capture the requirements under Government Code section 65583.2
(h) and (i).
Chapter 5,
Section 5.5;
Appendix F
18 allow 100 percent residential use, and
require residential use occupy 50 percent to the total floor area of a mixed-use project.
15 In addition, as you are aware, pursuant to SB 940 (statutes of 2020), the City from certain provisions of the Housing Crisis Act (Government code section 66300) relating to lowering the intensity of land use in order to allow for the City to proceed with general plan and zoning consistency efforts.
These provisions sunset upon the due date of the housing element (January 31, 2023).
Informational only. N/A
15 Urban Villages: The element includes many complex and challenging strategies, notably its Urban Villages, that are essential to the City’s approach in addressing its housing needs. However, several uncertainties or potentially
changing circumstances surround the beneficial impact of the programs in the planning period which should be addressed in the element. As an example, the City identifies some existing constraints to the Urban Villages strategy, including costs to prepare plans and “unplanned” Urban Village areas (pgs. 4-10-11). While the element does contain Program P-37 (CEQA Analysis for Urban Villages) to commit the City to identify funding and conducting program-level CEQA analysis for Urban Villages by 2027, the timeline for implementation is too late in the planning period. As another example, the element could include a program to conduct an in-depth mid- term evaluation of actions that incentivize or remove
constraints on Urban Villages, including effectiveness, and commit to making adjustments within a specified time
period. Finally, the element could describe its progress in completing the Urban Village Plan updates outlined in Project 4 (Five Wounds Urban Village Plans Update) and Project 5 (Consolidated Light Rail Station Urban Village Plan) of its Local Early Action Plan (LEAP) grant.
While the Urban Village Strategy is discussed as a constraint due to the resources that have been required to complete plans, sites identified to accommodate the RHNA in the City are not dependent upon completing Urban Village plans. All sites have the necessary General Plan designation or qualify for a General Plan policy that allows housing today. Staff discussed this with HCD staff in detail during the revision process. Staff added language to Program P-40, Evaluate Urban Village planning process, to clarify that the strategy was intended to unlock more sites for housing beyond those identified to accommodate the RHNA.
Chapter 3; pg.
3-16
15 Program R-6 (Mobilehome Park General Plan Designation for Remaining 56 Mobilehome Parks): Given the importance of this housing type in addressing a variety of housing needs Program R-6 was revised and now states that completion of this work will occur by June 2024.
Chapter 3; pg.
3-21.
19 and its impacts on potentially displaced residents,
implementation of Program R-6 should be revised to occur earlier in the planning period than 2026.
15 3. Address and, where appropriate and legally possible, remove governmental and nongovernmental constraints to the maintenance, improvement, and development of housing, including housing for all income levels and housing for persons with disabilities. The program shall remove constraints to, and provide reasonable accommodations for housing designed for, intended for occupancy by, or with supportive services for, persons with disabilities. (Gov. Code, § 65583, subd. (c)(3).)
15 & 16 As noted in Finding(s) B4 and B5, the element requires a complete analysis of potential governmental and
nongovernmental constraints. Depending upon the results of that analysis, the City may need to revise or add programs and address and remove or mitigate any identified
constraints.
Informational only. See response to B4/B5 above. N/A
16 4. 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))
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. (Gov. Code, § 65583, subd. (c)(5).)
16 Strategies, Actions, Metrics, and Milestones: To facilitate meaningful change and achieve beneficial impact during the planning period, programs must have specific commitments, metrics or numerical targets, geographic targeting, and definitive timelines such as deadlines, dates, or benchmarks for
implementation. While the element has included many
meaningful and significant policies and actions that address the identified fair housing issues, programs, or actions should be modified with definitive metrics and timelines, as follows:
Metrics: The element must revise its fair housing policies and actions to include metrics or numerical targets
Staff added detailed targets for metrics and more discrete/ segmented timelines for 50+ programs and policies, with a focus on those that have significant and meaningful AFFH outcomes and those related to Production and
Preservation.
Chapter 3
20 toward significant and meaningful AFFH outcomes.
Additionally, where appropriate, metrics should be
targeting impacts for people, households, and
neighborhoods (e.g., number of people or households
assisted, number of housing units built, number of parks or infrastructure projects completed).
Milestones: The element included some general timelines for AFFH programs, but the element should be revised to include discrete timelines for implementation throughout the planning period.
D. Quantified Objectives
16 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).)
16 The element must Include quantified objectives estimating the number of housing units by income category that can be
constructed, rehabilitated, and conserved over a five-year time period.
Staff added quantified objectives table. Chapter 3,
Table 3-10
and Table 3-
11 Attachment B
Summary of Housing and Community Development Commissioner Feedback Commission Meeting June 8, 2023
Following are summaries of Commissioners’ comments from the Commission’s consideration of the Housing Element at its June 8, 2023 meeting.
In addition, summaries of past public and Commissioner comments at three Commission study sessions can be found in the Commission’s packet for its June 8, 2023 meeting, starting on online page 65. https://www.sanjoseca.gov/home/showpublisheddocument/99050 Commissioner Comment
Huy Tran Stated that City will have an easier time meeting its RHNA goals if it can guarantee affordable housing funding. Asked about alignment of the City’s Siting Policy with the Housing Element, and if there is enough inventory in high-resource areas to build affordable housing. Questioned if proposed planned density in urban villages will come to fruition in the 8-year planning period. Voiced support for including a matrix in the Housing Element that details HCD’s comments and staff’s responses. Noted that when strategies are developed from an equity analysis, they are often too broad, and don’t address the problem. Expressed support for the Housing Element’s focus on equity but encouraged staff to evaluate equity analyses and consider how to advance specific targeted solutions that help promote equity.
Roberta Moore
Voiced support for preservation and housing stability. Noted the importance of “mom and pop” landlords in keeping rents predictable and stable.
Expressed concern for policies in the Housing Element that help a small number of tenants rather than increasing voucher programs to help a larger number of tenants. Suggested the City should subsidize inclusionary housing requirements to encourage more housing to be built. Believes that the City over-regulates property owners. Voiced support for prioritization of mobilehome General Plan designation work and promoting paths to homeownership. Voiced concern that too many regulations will put “mom and pop” landlords out of business.
Daniel Finn Voiced support for staff’s accelerating the mobilehome General Plan redesignation timeline to 2024 and removing R-10 on local inspections for mobilehome parks from the Housing Element.
Don Jackson Voiced support for a document or database that tracked public comment in the Housing Element process and staff’s responses. Asked if delay of Google’s Downtown West development would affect City’s ability to meet Housing Element goals.
Ryan Jasinsky Thanked staff for flexibility in responding to mobilehome park owners and residents’ concerns by eliminating strategy R-10 on local inspections of mobilehome parks. Asked if the increase in Class A units have helped stabilize Commissioner Comment
other rents and lowered the cost of Class B, Class C units. Expressed importance of equity and exploring programs that would allow purchase of an apartment unit or mobilehome to serve as a pathway for a downpayment on single-family home. Voiced support for homeownership programs which encourage greater investment and involvement in the community and can shift dynamics to create better resourced neighborhoods. Suggested that private or philanthropic sources of capital could help the City meet its needs.
Roma Dawson Said it was great that she could see many of staff’s edits to the Housing Element tied directly to HCD’s feedback letter from December 2022. Voiced concern for the delay in Housing Element completion, that staff should explain why, and that the lack of public involvement in the later stages resulting in erosion of public trust. Expressed concern for consideration of the Housing Element at the same time of the Mayor’s recent proposal to reallocate Measure E funds away from permanent affordable housing. Expressed strong concern that there has been no replacement preservation policy for COPA since it was rejected by City Council. Voiced support for preservation strategies and encouraged staff to highlight that preservation costs so much less than new construction of affordable housing. Stated strong support for current state legislation (SB 225 Caballero) that would provide preservation funds that the City should leverage. Stated that the Housing Element was too weak on focusing on implementation of anti-displacement policies and programs. Encouraged the City to revisit its urban village strategies as it seems to place focus on planning but lacks production of units. Encouraged staff to conduct robust outreach with a focus on language access by hiring a community-focused planner. Said the Housing Element should be the organizing principle for staff’s work and that it needs to be supported and reinforced by the City Manager’s Office. Questioned the capacity of City to deliver on Housing Element goals given low staffing levels and inability to fill vacant positions.
Alex Shoor Expressed support for creating an empty homes tax. Voiced concern for the exodus of Black residents, lack of homeownership and questioned if data showing these trends could justify a policy to address a race-targeted homeownership initiative. Questioned why so many strategies are focused on Diridon Station. Suggested the City should consider tying rent stabilization to income eligibility under Strategy S-29. Expressed support for streamlining permitting and prioritization of mixed-use development to increase affordable housing stock. Expressed the importance of public comments reflected in the Housing Element to enhance transparency and the public’s trust in government. Voiced support for strategies I-7 and H-12 regarding community engagement and stated that community “education” should be included as well. Voiced support for strategy I-9 on equitable representation on city bodies. Expressed concern on the City’s low staffing levels and questioned Commissioner Comment
whether existing City staff could carry out the strategies of the Housing Element, or if additional resources are needed.
Victoria Partida Expressed support for increasing homeownership programs and increased investment in communities as a result of homeownership.