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Request for Policy Analysis (Council Referrals)
Department Housing Rules Date 5/6/2026 Item C.2Department Rep. Name/Ext. Sarah Fields, Deputy Director Councilmember Sponsorship Vice Mayor Foley; Councilmembers Ortiz,Policy/Ordinance Subject Prefab Factory-Produced Housing Structures Candelas, and Tordillos Staff Recommendation
GREEN Adopt based on tradeoffs
outlined on next page
YELLOW Defer to a later designated
date or the annual Budget Process
RED Recommend Council not
adopt nominated idea
NEEDS CLARIFICATION OR
MORE TIME TO EVALUATE
Staff Evaluation
Is this already underway in a department work plan?
Yes No
Is this time critical or an emergency?
Yes No
Will this require substantial resources, staffing, budget, strategic support, or reprioritizing existing work plan? Yes No
Criterion to Determine Scale of Project Complexity Project complexity is determined by scoring the project in each of the 3 criterions below and then summing the score. a. Low Complexity is a sum of 6 or less. b. Medium Complexity is a sum of 7 – 9. c. High Complexity is a sum of 10 or greater.
Total Score =
Scoring Criterion
Low Complexity Medium Complexity High Complexity
Estimated Duration 6 – 9 months ܆ =1 9 - 18 months ܆ =2 More than 18 months ܆ =3 Organizational Complexity (Internal)
Can easily be absorbed into existing work plan
܆ =1 Planned work (future) ܆ =2 Work not currently proposed ܆ =3 Have staff with required skillset/knowledge
܆ =1 Have staff with required skillset/
requires moderate research
܆ =2 Do not have staff with required
skillset/requires significant research
3 =܆
Less than or equal 2 staff required
܆ =1 3 - 4 staff required ܆ =2 More than 5 staff required ܆ =3 (External) 1 Additional department; no
community outreach required
܆ =1 2 Other departments Involved;
some community outreach required
܆ =2 3 or more departments and/or external
partners involved; significant community outreach required 3 =܆
DEPT.
Required܆ Airport ܆ Auditor ܆ CMO ܆ OEDCA ܆ ESD ܆ Fire ܆ HR ܆ IT ܆ PRNS ܆ Police ܆ Retirement ܆ Attorney ܆ Clerk ܆ CMO – Budget ܆ Community Energy ܆ Finance ܆ Housing ܆ IPA ܆ Library ܆ PBCE ܆ PW ܆ DOT 6 ✔
✔ ✔ ✔
/s/ Lee Wilcox 5/5/2026 CMO Approval: Date
Analysis
Explain the rationale for staff recommendation, including any mitigating factors that need to be considered (recent legislative action, significant work plan changes, etc.). Please address the following as well. GREEN LIGHT: The Administration can implement this nominated idea under its current work plan. Item should be sent to Council to add to department work plan. (1) How will the idea be approached? (2) If adopted, what is its impact and/or tradeoff to the City Council Focus Area or to a department work plan, including strategic support? (3) What is the minimum viable scope to move the idea forward and reduce its complexity? The Housing Department will research and evaluate current opportunities and challenges associated with modular preဩfabricated housing development, as directed, and publish an information memorandum by the end of 2026. In addition to the previously identified topics (including labor standards; comparisons with traditional stickဩbuilt construction; financing options; economic and workforce benefits and drawbacks; and analysis of steel versus wood frame construction, with particular attention to opportunities for increased building height and density), the Department will also examine: (1) specific construction and development considerations unique to modular projects, (2) limitations arising from applicable tax credits and related provisions of the Internal Revenue Service Code, and (3) insurance challenges, including high deductibles and coverage gaps commonly associated with this type of development. Given the significant interest in, and ongoing development of, the modular preဩfabricated construction industry, this remains an area of active monitoring for the Department. Ongoing, systematic review of construction practices and emerging innovations that can advance Department and City objectives is essential to achieving critical policy and programmatic goals.
YELLOW LIGHT: Administration recommends Council defer this nominated idea to a later designated date or the annual Budget Process due to (describe cost implications, workload impacts, or other factors)RED LIGHT: The Administration recommends Council not to adopt this nominated idea due to (describe reason implementation would be difficult if not impossible – conflict with other laws, etc.).
Analysis (Continued)