Agenda packet — San Mateo City Council, May 23, 2022 (part 4 of 4)

11 54%
46%
74%
26%
0%
10%
20%
30%
40%
50%
60%
70%
80%
Owner Occupied Renter Occupied
Ownver vs Renter Occupancy
% of San Mateo Benchmark % of Event
21%
15%
32%
21%
11%
0%
9%
26%
39%
26%
0%
5%
10%
15%
20%
25%
30%
35%
40%
45%
Under 18 18-29 30-49 50-69 70+
Age
% of San Mateo Benchmark % of Event
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C I T Y O F S A N M A T E O 2 0 31 H O U S I N G E L E M E N T Appendix H-F

COMMUNITY NEEDS AND HOUSING NEEDS WORKSHOP - COMMUNITY RELATIONS COMMISSION – SEPTEMBER 29, 2021: SPEAKER NOTES

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CRC 9/29/2021 – meeting notes
Speaker notes (in order of speaker):

1. A staff representative from HIP Housing, a Home sharing program: HIP Housing is celebrating their 50th Anniversary and their archives show housing challenges from 20-30 years ago that are still relevant today. It takes a variety of housing choices to address housing needs, which the Home Sharing program provides. About 30% of Home Share matches in their program are in San Mateo. About 50% of home share seekers state that their reason for using the program was that the client needed a place to stay near family or caregivers. The coronavirus pandemic posed additional challenges due to loss of income and home owners used Home Sharing as a way to keep their housing costs below 30% of their monthly income. Most of Home Share owners were in the older age group (90 yrs +). They hope home sharing can remain a housing program of San Mateo.

2. A staff representative from Mid-Pen Housing, an affordable housing developer: Mid Pen is breaking ground soon on Downtown affordable housing project (Kiku Crossing) which has 225 affordable housing units. Mid-Pen operates three properties in the city and there are approximately 18,000 people on the wait list in the County. There are approximately 25,000 low- income people in the County who do not have access to housing. Studies have shown that the high housing costs have disproportionately affected people of color. Historically, resources have not been shared equally; affordable housing can and should be in San Mateo’s future.

3. A staff representative from Housing Choice: There are 817 residents in San Mateo with developmental disabilities and many live with their parents due to lack of housing. The best way to address this need is to use CDBG funds to incentivize developers to include units for people with severe disabilities. Cities can grant additional points for housing or services in developments for people with developmental disabilities.

4. A regional center client of Housing Choice: Speaking as a representative of someone with developmental disabilities, the city has a hammer to make developers build affordable housing and should use it wisely and firmly. Cities need to ask the following questions: 1) If there are $5,000/month units, why not have 1-2 units for $1,000-2,000/month? 2) Where are people supposed to park? His place has a fire hydrant in front of the building, so there is no ability for handicapped parking or loading zone for residents/people with disabilities.

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C I T Y O F S A N M A T E O
20 40 G E N E R A L P L A N

H O U S I N G E L E M E N T

Appendix H-F
21 ELEMENTS LISTENING SESSIONS – SUMMARIES OF PUBLIC ENGAGEMENT EVENTS HELD AT THE SAN MATEO COUNTYWIDE LEVEL FOR HOUSING ELEMENT ISSUES.

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1 MEETING SUMMARY
A

Countywide Stakeholder Listening Session #1: Fair Housing 9/27/2021, 1-2:30 pm on Zoom

Overview
On September 27, 2021, 21 Elements hosted the first of four housing element stakeholder listening session with several organizations focused on fair housing issues. Presenters, resources and details on what we heard follow.

Key themes included:
• Concern about the upcoming end of the eviction moratorium • The importance of transit-oriented affordable housing and stronger anti-displacement policies • The need for more education around accessibility regulations and reasonable accommodation • The ability of jurisdictions to use their platform (including jurisdiction websites) to promote education and resources for tenants and landlords.

Policies & Programs to consider:
• More funding for subsidized affordable housing near transit or good access to transit • Stronger just cause protections
• Rent stabilization and rent registries as a tool
• Tenant and community first right of purchase or right of first refusal (TOPA and COPA) • Creation of more ADUs and program to increase access for lower-income people Stakeholder Presenters & Additional Resources
Organization Speaker Name Contact
Center for Independence of
Individuals with Disabilities
Benjamin McMullan, Systems
Change Advocate
[email protected]
Community Legal Services
of East Palo Alto (CLSEPA)
Michelle Trejo—Saldivar, Law
Fellow, Housing Program
[email protected]
Housing Equality Law
Project
Mary Prem, Executive Director [email protected] Legal Aid for San Mateo
County
Shirley Gibson, Directing Attorney [email protected] Project Sentinel Ann Marquart, Executive Director [email protected] Housing Choices Jan Stokley, Executive Director
Kalisha Webster, Housing Advocate
(presented at a prior meeting)
[email protected]
[email protected]
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2 Public Interest Law Project Michael Rawson, Director, (unable to attend)
[email protected]
Root Policy Research AFFH
consultant to 21E
Heidi Aggeler, Managing Director [email protected]

Jurisdictions in Attendance

Belmont Millbrae San Mateo (County)
Brisbane Pacifica South San Francisco
Burlingame Portola Valley Woodside
Daly City Redwood City
East Palo Alto San Bruno California Department of
Half Moon Bay San Carlos Housing and Community
Menlo Park San Mateo (City) Development (HCD)

Key Themes and Actions
• Eviction Moratorium: There was widespread concern about what will happen when the California eviction moratorium ends on October 1, 2021. Just Cause eviction ordinances and Covid rent relief (especially for back rent) have been important to keep people in their homes.

CLSEPA shared a flyer after the session with a summary of renters’ rights and resources.

• Vulnerable Populations: The stakeholder groups shared several details about the housing needs of the most vulnerable populations.
o People with disabilities experience the most housing discrimination. Legal assistance organizations get the most calls regarding discrimination against people with and find it is the most misunderstood category.
o Displacement disproportionately affects Latinx, African American/Black households and families with children.
o Many or most evictions are no-fault evictions, not resulting from a failure to pay rent.

• Anti-Displacement Policies: Jurisdictions were curious about which anti-displacement policies were favored by the stakeholder groups.
o Affordable housing: More subsidized affordable housing is needed. Stakeholders noted that it is key to locate affordable housing in places located on transit or with good access to transit.
o Just Cause protections, rent stabilization: While there are some baseline protections at the state level, they need to be strengthened. The rent gauging gap does not go far enough to protect lower-income households.
o TOPA and COPA: Currently, there is significant interest in Tenant and Community Opportunity to Purchase Act policies that give tenants and nonprofits a first right to purchase or a right of first refusal when a property goes on the market. 632 of 955

3 o Rent registries: Stakeholders noted that a rental registry is important in order to obtain data that can be used to inform anti-displacement policies, but it is not an anti- displacement policy on its own.
o Section 8 vouchers: Stakeholders noted that while vouchers can provide opportunities for lower-income households to live or remain in the county, there are not enough vouchers to meet the need. In addition, vouchers have resulted in some concentration of low-income households in areas with less economic and educational opportunity. o Accessory dwelling units: ADUs are a great housing solution in the suburbs, as they provide suburb-appropriate density along with a good quality of life and provide more affordable options without requiring subsidy.

• Accessibility: Cities’ housing elements typically only have the minimum standard/generic language for accessibility. Some of the participating jurisdictions indicated an interest in doing more and are looking for examples of cities going beyond what is required. o Cities should be prominently promoting organizations working with tenants. City websites get the most visibility out of any form of advertisement/media o Jurisdictions were very interested in data that quantifies the existing supply of accessible housing and the demand for accessible housing. o Stakeholders suggested that affordability and accessibility must be considered together. o Transit-friendly locations are key for people with disabilities. o Stakeholders noted that “visitability” policies – making sure homes allow for access to those who are visiting – are less common today and should be considered. Consider requiring some degree of accessibility and visitability in new homes. o Lack of accessibility requirements for new townhomes were a point of concern.

• Reasonable Accommodation: The speakers indicated that there is widespread confusion about the meaning of reasonable accommodation. They shared ideas that could help educate residents and landlords.
o Building departments should be posting reasonable accommodations policies. o Education for and outreach to apartment managers, property owners and homeowner associations is needed.

• Ideas for Action:
o Perform an audit of each jurisdiction website for reasonable accommodation policies. o Improve jurisdiction websites to give a more prominent platform to organizations that work with tenants on fair housing issues.
o Create a program to rent ADUs to people who need housing (run by HIP Housing?). o Look at SB 9 and how it may increase the # of duplexes (will they be accessible?). o Identify cities that go beyond the standard accessibility language in housing elements. o Find data that quantifies the need for accessible housing (and the existing supply). 633 of 955

4 Appendix: Raw Notes

Room 1 (Josh) Notes:

Ben McMullan – CIID

1. Areas that can use work

2. Inaccessible new house – Many are built in town homes. There is a lack of visibility. No ground floor restroom. One bedroom on ground floor.
a. Restroom on ground floor
b. Access to kitchen

3. All new construction be accessible and visitable

4. Encourage more ADUs

5. Funding for home repairs for people with disability

6. Affordability

7. Mary to circle back with best practices for policies a. Report on where there are systemic violations

8. Education on reasonable accommodation for cities and apartment managers a. Require they take localized training
Ann Marquart – Project Sentinel

1. Tenant landlord

2. Mediation

3. Special emphasis

4. More visibility for fair housing

5. Make it clear how to make it more visible

6. Post reasonable accommodation

7. Most complaints about discrimination of disability

8. Reforms coming to service/companion animals rules

9. Companion animals have same civil rights protections

10. Many property owners do not understand laws

11. The lack of affordable housing

12. People are very worried about Oct 1 and after emergency rental restrictions end

13. Biggest issue with reasonable accommodation - landlords Shirley – Legal Aid

1. Eviction data from Legal Aid and EPA Legal Aid are based on that data

2. Black, Hispanic and families with children are the most hard-hit

3. It’s not a crisis of nonpayment, it is many no-fault evictions a. Even more disproportionately hitting black, Hispanic and children

4. Had the benefit of expanded just cause for 18 months. Been helpful. 634 of 955

5 5. Goals – strengthen no fault protections

6. “We don’t need data to figure out if there is a problem. We know there is a problem”

7. Rent registry does not prevent displacement, but data is useful, and as part of that lets get data about displacement

8. Covid rules did not cause the sky to fall

9. There are hotspots about how to use vouchers, there has been limited areas where vouchers getting used
a. But many of these are not in areas of opportunities

10. Time limited vouchers less useful

11. Make sure there are not group home discrimination

12. Post reasonable accommodation clearly
Michele – CLESPA

1. Just cause protections. They help tenants and inform tenants

2. Better rent stabilization

3. COPA/TOPA – Help displacement

Room 2 (Kristy) Notes:

• Ben McMullan - Center for Independence of Individuals with Disabilities o Advocate with housing, also look at transportation and health care issues o Biggest issues: Lack of affordable, accessible housing o Like to encourage affordable housing
o On transit lines, near transit
o Q from Nancy - with more power shutoffs, fire evacuation, etc. happening these days, for units not on the 1st floor, how is that being addressed? ▪ PSPS (Public Safety Power Shutoff) program where help distribute backup power packs for people dependent on power

• Ann Marquart - Project Sentinel
o More affordable housing
o Disability is the protected category that they get the most calls about, and is the most misunderstood
o Want housing next to transportation
o Protected categories
▪ Race
▪ National origin
▪ Gender
▪ Families
▪ Section 8 (NEW)
▪ There is now fair housing protection for Section 8
▪ But concern is that there are not enough certificates to go around, years of waiting lists, etc.
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6 ▪ Criminal history (is a little different)
o Q from Jennifer Rose: would be beneficial to all of the cities if you came up with collective wish-list of actions! Funding, help with promotion, policies, etc. ▪ Ann: Promote fair housing groups in big letters on a lot of city websites, give agencies a bigger platform
▪ For example, for first-time homebuyer training in San Jose, the only promotion was a notice on the city’s website, and it became clear that people go to city websites for information! Distributing flyers, holding zoom workshops - can only go so far, reach some people. ▪ Suggestion: “How can we promote project sentinel”
▪ HIP housing helped write language in last housing element (?)

• Mary Prem - Housing Equality Law Project
o Full service
▪ Focused on unserved or underserved areas
▪ Investigate complaints
▪ Counsel tenants
o Accessible housing
▪ Not just accessibility but visitability
▪ New construction (townhomes)
o Housing solutions for people seeking reentry
▪ Worked with SF city and human rights commission on “unchecking the box” o Add more ADUs
▪ housing is such a scarcity
▪ More affordable solution
▪ Greater life experience for people living in suburbs, not as dense o Really important that accessible housing is located near transit

• MIchelle Trejo-Saldivar - Community Legal Services of East Palo Alto (CLSEPA) o San Mateo County, plus Mountain View
o Especially serve low income, very low income, LatinX
o Housing needs: stronger rent stabilization policies, just cause protections ▪ There is a state just cause and rent control, but there is a need for stronger policies
▪ TOPA and COPA policies, other anti-displacement policies o Low income populations know where they will find affordable housing and where they will not: Recommendation jurisdictions take a look at where LI and VLI people live - they should only be paying 30% of income - where should we be pushing more affordable housing development

• Shirley GIbson - Legal Aid of San Mateo County
o Similar mission and population served as CLSEPA
▪ But only San Mateo County
▪ The 2 organizations share information across 2 organizations (Tableau), lots of data at fingertips
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7 o Why are these policies necessary from fair housing standpoint ▪ Displacement falls squarely and disproportionately on Black and Latinx households, households with children
▪ Disproportionality is even bigger when you look at no-fault termination evictions (not failure to pay rent)
o Biggest barriers to housing choice?
▪ We heavily rely on housing choice vouchers - unfortunately have managed to isolate and concentrate those tenants in areas of low economic and educational opportunity
▪ We must take take areality check: time-limited vouchers that transition people from homelessness to permanent opportunity are not working. It’s a revolving door because there isn’t enough time to stabilize households ▪ Look at how housing vouchers are administered and distributed o Note that while a rent registry is an interesting source of data, and it is great to have more info, it is NOT a anti-displacement policy in itself. Can use the data (which is better if you require data from landlords) to inform and structure more robust anti- displacement policies: looking at turnover, tenancy, how often, why

Room 3 (Vu-Bang) Notes:

• Mary Prem, Housing Equality Law Project
o Visitable housing units with accessibility on the ground floor unless there’s an elevator to other floors
o Serve areas that are deemed unserved, areas not covered by fair housing o Investigate fair housing complaints
o Training housing providers for more affordable housing o Collaborate with UC Berkeley - race studies in high school o City of SF- unchecking the box - re-entry housing programs, previously incardinated o Reasonable accommodations denial and other accessibility issues are most common work
o New construction, esp around transportation hub - housing that’s in townhome and not “visitable” (no toilet in common area, no elevators)
o Affordability and availability biggest concern - ADU units encouraged o Topic brought up with jurisdictions but haven’t seen adopted o Affordability and availability for housing
o Congestion on highways and accessibility in hubs

• Michelle Trejo-Salvidar
o Just Cause protections - provide tenants with their rights when tenant gets notice

• Shirley Gibson
o Be wary of full scale models of Just Cause - can pick and choose from model ordinances to shore up the weak Just Cause ordinances

• Ann Marquart, Project Sentinel
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8 o Disability and familial status got the most complaints - reasonable modifications, can go to CID to pay for modifications, VA will pay for some of those repairs. Reasonable Accommodations - companion/service animals (anyone giving the certificate now has to note how many hours of therapy), different parking space, reminder to pay the rent, o Policies: wishlist - something to project tenants after the moratoriums and now focused on back rents
o Something (not rent control) - new housing near transportation o Education - getting word out to housing providers, raise Project Sentinel to larger visibility so people can find them
o What cities have the best visibility to Project Sentinel - will follow up. o Section 8 renters - no discrimination
o Landlord should not evict everyone in the household after domestic disturbances

• Ben Mcmullan
o Systems change for Center for Independence of Individuals with Disabilities o San Bruno, SSF, County offices
o Visitability - wheelchair and mobility devices can adequately visit. Not many obstacles on different levels - Home Modification Program that people can take advantage of.

Having new housing be accessible from the get-go

o Plug for transit oriented housing - people with disabilities face needing housing and transit.
o Explore transit oriented housing - vastly great step forward o Paratransit coordinating chair on SamTrans and CalTrain accessibility advisory committee
o Biggest barriers to housing for vulnerable households - affordable and accessible housing. If it's affordable and not accessible, it only goes so far, and vice versa.

• Burlingame - has standard language on accessibility - want to know what language to use to go above and beyond. Townhouse units esp have concerns with. Set up well for TOD, but linking TOD + Accessibility + Affordability . SB9 - two flats or 2 townhouses preferred when it comes to accessibility.

• Hillsborough – language is generic, actual implementation only on ADUs, but predominantly single family housing. Transportation corridor only on El Camino Real and ½ mile from Burlingame Caltrain station.

• Jan (HCC): Physical accessibility is not the only type of accessibility barrier--I am thinking of people with cognitive disabilities--they shouldn't be left out of the discussion.

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1 MEETING SUMMARY
A

Countywide Stakeholder Listening Session #2: Housing Advocates 10/18/2021, 1-2:30 pm on Zoom

Overview
On October 18, 2021, 21 Elements hosted the second of four housing element stakeholder listening sessions with housing advocacy organizations. A majority of 21 E jurisdictions attended the listening session. Five stakeholder advocate groups introduced themselves and spoke about their group’s interest in the Housing Element process. Detailed information about speakers and attending jurisdictions is below and in the appendix.

Key themes included:
• Ongoing outreach needed to underserved and diverse communities • Production of new housing is critical to the SMC workforce o Greatest need for deeply affordable housing, dense, infill • Connecting labor, environment and equity to housing
• Rent increases are a primary concern
• Protecting vulnerable renting populations with assistance from the governments

Policies & Programs to consider:
• Additional funding for affordable housing through commercial linkage fees, inclusionary zoning, vacancy tax, sales tax, etc.
• Protections: eviction assistance, anti-harassment measures, stronger just cause, tenant right-to return, relocation assistance, improvements to the building inspection process, rental registries as a tool
• Production: Increase density within existing communities in non-high fire severity zones, eliminating harmful restrictions on density, eliminating parking minimums, streamlining housing building process, fair and inclusive zoning policies
• Prioritize BIPOC families in housing policies, outreach and practice (all stages of the practices) • Manage the threat of climate risk by adding green infrastructure.

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2 Stakeholder Presenters & Additional Resources
Organization Speaker Name Contact
Housing Leadership Council Angela Solis [email protected] Faith in Action Nani Friedman [email protected]
Greenbelt Alliance Zoe Siegel [email protected]
San Mateo County Central
Labor Council
Rich Hedges [email protected]
Peninsula for Everyone Jordan Grimes [email protected] San Mateo County Association
of Realtors
Gina Zari (invited, unable to
attend)
[email protected]

Learn more about Greenbelt Alliance’s endorsement program: https://www.greenbelt.org/climate- smart-development-endorsement-program/
Learn more about Greenbelt Alliance’s Resilience Playbook: https://www.greenbelt.org/resilience- playbook/
Full list of Greenbelt Climate Policies can be found in the draft housing element playbook (under policies tab) https://coda.io/@gazoe-siegel/housing-element-toolkit For those who wish to learn more about the focus groups in Redwood City that Trinidad from Faith in Action mentioned,, you can read the report here (posted on the City of Redwood City website):
https://www.redwoodcity.org/home/showpublisheddocument/23755/637623096709130000 Faith in Action supported with two other reports (tenant protections and preservation), found here:
https://www.redwoodcity.org/departments/city-manager/housing-services/housing-policies/anti- displacement-strategic-plan
Note Faith in Action works mostly with renter leaders in Daly City, San Mateo and Redwood City, but they have a presence in several other cities in the county as well.

Jurisdictions in Attendance:

Atherton Half Moon Bay San Mateo (City)
Brisbane Menlo Park San Mateo (County)
Burlingame Millbrae South San Francisco
Daly City Pacifica Woodside
East Palo Alto Redwood City
Foster City San Bruno +HCD

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3 Key Themes and Actions:

Themes
• Ongoing outreach needed to underserved and diverse communities • Production of new housing is critical to the SMC workforce o Greatest need for deeply affordable housing, dense, infill • Connecting labor, environment and equity to housing
• Rent increases is a primary concern
• Protecting vulnerable renting populations with assistance from the governments o Rental registries, eviction assistance, section 8 availability, anti-harassment measures.

Questions/Discussion
• How do you best balance providing adequate living wages for construction workers with keeping housing units affordable?
o Fair labor is critical to the building process
• Who should operate rental registries (city, county, nonprofit?) o Administered by RWC city staff
• Potential policies prioritizing BIPOC
o Understand needs of BIPOC communities throughout the process o Understand displacement policies
o More housing in transit rich corridors
• Section 8 Vouchers
o How to increase the availability
• Housing as a benefit to the community/not extracting from it

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4 Appendix: Additional Stakeholder Information & Input
o Housing Leadership Council: Angela Solis
▪ Network of organizers to support affordable housing
▪ Advocating for and preserving affordable housing
▪ Greatest need:
▪ Deeply affordable homes
▪ Focused on funding for affordable homes with example policies:
▪ Commercial linkage fees
▪ IZ, vacancy tax, sales tax, etc.
▪ Seeking greater outreach from jxs for Housing Element process- window into populations

o Faith in Action Bay Area: Trinidad Villagomez
▪ Focus in Redwood City
▪ Community organizers, leaders working in congregations schools, neighborhoods and apartments across SMC to uphold dignity of all people ▪ Listening to community experiences with housing (phone calls, door knocking, church involvement, people at food distribution sites)
▪ What the group heard from the community:
• Poor building conditions, harassment, discimination, rent increases, fear to speak to authorities, difficulty relocated, evictions for renovations and owner move in, unclear how to enforce existing rental rights, pandemic insecurity, rental debt, financial hardship, credit limitations, application fees
▪ From focus groups:
• Rent increase is the majority primary issue
▪ Vision:
• Regulations on eviction due to renovations
• Preventing harassment of tenants
• Partnership with city to work with tenants and landlords as a mediator o City to inspect buildings
o Rental assistance
o Process relocation assistance
o Report rent increases, eviction notices, their business license and taxes
o Education for tenant about rights
▪ Policies:
• Stronger just cause policy (define substantial renovation) and give tenants right to return (right of first refusal)
• Stronger relocation assistance administered by the city • Improvements to the building inspection process, with greater confidentiality with the tenant
• Rental registry program by city-tenant/landlord office • Anti-harassment policy
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5 ▪ More information:
https://www.redwoodcity.org/home/showpublisheddocument/23755/6376230 96709130000

o Greenbelt Alliance: Zoe Siegel
▪ Inclusive, climate resilient communities for all to thrive ▪ Housing and climate are linked
▪ Advocating for climate smart development
o SMART: Sustainable, Mixed, Affordable, Resilient, Transit- Oriented development
• Resilience Playbook
o Resources for local decision-makers and community leaders with policies, model ordinances, etc.
▪ Ensure fair and inclusive zoning policies that makes housing accessible to everyone
• Prioritize BIPOC families in housing policies, outreach and practice (all stages of the practices)
• Advance racial and social equity in process
▪ Increase density within existing communities in non-high fire severity zones ▪ Manage the threat of climate risk by adding green infrastructure. • Prepare for climate impacts, require nature-based solutions for climate resilience

o San Mateo County Labor Council: Richard Hedges
▪ Advocate for increased outreach
▪ Increases for min. wage, building of housing for all workers (safe and affordable) ▪ Builders: getting the work/pay required to live in San Mateo County (can afford to rent/own home)
• Service workers are struggling to live in SMC (especially retail pay) ▪ Advocated for housing built at Bay Meadows, advocated for 10% inclusive ▪ State law to allow for more density for affordable housing ▪ Qualified workforce is critical
▪ Removing barriers for Section 8 voucher holders

o Peninsula for Everyone: Jordan Grimes
▪ Frustration with lack of dense infill housing in SMC
▪ Member engage in local project advocacy, and planning meetings and are politically active at the local and state level
▪ Huge housing shortage in the county, decades of underbuilding ▪ Focus on as much being built as quickly as possible
▪ 3 Ps of housing policy, preservation, production, protection (interested in rental registries, want more rent data)
• Protection: Rent control, right to counsel with the eviction process • Production: eliminating harmful restriction on density, parking min, streamlining housing building process
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1 MEETING SUMMARY
A

Countywide Stakeholder Listening Session #3: Builders/Developers 11/1/2021, 1-2:30 pm on Zoom

Overview
On September 27, 2021, 21 Elements hosted the third of four housing element stakeholder listening sessions with housing developers and builders, including both affordable housing developers and market-rate housing developers. Detailed information about speakers and attending jurisdictions is below.

Key themes for affordable housing development included:
• Primary constraints to affordable housing include: the limits of local funding, tax credit availability (the county’s pool is small, limiting the size of a development that could get an award), appropriate sites
• Key policies and programs: sufficient and flexible local funding; either public land or land that is eligible for SB 35; streamlined process and alignment across city departments • Local governments should be aware of state and tax credit policies/requirements; be cognizant of the cumulative impacts of multiple layers of funding requirements; be prepared for community pushback now that high-resource areas are being targeted Key themes for market-rate housing development included:
• Primary constraints include competition for sites (with other uses) which drives up land costs; construction costs; city process and zoning; all the “easy” sites have already been developed, leaving sites with environmental or political (close to single-family homes) or other sensitivities • Key policies and programs: Specific plans and master plans and form-based zoning have been successful; removing CEQA from the equation is helpful; seek a balance of flexibility and predictability
• Localities should exercise caution with parking and ground-floor commercial requirements • Property tax exemption is likely best tool for encouraging moderate/middle income housing created by the market

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2 Stakeholder Presenters & Additional Resources
Organization Speaker Name Contact
MidPen Housing
(Affordable)
Abby Goldware Potluri [email protected]
HIP Housing
(Affordable)
Kate Comfort [email protected]
BRIDGE Housing
(Affordable)
Brad Wiblin [email protected]
Mercy Housing
(Affordable)
William Ho [email protected]
Habitat for Humanity—
Greater SF
(Affordable)
Maureen Sedonaen [email protected]
Eden Housing
(Affordable)
Ellen Morris [email protected]
Affirmed Housing
(Affordable)
Rob Wilkins [email protected]
The Core Companies
(Affordable, Market
Rate)
Chris Neale

[email protected]
Sand Hill Property
Company (Affordable,
Market Rate)
Candice Gonzalez (invited,
unable to attend)
[email protected]
Sares | Regis
(Market Rate)
Andrew Hudacek (invited,
unable to attend)
[email protected]
Summerhill Apartment
Communities
(Market Rate)
Elaine Breeze [email protected]
Greystar
(Market Rate)
Jonathan Fearn [email protected]

Jurisdictions in attendance:

Belmont Half Moon Bay San Bruno
Burlingame Menlo Park San Mateo (City)
Daly City Pacifica San Mateo (County)
East Palo Alto Portola Valley South San Francisco
Foster City Redwood City Woodside

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3 Roundtable Discussion Questions/Answers
Affordable Housing Developers

1. What do you perceive are the primary constraints on affordable housing development? o Local funding – esp since state housing laws have helped on the land use side o Having funding programs that actually match the supply side/building of the homes o Local Funding and Operating Subsidy
o Current cap in the 9% tax credit round (in last several rounds, not many projects going in because not enough credits in the region) – only projects with fewer than 60 units, plus high costs
o On preservation side – have to be agile and fast, if cities want to do this, they need to have systems to deal with tight escrow periods
o Appropriate sites

2. Are long lead (escrow) times possible in the property market today? o Sellers are amenable to longer lead times than pre-covid, though Peninsula is still tight o What’s key is having a good read on public partners’ funding commitment o For every site where factors line up, you lose a site because other things don’t line up o You can tie it up to close upon entitlements, but carrying cost adds up, so if public commitment can come in earlier that helps reduce cost

3. What are new policies or improved policies that you think would go farthest to making it easier to develop affordable housing?
o Local Funding and Operating Subsidy, esp flexible funding o 20% setaside dedicated to homeownership programs-
o Fee waivers
o Streamlined project timelines on the city’s side
o Consistent, regular NOFA timelines
o Having all departments aligned on goals
o Not having extra requirements/costs for affordable housing developments o Affordable housing should not bear burden for infrastructure costs o Remove restrictive racial covenants
o More policies like SB 9 and 10
o Update zoning of sites that were zoned in the 1960s
o Resources for site analysis, more points awarded when possible to incentivize and also help with by right potentially

4. What would you say are the 3 most important things that jurisdictions can provide in order to facilitate affordable housing development in their jurisdiction? o Local Funding and Operating Subsidy
- Shift unused resources (downpayment assistance for example) to production allocation for more housing or land purchases
- Nimble funding sources
- Affordable homeownership
o Land with appropriate zoning
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4 - Public land, esp in high resource areas (https://belonging.berkeley.edu/2021- tcac-opportunity-map)
- Making more land available with by right zoning or SB35 - Or priority zoning for affordable – San Jose allowing affordable housing to convert industrially zoned land
o Process
- Streamlining and alignment across city Departments
- Dedicated planner to shepherd affordable housing projects o I’d like to encourage jurisdictions to think outside the box and find ways to encourage partnerships between for and nonprofit developers. HIP Housing has had several great experience on projects using diverted impact fees and limited partnerships.

5. What should jurisdictions be aware of as they designate sites for affordable housing? o Think about how state funding sources/developers are looking at sites. “Vanilla” Aff family is gone unless in high resource areas so need operating subsidy. Sites need to be in amenity rich area (put site through amenity scoring lens) o Operating subsidies needed to support the deeper affordability that is sought today o Layering of requirements and compatibility of different populations o Think about not just # of units but also # of people being served o A comprehensive view of constraints, impacts of delays on developers o Be prepared for pushback in high resource areas
o We need more ownership, multifamily sites should be funded and counted by # of people served, not just # of doors; make residential "only" or limit commercial so can residential compete

6. Most of the Cities I consult for are small and do not have the capacity or expertise to shepherd affordable projects. What can you recommend otherwise?
o Important who the city chooses to partner with. Experienced developers can do some education on that. Hire a consultant or someone who can help to navigate the process o Small cities are sometimes great because they don’t have as much bureaucracy and can get things done more quickly
o Smaller cities could look to partner with Developers who build under 20 units (like Habitat and others on this call) and we welcome the opportunity to learn together. P.S.

It's hard to make it work financially if there are under 6 units however:)

7. What is your experience with rolling NOFAs (no deadline) versus NOFAs that have a fixed deadline for responses? Are there particular advantages or disadvantages to either one of these?
o Affordable developers rely on consistent, regular process o Don’t create a land rush and have affordable developers bid up land o Like rolling deadlines, since in the preservation world, can’t wait until a NOFA o No deadlines better align with development
o Rolling NOFA's are good, allow for flexibility to be responsive o If you really need to schedule it, make sure NOFA schedules coincide with other funding sources
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5 8. Would you have advice for jurisdictions with a lot of environmental constraints that can make housing expensive--faults, steep slopes, limited sewer, fire hazard, etc.? o Often they aren’t as bad as you might initially think. A second look can make something workable
o All the easy land has been developed on already! So don’t hold back, this is the norm, not the exception
o There are sometimes sources for brownfield funding

9. What is the densities that are working best for 100% affordable projects that cities should be planning for in the Housing Element process?
o Anything over 20 duac but 30-50 is better, gives more flexibility

10. What site criteria make a site feasible for securing tax credits? o High resource area (amenity rich)
o Site logistics (e.g. flat site, sufficient size)
o No need to build out infrastructure

11. Do you have a "rule of thumb" for how much local subsidy you are looking for in order to make an affordable housing development "pencil"? Do you typically need to secure County funds for the project as well as city funds and/ or land?
o 100-300K per home
o 30% local subsidy. Typically need county, city funding and land but depends on project specifics

12. Do you have any advice as jurisdictions release NOFAs/prioritize their affordable housing trust funds?
o Put more money in production! Support ownership programs, modify program to accommodate and understand their impacts
o Family housing that can compete (e.g. high resource area) o Senior housing at lower AMI's
o Operating Subsidies that aren't a COSR (e.g. LOSP) to serve homeless/ELI

13. From your experience in responding to site-specific RFPs, what would you say makes for a good RFP that you would be super excited to respond to?
o Large sites
o Sites with good logistics
o Consider RFQ's instead of RFP's

Market-Rate Housing Developers

1. What do you perceive are the primary constraints on market-rate housing development? o Competing with other land uses in acquisitions - life science and industrial and certain commercial driving more value
o City constraints
o Construction costs
o All the easy sites are gone. Now they’re politically sensitive, closer to single-family neighborhoods
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6 2. What are new policies or improved policies that you think would go farthest to making it easier to develop infill housing?
o Clear paths to entitlements would help
o Specific plans and master plans are great, CEQA document, design standards o Other paths that remove CEQA from the equation
o Would be a mistake to only think about high density residential, need to think about housing of all shapes and sizes (SB 9, ADUs, duplexes)

3. Which jurisdictions are doing a good job? (Answers were mostly about specific plans) o Redwood City
o Milpitas
o Santa Clara County
o City of Santa Clara
o Oakland – 4 specific plans
o Burlingame’s general plan
o Caution that specific plan does take time, often falls behind schedule o San Mateo County’s transit has a lot of potential

4. Conversely, what are some cities that took approaches you think didn't work out well and why? o A city that got very detailed in a specific plan, and it wasn’t relevant to the market, so it sat for a very long time before the city realized they needed to adjust the specific plan

5. What would you say are the 3 most important things that jurisdictions can provide to facilitate more housing development in their jurisdiction?
o Flexibility is key, but balance with predictability and consistent standards o Form-based zoning allows for evolution of details – we talk in terms of density, but form-based zoning images make more sense to people
o Resources
o Streamlined processes
o Restrictions on other competing uses
o Partnerships with city departments that streamline and adhere to code standards and other standards

6. What should jurisdictions be aware of as they designate sites for multifamily housing? o Anticipate objections and set up ways to mitigate them

7. Is there a range of project densities or size that is your sweet spot? o Depends on location
o Depends on rents
o Summerhill - Type III over Type I garage, (5 stories wood over 2 stories concrete), 20-22 units to the acre – 3 story resioential density
o Densities are going down, because unit mix is changing, putting bigger units in them.

Used to have a lot of studios and 1BRs, now making 2BRs and larger 1BRs

8. Questions on parking. Are you finding car stackers practical for your developments? o Yes starting to do this in the right locations (Core, Summerhill) o Not necessarily cheaper but allows you to use land more efficiently and not go underground
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7 o Hard parking minimums can be problematic when it comes to site planning, so some flexibility on parking is key
o 1:1 parking ratio works near transit

9. Does this group see a lot of potential in SB 10? -- urban infill for up to 10 unit multi-family projects -- exempt from CEQA
o Fan, there are possibilities, but we’ll see how much it actually gets implemented o What’s missing is the small scale developer (they’ve been zoned out), if SB 9 and 10 can spawn that ecosystem, it can make a difference. Right now the pool isn’t deep enough, not enough to sustain a business. If a community wants them, they will need to cultivate these types of development and developers

10. How does developing mixed use developments affect housing? How does it affect competing land uses?
• Summerhill has mixed-use projects with ground floor commercial that is not leased • What makes good retail is sometimes at direct odds with what makes for good unit plans above. Depth of retail etc. It is a challenge
• Amount of retail, needs foot traffic, really depends on location. Only so much retail to go around

11. What are ways that you think jurisdictions could facilitate the development of moderate and middle income housing?
o Projects with JPA programs
o Property tax relief for moderate-income units
o Once upon a time, market-rate housing delivered housing for middle income households, we just don’t have a lot of housing opportunities. Restricting supply doesn’t restrict demand. Allow more housing generally
o Access to specialized loan products and property tax incentives would help with middle income housing
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1 MEETING SUMMARY
A

Countywide Stakeholder Listening Session #4: Service Providers 11/15/2021, 1-2:30 pm on Zoom

Overview
On November 15, 2021, 21 Elements hosted the fourth of four housing element stakeholder listening sessions with San Mateo County service providers. Detailed information about speakers (see appendix for organizational information) and attending jurisdictions is below.

Key themes included:
• Key location characteristics were similar for most groups: access to transit, groceries, medical services, pharmacy, schools/parks/community centers/senior centers, jobs and job training. • Most of these stakeholder groups serve people with a range of incomes – focused primarily at the low end of the income spectrum but also into moderate levels. • Need affordable housing (or access to vouchers/subsidies that help with access to market-rate housing) of all shapes and sizes: mostly smaller units (studios to 2BR) but there is a need for larger units. It is hard for larger families (5-8 people) to find appropriately sized housing. Space, closets and storage, design for people with disabilities. See below for details. • Some people need onsite supportive services; others just need to be able to easily access services, whether by transit or if it can come to them. • Work with service providers and people experiencing issues firsthand before creating programs. • Use your networks and power to encourage business/tech/philanthropy to support service providers
Policies & Programs to consider:
• Actively partner with affordable housing developers to streamline and facilitate development • Stabilize market rents
• Use public land for affordable housing
• Create more workforce housing.
• Increase inclusionary housing
• Encourage and facilitate more homesharing
• Educate landlords on their rights so they are more willing to partner with Housing First service providers

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2 Stakeholder Presenters & Additional Resources
Organization

Speaker Name Contact
Daly City Partnership
(one of San Mateo
County’s Core Agencies)
Marya Ouro-Gbeleou

[email protected]
HIP Housing Laura Moya [email protected]

LifeMoves Jacob Stone [email protected]

Mental Health
Association of San
Mateo County
Melissa Platte [email protected]
National Alliance on
Mental Illness
Michael Lim [email protected]
Ombudsman of San
Mateo County
Bernadette Mellott [email protected]

Samaritan House San
Mateo (one of San
Mateo County’s Core
Agencies)
C. LaTrice Taylor [email protected]

Youth Leadership
Institute
Alheli Cuenca [email protected]

Abode Services Jeremiah Williams (unable to
participate live, interviewed)
[email protected]
El Concilio Gloria Flores-Garcia (unable to
participate live)
[email protected]

Roundtable Discussion Questions/Answers

1. We assume that transit-oriented or transit accessible housing is important. Are there any other location characteristics that you would highlight are important for the people you serve? o Mental Health Association – access to transit, medical care, grocery stores, pharmacy o Daly City Partnership – in Daly city all services are sited in the govt center by design, so housing should either be close to it or have direct transit access o Youth Leadership Institute – parks within or near housing developments are important to young people, new community centers or access to existing ones, high walkability o HIP Housing – agree with all mentioned, near schools for family housing, senior centers for senior housing
o National Alliance on Mental Illness – justice-informed community (people who have experience with law enforcement, ranging from a 5150 call or involuntary hold to being incarcerated in jail or prison system) need access to services 652 of 955

3 o Abode – varies. Have some unique programs, sometimes relocate people out of the county. Medical, schools, childcare, transportation. Access to jobs/job training

2. What is the range of income levels of the population you serve? o Mental Health Association - 0 to 15%
o LifeMoves – range from 0 to 100%
o Daly City Partnership – weighted to the lower end 0 to 30, 0 to 50%, a lot at 80% too but not as many
o National Alliance on Mental Illness – lower end, but mental illness spans people across the whole income spectrum
o Abode – serve the lowest incomes

3. What role does market-rate housing play for the people you serve? Are vouchers helping? o Mental Health Association – for most clients, market-rate housing is out of reach, even affordable is also often out of reach (since it serves 40% to 120% AMI) o Ombudsman – her clients in assisted living get a $1500 check, rent is $5000+, sometimes families or retirement funds make it work. Now facing a number of families who cannot help anymore because of lost jobs during the pandemic. 15 people on evictions list right now, many are 85+ years. If they are evicted they will end up on the streets. Looking for solutions for them. They don’t take transportation, they can’t o HIP Housing – 95% of clients in homesharing program are at or below 80% of AMI, sometimes not low enough to access affordable housing. And some are on fixed income and don’t qualify for affordable housing and don’t make enough to access homesharing program. Waiting lists are way too long
o Daly City Partnership – see a lot of same types of people that Ombudsman sees, just a few years earlier, before they need assisted living. It’s a tough spot to be aging in San Mateo County, unless you’re healthy or living with your adult children. Think about dignity for our older folks. We need to care for our elders. o Abode – do master leases, use vouchers, so existing and new market-rate housing plays an important role. Develop relationships with landlords that accept vouchers (provide case mgt/contact for landlords, help to avoid evictions). Important to educate landlords around their rights, not a lot of legal services available to them. Work with a range of landlord and building types.

4. Do affordable units need to be designed in a certain way or certain size to meet the needs of the people you serve?
o Mental Health Association – definitely need more units that are available for people with physical disabilities. Serve people with serious mental illness, HIV/AIDS debilitating conditions, etc. It used to be that they would die far younger than most, but now people are now living into 60s-70s-80s. This is great but long-term effects of medications have impact on their bodies, put them at greater risk for falls, etc. Mostly studios and 1BRs (preferred), closets and storage in the unit are critical o Youth Leadership Institute – serve young people – in Half Moon Bay they are seeing 3 HH living in one unit, looking to advocate for pathway to homeownership, also single family housing (3BR/2BA). Want as much space as possible, spacious living areas. 653 of 955

4 During pandemic school from home was incredibly challenging esp when community centers weren’t open or limited. Also like ADA accessible, parking spaces, access to community parks, trails, since there are not a lot of things for young people to do; storage units and closets, public bathrooms in developments o HIP Housing – serve single individuals, families and seniors. Larger families get missed, families of 5-8 or larger can’t find any affordable housing options. Some seniors would benefit from onsite services, during pandemic especially suffered from isolation o LifeMoves – serving more seniors every year, medically fragile folks – in terms of families serve primarily smaller households of 2-3, but do have a few large HH too o National Alliance on Mental Illness – agree with many things mentioned above, add better noise insulation since clients may have experienced trauma and loud levels of noise can trigger them to the next episode
o Abode – need all types of units

5. For the population you serve, if the cities were able to encourage a set-aside within affordable housing for special needs, who needs onsite supportive services? Who can live in general affordable housing (assuming deeper levels of affordability)? o Mental Health Association – only 30% of people we serve need to have site-based services onsite, but 100% of clients need access to support services. Deep affordability/subsidies/vouchers can work as long as there are services that can be brought in to work with them
o National Alliance on Mental Illness – some of our clients may lose custody of their children or have shared custody. Studio will suffice for most but for some who are working to get their life back in order, helps to have a little bit more space when they have their children visit
o Daly City Partnership – Was able to tour Sweeney Lane (MidPen Housing) in Daly City – wonderful onsite services. Was moved, this is what our people need, it’s a shame that it is so small. Excellent example of good practice of surveying residents about their needs and evolved services as needed. Many clients don’t need that level though. Echo importance of evolving services over time. Midway Village in Daly City – for several years there weren’t onsite services, people there for generations, underserved population historically. Some of the seniors today moved there when they were young – we need to think about aging in place, be thoughtful over the long term about evolving resident needs. There is a need for large units (4 children) in the market even though the smaller households are most common. # of kids is a limiting factor on affordable applications
o Ombudsman – there is no affordable assisted living. Pipe dream is that some people might be able to live in affordable housing with their families if they had some onsite services. Some need their medications to be given to them. Physical therapy is provided in nursing homes. Cheapest assisted living is $4500, ranges up to $10K/mo. Seniors need the same basic services no matter their income. Also serve mentally and physically disabled in residential homes. Nobody wants them, which is very sad.

6. Aside from more money, what can jurisdictions do to be helpful? Future programs and policies not just about the direct allocation of money
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5 o Daly City Partnership – Sweeney Lane is an example of the city getting behind a development and working collaboratively to get everything together – zoning, permitting, convincing adjoining land owner with lot to sell the lot. Worked to move things as quickly as possible. It takes such a long time to make these projects happen, which is a problem when people are homeless *today*
o HIP Housing – one of the things jurisdictions can do is encourage and support affordable and accessible prices in the overall housing market. More supportive services for mental health issues, esp at earlier stages. More supportive services to people on fixed income, make sure they don’t lose fixed income if they get access to new resources. Jurisdictions may not recognize homesharing as a solution, but they should consider it, it is readily available, no cost, can help fill in the gaps o Mental Health Association – agree with everything that has been said. Use city and county owned property for low income housing. Support developers that include extremely low income units, that provide support services onsite or accessible. There’s a lot of talk about teacher housing – nonprofit staff need affordable housing too. Would help to recruit and retain employees, who we are losing every day. If we can’t hire staff, we will not be able to serve
o Ombudsman – all the market-rate developers who are building these beautiful residential buildings, but only put 3 low income units in 25 unit building. We should incentivize them to add more low-income units. Give the developer a tax credit to incentivize them to increase the # of low income units. Get more people off the streets and into nice apartments.
o National Alliance on Mental Illness – incentives to builders is great. Also think about how to halt the exchange of ownership on property. Every time land is sold and changes hands, it becomes more expensive. Think more creatively about ownership of land o Abode – Besides more money, we need more vouchers, more staff. More project-based housing. Education for landlords on their rights will help more landlords be willing to take vouchers, sign master leases. Rapid rehousing is needed but it doesn’t work for everyone; we need more permanent supportive housing. Jurisdictions should reach out to people at ground level for input before creating programs.

7. Are there options for people that have animals?
o Mental Health Association - Most of our clients can have an animal as long as we work with them to request a reasonable accommodation. 100% of our units can and will make the accommodation.
o National Alliance on Mental Illness – pets are huge thing for our clients, not only with soothing them but also creating a sense of responsibility, gives them second thoughts when they are thinking of ending their lives
o HIP Housing – it is still a big barrier in affordable housing when their pet is not a service or supportive animal. Many people have more than one pet which is also a barrier.

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6 8. How much have the large companies--Apple, Facebook, YouTube, etc--stepped up to help provide money for these services and housing units?
o Mental Health Association - To our knowledge, not much. o Ombudsman – got turned down for grants from FB, Google, Genentech o Samaritan House – they do fund some things, some of the folks here do have funding, depends on the focus, housing, food, youth has been big. Need to understand what is it that they really want to fund and tailor what you’re doing to what they’re asking for o Daly City Partnership – CZI is funding all of the Core Agencies in SMC, doing a lot of work around free, high-quality training for their grantees and others. They are at the forefront. Key to support for Core Agencies: someone at County advocated for the Core Agencies. Jurisdictions, use your network and political power to help orgs o HIP Housing – has benefited from CZI as well

9. Additional comments
o Samaritan House – article came out today about most expensive zip codes in the country. For the 5th year in a row: Atherton. In the Bay Area we have 47 out of 100 zip codes that are among the highest in the country. In SMC, 10 of the 47. Somehow, some way we need to figure out how to solve this with partners, with developers (who have codes to follow, does tax credit offset how much they can make, when it’s more about the money and those who can afford it vs. police, firemen, nonprofit workers). We are fast approaching that cliff where we’re not only pricing out our clients but also the middle class. We need to do something, not sure what it is. We’ve got a fire. Where are the hoses, where is the water, where are the fire trucks? Tech companies should be a part of this process. We need the people with the money at the table. The tech companies are contracting with people so they don’t have to pay benefits. People are working from other parts of the state/country because their money doesn’t go as far in the Bay Area. $140K income for a family of 4 only covers the basics. I know the people who are here know that. But who else do we need at the table to know it too. o Daly City Partnership - One of my favorite quotes, "Tell the rich of the midnight sighing of the poor." We need to educate the upper-class and business folks - appeal to their conscience. But that is my own personal view. LaTrice (Samaritan House) is so right. o National Alliance on Mental Illness – Need to look at transportation, exploring localities that are hubs. In a few years (or even now) we are facing the challenges of our own existence. NAMI San Mateo had to give up its permanent site and move offsite. Current location is not ideal, not close to any public transportation system. El Camino is going to look like two walls of buildings with homes. Is that what we want or do we want to add transit to allow people access to services. Jurisdictions should start thinking about transportation hubs. Think about housing density and building up because limited land, is precious. Need to think about it now since it takes time to build infrastructure

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7 Appendix: Additional Stakeholder Information

Human Investment Project (HIP Housing)
• Mission: HIP Housing’s Mission is to invest in human potential by improving the housing and lives of people in our community. HIP Housing enables people with special needs, either from income or circumstance, to live independent, self-sufficient lives in decent, safe, low-cost homes. To achieve our mission, HIP Housing provides Home Sharing, Self-Sufficiency, and Property Development.
• Where you operate: All cities in San Mateo County
• Whom you serve: Families and Individuals who live, work, go to school or have a housing voucher in San Mateo County.

LifeMoves
• Mission: To provide interim housing and supportive services for homeless families, couples and individuals to rapidly return to stable housing and achieve long-term self-sufficiency. • Where you operate: Countywide, Daly City to East Palo Alto and Half Moon Bay on the coast • Whom you serve: families, couples and individuals experiencing homelessness Mental Health Association of San Mateo County
• Mission: Mental Health Association of San Mateo County is dedicated to improving and enriching the quality of life for individuals in our community who have a mental illness, HIV or AIDS or a co-occuring disorder by providing stable housing and supportive services. • Where you operate: San Mateo County
• Whom you serve: Individual adults, transition age youth, and families.

Samaritan House
• Mission: Fighting Poverty, Lifting Lives
• Where we operate:
o San Mateo Office: Belmont, Burlingame, Foster City, Hillsborough, Millbrae, San Carlos, San Mateo
o E. Palo Alto Office: E. Palo Alto, Menlo Park
• Whom we serve: residents in need, including families with children, seniors, persons living with disabilities, veterans, and unhoused individuals
Daly City Partnership
• Mission: Working together to enrich life in our community • Where you operate: Daly City, Colma, Broadmoor residents primarily. San Mateo County residents.
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8 • Whom you serve: Residents in need, including families with children, seniors, persons living with disabilities, veterans, and unhoused individuals and families. Services for all ages and stages.

Youth Leadership Institute
• Mission: yli builds communities where young people and their adult allies come together to create positive social change. We achieve this in two key ways: providing training, tools and resources for effective youth advocacy, and by leveraging the experience and savvy of adult allies.
• Where you operate: Half Moon Bay, Daly City, & greater San Mateo County • Whom you serve: Low income and BIPOC youth
Ombudsman Services of San Mateo County
• Mission: The residents of Long Term care Facilities are often the most vulnerable in society.

OSSMC works to ensure the protection of these residents through advocacy, direct intervention and collaboration with service providers.
• Where you operate: OSSMC provides services to all licensed LTC facilities in San Mateo County. • Whom you serve: We service all residents in licensed LTC facilities in SMC. We presently serve 442 facilities with a total of 9278 residents
El Concilio of San Mateo County
• Mission: ECSMC is committed to increasing education, employment and access to quality of life services to underserved communities in San Mateo County • Where you operate: County wide, East Palo Alto, Menlo Park, North Fair Oaks/Redwood City • Whom you serve: Low Income, non/limited English speaking and non/limited literacy residents Abode Services
• Mission: Abode Services' mission is to end homelessness by assisting low-income, un-housed people, including those with special needs, to secure stable, supportive housing; and to be advocates for the removal of the causes of homelessness. • Where you operate: Alameda, Santa Clara, San Francisco, Santa Cruz, San Mateo, and Napa counties.
• Whom you serve: People identified as homeless or at risk of becoming homeless 658 of 955
C I T Y O F S A N M A T E O 2 0 31 H O U S I N G E L E M E N T Appendix H-F
ROOT POLICY FAIR HOU SING SURVEY SUMMARY – FEEDBACK RECEIVED FROM THE

PUBLIC THROUGH A COUNTYWIDE SURVEY ON FAIR HOUSING ISSUES

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ROOT POLICY RESEARCH CITY OF SAN MATEO RESIDENT SURVEY, PAGE 1 City of San Mateo Resident Fair Housing
Survey Preliminary Results
As of January 20, 2022, the San Mateo County Fair Housing Survey has gathered 108 responses from residents in the City of San Mateo. Main findings are listed below.

Top challenges in housing situation.
 I would like to move but I can’t afford anything that is available/My income is too low for me to find anywhere else to rent (30%);
 My house or apartment isn’t big enough for my family members (28%);  I worry that if I request a repair it will result in a rent increase or eviction (17%).

Top challenges in paying for housing:
 I can’t keep up with my utilities (15%);
 I can’t keep up with my property taxes (12%).

Top challenges in neighborhood:
 There are not enough job opportunities in the area (22%),  I can’t get to public transit/bus/light rail easily or safely (18%),  Schools in my neighborhood are poor quality (17%).

Displacement. Twenty-eight percent of respondents indicated having been displaced in the past five years. The top reason for displacement was “Rent increased more than I could pay” (40%).

Availability of housing. Seventy-three respondents have looked for housing seriously in the past five years of those, 17 (24%) indicated that a “Landlord did not return calls and/or emails asking about a unit”, and 31 (44%) indicated they have been denied housing to rent or buy in San Mateo County in the past 5 years. The main reason for denial (37%) was “income too low.”
Voucher holders. The survey gathered responses from 25 voucher holders. The majority (77%) indicated that finding an affordable unit is somewhat or very difficult. Six of them indicated this is due to “Landlords have policies of not renting to voucher holders.” 660 of 955
ROOT POLICY RESEARCH CITY OF SAN MATEO RESIDENT SURVEY, PAGE 2 Residents with a disability. Twenty-seven percent of respondents indicated having a disability or having a member of their household with a disability. Seventy-five percent indicated their home does not meet the needs of their household member with a disability.

Improving quality of life. Residents were also asked about several resources that would improve their living situation.

When asked what type of help they need to improve their housing security, top answers were:
 Help me with a down payment/purchase (39%);
 Help me get a loan to buy a house (27%); and
 Help me with the housing search (23%).

When asked what type of help they need to improve their neighborhood, top answers were:
 Better lighting (38%);
 Improve street crossings (30%); and
 Reduce crime (27%).

When asked what type of help they need to improve their health, top answers were:
 Make it easier to exercise (41%);
 More healthy food (37%); and
 Better/access to mental health care (26%).

When asked what type of help they need to improve their job situation, top answers were:
 Increase wages (49%);
 Find a job near my apartment/house (28%); and
 Help paying for college (24%).

When asked what type of help they need to improve children’s education, top answers were:
 Stop bullying/crime/drug use at school (29%);
 Make school more challenging (28%); and
Have more activities afterschool (26%).
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C I T Y O F S A N M A T E O
20 40 G E N E R A L P L A N

H O U S I N G E L E M E N T

Appendix H-F
COMMUNITY CORRESPONDENCE RECEIVED BY THE CITY AS OF MARCH 30 , 2022

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(5 PROMETHEUS

10.11.2021
San Mateo Planning Commission
City of San Mateo 330 W. 20fh Ave.,
San Mateo, CA 94403
Re: Housing Element Update Process
Dear Chair Maldonado and City of San Mateo Planning Commissioners, On behalf of Prometheus Real Estate Group, I am writing today regarding the Housing Element Update Process. As a company long based in San Mateo and an employer and investor throughout San Mateo and it"s Downtown, Prometheus Real Estate Group supports the City's efforts to address "its RHNA allocation within the existing land use and zoning designations without the need to rezone or increase densities as stated in the Staff Report. While Prometheus and our project partners continue to follow and support the General Plan Update process, which will provide a plan for growth throughout the City for the years ahead, we believe that the City's current zoning and Iand use guidelines do provide a framework for addressing the City's 7,015-unit RHNA allocation. However, we would propose greater focus on ways to better streamline and achieve greater certainty throughout the development process.

Towards that end, below are several suggestions that we believe would better facilitate the development process and help towards attaining the RHNA housing numbers needed.

1. State Density Bonus and Measure Y
a. There have been recent discussions within the City regarding the Density Bonus Law and its ability to allow a project to go beyond a Iocal voter initiative-based height limit. We would recommend clarifying the details of how this would work so that a project applicant could plan accordingly.

Having certainty in such an interpretation can allow for a more creative approach to defining a specific project and potentially incorporating some or more housing if possible. Along with additional height, this would also include greater FAR and densities.

Having these guidelines and interpretations formally confirmed at the start of a project will greatly facilitate the initial underwriting and City review process which will benefit all parties involved. b.

2. Community Benefits
a.Some zoning districts in the City of San Mateo have underlying residential uses allowed. Within those allowed residential use guidelines can be Ianguage regarding gaining additional densities through Community Benefits. By more clearly defining the Community Benefit process, higher residential densities can potentially be achieved and RHNA targets realized. b. While the recent "interim program" from 2020 provided a proposed framework for an economic Iand-use consultant to value the community benefits on a project-by-project basis, we believe further refinement of this process is warranted, in an effort to provide morer certainty in community benefit requirements, resulting in higher densities and greater ability to attain the necessary RHNA numbers.

Thafor your time on this matter,
'JE".':

JonaThan Stone
Senior Director of Development
Prometheus Real Estate Group, Inc.
1900 South Norfolk Street, Suite 150, San Mateo, CA 94403 650.931.3448
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DEVELOPMENTAL DISABILITIES SUBMISSION FOR

Supreme Court’s 1999 decision in Olmstead v. L.C., people with developmental disabilities are entitled to receive community-based services that allow them to live in the least restrictive community setting. This shift to de-institutionalization has led to the closure of the most restrictive segregated settings and to the requirement that local jurisdictions in their Housing Elements assess and plan specifically for the housing needs of people with developmental disabilities who receive services from the Regional Center in order to live in their home community.

Demographic and Other Trends Affecting the Housing Needs of People with Developmental Disabilities
The City of San Mateo Population with Developmental Disabilities Grew by 12% Since the Last Housing Element and Accounts for 21% of the County’s Total Population with Developmental Disabilities. The City of San Mateo is home to 835 people with developmental disabilities (Table __). This represents an increase of 12% over the 2013 population of 746 reported in the City’s 2015 Housing Element and reflects a much higher growth rate than the general population. In addition, the City’s population with developmental disabilities accounts for 21% of the total County population with developmental disabilities, although the city’s total population is only 14% of the County’s total population.

Table ___ Comparison of the 2021 City and County Populations with Developmental Disabilities Age City of San Mateo County of San Mateo City of San Mateo as % of County
Under age 18 304 1169 26%
18 and older 531 2764 19%
Total 835 3933 21%
Source: The City of San Mateo data is based on zip code level data for zip codes 94401, 94402, and 94403 published by the California Department of Developmental Services as of September 30, 2021. County level data is published by the Department of Developmental Services as of June 30, 2021. Both sources exclude children from birth to the third birthday because approximately 75% of this age group is found not eligible for continuing lifelong services on their third birthday.

Decline in Living Arrangements for Adults with Developmental Disabilities Outside the Family Home.

Of the City’s total population with developmental disabilities, 531 (64%) are adults and 304 (36%) are 1 672 of 955
under age 18 (Table __). Assessing the housing needs of adults with developmental disabilities is of particular importance because as they age the adults will require a residential option outside the family home, whereas the family home is the preferred living option for children with developmental disabilities. In 2021, 505 City of San Mateo residents with developmental disabilities lived in the family home compared to 389 in 2013 as reported in the 2015 to 2023 Housing Element. This 30% increase in reliance on the family home is 2.5 times greater than the City’s 12% increase in the developmental disabilities population during that same period. Increased reliance on the family home is primarily explained by overall growth in the population with developmental disabilities coupled with significant declines in opportunities for the City’s adults with developmental disabilities to live either in licensed care facilities (11% decline) or in affordable housing with supportive services (11% decline). (Table __.) As adults with developmental disabilities age, they need opportunities to live outside the family home both because of the aging of their family caregivers and also because many adults with developmental disabilities would like to live in their own apartment with supportive services.

Table ___ Changes in Living Arrangements of Adults with Developmental Disabilities Living Arrangements
2013
Number
2021
Number
2021
Percent of Total Adults % Change Since 2013
Total (children & adults) in
the Family Home 389 505 -- 30%
Adults In the family home
Not reported-- see
note 201 38% --
Own apartment with
supportive services 64 52 10% -11%
Licensed Facilities 294 265 50% -11%
Other (including homeless) 7 13 2% .8%
Total Adults
Not reported--see
note 531 100% --
Note: The 2013 data are reported in the 2015 Housing Element, which failed to separately count those under 18 and those 18 and older, making it difficult to estimate changes in the significance of the family home as a residential setting specifically for adults. The 2021 data are published at the zip code level by the California Department of Developmental Services as of September 30, 2021. These data assume that occupants of licensed facilities are 18 and older which is generally true, but if incorrect this assumption would tend to understate, not overstate, the need for other housing options for adults with developmental disabilities.

Increase of Autism Diagnosis Reflected in Increase in Adults in their 20s and 30s. Growth in the City of San Mateo’s population with developmental disabilities since the 2015 Housing Element correlates with a significant annual increase in the diagnosis of autism that began in the mid-1980s and did not level out until after 2015. The cumulative impact of this trend is already seen in the growth in the San Mateo County population age 18 to 41 with developmental disabilities and will continue into the future. This trend has significant implications for housing needs among City of San Mateo adults with developmental disabilities during the period of the 2023 to 2031 Housing Element. 2 673 of 955
Table __ Changes in Age Distribution of Adult Population in San Mateo County Age 2015 Number 2021 Number % Change
18 to 31 1023 1189 16%
32 to 41 397 457 15%
41 to 52 382 335 -12%
52 to 61 385 348 -10%
62 plus 327 435 33%
Total adults 2514 2764 10%
Source: County level data is published by the Department of Developmental Services as of June 30, 2021 and as of September 30, 2015.

Longer Life Spans. Between September 2015 and June 2021, the California Department of Developmental Services reports that the number of San Mateo County residents with developmental disabilities age 62 and older grew by 33% (Table __). This is not due to migration of senior citizens with developmental disabilities to San Mateo County, but rather to well-documented gains in life span among people with developmental disabilities. With longer life expectancy, more adults with developmental disabilities will outlive their parents and family members with whom a growing number of City of San Mateo adults with developmental disabilities now live because of the lack of other residential options.

Longer life spans will also slow the pace of resident turnover in the county’s limited supply of licensed care facilities, which will further reduce opportunities for the growing population of people with developmental disabilities to secure housing outside the family home.

Decline in Licensed Care Facilities. The California Department of Developmental Services reports that between September 2015 and June 2021, San Mateo County lost 5% of its supply of licensed care facilities for people with developmental disabilities (including Community Care Facilities, Intermediate Care Facilities, and Skilled Nursing Facilities), thereby increasing the need for affordable housing options coordinated with supportive services funded by the Regional Center. This trend is mirrored in the 11% decline in the number of City of San Mateo adults able to live in licensed care homes between 2013 and 2021 (Table __). The reduced role of licensed care facilities demonstrates the need for the City’s Housing Element to plan for affordable housing that includes people with developmental disabilities so that adults with developmental disabilities are not forced out of the county when they lose the security of their parent’s home.

Displacement. The California Department of Developmental Services has documented a 12% decline in the age group 42 to 51 and a 10% decline in the age group 52 to 61 in San Mateo County between September 2015 and June 2021. (Table __). In light of gains in life expectancy, this loss can reasonably be attributed to homelessness or displacement from the county because of the lack of residential living options (either licensed facilities or affordable housing) when an elderly parent caregiver passes away or becomes unable to house and care for the adult. Displacement takes a particular toll on adults with 3 674 of 955
developmental disabilities who depend on familiarity with transit routes and shopping and services, as well as support from community-based services and informal networks built up over years in living in the City of San Mateo.

Higher Rates of Physical Disabilities. People with developmental disabilities are more likely than the general population to have an accompanying physical disability. Twenty-seven percent (27%) of San Mateo County residents with developmental disabilities have limited mobility, and 13% have a vision or hearing impairment. The need for an accessible unit coupled with the need for coordinated supportive services compounds the housing barriers faced by those with co-occurring intellectual and physical disabilities.

Ineligibility for Many Affordable Rental Units. Some adults with developmental disabilities depend on monthly income of under $1,000 from the Supplemental Security Income (SSI) program, pricing them out of even the limited number of Extremely Low Income affordable housing units in the City of San Mateo. Those with employment tend to work part-time in the lowest paid jobs and also struggle to income-qualify for many of the affordable housing units for rent in the City of San Mateo.

Transit-Dependent. Most adults with developmental disabilities do not drive or own a car and rely on public transit as a means to integration in the larger community.

Best Practices for Inclusion of People with Developmental Disabilities in Typical Affordable Housing
As demonstrated by a growing number of inclusive affordable housing developments in neighboring jurisdictions, the City of San Mateo can meet the housing needs of people with developmental disabilities by adopting policies and programs to promote their inclusion with coordinated services in typical affordable housing. The following considerations should guide the City of San Mateo in this pursuit:
● Integration in typical affordable housing is a priority in order to affirmatively further fair housing for a group that has historically experienced no alternatives to segregated living and also to counter the displacement of adults with developmental disabilities out of San Mateo County. ● Coordination of housing with onsite supportive services funded by the Golden Gate Regional Center should be encouraged. These fully funded coordinated services provide a supported pathway for people with developmental disabilities to apply for and retain an affordable apartment and are often as essential to a person with a developmental disability as a physically modified unit is to a person with a mobility, vision, or hearing impairment. ● A mix of unit sizes at inclusive housing properties would address the needs of those who require live-in aides, want to live with roommates or partners, or have children. ● Location near public transit would accommodate the transit-dependency of most adults with developmental disabilities.
● Deeply affordable housing is needed, targeting incomes not more than 30% of Area Median Income and taking advantage of Housing Authority Project Based Vouchers or HUD 811 Project 4 675 of 955
Rental Assistance when available to create housing opportunities for those who cannot meet minimum income requirements for units priced at 30% of Area Median Income.

Policy and Program Recommendations
The City of San Mateo has a responsibility not simply to assess the housing needs of people with developmental disabilities but also to create policy, zoning, program and other changes that make it more feasible for affordable housing developers to include people with developmental disabilities in their housing in coordination with the supportive services available from the Golden Gate Regional Center. The City’s 2015 Housing Element identified a need for housing for an additional 30 to 87 people with developmental disabilities, but the number of adults with developmental disabilities living in their own apartment actually declined by 11% since the last Housing Element, even as the population grew by 12%. The City’s lack of progress in meeting the housing needs of people with developmental disabilities since the last Housing Element demonstrates the need for policies and programs that specifically incentivize inclusion of people with developmental disabilities in affordable housing with coordinated services provided by the Golden Gate Regional Center.
● Establish and monitor a quantitative goal. Tracking the City’s success in housing people with developmental disabilities is essential to determine whether policies and programs are having an effect in overcoming historic patterns of discrimination and exclusion of people with developmental disabilities from affordable housing. A goal of 150 new Extremely Low-Income housing units for City of San Mateo residents with developmental disabilities over the period of the 2023 Housing Element would represent meaningful progress towards the total unmet housing need of this special needs population.

Sample Language: The City of San Mateo shall monitor progress towards a quantitative goal of 150 new Extremely Low Income housing units that are subject to a preference for people with developmental disabilities needing the coordinated services provided by Golden Gate Regional Center to live inclusively in affordable housing.
● Target City-Owned Land, Land Dedicated to Affordable Housing under the Inclusionary Ordinance and City Housing Funds to Meet City-Specific Priorities. City-owned land, land dedicated to affordable housing in lieu of providing affordable units under the inclusionary ordinance, and city housing funds are often essential to the development of affordable housing that is financially feasible in high-cost City of San Mateo. In creating guidelines for the scoring of any competitive requests for proposals for these scarce resources, the City should grant additional points to affordable housing projects that address the housing needs of City of San Mateo residents who are most difficult to house under existing state and federal housing finance programs--for example, by prioritizing proposals with a higher number of extremely low income units or that make a percentage of units subject to a preference for identified categories of special needs people who would benefit from coordinated onsite services, including but not limited to people with developmental disabilities who benefit from services of the Golden Gate Regional Center.
5 676 of 955
Sample Language: In publishing requests for competitive proposals for any city-owned land, land dedicated to affordable housing under the city’s inclusionary ordinance or city housing funds, the City of San Mateo shall grant additional points to proposals that address the city’s most difficult to achieve housing priorities, by, for example, providing a greater number of extremely low-income units or committing to make a percentage of the units subject to a preference for people with special needs who will benefit from coordinated onsite services, such as people with developmental disabilities who receive services from the Golden Gate Regional Center. ● Offer Developers a Range of Affordability Options Under the Inclusionary Ordinance. Most adults with developmental disabilities have incomes too low to satisfy minimum income requirements for the Low Income units currently offered under the city’s inclusionary ordinance and are effectively excluded from this housing option. California law (AB 1505, the “Palmer Fix”) explicitly allows cities to adopt inclusionary housing ordinances that address a range of income levels from moderate-income to extremely low-income. The City should take advantage of this authority to make its ordinance more responsive to local needs by offering developers of market rate housing a menu of options for including affordable units, for example, by setting a higher percentage of units priced at moderate income and a lower percentage of units set at extremely low income. Such a menu would address a broader range of City of San Mateo housing needs, while giving developers more options for meeting the inclusionary requirement.

Sample Language: The City of San Mateo shall revise its inclusionary housing ordinance to offer developers a menu of options for achieving affordability, adjusting the percentage of units required to be affordable depending on the degree of affordability achieved (moderate-income, low income, very low income, and extremely low income). ● Reduce Parking Requirements for People with Developmental and Other Disabilities. Adults with developmental disabilities have reduced parking needs because they rarely have a driver's license or own a car. This may also be true of other categories of people with disabilities. The City should revise its ordinances to limit parking required for affordable units for people with developmental disabilities to .5 space for each affordable studio or 1 bedroom unit and 1 space for an affordable 2 bedroom unit or larger. A similar reduction should be considered for physically accessible units required to be included in affordable housing.

Sample Language: The City shall encourage the inclusion of people with developmental and other disabilities in affordable housing by recognizing their transit dependence and establishing lower parking ratios for units targeted to people with developmental and other disabilities than would otherwise be required for affordable housing.
● Local Density Bonus Concessions. The state density bonus law currently provides additional density for housing projects that include at least 10% of the units for disabled veterans, transition-age foster youth, and homeless persons at the very low income level. Above and beyond the density bonus guidelines mandated by state law, the City should add the same incentives when at least 10% of the units are subject to preference for people with 6 677 of 955
developmental disabilities who will benefit from coordinated onsite services provided by the Golden Gate Regional Center.

Sample Language: In implementing the California density bonus statute, the City shall provide for the same density bonus, incentives, or concessions for housing projects that include at least 10% of the units for people with developmental disabilities at the very low-income level as are available to projects that include at least 10% of the units for disabled veterans, transition-age foster youth, and homeless persons at the very low-income level.

Affirmative marketing is particularly needed by people with developmental disabilities who, because of cognitive, communication and social impairment, may rely on housing navigation services funded by the Golden Gate Regional Center to learn about and apply for affordable housing.

Sample Language: As a condition of the disposition of any city-owned land, land dedicated to affordable housing under the city’s inclusionary ordinance, the award of city financing, any density bonus concessions, or land use exceptions or waivers for any affordable housing project, the City shall require that the housing developer implement an affirmative marketing plan for physically accessible units which, among other measures, provides disability-serving organizations adequate prior notice of the availability of the accessible units and a process for supporting people with qualifying disabilities to apply. ● Extremely Low-Income Accessory Dwelling Units. As part of a larger plan to increase the supply of Accessory Dwelling Units (ADUs), the City should consider creating a forgivable loan program for homeowners who build ADUs and rent them for at least 15 years at Extremely Low Income rent levels to people with developmental disabilities.

Sample Language: Subject to funding availability, the City shall devise a program of financing for Accessory Dwelling Units subject to rent restrictions for at least 15 years at Extremely Low-Income rent levels to people with developmental disabilities who would benefit from coordinated housing support and other services provided by the Golden Gate Regional Center. ● Affirmatively Further Fair Housing. Not only is disability the highest-ranked source of Fair Housing complaints, a growing body of San Mateo County data indicates that Black, Indigenous and other People of Color (BIPOC) with disabilities experience higher rates of housing discrimination and severe rent burden than either BIPOC without disabilities or whites with disabilities. Currently the City of San Mateo offers its residents exceptional employment, educational and social opportunities but the severe shortfall of Extremely Low Income units means that BIPOC--particularly those with disabilities--are too often excluded from enjoying 7 678 of 955
those community assets. Multiple barriers including high land and construction costs and limited funding make it difficult for developers to produce Extremely Low Income units that will overcome such disparities. Policies that lead to increased production of Extremely Low Income units, as well as city staff dedicated to implementing and overseeing those policies, will Affirmatively Further Fair Housing in the City of San Mateo and decrease displacement and homelessnessness for the most at-risk City of San Mateo residents.

Sample Language: The City of San Mateo's plans to Affirmatively Further Fair Housing for Black, Indigenous and other People of Color, particularly those with disabilities, shall include policies designed to increase the production of Extremely Low Income units, as well as adequate staff capacity to implement and monitor the impact of these policies. 8 679 of 955
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TENANT-PROTECTION POLICY OPTIONS FOR SAN MATEO

Proposed by ONE SAN MATEO | For more information:
[email protected]

March 3, 2021

According to many sources, nearly 47 percent of San Mateo households are renters. On average, these renter households have significantly lower incomes than homeowner households. According to the Affordable Housing Task Force’s 2016 final report, median household income for renters at the time was $64,445, whereas the median household income for owners was $117,700. Faced with constrained incomes and high rents, many renters in San Mateo pay a disproportionately high percentage of their income on housing, and many renter households are badly overcrowded. Latinos and African Americans are affected in especially large numbers by these adverse conditions.

Due to the nature of renting (as opposed to owning), renter households are vulnerable to disruptions completely outside their control. Chief among these is the possibility of rent hikes and eviction, both of which can have far-reaching impacts that easily lead to family trauma.

The passage of AB 1482 created minimal protections for renters against the threat of disruption. But these protections are minimal. Renters in San Mateo need and deserve more.

One San Mateo proposes the following policies for their potential to bring positive change to renters’ lives.

CLOSING GAPS AND LOOPHOLIES IN AB 1482

1. Create “just cause” protection from Day One.

Since AB 1482 stipulates that just cause protections apply to tenants who have been in place 12 months or more, the ordinance deprives compliant tenants of the security they would have if the protections were to go into effect on Day One. The most effective way to address this shortcoming is to pass an ordinance requiring that the just cause provisions under AB 1482 go into effect on Day One. Many local city councils have adopted just cause policies that go into effect on Day One, among them San Jose, Hayward, Oakland, and Alameda. Most just cause policies exist in combination with rent stabilization, but not all.

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Resources on just cause policies adopted by local city councils:

 Information about Hayward’s just cause ordinance:

https://www.hayward-ca.gov/discover/news/mar19/just-cause-eviction- protections-extended-more-hayward-tenants

 Article on Alameda’s just cause ordinance:

https://www.eastbaytimes.com/2019/06/05/alameda-adopts-additional- protection-for-renters/

 Alameda city staff report from 5/21/19 with link to ordinance:

https://alameda.legistar.com/LegislationDetail.aspx?ID=3943916&GUID=B6 65E57F-45B4-4ECF-9269-3D98649DD5E3&Options=&Search=&FullText=1

A less effective approach to the problem is to pass a minimum lease requirement requiring that landlords provide tenants with the option of a one-year lease. This would provide tenants with security for the first year of tenancy but leave them vulnerable to eviction at the end of the first year before the just cause protections under AB 1482 go into effect.

Resources on minimum leases

 Menlo Park FAQ on minimum lease ordinance (with link to the ordinance):

https://www.menlopark.org/Faq.aspx?QID=386

 Redwood City minimum lease ordinance:

https://library.municode.com/ca/redwood_city/codes/code_of_ordinances? nodeId=CH42AMILETEREREUN

2. Prevent renovictions by closing the “substantial remodel” loophole.

Under the terms of AB 1482, a landlord can evict a tenant if s/he intends to demolish or “substantially remodel” the property. The law says that the landlord has to be doing substantial modification that requires a permit from a governmental agency, that cannot be reasonably accomplished with the tenant in place, and that requires the tenant to vacate the property for at least 30 days. Now that there are fewer acceptable rationales for evicting tenants, landlords have manipulated the substantial remodel clause to their advantage. Shirley Gibson, attorney for Legal Aid of San Mateo County, said that in the months before COVID, “substantial remodel” was the most frequently chosen reason for 681 of 955
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60-day termination notices. She further said that when landlords were challenged about their intentions in the unlawful detainer process, it would often turn out that the plans were mostly cosmetic or possibly could be done within 30 days. In response to landlord abuses under the "substantial remodel" provision, several cities have passed an ordinance requiring that landlords obtain permits before serving tenants an eviction notice. Among these are Long Beach, Los Angeles and South Pasadena. The Long Beach and South Pasadena ordinances were passed by a unanimous vote. While One San Mateo has not yet confirmed the vote on the Los Angeles ordinance, we are aware that it was adopted as an urgency ordinance, which requires approval by at least three-fourths of the 15-member council.

Resources on renovictions:
 Article about Long Beach ordinance:

https://www.presstelegram.com/2020/02/18/long-beach-ordinance-tackles- substantial-remodel-loophole-in-tenant-protection-act

 Long Beach staff report from 2/11/20:

http://longbeach.legistar.com/View.ashx?M=F&ID=8060909&GUID=66F42 362-6D3D-4F94-B8E0-2106FFE60EBE

 Long Beach ordinance adopted with first reading on 2/18/20 with second reading on 3/11/20:

http://longbeach.legistar.com/View.ashx?M=F&ID=8075455&GUID=4EBE9 48B-965A-4FEE-8D72-873E14400F28

 Article about the Los Angeles ordinance adoption:

https://www.the-new-
inth.com/closing_a_loophole_in_the_tenant_protection_act

 Los Angeles ordinance:

http://clkrep.lacity.org/onlinedocs/2020/20-0203_ORD_186586_04-03- 2020.pdf

 Article about South Pasadena ordinance adoption:

https://southpasadenareview.com/city-council-passes-tenant-protection-for- remodels/

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3. Create a data registry to track compliance.

While AB 1482 created a set of renter protections, there currently is no way to track whether the requirements of the law are being adhered to. A data registry would provide a mechanism for monitoring whether landlords were raising rents within the prescribed limits and eviting tenants only for just cause.

A data registry could provide other valuable information as well. During the course of San Mateo’s affordable housing task force in 2015/16, the absence of accurate data on rents was a complaint expressed by all parties. It was a strong impediment to understanding the realities of the rental environment that the group was charged with addressing.

The value of data cannot be overstated. It is the cornerstone to assessing current realities and responding with the creation of appropriate policies, whether in housing or any other area of human endeavor. As Matthew Desmond, author of the Pulitzer prize-winning book Evicted, wrote, “Imagine if we didn't know how many Americans were incarcerated each year or how many dropped out of high school, got divorced, or lost their job. If we don't know how big a problem something is, where it is happening, or how many families are touched by it, then how can we begin the critical work of finding solutions?” The City of El Cerrito created a data registry in 2019, and the City Council of Concord voted on December 1, 2020 to launch one.

Resources on data registry:
 El Cerrito FAQ on rent registry:

https://el-cerrito.org/DocumentCenter/View/14344/FAQ_Rent- Registry_2020-Final_v1

 El Cerrito rent registry ordinance:

http://www.el-cerrito.org/1356/Rent-Registry

 Article on Concord rent registry:

https://www.mercurynews.com/2021/01/15/east-bay-city-to-post-rent- increases-eviction-details-online

 Concord municipal code describing tenant protection program, including rent registry:

https://www.codepublishing.com/CA/Concord/html/Concord19/Concord194

0.html#19.40.110

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 Link to January 12, 2021 Concord City Council meeting, Agenda Item 9A, when implementation details for the registry were discussed (what info should be collected, what would be made public, etc):

https://stream.ci.concord.ca.us/OnBaseAgendaOnline/Meetings/ViewMeetin g?id=578&doctype=1 (scroll to Agenda Item 9A for relevant documents)

 Staff report from the January 12, 2021 Concord City Council meeting

https://stream.ci.concord.ca.us/OnBaseAgendaOnline/Documents/ViewDoc ument/Agenda%20Staff%20Report%20for%20-
%20RENT%20REGISTRY%20REPORT%20INFORMATION%20(11054).pdf ?meetingId=578&documentType=Agenda&itemId=11054&publishId=7780&i sSection=false
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Subject: San Mateo’s Draft Sixth Cycle Housing Element
From: Adam Buchbinder
To: [email protected]
cc: [email protected], [email protected] February 1, 2022
To whom it may concern:

The Campaign for Fair Housing Elements is a coalition dedicated to ensuring that every city in California produces a Housing Element which complies with the California Department of Housing and Community Development’s requirements. We have reviewed San Mateo’s Housing Element process and Draft Adequate Sites List as of January 14 1 .

We have the following concerns. The city's estimates of ADU production are too optimistic. The expected density of sites is unrealistic. There’s no evidence that sites will be developed in the first place. The site inventory is not informed by AB 686’s requirements to Affirmatively Further Fair Housing.

ADU Estimates
The city’s ADU estimates are incorrect. According to HCD’s Site Inventory Guidebook 2 (page 31), there are two “safe harbor” options for ADU construction estimates. These are (1) five times the average annual construction before 2018, or (2) the average annual construction since 2018. According to San Mateo’s Annual Progress Reports and the city’s claims, data is available as follows:
2015 2016 2017 2018 2019 2020 2021
2 3 16 8 45 52 67
The safe harbor options are then as follows:

Option (1) (2015-2017) per year, 280 over eight years. 2 + 3 + 16 3 × 5 = 35
Option (2) (2018-) per year, 344 over eight years. 8 + 45 + 52 + 67 4 = 43
The City’s estimate of 480 ADUs is not supported by these calculations. If the City doesn’t use a Safe Harbor option, it must provide additional evidence. If the City doesn’t provide evidence it must reduce its ADU projections.
2 https://www.hcd.ca.gov/community-development/housing-element/housing-element-memos/docs/sites_i nventory_memo_final06102020.pdf
1 https://cityofsanmateo.org/DocumentCenter/View/86766/Draft-Adequate-Sites-List-and-Methodology 685 of 955
Realistic Capacity
The City states on page 2: “When establishing realistic unit capacity calculations, the jurisdiction must consider existing development trends of existing or approved residential developments at a similar affordability level in that jurisdiction“. The city must not only consider previous development trends, but also whether a site will be developed at all . HCD requires cities to account for the difference between a site’s nominal capacity (the number of units it can theoretically support) and its realistic capacity (the number of units likely to be developed there over the next RHNA cycle). 3 The City assumes that its entire site inventory will be developed--an unwarranted and unsupportable assumption.

Specifically, at least half of the city’s lower-income inventory is assigned to non-vacant sites.

Cities are to presume that they will not be developed, in the absence of “substantial evidence” to the contrary. 4 The City states on page 1: “The analysis does not include the economic feasibility of specific sites, nor does it take into consideration the owner’s intended use of the land now or in the future.” As substantial evidence of development has not been provided, the city should use the probability of development of these sites over the previous cycle³.

Results from the last RHNA cycle shed light on the sites’ realistic capacity. An acceptable Site Inventory would take into account San Mateo’s historic rate of development. Only one in twelve sites were developed during the Fifth Cycle. 5
Fifth Cycle Development History
Sites listed in 5th HE Sites developed during ⅝ of 5th Cycle Percentage (Projected) 94 5 8.5%
The City has not provided evidence of future development for each site. Therefore, the City is required to use this percentage to compute the realistic capacity of its sites. 6 San Mateo has a total allocation of 7,081 units . Given this likelihood of development, a site capacity of 10,898 units will produce only 908 units over the planning period. Counting expected development of 6 See note 3, above.
5 Kapur, S., Damerdji, S., Elmendorf, C. S, & Monkkonen, P. (2021). What Gets Built on Sites That Cities "Make Available" for Housing? UCLA: The Ralph and Goldy Lewis Center for Regional Policy Studies.

Retrieved from https://escholarship.org/uc/item/6786z5j9 . Maps available at https://lewis.ucla.edu/RHNAmaps/
4 Housing Element Site Inventory Guidebook, p. 27, “If a housing element relies on nonvacant sites to accommodate 50 percent or more of its RHNA for lower income households, the nonvacant site’s existing use is presumed to impede additional residential development, unless the housing element describes findings based on substantial evidence that the use will likely be discontinued during the planning period.” [Emphasis mine.]
3 Housing Element Site Inventory Guidebook, pp. 20-21, “Local or regional track records, past production trends, or net unit increases/yields for redeveloping sites or site intensification. This estimate may be based on the rate at which similar parcels were developed during the previous planning period, with adjustments as appropriate to reflect new market conditions or changes in the regulatory environment. If no information about the rate of development of similar parcels is available, report the proportion of parcels in the previous housing element’s site inventory that were developed during the previous planning period. ” [Emphasis mine.]
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1,721 units on non-inventory sites and 344 ADUs , this means that the Site Inventory has a shortfall of 4,108 units . In order to produce this many units at a one-twelfth probability, sites must be identified for 49,824 units . (See Appendix A for details.) These numbers are high, but they underscore that if San Mateo continues to proceed as it has over the previous planning cycle, it is planning to fail. The city can either produce roughly fifty thousand more units of planned capacity, or justify these favorable assumptions by identifying and changing the factors that made development so unlikely. Unless that happens, the Draft Housing Element is not in compliance with HCD's guidance and should be rejected.

Expected Density
On page 3, an attempt is made to calculate the average built density of large residential projects. But this is overly optimistic in two ways. First, the Kiku Crossing project is a clear outlier. Will one in fourteen future projects be a 100% below market rate project within a half-mile of a Caltrain station using AB 1763 to develop at nearly four times base density? Calculating a median would have been better here. Secondly, the “average” was calculated by averaging all of the per-acre numbers, rather than dividing the total number of units by the total acreage, which yields 40 du/ac (without Kiku Crossing) and 43 du/ac (with). The method used by the city does not reflect the typical yield of an acre of housing, and the city should not use it.

Furthermore, the City refers to "proposed and/or approved" projects, then uses them to "demonstrate that as-built densities are consistently above zoned density" so the City may assume more realistic capacity for the sites. Six of the 14 projects included on this list also appear on the Cycle 6 Draft Adequate Sites List. Projects that are being counted towards Cycle 6 should not be used to calculate “as built” densities over Cycle 5. Eliminating these six projects yields 38 du/ac. Thus, the assumption of 100% zoned density production for R3, R4, R4D and R5 parcels (base density 35-50 du/ac), which the City applies to 31 sites with one of these designations, is wrong.

The City performs a similar analysis on the average built density of commercial & mixed use projects with residential development by averaging all of the per-acre numbers, which yields 48 du/ac, rather than dividing the total number of units by the total acreage, which yields 40 du/ac.

The city then notes that only 75% of commercial & mixed use projects included residential development and multiplies their calculated “average dwelling unit per acre for projects with residential ” by 0.75 to get an expected dwelling unit per acre for all commercial & mixed use projects. This is overly optimistic as the city has eliminated commercial & mixed use projects with no residential from their calculation, which is then applied (after a 25% discount) to all commercial & mixed use projects. It would be more accurate to simply calculate and apply the built residential density of all commercial & mixed use projects, which is 29 du/ac.

However, seven of the 20 projects included on the list of commercial & mixed use projects also appear on the Cycle 6 Draft Adequate Sites List. Eliminating these seven projects yields 1.7 du/ac. Thus, the City’s “conservative” assumption of 30 du/ac for commercial & mixed use projects does not reflect the typical yield and the City should not use it. 687 of 955
Additionally, the City states on page 8, “For those sites less than 0.5 acres, in general it was assumed that the realistic capacity would be approximately 50% of zoned capacity, given the difficulty of maximizing use of those sites.” However, of the 82 sites less than 0.5 acres and zoned for commercial & mixed use, only one has a realistic capacity of less than or equal to 50% zoned capacity. Sixty-three have a realistic capacity of 60%-80% of zoned capacity and 18 have a realistic capacity of 100% of zoned capacity.

Specific Issues
We’ve looked at some of the factors which have caused actual development to fall short of expectations in the past, and these errors continue to be reflected in the current inventory.

Forty-two of the 212 sites identified on the City’s Adequate Sites List were also included on the site inventories for Cycle 4 and Cycle 5. Three of these sites are rated 4 (out of 5) on development potential and 26 of these sites are rated 5. The city does not identify any constraints to development of these sites over the past fifteen years, nor note any new incentives to development, beyond the rezoning required by AB 1397.

One site appears on the City’s Sites List twice, with different unit allocations:

Site Address Assessor Parcel
Number (APN)
Very
Low
Low Moderate Above
Moderate
Total
4060 EL CAMINO REAL 042-241-180 13 8 8 22 51
4060 El Camino Real 042-241-180 10 6 7 17 40
For each site, the City notes the “Max Density Allowed (units / acre)”, “Realistic Max Density (units/acre)”, and “Parcel Size (gross acres)”. The City also notes the “Realistic Density times size”, which is presumably calculated by multiplying the Realistic Max Density by the Parcel Size. The “Total” number of units on each site is equivalent to the number reported for the “Realistic Max Density times size”, except for sites that already have an approved number of units.

However, 35 sites have a “Realistic Max Density times size” / “Total” that is larger than the Realistic Max Density multiplied by the Parcel Size. For 9 of these sites, it appears Max Density Allowed was used instead of Realistic Max Density in the calculation (highlighted orange below).

For 9 of these sites, a number larger than Max Density Allowed was used (highlighted red below), and for 17 sites, a number between Realistic Max Density and Max Density Allowed was used (highlighted yellow below). Between the duplicate APN and the overestimation of Realistic Density, the Sites List overestimates capacity by 616 units. 688 of 955
Assessor
Parcel
Number
(APN)
Max
Density
Allowed
(units /
acre)
Realistic
Max
Density
(units /
acre)
Parcel
Size
(gross
acres)
Realistic
Density
times size
[ reported ]
Total Realistic
Density
times size
[ actual ]
035-466-010 50 30 1.66 83 83 50
035-466-060 50 30 9.21 461 461 276
039-060-440 50 50 0.73 57 57 37
033-191-040 50 30 0.44 59 59 31
033-191-060 50 30 0.13
033-191-070 50 30 0.45
034-142-200 30 30 0.43 35 35 21
034-142-220 30 30 0.26
034-302-140 50 30 0.68 34 34 20
035-381-020 30 30 0.58 332 332 200
035-381-030 30 30 6.07
039-030-400 50 40 1.54 77 77 62
039-353-050 50 30 1.08 54 54 32
039-353-070 50 30 1.18 59 59 35
042-121-040 50 30 1.81 90 90 54
042-121-080 50 30 0.65 32 32 20
042-241-180 50 40 1.02 51 51 41
042-242-060 50 40 0.25 296 296 268
042-242-070 50 40 0.24
042-242-160 50 40 0.20
042-243-020 50 40 2.09
042-244-040 50 40 0.13
042-244-050 50 40 1.19
042-245-040 50 40 0.12
042-245-050 50 40 0.12
042-245-060 50 40 0.12
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042-245-070 50 40 0.12
042-245-080 50 40 0.12
042-245-090 50 40 0.12
042-245-100 50 40 0.24
042-245-110 50 40 0.24
042-245-120 50 40 0.30
042-245-130 50 40 0.36
042-263-010 50 40 0.73
032-122-210 35 35 0.14 7 7 5
Additionally, on page 8, the city states that “For this inventory, no individual site less than 0.5 acres is allocated toward lower income units; however, as per State guidance, such small sites can be considered either moderate income, above moderate income, or both.“ However, the following sites are allocated toward lower-income units and are below a half-acre in size.

Site Address Assessor Parcel
Number (APN)
Parcel Size
(gross acres)
Allocation
117 N San Mateo Dr 032-292-080 0.41 3 VLI, 2 LI
402 Tilton 032-331-010 0.13 1 VLI, 1 LI
406 Tilton 032-331-020 0.13 1 VLI, 1 LI
487 El Camino Real 034-144-220 0.42 5 VLI, 3 LI
20 42nd Ave 042-242-180 0.21 2 VLI, 1 LI
4142 El Camino Real 042-242-170 0.3 3 VLI, 2 LI
4100 El Camino Real 042-242-080 0.42 4 VLI, 2 LI
2028 El Camino Real 039-060-430 0.38 3 VLI, 2 LI
717 Woodside Way 032-122-210 0.14 2 VLI, 1 LI
Affirmatively Furthering Fair Housing (AB 686)
Per HCD’s Guidance Memo on Affirmatively Furthering Fair Housing, “AB 686 now requires that a jurisdiction identify sites throughout the community in a manner that is consistent with its duty to affirmatively further fair housing (AFFH) and the findings of its assessment of fair housing, pursuant to Government Code section 65583, subdivision (c)(10)(A). 7 While the City has 7 California Department of Housing and Community Development, Affirmatively Furthering Fair Housing, Guidance for All Public Entities and for Housing Elements, April 2021, pg 12 690 of 955
released excerpts from their Housing Needs Data Report 8 it is unclear how the data assessments presented in the report informed the selection of sites.

For example, no sites fall into the “Highest Resource” TCAC Opportunity Area designation and it appears that the sites predominantly fall into areas where three or four racial groups mix.

Map of Neighborhood Segregation by Census Tract, 2019
8 Excerpts from Draft Housing Needs Data Report: San Mateo, December 2021 691 of 955
Map of Sites listed on San Mateo’s Draft Site Inventory Please identify enough sites and commit to an appropriate program of rezoning and constraint removal in a manner that is consistent with your duty to affirmatively further fair housing and such that the actual capacity of the Sites Inventory over the next eight years meets or exceeds your RHNA.

The housing crisis is a regional problem, and our cities must work together to solve it. Thank you for your time and consideration,
Adam Buchbinder
Campaign for Fair Housing Elements
Peninsula for Everyone
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Appendix A
Of the sites listed in the City’s Site Inventory in the Fifth Housing Element, only about 8.5%, or one-twelfth, have been developed. (Data is available for five years of the cycle, so the math is .) The Draft Housing Element must include this information and use it to adjust 5 94 × 8
5 = 0 . 085
its Sixth Cycle estimates of realistic capacity.

Credit is also given for development on non-inventory sites, minus ADUs, as follows. Take the total production over the 2015-2020 timeframe. Subtract development on inventory sites, as reported on HCD’s dashboard 9 for 2018-2020 and by the City before that 10 . Because AMI projects are not reported by address, assume that none were in the site inventory. Because site names were not identified by address or APN, manual matching was necessarily fuzzy. Finally, scale the remainder by 8/6 to get the expected development over the entire Fifth Cycle.

Development on Non-Inventory Sites

VLI LI MI AMI
Production 2015-2020 126 52 94 1545
ADUs (2015-2017) 0 0 0 21
ADUs (2018-2020) 0 0 0 105
Development on Inventory Sites (2015-2017) 0 19 15 293 Development on Inventory Sites (2018-2020) 0 6 0 67 Net Non-Inventory Production 126 27 79 1059
Multiplied by 8/6 168 36 105 1412
10 https://www.cityofsanmateo.org/4477/Housing-Element-2015-23-Annual-Progress- 9 https://app.powerbigov.us/view?r=eyJrIjoiMDA2YjBmNTItYzYwNS00ZDdiLThmMGMtYmFhMzc1YTAzM DM4IiwidCI6IjJiODI4NjQ2LWIwMzctNGZlNy04NDE1LWU5MzVjZDM0Y2Y5NiJ9&pageName=ReportSect ion3da4504e0949a7b7a0b0
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New Capacity Needed to Accommodate RHNA
VLI LI MI AMI Total
RHNA floor 1819 1047 1175 3040 7081
Nominal Capacity 2162 1599 1530 5604 10895
Realistic Capacity (Adjusted to 1/12) 180 133 128 467 908 Projected Non-Inventory Production 168 36 105 1412 1721 ADUs (6% VLI, 31% LI, 48% MI, 15% AMI) 21 107 165 51 344 RHNA floor - Realistic Capacity - ADUs -
Non-Inventory Production = Shortfall 1450 771 777 1110 4108 Nominal Capacity Required To Eliminate Shortfall 17400 9252 9324 13320 49296 694 of 955
From: Eldridge, Karyl < >
Sent: Monday, February 07, 2022 10:21 AM
To: Rick Bonilla <[email protected]>; Amourence Lee <[email protected]>; Diane Papan <[email protected]>; Joe Goethals <[email protected]>; Eric Rodriguez <[email protected]>
Cc: Adam Nugent <[email protected]>; Ramiro Maldonado Jr. <[email protected]>; Margaret Williams <[email protected]>; Seema Patel <[email protected]>; John Ebneter <[email protected]>; Drew Corbett <[email protected]>; Patrice Olds <[email protected]>
Subject: OSM remarks on housing element programs

Dear Mayor Bonilla and Members of the San Mateo City Council,

In response to the staff report dated February 7, 2022, whose subject is “Housing Element Goals, Policies and Programs”, One San Mateo would like to offer the following remarks on a few items that are of special interest to us.

FRAMING. First, we would like to support the utilization of the Three P’s in the framing of the Housing Element goals. This reflects current thinking about the high-level categories of actions that need to be included in a comprehensive plan to promote inclusion and provide for a jurisdiction’s future housing needs. It is a crisp and effective way to organize thinking about the myriad strategies that can be used to address our affordability problem and ensure a suitable living environment for all San Mateans. We encourage adoption of the Three P’s framework and support the addition of a sustainability goal as well. In the interest of consistency, this fourth goal might begin with the word “Pursuit.”

DISPLACEMENT. Under the “Fair Housing” heading on Attachment 3, we encourage the inclusion of a number of strategies that have been upheld by community members in the context of surveys and forums and whose importance was acknowledged at the council’s blue skies event on January 29. These strategies are intended to reduce displacement by preventing people from being forced from their homes. The specific entries that address this are as follows:

▪ Require documentation from landlords who use remodel exemption to evict tenants (AB 1482) ▪ Require tenant relocation payments for No Fault evictions for those with tenure less than one year (extend 1482)
▪ Establish a rental registry to track rents and evictions citywide

POPULATION PRIORITIES. The individuals most underserved by the market, whose very survival is threatened by our spectacular housing costs, are those with the lowest incomes and those with special needs. Therefore, under the “Fair Housing” heading, we also encourage the prioritization of ELI and VLI units, along with units to serve people with special needs, in city-assisted affordable housing projects.

SITES. We are aware of the letter that has been forwarded to council from the Campaign For Fair Housing Elements and are sympathetic to the concerns that prompted the writing of this letter. Recent changes to the sites identification process have been made in the interest of increasing its authenticity and ensuring that it serves equity goals. If the current sites inventory for San Mateo fails to fulfill the newly imposed requirements, we encourage the city to remedy this in the interest of creating a Housing Element that both succeeds in its intended purpose and receives approval by HCD.

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R-1 ZONING. Finally, we feel compelled to mention that we continue to take exception to the strenuous efforts that have been made during this Housing Element update to avoid making changes to R-1 neighborhoods. R-1 zoning was originally introduced as a workaround to racially explicit zoning, and its status as a progenitor of white privilege was cemented during the decades when government-imposed policies excluded all but whites from owning homes in these neighborhoods. When Richard Rothstein addressed the SAMCAR community in October of 2020, he was asked what should be done to reverse the injustices of the past, and the first approach he mentioned was the modest densification of R-1 neighborhoods, i.e. allowing both plexes and modest-scale garden apartments to be built in neighborhoods currently zoned R-1. We concur with his thinking on this and regret that San Mateo has resisted moving in this direction, which would serve significantly to advance the goal of Affirmatively Furthering Fair Housing.

Thank you in advance for your consideration to our thoughts and for the opportunity to share them with you.

Sincerely,

Karyl Eldridge
Vice Chair of One San Mateo

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1 Sandra Council
From: Mary Way
Sent: Monday, February 7, 2022 4:31 PM
To: Joan Diskin
Cc: Sandra Council
Subject: FW: Joint Meeting on Housing Element
Hi Joan,

Here is another Public Comment for tonight’s meeting.

Mary

From: Evelyn Stivers <[email protected]>
Sent: Monday, February 7, 2022 4:29 PM
To: Rick Bonilla <[email protected]>; City Council (San Mateo) <[email protected]>; Planning Commission <[email protected]>
Cc: Eldridge, Karyl <[email protected]>; Jordan Grimes <[email protected]>; Adam Nugent <[email protected]>; Justin Alley <[email protected]>; Bob Whitehair <[email protected]>; Chris Blom <[email protected]>; Ellis Berns <[email protected]>; Schneider, Nancy <[email protected]>; Jim Sell <[email protected]>; Jan Stokley <[email protected]>; John Ebneter <[email protected]>; John Tastor <[email protected]>; Abreu, Ken <[email protected]>; Karyl Eldridge <[email protected]>; Valerie Rynne <[email protected]> Subject: Joint Meeting on Housing Element

Hello Mayor, members of the city council, and planning commission:

HLC is very interested in tonight’s joint Planning Commission and Council meeting to discuss policies for the housing element and I would like to share our perspective and our policy priorities. Housing Element policies are usually designed and formed to both meet the needs identified in the needs assessment and to overcome barriers identified under constraints. Additionally this year, the city must complete a fair housing analysis that would also present opportunities for solutions.

While this could hurt the city’s ability to get a certified housing element on the first try, if the city changes task order, it will make it easier to engage with the local community and to, make a better plan, and shorten the review process..

That said, we have some specific policies that we would like you to consider:

Funding:

1. Increase the commercial linkage fee and design it to preference partnerships between affordable housing providers and commercial developers.

2. Increase the transfer tax on real estate sales over 1 million dollars.

3. Make affordable homes exempt from some fees (like park fees) to decrease the cost and make the city’s limited resources stretch further.

On sites:

1. Beyond following state guidelines on the process for deve loping a sites list, look at publicly owned sites,
including areas that are owned by other agencies, for the opportunity to provide affordable homes. 697 of 955
2 2. Also look at quasi public sites (churches, nonprofits). If an institution is interested in developing affordable homes, what steps (including rezoning) does the city need to take to enable that development.

Overcoming Constraints:

1. Again, complying with state law and identifying constraints before you make decisions on policies is critical.

2. Strategies for parcel assembly

3. Lower your parking requirements, where appropriate

4. Review the neighborhood associations practices for electing leaders, hosting meetings, and providing opportunities for everyone in the neighborhood to participate.

In addition, the city needs specific policies and programs to create ELI housing and housing for special needs populations, and to help prevent displacement and homelessness.

The process for developing a housing element has changed significantly since the last cycle. It is challenging to keep up with the changes and meet the deadlines. But San Mateo has some of the strongest housing leaders on both the Planning Commission and City Council. It is HLC’s hope that the City will create a model Housing Element - one of the best in the state that will serve a an example to other communities in our county and follow the process as outlined by HCD. We look forward to the continued conversation about policies and programs after other work has been completed.

Thank you for your time and leadership.

Evelyn Stivers
Executive Director
Housing Leadership Council of San Mateo County
2905 S El Camino Real
San Mateo, CA 94403
510-334-3362 cell
www.hlcsmc.org

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Housing
Element
Best
Practices:

Lessons from
Previous Cycles
January 2022
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HOUSING ELEMENT BEST PRACTICES:

Lessons from Previous Cycles
MidPen Housing has compiled a set of case studies to illustrate high-impact policies advanced in the last Housing Element cycle and suggest strategies based on successful implementation. This current cycle presents an important opportunity to build and expand upon what worked previously to plan for equitable growth.

At the time of the last Housing Element cycle, many of the tools profiled were designed to exceed State- level policies established by the State Density Bonus Law (SDBL) for projects with affordable housing. In recent years, the State’s policies, through the more powerful SDBL and SB-35 procedural incentives, have evolved considerably, accelerating change. This creates an opportunity with this next cycle to again look at the State-level landscape as a base to respond to, build from, and exceed with local policies tailored to local specifics and needs.

As with the most recent cycle, jurisdictions can look at today’s tools and find ways to make them most effective by making more sites eligible, or set policies that go beyond them with the goals of delivering more housing more quickly. Jurisdictions able to maximize land opportunities and reduce development costs can help spread limited public resources further. Given the vastly changed State landscape, jurisdictions have a much different starting point than the last Housing Element cycle to evaluate opportunities that generate the most impact from their policies.

The Housing Element is a key step to advance the infrastructure needed to support inclusive development through planning and building tools. The most effective jurisdictions had site inventories and policies that were complementary. As jurisdictions work on their policy tools with this cycle, it is critical to take a tactical approach to site selection to realize feasible implementation. We hope these examples are useful to city partners and other community stakeholders.
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RATIONALE: Increases feasibility of affordable housing by spreading density and other planning calculations across a larger development site CITY EXAMPLE: Foster City
Foster City identified an undeveloped 15-acre City-owned property adjacent to City Hall as a housing opportunity site with a vision for a master-planned, mixed-use, mixed-income senior community. In 2011, the City began negotiations with the master developer and pursued a project that consisted of 66 affordable homes along with 355 market-rate and assisted living units. In addition to including the site in their housing element, another enabling policy was utilization of a senior housing overlay zone to facilitate affordable senior housing (reduced parking needs, reduced unit sizes, increased density, fee waivers, priority processing). This form-based/Floor Area Ratio (FAR)-based approach to density makes sense for projects with smaller unit types like senior or supportive housing. Structuring the development’s high-level approvals as a larger master plan instead of breaking into three to four separate projects enabled cost savings for the affordable residential component, increasing feasibility.

C OP YRIGHT C S TC E T I HCRARAB
543 Howard Street, San Francisco, CA 94105, T. 415 293 5700, F. 415 293 5701 WWW.BARARCH.COM

SCRA BR A EI H T C T
The New Home Company Foster City, CA
12002
[ FILE NAME :: Z:\12002 FOSTER CITY\6 DRAWINGS\6.40 CAD-CURRENT\PLOT FILES\FC-FORINDESIGN.DWG ] [ TAB : 34X22 PR ] [ March 22 - Friday 2013 - 10:26am ] [ Plotted by : PHEDGCOCK ] [ Pen Setting : Full 096 ] [ XREF FILE NAME :: :NHCS202_B_PLANT: :W3422PER: :W3422PERLOG ] 0 25' 50' 100' 150'12002 03.21.13
SWA
Setbacks & Heights Study Session

05.02.13 Sustainability and Parking Study Session

C OPYRIGHT C STC E T I HCRARAB
543 Howard Street, San Francisco, CA 94105, T. 415 293 5700, F. 415 293 5701 WWW.BARARCH.COM

SCRA BR A EI H T C T
Project Name (TBA) Foster City, CA
[ FILE NAME :: Z:\12002 FOSTER CITY\6 DRAWINGS\6.40 CAD-CURRENT\PLOT FILES\CURRENT SITE PLAN.DWG ] [ TAB : 34X22 PR PARKING DIAGRAM ] [ April 23 - Tuesday 2013 - 11:45am ] [ Plotted by : PHEDGCOCK ] [ Pen Setting : [ Unkown ] ] [ XREF FILE NAME :: :130313-AL STUDY-WD: :BLDG A CORE GROUND FLOOR: :BLDG A CORE GROUND FLOOR-OPT0: :BLDG B STAIR CORE GROUND FLOOR: :BLDG B U-STAIR CORE GROUND FLOOR: :BLDG C STAIR CORE GROUND FLOOR: :BLDG GB STAIR CORE GROUND FLOOR: :EXMAREBD: :FC-FP01-A: :FC-FP01-B: :FC-FP01-BLDG17: :FC-FP01-C: :FC-FP01-GA: :FC-FP01-GB: :FC-SP-01 - CURRENT: :FC-UP-A-UTGF: :FC-UP-A-UTGF-OPT0: :MP-FP01: :THYSSENKRUPP 3500 ENDURA 3-STAGE: :W1711PERLOG: :W2418PER: :W2418PERLOG: :W3422PER: :W3422PERLOG ] Parking Diagram
0 25' 50' 100' 150'12002 03.06.13 Parking Exhibit

C OPYRIGHT C STC E T I HCRARAB
543 Howard Street, San Francisco, CA 94105, T. 415 293 5700, F. 415 293 5701 WWW.BARARCH.COM

B A R ARCHITECTS
Surface Stalls Provided
FC Blvd Shared 222
FC Blvd Affordable Sr. Housing Dedicated 39
FC Blvd Assisted Living Dedicated 36
The Square Parallel -
Subtotal - Mixed Use 297
Shared On-Street Stalls Provided
Central St. Parallel parking 32
A Street Parallel parking 20
B Street Parallel parking 7
Subtotal - On Street 59
Garage parking provided
Stalls / Bldg
# of Bldgs.

Garage stalls
Assisted Living 28 1 28
Building Type A (2 per unit) 24 8 192
Building Type B (2 per unit) 28 4 112
Building Type C (2 per unit) 48 2 96
Subtotal - Garage Parking 428
Total Parking Provided 784
Z:\12002 Foster City\1 ADMINISTRATION\1.50 Program + Reports\1.55 Area + Statistics\130423_Parking_tab_wrkshtREV3.xlsx 222 Shared
Surface Stalls
Retail C/D w/ Assisted
Living Above 28 Stalls in
Garage
Retail A w/
Affordable Senior
Housing Above
Retail B
Bldg Type B
28 Garage
Stalls
Typical
Bldg Type C
48 Garage
Stalls Typical
Bldg
Type B
Bldg
Type B
Bldg
Type B
Bldg
Type C
Bldg
Type A
Bldg
Type A
Bldg
Type A
Bldg
Type A
Bldg
Type ABldg
Type A
Bldg
Type A
Bldg Type A
24 Garage Stalls
Typical 36 Surface Stalls
39 Surface Stalls
CENTRAL ST - 31 Stalls

BALCLUTHA DR

FOSTER CITY BLVD

SHELL BLVD

PASEO B

CIVIC CENTER DR
A STREET - 20 Stalls B STREET - 7 Stalls

PASEO A
PROJECT IMPACT EXAMPLE:

Alma Point at Foster Square - completed
• Units: 66 (127 units/acre, 78 units/acre including shared surface parking)
• Impact: The City’s senior housing overlay enabled the project to achieve a much higher density level while fitting within an appropriate built form for the site. Given that the site is senior housing with smaller units, the site can support much higher units/acre within the same building footprint.

Foster City’s code has a minimum square footage for rental units of 750 sq. ft., while senior housing units are typically below 550 sq. ft. for studios/1-bedrooms. The ability to leverage non-residential components of the project (public space and commercial space) reduced costs for elements
like parking and infrastructure. Senior parking requirements of .5/unit for residents and .5/unit for guest would have resulted in a required 1:1 ratio. With shared parking, the project was able to move forward with a .59:1 ratio
• Cost savings of $1.6M, including $1.27M in shared
infrastructure and $202K in saved costs via the parking reduction
• Increased density from 35 units/acre to 127 units/acre POLICY: Master-planned sites with opportunities to maximize housing density and share infrastructure; senior housing overlay 702 of 955
POLICY: Fee exemptions for affordable housing
RATIONALE: Increases feasibility of affordable housing by decreasing costs CITY EXAMPLE: Sunnyvale exemption for park in-lieu fees • Park dedication in-lieu fee: $69 per square foot
• This is the biggest lever in Sunnyvale’s fee schedule • The City waives park fees for affordable rental projects and for affordable units in mixed-income rental projects, such as affordable units in density bonus projects PROJECT IMPACT EXAMPLE:

Edwina Benner Plaza - completed
• Units: 66 (50 units/acre)
• Park impact fee: $2.4M
($37.6K per unit)
• Impact: This exemption reduced the
total development budget by about
5%. These waived fees are also
advantageous to the project’s ability
to secure financing as they count
towards the local leverage calculation
utilized by competitive financing
sources like the Low-Income Housing
Tax Credit program (LIHTC)
PROJECT IMPACT EXAMPLE:
1178 Sonora Court - in development
• Units: 176 (140 units/acre)
• Park Impact Fee: Approximately $7.8M
($44K per unit)
• Impact: This exemption reduced the
total development budget by about
6%. These waived fees are also
advantageous to the project’s ability to
secure financing as they count towards
the local leverage calculation utilized
by competitive financing sources like
the Low-Income Housing Tax Credit
program (LIHTC)
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POLICY: Reduced parking standards for affordable housing RATIONALE: Increases feasibility of affordable housing by decreasing costs Saves one of the typical waivers in the State Density Bonus Law (SDBL) so developers can use it for another feasibility-improving modification CITY EXAMPLE: Sunnyvale parking reductions
Reduced parking requirements for affordable housing developments and housing for seniors or persons with disabilities were adopted in 2011. The modified parking ratio that MidPen Housing was allowed to use for the 124-unit Fair Oaks Senior Housing project served as the basis for the adopted parking standard for affordable housing for seniors or persons with disabilities. The City also adopted provisions to allow development applications for senior housing, housing for persons with disabilities or housing affordable to lower income households to include requests for further reductions in the parking requirements. The request can be granted if the approving body finds that the applicant’s proposed parking standard is adequate through a combination of any of the following considerations: location or proximity to transportation, variety or forms of transportation available, accessibility, services and programs offered, or population served by the proposed housing development. Many jurisdictions have adopted lower parking requirements for affordable housing based on robust data showing lower rates of car ownership and utilization at affordable housing properties given income, as well as locations that are often proximate to high-quality transit given financing-program criteria.

PROJECT IMPACT EXAMPLE:

Onizuka Crossing - completed
• Units: 58 (46 units/acre)
• Parking spaces required without restrictions: 122
• Parking spaces provided with reductions: 93
• Cost per space: $22.5K
• Parking savings: $653K
• Impact: This policy reduced the total development
budget by about 2% and enabled the project
to utilize its SDBL concessions for other items
impacting feasibility
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POLICY: Exceptions to development standards for affordable housing RATIONALE: Increases feasibility of affordable housing through exemptions that go above and beyond what would be enabled through SDBL
CITY EXAMPLE: Half Moon Bay
Section 18.06.050(H) of the zoning code states that development standards for residential uses may be waived or relaxed for an affordable housing project. This provision allows developers much flexibility in designing affordable housing projects. Minimum lot sizes, widths, setbacks, parking, and other requirements can be reduced or waived, as long as the resulting development conforms to the certified Local Coastal Program (LCP) and other applicable provisions of the zoning code outside of chapter 18.06. This was applied in MidPen’s Half Moon Village project, which was enabled through partnership with the San Mateo County Housing Authority and City of Half Moon Bay.

PROJECT IMPACT EXAMPLE:

Half Moon Village - completed
• Units: 160 (27 units/acre)
• Exceptions: maximum height (from 28
to 40 ft) and parking (2.25 to .75)
Performed density calculations looking
at the larger campus area, which
arrived at a density that met LCP
requirements
• Impact: With reduced parking and
increased height, this policy enabled
redevelopment to increase the number
of homes from 60 existing units to 160
new units
Cost savings of $1.8M for reduced
parking, 3.7% of the total development
budget
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POLICY: Affordable Housing Overlay zone
RATIONALE: Increases feasibility of affordable housing through targeted incentives that exceed the SDBL
Upzoning tied to community benefit
CITY EXAMPLE: Menlo Park Affordable Housing Overlay (AHO) Through Menlo Park’s Housing Element process and site inventory analysis, they arrived at the policy tool of an AHO zone with incentives that go beyond the SDBL. The rezoning applied the overlay to affordable housing opportunity sites as well as a targeted specific plan area. Overlays like this create a win-win for site owners and developers that want to provide affordable housing, as the overlay increases site value for those who can execute on the development vision being incentivized. Menlo Park’s Gateway Apartments, an affordable housing property acquired by MidPen in the 1980s, presented an opportunity for adding units. The City worked to identify properties that could be a fit for both planning and implementation, looking at ownership and alignment.

PROJECT IMPACT EXAMPLE:

Sequoia Belle Haven - completed
• Units: 90 (31 units/acre)
• Units permitted under R-4-S zoning without AHO: 30
units/acre
• Units permitted under R-4-S zoning with the AHO: 48
units/acre vs 40 units/acre under max SDBL
• Units permitted under prior site zoning (R-3) with the SDBL: 18 units/acre max plus 35% SDBL for 25 units/
acre
• Other AHO incentives utilized:
- fee waiver
- reduced parking
- setbacks
- building height
• Impact: This policy enabled additional units on the
site (from 48 existing to 90 with the redevelopment)
through the rezoning pursued during the City’s
Housing Element process and increased project
feasibility through the AHO alternative to the SDBL
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POLICY: Use of surplus land and City-led rezoning
MIDPEN HOUSING PAGE 7 RATIONALE: Increases feasible development opportunities and removes zoning risk CITY EXAMPLE: Fremont
The City of Fremont reviewed their properties and identified surplus opportunities, including actions to enhance feasibility of development through its General Plan Amendment (GPA) and rezoning. They identified a 2.3 acre vacant site, which became Stevenson Terrace, as land to sell or lease to local public entities proposing the development of low- and moderate- income housing per the State’s Surplus Land Act requirement. The City also issued a Notice of Funding Availability (NOFA) to provide financing for affordable housing development which accelerated the process so that Stevenson Terrace could be entitled, positioned to secure additional needed financing, and constructed to provide affordable housing to families quickly. Additionally, the use of the SDBL permitted a higher density and concessions to support a cost-effective design, supporting the City’s vision for more affordable housing.

PROJECT IMPACT EXAMPLE:

Stevenson Terrace - completed
• Units: 80 (35 units/acre)
• Rezoning: City rezoned from open space to medium density residential prior to disposition • Impact: This policy enabled high density housing development and accelerated delivery of housing units
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POLICY: Identifying housing opportunity sites owned by mission-aligned organizations
RATIONALE: Increases likelihood of near-term progress on housing goals CITY EXAMPLE: Santa Cruz County
St. Stephens Senior Housing is a 40-unit senior affordable housing community in the Live Oak community of unincorporated Santa Cruz County. Long considered a “priority development area” by the former County Redevelopment Agency, it was through a partnership with regional non-profit Communities Organized for Relational Power in Action (COPA) that a local member organization expressed a willingness to support the provision of more affordable housing by utilizing a vacant portion of their property. The County of Santa Cruz subsequently approved the subdivision and rezoning of ~1.8 acres of the existing St. Stephens Church property from public facilities to multifamily residential to enable St. Stephens Senior Housing to be built. Beyond the utilization of the SDBL to achieve higher density, the County’s code also provided a 75% parking reduction for senior housing, as well as allowed a shared parking arrangement with the Church, which significantly reduced development costs.

These policies enabled the Church to enact
their vision of aligning surplus real estate to meet their core mission through advancing affordable housing.

PROJECT IMPACT EXAMPLE:

St. Stephens Senior Housing - completed
• Units: 40 (22 units/acre)
• Parking savings: $457.5K
• Impact: Rezoning and SDBL enabled additional units on the site, and the reduced parking allowance increased project feasibility and lowered development costs (standard requirements 708 of 955
POLICY: Public sector led rezoning for affordable housing RATIONALE: Increases feasible development opportunities and removes zoning risk CITY EXAMPLE: Santa Cruz County
As part of the 2007 Housing Element effort, the County rezoned 6 sites totaling approximately 29 acres to a density of 20 units/acre, creating potential for nearly 600 units.

They also completed the environmental review process.

PROJECT IMPACT EXAMPLE:

To date, MidPen has developed 3 of the 6 sites including Schapiro Knolls, Pippin Orchards Apartments and Aptos Blue, and is in the process of developing Pippin Phase II. These projects were zoned by-right per the County’s Planned Unit Development (PUD). Design review is the only remaining discretionary approval required to develop the property. This removes substantial business risk for incoming development partners and decreases the time and money needed to obtain entitlements. MidPen estimates this saved $2M between the 4 projects and also shortened each timeline by at least 12 months.

Santa Cruz County Housing Element Sites Developed / In Development • Project and Units: 4 communities totaling 254 homes
• Impact: This policy enabled 242 additional units beyond what would have been feasible under the previous zoning.
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POLICY: Identifying public and privately-owned sites with existing housing stock for total redevelopment to increase density RATIONALE: Potential to both improve and expand stock of housing Increases likelihood of near-term progress on housing goals CITY EXAMPLE: Pleasanton
Kottinger Gardens is the redevelopment of Kottinger Place and Pleasanton Gardens, two existing senior communities in the City of Pleasanton, into one integrated senior affordable housing community with 185 new units, doubling the original count. Kottinger Place was owned by the City’s Housing Authority and Pleasanton Gardens was privately owned by a nonprofit originally founded with representatives from three local churches. The two properties were located across the street from each other, but operated independently for 40 years. Bringing them together was the result of thoughtful planning and community outreach on the part of The Kottinger Place Redevelopment Task Force formed by the City of Pleasanton to address several long-term challenges at both properties, including increasing maintenance requirements, and the lack of accessibility and energy-efficient features in the homes. The redevelopment was financed and constructed in two phases.

PROJECT IMPACT
EXAMPLE:

Kottinger Gardens - completed
• Units: 185 (28 units/acre)
• Impact: Redevelopment
of 90 functionally obsolete
public housing units and
privately-owned affordable
homes for seniors into a
high-quality new senior
affordable development of
185 units
POLICY: Identifying public and privately-owned sites with existing housing stock for total redevelopment to increase density 710 of 955
February 28, 2022
Policy Recommendations for 6th Cycle Housing Element
Dear Planning sta
ﬀ:

YIMBY Law submits this letter to share our policy goals and recommendations for the Policies and Programs section of your Housing Element. We appreciate the opportunity to participate in the Housing Element process.

The Policies and Programs section of the city’s Housing Element must respond to data, analysis and
ﬁndings presented in the Housing Needs section. We
repeatedly see ﬁndings that housing prices are high, segregation exists, and there is a lack of housing for special populations, but the Policies and Programs don’t respond to these
ﬁndings or try to change outcomes. The overview of the city’s housing environment should set the scene, and the policies and programs should explain what the city is going to do to
ﬁx it.

Our policy goals are as follows:

Aﬃrmatively Furthering Fair Housing

1. Prioritize rezoning in high resource, historically exclusionary neighborhoods.

Many of the highest resource neighborhoods with the best access to jobs, good schools, and other amenities have histories of exclusion which are still re ﬂected in
their zoning. Cities should rezone to allow more housing opportunities in those neighborhoods, particularly those with low Vehicle Miles Traveled, as part of their 1 711 of 955
Housing Elements.

2. Establish a strong tenant protection ordinance so that new housing beneﬁts everyone. Development should not permanently displace current residents.

Housing replacement programs, temporary housing vouchers, right of return, and demolition controls will create stability for renters while allowing new homes to be built for new households and to accommodate the growth associated with RHNA.

In your sites inventory and rezoning programs, you should prioritize development on sites with owner-occupied housing & commercial uses over those with existing rent-controlled apartments or other rental housing with lower income residents.

3. Support homeownership opportunities for historically excluded groups.

Homeownership continues to be a path to building
ﬁnancial security and
inter-generational wealth, which has been systematically denied to many Americans. As a society, we need to make this right by intentionally o ﬀering
opportunities to communities who have been excluded. The housing element should identify opportunities to create a variety of for-sale housing types and create programs to facilitate property ownership among excluded groups.

Site Capacity

4. Adequately plan for density. Ensure that a site’s density will accommodate the number of homes that are projected to be built. In addition, make sure height limits, setback requirements, FAR, and other controls allow for adequate density and the ability to achieve a site’s realistic capacity. Housing will not be feasible if you have a high density paired with low height limits. This density should be emphasized around jobs and transit and should go beyond the Mullin density in those areas.

5. Provide su
ﬃcient zoned capacity to accommodate all income levels, including a minimum No Net Loss buﬀer of 30%. Not every site will be developed at maximum density during the eight-year planning period. Identify an ample amount of opportunity sites and zone the sites to accommodate lower-income housing types (usually a statutory minimum of 30 dwelling units per acre) to give the city the best chance at meeting its RHNA. 712 of 955

6. Use data from the 5th Cycle to calculate the likelihood of development for your 6th Cycle site inventory. Likelihood of development is a measure of the probability of an inventory site being developed during the planning period. The median likelihood of development across the state is 25%, meaning only one of every four sites will likely be developed during the planning period for the median city. Incorporating the likelihood of development into the zoned capacity will set the city up to successfully achieve their RHNA, making the housing element less of a paper exercise and more of an actionable, functional document.

Accessory Dwelling Units

7. Commit to an automatic mid-cycle adjustment if ADU permitting activity is lower than estimated in the housing element. We highly recommend complying with HCD’s standards of using one of its “safe harbor” methodologies to anticipate future ADU production. However, if the city is optimistic about ADU growth, then creating an automatic mid-cycle adjustment will automatically facilitate alternative housing options (i.e., a rezoning program, removing development constraints, ADU incentives, etc.) if the city falls behind the estimated ADU production.

8. Incentivize new ADUs, including those that are rent-restricted for moderate- or lower-income households or that are prioritized for households with housing choice vouchers. Consider o
ﬀering low- or no-interest loans, forgivable
loans, impact fee waivers for ADUs that are 750 square feet or larger, allowances to facilitate two-story and second-story ADU construction, etc.

Zoning

9. Allow residential to be built in areas that are zoned for commercial use.

There are a myriad of ways to do this, but a housing overlay is one common policy.

Additionally, consider eliminating new commercial space in mixed-use developments where there is not a strong demand or there is otherwise a glut of commercial space that is unused or frequently vacant.

10. Allow
ﬂexibility in inclusionary zoning. Cities should require diﬀerent percentages for diﬀerent AMI levels. Additionally, we urge cities to incentivize land 713 of 955
dedication to aﬀordable developers in order for market-rate developers to meet their inclusionary requirements. Avoid getting trapped into thinking that the aﬀordable units must be “sprinkled throughout” the market-rate units, or require the market-rate units to look exactly the same as the aﬀordable ones. This should be balanced against not locating all of the aﬀordable units in one place and ghettoizing neighborhoods by creating or perpetuating racially concentrated areas of poverty.

Better Entitlement Process & Reducing Barriers to Development

11. Ensure that the city has a ministerial process for housing permitting, especially multi-family housing, and remove impact fees for deed-restricted housing. A discretionary process for housing development creates uncertainty and adds to the cost of construction. For example, multi-family housing should not require a conditional use permit or city council approval unless the builder is asking for unique and extraordinary concessions. Right-sizing governmental constraints, entitlement processes, and impact fees will help the city successfully meet its RHNA.

12. Reduce parking standards and eliminate parking minimums. Minimum parking requirements are a major constraint on housing, especially for lower cost housing types. They can cost in excess of $30,000 per spot and can raise rents by as much as 17%, and eliminating them is particularly important for smaller & other spatially constrained sites. Consider adopting a parking maximum.

13. Cap fees on all new housing. Most construction costs are outside the City’s control, but reducing impact fees can demonstrate that a city is serious about building new housing. At a minimum, cities should delay the collection of impact fees until the issuance of the certi
ﬁcate of occupancy to reduce ﬁnancial impacts
on new housing and make the units cheaper by not asking the developer to carry impact fee charges or debt throughout the construction phase.

14. Provide local funding. One of the largest barriers to building new a ﬀordable
homes is the lack of city/county funds available to assemble sites, provide gap funding, and to pay for dedicated sta
ﬀ. Without new funding, especially at the
local level, we will not be able to build more aﬀordable homes. There are three 714 of 955
new revenue streams that should be considered: 1) Transfer tax, a one-time payment levied by a jurisdiction on the sale of a home, may be utilized to raise much needed revenue to fund aﬀordable homes; 2) Vacancy taxmay be collected on vacant land to convince landowners to sell their underutilized properties and be used to fund the construction of a
ﬀordable homes; 3) Commercial linkage
fees should be adopted or revisited for increases on new commercial developments.

We urge you to include these policies in your 6th cycle Housing Element.

Best regards,
Sonja Trauss
Executive Director
YIMBY Law
[email protected]
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TCAC/HCD
Opportunity
Map
Highest
Resource
Moderate
Moderate
(Rapidly
Changing)
High
High
Highest
TCAC - California Tax Credit Allocation Committee
HCD - California's Housing and Community Development Department Draft 2023-2031 Housing Element
City of San Mateo
723 of 955

From:

To:

Subject: Housing Element Draft Plan. (HEDP)
Date: Wednesday, April 6, 2022 3:59:49 PM
Attachments: image574731.png
Ms Sandhir:

I have reviewed the email of the HEDP and have several questions and areas of concern.

Firstly, why has the issue of current substantial vacancy rate in existing housing not being discussed or publicized. I have asked numerous officials including your office and the responses all seem to be “ I’m not aware of the current figure.” Nice evasion. Is there even any discussion or concerns relating to our declining population and technological changes allowing remote work and population shifts.

Secondly of the five items you wish to address, four relate to subsidized housing in one form or another and the fifth is “education “ of housing issues. There is not one mention of how these changes will affect the quality of life in our city and how the impacted neighborhoods may change. There are many thousands of families whose primary net worth is represented by the value of their home. They have saved for a lifetime to enjoy the amenities of life in San Mateo. To the extent that these changes will affect many of these families, are their concerns not even worth some consideration and discussion?
Many of us hear anecdotally of significant vacancy factors in market rate housing. For rent signs are ubiquitous throughout San Mateo. I believe that an honest discussion of how much housing and affordable housing is truly needed before we blatantly accept an arbitrary mandate from the state . The first obligation of the city council should be to address the legitimate needs and concerns of the residents of San Mateo with the equal fervor that it devotes to implementing the state housing creation mandate.

John Monfredini
Sent from my iPad
John Monfredini

724 of 955
1 From: Susan Shankle
Sent: Wednesday, April 13, 2022 3:08 PM
To: Housing
Subject: Housing Element
Hello,

The plan as written looks good, lots of good suggestions and goals. A few comments:

• What are we doing about water supply? Every new house and apartment is going to have sink taps, showers, dishwashers, toilets, and some with garden hoses. We are in a severe drought, and climate change suggests that might only get worse.

• How can we turn all those empty office buildings into housing? We know about the liabilities and zoning issues. But it’s silly to talk about building more buildings when we have so many already in place, some practically new or even unfinished. They all are fitted with plumbing and electricity, and many have full cafeteria facilities. Put your imaginations to work and envision these spaces as potential housing for homeless and low‐income San Mateans.

• Re: the homeless, are you working with existing entities that are already expert and experienced in these issues? Such as LifeMoves? https://www.lifemoves.org/

• What about rising sea levels? Is it wise to embark on a huge housing plan on sea‐level land next to the Bay? Do we want to look like Hong Kong? It’s a fabulous city but do we really want to duplicate that?

• Along with all these plans has to be education. We are lucky to have a diverse population of citizens from all over the world. People need to be educated about how to live in a crowded Bayside region: water use, recycling, transportation, parking, conservation, wildlands protection, environmental stewardship, the list goes on. If I was moving to an unfamiliar state or country, I would need to find out what my responsibilities would be, and how I could participate, support and respect the existing environment and animal life. Volunteers would be good for this, and cheap!

• A lot is said about how hard it is to build and do business here because of all the regulations, especially environmental.

They exist for a reason. We have clean air and water and a high quality of life, compared to many parts of the world. We want to keep it that way. Don’t back down or weaken those protections.

Thank you,
Susan Shankle
30‐year San Mateo Resident
Lifetime Bay Area Resident

725 of 955
1 From: [email protected]
Sent: Wednesday, April 6, 2022 11:02 PM
To: Housing
Subject: Online Form Submittal: Draft 2023-2031 Housing Element Comment Form Draft 2023-2031 Housing Element Comment Form

Draft Housing Element Feedback Form

Please share your comments regarding the Draft Housing Element.

Comment period for the draft document is April 6 through May 6, 2022.

First Name Bob
Last Name Stine
Email Address
Comment on 2023‐2031
Draft Housing Element
What consideration has been given to the additional needs for water that would accrue with the planned additional building of residential units?

Email not displaying correctly? View it in your browser.

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Original (move here after redaction) April 7
Redacted April 7
4-6-22 Monfredini.msg April 6
4-6-22 Zane.msg April 7
Docum s on Draft HE
From: Housing <[email protected]> on behalf of Housing Sent on: Wednesday, April 6, 2022 10:45:22 PM
To: -
Subject: FW
: Housing Element

From:

Sent: Wednesday, April 6, 2022 3:39 PM
To: Housing <[email protected]>
Subject: Housing Element

I realize that there is some type of state mandate that requires counties to establish more housing in each of our CA counties. What I do not understand is the lack of obvious concern that California has experienced an alarming drought for years. The seriousness of this water shortage has an effect on our water usage. Considering the amount of new homes, this represents a huge increase in the use of water in a myriad amount of ways. Additionally, there seems to be a rational neglect for the demands of food and home supplies, quality schools, and teachers to staff those schools. There are significant shortages now in these areas, and yet, home building continues. I believe this is both irrational and irresponsible.

Without being caustic, I think the myopic vision of these home planners will result in insurmountable, adverse challenges in our future. Surely, someone on your committees realizes this.

Maureen Zane
76 year old resident of San Mateo
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Subject: San Mateo’s Draft Sixth Cycle Housing Element
From:

To:
cc:

April 20, 2022
To whom it may concern:

The Campaign for Fair Housing Elements is a coalition dedicated to ensuring that every city in California produces a Housing Element which complies with the California Department of Housing and Community Development’s requirements. We have reviewed San Mateo’s Draft Housing Element as of April 10 1 . We previously sent in a letter reviewing San Mateo’s Housing Element process and Draft Adequate Sites List as of January 14; this letter is posted at the City’s website 2 .

It is discouraging that the city has failed to address the issues previously raised. Furthermore, the city’s draft policies do not address the city’s constraints, and do not meet HCD’s requirements 3 that programs include specific action steps, specific timeframes, and specific, measurable outcomes. Lastly, there is evidence that some sites on the inventory list will not be developed.

Previously Identified Issues Still Outstanding
The following issues identified in our previous letter have not been addressed. ● On page H-6 of the draft, the ADU numbers are still overestimated. Pages H-33 through H-34 justify this by stating that “The State now allows jurisdictions to count projected development of accessory dwelling units (ADUs) based on prior years’ production averages”. However, the state specifically recommends counting trends since 2018, when ADU laws were liberalized. 4 The city does not provide sufficient explanation to justify exceeding the safe harbor estimates. 480 are estimated; past production justifies an estimate of 344.
● On the same page, the nominal capacity of about 10.9k remains unrealistic. As shown in our February letter, previous production trends indicate a realistic capacity of only 908 units, far short of the realistic capacity needed to achieve the City’s RHNA floor of 7,015 units.
4 Housing Element Site Inventory Guidebook,
https://www.hcd.ca.gov/community-development/housing-element/housing-element-memos/docs/sites_in ventory_memo_final06102020.pdf , page 31.
3 https://www.hcd.ca.gov/community-development/building-blocks/index.shtml 2 https://www.cityofsanmateo.org/DocumentCenter/View/87035/Additional-Correspondence-as-of-2-11-22 , pages 1-10.
1 https://www.cityofsanmateo.org/DocumentCenter/View/87532/San-Mateo-2023-2031-Housing-Element-- -DRAFT
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● On page H-28, the city continues to incorrectly average residential project densities by project , failing to account for differences in project acreage. The expected density should be 43 du/ac, not 60 du/ac.
● On pages H-28 through H-31, the city uses the same incorrect averaging method for mixed-use developments, on a variety of levels. The expected density of mixed-use projects should be 29 du/ac, not 48 du/ac. (Excluding projects already on the Adequate Sites List, expected density is an alarmingly low 1.7 du/ac!) ● On pages H-40 through H-41, the city makes no mention of surveying property owners to determine whether or not they plan to redevelop their properties.

Participating in county-wide listening sessions with builders does not solve this problem.
● In Appendix C 5 , the details of the site inventory are still incorrect. Spot-checking APN 035‐466‐010, the city is still using maximum capacity, rather than realistic capacity, to figure site capacity, at least for some sites. Spot-checking APN 032‐292‐080, the city is still using sites under a half-acre for lower-income RHNA without justification, in violation of HCD’s guidelines.
● Also in Appendix C, the site inventory lists 131, 139, and 149 Kingston as “Pending project”, despite the relevant project having been withdrawn in August of 2021. 6 This is not an exhaustive inventory of incorrectly listed sites.

Inadequate “Missing Middle” Program
HCD’s “Building Blocks” website states:

Each jurisdiction must identify specific programs in its housing element that will allow it to implement the stated policies and achieve the stated goals and objectives. Programs must include specific action steps the locality will take to implement its policies and achieve its goals and objectives. Programs must also include a specific timeframe for implementation, identify the agencies or officials responsible for implementation, describe the jurisdiction’s specific role in implementation, and (whenever possible) identify specific, measurable outcomes.

Section 5.3 (page H-47) of the draft says that one of the programs is:

Support the production of more missing middle housing. (Policies H1.4, H1.11 and H1.13 )
Policy H1.4 (page H-59) concerns ADU development, policy H1.11 (page H-60) is to adopt an SB 9 ordinance (which would merely adhere to state law), and policy H1.13’s targets (same page) read:
6 https://www.cityofsanmateo.org/4004/Monte-Diablo-North-Kingston-SPAR 5 https://www.cityofsanmateo.org/DocumentCenter/View/87528/APPENDIX-C---Housing-Resources 729 of 955
Evaluate sites that have potential for Missing Middle development. Research and evaluate policies and code amendments to allow for Missing Middle housing under SB 10 and schedule for City Council consideration.

The research and evaluation of policies to allow for Missing Middle housing should be done now, not later. missingmiddlehousing.org provides useful specifications for missing-middle housing.

For example, consider a front-loaded side-by-side duplex 7 . It’s illegal to build in San Mateo’s R-2 zone 8 because of insufficient off-street parking; the design provides two stalls, but San Mateo requires four. (Municipal code §27.64.160.)
Next, consider a front-loaded stacked duplex 9 . It’s illegal to build in San Mateo’s R-2 zone because of insufficient off-street parking; the design provides two stalls, but San Mateo requires four. (Municipal code §27.64.160.) It’s also too narrow; the lot is forty-five feet wide, but San Mateo requires fifty feet. (Municipal code §27.18.040.) Then consider an alley-loaded townhouse 10 . It’s illegal to build in San Mateo’s R-3 zone (the lowest-density zone which is supposed to support townhouses) because the front setback is insufficient; the design has ten feet, but needs fifteen. (Municipal code §27.22.070.) It’s also too small; the parcel size is 2750 square feet, but it needs four or five thousand, depending on which area of the city it’s in. (Municipal code §27.22.040.) Identifying the portions of the city’s code which prohibit missing-middle housing–parking mandates and minimum lot sizes–does not require a years-long research process. These are constraints, and the city’s programs should focus on removing them.

Affirmatively Furthering Fair Housing
Site Locations
As noted in our previous letter, no sites in the city’s inventory fall into the “Highest Resource” TCAC Opportunity Area designation, and it appears that the sites predominantly fall into areas where three or four racial groups mix.

Air Quality Issues
The California Air Resources Board has published an Air Quality and Land Use Handbook 11 that considers the risks of poor air quality on sensitive receptors such as homes, daycares, etc, and 11 https://ww3.arb.ca.gov/ch/handbook.pdf
10 https://missingmiddlehousing.com/types/townhouse#idealized 9 https://missingmiddlehousing.com/types/duplex-stacked#idealized 8 https://sanmateo.ca.us.open.law/us/ca/cities/san-mateo/code/27.20 (All zoning laws evaluated as of April 10, 2022.)
7 https://missingmiddlehousing.com/types/duplex-side-by-side#idealized 730 of 955
recommends against locating these uses within five hundred feet of a roadway that averages in excess of 100,000 vehicles/day. This standard was cited by the City at least once, as background 12 for a General Plan update in 2009. As far back as 2001, the City identified 13 Highway 92 (east of Delaware) and Highway 101, as routes exceeding this threshold. Current Caltrans data 14 shows that Highway 92 east of El Camino exceeds 100,000 vehicles per day.

Specifically, the Caltrans data shows that Highway 101 daily vehicle counts range from 253,100 to 264,600 15 , as it moves through San Mateo city limits. AB 686 and related legislation would discourage locating housing - certainly affordable housing - in areas subject to high air pollution, which is a burden disproportionately borne by disadvantaged communities. A number of sites are within five hundred feet of Highway 101 and Highway 92 east of El Camino, totalling 2,396 units (21.9% of total) and 925 affordable units. Compliance with AB686 suggests the following sites should not be included in the inventory:

Address APN Total Units Affordable Units
1900 S. Norfolk St 035-391-090 245 99
2000 Winward Dr 035-610-030 160 24
1820 Gateway Drive 035-443-030 177 72
1800 Gateway Drive 035-430-060
1850 NORFOLK ST 035-381-020 332 134
1826 NORFOLK ST 035-381-030
19 KINGSTON ST 033-191-040 59 24
25 KINGSTON ST 033-191-060
3 KINGSTON ST 033-191-070
1017 3RD AVE 033-134-100 32 13
1015 3RD AVE 033-134-110
245 HUMBOLDT ST 033-134-240
1900 FASHION ISLAND 035-466-060 461 186
2260 BRIDGEPOINTE PKWY 035-466-070 97 39
2270 BRIDGEPOINTE PKWY 035-466-080 42 17
15 https://dot.ca.gov/programs/traffic-operations/census/traffic-volumes/2017/route-101 14 https://dot.ca.gov/programs/traffic-operations/census/traffic-volumes/2017/route-92-98 13 https://www.cityofsanmateo.org/DocumentCenter/View/5126/7-Mobility-and-Access 12 https://www.cityofsanmateo.org/DocumentCenter/View/5229/Appendix-C-Air-Quality-Analysis 731 of 955
3012 BRIDGEPOINTE PKWY 035-466-090 82 33
[NO ADDRESS] 035-466-110 89 36
1863 NORFOLK ST 035-383-200 105 53
1670 AMPHLETT BLVD 035-241-240 173 71
1700 AMPHLETT BLVD 035-241-250 122 49
1720 AMPHLETT BLVD 035-241-260 138 56
145 Kingston 033-171-040 35 0
139 Kingston 033-171-050
131 Kingston 033-171-060
1218 Monte Diablo 033-171-180
480 N Bayshore Blvd 033-081-280 47 19
Evidence On Specific Sites
Hillsdale Mall
Hillsdale Mall (41 Hillsdale Boulevard) is identified in the Site Inventory as a 39.91 acre parcel with potential for a total 1,995 units, 808 of which are affordable (40.5%). HCD’s Housing Element Sites Inventory Guidebook states that sites larger than 10 acres cannot be considered feasible for affordable housing without one of the following factors 16 :
a) an analysis demonstrating that sites of equivalent size were successfully developed during the prior planning period with an equivalent number of lower income housing units as projected for the site, or
b) evidence that the site is adequate to accommodate lower income housing such as developer interest, proposed specific-plan development, potential for subdivision, the jurisdiction’s role or track record in facilitating lot splits, or other information that can demonstrate feasibility of the site for development. The housing element should include programs promoting, incentivizing, and supporting lot splits and/or large lot development, or
c) a development affordable to lower income households has been proposed and approved for development on the site.

San Mateo’s Housing Element states on page H-31 that “The City has a demonstrated track record of large site development, typically completed in phases, that includes affordable 16 Housing Element Site Inventory Guidebook, page 17.
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residential development. Station Park Green (12 acres), Concar Passage (14.5 acres), and Bay Meadows (175 acres) are examples of approved large development projects that include substantial numbers of affordable units.“ Of these sites, Concar Passage was not completed during the previous planning period; in fact, no site work has even begun. For the two projects that were completed during the prior planning period, each one contains substantially less affordable housing: 97 units for Station Park Green and 98 for Bay Meadows (the portion of the master plan that was actually completed during the last cycle) 17 . Furthermore, the City’s report contains no information about the availability of the Hillsdale Mall site, and contains no information about a specific development affordable to lower income households that has been approved for the site. As such, the City has not demonstrated that this site should be considered for affordable housing, and certainly not to the tune of 808 units, or 40% of the total.

The estimated affordability of the project is not justified by the analysis provided.

If the City were to reasonably extrapolate from their track record of large site development, they would note that their percentage of affordable units delivered is much lower than 40% - closer to 10%. This would suggest that Hillsdale Mall could more reasonably expect 202 affordable units.

They would also note that Station Park Green took 15 years to move from planning to completion, and Bay Meadows took 30 years. Hillsdale could reasonably be expected to land somewhere in between these two durations and so only about a third of the units would reasonably be delivered in the 6th cycle - 67 units.

The Hillsdale Mall site also includes, among the 40 total acres, approximately 11 acres that were recently redeveloped and re-opened in late 2019. Records show the owner obtained a $240 million dollar construction loan for this work 18 . It is not reasonable to assume that this investment would be demolished to make way for housing. HCD’s guidance states 19 that for non-vacant sites, existing uses must be considered:

For example, an analysis might describe an identified site as being developed with a 1960’s strip commercial center with few tenants and expiring leases and, therefore, a good candidate for redevelopment, versus a site containing a newly opened retail center, an active Home Depot, the only grocery store in the city, etc. that is unlikely to be available for residential development within the planning period.

Therefore, this 11-acre portion should be excluded from the site inventory. When the overall site is thus reduced by 27%, the affordable unit count would proportionally drop - from a realistic 67 units delivered in the next cycle down to 49.
1900 S. Norfolk St
The City’s inventory describes this as a 1983 Class-B office building, and assigns it 245 units over 8.18 acres at 30 units per acre (including 99 affordable units). However, a cursory review 19 Site Inventory Guidebook, page 25.
18 https://pe-insights.com/news/2022/01/05/northwood-investors-paid-257m-to-purchase-an-interest-in-ma ll-asset/
17 Compiled City data through 2020, RHNA annual reporting 733 of 955
of the assessor’s map reveals that the site is a “U” shape, wrapping around a PG&E substation with another corner carved off. This unconventional shape will reduce its effective density.

Moreover, it contains an easement in PG&E’s favor running across the site that further encumbers its development. As mentioned above, it is also within 500’ of the intersection of Highway 101 and SR-92. These constraints, taken together, make this site unlikely to be developed.
2208 Bridgepoint Parkway
The City’s inventory describes this as a vacant restaurant site, and assigns it 5 units over 0.37 acres at 13.5 units per acre. As a small site there are no affordable units. However, this site is not vacant; a restaurant, Lazy Dog Restaurant & Bar, is under construction and is slated to open in early May 20 . It is unlikely this brand new use will be discontinued in the next 8 years. 2210 Bridgepoint Parkway
The City’s inventory describes this as a Hallmark retail store, and assigns it 5 units over 0.33 acres at 15.2 units per acre. As a small site there are no affordable units. This site is currently under construction and will open as a restaurant, California Fish Grill 21 . It is unlikely this brand new use will be discontinued in the next 8 years.
1900 Fashion Island Blvd
This site is owned by Target and it has come to our attention that James Tucker, Senior Director for Real Estate, has submitted a letter indicating that Target has no plans to change the use of their store in San Mateo. They also explained that the owners of the individual sites that comprise Bridgepoint Shopping Center are under an agreement governing the use of the sites.

They did not share details, but explained that generally agreements of this type for shopping center do provide owners with site controls as to site design and uses. 71-77 Bovet Road
This site is currently developed as the “Borel Square” shopping center. It is our understanding that the owner is interested in developing but that the tenants do not wish to leave. The owner has offered “buyouts” to the tenants to break their leases but to date they have all refused. We understand the CVS and 24 Hour Fitness have long term (30 year) leases and at least one other tenant has 7 years remaining on their lease with an option to extend for another 10 years at market rate. Given the tenant opposition to discontinuing their uses, it seems unlikely this site will be developed within the next 8 years.

Please address the issues raised our original letter in order to identify enough sites and commit to an appropriate program of rezoning and constraint removal in a manner that is consistent with 21 https://www.cafishgrill.com/pages/san-mateo
20 https://www.smdailyjournal.com/news/local/lazy-dog-restaurant-opening-in-san-mateo/article_7a53bf46- 9b7a-11ec-9577-33f27fd5aefd.html
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your duty to affirmatively further fair housing and such that the actual capacity of the Sites Inventory over the next eight years meets or exceeds your RHNA.

The housing crisis is a regional problem, and our cities must work together to solve it. Thank you for your time and consideration,

Campaign for Fair Housing Elements

Peninsula for Everyone
735 of 955
1 From: Housing
Sent: Friday, April 22, 2022 9:02 AM
To:

Subject: FW: Online Form Submittal: Draft 2023-2031 Housing Element Comment Form

From: [email protected] <[email protected]>
Sent: Thursday, April 21, 2022 9:25 PM
To: Housing <[email protected]>
Subject: Online Form Submittal: Draft 2023‐2031 Housing Element Comment Form

Draft 2023-2031 Housing Element Comment Form

Draft Housing Element Feedback Form
Please share your comments regarding the Draft Housing Element.

Comment period for the draft document is April 6 through May 6, 2022.

First Name David
Last Name Karp
Email Address
Comment on 2023‐2031
Draft Housing Element
Typical developer slop.

Email not displaying correctly? View it in your browser.

736 of 955
1 From: Housing
Sent: Monday, April 25, 2022 2:55 PM
To:

Subject: FW: Online Form Submittal: Draft 2023-2031 Housing Element Comment Form

From: [email protected] <[email protected]>
Sent: Sunday, April 24, 2022 9:57 PM
To: Housing <[email protected]>
Subject: Online Form Submittal: Draft 2023‐2031 Housing Element Comment Form

Draft 2023-2031 Housing Element Comment Form

Draft Housing Element Feedback Form
Please share your comments regarding the Draft Housing Element.

Comment period for the draft document is April 6 through May 6, 2022.

First Name Kailun
Last Name Wu
Email Address
Comment on 2023‐2031
Draft Housing Element
Hello San Mateo city planners,

A little bit about myself: I first moved here in 2015 and then bought a house in Hillsdale in 2019. I'm married and work full time. I do not speak on behalf of any political organization or government.

To me San Mateo is unique. It's connected to SF and South Bay, ocean and redwood forests. Perfect weather all year.

Diverse population. The downtown is a rare walkable gem.

Strong economy. Most cities in the world would dream of these resources.

And yet I know how impossible it is for younger generations to buy a home. I feel it. Everyone in an open house knows it.

There’s simply not much available within budget on Redfin. I’m deeply worried that the city is becoming too exclusive and rich so I started followin
g the city planning meetings. The new
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2 general plan is very encouraging and I hope we all work together to keep the momentum.

My thoughts on the housing elements:

1. Re-zone for medium density or missing middle wherever possible. We should model after Germany and Netherlands. 4- 6 stories will be both dense and not too towering.

2. Re-zone for mixed use blocks. Make homes close to offices and groceries and restaurants and vice versa so that residents don't have to drive (because of the distance). Otherwise people will again reach for cars and cause congestion, making it even harder to up-zone.

3. Encourage the city to connect to the majority of people who aren’t in the public hearings. Most people aren't aware of city planning and are too tired from work, from school, from parenting. Yet they are the silent majority who will be impacted.

Every idea is flawed and implementation is flawed too. But stagnation will only make our city more exclusive and
unsustainable. Thank you so much for your hard work. San Mateo with more new homes will only match and strengthen our values. The current and future generations will live in what we choose to zone build.

Regards,
Kai

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738 of 955
sierraclub.org/loma-prieta ~

SAN MATEO, SANTA CLARA & SAN BENITO COUNTIES
April 26, 2022
City of San Mateo City Council
330 West 20th Avenue
San Mateo, CA 94403

Subject: San Mateo 2023-2031 Housing Element - Draft
Dear Mayor Bonilla and Members of the San Mateo City Council and Planning Commission, The Sustainable Land Use Committee of the Loma Prieta Chapter of the Sierra Club (SLU) advocates on land use issues in San Mateo and Santa Clara Counties. Thank you for providing the opportunity for SLU to provide input on the Draft San Mateo 2023-2031 Housing Element.

The overall draft Housing Element (HE) is a good start, but more focused and stronger policies and programs are needed to have a reasonable expectation of meeting the RHNA number of 7,015 new housing units, particularly for affordable units.

Reaching the RHNA unit goal will require major changes in the speed of development in San Mateo. In order to reach the goal of 7,015 new units from 2023-2031, the city must add almost 900 new units each year. That is roughly the equivalent of building a new Concar Passage each year1. This will be infeasible unless a major effort is made to streamline and accelerate housing development. And, of course, it is important that new development also be thoughtfully designed to accomplish all the other General Plan goals of open space, quality of neighborhoods, etc. The HE Housing Plan (p.H-55 to H-74) needs to demonstrate a significant change to current policies and programs in order to realistically be able to reach the goal. This will not be easy, as the new RHNA goals are well above the rate of new housing added over the last few decades2. But it must be done if we are to adequately address the housing crisis in the region and leave the city well positioned for future generations to prosper.

The HE rightly points out that the housing problem is a regional one and that each city needs to meet or exceed its goal if the housing crisis, particularly for affordable housing, is to be solved. The lack of affordable housing on the Peninsula is a significant contributor to environmental degradation as workers must commute long distances by car, emitting GHG as well as other pollutants. It also leads to sprawl as more development is done in areas that were open space or agricultural land.

There are specific areas that will need to be retained or expanded to make sure the final HE contains the key actions needed to make significant progress on addressing the enormous lack of affordable housing

1 Concar Passage is the largest housing project approved in recent years and required major time and effort for approval. Developing a project like this each year, will therefore require a major effort above the current processes.
2 The 2015-2022 RHNA was 3,164 units and with only one year left it has 2,573 units completed. This current RHNA number is less than half the new RHNA number; thus, demonstrating the steep challenge of meeting the new RHNA number of 7,015.

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sierraclub.org/loma-prieta ~
in the Bay Area. Listed below are the most important goals, policies and programs in the draft HE that need to be retained and strengthened in the final HE.

1. The HE aims for a 56% buffer above the RHNA. This is a minimum, but perhaps a higher number should be considered as the ability to actually build out housing has proven, over time, to be very difficult.

2. Increasing affordable housing is emphasized in the draft HE and that is good. But the “buffers” for affordable housing levels are only 14%, 55% and 37%, while the buffer for market rate housing is 87%. The percentage buffer for affordable units should be at least as high as the buffer for market units since affordable units are needed more and are harder to develop. The affordable housing should be more strongly focused on low, very low and extremely low-income housing, as these are where the largest needs are and where the lack of inventory is the largest.

The very poor jobs/housing fit3 in the Peninsula can best be addressed with a focus on more affordable housing. As noted in the HE draft4, the lack of affordable housing was one of the major concerns expressed by the public.

3. Funding that can be used to support affordable housing is a fundamental need and more must be done to obtain funding. Affordable housing has to be subsidized and a lack of funding will limit the ability to build the needed affordable housing, particularly for low and very low-income units. This could include establishing or increasing: Vacancy Tax, Commercial Linkage Fees, and Transfer Tax. It is particularly important that funding focus on repairing the legacy of discrimination in housing for groups like African Americans. The following policies and programs should be strengthened to accomplish this goal:
a. H 1.2 - Utilize Public Funding for Low/Moderate Income Housing b. H 1.3 - Increase Below Market Rate Unit Production through Density Bonus/Community Benefits Programs
c. H 1.18 – Fee Schedule Review
d. H 3.3 - Evaluate Housing Revenue Sources
e. H 5.1.1 - Adjust the City's Below Market Rate (inclusionary) program to provide larger density bonuses, and/or increased city support in exchange for affordable units that address the needs of residents with disproportionate housing needs f. H 5.1.2 - Participate in a regional down payment assistance program with affirmative marketing to households with disproportionate housing needs including persons with disabilities, single parents, and Hispanic households
g. H 5.1.3 - Support the design of a regional forgivable loan program for homeowners to construct an ADU that is held affordable for extremely low-income households for 15 years

4. In addition to increased funding for affordable units, the HE should prioritize policies and programs that reduce costs and streamline the processes for affordable units. The following policies and programs should be strengthened to accomplish this need:

3 Jobs/Housing Fit: Jobs/housing fit means that the majority of homes within the city are affordable to the majority of employees who work in the city, and conversely, the jobs in the city pay enough to cover the cost of housing in the city. Without an adequate jobs/housing fit, businesses find it difficult to hire and retain lower-income employees.
4 Page H-43
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sierraclub.org/loma-prieta ~
a. H 1.6 - Streamline Housing Application Review
b. H 1.8 - Adopt Objective Design Standards
c. H 1.9 - Create Minimum Densities for Mixed-Use Residential Projects d. H 1.10 - Establish By-Right Housing Designation for Prior Housing Sites e. H 1.12 - Encourage Residential Uses within Housing Overlay

5. Almost the entire city, including R1 areas, will need to contribute to the increased housing through such mechanisms as expanded Missing Middle Units (duplex, triplex and fourplex) and ADUs and, possibly, new mechanisms enabling multi-unit housing on properties with a Residential Neighborhood General Plan land use designation, which generally covers single-family neighborhoods. Increased density should be focused within half mile of transit to align with Climate Action Plan goals for greenhouse gas reductions.

The Climate Action Plan requires attention to creating easy pedestrian and bicycle access to reduce greenhouse gas emissions (GHG). Therefore, while it is important to retain this broad opportunity for more housing, since R1 is a major part of the total area of the city, it is important to keep in mind that creating easy pedestrian and bicycle access to amenities and to transit is a critically important goal for the Climate Action Plan.

The “15-minute Neighborhood” 5 6 concept needs to be included in the General Plan, along with the Housing Element, as it would facilitate creating more housing in R1 neighborhoods while simultaneously reducing GHG. This is a mechanism that would insert community amenities, such as small neighborhood retail nodes, into otherwise auto-dominated areas such as R1 neighborhoods.

Even more priority should be placed on these efforts. The following policies and programs should be strengthened to accomplish this need:

a. H 1.4 - Incentivize Accessory Dwelling Units Development with streamlined approvals, development subsidies, or low or zero interest loans for construction cost b. H1 11 Consider how Opportunity Housing can be useful to create new housing in R1 neighborhoods within 1/2 mile of the transit corridors
c. H1-13- Encourage Development of Missing Middle Housing especially within a half mile of transit.
d. Include overlay zoning, in the General Plan, for “15-minute Neighborhoods” allowing insertion of small new neighborhood retail nodes with Green Streets network 7 to create walkable bikeable neighborhoods, with the daily amenities, to reduce auto trips and create healthier walkable neighborhoods, convenient for all ages including kids and seniors.

5 15-minute neighborhoods are being created in many cities especially post-COVID. https://www.strongtowns.org/journal/2019/9/6/7-rules-for-creating-15-minute-neighborhoods ) 6 Embraced by Mayors around the world, Portland and several small US cities have embraced the concept to rebuild their economies while creating healthier cities. https://en.wikipedia.org/wiki/15-minute_city 7 How to insert a Green Street network into an existing City. Sierra Club Loma Prieta https://www.sierraclub.org/sites/www.sierraclub.org/files/sce- authors/u4142/Green%20Streets%20Presentation%20-%201-20-21%20DC.pdf 741 of 955
sierraclub.org/loma-prieta ~

5. Climate Change is real. 8No mention is made of how housing, particularly new housing, needs to be located so as to be resilient to climate change. Sea levels are predictably going to rise more swiftly in the coming decades, according to the California Ocean Protection Council. 9 Wildfires are also predicted to become an increased threat with the continued drought and encroachment into the forested hill areas of our city. The increased risks of sea level rise (SLR) near the Bay and wildfires in the hilly areas needs to be factored into identifying areas for higher density and more affordable housing.

We ask that you consider this information as you finalize the Housing Element for submission to the State. SLU is prepared to help the City in advancing the HE as it is finalized and when it goes into effect.

Respectfully submitted,

Gita Dev, Co-Chair
Sustainable Land Use Committee
Sierra Club Loma Prieta

Cc: James Eggers
Executive Director
Loma Prieta Chapter Sierra Club

Gladwyn d’Souza
Conservation Committee Chair
Loma Prieta Chapter Sierra Club

8 Ocean Protection Council- Sea Level Rise Guidance: The rate at which sea levels will rise can help inform the planning and implementation timelines of state and local adaptation efforts. Understanding the speed at which sea level is rising can provide context for planning decisions and establish thresholds for action… https://opc.ca.gov/webmaster/ftp/pdf/agenda_items/20180314/Item3_Exhibit-A_OPC_SLR_Guidance-rd3.pdf 742 of 955
1 From: Housing
Sent: Wednesday, April 27, 2022 9:17 AM
To:

Subject: FW: Online Form Submittal: Draft 2023-2031 Housing Element Comment Form

From: [email protected] <[email protected]>
Sent: Tuesday, April 26, 2022 11:22 AM
To: Housing <[email protected]>
Subject: Online Form Submittal: Draft 2023‐2031 Housing Element Comment Form

Draft 2023-2031 Housing Element Comment Form

Draft Housing Element Feedback Form
Please share your comments regarding the Draft Housing Element.

Comment period for the draft document is April 6 through May 6, 2022.

First Name Larry
Last Name Garnick
Email Address
Comment on 2023‐2031
Draft Housing Element
I am a single family home owner at and have
been a resident of San Mateo for 30 years. I believe San Mateo is already too congested and the City should not pursue a plan for population or housing growth. The City’s proposed growth plans are frightening.

Email not displaying correctly? View it in your browser.

743 of 955
1 From: Housing
Sent: Wednesday, April 27, 2022 9:16 AM
To:

Subject: FW: Online Form Submittal: Draft 2023-2031 Housing Element Comment Form

From: [email protected] <[email protected]>
Sent: Tuesday, April 26, 2022 1:20 PM
To: Housing <[email protected]>
Subject: Online Form Submittal: Draft 2023‐2031 Housing Element Comment Form

Draft 2023-2031 Housing Element Comment Form

Draft Housing Element Feedback Form
Please share your comments regarding the Draft Housing Element.

Comment period for the draft document is April 6 through May 6, 2022.

First Name John
Last Name Tastor
Email Address
Comment on 2023‐2031
Draft Housing Element
It appears thatthe 25th Avenue corridor between El Camino and Hacienda has been eliminated. The Study Zone did
include the First Presbyterian church parking lot on the NW corner of 25th & Hacienda. There is strong interest in our congregation to build approximately 70 low-income Senior Apartments on this parcel as well as 190 West 25th. We would appreciate consideration of these parcels as potential sites for residential development.

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744 of 955
1 From: Housing
Sent: Thursday, April 28, 2022 11:33 AM
To:

Subject: FW: Online Form Submittal: Draft 2023-2031 Housing Element Comment Form

Administra
tive Tech| Housing
330 W. 20th Ave., San Mateo, CA 94403
650‐522‐7239|

From: norep
[email protected] <[email protected]>
Sent: Thursday, April 28, 2022 11:19 AM
To: Housing <[email protected]>
Subject: Online Form Submittal: Draft 2023‐2031 Housing Element Comment Form

Draft 2023-2031 Housing Element Comment Form

Draft Housing Element Feedback Form
Please share your comments regarding the Draft Housing Element.

Comment period for the draft document is April 6 through May 6, 2022.

First Name Annonymous
Last Name Annonymous
Email Address
Comment on 2023‐2031
Draft Housing Element
Hello,

I want to show my support for a Housing Element that respects the single family home neighborhoods in the the City of San Mateo. As a long time resident and voter, the collected voice 745 of 955
2 should be heard. We said yes to measure Y and we do not want our single family neighborhoods zoning changed. I moved to San Mateo to live in a quiet neighborhood and scrounged and saved to realize the dream of owning a home. I feel your Planning Commissioners are not listening to the voice of the community and clearly have their own agenda and are out of touch. It does not go unnoticed that your two newest
commissioners are more interested in proceeding on their own agenda than do what is best for all areas of San Mateo. I think the Planning Commission need to listen to real people and stop taking their lead from developers and their own misguided agendas.

Email not displaying correctly? View it in your browser.

746 of 955
1 From:

Sent: Thursday, April 28, 2022 3:23 PM
To:

Subject: Fwd: Planning Commission Regular Meeting
Follow Up Flag: Follow up
Flag Status: Flagged
Hi Nicky,
A comment for housing element to add.

Mary

Begin forwarded message:

From:

Date: April 28, 2022 at 2:15:03 PM PDT
To:

Subject: FW: Planning Commission Regular Meeting

City Clerk | City of San Mateo
330 W. 20th Ave., San Mateo, CA 94403
650‐522‐7042 |

From: Chris C
onway
Sent: Thursday, April 28, 2022 10:54 AM
To: City Council (San Mateo) <[email protected]> Subject: Planning Commission Regular Meeting

My inquiry to the San Mateo City Council is how was the selection of Diana Elrod as San Mateo’s consultant in the Planning Commission Regular meeting 04.26.22 determined and who made the selection? I would like to know what this consultant to San Mateo is being paid for work and why a consultant as left leaning as this person (they/them) was selected. It seems they/them is a fellow Columbia University alumnus like one of our very own council people (gender neutral to avoid offending anyone). This person’s views can easily be seen by reviewing who they/them advocate for.

Also, a request went out for more feedback on Housing Element and development within our city. Why does the city council continue to ask for more feedback when they do not listen to anyone unless they share their same progressive housing policies? It is much too late to try to spin this entire process as anything less than fair, honest and transparent. It is a complete sham to those who actually follow this convoluted procedure and actually know who our council members actually are and what they support.

Sad to see what the city council of San Mateo has turned into what it has done to divide our city into sections based on race and wealth. The racial undertones of comments by the city council, contributors and consultants are enough to anger many residents who have lived in and contributed much more to 747 of 955
2 this city than all of you. Stop ruining San Mateo, you had no part in creating or developing this city to what it is today.

Time to set policy in front of voters instead of behind your screens. End this very undemocratic process of conducting council meetings via Zoom. Face your constituents, or are you too timid to do that.

Chris Conway
San Mateo, Ca.

748 of 955
1 From: Housing
Sent: Thursday, May 5, 2022 4:02 PM
To:

Subject: FW: Housing Element Comment

From: Thomas Morgan II
Sent: Thursday, May 5, 2022 3:18 PM
To: Housing <[email protected]>
Subject: Housing Element Comment

The screenshot below is the problem with simply upzoning and the loss of local control, it simply drives up the cost of the land, after shelling out the asking price I am not sure how the new owner will make an already tight project pencil out.

Thank you,

Thomas Morgan

749 of 955
1 From: Housing
Sent: Thursday, May 5, 2022 4:03 PM
To:

Subject: FW: Online Form Submittal: Draft 2023-2031 Housing Element Comment Form

From: [email protected] <[email protected]>
Sent: Thursday, May 5, 2022 3:15 PM
To: Housing <[email protected]>
Subject: Online Form Submittal: Draft 2023‐2031 Housing Element Comment Form

Draft 2023-2031 Housing Element Comment Form

Draft Housing Element Feedback Form
Please share your comments regarding the Draft Housing Element.

Comment period for the draft document is April 6 through May 6, 2022.

First Name Ellen
Last Name Wang
Email Address
Comment on 2023‐2031
Draft Housing Element
Slow Growth is the key.

None of us knows what the future will bring.

Take an Objective look at housing from a multi-view approach.

California population is decreasing.

Coronavirus and technology has provided opportunities for workers to work from anywhere with no need to live near their old job site.

Dense housing has a Negative Impact on schools, police, recreation.

I do not want to walk by half-vacant high-rise housing or office buildings that block the sun.

Email not displaying correctly? View it in your browser.

750 of 955
1 From: Housing
Sent: Friday, May 6, 2022 8:27 AM
To:

Subject: FW: Online Form Submittal: Draft 2023-2031 Housing Element Comment Form

From: [email protected] <[email protected]>
Sent: Thursday, May 5, 2022 8:11 PM
To: Housing <[email protected]>
Subject: Online Form Submittal: Draft 2023‐2031 Housing Element Comment Form

Draft 2023-2031 Housing Element Comment Form

Draft Housing Element Feedback Form
Please share your comments regarding the Draft Housing Element.

Comment period for the draft document is April 6 through May 6, 2022.

First Name T
Last Name S
Email Address
Comment on 2023‐2031
Draft Housing Element
“While some people voiced their interest in up zoning single- family neighborhoods or eliminating them altogether, other homeowners want to protect them and are concerned with the future of investments they have made.”

I’d like to better understand who wants to re-zone or—more worrying—eliminate single-family housing here. “Upzoning” is an adorable word for “kicking people out of their homes to cram more people onto the land.” Are these people even San Mateo residents? The “no more housing” ship has sailed, so it’s not with any one’s energy to complain about more building; please, then, focus on sites that can be updated and REALISTICALLY adapted to include more housing. This would, therefore, include locations closer to mass transit.

Building on Campus Drive sounds like a nightmare to me, because public transportation is currently miserable in that area, and the 92/West Hillsdale interchan
ge can be horrific
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2 traffic-wise. If building must be done there, then the public transportation issue ALSO has to be addressed.

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752 of 955
1 From: Housing
Sent: Friday, May 6, 2022 4:58 PM
To:

Subject: FW: Housing Element
Attachments: Attachment A City of San Mateo Housing Element Comments for Developmental Disabilities

12.21.21.pdf; San Mateo Draft Housing Element Comments.pdf; Attachment B City of San Mateo Housing Element Comments for Developmental Disabilities 2.10.22.pdf

From: Kalisha Webster
Sent: Friday, May 6, 2022 3:21 PM
To: Housing <[email protected]>
Cc: Jan Stokley
Subject: Housing Element

Please find attached Housing Choices' comments on the City of San Mateo 2023‐2031 Housing Element Draft including Attachments A & B. We hope that the city will make meaningful changes to the analysis of housing needs of people with developmental disabilities and Fair Housing Assessment, as well as, further develop policies and programs which will meet the needs of Extremely Low Income households and increase housing accessibility for people with developmental disabilities in the next draft.

Thank you,

We have moved! Please note the new office address!
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May 6, 2022
Planning Manager and City CouncilCity of San Mateo, Planning Division330 West 20th AvenueSan Mateo, CA 94403 [email protected]:Comments on the Draft Housing Element Thank you for sharing this early draft of the Housing Element with the public. On behalf of SanMateo’s more than 800 residents with intellectual and developmental disabilities, HousingChoices is grateful for the opportunity to comment before it is sent to HCD. We also appreciatethe work that the City of San Mateo has done to engage with Housing Choices throughout thecommunity engagement process and consider the programs and policies that we haverecommended as best practices for inclusion of people of all abilities in the city’s future housingplans. However, we have concerns thatthe assessmentof the housing needs of the San Mateopopulation with developmental disabilities in the draft Housing Element is very superficial anddoes not provide enough analysis to support meaningful inclusion of people with developmentaldisabilities in the city’s housing plans. We also ask that the city immediately update the obsoleteand derogatory language used to describe developmental disabilities as including mild to severe“mental retardation” on page H-A-55 of Appendix A-Needs Analysis and instead use thestandard term “intellectual disability”.

About Housing Choices
Housing Choices is a housing organization funded by the Golden Gate Regional Center tosupport people with developmental disabilities to be fully integrated in San Mateo’s affordablehousing supply. We provide housing navigation services for both individuals and families. Wealso partner with affordable housing developers to make inclusive housing commitments forpeople with disabilities in their housing projects. At these projects we provide onsite housingretention services. A San Mateo example of this highly successful model is the new KikuCrossing where 8 of the 225 units will include a preference for people with developmentaldisabilities who will benefit from Housing Choices’ coordinated supportive services funded bythe Golden Gate Regional Center. TheGolden Gate Regional Center has contracted with 1 754 of 955
Housing Choices to provide the San Mateo planning staff and Housing Element consultants withan assessment of the housing needs of people with developmental disabilities, as required bySB 812. In addition, 21 Elements has facilitated Housing Choices’ involvement of people withdevelopmental disabilities in the planning process through its Equity Advisory Group.

Incomplete Assessment of Housing Needs of People with Developmental Disabilities On December 2, 2021, Housing Choices submitted an assessment of the housing needs of SanMateo residents with developmental disabilities (Attachment 1) which followed HCD guidancefor a complete analysis of special housing needs groups, including:
● A quantification of the total number of persons and households in the special housingneeds group, including tenure (rental or ownership), where possible.● A quantification and qualitative description of the need (including a description of thepotential housing problems faced by the special needs groups), a description of anyexisting resources or programs, and an assessment of unmet needs.● Identification of potential program or policy options and resources to address the need After receiving feedback on our comments from City staff Housing Choices submitted revisedcomments on February 10, 2022 (Attachment 2).

As discussed below, San Mateo’s draft does not incorporate any of the Housing Choices’ dataand analysis, does not meaningfully discuss the potential housing problems, unmet needs orbest practices for inclusion of people with developmental disabilities in integrated and leastrestrictive housing settings in the community. We believe that the inclusion of these missingelements would demonstrate that the city has a clear understanding of the accessibility needs ofpeople with developmental disabilities and how they differ from other disability types.Furthermore it would help the city to create more meaningful programs and policies to meet thehousing needs of residents with developmental disabilities as required by Housing Element law.

Underestimation of the San Mateo Population with Developmental Disabilities The draft analysis undercounts the population of San Mateo residents with developmentaldisabilities by using outdated demographic data reported by the Department of DevelopmentalServices (DDS) as of 2020 rather than the more current data from DDS as of September 2021provided in Housing Choices comments. On page H-A-56 of Appendix A- Needs Analysis, Table12 states that there are500 individuals age 18+and277 individuals under age 18withdevelopmental disabilities living in San Mateo based on Department of Developmental Services2020 data of consumer counts by zip code for a total of 777 San Mateo residents withdevelopmental disabilities. However, based on data reported by DDS by zip code as ofSeptember 2021 for zip codes 94401, 94402 and 94403 (provided to us by the City of SanMateo planning staff) there were531 individuals age18+and304 individuals under age 18with developmental disabilities living in San Mateo for a total of 835 San Mateo residents with 2 755 of 955
developmental disabilities. This represents an increase of 58 total residents or 7% of thepopulation.

In contrast, on page H-A-57, Table 13 reports a total population of 784 San Mateo residents withdevelopmental disabilities. This is most likely attributable to an error in the reporting ofindividuals living in Foster/ Family Homes and Other living arrangements which are bothreported by DDS as <11 but in Table 13 are both reported as 10.

Failure to Provide Data Establishing Trends Creating a Greater Need for Housing As mentioned above, Table 13 does report the population of San Mateo residents withdevelopmental disabilities by residence however, because it fails to report residence type foradults separately from that of children and because it omits a comparison to data reported in the2015 Housing Element important trends about the changing housing needs of San Mateoresidents with developmental disabilities is missing from this analysis. When looking at theresidence type of only adults aged 18+ we see that the greatest housing provider for adults withdevelopmental disabilities in the City of San Mateo is licensed care facilities (includingCommunity and Intermediate Care Facilities). As of 2021 50% of all adults with developmentaldisabilities in the City of San Mateo are housing in licensed care facilities, significantly higherthan the 32% of adults across all San Mateo County jurisdictions. Yet, when comparing this datato what was last reported in the 2015 Housing Element we find that despite an overall increasein the total population there has been a net decrease in the number of adults withdevelopmental disabilities transitioning into licensed care facilities or into their own apartmentwith supportive services during this time period.

The decrease of adults transitioning into licensed care facilities reflects data from DDS, andwhich was reported in Housing Choices comments to city staff, that San Mateo County hasexperienced a loss of 5% of its supply of community care facilities, a large number of which arelocated in the City of San Mateo. Data on increased life spans of people with developmentaldisabilities, which is also omitted from the Housing Element, compounds the loss of supply byincreasing turnover of beds available in the remaining licensed care facilities. Coupled with thedecline in adults living in their own apartments with supportive services, this data demonstratesthat the city must do more to meet the housing needs of people with developmental disabilitiesby increasing access to integrated affordable housing to prevent them from falling intohomelessness or being displaced after the death of a parental home provider.

Other data which Housing Choices’ comments reported on which are vital to an understandingof the barriers to housing access for this special needs population that were omitted from theHousing Element analysis are:1. Continuing increases in the diagnosis of autism affecting growth of the population of SanMateo residents with developmental disabilities (21% increase from 2013-2021) beyondthat of the general population (6% increase from 2010-2020)2. Decreases in age groups 42-61 despite increases in all other age groups including 62+which Housing Choices attributes to greater risk of displacement from the home 3 756 of 955
community among this age group upon the death or infirmity of the parent who wasproviding housing Lack of Meaningful Analysis of Strategies to Increase Housing Access for People withDevelopmental Disabilities The Housing Element acknowledges the significance of the transition from the family home foran adult with a developmental disability including the increased risk of displacement orhomelessness when a parent caregiver passes away or becomes unable to house and care forthe adult. There are also basic descriptions of the alternative housing options available topeople with developmental disabilities including:
● Living independently in conventional housing● Group living (including different levels of care and support) However, there is no further analysis of the housing needs of people with developmentaldisabilities beyond a single sentence on page H-A-55 which states “Some people withdevelopmental disabilities are unable to work, rely on Supplemental Security Income and livewith family members. By not including information, provided by Housing Choices, on bestpractices for inclusion of people with developmental disabilities in conventional affordablehousing, the city is unable to create meaningful strategies to increase housing accessibility forthis population needed to decrease the risk of displacement or homelessness when their familyhome is no longer an option. These best practices to increase accessibility include:
● Integration in typical affordable housingin orderto affirmatively further fair housingfor a group that has historically experienced no alternatives to segregated living and tocounter the loss of supply of licensed care facilities● Coordination of housing with onsite supportive servicesfunded by the Golden GateRegional Center should be encouraged. These fully funded coordinated services areoften as essential to a person with a developmental disability as a physically modifiedunit is to a person with a mobility, vision, or hearing impairment and provide a supportedpathway for people with developmental disabilities to apply for and retain an affordableapartment● A mix of unit sizes set-aside at inclusive housing propertieswould address theneeds of those who require live-in aides, want to live with roommates or partners, orhave children.● Location near public transitwould accommodate thetransit-dependency of mostadults with developmental disabilities.● Deeply affordable housingis needed, targeting incomesnot more than 30% of AreaMedian Income and taking advantage of Housing Authority Project Based Vouchers orHUD 811 Project Rental Assistance when available to create housing opportunities forthose who cannot meet minimum income requirements for units priced at 30% of AreaMedian Income. 4 757 of 955
‘Without this complete analysis of the housing needs of people with developmental disabilitiesany programs or policies aimed at increasing “accessible units” will be discriminatory in natureas they apply only to people with physical disabilities needing physically modified units and notto people of other abilities who may requireservicesto increase housing access. This is mostevident on page H-A-54 of Appendix A where accessible units are defined as designed to “offersgreater mobility and opportunity for independence” but makes no mention of the supportiveservices needed by people with other types of disabilities including developmental and mentalhealth disorders. This model of housing combined with supportive services has been shown tobe incredibly effective in helping individuals with developmental disabilities find and retainhousing, and is equally as important to a person with a developmental disability as the physicaldesign of a building is to a person with a physical disability. This also puts the city at risk of notmeeting HCD’s AFFH guidance to promote fair housing choice and access to opportunity tosupport integration for a historically segregated population. Per HCD guidance, “For personswith disabilities, fair housing choice and access to opportunity include access to accessiblehousing and housing in the most integrated setting appropriate to an individual’s needs asrequired under federal civil rights law, including equitably provided disability-related services thatan individual needs to live in such housing.” HCD defines fair housing choice as:● Actual choice, which means the existence of realistic housing options● Protected choice, which means housing that can be accessed without discrimination;and● Enabled choice, which means realistic access to sufficient information regarding optionsso that any choice is informed.

Need to Clarify How Programs and Policies Will Increase Housing Access For Peoplewith Developmental Disabilities We want to thank planning staff and the consultant who developed this draft for acknowledgingthe need for affordable housing to increase housing access for people with disabilities. This isespecially important for those whose sole source of income is from disability benefits such asSupplemental Security Income, which in 2022 has a maximum monthly payment of $1,040, wellbelow minimum income requirements for even the Extremely Low Income housing (30% of AMI)available in San Mateo. The lack of housing priced to be affordable to people of Extremely LowIncome does not only affect people with disabilities. According to the draft Housing Element,12.7% of all San Mateo households fall under the Extremely Low Income limits whichrepresents the second largest lower income group in the city, exceeded only by Low Incomehouseholds. And Figure 13 on page H-A-25 of Appendix A- Needs Analysis shows thatExtremely Low Income renters are the second largest proportion of San Mateo Rentersexceeded only by Above Moderate Income.

According to the HCD’s APR dashboard between 2015-2020 San Mateo met less than 15% ofits Very Low Income RHNA target (of which half are supposed to ELI). In order to address thisshortfall, the 2023-2031 draft housing element identified Policy 5.2.3: “Prioritize city fundingproposals for city funded affordable housing that are committed to serving hard to serveresidents (e.g., extremely low income, special needs, on site services)”. We strongly encourage 5 758 of 955
the city to go further in its commitment to meeting the need for more units of Extremely LowIncome housing by including proposals for city-owned land and land dedicated to affordablehousing under the inclusionary program to this Policy.

Secondly, people with developmental disabilities not only need deeply affordable housing, theyalso need housing that is coordinated with onsite supportive services funded by the GoldenGate Regional Center. In order to specifically address the housing needs of people withdevelopmental disabilities, San Mateo must clarify their definition of accessible/visitable units asreferenced in Policies 5.1.1 and most importantly 5.2.2 Incentivize developers through directsubsidies, fee waivers, and/or density bonuses, to increase accessibility requirements beyondthe federal requirement of 5% for subsidized developments. Currently, federal accessibilityrequirements only address the housing needs of people with physical disabilities. HousingChoices is extremely supportive of Policy 5.2.2 but asks that the city include incentivizinginclusion of units set aside for people with developmental disabilities who will benefit fromcoordinated on-site supportive services funded by the Golden Gate Regional Center to helpthem stay stably housed so that we do not continue to see decreases in the number of adultsable to transition into their own apartment.

Failure to Follow HCD Guidance for AFFH
Guidance from HCD for AFFH also recommends that jurisdictions complete an intersectionalanalysis of housing needs for people with disabilities as “there are significant disparities by racewithin the population with disabilities”. While there is data provided on the housing cost burdenof all San Mateo residents by race in the Assessment of Fair Housing there is no intersectionalanalysis which shows the compounding effects of being a person of color with a disability ascompared to a person of color without a disability or a white person with a disability. This is asignificant component of Housing Choices’ recommendations for Affirmatively Furthering FairHousing, and yet is omitted from the city’s draft.

Noncompliance with HCD Guidance for Completing an Assessment of Fair Housing In response to the passage of AB 686, HCD released the AFFH Data Viewer to support theoutreach and engagement jurisdictions are required to complete as part of their Assessment ofFair Housing. HCD explicitly states in their AFFH guidance that the Assessment of Fair Housingshould include local data and knowledge defined as “any locally gathered and availableinformation, such as a survey with a reasonable statistical validity or usefulness for identifyingcontributing factors, policies, and actions.” On page H-D-11 of Appendix D- AffirmativelyFurthering Fair Housing Narrative it is stated that a survey was administered to support the FairHousing Assessment which received 150 responses. In a city with a population of over 100,000residents this low of a response rate seems to indicate that the city did not complete the type ofrobust, targeted engagement required by HCD in administering the survey.

Reporting of data from the assessment also does not clearly show demographics of who wassurveyed to show the number of residents from special needs groups that are most likely to face 6 759 of 955
fair housing issues such as BIPOC populations, people with disabilities, female-headed households, the unhoused and others. For instance on page H-D-29 when discussing disparities specific to the disability community it is stated that “Of residents with a disability responding to the residents’ survey, 30% said that their home does not meet the needs of their household member.” However, there is no indication of how many of the 150 respondents indicated having a disability so it is not evident to the reader of this document if 25% is equivalent to 5, 10 or 40 responses. Nor is it clear if only people with physical disabilities were surveyed or this included people with other types of disabilities.

There also appears to be an over reliance on data from the AFFH data viewer in the Fair Housing Assessment. For instance on page H-D-14 there is an explanation of the different agencies to which Fair Housing Complaints can be reported including HUD, DFEH and local enforcement organizations including Project Sentinel, the Legal Aid Society of San Mateo County, and Community Legal Services of East Palo Alto. This section also explains that state Fair Housing Law covers protected classes beyond that of federal Fair Housing Law. Yet, demographics of Fair Housing complaints are only reported for HUD which received only 57 complaints for San Mateo County from 2017-2021. Whereas, data from Project Sentinel shows that they investigated nearly 300 Fair Housing discrimination cases in San Mateo County from 2015-2020. This does not include reports made to any of the other agencies listed. This would indicate that the draft housing element severely underestimates the number of Fair Housing complaints made in San Mateo County and City of San Mateo, and therefore cannot accurately gauge how well the city is doing in addressing Fair Housing issues.

We urge you to review the attached comments we submitted on December 2, 2021 and February 10, 2022 and make changes to the San Mateo Housing Element so that it meaningfully addresses the housing needs of its residents with developmental disabilities.

Sincerely,
Kalisha Webster
Senior Housing Advocate
Email
Cell
7 760 of 955

DEVELOPMENTAL DISABILITIES SUBMISSION FOR

CITY OF SAN MATEO HOUSING ELEMENT
Introduction to Developmental Disabilities
People with developmental disabilities have a disability that emerged before age 18, is expected to belifelong, and is of sufficient severity to require a coordinated program of services and support in order tolive successfully in the community. Developmental disabilities include intellectual disability, autism,Down syndrome, epilepsy, cerebral palsy, and other disabling conditions similar in their functional impactto an intellectual disability. Under California’s Developmental Disabilities Services Act and the U.S.Supreme Court’s 1999 decision inOlmstead v. L.C.,people with developmental disabilities are entitledtoreceive community-based services that allow them to live in the least restrictive community setting. Thisshift to de-institutionalization has led to the closure of the most restrictive segregated settings and tothe requirement that local jurisdictions in their Housing Elements assess and plan specifically for thehousing needs of people with developmental disabilities who receive services from the Regional Centerin order to live in their home community.

Demographic and Other Trends Affecting the Housing Needs of People withDevelopmental Disabilities The City of San Mateo Population with Developmental Disabilities Grew by 12% Since the Last HousingElement and Accounts for 21% of the County’s Total Population with Developmental Disabilities. TheCity of San Mateois home to835people with developmentaldisabilities (Table __). This represents anincrease of 12% over the 2013 population of 746 reported in the City’s 2015 Housing Element andreflects a much higher growth rate than the general population. In addition, the City’s population withdevelopmental disabilities accounts for 21% of the total County population with developmentaldisabilities, although the city’s total population is only 14% of the County’s total population.

Table ___ Comparison of the 2021 City and County Populations with Developmental Disabilities Age City of San Mateo County of San Mateo City of San Mateoas % of County Under age 18 304 1169 26%
18 and older 531 2764 19%
Total 835 3933 21%
Source: The City of San Mateo data is based on zip code level data for zip codes 94401, 94402, and 94403 published by the CaliforniaDepartment of Developmental Services as of September 30, 2021. County level data is published by the Department of Developmental Servicesas of June 30, 2021. Both sources exclude children from birth to the third birthday because approximately 75% of this age group is found noteligible for continuing lifelong services on their third birthday.

Decline in Living Arrangements for Adults with Developmental Disabilities Outside the Family Home.Of the City’s total population with developmental disabilities,531 (64%)are adults and304 (36%)are 1 761 of 955
under age 18 (Table __). Assessing the housing needs of adults with developmental disabilities is ofparticular importance because as they age the adults will require a residential option outside the familyhome, whereas the family home is the preferred living option for children with developmentaldisabilities. In 2021, 505 City of San Mateo residents with developmental disabilities lived in the familyhome compared to 389 in 2013 as reported in the 2015 to 2023 Housing Element. This 30% increase inreliance on the family home is 2.5 times greater than the City’s 12% increase in the developmentaldisabilities population during that same period. Increased reliance on the family home is primarilyexplained by overall growth in the population with developmental disabilities coupled with significantdeclines in opportunities for the City’s adults with developmental disabilities to live either in licensedcare facilities (11% decline) or in affordable housing with supportive services (11% decline). (Table __.)As adults with developmental disabilities age, they need opportunities to live outside the family homeboth because of the aging of their family caregivers and also because many adults with developmentaldisabilities would like to live in their own apartment with supportive services.

Table ___ Changes in Living Arrangements of Adults with Developmental Disabilities Living Arrangements
2013Number
2021Number
2021Percent of Total Adults % Change Since 2013
Total (children & adults) inthe Family Home 389 505 -- 30% Adults In the family home
Not reported-- seenote 201 38% --
Own apartment withsupportive services 64 52 10% -11%
Licensed Facilities 294 265 50% -11%
Other (including homeless) 7 13 2% .8%
Total Adults
Not reported--seenote 531 100% --
Note: The 2013 data are reported in the 2015 Housing Element, which failed to separately count those under 18 and those 18 and older, makingit difficult to estimate changes in the significance of the family home as a residential setting specifically for adults. The 2021 data are publishedat the zip code level by the California Department of Developmental Services as of September 30, 2021. These data assume that occupants oflicensed facilities are 18 and older which is generally true, but if incorrect this assumption would tend to understate, not overstate, the need forother housing options for adults with developmental disabilities.

Increase of Autism Diagnosis Reflected in Increase in Adults in their 20s and 30s. Growth in the CityofSan Mateo’s population with developmental disabilities since the 2015 Housing Element correlates witha significant annual increase in the diagnosis of autism that began in the mid-1980s and did not level outuntil after 2015. The cumulative impact of this trend is already seen in the growth in the San MateoCounty population age 18 to 41 with developmental disabilities and will continue into the future. Thistrend has significant implications for housing needs among City of San Mateo adults with developmentaldisabilities during the period of the 2023 to 2031 Housing Element. 2 762 of 955
Table __ Changes in Age Distribution of Adult Population in San Mateo County Age 2015 Number 2021 Number % Change
18 to 31 1023 1189 16%
32 to 41 397 457 15%
41 to 52 382 335 -12%
52 to 61 385 348 -10%
62 plus 327 435 33%
Total adults 2514 2764 10%
Source: County level data is published by the Department of Developmental Services as of June 30, 2021 and as of September 30, 2015.

Longer Life Spans. Between September 2015 and June2021, the California Department ofDevelopmental Services reports that the number of San Mateo County residents with developmentaldisabilities age 62 and older grew by 33% (Table __). This is not due to migration of senior citizens withdevelopmental disabilities to San Mateo County, but rather to well-documented gains in life span amongpeople with developmental disabilities. With longer life expectancy, more adults with developmentaldisabilities will outlive their parents and family members with whom a growing number of City of SanMateo adults with developmental disabilities now live because of the lack of other residential options.Longer life spans will also slow the pace of resident turnover in the county’s limited supply of licensedcare facilities, which will further reduce opportunities for the growing population of people withdevelopmental disabilities to secure housing outside the family home.

Decline in Licensed Care Facilities. The CaliforniaDepartment of Developmental Services reports thatbetween September 2015 and June 2021, San Mateo County lost 5% of its supply of licensed carefacilities for people with developmental disabilities (including Community Care Facilities, IntermediateCare Facilities, and Skilled Nursing Facilities), thereby increasing the need for affordable housing optionscoordinated with supportive services funded by the Regional Center. This trend is mirrored in the 11%decline in the number of City of San Mateo adults able to live in licensed care homes between 2013 and2021 (Table __). The reduced role of licensed care facilities demonstrates the need for the City’s HousingElement to plan for affordable housing that includes people with developmental disabilities so thatadults with developmental disabilities are not forced out of the county when they lose the security oftheir parent’s home.

Displacement. The California Department of DevelopmentalServices has documented a 12% decline inthe age group 42 to 51 and a 10% decline in the age group 52 to 61 in San Mateo County betweenSeptember 2015 and June 2021. (Table __). In light of gains in life expectancy, this loss can reasonably beattributed to homelessness or displacement from the county because of the lack of residential livingoptions (either licensed facilities or affordable housing) when an elderly parent caregiver passes away orbecomes unable to house and care for the adult. Displacement takes a particular toll on adults with 3 763 of 955
developmental disabilities who depend on familiarity with transit routes and shopping and services, aswell as support from community-based services and informal networks built up over years in living in theCity of San Mateo.

Higher Rates of Physical Disabilities. People withdevelopmental disabilities are more likely than thegeneral population to have an accompanying physical disability. Twenty-seven percent (27%) of SanMateo County residents with developmental disabilities have limited mobility, and 13% have a vision orhearing impairment. The need for an accessible unit coupled with the need for coordinated supportiveservices compounds the housing barriers faced by those with co-occurring intellectual and physicaldisabilities.

Ineligibility for Many Affordable Rental Units. Someadults with developmental disabilities depend onmonthly income of under $1,000 from the Supplemental Security Income (SSI) program, pricing themout of even the limited number of Extremely Low Income affordable housing units in the City of SanMateo. Those with employment tend to work part-time in the lowest paid jobs and also struggle toincome-qualify for many of the affordable housing units for rent in the City of San Mateo.

Transit-Dependent. Most adults with developmentaldisabilities do not drive or own a car and rely onpublic transit as a means to integration in the larger community.

Best Practices for Inclusion of People with Developmental Disabilities in TypicalAffordable Housing As demonstrated by a growing number of inclusive affordable housing developments in neighboringjurisdictions, the City of San Mateo can meet the housing needs of people with developmentaldisabilities by adopting policies and programs to promote their inclusion with coordinated services intypical affordable housing. The following considerations should guide the City of San Mateo in thispursuit:
● Integration in typical affordable housingis a priorityin order to affirmatively further fairhousing for a group that has historically experienced no alternatives to segregated living and alsoto counter the displacement of adults with developmental disabilities out of San Mateo County.● Coordination of housing with onsite supportive servicesfunded by the Golden Gate RegionalCenter should be encouraged. These fully funded coordinated services provide a supportedpathway for people with developmental disabilities to apply for and retain an affordableapartment and are often as essential to a person with a developmental disability as a physicallymodified unit is to a person with a mobility, vision, or hearing impairment.● A mix of unit sizesat inclusive housing propertieswould address the needs of those who requirelive-in aides, want to live with roommates or partners, or have children.● Location near public transitwould accommodate thetransit-dependency of most adults withdevelopmental disabilities.● Deeply affordable housing is needed,targeting incomesnot more than 30% of Area MedianIncome and taking advantage of Housing Authority Project Based Vouchers or HUD 811 Project 4 764 of 955
Rental Assistance when available to create housing opportunities for those who cannot meetminimum income requirements for units priced at 30% of Area Median Income.

Policy and Program Recommendations
The City of San Mateo has a responsibility not simply to assess the housing needs of people withdevelopmental disabilities but also to create policy, zoning, program and other changes that make itmore feasible for affordable housing developers to include people with developmental disabilities intheir housing in coordination with the supportive services available from the Golden Gate RegionalCenter. The City’s 2015 Housing Element identified a need for housing for an additional 30 to 87 peoplewith developmental disabilities, but the number of adults with developmental disabilities living in theirown apartment actually declined by 11% since the last Housing Element, even as the population grew by12%. The City’s lack of progress in meeting the housing needs of people with developmental disabilitiessince the last Housing Element demonstrates the need forpolicies and programs that specificallyincentivize inclusion of people with developmental disabilities in affordable housing with coordinatedservices provided by the Golden Gate Regional Center. ● Establish and monitor a quantitative goal.Trackingthe City’s success in housing people withdevelopmental disabilities is essential to determine whether policies and programs are having aneffect in overcoming historic patterns of discrimination and exclusion of people withdevelopmental disabilities from affordable housing. A goal of150 new Extremely Low-Incomehousing units forCity of San Mateoresidents withdevelopmental disabilities over the period ofthe 2023 Housing Element would represent meaningful progress towards the total unmethousing need of this special needs population.

Sample Language: The City of San Mateo shall monitor progress towards a quantitative goal of150 new Extremely Low Income housing units that are subject to a preference for people withdevelopmental disabilities needing the coordinated services provided by Golden Gate RegionalCenter to live inclusively in affordable housing. ● Target City-Owned Land, Land Dedicated to Affordable Housing under the InclusionaryOrdinance and City Housing Funds to Meet City-Specific Priorities. City-owned land, landdedicated to affordable housing in lieu of providing affordable units under the inclusionaryordinance, and city housing funds are often essential to the development of affordable housingthat is financially feasible in high-cost City of San Mateo. In creating guidelines for the scoring ofany competitive requests for proposals for these scarce resources, the City should grantadditional points to affordable housing projects that address the housing needs of City of SanMateo residents who are most difficult to house under existing state and federal housing financeprograms--for example, by prioritizing proposals with a higher number of extremely low incomeunits or that make a percentage of units subject to a preference for identified categories ofspecial needs people who would benefit from coordinated onsite services, including but notlimited to people with developmental disabilities who benefit from services of the Golden GateRegional Center. 5 765 of 955
Sample Language: In publishing requests for competitive proposals for any city-owned land, landdedicated to affordable housing under the city’s inclusionary ordinance or city housing funds, theCity of San Mateo shall grant additional points to proposals that address the city’s most difficultto achieve housing priorities, by, for example, providing a greater number of extremelylow-income units or committing to make a percentage of the units subject to a preference forpeople with special needs who will benefit from coordinated onsite services, such as people withdevelopmental disabilities who receive services from the Golden Gate Regional Center. ● Offer Developers a Range of Affordability Options Under the Inclusionary Ordinance. Mostadults with developmental disabilities have incomes too low to satisfy minimum incomerequirements for the Low Income units currently offered under the city’s inclusionary ordinanceand are effectively excluded from this housing option. California law (AB 1505, the “Palmer Fix”)explicitly allows cities to adopt inclusionary housing ordinances that address a range of incomelevels from moderate-income to extremely low-income. The City should take advantage of thisauthority to make its ordinance more responsive to local needs by offering developers of marketrate housing a menu of options for including affordable units, for example, by setting a higherpercentage of units priced at moderate income and a lower percentage of units set at extremelylow income. Such a menu would address a broader range of City of San Mateo housing needs,while giving developers more options for meeting the inclusionary requirement.

Sample Language: The City of San Mateo shall revise its inclusionary housing ordinance to offerdevelopers a menu of options for achieving affordability, adjusting the percentage of unitsrequired to be affordable depending on the degree of affordability achieved (moderate-income,low income, very low income, and extremely low income). ● Reduce Parking Requirements for People with Developmental and Other Disabilities. Adultswith developmental disabilities have reduced parking needs because they rarely have a driver'slicense or own a car. This may also be true of other categories of people with disabilities. TheCity should revise its ordinances to limit parking required for affordable units for people withdevelopmental disabilities to .5 space for each affordable studio or 1 bedroom unit and 1 spacefor an affordable 2 bedroom unit or larger. A similar reduction should be considered forphysically accessible units required to be included in affordable housing.

Sample Language: The City shall encourage the inclusion of people with developmental andother disabilities in affordable housing by recognizing their transit dependence and establishinglower parking ratios for units targeted to people with developmental and other disabilities thanwould otherwise be required for affordable housing. ● Local Density Bonus Concessions.The state densitybonus law currently provides additionaldensity for housing projects that include at least 10% of the units for disabled veterans,transition-age foster youth, and homeless persons at the very low income level. Above andbeyond the density bonus guidelines mandated by state law, the City should add the sameincentives when at least 10% of the units are subject to preference for people with 6 766 of 955
developmental disabilities who will benefit from coordinated onsite services provided by theGolden Gate Regional Center.

Sample Language: In implementing the California density bonus statute, the City shall providefor the same density bonus, incentives, or concessions for housing projects that include at least10% of the units for people with developmental disabilities at the very low-income level as areavailable to projects that include at least 10% of the units for disabled veterans, transition-agefoster youth, and homeless persons at the very low-income level.

Affirmative Marketing of Physically Accessible Units: Developers are allowed to affirmativelymarket accessible units to disability-serving organizations in San Mateo County (i.e. Golden GateRegional Center, Housing Choices Coalition for Person with Developmental Disabilities, Centerfor Independence of Individuals with Disabilities and others) but rarely take this step.Affirmative marketing is particularly needed by people with developmental disabilities who,because of cognitive, communication and social impairment, may rely on housing navigationservices funded by the Golden Gate Regional Center to learn about and apply for affordablehousing.

Sample Language: As a condition of the disposition of any city-owned land, land dedicated toaffordable housing under the city’s inclusionary ordinance, the award of city financing, anydensity bonus concessions, or land use exceptions or waivers for any affordable housing project,the City shall require that the housing developer implement an affirmative marketing plan forphysically accessible units which, among other measures, provides disability-servingorganizations adequate prior notice of the availability of the accessible units and a process forsupporting people with qualifying disabilities to apply. ● Extremely Low-Income Accessory Dwelling Units. Aspart of a larger plan to increase the supplyof Accessory Dwelling Units (ADUs), the City should consider creating a forgivable loan programfor homeowners who build ADUs and rent them for at least 15 years at Extremely Low Incomerent levels to people with developmental disabilities.

Sample Language: Subject to funding availability, the City shall devise a program of financing forAccessory Dwelling Units subject to rent restrictions for at least 15 years at ExtremelyLow-Income rent levels to people with developmental disabilities who would benefit fromcoordinated housing support and other services provided by the Golden Gate Regional Center. ● Affirmatively Further Fair Housing. Not only is disabilitythe highest-ranked source of FairHousing complaints, a growing body of San Mateo County data indicates that Black, Indigenousand other People of Color (BIPOC) with disabilities experience higher rates of housingdiscrimination and severe rent burden than either BIPOC without disabilities or whites withdisabilities. Currently the City of San Mateo offers its residents exceptional employment,educational and social opportunities but the severe shortfall of Extremely Low Income unitsmeans that BIPOC--particularly those with disabilities--are too often excluded from enjoying 7 767 of 955
those community assets. Multiple barriers including high land and construction costs andlimited funding make it difficult for developers to produce Extremely Low Income units that willovercome such disparities. Policies that lead to increased production of Extremely Low Incomeunits, as well as city staff dedicated to implementing and overseeing those policies, willAffirmatively Further Fair Housing in the City of San Mateo and decrease displacement andhomelessnessness for the most at-risk City of San Mateo residents.

Sample Language: The City of San Mateo's plans to Affirmatively Further Fair Housing for Black,Indigenous and other People of Color, particularly those with disabilities, shall include policiesdesigned to increase the production of Extremely Low Income units, as well as adequate staffcapacity to implement and monitor the impact of these policies. 8 768 of 955

1 DEVELOPMENTAL DISABILITIES SUBMISSION FOR

CITY OF SAN MATEO HOUSING ELEMENT
Introduction to Developmental Disabilities
People with developmental disabilities have a disability that emerged before age 18, is expected to be lifelong, and is of sufficient severity to require a coordinated program of services and support in order to live successfully in the community. Developmental disabilities include intellectual disability, autism, Down syndrome, epilepsy, cerebral palsy, and other disabling conditions similar in their functional impact to an intellectual disability. Under California’s Developmental Disabilities Services Act and the U.S. Supreme Court’s 1999 decision in Olmstead v. L.C., people with developmental disabilities are entitled to receive community-based services that allow them to live in the least restrictive community setting. This shift to de-institutionalization has led to the closure of the most restrictive segregated settings and to the requirement that local jurisdictions in their Housing Elements assess and plan specifically for the housing needs of people with developmental disabilities who receive services from the Regional Center in order to live in their home community.

Table ___ Comparison of the 2021 City and County Populations with Developmental Disabilities Age City of San Mateo County of San Mateo City of San Mateo as % of County
Under age 18 304 1169 26%
18 and older 531 2764 19%
Total 835 3933 21%
Source: The City of San Mateo data is based on zip code level data for zip codes 94401, 94402, and 94403 published by the California Department of Developmental Services as of September 2021. County level data is published by the Department of Developmental Services as of June 2021. Both sources exclude children from birth to the third birthday because approximately 75% of this age group is found not eligible for continuing lifelong services on their third birthday.
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2 Decline in Living Arrangements for Adults with Developmental Disabilities Outside the Family Home.

Of the City’s total population with developmental disabilities, 531 (64%) are adults and 304 (36%) are under age 18 (Table __). Assessing the housing needs of adults with developmental disabilities is of particular importance because as they age the adults will require a residential option outside the family home, whereas the family home is the preferred living option for children with developmental disabilities. In 2021, 505 City of San Mateo residents with developmental disabilities lived in the family home compared to 389 in 2013 as reported in the 2015 to 2023 Housing Element. This 30% increase in reliance on the family home is 2.5 times greater than the City’s 12% increase in the developmental disabilities population during that same period. Increased reliance on the family home is primarily explained by overall growth in the population with developmental disabilities coupled with significant declines in opportunities for the City’s adults with developmental disabilities to live either in licensed care facilities (10% decline) or in affordable housing with supportive services (19% decline). (Table __.) As adults with developmental disabilities age, they need opportunities to live outside the family home both because of the aging of their family caregivers and also because many adults with developmental disabilities would like to live in their own apartment with supportive services.

Table ___ Changes in Living Arrangements of Adults with Developmental Disabilities Living Arrangements
2013
Number
2021
Number
2021
Percent of Total Adults % Change Since 2013
Total (children & adults) in
the Family Home 389 505 -- 30%
Adults In the family home
Not reported-- see
note 201 38% --
Own apartment with
supportive services 64 52 10% -19%
Licensed Facilities 294 265 50% -10%
Other (including homeless) 7 13 2% 86%
Total Adults
Not reported--see
note 531 100% --
Note: The 2013 data are reported in the 2015 Housing Element, which failed to separately count those under 18 and those 18 and older, making it difficult to estimate changes in the significance of the family home as a residential setting specifically for adults. The 2021 data are published at the zip code level by the California Department of Developmental Services as of September 2021. These data assume that occupants of licensed facilities are 18 and older which is generally true, but if incorrect this assumption would tend to understate the need for other housing options for adults with developmental disabilities.

3 trend has significant implications for housing needs among City of San Mateo adults with developmental disabilities during the period of the 2023 to 2031 Housing Element.

Table __ Changes in Age Distribution of Adult Population in San Mateo County Age 2015 Number 2021 Number % Change
18 to 31 1023 1189 16%
32 to 41 397 457 15%
41 to 52 382 335 -12%
52 to 61 385 348 -10%
62 plus 327 435 33%
Total adults 2514 2764 10%
Source: County level data is published by the Department of Developmental Services as of June 30, 2021 and as of September 30, 2015.

4 Displacement. The California Department of Developmental Services has documented a 12% decline in the age group 42 to 51 and a 10% decline in the age group 52 to 61 in San Mateo County between September 2015 and June 2021. (Table __). In light of gains in life expectancy, this loss can reasonably be attributed to homelessness or displacement from the county because of the lack of residential living options (either licensed facilities or affordable housing) when a parent caregiver passes away or becomes unable to house and care for the adult. Displacement takes a particular toll on adults with developmental disabilities who depend on familiarity with transit routes and shopping and services, as well as support from community-based services and informal networks built up over years in living in the City of San Mateo.

Transit-Dependent. Most adults with developmental disabilities do not drive or own a car and rely on public transit as a means to integration in the larger community.

5 apartment and are often as essential to a person with a developmental disability as a physically modified unit is to a person with a mobility, vision, or hearing impairment. ● A mix of unit sizes at inclusive housing properties would address the needs of those who require live-in aides, want to live with roommates or partners, or have children. ● Location near public transit would accommodate the transit-dependency of most adults with developmental disabilities.
● Deeply affordable housing is needed, targeting incomes not more than 30% of Area Median Income and taking advantage of Housing Authority Project Based Vouchers or HUD 811 Project Rental Assistance when available to create housing opportunities for those who cannot meet minimum income requirements for units priced at 30% of Area Median Income.

Policy and Program Recommendations
The City of San Mateo has a responsibility not simply to assess the housing needs of people with developmental disabilities but also to create policy, zoning, program and other changes that make it more feasible for affordable housing developers to include people with developmental disabilities in their housing in coordination with the supportive services available from the Golden Gate Regional Center. The City’s 2015 Housing Element identified a need for housing for an additional 30 to 87 people with developmental disabilities, but the number of adults with developmental disabilities living in their own apartment actually declined by 11% since the last Housing Element, even as the population grew by 12%. The City’s lack of progress in meeting the housing needs of people with developmental disabilities since the last Housing Element demonstrates the need for policies and programs that specifically incentivize inclusion of people with developmental disabilities in affordable housing with coordinated services provided by the Golden Gate Regional Center.
● Establish and monitor a quantitative goal. Tracking the City’s success in housing people with developmental disabilities is essential to determine whether policies and programs are having an effect in overcoming historic patterns of discrimination and exclusion of people with developmental disabilities from affordable housing. Since its last Housing Element, the City of San Mateo facilitated land acquisition and provided city funding for one affordable housing project with a commitment to make 8 of the 225 apartments subject to a preference for people with developmental disabilities (Kiku Crossing). A goal of 100 new Extremely Low-Income housing units for City of San Mateo residents with developmental disabilities over the period of the 2023-2031 Housing Element would represent meaningful progress towards the total unmet housing need of this special needs population.

Sample Language: The City of San Mateo shall monitor progress towards a quantitative goal of 100 new Extremely Low Income housing units that are subject to a preference for people with developmental disabilities needing the coordinated services provided by Golden Gate Regional Center to live inclusively in affordable housing.

● Target City-Owned Land, Land Dedicated to Affordable Housing under the Inclusionary Ordinance and City Housing Funds to Meet City-Specific Priorities. City-owned land, land 773 of 955

6 dedicated to affordable housing in lieu of providing affordable units under the inclusionary ordinance, and city housing funds are often essential to the development of affordable housing that is financially feasible in high-cost City of San Mateo. In creating guidelines for the scoring of any competitive requests for proposals for these scarce resources, the City should grant additional points to affordable housing projects that address the housing needs of City of San Mateo residents who are most difficult to house under existing state and federal housing finance programs--for example, by prioritizing proposals with a higher number of extremely low income units or that make a percentage of units subject to a preference for identified categories of special needs people who would benefit from coordinated onsite services, including but not limited to people with developmental disabilities who benefit from services of the Golden Gate Regional Center.

Sample Language: In publishing requests for competitive proposals for any city-owned land, land dedicated to affordable housing under the city’s inclusionary ordinance or city housing funds, the City of San Mateo shall grant additional points to proposals that address the city’s most difficult to achieve housing priorities, by, for example, providing a greater number of extremely low-income units or committing to make a percentage of the units subject to a preference for people with special needs who will benefit from coordinated onsite services, such as people with developmental disabilities who receive services from the Golden Gate Regional Center.

● Offer Developers Additional Alternatives Under the Inclusionary Ordinance. Most adults with developmental disabilities and other special needs groups on fixed incomes, are unable to satisfy minimum income requirements for the Lower Income units currently required under the city’s inclusionary ordinance. California law (AB 1505, the “Palmer Fix”) explicitly allows cities to adopt inclusionary housing ordinances that address a range of income levels from moderate- income to extremely low-income. The City should take advantage of this authority to make its ordinance more responsive to local needs by offering developers of market rate housing an alternative means of compliance with the city’s BMR program if deeper levels of affordability are targeted, such as by allowing a lower percentage of units to be set aside if they are affordable to Extremely Low Income households. This same alternative can be extended to projects that make a percentage of units subject to a preference for identified categories of special needs people who would benefit from coordinated onsite services, including but not limited to people with developmental disabilities who benefit from services of the Golden Gate Regional Center. Such a menu would address a broader range of City of San Mateo housing needs, while giving developers more options for meeting the inclusionary requirement.

Sample Language: The City of San Mateo shall revise its inclusionary housing ordinance to offer developers an alternative means of compliance with the BMR program, to consider an applicant’s request to lower the percentage of set-aside units in projects which include extremely low income units or units for residents requiring specialized services (such as people with developmental disabilities who benefit from services of the Golden Gate Regional Center) in 774 of 955

7 connection with its review of the planning application for the project and may reject or accept the request in its sole discretion.

● Reduce Parking Requirements for People with Developmental and Other Disabilities. Adults with developmental disabilities have reduced parking needs because they rarely have a driver's license or own a car. This may also be true of other categories of people with disabilities. The City should revise its ordinances to limit parking required for affordable units for people with developmental disabilities to .5 space for each affordable studio or 1 bedroom unit and 1 space for an affordable 2 bedroom unit or larger. A similar reduction should be considered for physically accessible units required to be included in affordable housing.

● Local Density Bonus Priorities. The state density bonus law incentivizes the production of housing at the Low and Very Low Income level. But in counties like San Mateo County, with the highest Area Median Income in the state, these incentives reward the targeting of income levels that effectively exclude the many people with disabilities and seniors living on fixed incomes well below the Very Low Income target. The City of San Mateo should create additional local incentives to the state density bonus law to reward the production of more housing for City of San Mateo residents who do not benefit from the Low and Very Low Income units produced under the state density bonus law--for example, projects with a percentage of Extremely Low Income units and/or projects that make a percentage of units subject to a preference for identified categories of special needs people who would benefit from coordinated onsite services, including but not limited to people with developmental disabilities who benefit from services of the Golden Gate Regional Center.

Sample Language: In addition to implementing the California density bonus statute, the City shall provide an additional local density bonus, incentives, or concessions for housing projects that include a percentage of the units for people at the Extremely Low-Income affordability level and/or target special needs populations, such as people with disabilities who will benefit from coordinated onsite services provided by the Golden Gate Regional Center.

Affirmative marketing is particularly needed by people with developmental disabilities who, because of cognitive, communication and social impairment, may rely on housing navigation 775 of 955

8 services funded by the Golden Gate Regional Center to learn about and apply for affordable housing.

● Extremely Low-Income Accessory Dwelling Units. As part of a larger plan to increase the supply of Accessory Dwelling Units (ADUs), the City should consider creating a financing program for homeowners who build ADUs and rent them for at least 15 years at Extremely Low Income rent levels or that are subject to a preference for identified categories of special needs people who would benefit from coordinated onsite services, including but not limited to people with developmental disabilities who benefit from services of the Golden Gate Regional Center.

Sample Language: Subject to funding availability, the City shall devise a program of financing for Accessory Dwelling Units subject to rent restrictions for at least 15 years at Extremely Low- Income rent levels and/or target special needs populations, such as people with disabilities who will benefit from coordinated onsite services provided by the Golden Gate Regional Center. ● Affirmatively Further Fair Housing. Not only is disability the highest-ranked source of Fair Housing complaints, a growing body of San Mateo County data indicates that Black, Indigenous and other People of Color (BIPOC) with disabilities experience higher rates of housing discrimination and severe rent burden than either BIPOC without disabilities or whites with disabilities. Currently the City of San Mateo offers its residents exceptional employment, educational and social opportunities but the City’s severe shortfall of Extremely Low Income units means that BIPOC--particularly those with disabilities--are too often excluded from enjoying those community assets. Multiple barriers including high land and construction costs and limited funding make it difficult for developers to produce Extremely Low Income units that will overcome such disparities. Policies that lead to increased production of Extremely Low Income units, as well as city staff dedicated to implementing and overseeing those policies, will Affirmatively Further Fair Housing in the City of San Mateo and decrease displacement and homelessnessness for the most at-risk City of San Mateo residents.

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9 777 of 955
1 From: Housing
Sent: Friday, May 6, 2022 4:59 PM
To: y
Subject: FW: San Mateo Housing Element

From: Jennifer Martinez
Sent: Friday, May 6, 2022 1:06 PM
To: Housing <[email protected]>
Cc:

Subject: San Mateo Housing Element

May 4, 2022

Dear Mayor Bonilla and San Mateo City Council Members,

Thank you for the opportunity to provide a response to the 2022 Draft Housing Element. My letter focuses on the goal to Affirmatively Further Fair Housing.

State law requires that each community study patterns of racial segregation and concentrated affluence, identify the conditions that have contributed to these patterns, and plan for specific programs that will address these patterns.

First, San Mateo’s Housing Element fails to sufficiently study this problem. While the neighborhoods where people of color live have been analyzed, the neighborhoods with high concentrations of white residents have not been studied. By failing to analyze the underlying conditions of these neighborhoods (exclusionary zoning, the history of racial covenants, etc.), the Housing Element also fails to propose policies and programs that will change those conditions and address the racial segregation that those neighborhoods are also experiencing.

This is an egregious omission that flies in the face of affirmatively furthering fair housing to reduce segregation and create equal housing and opportunity access, regardless of race or ability.

Second, without adequate analysis, the Housing Element does not provide adequate solutions - by geography as is required by HCD guidelines - to meet the scale, depth, and nuance of the problem. Many of the proposed programs amount to “more marketing” in low-income neighborhoods. The programs and policy solutions should include approaches that address the underlying conditions of racial segregation, such as  change the zoning of R-1 neighborhoods to allow for more density,  pair investment strategies in under-invested areas with stronger anti-displacement measures to ensure low-income residents reap the benefits of neighborhood improvements,  improve access to reliable, affordable transportation and access to high-quality schools

Third, the minimal AFFH analysis that does exist states that “there is a relative lack of affordable housing opportunities in higher-resourced areas of the city.” Yet the Housing Element fails to propose housing sites, let alone affordable housing sites, in the high resource neighborhoods in the city. Again, those neighborhoods are left out of the equation and off the table in terms of being part of the solution to the city’s segregation problems.

While much work has been done to create the current Housing Element, it falls short of state guidelines as well as the hopes and aspirations we should have for San Mateo. There is no reason why the burden of the housing crisis we face in our communities should continue to fall on low-income people and people of color, 778 of 955
2 while the windfall benefits of increased home values accrue to a largely-white, wealthier part of our community.

Far from natural segregation, this is the outcome of decades of policies designed to favor some people over others, and we can choose differently. Now is the time to change this pattern of segregation and unequal benefits and burdens and create a different future for the next generations.

Respectfully,

Jennifer Martinez
Resident, San Mateo
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1 From: Housing
Sent: Monday, May 9, 2022 8:30 AM
To:

Subject: FW: Housing Element response by Social Action Ministry Attachments: SAM_Housing Element Letter_Final.pdf

From: Mike Heagerty < >
Sent: Friday, May 6, 2022 7:26 PM
To: Housing <[email protected]>
Cc: City Council (San Mateo) <[email protected]> Subject: Housing Element response by Social Action Ministry

Attached is the Social Action Ministry's response to the draft Housing Element. Thank you for your consideration.

Mike Heagerty

780 of 955

All people deserve respect, justice and opportunity

April 29, 2022

City Council Members: Rick Bonilla, Mayor; Diane Papan, Deputy Member; Joe Goethals, Council Member; Amourence Lee, Council Member; Eric Rodriguez, Council Member Planning Manager
City of San Mateo
330 West 20th Avenue
San Mateo, CA 94403

RE: Draft Housing Element

To whom it may concern,

Thank you for reaching out to the community regarding the Draft Housing Element outlining the process and review for expanding housing within our community over the next eight years. The Social Action Ministry (SAM) group at St. Matthew Catholic Church in San Mateo is concerned about the availability of affordable housing in our community.

SAM encourages our City leaders to focus on affordable housing for those members of our community in the very low- and low-income categories of median income for San Mateo County, identified in the Housing Element, many of whom are working in essential services and/or underemployed. We believe too much of our new housing construction has focused on the highest income earners of our region.

Your draft Housing Element correctly identifies the loss of affordability covenants on developments within the City of San Mateo that could potentially create a loss of affordable units, rather than an increase, during a time when the housing shortage is so acute. We need to push strong planning and allow zoning flexibility to convert under-utilized commercial projects for affordable residential developments. Our community is blessed with diversity from many walks of life, and we do not wish it to be only a home for the elite. Shelter and housing are a human right, and this is the time to focus on those who are the most shelter-insecure in our community as housing pressures become more amplified than anytime in our lives.

We appreciate your efforts and consideration of our position. We look forward to the results of your City Council meeting on May 16, 2022.

Sincerely,

Social Action Ministry
of St. Matthew Catholic Church

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All people deserve respect, justice and opportunity

Selected SAM members residing in San Mateo:

María del Carmen Muñoz

Anne A. Fariss

Michael Heagerty

John H. Love II

Vilma Sanchez

Susan Wilbur

782 of 955
1 From: Housing
Sent: Monday, May 9, 2022 8:31 AM
To:

Subject: FW: San Mateo draft housing element/Comments from One San Mateo

From: Planning <[email protected]>
Sent: Friday, May 6, 2022 5:08 PM
To: Housing <[email protected]>;

Subject: FW: San Mateo draft housing element/Comments from One San Mateo

From: Eldridge, Karyl >
Sent: Friday, May 6, 2022 3:28 PM
To:

Cc: Planning <planni [email protected]>; [email protected];

Subject: San Mateo draft housing el ement/Comments from One San Mateo

Dear Mayor Bonilla and Members of the San Mateo City Council,

This letter is submitted on behalf of One San Mateo to provide feedback in relation to the draft housing element for the City of San Mateo. One San Mateo is a community group formed in 2017 to work toward creating a city that is responsive to the needs of all. We strive to increase racial and economic equity, primarily through our advocacy for affordable housing and renter protections. We believe that safe and stable housing is fundamental to human dignity and well-being and essential to the health and sustainability of the overall community.

In reviewing the housing element, the core interest of One San Mateo has been to evaluate its effectiveness in upholding the mandates of Affirmatively Furthering Fair Housing. These mandates require cities to work proactively to reverse historical patterns of segregation and foster integrated communities. Our comments are offered from the perspective of these AFFH goals.

HOUSING NEEDS AND THE RISK OF DISPLACEMENT

Misleading metric. Preventing the displacement of existing residents is central to the fulfillment of AFFH, as is made clear by the AFFH guidance memo issued by HCD in April of 2021. As it currently stands, the needs analysis in the draft housing element contains metrics that seriously downplay the risk of displacement in San Mateo. One such metric appears as follows: “According to research from the University of California, Berkeley, 0.0% of households in San Mateo live in neighborhoods that are susceptible to or experiencing displacement ...” Regardless of the source, offering this as a meaningful metric of the displacement threat in San Mateo is extremely misleading. Elsewhere in the needs analysis, the northeast section of San Mateo, particularly the area south of Poplar Avenue, is said to be characterized by high poverty, concentrations of cost burdened households, and overcrowding. The existence of high levels of cost burden and overcrowding are clear predictors of 783 of 955
2 displacement. Furthermore, the needs analysis reveals that the North Central and downtown neighborhoods are “At Risk of Becoming Exclusive” or “Becoming Exclusive.” Looming exclusion necessarily translates into a threat of displacement. Thus, we maintain that this 0.0% statistic taken from UC Berkeley only serves to cloud the gravity of the displacement threat and underplay the need for aggressive action to prevent it. The credibility of the analysis would be strengthened if this statistic were removed.

Jobs-housing fit. The discussion of the increasing jobs-housing ratio does not go far enough toward exposing the growing pressures on lower-income residents and the displacement risk associated with this. While the rising jobs- housing ratio reflects the growing imbalance between jobs and housing, it does nothing to measure the relationship between affordability levels of the housing and the income levels of San Mateo residents. According to the needs analysis, “83.6% of permits issued in San Mateo were for above moderate-income housing, 6.2% were for moderate-income housing, and 10.1% were for low- or very low-income housing ...” Since many of the new jobs created over this period were low-wage, this signals a growing shortage of housing for residents at the lower end of the income scale. This, in turn, creates a risk of displacement. The needs analysis, particularly its assessment of displacement risk, would be strengthened by introducing a discussion of jobs-housing fit, a metric specifically designed to measure the number of low-wage workers within the city and the number of homes that are affordable to them.

MISSING CONSTRAINTS

Measure Y. The April 2021 guidance memo from HCD contains a list of zoning and land use barriers that includes an entry that reads: “Voter initiatives that restrict multi-family developments, rezoning to higher density, height limits, or similar measures that limit housing choices.” In discussing constraints, the draft housing element makes passing mention of Measure Y, the voter initiative that creates a limit on height and density for new buildings in San Mateo through 2030. However, the perfunctory character of this treatment dramatically understates the importance of Measure Y in restricting the development of new homes at all levels of affordability. Three years ago the city council considered an increase in the Below Market Rate (BMR) requirement to 20 percent. The economic consultants hired by the city ultimately concluded that it was infeasible, given the height and density limits imposed by Measure Y. This is but one illustration of how Measure Y operates to put a chokehold on the creation of housing, including affordable housing. A far more robust discussion of Measure Y is called for in the consideration of constraints.

R-1 zoning. The guidance memo from HCD states the following: “In addition to identifying and analyzing racially and ethnically concentrated areas of property, an analysis should also consider concentrated areas of affluence ... to guide meaningful goals and actions to address fair housing issues.” In the City of San Mateo, at least 70 percent of the land zoned for housing is R-1, and many of these R-1 neighborhoods are populated primarily by affluent whites. The draft housing element fails to discuss this reality, its causes, and the profound implications of R-1 zoning for segregating the community and perpetuating inequality.

SITES INVENTORY AND R-1 ZONING

One San Mateo’s strongest objection to the draft housing element is the fact that none of the sites are located in the highest opportunity areas. More specifically, we take issue with the fact that the housing plan takes a complete “hands-off” approach to neighborhoods zoned R-1. R-1 zoning is, by its very nature, exclusionary. First introduced in the wake of a 1917 Supreme Court decision that banned explicitly racist zoning, its very intent was to accomplish exclusion by other means. Also, the majority of R-1 neighborhoods in San Mateo were developed with racial covenants in their founding documents, barring all but whites from living within their borders. By protecting these neighborhoods from any meaningful densification, the housing element locks this history into place. It not only fails to reverse historical segregation, it entrenches it. Furthermore, this “hands-off” approach to R-1 is a missed opportunity, a huge and tragic one, since it prevents these neighborhood from unleashing their ability to address the community’s urgent housing need.

POLICIES, PROGRAMS AND AFFH
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3 Funding for those most at risk. The housing element includes a variety of policies giving priority to the lowest income members of the community, including those with special needs. Since these are the residents hardest to serve and most at risk of displacement, this prioritization is important for the achievement of AFFH goals. However, what is urgently needed is funding to create additional numbers of affordable units for these vulnerable populations. Thus the city is urged to include in its action plan the creation of a new funding source for affordable housing, coupled with the prioritization of units for VLI and ELI and for those with special needs.

Remove the Measure Y constraint. Measure Y is a significant barrier in the effort to create new housing, including affordable housing. The housing element should incorporate a commitment by the city to initiate a community process resulting in a new ballot measure to remove this constraint.

Increase the BMR. San Mateo’s Below-Market-Rate Program has been a powerful mechanism for generating affordable homes. As previously stated, the city council considered such an increase of the BMR in recent years, but the height-and-density limits of Measure Y (Measure P at the time) were found to render it infeasible. We encourage the city to include in its action plan an increase in the BMR, to be passed by council immediately in the wake of overturning Measure Y.

Transform exclusive neighborhoods into inclusive ones. As indicated above, there is currently no affordable housing located in the highest opportunity areas. This is clearly inconsistent with AFFH goals. The city should make the changes necessary to facilitate the meaningful densification of R-1 neighborhoods, thereby disabling a decades-old enforcer of segregation and enabling the transformation of exclusive neighborhoods into inclusive ones.

Protect tenants from displacement. In the housing element chart for Programs and Policies, Policy H3.4 includes an enumeration of tenant protections to be enacted during Cycle 6, many of which are currently being worked on. However, this list is muddled and insufficiently robust. Considering that this is an 8-year cycle, the list should include policies other than those currently under consideration. We suggest that this entry be revised to include the following:

 Expand tenant protections under AB 1482: Extend just cause provisions to the first year of tenancy, require documentation prior to remodel, expand relocation assistance for all no-fault evictions, provide first right of return for renovation and demolition.

 Create new resources for emergency rental assistance.

 Investigate adoption of a Community Opportunity to Purchase Act.

This last item, referred to as COPA, creates an opening for community nonprofits to purchase multi-family buildings when they first come on the market, providing an opportunity to preserve the affordability of the units and keep the tenants from being displaced.

Rent registry. Policy H3.6 currently reads “Explore rent registry.” Elsewhere in the housing element draft, it says that in response to community input, a decision was made to “Adopt a rent registry.” Thus the word “Explore” should be changed to “Adopt.” Furthermore, the rent registry should also be listed in the AFFH chart, as is the case with Policy H3.4. A rent registry tracks whether existing renter protections are being complied with and functions as a powerful vehicle to prevent displacement.

The creation of this housing element provides an opportunity to chart a course toward a brighter future for San Mateo in which inclusion is at the forefront, disparities are overcome, and the needs of all San Mateo residents are taken into full account. One San Mateo encourages incorporation of the changes described above so that it will fulfill its potential for doing so.

Sincerely,
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4 Karyl Eldridge
Vice Chair of One San Mateo

*Wire Fraud is Real*. Before wiring any money, call the intended recipient at a number you know is valid to confirm the instructions. Additionally, please note that the sender does not have authority to bind a party to a real estate contract via written or verbal communication. 786 of 955
1 Manira Sandhir
From: Adam Nugent
Sent: Wednesday, April 27, 2022 9:56 PM
To: Manira Sandhir; Zachary Dahl
Cc: Eloiza Murillo-Garcia; [email protected]
Subject: San Mateo Planning Commission Input - Draft Housing Element - Apr 26 Attachments: Planning Commission Input - Draft Housing Element - Adam Nugent - April 26.pdf Hi Manira and Zach,

Thank you, again, for your team's hard work on the City of San Mateo’s Draft Housing Element. It is a massive undertaking!

Here are my notes and consolidated input from last night’s Planning Commission review of the Draft Housing Element. I spent a few hours following
the meeting getting as much of the discussion topics I commented on during the meeting incorporated into my notes as possible.

I hope the additional detail and clarifying elements in these notes prove useful to the team.

Best,
Adam

Adam Nugent, PLA
Planning Commissioner, City of San Mateo
[email protected]

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Commissioner Adam Nugent, April 26, 2022 Planning Commission Meeting Commissioner Input
Draft 2023-2031 Housing ElementDraft for Public Review: Housing Element of the General Plan 2023-2031, April 6, 2022
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OutlineDraft 2023-2031 Housing Element Input
•Introduction and Thank You
•Part 1: Site Inventory Comments
•Methodology-focused
•Part 2: Aﬃrmatively Furthering Fair
Housing Comments
•General Comments
•Fair Housing Assessment
•Contributing Factors
Note: Topics to be discussed at
Continuance Meeting, May 3:
•Part 3: Other Housing Element
Sections
•Part 4: Goals, Policies, and
Programs
•Including Aﬃrmatively
Furthering Fair Housing
Policies and Programs
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Introduction and Thank You
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Thank you, Housing Element Team!
The work you are doing is extremely important and impactful •All of my comments and questions come from a place of deep respect and appreciation for the hard work you are doing!
•I am proud to have a city with staﬀ of such caliber, who genuinely desire to create a better, more just housing landscape for our future •This is HARD WORK; and you are undertaking it in uncharted territory that is fraught with puzzles and potential pitfalls
Introduction
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Thank you, Housing Element Team!
Fair warning:
•My comments are extensive
•To implement the Housing Element in a way that truly advances fair housing goals and meets the needs of our younger generations it will take:
•Tough decisions and a lot of work
•This Housing Element is an opportunity to make real progress:
•Repair racial and economic disparities
•Combat cost of living increases that are disproportionately harming younger adults
Introduction
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The Push for Change Has Never Been Greater
Demographics will drive our housing needs and our political will •The younger half of our population has a diﬀerent outlook and set of values than many who are in the older generations
•The political winds are blowing in the right direction for positive change •The Millennial and Gen-Z generations are the largest generations in history and will have continually increasing political voice and power
•It is the younger generations that are feeling the most pain in this crisis, and they are the most motivated to bring about change
•14% of 4-year university students experienced homelessness last year; 42% experienced housing insecurity (Governing, 4/26/2022)
•We cannot botch this for the next generation
Introduction
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Quantified Objectives Discussion
Draft City of San Mateo 2031 Housing Element, Chapter 8 •“According to HCD, the sum of the quantiﬁed objectives for the programs should ideally be equal to or surpass the community's identiﬁed housing needs.” (Page H-75)
•Nevertheless, in the Draft Housing Element, the City has chosen not to produce a plan that meets our Regional Housing Needs Assessment (RHNA) allocation
•The City has (erroneously*) calculated its own, quantiﬁed objectives that are below its regionally identiﬁed housing needs
•The Draft Housing Element does not currently include meaningful, quantiﬁable actions that would signiﬁcantly increase housing production to an appropriate level, but this can and should be changed •The only way we can justify not planning to meet our identiﬁed housing needs is if it is impossible for us to create programs, policies, develop funding, or make land use changes that can commensurably increase housing production in line with our allocation, i.e. if there were no precedents in which municipalities reformed policies and subsequently increased housing production
* The quantiﬁed objectives themselves are incorrect due to omissions in the Housing Element’s capacity calculation methodology, discussed next
Introduction
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Kevin Erdmann
“Unaffordable housing has one and only one
cause: purposeful communal enforcement
of it. This is legislated poverty.”
“We have a housing problem. And in researching that problem, you many have found that income inequality affects housing affordability. You many have found that the home building industry is inefficient. Dubious mortgage lending. Speculators. Slum lords, etc. etc. “All those things can be real things! They all can even be important things! We should deal with them AFTER the poisoning [purposeful communal enforcement of scarcity] stops!”Introduction 795 of 955
Part 1: Sites Inventory
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Fundamentally, there is not a set of
programs or proposals in the Draft Housing
Element that justify an assertion that there
will be a 300% increase in housing
production over the next eight years.
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My comments focus entirely on methodological
issues and I will heavily reference state statutes
and documented state guidance
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How much buﬀer do we have and how does it aﬀect
housing costs and fair housing?
Historically, most US cities planned for far more
housing than was needed for the existing
population. But as cities started to integrate in the
post-war era of the 1950s and 60s, a backlash
ended this practice, and a wave of mass
downzonings followed.

The result: Housing is increasingly unaﬀordable for
most households. This was deliberate, and often
predicted, as downzonings greatly reduced the
“zoning buﬀer” between current housing stock and
the maximum allowable housing capacity. “Before
1960, the buﬀer in both New York and Los Angeles
was at least 300% … New York’s fell to roughly
50% after the 1961 zoning update, and it was just
12% in Los Angeles in 2010.” (Shane Phillips,
Housing Initiative Project Manager, UCLA Lewis
Center for Regional Policy Studies)
Why does zoning capacity matter?
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•“Nonvacant Sites Analysis: For nonvacant sites,
demonstrate the potential and likelihood of
additional development within the planning
period based on extent to which existing uses
may constitute an impediment to additional
residential development, past experience with
converting existing uses to higher density
residential development, current market
demand for the existing use, any existing leases
or other contracts that would perpetuate the
existing use or prevent redevelopment of the site
for additional residential development,
development trends, market conditions, and
regulatory or other incentives or standards to
encourage additional residential development on
these sites”
This information needs to be objectively quantiﬁed
Methodological Shortcomings: Nonvacant Sites Analysis
Sites Inventory
A Necessary Threshold listed in the “HDC Housing Element Completeness Checklist 1/1/2021”:
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•“If nonvacant sites
accommodate 50 percent or
more of the lower-income RHNA
[which is the case in San Mateo],
demonstrate the existing use
is not an impediment to
additional development and
will likely discontinue in the
planning period, including
adopted ﬁndings based on
substantial evidence.”
Sites Inventory
Methodological Shortcomings: Nonvacant Sites Analysis
A Necessary Threshold listed in the “HDC Housing Element Completeness Checklist 1/1/2021”:
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Realistic Development Capacity
My Underlying Questions
•How does the city plan to increase home building by over 300%? •And is this development increase realistic under the described methodology? •What is diﬀerent in cycle 6 from cycle 5?
•The city’s site’s capacities have only decreased from cycle 5 as the city has grown and land uses intensiﬁed (new developments have replaced existing underutilized parcels)
•So, is there a proposed program or group of new programs that can be shown to increase home building by over 300%, based on substantial evidence from other municipalities or from economic studies? Sites Inventory
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Sites Inventory Analysis is IncompleteCurrent incompleteness prohibits City from assessing actual capacity to meet its RHNA allocation
•From the Draft Housing Element: “The purpose of the Sites Inventory is to evaluate whether there are suﬃcient sites with appropriate zoning to meet the RHNA goal. It is based on the City’s current land use designations and zoning requirements. The analysis does not include the economic feasibility of speciﬁc sites, nor does it take into consideration the owner’s intended use of the land now or in the future.” (Page H-25 Draft City of San Mateo 2031 Housing Element)
•My Q: What substantial evidence, then, does the city provide that uses will be discontinued for nonvacant sites?
•My Q: How does the city incorporate redevelopment trends in its site capacity calculations?
Sites Inventory
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Site Inventory Methodology - State Law
(Compare to Draft City of San Mateo 2031 Housing Element, Page H-26) •Government Code section 65583.2(c)(2) The housing element must describe the methodology used to determine the number of units calculated based on the following factors:

1.Land use controls and site improvements requirements,

2.*NEW* The realistic development capacity for the site,

3.*NEW* Typical densities of existing or approved residential developments at a similar aﬀordability level in that jurisdiction,

4.*NEW* The current or planned availability and accessibility of suﬃcient water, sewer, and dry utilities.

The realistic development capacity for sites has not been factored in an appropriate or meaningful way Sites Inventory 804 of 955
Page H-26
Draft City of San Mateo 2031 Housing Element
•“The number of units that might be able to be developed at various aﬀordability levels was then estimated, e.g.,
available land zoned at higher densities can be counted toward the very low- and low-income level needs, and land zoned at lower densities are counted toward the moderate and above moderate-income housing need. The analysis
was then completed using the actual average residential densities for developments built on land with various
zoning designations over the past ﬁve years.” (Page H-26 Draft City of San Mateo 2031 Housing Element)
•This a surprisingly short description of a crucial part of our otherwise extensive Draft Housing Element
•“was then estimated” is doing a lot of work in this passage •The City needs to show its math and data so the public can adjudicate its capacity calculations
Site Inventory Methodology
Sites Inventory
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Page H-26
Draft City of San Mateo 2031 Housing Element
•“The number of units that might be able to be developed at various aﬀordability levels was then estimated, e.g., available land zoned at higher densities can be counted toward the very low- and low-income level needs, and
land zoned at lower densities are counted toward the
moderate and above moderate-income housing need.

The analysis was then completed using the actual
average residential densities for developments built
on land with various zoning designations over the past
ﬁve years.” (Page H-26 Draft City of San Mateo 2031
Housing Element)
•Q: What is the denominator used in calculating the
average?
•Q: Does this denominator only use recently
developed sites or does it look at all similarly zoned
parcels?
Site Inventory Methodology
Sites Inventory
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Site Inventory MethodologyRealistic Development Capacity for nonresidential, nonvacant, or overlay zoned sites •Practically all sites are non-vacant, and so we must look at production trends…
Sites Inventory
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City must consider past experience
converting existing uses for Nonvacant Sites
•HCD’s “Site Inventory Guidebook,” page 24:
•“If the inventory identiﬁes nonvacant sites to address a portion of the RHNA, the housing element must describe
the realistic development potential of each site within the planning period. Speciﬁcally, the analysis must
consider the extent that the nonvacant site’s existing use impedes additional residential development, the
jurisdiction's past experience converting existing uses to higher density residential development, market
trends and conditions, and regulatory or other incentives or standards that encourage additional housing
development on the nonvacant sites.”
“Development potential”
X period of time (“planning period”)
= rate of parcel conversion to new housing
Realistic Development Capacity
Sites Inventory
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Nonvacant Site Analysis Methodology
From HCD’s “Site Inventory Guidebook,” May 2020, page 25 Sites Inventory
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Part C: Example
CalculationFrom HCD’s “Site Inventory
Guidebook,” May 2020, page 22
I cannot ﬁnd this factor in our
site inventory methodology
Sites Inventory
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Site Inventory Approach
Page H-26-27
Draft City of San Mateo 2031 Housing Element
The closest thing I can ﬁnd to a calculation
of the rate at which similar parcels were
redeveloped is this non-empirical
“Development Potential Ranking”.

The writers of this draft used a subjective,
ranked series of numbers, 1-5, in its
calculations to encode what amounts to an
unsubstantiated guesstimate of the
“realistic development capacity” of sites
This is like using “thumbs up” emojis
where we should be using available,
numerical, development trend data
Sites Inventory
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Realistic Development Capacity
for nonvacant sites
•Using qualitative characteristics to “rank” the “likelihood” of redevelopment for various sites is not an acceptable methodology in any HCD guidance documentation (Draft Housing Element, page H-26 to H-27) •The likelihood of redevelopment should be based on quantitative, measurable trends [rates] (HCD “Site Inventory Guidebook,” page 21) •The only valid exceptions should be for places without reasonably similar development history to calculate trends from, and that should generally not apply to the Bay Area
Sites Inventory
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Realistic Development Capacity
•Using qualitative characteristics to “rank” the “likelihood” of redevelopment for various sites is not an acceptable methodology in any HCD guidance documentation (Draft Housing Element, page H-26 to H-27) •When ratings are subjective, it is impossible for the public to ascertain the quality of the City’s analysis.
•It amounts to staﬀ saying, “there is enough capacity because, to us, it feels like there is enough capacity. Trust us.”
•It then becomes uncannily convenient that staﬀ “determined” we have enough zoned capacity to meet our RHNA allocation.
for nonvacant sites
Sites Inventory
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Realistic Development Capacity
•Using qualitative characteristics to “rank” the “likelihood” of redevelopment for various sites is not an acceptable methodology in any HCD guidance documentation (Draft Housing Element, page H-26 to H-27) •When we use objective, quantitative data and we ﬁnd that the probability of development is lower than what we need to meet our goals, we have the ability to draft policies that will enable changes that will help us meet our goals in predictable ways
•In contrast, when you base development capacity on subjective, non- empirical ratings, the Public has no way to understand how to change policies in ways that will meet our development needs
for nonvacant sites
Sites Inventory
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Non-Vacant Site Analysis Methodology - State Law
Government Code section 65583.2, subdivision (g)(2) states:
•“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.”
•Q: How can a qualitative ranking of sites be considered substantial evidence? Sites Inventory
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Realistic Development Capacity - Nonvacant Sites
•In sum, past production trends must be used, including whether or not a site will be developed at all. Staﬀ or consultant “intuition” is not acceptable •Unless there is substantial evidence that a site will be redeveloped according to a listed density, be it a letter from the property owner or a pre- application submission, the city should be using an objective, calculated probability of redevelopment based on all similar properties locally or regionally over the course of the past RHNA cycle.
•For the City of San Mateo, that probability is 8.5% according to a UCLA study published in 2021
Sites Inventory
Current incompleteness prohibits City from assessing actual capacity to meet its RHNA allocation
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•In sum, past production trends must be used, including whether or not a site will be developed at all. Staﬀ or consultant “intuition” is not acceptable •Each parcel capacity calculation should be multiplied by the probability of development for parcels in San Mateo, something akin to 0.085 (or

1.0 if the parcel has substantial evidence of redevelopment) •If there is additional, reﬁned and warranted, development trend data, such as the probability of development for parcels with a speciﬁc zoning- designation that are of a functionally equivalent size, that probability may be factored into the calculation if reviewed and approved by the PC or council
Current incompleteness prohibits City from assessing actual capacity to meet its RHNA allocation
Sites Inventory
Realistic Development Capacity - Nonvacant Sites
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The City shall serve the Public in its evaluation of suitable sites •From HCD Site Inventory Guidebook, page 27:
•“If a housing element relies on nonvacant sites to
accommodate 50 percent or more of its RHNA for
lower income households, the nonvacant site’s existing
use is presumed to impede additional residential
development, unless the housing element describes
ﬁndings based on substantial evidence that the use
will likely be discontinued during the planning period.

The housing element must include the following:
•As part of the resolution adopting the housing
elements, ﬁndings stating the uses on nonvacant
sites identiﬁed in the inventory to accommodate the
RHNA for lower income is likely to be discontinued
during the planning period and the factors used to
make that determination. This can be included in
the body or in the recital section of the resolution.”
Non-vacant Site Analysis Next Steps
Sites Inventory
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Non-vacant Site Analysis Next Steps
The City shall serve the Public in its evaluation of suitable sites •When substantial evidence is provided for site redevelopment, it should be available to the public, early in the process, in an easy, user-friendly way that is connected to the site geographically,
•The substantial evidence’s warrant for use should be adjudicated by the the Public through the Planning Commission and veriﬁed by HCD •Absent substantial evidence:
•The likelihood of redevelopment of any given site should default to the likelihood of development for all sites across the city (or all sites of a particular zoning category and equivalent size, if the data are available) Sites Inventory
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Realistic Development Capacity
Include a Monitoring Program with next-step actions
•Monitoring Programs with next-step actions should be incorporated if the expected housing development is not produced
•“In addition, the housing element should include monitoring programs with next-step actions to ensure sites are achieving the anticipated development patterns. The programs should identify modiﬁcations to incentives, sites, programs, or rezoning the jurisdiction will take should these strategies not yield the expected housing potential.” (HCD “Site Inventory Guidebook,” page 21)
Sites Inventory
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Part 2: Affirmatively Furthering
Fair HousingUsing California HCD Guidance for Public Entities and Housing Elements to advocate for our neighbors in San Mateo
Commissioner Adam Nugent, April 26, 2022 Planning Commission Meeting 821 of 955
AFFH General Comments
Where are we going with this?
•We should have a very clear end-state where this city has solved the identiﬁed patterns of segregation, geographic disparities, and aﬃrmatively furthered fair housing
•It does not have to be achieved by the end of this single cycle, but its expected year of achievement should be stated and agreed upon, under the direct consultation of identiﬁed, excluded demographics and protected classes, like an emissions goal
•This end-state should be discernible and anticipated by the goals and actions AFFH: General Comments
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Michael Kraus, a social psychologist and an associate professor at Yale University “Many Americans have a hard time recognizing the magnitude and persistence of racial inequality because, psychologically, we resist these truths. Psychologists refer to this kind of broad bias in perception as “motivated cognition” — that is, most Americans want to live in a society that is more racially equal, and so they engage in mental actions that ignore, discount or downplay contradictory evidence to maintain coherence between belief and reality.” AFFH: General Comments
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Likewise, when progress toward equality is
seen as inevitable, incentives for political
action are low.

AFFH: General Comments
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We need to end residential segregation
and reinvest in our Northern
Neighborhoods
Without displacement
AFFH: General Comments
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State Guidance
Aﬃrmatively Furthering Fair Housing
•New California laws require active steps
by our city government to dismantle
housing segregation
•Actions must be taken in the Housing
Element/General Plan creation in 2021
and 2022
•HCD outlines best practices and
policies for cities to use
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Quick AFFH
Overview for Readers
of These Notes
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What is AFFH?
Aﬃrmatively Furthering Fair Housing
Aﬃrmatively furthering fair housing means
taking meaningful actions, in addition to
combating discrimination, that overcome
patterns of segregation and foster
inclusive communities free from barriers
that restrict access to opportunity based
on protected characteristics.

The duty to aﬃrmatively further fair
housing extends to all of a public
agency’s activities and programs relating
to housing and community development.

AFFH: General Comments
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•Address signiﬁcant disparities in housing
needs and in access to opportunity
•Replace segregated living patterns with
truly integrated and balanced living
patterns
•Transform racially and ethnically
concentrated areas of poverty into areas
of opportunity
•Foster and maintain compliance with
civil rights and fair housing laws
Meaningful Action
AFFH requirements
AFFH: General Comments
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Fair Housing Actions
What we need San Mateo to do
•Create housing mobility strategies
•Provide new housing choices and
aﬀordability in areas of opportunity
•Design place-based strategies to
encourage community conservation
and revitalization
•Protect existing residents from
displacement
AFFH: General Comments
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AFFH: General Comments
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6.3 San Mateo’s Fair Housing
Assessment
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Fair Housing AssessmentShortcomings In the Assessment of Segregation and Integration Patterns and Trends:
•No analysis of racially segregated, concentrated areas of aﬄuence •Missing assessment of the most segregated racial population: non- Hispanic whites (APPENDIX D, Attachment 4 – UC Merced Segregation Report)
•No opportunity sites are located within the city’s highest-opportunity areas "Figure II-7: White Majority Census Tracts," Root Policy Research Map and Data Packet, Page 11
AFFH: Fair Housing Assessment
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Racially Concentrated Areas of Aﬄuence Completely Left Out of the Analysis and Sites Inventory Assessment’s Miss:
70-80% WHITE
70-80% WHITE
70-80% WHITE
90% NON-WHITE
"Figure II-6: % Non-
White Population by
Census Block Groups,"
2018, Root Policy
Research Map and
Data Packet, Page 10 AFFH: Fair Housing Assessment
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Fair Housing AssessmentShortcomings In the Assessment of Segregation and Integration Patterns and Trends:
•Why is income-segregation substantially higher in San Mateo compared to the rest of the Bay Area?
•This assessment should highlight factors that can be ﬁxed •Why has San Mateo’s income segregation at the neighborhood level not improved over time and why is it worse than the Bay Area average? AFFH: Fair Housing Assessment
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Fair Housing Assessment
•Missing meaningful assessment of segregation in San Mateo relative to the Bay Area region
•Extremely low population of black people. Why?
•Need assessment of causes for the growing exclusion of this demographic from San Mateo in order to solve for this issue Shortcomings In the Assessment of Segregation and Integration Patterns and Trends:

AFFH: Fair Housing Assessment
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Exclusion and displacement —> low population relative to Bay Area •Only 2% of the city’s population is now black
•In 1990 the North Central census tract was
18% black, the highest in the city
•In 2017 it was only 4% black
•Discuss possible causes:
•Disinvestment-driven displacement in
North Central due to rising rental costs
and lack of improvement of rental housing
conditions
•Government policy preventing home
purchasing
•Historical exclusion elsewhere in the city
Assessment’s Miss: Black population
AFFH: Fair Housing Assessment
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Housing Habitability Issues
Assessment’s Miss: Geographic Differences
•Strong and distinguishing
characteristic of North Central
•Highly concentrated in North
Central and downtown
•North Shoreview is not
characterized by this issue
See also: ”Figure III-11: Healthy Places
Index by Census Tract, 2021," Root Policy
Research Map and Data Packet, Page 40 AFFH: Fair Housing Assessment 838 of 955
Overcrowding issues in North Central
•Strong and distinguishing characteristic of
southern North Central
•Highly concentrated in one neighborhood
•North Shoreview (13%) is much less
characterized by this issue
•San Mateo overcrowding overall average:
7%, which is heavily skewed by North
Central
•San Mateo Park: < 1%
•North Central north of Poplar Ave: 1%
•North Central south of Poplar Ave: 27%
Assessment’s Miss: Geographic Differences
"Figure IV-19: Overcrowded Households by Census Tract,
2019," Root Policy Research Map and Data Packet, Page 60 AFFH: Contributing Factors 839 of 955
Fair Housing Assessment
•North Central residents, including many who are alive today, have experienced the trauma of exclusion and steering from other neighborhoods of San Mateo
•Paired with a strong history of disinvestment and government practices to prevent POC from home ownership, the neighborhood and its people will need thoughtful repair in both the public and private realms Resident trauma and exclusion
AFFH: Fair Housing Assessment
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6.3.2 Contributing factors and
Fair Housing Action Plan.
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Excerpt from HCD’s AFFH Presentation
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Excerpt from HCD’s AFFH Presentation
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Analysis of Contributing Factors is inadequate
•It currently focuses more on the characteristics of the victims of our discriminatory structures and thus functions more as a continuation of the fair housing assessment than what it’s meant to be
•For instance, listing the fact that Hispanic residents are more likely to work low-wage jobs or that Hispanic residents are primarily concentrated in the northeastern area of the city where residents face higher poverty and cost burden as well as poor opportunity outcomes is something that belongs in the fair housing assessment, not in the contributing factors space AFFH: Contributing Factors
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Analysis of Contributing Factors is inadequate
What is a fair housing contributing factor?
•Fair housing contributing factor = a factor that creates, contributes to, perpetuates, or increases the severity of one or more fair housing issues •City-controlled regulatory factors, policies, or ways of doing business that cause or contribute to fair housing issues should be fully identiﬁed and take primacy in this analysis, but they are inadequately discussed AFFH: Contributing Factors
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Examples of Contributing Factors to Fair Housing Issues by Area •Segregation and Integration
•Community opposition
•Lack of community
revitalization strategies
•Lack of private investments
in speciﬁc neighborhoods
•Land use and zoning laws
From HCD’s “Aﬃrmatively Furthering Fair Housing: Guidance to All Public Entities and for Housing Elements” Pages 68-70
AFFH: Contributing Factors
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Examples of Contributing Factors to Fair Housing Issues by Area •Racially and Ethnically
Concentrated Areas of Poverty
•Deteriorated and abandoned
properties
•Displacement of residents
due to economic pressures
•Land use and zoning laws
•Occupancy codes and
restrictions
From HCD’s “Aﬃrmatively Furthering Fair Housing: Guidance to All Public Entities and for Housing Elements” Pages 68-70
AFFH: Contributing Factors
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Examples of Contributing Factors to Fair Housing Issues by Area From HCD’s “Aﬃrmatively Furthering Fair Housing: Guidance to All Public Entities and for Housing Elements” Pages 68-70
•Disparities in Access to Opportunity
•The availability, type, frequency, and
reliability of public transportation
•Land use and zoning laws
•Lack of public investments in
speciﬁc neighborhoods, including
services or amenities
•Location of proﬁcient schools and
school assignment policies
•Location and type of aﬀordable
housing AFFH: Contributing Factors
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Examples of Contributing Factors to Fair Housing Issues by Area From HCD’s “Aﬃrmatively Furthering Fair Housing: Guidance to All Public Entities and for Housing Elements” Pages 68-70
•Disproportionate Housing Needs,
Including Displacement Risks
•The availability of aﬀordable
units in a range of sizes
•Lack of renter protections
•Land use and zoning laws
AFFH: Contributing Factors
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Analysis of Contributing Factors
Analysis of Contributing Factors is inadequate.
•Contributing Factors analysis must answer key “why” questions:
•What unique factors, characteristics, and history in North Central and, separately, North Shoreview are leading to the concentration of higher poverty, low economic and environmental opportunity, high-cost burden, overcrowding, and ﬂood hazards compared to the rest of the City of San Mateo?
•What existing government constraints or policies have perpetuated these concentrated characteristics?
•What factors, policies, and history in other parts of the city contribute to the absence of these characteristics, especially west of El Camino? AFFH: Contributing Factors
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Shortcomings
•The Housing Element needs to assess the geographic and regulatory causes leading to the concentration of poverty, low economic and environmental opportunity, high-cost burden, and overcrowding in North Central and, to a lesser extent, North Shoreview
•The Housing Element also needs to assess the geographic and regulatory causes leading to the concentration of aﬄuence and, disproportionately, white people in western neighborhoods
•This necessary assessment of causes is needed in order to develop place- based programs and actions that will meaningfully repair these issues The Analysis of Contributing Factors
AFFH: Contributing Factors
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Must be able to guide Signiﬁcant, Meaningful, and Suﬃcient policies to Overcome Patterns of Segregation
•Existing patterns of segregation in San Mateo are signiﬁcant and persistent •Census tract divergence within the city ranges from 82% white to 6% white (San Mateo Park vs North Central, respectively)
•Class segregation largely follows these lines
•Actions and policies must be suﬃcient to overcome this pattern in a reasonable period of time
•Why is the white population signiﬁcant? Check out Appendix D and read Segregation by Design by Prof. Jessica Trounstine
The Analysis of Contributing Factors
AFFH: Contributing Factors
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Must be able to guide Signiﬁcant, Meaningful, and Suﬃcient policies to Overcome Patterns of Segregation
•The Housing Element also fails to discuss strategic approaches to inform and strongly connect “Contributing Factors” to “Goals and Actions” •This contributes to the the creation of goals and actions that are not yet suﬃcient to produce meaningful action
The Analysis of Contributing Factors
AFFH: Contributing Factors
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Must be able to guide Signiﬁcant, Meaningful, and Suﬃcient policies to Overcome Patterns of Segregation
•Again, existing patterns of segregation in San Mateo are signiﬁcant and persistent •Analysis of Contributing Factors should be able to connect to Actions and Policies that are structured in a way that, economically, creates value for the city and for residents, without destroying the value of existing places
•This should not be about diminishing the quality of existing high-resource neighborhoods in order to achieve parity
•This process is about:
•Lifting up disinvested portions of our city, and
•Pairing that uplift with expanded access and residential integration across the city through thoughtful government-guided programs
The Analysis of Contributing Factors
AFFH: Contributing Factors
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Tell the Story: North Shoreview: Environmental Hazard and Isolation •Why is North Shoreview an edge
Racially/Ethnically Concentrated
Area of Poverty?
•What characteristics
distinguish North Shoreview
from other similar
neighborhoods, and how
might they lead to higher
concentrations of marginalized
or vulnerable groups?
Identify and Prioritize Contributing Factors
"Figure IV-31: Special Flood Hazard Areas, 2000,"
Root Policy Research Map and Data Packet, Page 69 AFFH: Contributing Factors 855 of 955
Identify and Prioritize Contributing Factors:

Tell the Story
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Tell the Story: North Shoreview: Environmental Hazard and Isolation •Why is North Shoreview an edge
Racially/Ethnically Concentrated
Area of Poverty?
•Key diﬀerences between North
Shoreview and South
Shoreview:
•Levy protection and ﬂood
hazard chance.
•Limited access to circulation
and transportation
Identify and Prioritize Contributing Factors
"Figure IV-31: Special Flood Hazard Areas, 2000," Root Policy Research Map and Data Packet, Page 69
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Tell the Story: North Central: Poor Housing Conditions + Overcrowding •Why is North Central (south of
Poplar) an edge Racially/
Ethnically Concentrated Area of
Poverty?
•What characteristics distinguish
North Central south of Poplar
Ave from other parts of the city,
and
•How might they lead to higher
concentrations of marginalized
groups?
Identify and Prioritize Contributing Factors
Overcrowding
Unhealthy Housing
Conditions
AFFH: Contributing Factors
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Tell the Story: North Central: Disinvestment + Environmental Hazard Identify and Prioritize Contributing Factors
•Why is North Central (south of Poplar) an
edge Racially/Ethnically Concentrated Area of
Poverty?
•Key diﬀerences between North Central
(south of Poplar) and other areas:
•Decades of disinvestment:
•Both private housing stock and
public infrastructure
•Overcrowding and poverty as both
symptoms and causes of private
disinvestment
•Levy protection and ﬂood hazard
chance (in portions of that area)
"Figure IV-31: Special Flood Hazard Areas, 2000,"
Root Policy Research Map and Data Packet, Page 69 AFFH: Contributing Factors 859 of 955
Tell the Story: North Central: Historical Ghettoization + Failed, Segregated Schools Identify and Prioritize Contributing Factors
•Why is North Central (south of Poplar) an
edge Racially/Ethnically Concentrated Area
of Poverty?
•Key diﬀerences between North Central
and other areas:
•History of a highly segregated
neighborhood and its
underperforming school
•Neighborhood’s Turnbull Learning
Academy closed about 15 years ago
•The building repurposed for the
College Park Mandarin Immersion
magnet school
AFFH: Contributing Factors
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AFFH Links
and Resources
•California HCD Aﬃrmatively Furthering
Fair Housing (AFFH) Guidance https://
www.hcd.ca.gov/community-
development/aﬀh/docs/
aﬀh_document_ﬁnal_4-27-2021.pdf
•AFFH Data Viewer https://aﬀh-data-
resources-cahcd.hub.arcgis.com
•California Healthy Places Index https://
map.healthyplacesindex.org
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The Planning Commission discussion will resume on
May 3rd at 7pm where we will discuss Goals, Policies,
and Actions, including those related to AFFH
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1 Manira Sandhir
From: Adam Nugent
Sent: Thursday, May 5, 2022 5:45 PM
To: Manira Sandhir; Zachary Dahl
Cc: Eloiza Murillo-Garcia; [email protected]
Subject: San Mateo Planning Commissioner Input - Draft Housing Element - May 3 Attachments: Planning Commission Input - Draft Housing Element - Adam Nugent - May 3.pdf Hi Manira and Zach,

I appreciate the work you and your team is doing. Our May 3rd continuance meeting was the right call. Thank you for making it happen!

Here are my notes and consolidated input from that May 3rd Planning Commission review of the Draft Housing Element. Again, I hope the additional detail and clarifying elements in these notes prove useful to the team.

Best,
Adam

Adam Nugent, PLA
Planning Commissioner, City of San Mateo
[email protected]

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Commissioner Adam Nugent, May 3, 2022 Planning Commission Meeting Draft Housing Element
CommentsDraft for Public Review: Housing Element of the General Plan 2023-2031, April 6, 2022
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OutlineDraft 2023-2031 Housing Element Input
•Introduction and Thank You (Same as 4/26)
•Part 3: Other Housing Element Sections
•Part 4: Goals, Policies, and Programs
•Selected Excerpts of Rejection Letters
for Other Cities
•Goals, Policies, and Actions Discussion
•AFFH-Speciﬁc Policy-by-Policy Review
•Non-AFFH-Speciﬁc Policy-by-Policy
Review
Note: Topics that were discussed at the
April 26 Planning Commission Meeting:
•Part 1: Site Inventory Comments
•Methodology-focused
•Part 2: Aﬃrmatively Furthering Fair
Housing Comments
•General Comments
•Fair Housing Assessment
•Contributing Factors
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Public Comments
Notes and Highlights
•Market special-needs units to the most appropriate special needs population.

Unit-speciﬁc needs should be marketed so that the unique, appropriate population is matched with the special features of the unit •Measure Y as an obstacle to aﬀordable housing development 866 of 955
Thank you, Housing Element Team!
The work you are doing is extremely important and impactful •All of my comments and questions come from a place of deep respect and appreciation for the hard work you are doing!
•I am proud to have a city with staﬀ of such caliber, who genuinely desire to create a better, more just housing landscape for our future •This is HARD WORK; and you are undertaking it in uncharted territory that is fraught with puzzles and potential pitfalls
Introduction
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Thank you, Housing Element Team!
Fair warning:
•My comments are extensive
•To implement the Housing Element in a way that truly advances Fair Housing Goals and meets the needs of our younger generations it will take:
•Tough decisions and a lot of work
•This Housing Element is an opportunity to make real progress:
•Repair racial and economic disparities
•Combat cost of living increases that are disproportionately hitting younger adults
Introduction
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The Push for Change Has Never Been Greater
Demographics will drive our housing needs and our political will •The younger half of our population has a diﬀerent outlook and set of values than many who are in the older generations
•The political winds are blowing in the right direction for positive change •The Millennial is the largest generation in history and Gen-Z is close behind; they will have continually increasing political voice and power
•It is the younger generations that are feeling the most pain in this crisis, and they are the most motivated to bring about change
•14% of 4-year university students experienced homelessness last year; 42% experienced housing insecurity (Governing, 4/26/2022)
•We cannot botch this for the next generation
Introduction
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Kevin Erdmann
“Unaffordable housing has one and only one
cause: purposeful communal enforcement
of it. This is legislated poverty.”
“We have a housing problem. And in researching that problem, you many have found that income inequality affects housing affordability. You many have found that the home building industry is inefficient. Dubious mortgage lending. Speculators. Slum lords, etc. etc. “All those things can be real things! They all can even be important things! We should deal with them AFTER the poisoning [purposeful communal enforcement of scarcity] stops!”Introduction 870 of 955
Part 3: Other Housing Element
Sections
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Constraints Analysis
Draft Analysis Not Very Useful
•Constraints analysis should provide metrics on how existing land use and related policies aﬀect the City’s ability to build housing •What are the counterfactuals?
•How much more housing could be built under diﬀerent zoning scenarios? •What are the true limiting factors over the long term? •Why are construction costs so high and what can the city do to counteract these trends?
Part 3: Other Housing Element Sections
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Constraints Analysis
Zoning and Land Use Constraints
•Height and Density Constraints on BMR Units: Measure Y •Height and Density constraints contained in measure Y are limiting the city’s ability to increase the percentage of BMR units for the city’s inclusionary ordinance •Recent city-commissioned study found increasing the inclusionary percentage to 20% would render projects infeasible
•This adds up and translates to needing signiﬁcantly more redevelopable land to achieve any given quantity of subsidized units than necessary •Increases costs substantially by increasing costs imposed by land acquisition and entitlement processes
Part 3: Other Housing Element Sections
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Constraints Analysis
Zoning and Land Use Constraints
•Height and Density Constraints: Measure Y
•Density limits also signiﬁcantly reduce the number of units that can be built by 2-3x, even under the existing 5-story height limit
•Doubles or triples the land costs per unit for all ranges of aﬀordability •Doubles or triples the procedural, consultant, and time costs of additional design and entitlement processes
Part 3: Other Housing Element Sections
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Constraints Analysis
Community Opposition
•Community opposition is a clear problem
•Most people want more housing and to solve our housing crisis •It only takes a few, vocal or inﬂuential residents to block housing •Counterfactuals are hard to quantify, but the eﬀects of a vocal, negative minority are likely enormous
•When good, potential projects never even get proposed
•When bad policies and zoning go unchanged
•Need policies to overcome community opposition - especially as it relates to AFFH Part 3: Other Housing Element Sections
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Constraints Analysis
Fee Disparities
•Fees take up an unusually large proportion of the total costs of development in the City of San Mateo compared to the rest of San Mateo County •Fees impact small multi-family projects especially hard •They are 3.5 times higher per unit than single family homes Part 3: Other Housing Element Sections
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Part 4: San Mateo’s Goals,
Policies, and Actions
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Dr. Martin Luther King Jr. “Letter from Birmingham Jail” 1963 “We must come to see that human progress
never rolls in on wheels of inevitability. It
comes through the tireless efforts and
persistent work of men willing to be
coworkers with God, and without this hard
work time itself becomes an ally of the
forces of social stagnation.”
Part 4: San Mateo’s Goals, Policies, and Actions
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Excerpts from HCD’s AFFH Presentation
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Excerpts from HCD’s AFFH Presentation
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Selected Excerpts of Rejection
Letters for Other Cities’ 6th-Cycle
Housing Elements
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LA’s exemplary Housing Element Rejected
•Praised for metrics used to
demonstrate and determine
adequate sites for the Housing
Element
•Pursuing large rezoning program
Los Angeles
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Reason: AFFH
•Programs did not include metrics
•“In addition, while the element
included some actions to replace
segregated patterns, these
actions lacked speciﬁc
geographic focus (communities
with fair housing issues), ﬁrm
commitments and signiﬁcant
targets for AFFH outcomes.”
LA Rejection Letter
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Programs
How should programs be structured?
•“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.” (From HCD’s Davis, CA rejection letter)
•“Programs should include speciﬁc actions and commitments the City will take to implement the program. For example, a Program should be speciﬁc on the regulatory incentives, zoning standards, and programs it will oﬀer to assist in the development of housing.” (From HCD’s Davis, CA rejection letter)
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AFFH-specific
Goals and Actions must be signiﬁcant and meaningful
•“Goals and actions must speciﬁcally respond to the analysis and 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, metrics, and milestones as appropriate and must address housing mobility enhancement, new housing choices, and aﬀordability in high opportunity areas, place-based strategies for community preservation and revitalization, and displacement protection.” (From HCD’s Redondo Beach rejection letter) 885 of 955
AFFH-specific
Programs must have metrics and milestones
•“Based on the outcomes of a complete AFFH analysis, the element must add or modify programs to include speciﬁc metrics and milestones to target meaningful AFFH outcomes, including providing mobility opportunity, place- based strategies [for community preservation and revitalization], new housing opportunities, and preservation and conservation eﬀorts to address displacement.” (From HCD’s Davis, CA rejection letter)
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AFFH-specificPrograms must have objective measures to determine success of outcomes •[We need to] “replace non-committal language such as “if feasible”, “assess the feasibility of”, or “assess” with language that commits to follow-up actions. The program must include speciﬁc timeframes for action and provide quantiﬁable description of actions to objectively measure for successful outcomes.” (From HCD’s Redondo Beach rejection letter)
•Many policies with AFFH impacts proposed by San Mateo’s Draft Housing Element are characterized by this issue
•All proposed policies that have words like “investigate,” “explore,” or “evaluate” should be amended to provide speciﬁc timeframes for action and provide quantiﬁable descriptions of actions to objectively measure for successful outcomes
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Goals, Policies, and Actions
Discussion
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Goals, Policies, and Actions
Actions must be:
•Signiﬁcant
•Meaningful
•Suﬃcient to Overcome Patterns of Segregation
•Aﬃrmatively Further Fair Housing
Part 4: San Mateo’s Goals, Policies, and Actions
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Goals, Policies, and Actions
Necessary Components
•Metrics and milestones for evaluating:
•Progress on programs/actions
•Fair housing results
•Remember:
•Must have a clear timeline with speciﬁc dates and milestones paired with quantiﬁable outcomes •Meaningful impact during the planning period
•Go beyond a continuation of past actions
Part 4: San Mateo’s Goals, Policies, and Actions
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•Address signiﬁcant disparities in housing
needs and in access to opportunity
•Replace segregated living patterns with
truly integrated and balanced living
patterns
•Transform racially and ethnically
concentrated areas of poverty into areas
of opportunity
•Foster and maintain compliance with
civil rights and fair housing laws
Meaningful Action
AFFH requirements
Part 4: San Mateo’s Goals, Policies, and Actions
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How to combat exclusion and segregation
•We will need to tie our policies to
key quantitative metrics focused
on integration and segregation
data
•We will also need well-deﬁned
anti-displacement program
requirements
•Without these two things we will
further collectivize the right to
exclude
Goals, Policies, and Actions
UC Berkeley Othering and Belonging Institute
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Goals, Policies, and ActionsAddress signiﬁcant disparities in housing needs and in access to opportunity •Hispanic residents, single female parent households, renters, and the people of North Central, and to a lesser extent North Shoreview, have Disproportionate Housing Needs:

1.Cost Burden & Severe Cost Burden

2.Overcrowding

3.Substandard Housing

4.Displacement risk
•Investment-driven
•Disinvestment-driven
Part 4: San Mateo’s Goals, Policies, and Actions
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Goals, Policies, and ActionsAddress signiﬁcant disparities in housing needs and in access to opportunity •Cost Burden and Severe Cost Burden
•Site inventory, together with goals, policies, and actions, must be suﬃciently developed to actually produce at a minimum, the allocated 7000+ units of housing in San Mateo •Previous production trends indicate less than 1,000 units can be reasonably expected to be developed over the course of the 6th housing cycle, as currently planned in this Draft Housing Element
•Failure to adequately plan for the minimum allocated number of units will lead to further increasing cost burden and severe cost burden. It will also drive young families out of the Bay Area
•The City’s methodology must be revised to produce a high likelihood of meeting our regional allocation in order to address this AFFH disparity Part 4: San Mateo’s Goals, Policies, and Actions
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Goals, Policies, and ActionsAddress signiﬁcant disparities in housing needs and in access to opportunity •Overcrowding
•Overcrowding is similarly aﬀected by the reasonable achievement of the regional housing needs allocation goals
•Overcrowding is also highly location-speciﬁc and must be addressed in a combined eﬀort to prevent displacement as part of a program to transform racially and ethnically concentrated areas of poverty into areas of opportunity
•North Central contains an area that is nearly 4X the San Mateo average •27% vs 7% overcrowded households
•Thousands of people in North Central live in overcrowded conditions •Overcrowding is a measurable factor.
•Policies and Actions should be tailored to eliminate disparities in overcrowding and overcrowding in general within set timelines, say 1 and 2 decades, respectively Part 4: San Mateo’s Goals, Policies, and Actions
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Goals, Policies, and ActionsAddress signiﬁcant disparities in housing needs and in access to opportunity •Substandard Housing
•Substandard Housing is closely linked geographically to overcrowding in North Central
•Material conditions must be improved, as with overcrowding, in a way that prevents displacement
•Best done as part of a larger program to transform racially and ethnically concentrated areas of poverty into areas of opportunity •Policies and Actions should be tailored to realistically eliminate substandard and unhealthy housing conditions within a set timeline, say 1-2 decades Part 4: San Mateo’s Goals, Policies, and Actions
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Address signiﬁcant disparities in housing needs and in
access to opportunity
•Displacement Risk 1
•Programs must be developed to speciﬁcally address
displacement risk caused both by cost burden and by
potential neighborhood reinvestment
•Robust Right of Return for renters, paired
with…
•Alternative option for Unrestricted Negotiable
Tenant Buyouts
•Some tenants may not want to return
•All residents should be materially better
oﬀ following any neighborhood
investment
•All zoning changes and production policies
must be formulated to make the increased
costs imposed by associated displacement
protections feasible
Goals, Policies, and Actions
Part 4: San Mateo’s Goals, Policies, and Actions
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Address signiﬁcant disparities in housing needs and in
access to opportunity
•Displacement Risk 2
•Programs must be developed to speciﬁcally
address displacement risk caused both by cost
burden and by potential neighborhood
reinvestment
•Relocation Payments for substantial
remodel, demolition…
•and owner move-in
•All residents should be materially
better oﬀ following any
neighborhood investment
•All zoning changes and production policies
must be formulated to make the increased
costs imposed by associated displacement
protections feasible
Goals, Policies, and Actions
Part 4: San Mateo’s Goals, Policies, and Actions
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Address signiﬁcant disparities in housing needs and in
access to opportunity
•Displacement Risk 3
•Programs must be developed to speciﬁcally address
displacement risk caused both by cost burden and by
potential neighborhood reinvestment
•Create Community Opportunity to Purchase/
Tenant Opportunity to Purchase program,
paired with…
•Partnerships with Philanthropic Organizations
to bring funds to our most disinvested places
•All residents should be materially better
oﬀ following any neighborhood
investment
•All zoning changes and production policies
must be formulated to make the increased
costs imposed by associated displacement
protections feasible
Goals, Policies, and Actions
Part 4: San Mateo’s Goals, Policies, and Actions
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Address signiﬁcant disparities in housing needs and in
access to opportunity
•Displacement Risk 4
•Programs must be developed
to speciﬁcally address
displacement risk caused both
by cost burden and by potential
neighborhood reinvestment
•Extend AB1482
protections to tenants
whose tenure is less than
1 year
Goals, Policies, and Actions
Part 4: San Mateo’s Goals, Policies, and Actions
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Goals, Policies, and Actions
Additional Policy Suggestions
•Fee Parity
•San Mateo charges higher fees than the majority of its peers, and the city’s fees impose signiﬁcant costs on developers–especially for small multi-family housing •The city’s massive fees for small multi-family projects impose obvious burdens on developers and should be amended to support lower-cost home building •Achieve parity with Single Family home development
Part 4: San Mateo’s Goals, Policies, and Actions
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Goals, Policies, and Actions
Additional Policy Suggestions
•Aﬀordable Housing Overlay
•Provide aﬀordable housing developers an advantage in the market for developable properties
•Geographically locate the overlay(s) to compensate for existing housing disparities in access to opportunity
Part 4: San Mateo’s Goals, Policies, and Actions
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AFFH-Specific Policy-by-Policy
Review
Part 4: San Mateo’s Goals, Policies, and Actions
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Part 4: San Mateo’s Goals, Policies, and Actions
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Adjust City’s BMR Program
•Positive program but:
•Lacks ﬁrm commitments
•Lacks signiﬁcant targets for
AFFH outcomes
Policy 5.1.1
Part 4: San Mateo’s Goals, Policies, and Actions
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Participate in a Regional Downpayment program
•Program with potential life-
changing outcomes but:
•Limited scope will not
signiﬁcantly address large-scale
Systemic issues
Policy 5.1.2
Part 4: San Mateo’s Goals, Policies, and Actions
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Support the Design of Regional Forgivable Loan Program for 15-year ELI ADU Construction •Potential to contribute to overcoming
patterns of segregation
•Positive program with potential life-
changing outcomes but:
•Limited scope will not signiﬁcantly
address large-scale systematic issues
•Deliverables should occur early in the
planning period to ensure actual
housing outcomes
•Lacks speciﬁc actions and metric-ready
commitments
Policy 5.1.3
Part 4: San Mateo’s Goals, Policies, and Actions
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Support the Design of Regional Forgivable Loan Program for 15-year ELI ADU Construction •Policy revision recommendations:
•Expand to SB 9 projects
•Incorporate option for longer
deed restriction (55 years) for
one low income unit within a
SB 9 program
Policy 5.1.3 continued
Part 4: San Mateo’s Goals, Policies, and Actions
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Aﬃrmatively Market BMR units to households with disproportionate housing needs •Positive program with metrics
•People with special needs have
unique and special needs. Each
potential recipient may be quite
diﬀerent from the next and the
program will need to be
tailorable
•Limited scope will not
signiﬁcantly address large-scale
systemic issues
Policy 5.2.1
Part 4: San Mateo’s Goals, Policies, and Actions
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Incentivize development of new accessible units
•Positive program with potential
life-changing outcomes but:
•Limited scope
•Deliverables should occur earlier
in the planning period to ensure
actual housing outcomes
•Lacks speciﬁc actions and
metric-ready commitments
Policy 5.2.2
Part 4: San Mateo’s Goals, Policies, and Actions
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Prioritize city aﬀordable housing funds for hard-to-serve residents •Positive program but:
•Limited $ = limited impact
•Lacks speciﬁc actions and
quantiﬁable commitments
Policy 5.2.3
Part 4: San Mateo’s Goals, Policies, and Actions
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Conduct an area plan for North Shoreview and North Central •Potentially substantial program, but:
•Currently lacking ﬁrm commitments
and signiﬁcant targets for AFFH
outcomes
•Policy 5.3.1 should be speciﬁc on
the regulatory incentives, zoning
standards, and programs it will oﬀer
Policy 5.3.1
•Deliverables should occur earlier and
demonstrate that the program will
have a beneﬁcial impact within the
planning period
•Provide measurable milestones and
a target dates to achieve goals
Part 4: San Mateo’s Goals, Policies, and Actions
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Conduct an area plan for North Shoreview and North Central •Actions must speciﬁcally respond
to the analysis and the identiﬁed
and prioritized contributing factors
to fair housing issues and must be
signiﬁcant and meaningful
enough to overcome identiﬁed
patterns and trends
Policy 5.3.1 continued
•Speciﬁc planning goals must also include:
•Displacement prevention +
•Elimination of disproportionate
concentrations poverty, low income
households, and overcrowding
Part 4: San Mateo’s Goals, Policies, and Actions
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Plan for the opposite of Urban
Renewal
Urban Renewal conﬂated overcrowding with urban density
•Must not repeat the horrors of these Mid-Century
Planning Eﬀorts
•Urban Renewal sought to:
•Disperse and displace the resident population,
without providing adequate accommodations
elsewhere
•“Clear” slums, and replace them with things
like:
•Freeways, stadiums, convention centers,
•Inadequately-sized public housing
projects
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Conduct an area plan for North Shoreview and North Central •Planning goals should be structured with metrics and target dates, for example:
•Eliminate overcrowding by 2040
•Achieve parity with City in economic integration by 2050 Policy 5.3.1 continued
Part 4: San Mateo’s Goals, Policies, and Actions
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Conduct an area plan for North Shoreview and North Central Policy 5.3.1 continued
•Additional example planning goals:
•Achieve health and housing habitability parity with City by 2040 •Eliminate disproportionate concentrations of low-income residents while maintaining an outmigration rate below 20xx rate and increasing subsidized, deed-restricted aﬀordable housing at 150% the rate of outmigration
Part 4: San Mateo’s Goals, Policies, and Actions
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Conduct an area plan for North Shoreview and North Central •Plan to feasibly accommodate Community Beneﬁts
Agreements that balance redevelopment proposals with
tangible, local beneﬁts to residents in the area, e.g.:
•Creating aﬀordable housing
•Funding renter assistance programs for nearby residents •Other investments that meet community-identiﬁed
needs, such as infrastructure and community amenities
Policy 5.3.1 continued
Part 4: San Mateo’s Goals, Policies, and Actions
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Conduct an area plan for North Shoreview and North Central •R-1 portions of these neighborhoods should be provided total parity of treatment with the rest of San Mateo’s R-1
neighborhoods
•Why? The lower home values and lower wealth of non-white, owner-occupant homeowners means we need to carefully
manage and enhance the amenity-related value of ownership housing in places predominantly occupied by minorities
•Balance this task with displacement protections
Policy 5.3.1 continued
Part 4: San Mateo’s Goals, Policies, and Actions
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Conduct an area plan for North Shoreview and North Central •Provide speciﬁc timeframes for action and a quantiﬁable description of actions to objectively measure for successful outcomes
•Metrics to evaluate the plan must be in place and they must ultimately:
•Replace segregated living patterns with truly integrated and balanced living patterns •Transform racially and ethnically concentrated areas of poverty into areas of opportunity
Policy 5.3.1 Conclusions
Part 4: San Mateo’s Goals, Policies, and Actions
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Continue to fund minor home repairs
•Nice program but:
•Limited $ = limited impact
•Existing program
Policy 5.3.2
Part 4: San Mateo’s Goals, Policies, and Actions
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Monitor aﬀordable housing projects at risk of conversion •Important to preserve
aﬀordability, but:
•“Monitor” and “develop a plan”
are inadequate policies
Policy 5.3.3
Part 4: San Mateo’s Goals, Policies, and Actions
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Tenant Protections to extend AB1482 related to relocation, documentation, and right to return policy
•Vital, can be strengthened
•Relocation payments for
demolition should be uncapped
and negotiable
Policy 5.4.1
Part 4: San Mateo’s Goals, Policies, and Actions
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Non-AFFH-Specific Policy-by-
Policy Review
Part 4: San Mateo’s Goals, Policies, and Actions
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Policy Comment Potpourri
Selected Policies
•Policy H 1.2 - Utilize Public Funding for Low/
Moderate Income Housing
•Comment: Well deﬁned, ongoing program
•Policy H 1.3 - Increase Below Market Rate Unit
Production through Density Bonus/Community
Beneﬁts Programs *
•Policy H 1.5 - Encourage Family Housing *
* = Replace non-committal
language such as “explore”
or “assess” with language
that commits to follow-up
actions. The program must
include speciﬁc timeframes
for action and provide
quantiﬁable description of
actions to objectively
measure for successful
outcomes.

Part 4: San Mateo’s Goals, Policies, and Actions
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Policy Comment Potpourri
Selected Policies
•Policy H 1.9 - Create Minimum Densities for Mixed-
Use Residential Projects
•Comment: Provide quantiﬁable description of
actions to objectively measure
•Policy H 1.13 - Encourage Development of Missing
Middle Housing *
•Comment: Provide a quantiﬁable, developed
program of actions
•Policy H 1.14 - Evaluate and Update Special Needs
Group Housing Requirements *
* = Replace non-committal
language such as “explore”
or “assess” with language
that commits to follow-up
actions. The program must
include speciﬁc timeframes
for action and provide
quantiﬁable description of
actions to objectively
measure for successful
outcomes.

Part 4: San Mateo’s Goals, Policies, and Actions
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Policy Comment Potpourri
Selected Policies
•Policy H 2.1 - Fund Housing Rehabilitation Eﬀorts
•Comment: Provide metrics to evaluate eﬀectiveness
of program based on citywide habitability and health
trends
•Policy H 2.3 - Encourage Energy and Water Eﬃciency in
Existing Units
•Comment: Provide metrics to evaluate eﬀectiveness
of program based on citywide habitability and health
trends
•Policy H 2.4 - Explore Capital Improvements in lower-
resourced Neighborhoods *
* = Replace non-committal
language such as “explore”
or “assess” with language
that commits to follow-up
actions. The program must
include speciﬁc timeframes
for action and provide
quantiﬁable description of
actions to objectively
measure for successful
outcomes.

Part 4: San Mateo’s Goals, Policies, and Actions
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Policy Comment Potpourri
Selected Policies
•Policy H 2.5 - Promote Housing Resilience
•Comment: Existing, ongoing, important
•Policy H 2.6 - Require Replacement Units
•Comment: Make this a permanent local
ordinance
Part 4: San Mateo’s Goals, Policies, and Actions
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•Change “Evaluate” to “Pursue” Additional Local Funding Sources:
•Vacancy Tax - Parcel taxes in the form of a vacant property tax have been used by cities (VPT, Oakland) to fund aﬀordable housing and homeless services; as well as to entice owners of undeveloped sites to either sell or build homes on their parcels. •Increase Commercial Linkage Fees - To help mitigate the increase in demand for housing, cities have the ability to charge a fee on new commercial developments.

The revenue generated can then be used to help fund aﬀordable housing construction.
•Transfer Tax - A one-time tax payment that is levied by a government on the transfer of ownership to property (i.e. sale of a home) from one individual or entity to another within it’s deﬁned boundaries. The raised revenue can then be utilized to fund aﬀordable housing within the jurisdiction.

Policy Comment Potpourri
Policy H 3.3 “Evaluate Housing Revenue Sources”
Part 4: San Mateo’s Goals, Policies, and Actions
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Policy Comment Potpourri
Selected Policies
•Policy H 3.3 - Evaluate Housing Revenue Sources*
•Policy H 3.5 - Explore Below Market Rate Set
Asides*
•Policy H 3.6 - Examine a Rental Registry Option*
•Change to: Adopt a Rental Registry based on
best practices
•Policy H 3.7 - Explore Code Amendments and
Collaboration opportunities for Expanding
Homeless Shelters*
* = Replace non-committal
language such as “explore”
or “assess” with language
that commits to follow-up
actions. The program must
include speciﬁc timeframes
for action and provide
quantiﬁable description of
actions to objectively
measure for successful
outcomes.

Part 4: San Mateo’s Goals, Policies, and Actions
936 of 955
Links and Resources
•California HCD Aﬃrmatively Furthering
Fair Housing (AFFH) Guidance https://
www.hcd.ca.gov/community-
development/aﬀh/docs/
aﬀh_document_ﬁnal_4-27-2021.pdf
•AFFH Data Viewer https://aﬀh-data-
resources-cahcd.hub.arcgis.com
•California Healthy Places Index https://
map.healthyplacesindex.org
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1 From: Housing
Sent: Thursday, May 12, 2022 10:37 AM
To:

Subject: FW: City Council Draft Housing Element Meeting Follow Up Flag: Follow up
Flag Status: Flagged

From:

Sent: Thursday, May 12, 2022 10:27 AM
To: General Plan <[email protected]>; Housing <[email protected]> Subject: Re: City Council Draft Housing Element Meeting

Good morning.

Please consider the density of housing in San Mateo.
 Then consider that we are in a d rought. Where will the water come from to provide adequate plumbing in all of these new homes you wish to build?
 Will there be newly built, qualit y schools to provide state-of-the-art learning, or will our classrooms be overcrowded?
 As of now, Mills-Peninsula finds it challenging to accommodate the amount of patients going to the lab and doctors' appointments everyday. What will San Mateo provide to alleviate the amount of lab techs that are needed, availability of medical appointments, the ability to treat ER patients, and to provide the time slots needed for operations?
 The pandemic demonstrated how quickly food and home goods disappear off shelves. Will San Mateo provide more grocery stores for the amount of people that would move into ALL of the new housing?  With this increase of populati on, our neighborhood streets as well as freeways are already congested to the point of slowing down to 20 mph at given times during the day and week. What are the considerations and possibly cautions in regard to this clearly present situation throughout San Mateo? Needless to say, the general plan of housing in San Mateo neglects to look at the big picture. Instead, sadly, it is myopic in regard to filling quotas rather than providing for the needs of its community.

With deep concerns,
Maureen Zane

-----Original Message-----
From: City of San Mateo <[email protected]> To: Maureen Zane
Sent: Thu, May 12, 2022 9:16 am
Subject: City
Council Draft Housing Element Meeting
Share Your Thoughts on Draft Housing Element!
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2 View this email in your browser

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City Council Meeting

NOTICE OF PUBLIC HEARING

NOTICE IS HEREBY GIVEN that the City of San Mateo City Council will hold a public hearing regarding the City’s 2023-2031 Draft Housing Element.

MEETING DATE: Monday, May 23, 2022 at 5:30 p.m.

MEETING LOCATION: City Council Chamber, City Hall, 330 W. 20th Avenue, San Mateo, CA 94403; and Remotely via zoom, please visit www.cityofsanmateo.org/publicmeetings for meeting information and access.

PROJECT NAME: 2023-2031 Housing Element Update

PROJECT LOCATION: Citywide

PROJECT DESCRIPTION: Based on community, Planning Commission, and City Council input, the City has developed a Draft 2023-2031 Housing Element that identifies how the City 939 of 955
3 can accommodate 7,015 housing units over the next 8 years and establishes goals, policies and programs to help address the current and future housing needs within the City while affirmatively further fair housing policies. It is an important document that will guide future decisions about housing and sets forth an action plan to implement housing goals in the next eight years. The City Council will hold a public hearing to receive community input and consider the Draft Housing Element. The Draft Housing Element is available for public review at City Hall and online at https://www.cityofsanmateo.org/4478/Housing-Element-2023-2031.

STAFF CONTACT: Manira Sandhir, Planning Manager, ,
[email protected];
City of San Mateo, Planning Division, 330 West 20th Avenue, San Mateo, CA 94403

***
The City Council public hearing has been set for the above date which is open to the public in person or remotely. You may send written comments to the City Staff Contact listed above, and please reference “Housing Element” in the subject line.

If any person challenges this item in court, that person may be limited to raising only those issues the person or someone else raised at the public meeting described in this notice, or in written correspondence delivered at, or prior to, the public meeting.

AMERICANS WITH DISABILITIES ACT — In compliance with the Americans with Disabilities Act, those requiring accommodations for this meeting should notify the city staff, 48 hours prior to the meeting, at [email protected] or (650) 522-7040.

For additional project information please refer to
https://www.cityofsanmateo.org/4478/Housing-Element-2023-2031.

THANK YOU!

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4 Questions? Contact:

Manira Sandhir, Planning Manager and Zoning Administrator, tel: , fax: , email:

office: City Hall-Planning Division, 330 W. 20th Ave, San Mateo, CA 94403 Want to change how you receive these emails?
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941 of 955
1 From: Housing
Sent: Tuesday, May 17, 2022 9:55 AM
To:

Subject: FW: Carpemnters Union Input on Housing Element Attachments: San Mateo Housing Element.pdf

Administra
tive Tech| Housing
330 W. 20th Ave., San Mateo, CA 94403

From: Edwar
d Evans
Sent: Monday, May 16, 2022 9:43 AM
To: Housing <[email protected]>
Subject: Carpemnters Union Input on Housing Element

Dear Sir or Madame,
Please accept the attached letter from the Carpenters Union as input on the San Mateo Housing Element. Thank you.

All the best,

Ed Evans
Senior Field Representative/Financial Secretary-Treasurer Local 217, San Mateo County
Nor Cal Carpenters Union
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2 1

"Any time you have an opportunity to make a difference in this world and you don't, then you are wasting your time on earth." Roberto Clemente

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1 From: Housing
Sent: Tuesday, May 17, 2022 9:56 AM
To:

Subject: FW: Housing Element
Attachments: San Mateo Housing Element Public Comment_Spievack.pdf

Administra
tive Tech| Housing
330 W. 20th Ave., San Mateo, CA 94403

From: Na
talie Spievack
Sent: Thursday, May 12, 2022 9:10 PM
To: Housing <[email protected]>
Subject: Housing Element

Hello,

I hope this email finds you well. My name is Natalie Spievack, and I am a Master of City Planning student studying housing and community development at UC Berkeley. I was also raised in San Mateo and am a 2014 graduate of Hillsdale High School.

I appreciate the thought and effort that have gone into the draft housing element. Attached, please see my public comment on how San Mateo can prioritize educational equity and school integration in its housing element.

If you are interested, I am happy to discuss this further with you and your colleagues. Thank you for your consideration.

Best,
Natalie

‐‐
Natalie Spievack
Master of City Planning (Class of 2023)
Housing, Community, & Economic Development

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1 May 12, 2022

Christina Horrisberger

Re: Prioritizing Educational Equity and School Integration in San Mateo’s Housing Element 2022 Update

Dear Ms. Horrisberger,

I am writing to provide recommendations for the City of San Mateo’s Planning Division to prioritize educational equity and school integration in the City’s 2023-2031 Housing Element. As a San Mateo resident until age 18 and a Class of 2014 graduate of Hillsdale High School, I enthusiastically support the Planning Division’s focus on equity in the draft Housing Element. However, the draft Housing Element does not adequately consider the links between housing and educational opportunity.

I urge the City to expand attention to the schools-housing nexus in the final 2023-2031 Housing Element.

In doing so, the Housing Element will meet the state requirement to address educational opportunity in the Assessment of Fair Housing. Addressing the schools-housing nexus will also allow San Mateo to better plan for its families and be a leader among California cities. This letter describes how connecting housing policy with education goals can advance equity in both spaces and offers three sets of strategies to bring this goal to fruition.

The persistent link between where students live and where they go to school means that housing and educational inequities cannot be solved in siloes. Like most school districts across the country, the San Mateo-Foster City School District (SMFCSD) largely assigns students to schools by drawing school assignment boundaries around surrounding neighborhoods (Appendix, Figure 1). 1 This means that
school demographics largely reflect underlying neighborhood demographics. As a result of policies and practices that have limited access to high-opportunity neighborhoods, Latinx students2 and low-income students are concentrated in areas zoned for lower-performing schools.3 These areas include the Shoreview, North Central, and Fiesta Gardens neighborhoods (Figures 2 and 3).4

Local housing policy perpetuates housing and school segregation in San Mateo. During the planning period for the 5
th Cycle Housing Element (2015-2023), the bulk of affordable multi-family housing that

1 This analysis focuses on SMFCSD, the local elementary school district, because segregation levels are higher in elementary school than in middle or high school. That is because the larger number of elementary school attendance zones means the racial composition of neighborhoods and schools is more closely linked. 2 Black, Native Hawaiian and Pacific Islander, and Native American students, who are also marginalized, are not included in this analysis because they represent very small shares of the San Mateo population (<3%). 3 Rothstein, Richard, “The Black Lives Next Door,” The New York Times, August 14, 2020, https://www.nytimes.com/2020/08/14/opinion/sunday/blm-residential-segregation.html. 4 There are some notable exceptions. George Hall, College Park Mandarin Immersion, and North Shoreview Montessori are a highly rated public schools located in lower-income areas. However, College Park and North Shoreview are magnet schools, meaning they have no residential boundaries and are accessible by transfer request only. While siting high-performing magnet schools in low-income areas can help increase access to opportunity, research has shown that low-income families are less likely to apply due to a lack of time and information to navigate the school application process. 948 of 955
2 was approved or built was located in areas that are zoned for lower-performing schools (Figure 4). Additionally, according to the draft Sites Inventory for the 6th Cycle Housing Element (2023-2031), most sites identified for potential development are located in areas zoned for lower-performing schools (Figure 5). While the City may be concerned about building affordable housing in areas near high-performing schools due to a relative lack of public transportation, it is important to note that many low-income families have vehicles and do not rely on public transportation. Patterns of Housing Choice Voucher utilization also perpetuate housing and school segregation. Voucher holders are more concentrated in areas zoned for lower-performing schools, likely because those areas remain more affordable or accessible (Figure 6). Affordable housing strategies that increase access to high-performing schools can simultaneously address housing and educational equity. Housing is made more equitable because high-performing schools tend to be located in high-opportunity neighborhoods with other amenities like good jobs, safe public spaces, and clean air that facilitate positive long-term outcomes. Education is made more equitable because increasing access to high performing schools promotes school integration, which has long-term educational and economic benefits for low-income students and students of color, and social and civic benefits for all students.5 Furthermore, the benefits of school and housing integration extend across generations – children who attend integrated schools are more likely to live in integrated neighborhoods and send their children to integrated schools as adults.6 The current moment offers a unique opportunity for the City of San Mateo to meet its goals of housing affordability and equity while promoting school integration. The City has made achieving housing equity and access for all residents a priority of its 2023-2031 Housing Element. SMFCSD has demonstrated a similar commitment to equity through the recent creation of its Equity Task Force. Additionally, the federal Affirmatively Furthering Fair Housing (AFFH) rule and the State of California’s AFFH law have introduced stronger requirements and accountability for cities to address segregation through their housing policies. The following strategies are recommended for incorporation into the 2023-2031 Housing Element: 1. Increase affordable housing, especially multi-family housing that can accommodate families with school-aged children, in areas near high-performing schools. a. Purchase existing multi-family rental properties near high-performing schools and support developers to remove them from the market and restrict them as permanently affordable housing. b. Acquire land near high-performing schools and facilitate development of affordable housing on those sites. 5 Johnson, Rucker C. 2019. Children of the Dream: Why School Integration Works. New York: Basic Books; Turner, Margery Austin, Matthew M. Chingos, and Natalie Spievack. (2021). White People’s Choices Perpetuate School and Neighborhood Segregation: What Would It Take to Change Them? Washington, DC: Urban Institute. 6 Braddock, Jomills H., II, and Amaryllis Del Carmen Gonzalez. (2010). “Social Isolation and Social Cohesion: The Effects of K-12 Neighborhood and School Segregation on Intergroup Orientations.” Teachers College Record 112 (6): 1631–53; Goldsmith, Pat Rubio. 2010. “Learning Apart, Living Apart: How the Racial and Ethnic Segregation of Schools and Colleges Perpetuates Residential Segregation.” Teachers College Record 112 (6): 1602–30. 949 of 955
3 c. Target areas near high-performing schools for upzoning to enable denser construction. d. Increase inclusionary zoning requirements in areas near high-performing schools to generate additional affordable units. 2. Work with the County of San Mateo to strengthen housing policies and supports that help low-income families live in areas near high-performing schools. a. Pair new housing units built in areas near high-performing schools with project-based vouchers (PBVs) to ensure their long-term affordability. b. Provide voucher holders with information about units near high-performing schools through mobility counseling. c. Increase voucher exception payment standards for areas near high-performing schools to the highest level possible to ensure that the level of assistance is sufficient to afford rent in expensive areas. d. Remove barriers to moving to neighborhoods with high-performing schools by providing families with grants for security deposits and moving expenses. e. Incorporate voucher waitlist preference for families with young children to maximize the effects of moving to high-opportunity neighborhoods and enrolling in high-performing schools. f. Increase the value of the cash payments offered to landlords through San Mateo County’s Landlord Incentive Programs to landlords who rent properties near high-performing schools to voucher holders. g. Increase the level of first-time homeowner downpayment assistance offered to families buying homes near high-performing schools in order to increase the feasibility of moving into more expensive neighborhoods. 3. Increase coordination between the Planning Division, SMFCSD, and SamTrans to pursue strategies that increase access to high-performing schools for marginalized students. a. Collaborate with SMFCSD to identify priority for students who live in subsidized housing or underserved areas in the school assignment policy. b. Collaborate with SMFCSD and SamTrans to ensure the provision of efficient transportation options for students who want to attend high-performing schools outside their neighborhood. While these strategies have the potential to substantially improve both housing and educational equity, they should not take the place of investment in housing and schools in low-income and Latinx communities in San Mateo. These investments have opportunity-enhancing effects on the surrounding area and are critical for meeting the needs of people who cannot or do not want to move.7 Simultaneous pursuit of the coordinated housing and school integration strategies outlined in this letter and investment in historically disinvested neighborhoods is the most promising path to equity. Additionally, the City must couple these policies with strong anti-displacement protections to ensure that 7 Diamond, R., & McQuade, T. (2019). Who Wants Affordable Housing in Their Backyard? An Equilibrium Analysis of Low-Income Property Development. Journal of Political Economy, 127(3), 1063-1117. 950 of 955
4 gentrification pressures do not reduce school diversity by pushing Latinx and low-income students out of schools. Again, I applaud the prioritization of equity in San Mateo’s draft 2023-2031 Housing Element. I welcome the opportunity to further discuss the recommendations in this letter with you and your colleagues. Thank you for your consideration. Sincerely, Natalie Spievack Master of City Planning Candidate University of California, Berkeley 951 of 955
5 Appendix FIGURE 1 School Ratings Within Each School Assignment Boundary, SMFCSD Source: San Mateo-Foster City School District (2022); GreatSchools (2022). 952 of 955
6 FIGURE 2 Median Family Income as a Percent of Area Family Median Income Source: PolicyMap using American Community Survey 5-Year Estimates (2015-2019). FIGURE 3 Percent Hispanic or Latino Source: PolicyMap using American Community Survey 5-Year Estimates (2015-2019). 953 of 955
7 FIGURE 4 Major Affordable Housing Developments Approved During the 2015-2023 Housing Element Cycle and Rating of Zoned Elementary School Notes: Kiku Crossing marked as “dispersed” because it is located in North Central San Mateo, where students are assigned to various elementary schools throughout San Mateo. Source: Google Earth using the City of San Mateo’s Draft 2023-2031 Housing Element; GreatSchools (2022). FIGURE 5 Draft Sites Inventory for 2023-2031 Housing Element and Rating of Zoned Elementary School Source: City of San Mateo’s Draft 2023-2031 Housing Element; GreatSchools (2022).

Dispersed Sunnybrae - 3 Sunnybrae - 3
Sunnybrae - 3 Parkside - 4
Sunnybrae - 3
Laurel - 4
Audubon - 6 Foster City - 9 Dispersed
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8 FIGURE 6 Number of Households with Housing Choice Vouchers Source: PolicyMap using American Community Survey 1-Year Estimates (2020). 955 of 955

San Mateo City CouncilMay 23, 2022

San Mateo City Council
May 23, 2022