CITY OF SAN MATEO
City Council Special Meeting
November 7, 2022
5:30 PM
Council Chambers
Entrance is on O’Farrell Street
COUNCIL MEMBERS
Rick Bonilla, Mayor
Diane Papan, Deputy Mayor
Joe Goethals
Amourence Lee
Eric Rodriguez
AGENDA
THIS MEETING IS BEING HELD PURSUANT TO THE GOVERNOR’S EXECUTIVE ORDERS WHICH SUSPEND CERTAIN REQUIREMENTS OF THE BROWN ACT.
THIS MEETING CAN BE ATTENDED IN PERSON OR REMOTE BY JOINING ZOOM – SEE CODES BELOW.
PUBLIC COMMENTS WILL BE ACCEPTED BOTH IN PERSON AND REMOTEL Y.
SEE END OF AGENDA FOR OPTIONS AND INSTRUCTIONS ON HOW TO PARTICIPATE IN THE MEETING.
To join via Zoom – click here:
November 7, 2022
To join via telephone: (408) 638-0968
Webinar ID: 846 1126 2690 Passcode: 577823
CALL TO ORDER
Roll Call
CLOSED SESSION
The public will have an opportunity to comment before the consideration of these items. Following the meeting a report of action from Closed Session will be provided if required.
1. Conference with Legal Counsel – Existing Litigation, Workers' Compensation (Paragraph (1) of subdivision (d) of Government Code Section 54956.9 Name of claimant: William Davenport
STUDY SESSION
The public will have an opportunity to comment during the consideration of these items.
2. Draft 2023-2031 Housing Element Study Session
Provide staff direction on responses to the California Department of Housing and Community Development’s comment letter on the City’s Draft Housing Element.
CEQA: This study session is not a project subject to CEQA, because it can be seen with certainty that it will not cause a physical change in the environment. (Public Resources Code Section 21065.)
ADJOURNMENT
----------------------------------------------------------------------------------------------------------------------------- AGENDAS:
Agendas and material are posted on the City’s website on the Friday preceding each Council Meeting and can be viewed on the City's website at
www.cityofsanmateo.org
. Any supplemental material distributed to the Council after the posting of the agenda will be made part of the official record.
WATCHING A MEETING ON TV:
City Council meetings are broadcast live on Comcast/channel 27, Wave/channel 26, or AT&T/channel 99.
For transmission problems during the broadcast, please call (650) 522-7099. For all other broadcast comments, call (650) 522-7040, Monday-Friday, 8 a.m. - 5 p.m.
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WATCHING A MEETING ON A COMPUTER:
There are three ways to stream.
1) Public Meeting Portal
www.cityofsanmateo.org/publicmeetings
2) City YouTube channel and stream it on YouTube:
http://youtube.com/CityofSanMateo
3) Watch TV live stream:
https://www.cityofsanmateo.org/193/Channel-San-Mateo-Live-Stream
PUBLIC COMMENTS/REQUEST TO SPEAK
Prior to the Meeting
Send comments to:
[email protected]
until 4 p.m. the day of the meeting.
During the meeting
By Zoom:
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Call (408) 638-0968 and enter the conference ID found at the top of the meeting agenda. When the item of interest is open for consideration, select *9 to raise your hand. When called upon, press *6 to unmute, state your name and provide your comments.
In Person:
At the meeting complete a “Request to Speak” form, submit a request at the speaker kiosk or scan the QR code.
ACCESSIBILITY:
In compliance with the Americans with Disabilities Act, those with disabilities requiring special accommodations to participate in this meeting may contact the City Clerk’s Office at (650) 522-7040 or [email protected]
. Notification 48 hours prior to the meeting will
enable the City to make reasonable arrangements to ensure accessibility to this meeting.
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CITY OF SAN MATEO
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CITY OF SAN MATEO
Agenda Report
City Hall
330 W. 20th Avenue
San Mateo CA 94403
www.cityofsanmateo.org
Agenda Number: 2 Section Name: STUDY SESSION Account Number: 10-3133 File ID: 22-6785 TO: City Council
FROM: Drew Corbett, City Manager
PREPARED BY: Community Development Department
MEETING DATE: November 07, 2022
SUBJECT:
Draft 2023-2031 Housing Element Study Session
RECOMMENDATION:
Provide staff direction on responses to the California Department of Housing and Community Development’s comment letter on the City’s Draft Housing Element.
BACKGROUND:
Since 1969, California has required that all local governments (cities and counties) adequately plan to meet the housing needs of their community. California’s local governments meet this requirement by adopting housing elements, which are updated every 5-8 years. Housing elements are one of several "chapters,” or elements, of a city’s General Plan, and are required by the State. Housing elements are the only element of a General Plan subject to State requirements for content and they must be certified by the California Department of Housing and Community Development (HCD). State funding programs for transportation, infrastructure, and housing often require or consider in decision making a local jurisdiction’s compliance with housing element law. In addition, non-compliance with housing element requirements and targets could limit a local jurisdiction’s ability to impose local zoning and land use controls over housing development.
For the upcoming eight-year housing element cycle (2023-2031), HCD has identified the nine-county Bay Area region’s housing need to be 441,176 units, with this number broken down into four income categories, from very low-income households (which includes extremely low) to above moderate (market rate) housing. This Regional Housing Needs Determination (RHND) is based on population projections produced by the California Department of Finance (DOF), as well as adjustments that incorporate the region’s existing housing need.
The City of San Mateo’s Regional Housing Needs Allocation (RHNA) for this housing cycle is 7,015 new housing units distributed across the four income groups: very low, low, moderate and above moderate. The City’s Draft Housing Element identifies how the City can accommodate its RHNA of 7,015 new homes over the next eight years, plus a buffer, and establishes goals, policies and programs to help address the City’s current and future housing needs.
Preparation of the City’s Housing Element initially started in January 2021, with a robust community engagement process consisting of community meetings, stakeholder meetings, pop-up events, and surveys. The Draft Housing Element was published from April 6, 2022 through May 6, 2022 for a 30-day Public Comment Period and was reviewed by the Planning Commission on April 26, 2022 and May 3, 2022. On May 23, 2022, the City Council reviewed the Draft Housing Element and provided staff direction. Staff revised the Draft based on Council’s direction and on July 1, 2022, the Draft 2023-2031 Housing Element was submitted to HCD. HCD completed their first 90-day review and provided a comment letter on September 28, 2022, with feedback based on their review (Attachment 1).
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HCD Comment Matrix
HCD’s comment letter requested additional background information and further analysis in several areas of the Housing Element, including the feasibility of future housing sites, fair housing policy, housing goals, policies and programs, and removing constraints to building housing. The Housing Element team prepared the attached HCD Comment Matrix, which outlines each of the comments by section (Attachment 2). Several of the specific HCD comments have the potential to change the nature of the goals, policies and programs, which have already been reviewed by Council and were prepared with Council feedback. Some of the specific comments include:
•Needs Analysis – Providing more detailed timelines and commitments on the Affirmatively Furthering Fair Housing (AFFH) Goals, Actions, Metrics and Milestones.
•Constraints – Creating a program to include outreach and mitigation measures for the impact of Measure Y on housing development throughout the planning period.
•Goals, Policies and Programs (GPP) – Providing more detailed timelines and commitments on actions for various GPPs.
More detailed information on HCD’s specific comments and proposed staff responses by Housing Element section are available in the matrix.
Builder’s Remedy
There have been recent press reports regarding the “Builder’s Remedy” that can be used to avoid local zoning requirements when a jurisdiction’s housing element does not substantially comply with State law. These reports have stated that if a jurisdiction has a noncompliant housing element, the city or county must approve the housing development project, even if it does not comply with the General Plan and Zoning requirements. The “Builder’s Remedy” arises from the Housing Accountability Act (HAA).
Housing elements are required to comply with current State housing element law for the sixth housing cycle (2023-2031) on the established due date, which is January 31, 2023, for the Bay Area region. If a sixth cycle element has not been locally adopted by this deadline, the housing element would likely be deemed out of compliance with State law by HCD.
Up until recently, it was a widely held assumption that the 120-day grace period outlined in State law would apply to housing elements still being reviewed by HCD or being updated by local jurisdictions in response to HCD comments.
However, HCD has recently taken the position that the grace period does not apply beyond the January 31, 2023 deadline, and any jurisdiction without an adopted sixth cycle housing element would be deemed out of compliance and subject to development applications utilizing the “Builder’s Remedy” provision in the HAA.
However, it should be noted that HCD certification is not required for a housing element to be found substantially compliant with State law. State law provides that a local jurisdiction may adopt its own findings explaining why its housing element is substantially compliant with State law despite HCD’s findings. Thus, a local jurisdiction can continue to work with HCD to achieve certification of its adopted housing element after the deadline without being deemed out of compliance. That said, the goal of staff is to continue to work closely with HCD throughout the review process in order to ensure that the adopted housing element legally complies with State law.
Next Steps
Given the January 31, 2023 deadline to adopt a substantially compliant housing element, staff is proposing the next steps and anticipated timeline for approval and certification of the Housing Element as follows:
•November/December 2022 – Update the Draft Housing Element in response to HCD comments and resubmit for second review.
•January 2023 – Public hearings before the Planning Commission for a recommendation on the Housing Element and the City Council to adopt Housing Element.
•End of January 2023 – Submit the adopted Housing Element to HCD for certification.
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Once the Draft Housing Element has been updated to address all HCD comments, public hearings before the Planning Commission and City Council will be scheduled for final review and adoption, which will be scheduled before the January 31, 2023 deadline. Following City Council adoption, it will be submitted to HCD for final certification.
Council Direction
As previously mentioned, HCD provided several comments that could result in significant changes to the goals, policies and programs that Council has previously reviewed and provided their feedback on. Staff is seeking Council direction on whether they have any objections in staff taking the necessary steps to strengthen the language in the draft Housing Element to address HCD’s comments. Addressing HCD’s comments will bring the City closer to submitting a substantially compliant housing element by the January 31, 2023 deadline.
BUDGET IMPACT:
There are no direct budgetary impacts to taking this action. The preparation of the Housing Element has been accounted for in the City’s budget.
ENVIRONMENTAL DETERMINATION:
This study session is not a project subject to CEQA, because it can be seen with certainty that it will not cause a physical change in the environment. (Public Resources Code Section 21065.) Since the Housing Element does not require the City to process any land use or zoning designation amendments, it is currently anticipated that the Housing Element can be processed with an exemption under CEQA (California Code of Regulations Section 15061(b)(3)). Preparation of documentation to support this CEQA determination will be provided prior to consideration of the Housing Element by the Planning Commission and City Council for adoption early next year.
NOTICE PROVIDED
All meeting noticing requirements were met.
ATTACHMENTS
Att 1 - HCD Comment letter on Draft 2023-2031 Housing Element Att 2 - HCD Comment Matrix
STAFF CONTACT
Eloiza Murillo-Garcia, Housing Manager
[email protected]
(650) 522-7223
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PLEASE NOTE:
Housing element technical assistance information is available on HCD’s website at https://www.hcd.ca.gov/planning-and-community-development/hcd-memos. Among other resources, the housing element section contains HCD’s latest technical assistance tool, Building Blocks for Effective Housing Elements (Building Blocks), available at https://www.hcd.ca.gov/planning-and-community-development/housing-elements/building- blocks and includes the Government Code addressing State Housing Element Law and other resources.
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STATE OF CALIFORNIA - BUSINESS, CONSUMER SERVICES AND HOUSING AGENCY GAVIN NEWSOM, Governor
DEPARTMENT OF HOUSING AND COMMUNITY DEVELOPMENT
DIVISION OF HOUSING POLICY DEVELOPMENT
2020 W. El Camino Avenue, Suite 500
Sacramento, CA 95833
(916) 263-2911 / FAX (916) 263-7453
www.hcd.ca.gov
September 28, 2022
Christina Horrisberger, Director
Director of Community Department
City of San Mateo
330 West 20
th Avenue
San Mateo, CA 94403
Dear Christina Horrisberger:
RE: City of San Mateo’s 6
th Cycle (2023-2031) Draft Housing Element
Thank you for submitting the City of San Mateo’s (City) draft housing element received for review on July 1, 2022. Pursuant to Government Code section 65585, subdivision (b), the California Department of Housing and Community Development (HCD) is reporting the results of its review. Our review was facilitated by a conversation on August 31, 2022 with yourself, Zachary Dahl, Eloiza Murillo-Garcia, Manira Sandhir, Nicholas Vu, and consultant Diana Elrod. In addition, HCD considered comments from Housing Leadership Council, YIMBY Law and Greenbelt Alliance, One San Mateo,
Adam Nugent, and Adam Buchbinder pursuant to Government Code section 65585, subdivision (c).
The draft element addresses many statutory requirements; however, revisions will be necessary to comply with State Housing Element Law (Article 10.6 of the Gov. Code).
The enclosed Appendix describes the revisions needed to comply with State Housing Element Law.
Public participation in the development, adoption and implementation of the housing element is essential to effective housing planning. Throughout the housing element process, the City should continue to engage the community, including organizations that represent lower-income and special needs households, by making information regularly available and considering and incorporating comments where appropriate. Please be aware, any revisions to the element must be posted on the local government’s website and to email a link to all individuals and organizations that have previously requested notices relating to the local government’s housing element at least seven days before submitting to HCD.
For your information, pursuant to Assembly Bill 1398 (Chapter 358, Statutes of 2021), if a local government fails to adopt a compliant housing element within 120 days of the statutory deadline (January 31, 2023), then any rezoning to accommodate the regional
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Christina Horrisberger, Director
housing needs allocation (RHNA), including for lower-income households, shall be completed no later than one year from the statutory deadline. Otherwise, the local government’s housing element will no longer comply with State Housing Element Law, and HCD may revoke its finding of substantial compliance pursuant to Government Code section 65585, subdivision (i).
Several federal, state, and regional funding programs consider housing element compliance as an eligibility or ranking criteria. For example, the CalTrans Senate Bill (SB) 1 Sustainable Communities grant; the Strategic Growth Council and HCD’s Affordable Housing and Sustainable Communities programs; and HCD’s Permanent Local Housing Allocation consider housing element compliance and/or annual reporting requirements pursuant to Government Code section 65400. With a compliant housing element, the City will meet housing element requirements for these and other funding sources.
We are committed to assist the City in addressing all statutory requirements of State Housing Element Law. If you have any questions or need additional technical assistance, please contact Hillary Prasad, of our staff, at [email protected] .
Sincerely,
Paul McDougall
Senior Program Manager
Enclosure
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APPENDIX
CITY OF SAN MATEO
The following changes are necessary to bring the City’s housing element into compliance with Article 10.6 of the Government Code. Accompanying each recommended change, we cite the supporting section of the Government Code.
Housing element technical assistance information is available on HCD’s website at https://www.hcd.ca.gov/hcd-memos
. Among other resources, the housing element section
contains HCD’s latest technical assistance tool, Building Blocks for Effective Housing Elements (Building Blocks), available at
https://www.hcd.ca.gov/building-blocks and includes the Government Code addressing State Housing Element Law and other resources.
A. Review and Revision
Review the previous element to evaluate the appropriateness, effectiveness, and progress in implementation, and reflect the results of this review in the revised element. (Gov. Code, § 65588 (a) and (b).)
The review requirement is one of the most important features of the element update. The review of past programs should analyze the City's accomplishments over the previous planning period. This information provides the basis for developing an effective housing program.
A thorough program-by-program review is necessary to evaluate City's performance in addressing housing goals. While the element describes actual results of the prior element’s programs, it must provide a description of how the objectives and programs of the updated element incorporate changes resulting from the evaluation.
As part of the evaluation of programs in the past cycle, the element must analyze the effectiveness of goals, policies, and related actions in meeting the housing needs of special needs populations (e.g., elderly, persons with disabilities, large households, female headed households, farmworkers and persons experiencing homelessness). Programs should be revised as appropriate to reflect the results of this evaluation.
B. Housing Needs, Resources, and Constraints
1. Affirmatively further[ing] fair housing in accordance with Chapter 15 (commencing with Section 8899.50) of Division 1 of Title 2…shall include an assessment of fair housing in the jurisdiction. (Gov. Code, § 65583, subd. (c)(10)(A).)
Fair Housing Issues: The element must include other relevant factors that contribute to fair housing issues in the jurisdiction. For instance, the element can analyze historical land use and investment practices or other information and demographic trends.
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Enforcement: While the element lists fair housing laws in Appendix D, it must state whether the City complies with federal and state fair housing laws. If the City does not currently comply, a program should be added as appropriate.
Integration and Segregation: The element provided some data regarding segregation and integration of race, disability, familial status, and income. The element must describe the census tracts that have geographic concentrations of race (i.e., concentrations identified as white majority). In addition, the element must discuss and analyze data on persons with disabilities for trends over time and patterns across census tracts as well as evaluate patterns at a regional basis, comparing the City to the region. The element must also include a local and regional analysis of integration and segregation for familial status.
Lastly, the element must describe and analyze concentrations of income geographically throughout the City.
Racial/Ethnic Areas of Concentration of Poverty and Affluence (R/ECAP): The element includes information relative to R/ECAP within the City but should also analyze where they are in the region. The element must also address concentrated areas of affluence both locally and regionally. The combination of the R/ECAP and areas of affluence analyses will help guide goals and actions to address fair housing issues. The analysis should evaluate the patterns and changes over time at a local (e.g., neighborhood to neighborhood) and regional level (e.g., city to region).
Disproportionate Housing Needs including Displacement: While the element includes some data on disproportionate needs, additional information is needed. The element must describe any geographic concentration of cost burden and overcrowding by tenure, as well as any concentrations of substandard housing both locally and regionally. In addition, the element must describe and analyze the census tracts with displacement risk. While the map depicts a lot of areas vulnerable to displacement, this must be supported with an analysis.
Sites Inventory: While the element includes a summary of some factors, the analysis must identify whether sites improve or exacerbate conditions and whether sites are isolated by income group. A full analysis should address the income categories of identified sites with respect to location, the number of sites and units by all income groups and how that affects the existing patterns for all components of the assessment of fair housing (e.g., segregation and integration, access to opportunity). If sites exacerbate conditions, the element should identify further program actions that will be taken to promote equitable quality of life throughout the community (e.g., anti-displacement and place-based community revitalization strategies).
Contributing Factors: The element identifies many contributing factors to fair housing issues. The element must prioritize these factors to better formulate policies and programs and carry out meaningful actions to Affirmatively Furthering Fair Housing (AFFH). In addition, the element must describe how the actions in Appendix D Fair Housing Plan are tied to the housing element programs and include implementation.
Goals, Actions, Metrics, and Milestones: The element must be revised to add or modify goals and actions based on the outcomes of a complete analysis. Goals and actions must
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specifically respond to the analysis and to the identified and prioritized contributing factors to fair housing issues and must be significant and meaningful enough to overcome identified patterns and trends. Actions must have specific commitment, 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.
2. Include an analysis of population and employment trends and documentation of projections and a quantification of the locality's existing and projected needs for all income levels, including extremely low-income households. (Gov. Code, § 65583, subd. (a)(1).)
Extremely Low-Income Households (ELI): The element must quantify the number of existing and projected ELI households, and also analyze their housing needs. The analysis of ELI housing needs should consider tenure and rates of overpayment.
3. Include an analysis and documentation of household characteristics, including level of payment compared to ability to pay, housing characteristics, including overcrowding, and housing stock condition. (Gov. Code, § 65583, subd. (a)(2).)
Overpayment: The element must quantify and analyze the number of lower-income households overpaying by tenure (i.e., renter and owner).
Housing Costs: While the element includes estimated rents for residents, it utilizes American Community Survey (ACS) data. The element should supplement census data with other sources (e.g., local knowledge).
4. An inventory of land suitable and available for residential development, including vacant sites and sites having realistic and demonstrated potential for redevelopment during the planning period to meet the locality’s housing need for a designated income level, and an analysis of the relationship of zoning and public facilities and services to these sites. (Gov.
Code, § 65583, subd. (a)(3).)
Progress in Meeting the Regional Housing Need Allocation (RHNA): The City’s RHNA may be reduced by the number of new units built since June 30, 2022; however, the element must demonstrate their affordability based on actual sales price, rent level or other mechanisms ensuring affordability (e.g., deed restrictions). The element should also discuss the status, any barriers to development and other relevant factors to demonstrate their availability in the planning period.
Realistic Capacity: While the element provides assumptions of buildout for sites included in the inventory, it must also provide support for these assumptions. For example, the element should demonstrate what specific trends, factors, and other evidence led to the assumptions. The estimate of the number of units for each site must be adjusted as necessary, based on the land use controls and site improvements and typical densities of existing or approved residential developments at a similar affordability level. The element currently assumes realistic capacity at 100 percent of base zoned density for multifamily units in R-3, R-4, and R-5 zones. The analysis must provide substantial support and demonstrate a history of developing at maximum density within the City. Examples to support realistic capacity assumptions should also include affordability levels, and percent of maximum densities.
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The calculation of residential capacity must also account for the likelihood of residential development in zoning where 100 percent nonresidential uses are allowed. The analysis should be based on factors such as development trends including nonresidential, performance standards requiring residential uses or other relevant factors such as enhanced policies and programs. For example, the element could analyze all development activity in these nonresidential zones, how often residential development occurs and adjust residential capacity calculations, policies, and programs accordingly.
Small and Large Sites: Sites smaller than an half acre and larger than 10 acres in size are deemed inadequate to accommodate housing for lower-income housing unless it is demonstrated that sites of equivalent size were successfully developed during the prior planning period for an equivalent number of lower-income housing units as projected for the site or unless the housing element describes other evidence to HCD that the site is adequate to accommodate lower-income housing (Gov. Code, § 65583.2, subd. (c)(2)(A).). For example, a site with a proposed and approved housing development that contains units affordable to lower-income households would be an appropriate site to accommodate housing for lower-income households. (Gov. Code, § 65583.2, subd. (c)(2)(C).) In addition, the element must describe feasibility of the Hillsdale and Bridgepointe sites including likelihood of development during the planning period, whether a specific plan is needed, and if the existing uses will remain. Lastly the element must describe a history of lot consolidation as a method of developing housing as well as whether the City has any incentives to consolidate lots with different owners.
Suitability of Nonvacant Sites: The element must include an analysis demonstrating the potential for redevelopment of nonvacant sites. To address this requirement, the element describes in general the existing use of each nonvacant site, for example, “commercial” or “parking lot”. This alone is not adequate to demonstrate the potential for redevelopment in the planning period. The description of existing uses should be sufficiently detailed to facilitate an analysis demonstrating the potential for additional development in the planning period. In addition, the element must analyze the extent that existing uses may impede additional residential development. For example, the element includes sites identified as parking lots, church, gas station, an auto repair, and a warehouse; but must also demonstrate whether these existing uses would impede development of these sites within the planning period. The element can summarize past experiences converting existing uses to higher density residential development, include current market demand for the existing use, provide analysis of existing leases or contracts that would perpetuate the existing use or prevent additional residential development and include current information on development trends and market conditions in the City and relate those trends to the sites identified. The element could also consider indicators such as age and condition of the existing structure, expressed developer interest, existing versus allowable floor area, low improvement to land value ratio, and other factors.
In addition, as noted in the housing element, the housing element relies upon nonvacant sites to accommodate more than 50 percent of the RHNA for lower-income households.
For your information, the housing element must demonstrate existing uses are not an impediment to additional residential development and will likely discontinue in the planning
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period (Gov. Code, § 65583.2, subd. (g)(2).). Absent findings (e.g., adoption resolution) based on substantial evidence, the existing uses will be presumed to impede additional residential development and will not be utilized toward demonstrating adequate sites to accommodate the regional housing need allocation.
City-Owned Sites: The element must include additional discussion on each of the City- owned sites identified to accommodate the RHNA. Specifically, the analysis should address general plan designations, allowable densities, support for residential capacity assumptions, existing uses and any known conditions that preclude development in the planning period and the potential schedule for development. If zoning does not currently allow residential uses at appropriate densities, then the element must include programs to rezone sites pursuant to Government Code section 65583.2, subdivisions (h) and (i). In addition, the housing element must include a description of whether there are any plans to sell the property during the planning period and how the jurisdiction will comply with the Surplus Land Act Article 8 (commencing with Section 54220) of Chapter 5 of Part 1 of Division 2 of Title 5.
Replacement Housing Requirements: If the sites inventory identifies sites with existing residential uses, it must identify whether the current residential uses are affordable to lower-income households or describe whether the additional residential development on the site requires the demolition of the existing residential use. For nonvacant sites with existing, vacated, or demolished residential uses and occupied by, or subject to an affordability requirement for, lower-income households within the last five years there must be a replacement housing program for units affordable to lower-income households. (Gov.
Code, § 65583.2, subd. (g)(3).) Absent a replacement housing program, these sites are not adequate sites to accommodate lower-income households. The replacement housing program has the same requirements as set forth in Government Code section 65915, subdivision (c)(3). The housing element must be revised to include such analysis and a program, if necessary.
Previously Identified Nonvacant and Vacant Sites: If nonvacant sites identified in a prior adopted housing element or vacant sites identified in two or more consecutive planning periods, the sites are inadequate to accommodate housing for lower-income households unless:
• The site’s current zoning is appropriate for the development of housing affordable to lower-income households by either including analysis or meeting the appropriate density and
• The site is subject to a housing element program that requires rezoning within three years of the beginning of the planning period to allow residential use by right for housing developments in which at least 20 percent of the units are affordable to lower-income households. (Gov. Code, § 65583.2, subd. (c).)
Accessory Dwelling Units (ADU): The element projects 480 ADUs over the planning period or approximately 60 ADUs per year over the eight-year planning period. The element also notes permitting 44 ADUs in 2019, 47 in 2020, and 66 in 2021. The trend does not consider the number of permits in 2018 (eight ADUs) and does not support an assumption
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of 60 ADUs per year. To support assumptions for ADUs in the planning period, the element should reduce the number of ADUs assumed per year and reconcile trends with HCD records, including additional information such as more recent permitted units and inquiries, resources and incentives, other relevant factors and modify policies and programs as appropriate. Further, programs should commit to additional incentives and strategies, frequent monitoring (every other year) and specific commitment to adopt alternative measures such as rezoning or amending the element within a specific time (e.g., six months) if needed.
AB 725: For jurisdictions that are considered Metropolitan, the element must identify at least 25 percent of the remaining moderate and above moderate RHNA on sites that allow at least four units of housing (e.g., four plex or greater) (Gov. Code, § 65583.2, subd. (c)(4)).
Infrastructure: While the element includes a general discussion on water and sewer capacity, it must demonstrate sufficient existing or planned water and sewer capacity to accommodate the City’s regional housing need for the planning period. (Gov. Code, § 65583.2, subd. (b).). In addition, the element generally mentions infrastructure constraints for infill development. The element must describe and analyze the constraints as well as their impacts on the identified sites to meet the RHNA.
For your information, water and sewer service providers must establish specific procedures to grant priority water and sewer service to developments with units affordable to lower-income households. (Gov. Code, § 65589.7.) Local governments are required to immediately deliver the housing element to water and sewer service providers. HCD recommends including a cover memo describing the City ’s housing element, including the City’s housing needs and regional housing need. The element should demonstrate compliance with these requirements and add or modify programs, if necessary. For additional information and sample cover memo, see the Building Blocks at https://www.hcd.ca.gov/priority-for-water-and-sewer
.
Environmental Constraints: While the element generally describes a few environmental conditions within the City (p. H-B-44), it must relate those conditions to identified sites and describe any other known environmental or other constraints that could impact housing development on identified sites in the planning period.
Zoning for a Variety of Housing Types:
• Emergency Shelters: The housing element must demonstrate the permit processing, development, and management standards for emergency shelters are objective and encourage and facilitate the development of, or conversion to, emergency shelters. In particular, the element describes development standards for emergency shelters; however these standards are beyond the development standards allowed under housing element law. The element must demonstrate that emergency shelters are subject to the same development and management standards applicable to residential or commercial development within the same zone except for those standards prescribed by Government Code section 65583 (a)(4)(A). The element must also clarify that emergency shelters are allowed
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without discretionary action in the C2 zone and describe sufficient and suitable capacity in the identified zone. In addition, the element should describe how emergency shelter parking requirements comply with AB139/Government Code section 65583, subdivision (a)(4)(A) or include a program to comply with this requirement.
• Low Barrier Navigation Centers: While the element includes a program to allow Low Barrier Navigation Centers, it is limited to emergency shelter zones. Low Barrier Navigation Centers shall be a use by-right in zones where multifamily and mixed uses are permitted, including nonresidential zones permitting multifamily uses pursuant to Government Code section 65660. The element must demonstrate compliance with this requirement and include programs as appropriate. • Single Room Occupancy (SRO) Units: The element must describe where SROs are allowed or add a program as appropriate.
• Manufactured Housing: The element must clarify whether manufactured homes are subject to additional regulations beyond state law if on a permanent foundation and add a program as needed.
• Accessory Dwelling Unit (ADU): The element indicates the City modifies its zoning code to ease barriers to the development of ADU’s. However, after a cursory review of the City’s ordinance, HCD discovered several areas which are not consistent with State ADU Law. HCD will provide a complete listing of ADU non-compliance issues under a separate cover. As a result, the element should add a program to update the City’s ADU ordinance in order to comply with state law. For more information, please consult HCD’s ADU Guidebook, published in December 2020, which provides detailed information on new state requirements surrounding ADU development.
5. An analysis of potential and actual governmental constraints upon the maintenance, improvement, or development of housing for all income levels, including the types of housing identified in paragraph (1) of subdivision (c), and for persons with disabilities as identified in the analysis pursuant to paragraph (7), including land use controls, building codes and their enforcement, site improvements, fees and other exactions required of developers, and local processing and permit procedures... (Gov. Code, § 65583, subd. (a)(5).)
Land Use Controls: The element must identify and analyze all relevant land use controls impacts as potential constraints on a variety of housing types. The analysis should analyze land use controls independently and cumulatively with other land use controls. The analysis should specifically address requirements related to parking, heights, lot coverage and limits on allowable densities. The analysis should address any impacts on cost, supply, housing choice, affordability, timing, approval certainty and ability to achieve maximum densities and include programs to address identified constraints. The element must analyze the maximum heights of 35 feet in multifamily zones and whether three-story buildings are allowed as well as whether allowed densities can be met in the TOD Hillsdale Station with a 24-foot height restriction. The element should also analyze the open space requirements for the R-3 zone. In addition, the element should analyze requiring more than one parking space for studio and one-bedroom units and the minimum requirement of 2.2 spaces for 1,400 square foot units regardless of bedroom size and add programs to specifically address the constraints. In addition, the element should clarify
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how multifamily developments are allowed in the E and C zones and whether they require a use permit. Both in the element and in public comments, height restrictions, floor area definitions, maximum densities of 50 dwelling units an acre, and design review guidelines were identified as constraints to development and should be addressed in programs as appropriate.
Fees and Exaction: The element must describe all required fees for single family and multifamily housing development, including impact fees, and analyze their impact as potential constraints on housing supply and affordability. For example, the analysis could identify the total amount of fees and their proportion to the development costs for both single family and multifamily housing. While Table 4 lists fee deposits, the element should also include typical fees for each and clarify whether the fees are the same for single family and multifamily developments. The element should also identify fees related to annexation, variances, conditional use permits (CUP), general plan amendments, zone changes, site plan review, planned unit developments, specific plans, development agreements, and environmental fees. Table 6 should also describe the typical fees as a percent of the total development cost for both single family and multifamily developments and add a program as appropriate.
Local Processing and Permit Procedures: While the element includes information about processing times, it should also describe the procedures for a typical single family and multifamily development. The analysis should address the approval body, the number of public hearing if any, approval findings and any other relevant information, specifically for special use permits, site plans and architectural review (as well as whether finding five is related to a crime free ordinance). The analysis should address impacts on housing cost, supply, timing and approval certainty. The element should identify and analyze approval findings for impacts on approval certainty, the presence of processes or guidelines to promote certainty and add or modify programs as appropriate. The element should also clarify whether the listed typical approval times are for both single family and multifamily developments. Lastly, it should clarify whether the preapplication process adds six to nine months in addition to the typical approval times listed and add or modify programs as appropriate.
Local Ordinances: While the element identifies the City’s community benefit program, it must describe whether the incentives are in addition to state density bonus law. The element must clarify how the 75 dwelling units an acre allowed using the community benefit program interacts with the restricted densities under measure Y. In addition, the element must describe how the inclusionary program, community benefit program, and state density bonus law interact with incentives provided.
Zoning Fees and Transparency: The element must clarify its compliance with new transparency requirements for posting all zoning and development standards, and inclusionary requirements for each parcel on the jurisdiction’s website pursuant to Government Code section 65940.1(a)(1).
Measure Y: The element must describe the impacts of measure Y on height and density restrictions as a constraint on housing development and affordability. The element must add a program to include outreach and mitigation measures for the impact of Measure Y
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on housing development throughout the planning period. The element should analyze the measure as a constraint on development based on site suitability for development.
State Density Bonus Law: The City’s current density bonus ordinance should be reviewed for compliance with current state density bonus law and programs should be added as necessary. (Gov. Code, § 65915.)
Design Review: The element must describe and analyze the design review guidelines and process, including approval procedures and decision-making criteria, for their impact as potential constraints on housing supply and affordability. For example, the analysis could describe required findings and discuss whether objective standards and guidelines improve development certainty and mitigate cost impacts. The element must demonstrate this process is not a constraint or include a program to address this permitting requirement, as appropriate.
On/Off-Site Improvements: The element must identify subdivision level improvement requirements, such as minimum street widths (e.g., 40-foot minimum street width) and analyze their impact as potential constraints on housing supply and affordability.
Constraints on Housing for Persons with Disabilities: The element briefly describes its reasonable accommodation procedures. However, the element should also describe the process and decision-making criteria such as approval findings and analyze any potential constraints on housing for persons with disabilities. In addition, the element states that Policy H.1.14 commits to revise the definition of family, but there are no actions within the program to revise the definition of family to remove constraints. The element must add or revise a program to remove the constraints as noted. Lastly, group homes for seven or more persons appears to be excluded from several zones allowing residential uses and subject to a CUP. The element should evaluate these requirements as constraints and include specific commitment to amend zoning and permit procedures to allow these uses in all residential zones with objectivity to facilitate approval certainty.
6. An analysis of potential and actual nongovernmental constraints upon the maintenance, improvement, or development of housing for all income levels, including… …requests to develop housing at densities below those anticipated in the analysis required by subdivision (c) of Government Code section 65583.2, and the length of time between receiving approval for a housing development and submittal of an application for building permits for that housing development that hinder the construction of a locality’s share of the regional housing need in accordance with Government Code section 65584... (Gov.
Code, § 65583, subd. (a)(6).)
Developed Densities and Permit Times: The element must be revised to include analysis of requests to develop housing at densities below those anticipated, and the length of time between receiving approval for a housing development and submittal of an application for building permits that potentially hinder the construction of a locality’s share of the regional housing need.
7. Analyze any special housing needs such as elderly; persons with disabilities, including a developmental disability; large families; farmworkers; families with female heads of
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households; and families and persons in need of emergency shelter. (Gov. Code, § 65583, subd. (a)(7).)
Special Needs Populations: While the element quantifies the City’s special needs populations, it must also analyze their special housing needs. For a complete analysis of each population group, the element should discuss challenges faced by the population, the existing resources to meet those needs (availability senior housing units, # of large units, # of deed restricted units, etc.), an assessment of any gaps in resources, and proposed policies, programs, and funding to help address those gaps. In addition, the element must quantify and analyze the number of elderly persons in the City.
C. Housing Programs
1. Include a program which sets forth a schedule of actions during the planning period, each with a timeline for implementation, which may recognize that certain programs are ongoing, such that there will be beneficial impacts of the programs within the planning period, that the local government is undertaking or intends to undertake to implement the policies and achieve the goals and objectives of the Housing Element. (Gov. Code, § 65583, subd. (c).)
To address the program requirements of Government Code section 65583, subdivision (c)(1-6), and to facilitate implementation, programs should include: (1) a description of the City’s specific role in implementation; (2) definitive implementation timelines; (..3) objectives, quantified where appropriate; and (4) identification of responsible agencies and officials. Programs to be revised include the following:
• P olicy 1.2 (Utilize Public Funding): This program should include proactive outreach to developers throughout the planning period as well as a geographic target for the metric.
• P olicy 1.4 (Incentivize ADU Development): This program should revise action C to include discrete timing of how often it will be completed and monitored. In addition, action D should include back-up actions if estimates are not met (e.g., identify additional sites or provide additional incentives) as well as monitor affordability. • P olicy 1.5 (Encourage Family Housing): The program should include back-up actions, with specific timing, if the identified incentives are not implemented. • P olicy 1.6 (Streamline Housing Application Review): Action B must include specific timing of when permit application requirements will be updated. In addition, the timing of action C must be completed earlier in the planning period. • Policies 1.15 (Supportive Housing Requirements) and 1.16 (Mobile Home Parks):
These programs must revise timing to be implemented earlier in the planning period for a beneficial impact.
• Policy 1.17 (Farmworker Housing): This program must move up timing to be implemented earlier in the planning period. In addition, the program should cite the government code for farmworker housing.
• Policy 1.18 (Permitting and Development Fee Review): This program must clarify timing in Action A, specifically whether the study will be complete within the
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identified timeframe or if the fees will be reduced by that date. In addition, Action B must specify when the first review will occur and when adjustments will take place. • P olicy 1.19 (Senior Housing): This program must clarify what potential actions will be implemented for seniors as well as whether other special needs groups are included in the program.
• P olicy 2.1 (Housing Rehabilitation Efforts), 2.3 (Energy and Water Efficiency), 3.4 (Expand Tenant Protections), and 4.3 (Community Education and Outreach): This program must describe how often outreach will occur throughout the planning period.
• Policy 3.3 (Evaluate Housing Revenue Sources): This program must describe the implementation component for action A.
• Policy 3.5 (Creation of Below Market Rate Set Asides): This program must add implementation and timing for what will result from the study. • Policy 4.2 (Countywide Below Market Rate Unit Waitlist): This program must clarify how support will be provided as well as how often throughout the planning period. • Policy 4.4 (Enable Affirmative Marketing): Timing must be clarified to state whether the marketing will occur once in the planning, or on a project-by-project basis. • Policy 5.1.2 (Regional Down Payment Assistance): This program should include outreach for education.
• Policy 5.2.2 (Incentivize Developers): This program must clarify whether incentives are in place, timing to implement the incentives, as well as conducting proactive outreach.
• Policy 5.3.2 (Fund Minor Home Repairs): The program should clarify how often outreach will occur as well as specify whether the metrics are annually or throughout the planning period.
• Policy 5.4.2 (Project Sentinel): This program should be revised to include outreach and describe how awareness will be increased.
• Policy 5.4.3 (Fair Housing Webpage): This program should describe how often the website will be updated and whether outreach will be included. • Policy 5.4.5 (Future Improvements in Disadvantaged Communities): This program must include an action to implement the feasibility study as well as a back-up if the study is not implemented.
2. Identify actions that will be taken to make sites available during the planning period with appropriate zoning and development standards and with services and facilities to accommodate that portion of the city’s or county’s share of the regional housing need for each income level that could not be accommodated on sites identified in the inventory completed pursuant to paragraph (3) of subdivision (a) without rezoning, and to comply with the requirements of Government Code section 65584.09. Sites shall be identified as needed to facilitate and encourage the development of a variety of types of housing for all income levels, including multifamily rental housing, factory-built housing, mobilehomes, housing for agricultural employees, supportive housing, single-room occupancy units, emergency shelters, and transitional housing. (Gov. Code, § 65583, subd. (c)(1).)
As noted in Finding B4, the element does not include a complete site analysis, therefore, the adequacy of sites and zoning were not established. Based on the results of a complete sites inventory and analysis, the City may need to add or revise programs to address a
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shortfall of sites or zoning available to encourage a variety of housing types. In addition, the element should be revised as follows:
Policy 1.1 (Monitor RHNA): While this program ensures sufficient sites are identified, it should commit to identifying additional sites throughout the planning period if needed to accommodate the City’s RHNA.
Policy 1.10 (Establish By-Right Housing for Prior Housing Sites) and 2.6: Previously identified nonvacant sites are inadequate to accommodate the need for lower-income households unless the site is subject to a housing element program that requires rezoning within three years of the beginning of the planning period to allow residential use by-right for housing developments in which at least 20 percent of the units are affordable to lower-income households. (Gov. Code, § 65583.2, subd. (c).) The program must be revised to comply as well as clarify that the densities for the identified sites are appropriate for lower-income households. In addition, timing of Policy 2.6 should occur no later than 3 years from the start of the planning period.
Policy 1.12 (Encourage Residential Uses within Housing Overlay): The program must clarify which commercial zones will be included in the program actions.
Policy 2.4 (Capital Improvements in Lower-Resourced Neighborhoods): The program should describe what capital improvements will be included.
Policy 3.7 (Expanding Homeless Shelters): This program must clarify implementation actions after the study in action A. In addition, a government citation must be added for Action C and implementation timing must be earlier in the planning period to ensure beneficial impact.
3. The Housing Element shall contain programs which assist in the development of adequate housing to meet the needs of extremely low-, very low-, low- and moderate-income households. (Gov. Code, § 65583, subd. (c)(2).)
While the element includes Policy 5.1.3 (Regional Forgivable Loan Program) to support the regional program to assist ELI households, it is a regional policy. The element should specify what actions the City is taking to address the ELI need. The program should also specify whether proactive outreach will occur to implement the program.
4. Address and, where appropriate and legally possible, remove governmental and nongovernmental constraints to the maintenance, improvement, and development of housing, including housing for all income levels and housing for persons with disabilities.
The program shall remove constraints to, and provide reasonable accommodations for housing designed for, intended for occupancy by, or with supportive services for, persons with disabilities. (Gov. Code, § 65583, subd. (c)(3).)
As noted in Findings B5 and B6, the element requires a complete analysis of potential governmental and nongovernmental constraints. Depending upon the results of that analysis, the City may need to revise or add programs and address and remove or mitigate any identified constraints. In addition, the element should be revised as follows:
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• P olicy 1.3 (Increase Below Market Rate Unit Production): This program should be revised to include an action to comply with State Density Bonus law as well as specific timing for implementation. The program should clarify whether the action currently listed is in addition to state law requirements. • P olicy 1.7 (Update Zoning Code Development Standards): This program must make a firm commitment to remove parking requirements that are a constraint to multifamily development.
• Policy 1.13 (Encourage Development of Missing Middle Housing): This program should include specific implementation and specify whether the identified policies and codes will be revised to remove constraints.
• Policy 1.14 (Evaluate and Update Special Needs Group Housing Requirements):
This policy should commit to reviewing and revising procedural requirements to permit group homes for seven or more persons in all zones allowing residential uses based on objective criteria to facilitate approval certainty. In addition, the program must be implemented earlier in the planning period to ensure a beneficial impact.
5. P romote and affirmatively further fair housing opportunities and promote housing throughout the community or communities for all persons regardless of race, religion, sex, marital status, ancestry, national origin, color, familial status, or disability, and other characteristics... (Gov. Code, § 65583, subd. (c)(5).)
As noted in Finding B1, the element must include a complete analysis of AFFH. The element must be revised to add goals and actions based on the outcomes of a complete analysis. Goals and actions must specifically respond to the analysis and to the identified and prioritized contributing factors to fair housing issues and must be significant and meaningful enough to overcome identified patterns and trends. Actions must have specific commitment, 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.
While programs in Table 13 include specific timelines, all programs in the element that AFFH must include specific metrics and milestones with geographic targets that address the fair housing analysis. In addition, Policy 5.2.1 (City Supported Housing) should specify what actions will be taken to add more affordable housing to moderate and high resource areas as well as whether incentives are provided.
6. The housing program shall preserve for low-income household the assisted housing developments identified pursuant to paragraph (9) of subdivision (a). The program for preservation of the assisted housing developments shall utilize, to the extent necessary, all available federal, state, and local financing and subsidy programs identified in paragraph (9) of subdivision (a), except where a community has other urgent needs for which alternative funding sources are not available. The program may include strategies that involve local regulation and technical assistance. (Gov. Code, § 65583, subd. (c)(6).)
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Policy 2.2 (Retention of Existing Lower-Income Units) and 5.3.3 (Monitor Affordable Housing Projects) should reference State Preservation Notice Law (Gov. Code, § 65863.10, 65863.11, and 65863.13) and state noticing requirements to tenants and affected public entities. The program should also be expanded to include other potential at-risk properties not included in the analysis. HCD will send additional information under separate cover.
D. Quantified Objectives
Establish the number of housing units, by income level, that can be constructed, rehabilitated, and conserved over a five-year time frame. (Gov. Code, § 65583, subd. (b)(1 & 2).)
The element must include quantified objectives to establish an estimate of housing units by income category that can be constructed, rehabilitated, and conserved over the planning period. While the element includes these objectives for construction, it must also include estimates for rehabilitation and not limit conserved units to at-risk properties.
E. Public Participation
Local governments shall make a diligent effort to achieve public participation of all economic segments of the community in the development of the Housing Element, and the element shall describe this effort. (Gov. Code, § 65583, subd.(c)(9).)
While the element includes a summary of public participation including outreach to the community, it must also describe whether translation services were available outside of the Lets Talk Housing sessions.
F. Consistency with General Plan
The Housing Element shall describe the means by which consistency will be achieved with other general plan elements and community goals. (Gov. Code, § 65583, subd. (c)(7).)
While the element discusses how internal consistency will be achieved with other elements of the general plan as part of the housing element update, it should also discuss how internal consistency will be maintained throughout the planning period.
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THE FOLLOWING PUBLIC
COMMENTS WERE SUBMITTED
FOLLOWING THE PUBLICATION
OF THE AGENDA PACKET
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City of San Mateo330 W 20th Ave.San Mateo, CA 94403
To the honorable San Mateo City Council,
The Housing Leadership Council of San Mateo County appreciates this opportunity to engagethe City of San Mateo on its housing element. Earlier this year, we sent the city two lettersoutlining opportunities to approve the initial draft of its housing element,onefocused primarilyon needs and constraints,the otherfocused on affirmativelyfurthering fair housing, the sitesinventory, and the goals, policies, and programs.
Now that the city has received its review letter from the department of Housing and CommunityDevelopment, San Mateo has a new opportunity to address the housing needs of its entirecommunity. However, we are concerned that arecentstaff report and matrix of responses toHCD’s commentsdoes not adequately reflect the citycouncil’s strong commitment to meetingthe housing needs of all. One line in particular raises concerns that San Mateo is consideringlegally dubious options. From the staff report:
It should be noted that HCD certification is not required for a housing element to be foundsubstantially compliant with State law. State law provides that a local jurisdiction may adopt itsown findings explaining why its housing element is substantially compliant with State lawdespite HCD’s findings. Thus, a local jurisdiction can continue to work with HCD to achievecertification of its adopted housing element after the deadline without being deemed out ofcompliance.
A local jurisdiction may attempt to adopt its own findings before receiving HCD certification, butdoing so significantly increases the risk of lawsuits. Manhattan Beach attempted to adopt theirhousing element before receiving HCD certification; the city has now beensued twiceby thenonprofit Californians for Homeownership (associated with the CA Realtors Association). If SanMateo were to attempt to adopt its current draft housing element without first implementingsignificant revisions, it would be asking for a lawsuit.
In order to plan for the needs of its entire community and comply with state law, San Mateomust revise large portions of its housing element as follows:1. Adjust realistic capacity for sites within the inventory based on site-specificinformation, and remove unrealistic sites: Currently,San Mateo’s site inventoryassumes all parcels will be built out to 100% of zoned capacity. On some sites, such asHillsdale Mall, 100% buildout is inconceivable even if the city made dramatic policy
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changes. 12 acres of the ~40-acre Hillsdale site were renovated within the past 3 years,making them extremely unlikely to become new homes anytime soon. Yet San Mateo’scurrent draft housing element assumes that 100% of the Hillsdale site will become newhomes at 100% of zoned capacity, a clear violation of the law. 1 In another example, theBridgepoint Shopping Center recently renewed long term leases with several tenants,making development of the site highly unlikely. Unless the city can provide compellingevidence that these sites will be developed, such as property owner interestandtheprovision of favorable development standards, they must be removed from theinventory. 2 As referenced earlier, Manhattan Beachhas been sued twice for includingsites that will not become housing in the next eight years within its inventory. Other siteshave similar pre-existing uses that impede housing. Upon removal of unrealistic sitesfrom the inventory and appropriate reduction of realistic capacity for other sites, SanMateo will no longer be able to demonstrate capacity to meet its Regional HousingNeeds Allocations. As a result, the city will need to upzone beyond the limits created byMeasure Y.2. Fully analyze constraints to housing: The matrix of responses to HCD’s review letterprovided by staff still makes no commitment to address Measure Ywithin the housingelement. In its review letter, HCD writes “The elementmust describe the impacts ofmeasure Y on height and density restrictions as a constraint on housing developmentand affordability. The element must add a program to include outreach and mitigationmeasures for the impact of Measure Y.” Addressing the constraint “as part of the GPU[General Plan Update] adoption process,” as staff offer in their matrix of responses, doesnot suffice. The housing element is a chapter of the general plan; as such, constraints tohousing, including Measure Y, should be addressed within the housing element. HCDlists a number of other significant underanalyzed and unaddressed constraints, includingdiscretionary review processes, development fees, and parking requirements.3. Fully analyze Affirmatively Furthering Fair Housing:In its current housing element,San Mateo seeks to justify current patterns of segregation rather than analyze andaddress them. In fact, by concentrating all of its opportunity sites outside of San Mateo’shighest opportunity areas, the housing element actively promotes segregation. In orderto satisfy AFFH requirements, the city needs new policies to protect lower-incomerenters and promote housing in its highest-opportunity areas.4. Implement new policies and programs to increase validity of site inventory: Basedon complete analyses of sites, constraints, and AFFH, San Mateo will need to implementnew policies and programs. State law is particularly clear: Identified constraints must be 2 Gov. Code, §65583.2(g)(2): “An existing use shall be presumed to impede additional residentialdevelopment, absent findings based on substantial evidence that the use is likely to be discontinuedduring the planning period.” 1 HCD Site Inventory Guidebook, p. 20: “The capacitycalculation must be adjusted to reflect the realisticpotential for residential development capacity on the sites in the inventory. Specifically, when the site hasthe potential to be developed with nonresidential uses, requires redevelopment, or has an overlay zoneallowing the underlying zoning to be utilized for residential units, these capacity limits must be reflected inthe housing element.”
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removed to the extent possible.
3 Programs must promote AFFH goals.
4 HLCrecommends the following programs:○ Implement an affordable housing overlayfocused onland owned by religiousinstitutions and schools in high-opportunity single-family neighborhoods. Theoverlay should allow development standards at least as generous as the city’sR6-D development standards to provide maximum flexibility for these public andsemi-public institutions to create new homes. Furthermore, proposals for housingon sites owned by religious institutions or schools should be exempt from designreview hearings and limited to two planning commission hearings. (AFFH)○ Implement a rental registryto track rentals and provide data to the city regardingprices and evictions. Data from a rental registry will help the city identify landlordsviolating the law and devise additional renter protections as needed. (AFFH)○ Reduce fees on affordable housing, especially impactfees and open space fees.Waive fees entirely for low- and very low-income units, defer them until receptionof occupancy permit for moderate-income units. (AFFH, constraints)○ Allow ministerial approval for all opportunity sites,eliminating design review andplanning commission review. Discretionary review processes add cost anduncertainty to the development process; these processes also put a heavyburden on planning staff time, which the city is eminently short of. (constraints)○ Reduce parking requirementsby (1) requiring only1 parking space for1-bedroom, 2-bedroom, and 3-or-more-bedroom units (2) eliminating guestparking requirements throughout the city (3) eliminating parking requirements forunits serving those with physical or mental disabilities. (constraints)○ Upzone opportunity sites above Measure Y limitstopromote viability ofopportunity sites. The exact quantity of upzoning required will depend in part onthe results of a complete site inventory analysis. HLC believes that, in order todemonstrate viability of opportunity sites, the city should rezone as follow:i. Rezone R3, R4, R4-D, R5, R5-D, R6-D; all C1, C2, and C3 districts; andall E zoning districts to allow:1. 85 feet height and 8 stories2. Eliminate density cap3. Eliminate minimum lot size4. Increase FAR to 5ii. Rezone CBD, CBD/S, TOD, and all C4 districts to allow:1. 125 feet height and 12 stories 4 Gov. Code, § 65583(c)(10)(A)(v): “Strategies and actions to implement [AFFH] priorities and goals,which may include, but are not limited to, enhancing mobility strategies and encouraging development ofnew affordable housing in areas of opportunity, as well as place-based strategies to encouragecommunity revitalization, including preservation of existing affordable housing, and protecting existingresidents from displacement. 3 Gov. Code, § 65583(c)(3): “Address and, where appropriate and legally possible, remove governmentaland nongovernmental constraints to the maintenance, improvement, and development of housing,including housing for all income levels.”
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2. Eliminate density cap3. Eliminate minimum lot size, rear setbacks, and side setbacks4. Eliminate maximum lot coverage5. Eliminate private open space requirement6. Increase FAR to 8 San Mateo’s city council is responsible for providing staff direction to implement thesepolicies and programs.These are not controversial proposals; according to the city’s ownCommunity Input Survey, when asked about their zoning preferences, “63% of San Mateoresidents indicated they would support concentrating new housing in higher-density buildingsdowntown and near transit up to 12 stories. 5 HLC’sproposals reflect the widely held preferencesof the San Mateo community.
Fundamentally, cities cannot analyze their way into new homes, nor can they analyze their wayinto compliance with state law. The housing element process challenges cities to provide aseries of analyses and then commit to substantially change local policies in ways thatincentivize new housing development. HLC looks forward to continue working with San Mateo’sleaders as they strive to meet the housing needs of the entire community.
Thank you for your consideration,
Jeremy LevinePolicy Manager, Housing Leadership Council of San Mateo County 5 Community Opinion Survey: Summary Report, p. 12
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Draft 2023
-
2031
Housing Element
City Council, November 7, 2022
Zachary Dahl, Deputy Director
Eloiza Murillo-Garcia, Housing Manager
Community Development Department
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Housing Element Team
City of San Mateo
• Zachary Dahl, Deputy Director
• Eloiza Murillo-Garcia, Housing Manager
• Manira Sandhir, Planning Manager
• Sandra Council, Housing Manager (past)
• Julia Klein, Principal Planner
• Linda Ly, Associate Planner
• Nicholas Vu, Housing Specialist
Consultants
• Diana Elrod, Diana R. Elrod Consulting
• Nicholas Hamilton, Good City Co.
• Root Policy
• 21 Elements (San Mateo County
Planning Collaborative)
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Tonight's Agenda and Presentation Overview
• Staff Presentation
• Housing Element Background
• HCD Comment Letter Overview
• Housing Element Timeline and Next Steps
• Builder’s Remedy Summary
• Clarifying Questions
• Public Comment
• City Council Discussion and Direction
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Meeting Objectives
• Receive overview of HCD’s first review of the City's Draft Housing Element
• Receive Public Comments
• Council Discussion and Direction on Draft Housing
Element updates and revisions to address HCD comments
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Housing Element Background
• Required Element of the General Plan
• Requires Certification by State Housing and Community Development Department (HCD)
• 6th Housing Element Cycle – 2023-2031
• Regional Housing Needs Allocation
• Bay Area – 441,176 units
• City of San Mateo – 7,015 units
• Draft Housing Element submitted to HCD on July 1, 2022 • HCD Comment letter received on September 28, 2022
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City’s Regional Housing Needs Allocation (RHNA)
Income
Category
Very Low
50% AMI
Low
80% AMI
Moderate
120% AMI
Above
Moderate
Income
Total
2023-31
Allocation 1,777 1,023 1,175 3,040 7,015
AMI – Area Median Income
County of San Mateo AMI is $166,600 for a 4-person household
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Draft Housing Element Timeline
• April 6 – May 6 Draft HE 30-day public comment period • May 16 City Council review of Draft HE
• July 1 Updated Draft HE submitted to HCD
• September 28 HCD First Review Letter received
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HCD First Review Letter
• HCD Review Letter included 91
• Comments included consideration of comments made by organizations and individuals • HCD Comment Matrix (Attachment 2)
• Each comment numbered and categorized with applicable HE section • Summary of the current HE status in relation to comment • Staff recommendation on how to respond
• Addressing comments will require significant changes to various sections of the Draft Housing Element
• Comment areas include:
• Sites Inventory
• Constraints Analysis
• Goals, Policies and Programs (GPPs)
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HCD Comments to Discuss
• Sites Inventory Category Comments:
• 19 - Suitability of Nonvacant sites
• 20 - Analysis of Existing Uses as Impediments to residential development • Zoning Category Comments:
• 31 - Emergency Shelters
• 37 - Accessory Dwelling Units (ADUs)
• Constraints Category Comments:
• 38 - Land Use Controls
• 40 - Open Space Requirements for R-3 Zone
• 41 - Parking Requirements
• 48 - Measure Y
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HCD Comments to Discuss (cont.)
• Goals, Policies and Programs Comments:
• 60 – Encourage Family Housing
• 61 – Streamline Housing Application Review
• 81 – Expanding Homeless Shelters
• 84 – Parking Requirements for Multi-Family Development • 85 – Encourage Missing Middle Housing
• 86 – Evaluate and Update Special Needs Group Housing Requirements
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Sites Inventory Comments
Number Section HCD Comment Current Status Recommendation 19 Inventory Suitability of Nonvacant Sites: The element must include an analysis demonstrating the potential for redevelopment of nonvacant sites. To address this requirement, the element describes in general the existing use of each nonvacant site, for example, “commercial” or “parking lot”. This alone is not adequate to demonstrate the potential for redevelopment in the planning period. The description of existing uses should be sufficiently detailed to facilitate an analysis demonstrating the potential for additional development in the planning period.
The Draft HE included tables
for pipeline projects and
approved projects to
demonstrate pattern of
redevelopment for
nonvacant sites in the City.
For the sites inventory,
details of existing use,
existing General Plan Land
Use, active planning
applications and
redevelopment potential
were included.
Methodology: Bolster narrative and
methodology section for development on
nonvacant sites; add background info on
age/size of building demolished for
recently entitled development, existing
versus allowable floor area, etc. Refer to
ranking system that was created to justify
redevelopment potential.
Sites Inventory: Update sites inventory
with additional detailed descriptions of
existing uses and maximum
redevelopment potential, including
referencing developer interest and
potential expanded capacity through the
General Plan Update process expected to
be completed in 2024. Include
redevelopment ranking score per
methodology.
New Policy: Add policy for outreach to
property owners of sites on the inventory;
note sites with expressed developer
interest.
20 Inventory In addition, the element must analyze the extent that existing uses may impede additional residential development. For example, the element includes sites identified as parking lots, church, gas station, an auto repair, and a warehouse; but must also demonstrate whether these existing uses would impede development of these sites within the planning period. The element can summarize past experiences converting existing uses to higher density residential development, include current market demand for the existing use, provide analysis of existing leases or contracts that would perpetuate the existing use or prevent additional residential development and include current information on development trends and market conditions in the City and relate those trends to the sites identified. The element could also consider indicators such as age and condition of the existing structure, expressed developer interest, existing versus allowable floor area, low improvement to land value ratio, and other factors.
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Zoning and Land Use Comments
Number Section HCD Comment Current Status Recommendation 31 Zoning for
Housing
Types
Emergency Shelters: The housing element must demonstrate the permit processing, development, and management standards for emergency shelters are objective and encourage and facilitate the development of, or conversion to, emergency shelters. In particular, the element describes development standards for emergency shelters; however these standards are beyond the development standards allowed under housing element law.
The element must demonstrate that emergency shelters are subject to the same development and management standards applicable to residential or commercial development within the same zone except for those standards prescribed by Government Code section 65583 (a)(4)(A).
Policy H-3.7 that identifies program
to evaluate City policies and zoning to
meet or expand emergency shelters.
Constraints analysis in Appendix B,
Section 2.9.5-2.9.7 provides general
information about zoning capacity,
strategies and programs to provide
emergency shelters and address
homelessness.
- Review existing requirements and
constraints analysis against State law
and revise, adding a program if
needed.
37 Zoning Accessory Dwelling Unit (ADU): The element indicates the City modifies its zoning code to ease barriers to the development of ADU’s. However, after a cursory review of the City’s ordinance, HCD discovered several areas which are not consistent with State ADU Law. HCD will provide a complete listing of ADU non-compliance issues under a separate cover. As a result, the element should add a program to update the City’s ADU ordinance in order to comply with state law. For more information, please consult HCD’s ADU Guidebook, published in December 2020, which provides detailed information on new state requirements surrounding ADU development A letter from HCD about the City's
ADU ordinance and compliance with
state law has not yet been received; a
copy of the City's adopted ADU
ordinance was sent to HCD last April
and state law notes that HCD should
identify any compliance concerns
within 60 days.
Evaluate comment letter from HCD,
once received, and amend as the
ADU Ordinance as necessary to
ensure compliance with state law;
add a program to note the ADU
ordinance will be maintained in
compliance with state law.
38 Constraints Land Use Controls
: The element must identify and analyze all relevant land use controls impacts as potential constraints on a variety of housing types. The analysis should analyze land use controls independently and cumulatively with other land use controls.
The analysis should specifically address requirements related to parking, heights, lot coverage and limits on allowable densities. The analysis should address any impacts on cost, supply, housing choice, affordability, timing, approval certainty and ability to achieve maximum densities and include programs to address identified constraints.
An analysis of the City's land use
controls and how they impact
housing development was provided
in the Constraints Analysis.
Update Constraints Analysis to
provide additional information.
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Constraints Analysis Comments
Number Section HCD Comment Current Status Recommendation 40 Constraints The element should also analyze the open space requirements for the R-3 zone.
A program (Policy H-1.1.3) was identified to study
impediments to missing middle housing (including
open space requirements).
Update the constraints analysis to
evaluate open space requirements
in the R-3 zone and amend Policy
H-1.1.3 as needed.
41 Constraints
In addition, the element should analyze requiring more
than one parking space for studio and one-bedroom
units and the minimum requirement of 2.2 spaces for
1,400 square foot units regardless of bedroom size and
add programs to specifically address the constraints.
General analysis states that parking may be a
constraint and projects tend to utilize State Density
Bonus Law to request reduced parking standards. A
program (Policy H-1.7) was identified to evaluate
parking requirements for residential and mixed-use
development projects near transit.
Add analysis of how parking
requirements may pose a
constraint to all multifamily
housing developments and amend
Policy 1.7 as needed. Recent state
legislation AB 2097 already affects
jurisdictions' ability to require
parking for projects near transit.
Council direction needed on if
parking requirements for the rest
of the City should be evaluated.
48 Constraints
Measure Y: The element must describe the impacts of
measure Y on height and density restrictions as a
constraint on housing development and affordability.
The element must add a program to include outreach
and mitigation measures for the impact of Measure Y on
housing development throughout the planning period.
The element should analyze the measure as a constraint
on development based on site suitability for
development.
The Draft HE identifies a path to meeting the City's
6th cycle RHNA allocation within the limits of
Measure Y; and Measure Y was discussed in the
Constraints Analysis, noting it as a housing
production constraint that results in additional
sites needed to meet the City's RHNA. The
community discussion about Measure Y and
housing growth in the City over the next 20 years is
happening and will continue as part of the GPU
adoption process.
Add additional information about
the General Plan Update (GPU) and
how this topic will be addressed as
part of the GPU adoption process in
2023/24.
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Goals, Policies and Programs Comments
Number Section HCD Comment Current Status Recommendation 60 GPPs Policy 1.5 (Encourage Family Housing):
The program should include back-up
actions, with specific timing, if the
identified incentives are not
implemented.
The current program measure
and implementation action
discuss proposing 3-bedroom
affordable units as part of the
City's inclusionary requirements.
City staff needs to conduct a study and come to
council with a proposal. Also, perhaps the policy
could be broken into City subsidized projects and
private development projects.
61 GPPs
Policy 1.6 (Streamline Housing Application
Review): Action B must include specific
timing of when permit application
requirements will be updated. In addition,
the timing of action C must be completed
earlier in the planning period.
Action B - Since permit
application requirements are
constantly being updated, the
current Draft HE mentions 2023-
2031.
Action C - The Planning Division
continues to implement SB 330
timelines for qualifying projects.
Action B - The timeline would be updated to track
the first round of streamlining measures, which are
expected to be completed in 2023-2024.
Action C - Verify if code amendments are needed for
SB 330, or delete.
Possibly combine with 1.7, 1.8, 1.9,
and 1.15 to keep
all zoning amendments under one policy.
81 GPPs Policy 3.7 (Expanding Homeless Shelters):
This program must clarify implementation
actions after the study in action A. In
addition, a government citation must be
added for Action C and implementation
timing must be earlier in the planning
period to ensure beneficial impact.
These details were not provided. Will try to provide more details, but challenging since the study would identify potential
implementation actions, will also evaluate feasibility
of implementing earlier.
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Goals, Policies and Programs Comments
Number Section HCD Comment Current Status Recommendation 84 Other
GPPs
Policy 1.7 (Update Zoning Code Development Standards):
This program must make a firm commitment to remove
parking requirements that are a constraint to multifamily development.
Intent of the policy was to
evaluate and let community and
decisionmaker input guide the
updated parking standards, but
does not commit to a specific
outcome.
Request input from the City Council
on making a stronger commitment to
modifying or removing any parking
requirements identified as a
constraint to multi-family
development.
85 Other
GPPs
Policy 1.13 (Encourage Development of Missing Middle
Housing): This program should include specific
implementation and specify whether the identified
policies and codes will be revised to remove constraints.
The intent of this policy is to
reduce/remove contains to
missing middle housing
developments; but does not
commit to a specific outcome.
Request input from the City Council
on committing to modifying or
removing any policies or codes that
are a constraint on missing middle
housing development.
86 Other
GPPs
Policy 1.14 (Evaluate and Update Special Needs Group
Housing Requirements): This policy should commit to
reviewing and revising procedural requirements to permit group homes for seven or more persons in all zones
allowing residential uses based on objective criteria to facilitate approval certainty. In addition, the program must be implemented earlier in the planning period to
ensure a beneficial impact
The policy does not include a
commitment to a specific
outcome.
Request input from the City Council
on committing to reviewing and
revising procedural requirements to
permit group homes in all zones that
allow residential uses based on
objective criteria to facilitate
approval certainty.
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Year No. Implementation Actions
Ongoing 2023-2031 27
2023 6
2024 7
2025 5
2026 12
2027 2
2028 4
2029 2
2030 2
2031 0
Total 67
Housing Element Implementation Schedule
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Next Steps
To meet the January 31, 2023 deadline to adopt the Housing Element, the following timeline is anticipated:
• November/December 2022 – Update the Draft Housing Element and resubmit to HCD for second review
• January 2023 – Public hearings before the Planning Commission for a recommendation and the City Council to adopt Housing Element • End of January 2023 – Submit adopted Housing Element to HCD for certification
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Loss of Local Control “Builder’s Remedy”
• Housing elements are required to comply with current State housing element law by January 31, 2023
• HCD is no longer providing 120-day grace period to housing elements • A jurisdiction without an adopted sixth cycle housing element is at risk of being deemed out of compliance
• Subject to loss of local zoning and land use control. • Development applications could utilize the “Builder’s Remedy” provision in the HAA, (Government Code Section 65589.5).
• Local adoption, not HCD certification, is the key step required for a housing element to be found substantially compliant per state law.
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Next Steps
• To address HCD comments, many of the goals, policies and programs will require changes and increased levels of commitment • Recommendations on how to address each comment provided • Staff is seeking Council input and direction on the recommended updates and revisions to the HE to address HCD’s comments • Addressing HCD’s comments will bring the City closer to having a substantially compliant housing element by the January 31, 2023
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Council Input and Direction
• Provide Input and Direction on how to revise the
Draft Housing Element in response to HCD’s
comments.
• Do you agree with the staff recommendations?
• Specifically on the highlighted comments
• Are there any recommendations that should be
changed or modified?
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Highest
Resource
HighestThank You!
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Highest
Resource
HighestClarification Questions
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Highest
Resource
HighestPublic Comments
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Council Input and Direction
• Provide Input and Direction on how to revise the
Draft Housing Element in response to HCD’s
comments.
• Do you agree with the staff recommendations?
• Specifically on the highlighted comments
• Are there any recommendations that should be
changed or modified?
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Highest
Resource
Highest
Backup Slides
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HCD Comment Matrix – All Comments
Comment Number Section HCD Comment Current Status Recommendation 1 Review and Revise As part of the evaluation of programs in the past cycle, the element must analyze the
effectiveness of goals, policies, and related
actions in meeting the housing needs of special
needs populations (e.g., elderly, persons with
disabilities, large households, female headed
households, farmworkers and persons
experiencing homelessness). Programs should
be revised as appropriate to reflect the results
of this evaluation.
An evaluation of the City's
past HE (cycle 5) was
included, but a specific
analysis of policy/program
effectiveness was not
included.
Review/update past HE evaluation to
analyze effectiveness, and identify areas
where GPPs in Draft HE could be
strengthened/expanded, if necessary.
2 Needs - AFFH Fair Housing Issues: The element must include other relevant factors that contribute to fair
housing issues in the jurisdiction. For instance,
the element can analyze historical land use and
investment practices or other information and
demographic trends
This is asking for local
knowledge of trends, some
of which was included in the
Draft HE.
Draft narrative of how housing
developed over time in San Mateo,
including single-family tracts, etc.
3 Needs - AFFH Enforcement: While the element lists fair housing laws in Appendix D, it must state
whether the City complies with federal and
state fair housing laws. If the City does not
currently comply, a program should be added
as appropriate.
This information was implied
in the Draft HE, but was not
explicitly stated.
Revise Draft HE to add more specific
language on how it complies with federal
and state fair housing laws.
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Comment Number Section HCD Comment Current Status Recommendation 4 Needs - AFFH Integration and Segregation: The element provided some data regarding segregation and integration of race, disability, familial status, and income. The element must describe the census tracts that have geographic concentrations of race (i.e., concentrations identified as white majority). In addition, the element must discuss and analyze data on persons with
disabilities for trends over time and patterns across census tracts as well as evaluate patterns at a regional basis, comparing the City to the region. The element must also include a local and regional analysis of integration and segregation for familial status. Lastly, the element must describe and analyze
concentrations of income geographically throughout the City.
The Draft HE included the
extensive analysis on
segregation and integration
supplied by ABAG in conjunction
with UC Merced. Root Policy (21
Elements consultant)
summarized the data in their
draft of the AFFH findings.
Many jurisdictions are receiving the
same or similar comment. Staff will
confer with Root Policy on how to
respond to this request.
5 Needs - AFFH
Racial/Ethnic Areas of Concentration of Poverty and Affluence (R/ECAP)
: The element includes information relative to R/ECAP
within the City but should also analyze where they are in the region. The element must also address concentrated areas of affluence both locally and regionally. The combination of the R/ECAP and areas of affluence analyses will help guide goals and actions to address fair housing issues. The analysis should evaluate the patterns and changes over time at a local (e.g., neighborhood to neighborhood) and regional level (e.g., city to region).
Root Policy provided the basic
analysis for R/ECAPs for all
jurisdictions in San Mateo
County.
Many jurisdictions are receiving the
same or similar comment. Staff will
confer with Root Policy on how to
respond to this request.
6 Needs - AFFH Disproportionate Housing Needs including Displacement : While
the element includes some data on disproportionate needs, additional information is needed. The element must describe any geographic concentration of cost burden and overcrowding by tenure, as well as any concentrations of substandard housing both locally and regionally. In addition, the element must describe and analyze the census tracts with displacement risk.
While the map depicts a lot of areas vulnerable to displacement, this must be supported with an analysis.
Root Policy provided the basic
analysis for disportionate
housing needs and displacement
for all jurisdictions in San Mateo
County.
Many jurisdictions are receiving the
same or similar comment. Staff will
confer with Root Policy on how to
respond to this request.
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Comment Number Section HCD Comment Current Status Recommendation 7 Needs - AFFH Sites Inventory: While the element includes a summary of some factors, the analysis must identify whether sites improve or exacerbate conditions and whether sites are isolated by income group. A full analysis should address the income categories of identified sites with respect to location, the number of sites and units by all income groups and how that affects the existing patterns for all components of the assessment of fair housing (e.g., segregation and integration, access to opportunity). If sites exacerbate conditions, the element should identify further program actions that will be taken to promote equitable quality of life throughout the community (e.g., anti-displacement and place- based community revitalization strategies).
The Draft HE contained an extensive
discussion of how the inventory relates to
AFFH criteria. This analysis was crafted by
Root Policy in conjunction with staff.
Many jurisdictions are
receiving the same or
similar comment. Staff will
confer with Root Policy on
how to respond to this
request.
8 Needs - AFFH Contributing Factors
: The element identifies many contributing
factors to fair housing issues. The element must prioritize these factors to better formulate policies and programs and carry out meaningful actions to Affirmatively Furthering Fair Housing (AFFH).
In addition, the element must describe how the actions in Appendix D Fair Housing Plan are tied to the housing element programs and include implementation.
The Draft HE identifies many contributing
factors, and the Fair Housing Action Plan
(FHAP) includes discrete actions to
address these concerns. This request
seeks to specifically prioritize the factors,
which were implied but not explicit. In
addition, many of the FHAP actions were
explicitly tied to the general Goals,
Policies and Programs.
Amend the narrative to be
more explicit.
9 Needs - AFFH Goals, Actions, Metrics, and Milestones
: The element must be
revised to add or modify goals and actions based on the outcomes of a complete analysis. Goals and actions must specifically respond to the analysis and to the identified and prioritized contributing factors to fair housing issues and must be significant and meaningful enough to overcome identified patterns and trends.
Actions must have specific commitment, 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
The Draft HE contained a comprehensive
list of actions to address fair housing
concerns. Based on the additional
analysis requested above, some of these
programs may need to be revised and
some may need to be added.
Confer with Root Policy on
the above analyses and
develop a modified FHAP,
as needed.
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Comment Number Section HCD Comment Current Status Recommendation 10 Needs - Other Extremely Low-Income Households (ELI): The element must quantify the number of existing and projected ELI households, and also analyze their housing needs. The analysis of ELI housing needs should consider tenure and rates of overpayment.
This information was included in the
Draft HE, as per ABAG's data packet.
This information is already included in
Appendix A (Section 4.6)
Request clarification from HCD
on what specifically is being
requested, and updated/clarify
Draft HE as needed.
11 Needs - Other Overpayment
: The element must quantify and analyze the
number of lower-income households overpaying by tenure (i.e., renter and owner).
This information was included in the
Draft HE, as per ABAG's data packet.
This information is already included in
Appendix A.
Request clarification from HCD
on what specifically is being
requested, and updated/clarify
Draft HE as needed.
12 Needs - Other Housing Costs
: While the element includes estimated rents for
residents, it utilizes American Community Survey (ACS) data. The element should supplement census data with other sources (e.g., local knowledge).
This information was included in the
Draft HE, as per ABAG's data packet.
This information is already included in
Appendix A.
Request clarification from HCD
on what specifically is being
requested, and updated/clarify
Draft HE as needed.
13 Inventory
Progress in Meeting the Regional Housing Need Allocation (RHNA)
: The City’s RHNA may be reduced by the number of new
units built since June 30, 2022; however, the element must demonstrate their affordability based on actual sales price, rent level or other mechanisms ensuring affordability (e.g., deed restrictions). The element should also discuss the status, any barriers to development and other relevant factors to
demonstrate their availability in the planning period.
The Draft HE included general
information on this topic, but not to
the level of detail requested in this
comment.
Similar to other cities' review
letters, HCD is requesting more
detail on each pipeline project
from status (whether approved,
under construction, etc.;
probable completion date;
explanation of how affordability
has been calculated). Update the
spreadsheets with pipeline
projects to have more detail
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Comment Number Section HCD Comment Current Status Recommendation 14 Inventory Realistic Capacity: While the element provides assumptions of buildout for sites included in the inventory, it must also provide support for these assumptions. For example, the element should demonstrate what specific trends, factors, and other evidence led to the assumptions. The estimate of the number of units for each site must be adjusted as necessary, based on the land use controls and site improvements and typical densities of existing or approved residential developments at a similar affordability level. The element currently assumes realistic capacity at 100 percent of base zoned density for multifamily units in R-3, R-4, and R-5 zones. The analysis must provide substantial support and demonstrate a history of developing at maximum density within the City. Examples to support realistic capacity assumptions should also include affordability levels, and percent of maximum densities.
The Draft HE provided an
extensive analysis of how realistic
capacity was calculated. Similar to
other jurisdictions' letters, the
State is requesting even further
explanation.
Develop a more detailed
narrative by explaining each site
individually and outline basis for
the realistic capacity calculation;
past development approval and
pipeline project data does
support the realistic capacity
assumptions included in the
Draft HE.
15 Inventory
The calculation of residential capacity must also account for the likelihood of residential development in zoning where 100 percent nonresidential uses are allowed. The analysis should be based on factors such as development trends including nonresidential, performance standards requiring residential uses or other relevant factors such as enhanced policies and programs. For example, the element could analyze all development activity in these nonresidential zones, how often residential development occurs and adjust residential capacity calculations, policies, and programs accordingly.
The Draft HE provided a general
analysis on this topic, but not to
the level requested by HCD. For
any site that could be developed
with nonresidential uses, HCD is
seeking an analysis of the
likelihood the site will actually be
developed with residential uses.
Develop a more detailed
narrative by demonstrating sites
over the last five years that
could have been developed for
nonresidential but were actually
built with residential (100% or
mixed-use).
16 Inventory Small and Large Sites
: Sites smaller than an half acre and larger than
10 acres in size are deemed inadequate to accommodate housing for lower-income housing unless it is demonstrated that sites of equivalent size were successfully developed during the prior planning period for an equivalent number of lower-income housing units as projected for the site or unless the housing element describes other evidence to HCD that the site is adequate to accommodate lower- income housing (Gov. Code, § 65583.2, subd. (a) (3)
This information is provided in the
Draft HE narrative (i.e. Concar
Passage) for large sites; there are
no small sites that have been
identified as potentially
affordable.
Request clarification from HCD
on what specifically is being
requested, and updated/clarify
Draft HE as needed.
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Comment Number Section HCD Comment Current Status Recommendation 17 Inventory In addition, the element must describe feasibility of the Hillsdale and Bridgepointe sites including likelihood of development during the planning period, whether a specific plan is needed, and if the existing uses will remain.
The Draft HE included detailed information
about the Hillsdale sites (i.e. Imagine
Hillsdale outreach campaign). The
Bridgepointe sites were addressed more
generally.
Update Draft HE to provide more specific
information and analysis.
18 Inventory Lastly the element must describe a history of lot consolidation as a method of developing housing as well as whether the City has any incentives to consolidate lots with different owners.
The Draft HE provided a general analysis
on the topic of lot consolidation, but not
to the level requested by HCD.
Update Draft HE to provide more specific
information and analysis.
19 Inventory Suitability of Nonvacant Sites
: The element must include an analysis demonstrating the potential for redevelopment of nonvacant sites. To address this requirement, the element describes in general the existing use of each nonvacant site, for example, “commercial” or “parking lot”. This alone is not adequate to demonstrate the potential for redevelopment in the planning period. The description of existing uses should be sufficiently detailed to facilitate an analysis demonstrating the potential for additional development in the planning period.
The Draft HE included tables for pipeline
projects and approved projects to
demonstrate pattern of redevelopment for
nonvacant sites in the City.
For the sites inventory, details of existing
use, existing General Plan Land Use, active
planning applications and redevelopment
potential were included.
Methodology: Bolster narrative and
methodology section for development
on nonvacant sites; add background info
on age/size of building demolished for
recently entitled development, existing
versus allowable floor area, etc. Refer to
ranking system that was created to
justify redevelopment potential.
Sites Inventory
: Update sites inventory
with additional detailed descriptions of
existing uses and maximum
redevelopment potential, including
referencing developer interest and
potential expanded capacity through the
General Plan Update process expected to
be completed in 2024. Include
redevelopment ranking score per
methodology.
New Policy
: Add policy for outreach to
property owners of sites on the
inventory; note sites with expressed
developer interest.
20 Inventory In addition, the element must analyze the extent that existing uses may impede additional residential development. For example, the element includes sites identified as parking lots, church, gas station, an auto repair, and a warehouse; but must also demonstrate whether these existing uses would impede development of these sites within the planning period. The element can summarize past experiences converting existing uses to higher density residential development, include current market demand for the existing use, provide analysis of existing leases or contracts that would perpetuate the existing use or prevent additional residential development and include current information on development trends and market conditions in the City and relate those trends to the sites identified. The element could also consider indicators such as age and condition of the existing structure, expressed developer interest, existing versus allowable floor area, low improvement to land value ratio, and other factors.
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Comment
Number
Section HCD Comment Current Status Recommendation
21 Inventory In addition, as noted in the housing element, the housing element relies upon nonvacant sites to accommodate more than 50 percent of the RHNA for lower- income households. For your information, the housing element must demonstrate existing uses are not an impediment to additional residential development and will likely discontinue in the planning period (Gov. Code, § 65583.2, subd. (g)(2).).
Absent findings (e.g., adoption resolution) based on substantial evidence, the existing uses will be presumed to impede additional residential development and will not be utilized toward demonstrating adequate sites to accommodate the regional housing need allocation.
The Draft HE provided a general
analysis on the redevelopment
potential/likelihood on nonvacant
sites, but not to the level requested
by HCD.
Update narrative consistent with
updated sites inventory
methodology; further discuss
factors that make a site a
candidate for
turnover/redevelopment.
22 Inventory City-Owned Sites: The element must include additional discussion on each of the City- owned sites identified to accommodate the RHNA. Specifically, the analysis should address general plan designations, allowable densities, support for residential capacity assumptions, existing uses and any known conditions that preclude development in the planning period and the potential schedule for development. If zoning does not currently allow residential uses at appropriate densities, then the element must include programs to rezone sites pursuant to Government Code section 65583.2, subdivisions (h) and (i). In addition, the housing element must include a description of whether there are any plans to sell the property during the planning period and how the jurisdiction will comply with the Surplus Land Act Article 8 (commencing with Section 54220) of Chapter 5 of Part 1 of Division 2 of Title 5.
Two City-owned sites were identified
on the sites inventory list - 4th
Ave/Railroad Ave (Talbot's - 445 S. B
Street; APN: 034-179-050;-060) and
the Ravioli site (505 S. B Street; APN:
042-242-170). The City has a
preliminary agreement with a
developer to construct a 60-unit,
100% affordable housing project on
the Talbot's site.
Update Appendix C, Section 3.5
with additional narrative about
the Talbot's site, including
information that is currently
provided in the sites inventory
table. Remove Ravioli site from
discussion.
21 Inventory In addition, as noted in the housing element, the housing element relies upon nonvacant sites to accommodate more than 50 percent of the RHNA for lower- income households. For your information, the housing element must demonstrate existing uses are not an impediment to additional residential development and will likely discontinue in the planning period (Gov. Code, § 65583.2, subd. (g)(2).).
Absent findings (e.g., adoption resolution) based on substantial evidence, the existing uses will be presumed to impede additional residential development and will not be utilized toward demonstrating adequate sites to accommodate the regional housing need allocation.
The Draft HE provided a general
analysis on the redevelopment
potential/likelihood on nonvacant
sites, but not to the level requested
by HCD.
Update narrative consistent with
updated sites inventory
methodology; further discuss
factors that make a site a
candidate for
turnover/redevelopment.
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22 Inventory City-Owned Sites: The element must include additional discussion on each of the City- owned sites identified to accommodate the RHNA. Specifically, the analysis should address general plan designations, allowable densities, support for residential capacity assumptions, existing uses and any known conditions that preclude development in the planning period and the potential schedule for development. If zoning does not currently allow residential uses at appropriate densities, then the element must include programs to rezone sites pursuant to Government Code section 65583.2, subdivisions (h) and (i). In addition, the housing element must include a description of whether there are any plans to sell the property during the planning period and how the jurisdiction will comply with the Surplus Land Act Article 8 (commencing with Section 54220) of Chapter 5 of Part 1 of Division 2 of Title 5.
Two City-owned sites were
identified on the sites inventory
list - 4th Ave/Railroad Ave
(Talbot's - 445 S. B Street; APN:
034-179-050;-060) and the Ravioli
site (505 S. B Street; APN: 042-
242-170). The City has a
preliminary agreement with a
developer to construct a 60-unit,
100% affordable housing project
on the Talbot's site.
Update Appendix C, Section
3.5 with additional narrative
about the Talbot's site,
including information that is
currently provided in the sites
inventory table. Remove
Ravioli site from discussion.
25 Inventory Accessory Dwelling Units (ADU): The element projects 480 ADUs over the planning period or approximately 60 ADUs per year over the eight-year planning period. The element also notes permitting 44 ADUs in 2019, 47 in 2020, and 66 in 2021. The trend does not consider the number of permits in 2018 (eight ADUs) and does not support an assumption of 60 ADUs per year. To support assumptions for ADUs in the planning period, the element should reduce the number of ADUs assumed per year and reconcile trends with HCD records, including additional information such as more recent permitted units and inquiries, resources and incentives, other relevant factors and modify policies and programs as appropriate. Further, programs should commit to additional incentives and strategies, frequent monitoring (every other year) and specific commitment to adopt alternative measures such as rezoning or amending the element within a specific time (e.g., six months) if needed.
The City issued building permits
for 22 ADUs in 2018, not eight; the
estimated annual ADU
development was based on a four
year average (2019-2022) of
permits issued; and the policy
does include programs to
incentivize ADU production into
the future.
Update average to include five
years of permit data and
adjust future projections
accordingly; and update policy
to include programs to be
more explicit about annual
monitoring and incentives to
support local ADU production.
26 Inventory AB 725: For jurisdictions that are considered Metropolitan, the element must identify at least 25 percent of the remaining moderate and above moderate RHNA on sites that allow at least four units of housing (e.g., four plex or greater) (Gov. Code, § 65583.2, subd. (c)(4)).
This requirement was not included
in the original HCD completeness
checklist, and many jurisdictions
are receiving this comment.
Research inventory for
compliance, and add a
narrative in the methodology
section to address.
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27 Inventory Infrastructure: While the element includes a general discussion on water and sewer capacity, it must demonstrate sufficient existing or planned water and sewer capacity to accommodate the City’s regional housing need for the planning period. (Gov. Code, § 65583.2, subd. (b).).
The Draft HE is using existing
zoning capacity to meet its RHNA,
and both of the City's water
providers have an adopted Urban
Water Management Plans based
on this existing zoning capacity;
sewer capacity has been
demonstrated with the current
and future treatment plant.
Add more discussion on the
current Water Service Plans
and Sewer Treatment Plant
capacity.
28 Inventory In addition, the element generally mentions infrastructure constraints for infill development. The element must describe and analyze the constraints as well as their impacts on the identified sites to meet the RHNA.
The Draft HE provided an
explanation regarding constraints
in general terms; this comment
seeks details on a site-by-site
basis, which will require additional
analysis.
Provide additional information
in the sites inventory.
29 Inventory For your information, water and sewer service providers must establish specific procedures to grant priority water and sewer service to developments with units affordable to lower-income households. (Gov.
Code, § 65589.7.) Local governments are required to immediately deliver the housing element to water and sewer service providers. HCD recommends including a cover memo describing the City ’s housing element, including the City’s housing needs and regional housing need. The element should demonstrate compliance with these requirements and add or modify programs, if necessary. For additional information and sample cover memo, see the Building Blocks at https://www.hcd.ca.gov/priority- for-water-and-sewer.
The Draft HE included information
to demonstrate compliance with
this requirement.
Direct reviewer to where this
information is located; and, if
needed, add a program to
specifically indicate the City
will comply.
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27 Inventory Infrastructure: While the element includes a general discussion on water and sewer capacity, it must demonstrate sufficient existing or planned water and sewer capacity to accommodate the City’s regional housing need for the planning period. (Gov. Code, § 65583.2, subd. (b).).
The Draft HE is using existing zoning
capacity to meet its RHNA, and both
of the City's water providers have an
adopted Urban Water Management
Plans based on this existing zoning
capacity; sewer capacity has been
demonstrated with the current and
future treatment plant.
Add more discussion on the
current Water Service Plans and
Sewer Treatment Plant capacity.
28 Inventory In addition, the element generally mentions infrastructure constraints for infill development. The element must describe and analyze the constraints as well as their impacts on the identified sites to meet the RHNA.
The Draft HE provided an explanation
regarding constraints in general
terms; this comment seeks details on
a site-by-site basis, which will require
additional analysis.
Provide additional information in
the sites inventory.
29 Inventory For your information, water and sewer service providers must establish specific procedures to grant priority water and sewer service to developments with units affordable to lower-income households. (Gov. Code, §
65589.7.) Local governments
are required to immediately deliver the housing element to water and sewer service providers. HCD recommends including a cover memo describing the City ’s housing element, including the City’s housing needs and regional housing need.
The element should demonstrate compliance with these requirements and add or modify programs, if necessary. For additional information and sample cover memo, see the Building Blocks at https://www.hcd.ca.gov/priority-for-water-and-sewer.
The Draft HE included information to
demonstrate compliance with this
requirement.
Direct reviewer to where this
information is located; and, if
needed, add a program to
specifically indicate the City will
comply.
30 Inventory Environmental Constraints: While the element generally describes a few environmental conditions within the City (p. H-B-44), it must relate those conditions to identified sites and describe any other known environmental or other constraints that could impact housing development on identified sites in the planning period.
The Draft HE provided an explanation
regarding constraints in general
terms; this seeks more detail on a site-
by-site basis.
Provide additional information in
the sites inventory.
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31 Zoning for
Housing Types
Emergency Shelters: The housing element must demonstrate the permit processing, development, and management standards for emergency shelters are objective and encourage and facilitate the development of, or conversion to, emergency shelters. In particular, the element describes development standards for emergency shelters;
however these standards
are beyond the development standards allowed under housing element law.
The element must demonstrate that emergency shelters are subject to the same development and management standards applicable to residential or commercial development within the same zone except for those standards prescribed by Government Code section 65583 (a)(4)(A).
Policy H-3.7 that identifies
program to evaluate City policies
and zoning to meet or expand
emergency shelters.
Constraints analysis in Appendix B,
Section 2.9.5-2.9.7 provides
general information about zoning
capacity, strategies and programs
to provide emergency shelters and
address homelessness.
- Review existing
requirements and constraints
analysis against State law and
revise, adding a program if
needed.
- Add AB 139 discussion and
possible program to address
emergency shelter parking
requirements.
- Update Policy H 3.7 to allow
Low Barrier Navigation
Centers in areas consistent
with Government Code
section 65660.
32 Zoning for
Housing Types
The element must also clarify that emergency shelters are allowed without discretionary action in the C2 zone and describe sufficient and suitable capacity in the identified zone.
This is identified in Constraints,
Appendix B, Section 2.9.6.
Emergency shelters are allowed by
right in the C2 and C3 zones with a
300 ft. buffer from R1 zones.
33 Zoning In addition, the element should describe how emergency shelter parking requirements comply with AB139/Government Code section 65583, subdivision (a)(4)(A) or include a program to comply with this requirement.
This comment was not addressed
in the Draft HE.
34 Zoning Low Barrier Navigation Centers: While the element includes a program to allow Low Barrier Navigation Centers, it is limited to emergency shelter zones. Low Barrier Navigation Centers shall be a use by-right in zones where multifamily and mixed uses are permitted, including nonresidential zones permitting multifamily uses pursuant to Government Code section 65660. The element must demonstrate compliance with this requirement and include programs as appropriate.
This comment was not addressed
in the Draft HE.
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35 Zoning Single Room Occupancy (SRO) Units: The element must describe where SROs are allowed or add a program as appropriate.
This comment was not addressed in
the Draft HE.
Staff to review existing
requirements against State law
and revise, adding a program if
needed. Maintain existing
program from previous Housing
Element, if it addresses HCD
comment.
36 Zoning Manufactured Housing: The element must clarify whether manufactured homes are subject to additional regulations beyond state law if on a permanent foundation and add a program as needed
The City allows manufactured homes
as single-family dwellings.
Staff to review existing zoning
requirements against State law
and revise, adding a program if
needed.
37 Zoning Accessory Dwelling Unit (ADU): The element indicates the City modifies its zoning code to ease barriers to the development of ADU’s. However, after a cursory review of the City’s ordinance, HCD discovered several areas which are not consistent with State ADU Law. HCD will provide a complete listing of ADU non- compliance issues under a separate cover. As a result, the element should add a program to update the City’s ADU ordinance in order to comply with state law. For more information, please consult HCD’s ADU Guidebook, published in December 2020, which provides detailed information on new state requirements surrounding ADU development
A letter from HCD about the City's
ADU ordinance and compliance with
state law has not yet been received; a
copy of the City's adopted ADU
ordinance was sent to HCD last April
and state law notes that HCD should
identify any compliance concerns
within 60 days.
Evaluate comment letter from
HCD, once received, and amend
as the ADU Ordinance as
necessary to ensure compliance
with state law; add a program to
note the ADU ordinance will be
maintained in compliance with
state law.
38 Constraints Land Use Controls: The element must identify and analyze all relevant land use controls impacts as potential constraints on a variety of housing types. The analysis should analyze land use controls independently and cumulatively with other land use controls. The analysis should specifically address requirements related to parking, heights, lot coverage and limits on allowable densities. The analysis should address any impacts on cost, supply, housing choice, affordability, timing, approval certainty and ability to achieve maximum densities and include programs to address identified constraints.
An analysis of the City's land use
controls and how they impact housing
development was provided in the
Constraints Analysis.
Update Constraints Analysis to
provide additional information.
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39 Constraints The element must analyze the maximum heights of 35 feet in multifamily zones and whether three-story buildings are allowed as well as whether allowed densities can be met in the TOD Hillsdale Station with a 24-foot height restriction.
The maximum height in multifamily
zones ranges between 35 to 55 feet.
There are no limits on building stories
in the City.
TOD Hillsdale Station area allows
maximum heights of 24 feet to 55 feet.
The 24 feet height limit applies to
single-family zone parcels in the
Hillsdale TOD Specific Plan.
Staff will edit the Land Use
Control (Table 2) to clarify the
height requirements as up to
55 feet.
40 Constraints The element should also analyze the open space requirements for the R-3 zone.
A program (Policy H-1.1.3) was
identified to study impediments to
missing middle housing (including
open space requirements).
Update the constraints analysis
to evaluate open space
requirements in the R-3 zone
and amend Policy H-1.1.3 as
needed.
41 Constraints In addition, the element should analyze requiring more than one parking space for studio and one-bedroom units and the minimum requirement of 2.2 spaces for 1,400 square foot units regardless of bedroom size and add programs to specifically address the constraints.
General analysis states that parking
may be a constraint and projects tend
to utilize State Density Bonus Law to
request reduced parking standards. A
program (Policy H-1.7) was identified
to evaluate parking requirements for
residential and mixed-use
development projects near transit.
Add analysis of how parking
requirements may pose a
constraint to all multifamily
housing developments and
amend Policy 1.7 as needed.
Recent state legislation AB
2097 already affects
jurisdictions' ability to require
parking for projects near
transit.
Council direction would be
needed on whether the City
should evaluate parking
requirements for the rest of the
City
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42 Constraints In addition, the element should clarify how multifamily developments are allowed in the E and C zones and whether they require a use permit.
Both in the element and in public comments, height restrictions, floor area definitions, maximum densities of 50 dwelling units an acre, and design review guidelines were identified as constraints to development and should be addressed in programs as appropriate.
Multi-family developments are allowed in
certain E and C zones, both by-right and
through a Special Use Permit (noted in
Appendix B, Section 2.7.7). The Draft HE
analysis and policies address this comment
as follows:
- Revise floor area definition (Policy H1.7)
- Adopt Objective Design Standards (Policy
H1.8).
- Existing height and density requirements
do not preclude multi-family development
or prevent the City from meeting its RHNA.
- The General Plan Update process is
anticipated to allow for increased heights
and densities.
Update Constraints Analysis to
clarify multi-family development
requirements in the E and C zones;
and update analysis to explain how
existing development standards
affect housing development
projects as appropriate.
43 Constraints Fees and Exaction: The element must describe all required fees for single family and multifamily housing development, including impact fees, and analyze their impact as potential constraints on housing supply and affordability. For example, the analysis could identify the total amount of fees and their proportion to the development costs for both single family and multifamily housing. While Table 4 lists fee deposits, the element should also include typical fees for each and clarify whether the fees are the same for single family and multifamily developments.
Constraints Analysis included fees and
analysis by typical single-family and multi-
family development (Table 6). Staff
identified that the City's fee are at the
median when compared to other
jurisdictions in San Mateo County.
Update narrative/analysis to be
more explicit about if the City's
fees pose a constraint to housing
development.
44 Constraints
The element should also identify fees related to annexation, variances, conditional use permits (CUP), general plan amendments, zone changes, site plan review, planned unit developments, specific plans, development agreements, and environmental fees. Table 6 should also describe the typical fees as a percent of the total development cost for both single family and multifamily developments and add a program as appropriate.
Most of this information is provided in
Appendix B, Section 2.8.1.
Review Constraints Analysis against
HCD comment and update as
needed; update Table 6 to include
requested fee amounts and specify
all planning application types.
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45 Constraints Local Processing and Permit Procedures: While the element includes information about processing times, it should also describe the procedures for a typical single family and multifamily development. The analysis should address the approval body, the number of public hearing if any, approval findings and any other relevant information, specifically for special use permits, site plans and architectural review (as well as whether finding five is related to a crime free ordinance). The analysis should address impacts on housing cost, supply, timing and approval certainty. The element should identify and analyze approval findings for impacts on approval certainty, the presence of processes or guidelines to promote certainty and add or modify programs as appropriate. The element should also clarify whether the listed typical approval times are for both single family and multifamily developments. Lastly, it should clarify whether the preapplication process adds six to nine months in addition to the typical approval times listed and add or modify programs as appropriate.
This information is provided in
Appendix B, Section 2.7.2.
Review Constraints Analysis against HCD
comments and update as needed
46 Constraints Local Ordinances
: While the element identifies the City’s community benefit program, it must describe whether the incentives are in addition to state density bonus law. The element must clarify how the 75 dwelling units an acre allowed using the community benefit program interacts with the restricted densities under measure Y. In addition, the element must describe how the inclusionary program, community benefit program, and state density bonus law interact with incentives provided.
The Draft HE provided a general
discussion on this topic, but not to
the level requested by HCD.
Update Draft HE narrative to provide
additional information and clarification.
47 Constraints Zoning Fees and Transparency
: The element must clarify its compliance with
new transparency requirements for posting all zoning and development standards, and inclusionary requirements for each parcel on the jurisdiction’s website pursuant to Government Code section 65940.1(a)(1).
The constraints section states that
the City meets all transparency
requirements for Gov. Code Section
65940.1(a)(1).
Verify and provide cross references in the
narrative.
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48 Constraints Measure Y: The element must describe the impacts of measure Y on height and density restrictions as a constraint on housing development and affordability. The element must add a program to include outreach and mitigation measures for the impact of Measure Y on housing development throughout the planning period. The element should analyze the measure as a constraint on development based on site suitability for development.
The Draft HE identifies a path to
meeting the City's 6th cycle RHNA
allocation within the limits of
Measure Y; and Measure Y was
discussed in the Constraints
Analysis, noting it as a housing
production constraint that results in
additional sites needed to meet the
City's RHNA. The community
discussion about Measure Y and
housing growth in the City over the
next 20 years is happening and will
continue as part of the GPU
adoption process.
Add additional information about the
General Plan Update (GPU) and how this
topic will be addressed as part of the GPU
adoption process in 2023/24.
49 Constraints State Density Bonus Law
: The City’s current density bonus ordinance should
be reviewed for compliance with current state density bonus law and programs should be added as necessary. (Gov. Code, § 65915.) The City's current Density Bonus
Ordinance is in compliance with
State law.
Note that the ordinance is in compliance,
and include a program that the City will
periodically review ordinance to ensure it
maintains compliance with state law.
50 Constraints Design Review
: The element must describe and analyze the design review guidelines and process, including approval procedures and decision-making criteria, for their impact as potential constraints on housing supply and affordability. For example, the analysis could describe required findings and discuss whether objective standards and guidelines improve development certainty and mitigate cost impacts. The element must demonstrate this process is not a constraint or include a program to address this permitting requirement, as appropriate.
The City is in the process of
developing Objective Design
Standards and has a program to
implement (Policy H-1.8).
Update narrative to conclude whether
design review guidelines pose a
constraint.
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51 Constraints On/Off-Site Improvements: The element must identify subdivision level improvement requirements, such as minimum street widths (e.g., 40-foot minimum street width) and analyze their impact as potential constraints on housing supply and affordability.
Section 2.6 of Appendix B addresses
on/off-site improvements
associated with subdivisions and
planning applications.
Update narrative to provide further details
on subdivision requirements.
52 Constraints Constraints on Housing for Persons with Disabilities: The element briefly describes its reasonable accommodation procedures. However, the element should also describe the process and decision-making criteria such as approval findings and analyze any potential constraints on housing for persons with disabilities.
Section 2.9.4 of Appendix B
identifies the City's requirements
for reasonable accommodation,
including those that can be done
by-right.
Expand narrative to describe the process
and decision-making criteria for
reasonable accommodation requests
under SMMC 27.78.
53 Constraints
In addition, the element states that Policy H.1.14 commits to revise the definition of family, but there are no actions within the program to revise the definition of family to remove constraints. The element must add or revise a program to remove the constraints as noted.
Noted. Add program to revise the definition of
family to remove constraints.
54 Constraints Lastly, group homes for seven or more persons appears to be excluded from several zones allowing residential uses and subject to a CUP. The element should evaluate these requirements as constraints and include specific commitment to amend zoning and permit procedures to allow these uses in all residential zones with objectivity to facilitate approval certainty.
This was included as a program
(Policy H-
1.14) to allow larger group
homes consistent with State law
and fair housing requirements.
Update program and narrative to meet
statutory requirements and address
constraints.
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55 Constraints Developed Densities and Permit Times: The element must be revised to include analysis of requests to develop housing at densities below those anticipated, and the length of time between receiving approval for a housing development and submittal of an application for building permits that potentially hinder the construction of a locality’s share of the regional housing need.
Staff included an analysis of time lapse
between planning approval and building
permit submittal.
Direct HCD to the location of this
information - H-B-43
56 Needs Special Needs Populations
: While the element quantifies the City’s special
needs populations, it must also analyze their special housing needs. For a complete analysis of each population group, the element should discuss challenges faced by the population, the existing resources to meet those needs (availability senior housing units, # of large units, # of deed restricted units, etc.), an assessment of any gaps in resources, and proposed policies, programs, and funding to help address those gaps. In addition, the element must quantify and analyze the number of elderly persons in the City This information was provided in the
needs packet supplied by ABAG, and in
other places throughout the Element
(such as in the resources section)
Create a summary of this information
from various areas of the Housing
Element, and indicate the programs
to address those needs.
57 GPPs To address the program requirements of Government Code section 65583, subdivision (c)(1-6), and to facilitate implementation, programs should include: (1) a description of the City’s specific role in implementation; (2) definitive implementation timelines; (3) objectives, quantified where appropriate; and (4) identification of responsible agencies and officials.
Programs to be revised include the following:
This comment is the preamble to the
individual policy comments listed below.
N/A
58 Policy 1.2 (Utilize Public Funding): This program should include proactive outreach to developers throughout the planning period as well as a geographic target for the metric.
The current policy states: "Produce City
supported housing projects with
affordability restrictions utilizing local
public
funds; and use this funding to leverage
other
regional, state, and federal funding
sources
to increase the number of affordable
housing
units developed in each project." It
includes three implementation measures
but does not include a standalone
outreach measure.
An implementation measure could
be added to - add study areas for GP
update - hold developer roundtable
bi-annual meetings etc.
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59 Policy 1.4 (Incentivize ADU Development): This program should revise action C to include discrete timing of how often it will be completed and monitored. In addition, action D should include back-up actions if estimates are not met (e.g., identify additional sites or provide additional incentives) as well as monitor affordability.
For Action C, ADU permit fee review was
anticipated when the City's fee schedule is
reviewed/updated (approx. every five years);
for Action D, it is generally consistent with the
comment, but does not provide the level of
detail requested by HCD.
Action C - Increase frequency of
when ADU permitting fees reviewed
(every 2-3 years).
Action D - Provide more specific
information about how ADU
production can be
maintained/encouraged, and explore
how ADU affordability could be
monitored.
60 Policy 1.5 (Encourage Family Housing): The program should include back-up actions, with specific timing, if the identified incentives are not implemented.
The current program measure and
implementation action discuss proposing 3-
bedroom affordable units as part of the City's
inclusionary requirements.
City staff needs to conduct a study
and come to council with a proposal.
Also, perhaps the policy could be
broken into City subsidized projects
and private development projects.
61 Policy 1.6 (Streamline Housing Application Review): Action B must include specific timing of when permit application requirements will be updated. In addition, the timing of action C must be completed earlier in the planning period.
Action B - Since permit application
requirements are constantly being updated,
the current Draft HE mentions 2023-2031.
Action C - The Planning Division continues to
implement SB 330 timelines for qualifying
projects.
Action B - The timeline would be
updated to track the first round of
streamlining measures, which are
expected to be completed in 2023-
2024.
Action C - Verify if code amendments
are needed for SB 330, or delete.
Possibly combine with 1.7, 1.8, 1.9, to
keep all zoning amendments under
one policy. Perhaps even 1.15, see
below.
62 Policies 1.15 (Supportive Housing Requirements) and 1.16 (Mobile Home Parks): These programs must revise timing to be implemented earlier in the planning period for a beneficial impact.
Current timing is 2027-2028. Should it be combined with other code amendment efforts (see
above)?
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63 Policy 1.17 (Farmworker Housing): This program must move up timing to be implemented earlier in the planning period. In addition, the program should cite the Government Code for farmworker housing.
Current timing is 2029-2030. Can be amended to cite Government Code section. Should it be combined
with other code amendment efforts?
64 Policy 1.18 (Permitting and Development Fee Review): This program must clarify timing in Action A, specifically whether the study will be complete within the identified timeframe or if the fees will be reduced by that date. In addition, Action B must specify when the first review will occur and when adjustments will take place.
The current timing is 2024-2025, which is
when the study would be completed and the
fees updated, if needed.
Clarify in timeline
65 Policy 1.19 (Senior Housing): This program must clarify what potential actions will be implemented for seniors as well as whether other special needs groups are included in the program.
The current program measure states that the
City would "Evaluate potential policies and
code amendments to support the production
of
housing for seniors."
Other special needs groups are addressed in
different programs.
The current policy states the
intended action. Identify what
specific actions would be
implemented.
66 Policy 2.1 (Housing Rehabilitation Efforts), 2.3 (Energy and Water Efficiency), 3.4 (Expand Tenant Protections), and 4.3 (Community Education and Outreach): This program must describe how often outreach will occur throughout the planning period.
The Draft HE does not explicitly describe the
frequency of outreach efforts.
Update the Implementation Actions
to make outreach timelines more
explicit.
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67 Policy 3.3 (Evaluate Housing Revenue Sources): This program must describe the implementation component for action A.
The implementation component for Action A
is included in the Draft HE.
Update the Implementation Actions
to describe the implementation
component for Action A in greater
detail.
68 Policy 3.5 (Creation of Below Market Rate Set Asides): This program must add implementation and timing for what will result from the study.
The Draft HE does not explicitly describe the
timing of the results from the study.
Update the Implementation Actions
to make study timing and
implementation more explicit.
69 Policy 4.2 (Countywide Below Market Rate Unit Waitlist): This program must clarify how support will be provided as well as how often throughout the planning period.
The Draft HE does not explicitly state how
support will be provided.
Expand and clarify on how the City
will provide support to this program.
70 Policy 4.4 (Enable Affirmative Marketing): Timing must be clarified to state whether the marketing will occur once in the planning, or on a project-by-project basis.
The Draft HE does not specify whether the
marketing will occur once in the planning
period on a project-by-project basis.
Clarify timing to state that marketing
will occur on a project-by-project
basis.
71 Policy 5.1.2 (Regional Down Payment Assistance): This program should include outreach for education.
The Draft HE does not explicitly state an
outreach for education component.
Update to provide more details and
be more explicit about outreach.
72 Policy 5.2.2 (Incentivize Developers): This program must clarify whether incentives are in place, timing to implement the incentives, as well as conducting proactive outreach.
The Draft HE does not explicitly state the
timing to implement the incentives and the
proactive outreach efforts.
Update to provide more details and
be more explicit about the timing to
implement the incentives and
proactive outreach efforts.
73 Policy 5.3.2 (Fund Minor Home Repairs): The program should clarify how often outreach will occur as well as specify whether the metrics are annually or throughout the planning period.
The Draft HE does not explicitly state how
often outreach will occur.
Update to explicitly state how often
outreach will occur and clarify
whether the metrics are measured
annually or throughout the planning
period.
89 of 102
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Number
Section HCD Comment Current Status Recommendation
74 Policy 5.4.2 (Project Sentinel): This program should be revised to include outreach and describe how awareness will be increased.
The Draft HE does not explicitly include
outreach and how awareness will be
increased.
Update to include outreach and
describe how awareness will be
increased.
75 Policy 5.4.3 (Fair Housing Webpage): This program should describe how often the website will be updated and whether outreach will be included.
The Draft HE does not specify how often the
website will be updated and whether outreach
will be included.
Update to describe how often the
website will be updated and what
type of outreach will be included.
76 Policy 5.4.5 (Future Improvements in Disadvantaged Communities):
This program must include an action to implement the feasibility study as well as a back-up if the study is not implemented.
The Draft HE does not include an action to
implement the feasibility study.
Update to include an action to
implement the feasibility study and
back-up plan if the study is not
implemented.
77 Other GPPs Policy 1.1 (Monitor RHNA)
: While this program ensures sufficient sites
are identified, it should commit to identifying additional sites throughout the planning period if needed to accommodate the City’s RHNA.
This comment requests that the program be
amended to explicitly state the City will
identify additional sites as needed.
Revise program to be explicit.
78 Other GPPs
Policy 1.10 (Establish By-Right Housing for Prior Housing Sites) and 2.6:
Previously identified nonvacant sites are inadequate to accommodate the need for lower-income households unless the site is subject to a housing element program that requires rezoning within three years of the beginning of the planning period to allow residential use by-right for housing developments in which at least 20 percent of the units are affordable to lower-income households. (Gov. Code, § 65583.2, subd. (c).) The program must be revised to comply as well as clarify that the densities for the identified sites are appropriate for lower-income households. In addition, timing of Policy 2.6 should occur no later than 3 years from the start of the planning period.
The Draft HE includes a program to address
this requirement. The State requests
additional edits to confirm both timing and
appropriateness of densities for lower income
households.
Revise program to be explicit.
79 Other GPPs Policy 1.12 (Encourage Residential Uses within Housing Overlay) : The
program must clarify which commercial zones will be included in the program actions.
Policy noted commercial zones generally, but
individual zones are not identified.
Revise policy to be more specific
about which commercial zones will
be evaluated for inclusion in the
overlay.
90 of 102
Comment
Number
Section HCD Comment Current Status Recommendation
80 Other GPPs Policy 2.4 (Capital Improvements in Lower-Resourced Neighborhoods):
The program should describe what capital improvements will be included.
No specific capital improvements identified. Revise to provide more details, but will not be able to identify specific
projects, reference EJ policies and
community engagement in the GPU.
81 Other GPPs Policy 3.7 (Expanding Homeless Shelters)
: This program must clarify
implementation actions after the study in action A. In addition, a government citation must be added for Action C and implementation timing must be earlier in the planning period to ensure beneficial impact.
These details were not provided. Will try to provide more details, but challenging since the study would
identify potential implementation
actions, will also evaluate feasibility
of implementing earlier.
82 Other GPPs While the element includes Policy 5.1.3 (Regional Forgivable Loan Program) to support the regional program to assist ELI households, it is a regional policy. The element should specify what actions the City is taking to address the ELI need. The program should also specify whether proactive outreach will occur to implement the program.
These details were not provided. Research strategies that can be implemented locally and will note
that proactive outreach will be
included.
83 Other GPPs Policy 1.3 (Increase Below Market Rate Unit Production): This program should be revised to include an action to comply with State Density Bonus law as well as specific timing for implementation. The program should clarify whether the action currently listed is in addition to state law requirements.
Policy meets these requirements, but did not
explicitly note these details.
Revise to be more explicit
84 Other GPPs Policy 1.7 (Update Zoning Code Development Standards): This program must make a firm commitment to remove parking requirements that are a constraint to multifamily development.
Intent of the policy was to evaluate and let
community and decisionmaker input guide the
updated parking standards, but does not
commit to a specific outcome.
Request input from the City Council
on making a stronger commitment
to modifying or removing any parking
requirements identified as a
constraint to multi-family
development.
85 Other GPPs Policy 1.13 (Encourage Development of Missing Middle Housing): This program should include specific implementation and specify whether the identified policies and codes will be revised to remove constraints.
The intent of this policy is to reduce/remove
contains to missing middle housing
developments; but does not commit to a
specific outcome.
Request input from the City Council
on committing to modifying or
removing any policies or codes that
are a constraint on missing middle
housing development.
91 of 102
Comment
Number
Section HCD Comment Current Status Recommendation
86 Other GPPs Policy 1.14 (Evaluate and Update Special Needs Group Housing Requirements): This policy should commit to reviewing and revising procedural requirements to permit group homes for seven or more persons in all zones allowing residential uses based on objective criteria to facilitate approval certainty. In addition, the program must be implemented earlier in the planning period to ensure a beneficial impact.
The policy does not include a commitment
to a specific outcome.
Request input from the City Council
on committing to reviewing and
revising procedural requirements to
permit group homes in all zones that
allow residential uses based on
objective criteria to facilitate
approval certainty.
87 GPPs AFFH While programs in Table 13 include specific timelines, all programs in the element that AFFH must include specific metrics and milestones with geographic targets that address the fair housing analysis. In addition, Policy
5.2.1 (City Supported Housing) should specify what actions will be taken to add more affordable housing to moderate and high resource areas as well as whether incentives are provided.
As noted, all programs include specific
timelines, but this request seeks further
detail on actions to be taken.
Revise draft to be explicit
88 Other GPPs Policy 2.2 (Retention of Existing Lower-Income Units) and 5.3.3 (Monitor Affordable Housing Projects) should reference State Preservation Notice Law (Gov. Code, § 65863.10, 65863.11, and 65863.13) and state noticing requirements to tenants and affected public entities. The program should also be expanded to include other potential at-risk properties not included in the analysis. HCD will send additional information under separate cover.
The City is waiting on additional
information from HCD and will reference
the State Preservation Notice Law and the
state noticing requirements to tenants in
Policies 2.2 and 5.3.3.
Revise draft to be explicit
89 Quantified
Objectives
The element must include quantified objectives to establish an estimate of housing units by income category that can be constructed, rehabilitated, and conserved over the planning period. While the element includes these objectives for construction, it must also include estimates for rehabilitation and not limit conserved units to at-risk properties.
The City does 31 rehab projects annually
through CDBG over 8 years plus 10
expected CALHOME rehabs
Revise draft to be explicit
90 Public
Participation
While the element includes a summary of public participation including outreach to the community, it must also describe whether translation services were available outside of the Lets Talk Housing sessions.
Partially complete - needs to be added to
Public Participation section
Revise draft to be explicit or point
HCD to the page where this is
covered
91 Consistency with
the GP
While the element discusses how internal consistency will be achieved with other elements of the general plan as part of the housing element update, it should also discuss how internal consistency will be maintained throughout the planning period.
The draft explained the relationship
between the Housing Element and the
General Plan Update effort and how
consistency will be maintained.
Add a program that codifies the
existing practice of tracking all
General Plan Amendments as they
occur to maintain internal
consistency.
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Housing Element Implementation Schedule
Year Policy Action GPU Implementation
Ongoing 2023-2031 H1.1 - Monitor RHNA Provide annual report to City Council on RHNA H1.2 - Public Funding a) Set aside "Boomerang Funds"
H1.2 - Public Funding c) Prioritize funds for at least 535 BMRs H1.4 - ADUs b) Create uniform ADU standards countywide
H1.4 - ADUs c) Adjust ADU fees
H1.4 - ADUs d) Monitor ADU/JADU production
H1.6 - Streamline Applciation Review b) Update permit submittal requirements H1.18 - Fee Study b) Update fee schedule
H2.1 - Housing Rehabilitation
a) Annual goal of 10 minor home repairs and 14
accessibility modifications
H2.1 - Housing Rehabilitation b) Provide $500,000 for rehabilitation loans
93 of 102
Housing Element Implementation Schedule
Year Policy Action GPU Implementation
Ongoing 2023-2031
H2.1 - Housing Rehabilitation c) Affirmatively market rehabilitation programs H2.3 - Energy/Water Efficiency a) Annual goal of 7 weatherization upgrades H2.3 - Energy/Water Efficiency b) Update reach codes every three years H2.4 - Capital Improvements
Annual improvement projects in North
Central/North Shoreview
H3.1 - Prevent Homelessness a) Provide CDBG/PLHA for homeless prevention H3.1 - Prevent Homelessness
b) Support county on Stone Villa shelter
conversion
H3.2 - Investigate Fair Housing
Annual goal of 18 investigations, 30
consultations, outreach for 26 individuals, and
legal assistance for 185 renters
H3.3 - Housing Revenue Sources b) Evaluate new funding sources H3.7 - Expand Homeless Shelters a) Evaluate best practices for shelter expansion
94 of 102
Housing Element Implementation Schedule
Year Policy Action GPU Implementation
Ongoing 2023-2031
H3.7 - Expand Homeless Shelters b) Evaluate zoning to ensure shelter capacity H4.1 - Update Housing Webpage
a) Improve webpage with new housing
materials
H4.1 - Update Housing Webpage
b) Provide housing materials in multiple
languages
H4.2 - Countywide BMR Waitlist
Support the county’s online portal for a BMR
waitlist
H4.3 - Education/Outreach
a) Build a robust community engagement
process
H4.3 - Education/Outreach b) Participate in countywide best practices H4.3 - Education/Outreach
c) Provide info on tenant protections,
discriminatory practices, and resources for
special needs groups
H5.4.2 - Landlord Training
Increase awareness of fair housing law/tenants
rights
Ongoing Subtotal 27
95 of 102
Housing Element Implementation Schedule
2023
Year Policy Action GPU Implementation
2023
H1.6 - Streamline Application Review a) Update Pre-App and Dev Review GPU Adoption
H1.8 - Objective Design Standards Adopt Objective Design Standards H1.9 - Minimum Density a) Establish min density for mixed use H1.9 - Minimum Density b) Require residential in all mixed use H1.20 - Prioritize Infrastructure Deliver HE to local water and sewer providers H2.5 - Housing Resilience
Complete levee project in low-income
neighborhood
2023 Subtotal 6
96 of 102
Housing Element Implementation Schedule
2024
Year Policy Action GPU Implementation
2024
H1.3 - Inclusionary Policy a) Amend Affordable Housing Ordinance Citywide Rezoning to
align with GPU Land Use
Map
H1.4 - ADUs a) ADU tools and resources
H1.6 - Streamline Applciation Review a) Update Pre-App and Dev Review H1.11 - SB9 Adopt an ordinance to implement SB9
H3.4 - Tenant Protections a) Extend AB1482 to tenants with tenure H3.4 - Tenant Protections c) Strengthen enforcement penalty H3.6 - Rental Registry Research options for rental registry list 2024 Subtotal 7
97 of 102
Housing Element Implementation Schedule
2025
Year Policy Action GPU Implementation
2025
H1.2 - Public Funding b) Create Housing Trust Fund
Citywide Rezoning to
align with GPU Land Use
Map
H1.3 - Inclusionary Policy b) Adopt community benefits program H1.7 - Update Development Standards a) Amend FAR Provisions H1.10 - Prior Housing Sites Establish by-right designation H1.18 - Fee Study
a) Implement ways to reduce fees for
multifamily
2025 Subtotal 5
98 of 102
Housing Element Implementation Schedule
2026
Year Policy Action GPU Implementation
2026
H1.5 - Family Housing
Require minimum for 3-bedroom units in city
funded projects
Update and Amend
Specific Plans including
Downtown Area Plan
H1.6 - Streamline Applciation Review c) SB 330 zoning code amendment H1.12 - Housing Overlay Amend Overlay ordinance for multi-family H1.13 - Missing Middle Housing a) Conduct sites study for missing middle H1.13 - Missing Middle Housing b) Research SB10 code amendment H3.3 - Housing Revenue Sources a) Conduct study on increasing CLF H3.4 - Tenant Protections
b) Landlord documentation to close remodel
loophole
H3.5 - BMR Set Asides
Research prioritization of special needs/large
families for BMR
99 of 102
Housing Element Implementation Schedule
2026 -2027
Year Policy Action GPU Implementation
2026
H4.4 - Affirmative Marketing a) Research for affirmative marketing strategy Update and Amend
Specific Plans including
Downtown Area Plan
H4.4 - Affirmative Marketing
b) Include new special needs groups in
marketing
H4.4 - Affirmative Marketing c) Include bilingual materials in marketing H5.4.4 - Reasonable Accomadations Implement a signage program in multifamily 2026 Subtotal 12
2027 H2.2 - Retain Low Income Units a) Preserve affordability at Bridgepoint H5.4.5 - No Displacement Establish a community land trust 2027 Subtotal 2
100 of 102
Housing Element Implementation Schedule
2028-2029
Year Policy Action GPU Implementation
2028
H1.14 - Special Needs Housing
Amendment to allow group homes for 7+
residents
H1.15 - Supportive Housing AB 2162 zoning code amendment H1.17 - Farmworker Housing
Amend zoning code to allow farmworker
housing
H2.6 - Replacement Units
Ordinance to permanently requrie replacement
units
2028 Subtotal 4
2029
H3.7 - Expand Homeless Shelters
c) Amend zoning to allow low barrier
navigavtion centers where emergency shelters
are
H5.3.1 - North Area Plan
Prepare area plan for North Shoreview/North
Central
2029 Subtotal 2
101 of 102
Housing Element Implementation Schedule
2030-2032
Year Policy Action GPU Implementation
2030
H1.16 - Mobile Home Parks GCS 65852.7 zoning code amendment H1.19 - Senior Housing Evaluate policies to encourage senior housing 2030 Subtotal 2
2031
N/A N/A
2031 Subtotal 0
2032
H2.2 - Retain Low Income Units b) Preserve affordability at Belmont Building 2032 Subtotal 1
Grand Total 68
102 of 102