San Mateo City Council
January 24, 2023

3. Increase coordination between the Planning Division, SMFCSD, and SamTrans to pursue strategies that increase access to high-performing schools for marginalized students. a. Collaborate with SMFCSD to identify priority for students who live in subsidized housing or underserved areas in the school assignment policy.
b. Collaborate with SMFCSD and SamTrans to ensure the provision of efficient transportation options for students who want to attend high-performing schools outside their neighborhood.

While these strategies have the potential to substantially improve both housing and educational equity, they should not take the place of investment in housing and schools in low-income and Latinx communities in San Mateo. These investments have opportunity-enhancing effects on the surrounding area and are critical for meeting the needs of people who cannot or do not want to move.7 Simultaneous pursuit of the coordinated housing and school integration strategies outlined in this letter and investment in historically disinvested neighborhoods is the most promising path to equity. Additionally, the City must couple these policies with strong anti-displacement protections to ensure that

7 Diamond, R., & McQuade, T. (2019). Who Wants Affordable Housing in Their Backyard? An Equilibrium Analysis of Low-Income Property Development. Journal of Political Economy, 127(3), 1063-1117.

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4 gentrification pressures do not reduce school diversity by pushing Latinx and low-income students out of schools.

Again, I applaud the prioritization of equity in San Mateo’s draft 2023-2031 Housing Element. I welcome the opportunity to further discuss the recommendations in this letter with you and your colleagues. Thank you for your consideration.

Sincerely,
Natalie Spievack
Master of City Planning Candidate
University of California, Berkeley

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5 Appendix

FIGURE 1
School Ratings Within Each School Assignment Boundary, SMFCSD

Source: San Mateo-Foster City School District (2022); GreatSchools (2022).

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6 FIGURE 2
Median Family Income as a Percent of Area Family Median Income

Source: PolicyMap using American Community Survey 5-Year Estimates (2015-2019).

FIGURE 3
Percent Hispanic or Latino

Source: PolicyMap using American Community Survey 5-Year Estimates (2015-2019).

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7 FIGURE 4
Major Affordable Housing Developments Approved During the 2015-2023 Housing Element Cycle and Rating of Zoned Elementary School

Notes: Kiku Crossing marked as “dispersed” because it is located in North Central San Mateo, where students are assigned to various elementary schools throughout San Mateo.

Source: Google Earth using the City of San Mateo’s Draft 2023-2031 Housing Element; GreatSchools (2022).

FIGURE 5
Draft Sites Inventory for 2023-2031 Housing Element and Rating of Zoned Elementary School

Source: City of San Mateo’s Draft 2023-2031 Housing Element; GreatSchools (2022).

Dispersed
Sunnybrae - 3
Sunnybrae - 3
Sunnybrae - 3
Parkside - 4
Sunnybrae - 3
Laurel - 4
Audubon - 6
Foster City - 9
Dispersed

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8 FIGURE 6
Number of Households with Housing Choice Vouchers

Source: PolicyMap using American Community Survey 1-Year Estimates (2020).

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C I T Y O F S A N M A T E O 2 0 31 H O U S I N G E L E M E N T Appendix H-F

THE FOLLOWING ADDITIONAL CORRESPONDENCE WAS ADDED TO THIS APPENDIX FOLLOWING THE DRAFT HOUSING ELEMENT SUBMITTED TO HCD IN JULY 2022.

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1 From:

Sent: Monday, May 23, 2022 8:51 AM
To:

Subject: FW: Agenda Item #1 San Mateo Housing Element - Carpenters Input Attachments: San Mateo Housing Element - Council.pdf
FYI

From:

Sent: Monday, May 23, 2022 8:21 AM
To:

Subject: FW: Agenda Item #1 San Mateo Housing Element ‐ Carpenters Input

Patrice M. Olds, MMC
City Clerk | City of San Mateo
330 W. 20th Ave., San Mateo, CA 94403

From: Edward Evans
Sent: Friday, May 20, 2022 3:54 PM
To: City Council (San Mateo) <[email protected]> Cc: Clerk <[email protected]>
Subject: Agenda Item #1 San Mateo Housing Element ‐ Carpenters Input

Dear Madame or Sir,
Please kindly provide a copy of this to each Council member's packet, before the next City Council meeting and please keep one for your records as well. Thank you very much on behalf of The Carpenters Union.

All the best,

Ed Evans
Senior Field Representative/Financial Secretary-Treasurer Local 217, San Mateo County

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2 Nor Cal Carpenters Union

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

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1 From: Housing
Sent: Friday, May 20, 2022 2:40 PM
To:

Subject: FW: Housing Element Sites Inventory

From: Charity Wagner
Sent: Thursday, May 19, 2022 4:03 PM
To: Zachary Dahl
Cc:

Subject: Re: Housing Element Sites Inventory

Thank you Zachary. It was our intention for the property to be added to the inventory given the city councils direction for the land‐use designation to be updated as part of the general plan amendment process. Understanding now, based on your email below, that the city is only interested in adding sites to the inventory that have a current designation that supports additional development capacity, it makes sense that this property not be included in the inventory. I do know that the landowners are seeking interest in future development applications once the designation has been updated through the city general plan amendment process.

On Thu, May 19, 2022 at 3:51 PM Zachary Dahl   wrote:

Hi Charity,

Thank you for the comment letter and the interest in having this site added to the Housing Element’s Adequate Sites Inventory.  This letter will be added to the record and provided to the City Council when they review the draft Housing Element at a special meeting on Monday, May 23rd.

In reviewing your site, it appears that based upon it’s current land use and density, it does not have any further development capacity.  For the Sites Inventory, we are focusing on sites that can accommodate additional housing units based on their current land use and zoning designation and do not require any rezoning  Thus, this site does not meet the criteria we have set for inclusion on our Sites Inventory.  However, whether or not this site is included on our Sites Inventory does not change its current or future development potential, or ability to pursue a development application.

Thanks again, and have a nice afternoon.

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2 Zachary Dahl, AICP
Deputy Director
Community Development Department
330 W. 20th Ave., San Mateo, CA 94403

From: Charity Wagner
Sent: Thursday, May 5, 2022 11:45 AM
To: Zachary Dahl  ; Housing <[email protected]> Cc:

Subject: Re: Housing Element Sites Inventory

Hi Zach,

I am following up on our phone conversation from a couple weeks ago regarding a request to add the 1501‐1555 W Hillsdale property (Parkview Terrace) onto the Housing Sites Inventory list. Please accept the attached letter as a formal request from the landowner.

This property is an excellent candidate for the inventory because there is great potential to make use of underutilized space on an already developed multi‐family housing site. As stated in the attached letter, the existing apartments will remain (no displacement). Timing of the new construction is alsovery likely within this housing inventory cycle.

Lastly, the landowner was pleased with the City Council's direction to include this particular property in the preferred General Plan land use map update within an increase to medium density.

Thanks in advance for your consideration.

Sincerely, Charity

On Wed, Apr 13, 2022 at 9:52 AM Charity Wagner   wrote:

Hi Zach,

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3 I hope you are having a good week. I am writing to see if you have a minute to connect on the process for adding the property at 1501‐1555 West Hillsdale into the Housing Sites Inventory as part of the Housing Element Update. I see that the draft element is out for public review. We'd like to formally request inclusion on the inventory. Will the City consider individual requests for inclusion or are they limited to the study areas identified in the draft update? Of course I know that the property doesn't need to be included on the inventory list in order to process an application for housing development. We are just looking at all avenues to promote the possibility for future development on the underutilized portions of this property.

Let me know your thoughts on how best to proceed with this request.

I also left you a voice mail yesterday. I am happy to chat via phone this week if you have time to connect.

Many thanks, Charity

‐‐
Charity Wagner

‐‐
Charity Wagner

* PRIVILEGE AND CONFIDENTIALITY NOTICE: This message, together with any attachments, is intended only for the use of the individual or entity to which it is addressed. It may contain information that is confidential and prohibited from disclosure. If you are not the intended recipient, you are hereby notified that any dissemination or copying of this message or any attachment is strictly prohibited. If you have received this message in error, please notify the original sender immediately by telephone or by return e‐mail and delete this message along with any attachments from your computer. Thank you.
‐‐

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4 Charity Wagner

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1 From: Housing
Sent: Monday, May 23, 2022 1:48 PM
To:

Subject: FW: water, WATER,WATER, where is it coming from for all the new toilets???????

From: Susan Pizzi
Sent: Sunday, May 22, 2022 10:00 AM
To: Housing <[email protected]>
Subject: water, WATER,WATER, where is it coming from for all the new toilets???????

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From: Katrina Salas-Padilla < >
Sent: Sunday, May 22, 2022 9:56 PM
To: Clerk <[email protected]>
Subject: Draft 2023-2031 Housing Element Public Hearing

Dear Mayor Bonilla and Members of the City Council:

Below, in the forwarded message, is a letter that I sent to the Planning Commission on Wednesday May 11, after the study session the prior night, regarding the new building proposal for PA-2021-082 31- 57 S. B St Pre-App that has since been approved. I also attached it as a PDF for reference and for filing, as needed.

Though it is specifically addressing concerns about the proposed project on the corner of B St. and 1st St., I believe it touches on broader issues about housing scarcity, segregation - further marginalizing the low-income, hispanic communities in certain areas of San Mateo.

Since I sent this letter to the planning commission, I have been in correspondence with commissioner Adam Nugent. He provided me with the current draft of the Housing Element, as well as his notes pertaining to the prior draft as well as this draft. I have reviewed each of those three documents extensively, as well as appendix D of the Housing Element. I am writing to say that I fully support his concerns, particularly those around affordable housing in the North Central neighborhood of San Mateo, and the lack of explicit planning on how to address this issue, along with other issues of segregation in San Mateo. I believe that, as it stands, the Housing Element fails to address

In addition to supporting Adam's points, which he details in his notes on the current draft of the Housing Element that will be discussed tomorrow, Monday, May 23, I have some adjacent concerns detailed below:
• In the current draft of the Housing Element, I don’t see actionable evidence of real programs and policies intended to address issues of inequality, scarcity, and vulnerability among the low income population in San Mateo
• I am also struck by the fact that the North Central region was not identified as a location in need of more affordable housing, yet it cited multiple times throughout the Housing Element and subsequent appendices, that the region was “overcrowded”, thus I can only assume the assessment is made on a technicality that bases on raw volume of housing currently at or under market rate rather than the very observable fact that it still isn’t enough?
• I also don’t see acknowledgement around what COVID did to the rental and real estate market, which is an extremely temporary phenomena that will inevitably rebound and thus should be further factored into the immediate analysis regarding market value.

Failure to fully address and serve the low-income community that is directly impacted by the development projects in downtown San Mateo as they threaten their community cohesion and livelihood may be in direct violation of the CA Fair Employment and Housing Act, as well as other recently revised and enacted CA laws on housing, particularly SB 330 and SB 8.

My primary draw towards issues of housing, aside from the homelessness and displacement issues that we and neighboring communities continue to witness and feel impacted by, is due to the ongoing development in the downtown region of San Mateo as it is also part of the North Central neighborhood. Rezoning to risk further impacting the neighborhood and negatively impacting housing options and costs for low-income community members is a real threat to the general wellbeing and safety of our whole city. Oakland saw a similar rise in re-development in the early 2010's just after the recession, as did part of San Francisco, and both cities are still struggling with increased crime, violence, homelessness, and civil unrest.

I appreciate your taking my concerns to heart when reviewing the Housing Element and subsequent city planning and development projects, particularly as they apply to the vibrant low-income and predominantly hispanic and latino communities in the North Central and North Shoreline neighborhoods of San Mateo. We should be contributing to a better, healthier community with real, sustainable longevity and opportunity for all of its members, and setting an

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example for the greater Bay Area and state of California at large. We should not continue to contribute to the issues of displacement, segregation, inequality, and housing crisis by overlooking the obvious threat of improperly calculated developments and failing to follow through with creating programs and resources for those struggling to get by.

Respectfully,
Katrina Monet Salas-Padilla

---------- Forwarded message ---------
From: Katrina Salas-Padilla < >
Date: Wed, May 11, 2022 at 9:46 PM
Subject: Concerns regarding the project proposed for the block on B Street and 1st To: <[email protected]>

To Whom it May Concern:

My name is Katrina Salas-Padilla, soon to be Katrina Butler. I spoke yesterday during the planning meeting about concerns that I have to do with the proposed rezoning and building project on B St. in San Mateo, on the corner of what is currently Donut Delite. I believe Harvest Properties is developing the proposed plans for the project.

My concerns were specifically about the plan for integrating the nearby latino and hispanic community members who regularly patron the vibrant B St corridor between Tilton and First St, and what efforts are in place to bolster the continued housing crisis in CA and, specifically, the SF Bay Area, particularly for the lower income community immediately surrounding the location of the proposed project.

My fiance and I moved to San Mateo last spring, so unfortunately I was not present at the time of the decision to remove the grocery store in that same vicinity to replace it with a luxury apartment complex, or I would have vocalized these same concerns.

I am a local to the greater Bay Area; I grew up in Benicia just over the bridge from Martinez and Concord. I did my undergraduate degree and worked for many years thereafter at Stanford University. I lived in San Francisco for nearly a decade prior to moving to San Mateo last year. I have seen what projects like the one that Harvest Properties is proposing can do to a community. More than that, I have devoted years of academic study to understanding precisely how displacement, specifically displacement due to industrial pursuits that subsequently brew gentrifying practices, can do to a marginalized group. In short, mental health issues rise, as do suicide rates. If you didn’t already know, while the pandemic lowered the overall suicide rate by 3%, it increased the rate by a combined total of 8% among latino, black, and native american young men.

Furthermore, crime will rise. In case you aren’t already aware, San Mateo crime rates are presently among the safest in the entire SF Bay Area. San Mateo is currently much safer than Burlingame - the city that Harvest Properties aspires to turn San Mateo into per his presentation last night - and it is even safer than the very safe town of Benicia where I grew up.

This is due to the fact that San Mateo possesses one of the most inspiring elements of any other city I’ve found in the SF Bay Area; an extremely diverse mix of races, ethnicities, and economic classes. The wealth gap here is very comfortably mended by a strong middle and upper middle class, and the surrounding cities are able to pick up the slack enough to prevent extreme inequality from doing what it does best; push people who do not deserve to suffer - to their very edge.

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The economic views that the Harvest Properties representative proposed in last night's meeting were, at best, very flawed. Sure, regions that have a history of being red-lined might make prime real estate for developers who allow the few who own properties in such regions to profit on their coat tails, but how many of the working class families in the north central San Mateo area that pushes out toward the bay actually own their homes? I’d like to remind you that the state of California has recently put several measures in place to strengthen tenants rights for renters. They are also making it much harder to out zone multi family complexes precisely for reasons of scarcity around affordable housing. I am not a legal professional, but I am a policy professional within the National Laboratory system, funded by the U.S. Department of Energy, and I believe that Harvest Properties’ pursuit of turning the corner of B St. and 1st in downtown San Mateo solely into a mid-rise commercial and office building could be illegal according to current state regulations, and it is certainly unethical.

I haven’t even mentioned the fact that one of the only homeless resource centers is literally on the very next block of this proposed project’s location. I intend to forward these concerns to San Francisco officials who might have a vested interest in the matter, given the fact that many of the neighboring homeless end up on their streets at a high cost to their residents.

Though I am a child of Mexican immigrants, and Spanish and English were both my first languages, I am also an entrepreneur, business wise, such that I have taught classes for Stanford in such subjects for years as a Subject Matter Expert. Given that study, I am also qualified to say that my background and history in this region make me a “super user”, “pro-sumer”, or particularly shaped for understanding what it would take to make this specific region of San Mateo vibrant and attractive to the broader Bay Area community without as much of a social and economic cost downstream. The key word is integration. People like me, like my peers - young to middle aged working professionals who are middle, upper middle class, and upper class, who are educated and active members of our communities - do not want to see MORE gentrification and MORE industrial complexes. What we would like to see is subtle preservation of the community gems like this particular corridor of B St. This doesn’t mean STOP ALL development projects, because I’m aware that at least two of the buildings on the proposed project’s block have been vacant for a long time. This means that building with affordable housing, homage to the historically diverse and primarily latino local groups, and other sustainable and environmentally focused elements, is crucial.

We do not have enough service workers and working class employees to fill our employment needs around the country and that is very true in San Mateo and the SF Bay Area. The moves that Harvest Properties is proposing is only going to make it harder for those people to live and work in our community. There will not be a supply to meet the demand that the development project envisions by opening the door for more working professionals. And where are those working professionals coming from? They don’t seem to be repopulating in droves given the new hybrid lifestyle many major companies have promised.

What you can expect to see should you accept Harvest Properties application without consideration for the needs of those currently inhabiting the immediate vicinity of the project location: Aside from rising mental health concerns, homlessness issues, and increased crime, you’ll experience even more homeowners fleeing to more affordable parts of the U.S., housing prices will not rise at the rate that they are in other Bay Area cities as has been the case in San Mateo for months. Furthermore, you might even be in over your head with tenant issues which will ultimately come down to planning oversights that should have attempted to promote projects that address the housing and other economic issues we continue to face as a country and as a state, rather than contribute to them.

I appreciate that two out of three of the commissioners who responded last night felt similarly to my above points, but to the one who did not; I encourage you to spend 15 minutes on this specific street corner at 9:45pm on ANY day of the week. It’s rather quiet, despite the train, and most of the dinner rush is gone by then. This includes most of the bar scene. Regardless, I lived in the heart of the Mission District as well as North Beach in San Francisco for a long time, and the bustle of a night scene is, for some people, very attractive. This might be especially true for the kind of people you want to work and live in a place like downtown San Mateo; young students, recent grads, working class people with strong work ethics. People who have a very long life and relationship to cultivate with this city - not just those who want to clog the streets on weekends for brunch and then leave like with Burlingame.

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I will be sharing these concerns with other officials and interest groups who may also have a concern in the matter, and I will make an effort to continue to show up at planning meetings where this particular project is being discussed.

Respectfully,
Katrina Monet Salas-Padilla

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San Mateo City Council
Who:

Shawn Leong representing the family that has operated Ah Sam Florist and Greenhouses since 1933 and owns the property at 2621 Palm Place and 2645 S El Camino Real San Mateo Observation:

I have been following planning and development of the areas around our business for 40+ years. The past choices our community has made for development in the past have led to some of the shortcomings now and into the future. We have eleven more years until Ah Sam’s centennial anniversary. Celebrating 100 years in business in San Mateo. The business, the family, the employees and retired employees and clients are woven into this community.

However, the lack of affordable housing, parking and synergies in our neighborhoods are impacting the quality of life and our ability to enjoy running our flower business. Many of my fellow business owners will repeat the same issues of lack of workers, affordable housing and parking. We continue to see the shrinking presence of the small business that make a community vibrant and captivating.

The short term decisions and loop hole weaving of developers have created a process for everyone looking out for their own needs at the present time. How many developers remain in San Mateo after they have concluded their business. There needs to be a commitment to the community and the future, not just the next 10 or 20 years, but long term, the next 50 to 100 years.

Open for discussion.

The development of 2624 Palm Place into affordable housing and below-market housing with the consideration of generational integration and plenty of parking on the site. We can’t just check the boxes to meet the current planning guidelines but need to develop the nucleus of a plan that will give long term purpose to the proposed property. This property and the adjective lots have been excluded from the high density zone even though the properties are closer to the Hillsdale train station than Hillsdale Mall itself. Palm Place would make the ideal commercial alley from 25th ave to the Hillsdale train station in the next 100 years. We are open to discuss how we can achieve this and meet the needs of the family, staff and community.

Summary,
We are part of this community now and will be into the future. By providing for our business, housing for our staff, retired staff and future staff we can continue to provide a service for all the residences. Plus as a member of our community we would like to help individuals be able to live in San Mateo and work in the different businesses that support our San Mateo community.

Ah Sam and our family and staff have a plan to continue in this community. We have grown and want to make plans to continue to thrive and that will not be possible unless we are able to do something about affordable housing and parking. No we are not selling our property and No we are not going out of business. We have fought this battle since 1985 when the business transferred from the 2nd generation to the current generation. We invite each member of the Council, Mayor and planning staff to visit with us to discuss this more.

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1 Nicholas "Nicky" Vu
From: Housing
Sent: Wednesday, May 25, 2022 11:31 AM
To: Eloiza Murillo-Garcia; Nicholas "Nicky" Vu; Linda Ly Subject: FW: Online Form Submittal: Draft 2023-2031 Housing Element Comment Form

Sandra Belluomini
Administrative Tech| Housing
330 W. 20th Ave., San Mateo, CA 94403

From: norepl
[email protected] <[email protected]>
Sent: Wednesday, May 25, 2022 7:29 AM
To: Housing <[email protected]>
Subject: Online Form Submittal: Draft 2023‐2031 Housing Element Comment Form

Draft 2023-2031 Housing Element Comment Form

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

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

First Name  Dennis
Last Name  Keane
Email Address
Comment on 2023‐2031
Draft Housing Element
This sure doesn't sound like fixing affordable housing.

" Around 2,000 would be very low income, 1,500 low, 1,600 moderate and 5,700 above average."

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2 I have to assume most of our council is hypnotized by developers. As Joe Biden just said, "Where is our backbone." Very sad.

Email not displaying correctly? View it in your browser.

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1 Nicholas "Nicky" Vu
From: Housing
Sent: Monday, June 13, 2022 11:18 AM
To: Eloiza Murillo-Garcia; Nicholas "Nicky" Vu
Subject: FW: Housing Element Update

From: Blake Wellen
Sent: Monday, June 13, 2022 9:01 AM
To: Housing <[email protected]>
Subject: Housing Element Update

Greetings, San Mateo Housing Element Update.

Can you please provide the most up-to-date list and map of the opportunity sites? Can you please tell me what the proposed densities and heights are as it relates to multifamily development? I assume those densities/heights

cannot supersede Measure Y constraints, or can they? Please advise.

Kindly,

Blake Wellen
Bella Vista Land Advisors
Real Estate Brokerage & Development

www.bvla.net

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1 Nicholas "Nicky" Vu
From: [email protected]
Sent: Sunday, June 26, 2022 4:14 PM
To: Housing
Subject: Online Form Submittal: Draft 2023-2031 Housing Element Comment Form Draft 2023-2031 Housing Element Comment Form

Draft Housing Element Feedback Form

Please share your comments regarding the Draft Housing Element.

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

First Name  Neel
Last Name  Desai
Email Address
Comment on 2023‐2031
Draft Housing Element
Critical of housing proposals located always near downtown.

Abreast
logistics neighborhoods could benefit, higher density buildings especially west. San Mateo regarding units why, emphasize lesser "Studios and 1br." pushing out. Families communities need to be mix usage families,seniors and veterans. How many hotels were purchase for temporary housing eventually. Sold due mandated SB-09 were construction of BMR is in
development. Si
gn me up for newsletter. Thanks

Email not displaying correctly? View it in your browser.

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1 Nicholas "Nicky" Vu
From: [email protected]
Sent: Sunday, June 26, 2022 4:33 PM
To: Housing
Subject: Online Form Submittal: Draft 2023-2031 Housing Element Comment Form Draft 2023-2031 Housing Element Comment Form

Draft Housing Element Feedback Form

Please share your comments regarding the Draft Housing Element.

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

First Name  chrisann
Last Name  nino
Email Address
Comment on 2023‐2031
Draft Housing Element
Hi' whom eligible city residence or everyone or those. Working in the city critical only dismal amount families, how making higher 3br. For
families restricting needs of families (majority of units) always single or studies. Make housing fair I work have a family increase the density.

Thanks

Email not displaying correctly? View it in your browser.

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1 Nicholas "Nicky" Vu
From: [email protected]
Sent: Sunday, June 26, 2022 4:29 PM
To: Housing
Subject: Online Form Submittal: Draft 2023-2031 Housing Element Comment Form Draft 2023-2031 Housing Element Comment Form

Draft Housing Element Feedback Form

Please share your comments regarding the Draft Housing Element.

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

First Name  Erik
Last Name  Pierre
Email Address
Comment on 2023‐2031
Draft Housing Element
Simply ratio of new developments construction of larger is efficient.

Fully aware lots are old must purchase logic excellent. Needs for BMR
housing small density is obsolete recommend planning,
increase the density. Taller possibly 12-15 fls we need the units. Thanks

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July 1,
2022

City of San Mateo
330 W. 20
th Ave.

San Mateo, CA 94403
Transmitted Electronically

Dear Sir/Madam

RE: 6
th Cycle Housing Element:  Constraints Section

The Building Industry Association of the Bay Area (BIA) respectfully submits the comments contained herein regarding San Mateo’s draft Housing Element.  Inclusive in each city’s DRAFT Housing element is a requirement to include a chapter that provides a comprehensive listing and honest review of government and private sector constraints that may inhibit a city’s ability to achieve buildout of its Housing Element.

Per HCD’s Construction by Income Building Activity Annual Report, Santa Clara permitted 316 residential units in 2021 (VLI: 0, LI: 38, Mod: 39, Mkt: 239).  ABAG’s 6
th cycle RHNA allocation (2023‐2031) for San Mateo is 7,015 total units i.e., VLI: 1,777, LI: 1,023, Mod: 1,175 and Mkt: 3,040. Considering the ongoing housing crisis, it is recommended that San Mateo thoroughly analyze all government‐imposed constraints along with non‐ government constraints that add to the cost and/or inhibit the city’s ability to permit and produce new housing of all income levels i.e., VLI, LI, Moderate and Market Rate.

BIA recommends the Constraints Section of the city’s Housing Element provide, at a minimum, a listing and analysis of the following:

GOVERNMENT IMPOSED CONSTRAINTS:

Development Regulations:
 Parking
 FAR
 Height and/or Density Ranges
 Moratoriums on conversion of non‐residential zoned land  Requiring Commercial Square Footage within Mixed‐Use projects

Mitigation Fees
 Increased Park Dedication Fees
 Increase Affordable Housing Fees
Inclusionary Housing (IZ)
 Increasing Inclusionary Housing mandates i.e., accelerating/increasing VLI/LI requirements for new housing projects
 Amenity/Community Benefit Plans (Public Art, PoPo’s i.e., Privately Owned/Public Open Spaces, Childcare centers)

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 Requiring “above & beyond” dedication requirements for Parks, Roads/Transportation, etc.

Environmental Constraints
 Fault Zones
 Historic Buildings/Neighborhoods
New Taxes
 CFD’s for Schools, Infrastructure or Services
 New/Increased/Extended Parcel Taxes
 Any/All New Taxes on Housing
 Revenue “Neutral” conditions (requiring new housing pay 100% for city services) Mandated Labor Requirements
 Project Labor Agreements
 Prevailing Wage Requirements
 “Local” Construction Workforce Requirements
 Union Apprenticeship Requirements
 “Local” Business Sourcing Requirement
Citizen Concerns:
 Nimbyism/Neighborhood Opposition
 CEQA Lawsuits solely to stop/delay housing projects

Permit Processing Time
Long permitting processing times or permit processes that have a high degree of uncertainty i.e., discretionary reviews or processes with multiple public meetings, increase the cost of housing development for developers by (1) increasing carrying costs waiting for permits or (2) increasing the chance that a project will be rejected following a lengthy processing period.

NON‐GOVERNMENT CONSTRAINTS
Land & Housing Development/Construction Costs
 Land (average cost per multi‐family unit approaches $100,000 throughout Bay Area)  Hard Costs (materials & labor)
 Soft Costs (architects, consultants, govt fees, financing)  Supply‐chain and inflationary costs of materials

BIA appreciates this opportunity to provide comment and recommendation on the City’s 6th Cycle Housing Element and looks forward to working with the City of San Mateo to positively address the region’s on‐going housing crisis.

Respectfully,

Patricia E. Sausedo, Director
BIA Bay Area South Bay Government Affairs

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1 Nicholas "Nicky" Vu
From: Housing
Sent: Thursday, July 7, 2022 3:31 PM
To: Nicholas "Nicky" Vu; Eloiza Murillo-Garcia
Subject: FW: San Mateo 6th Cycle Housing Element Constraints Section Attachments: 7.1.22_BIAltr_San Mateo_Constraints.docx

From:

Sent: Thursday, July 7, 2022 2:01 PM
To: Housing <[email protected]>
Subject: San Mateo 6th Cycle Housing Element Constraints Section

Dear Sir/Madam,
Please accept the attached comment letter on behalf of BIA Bay Area for the San Mateo 6 th Cycle Housing Element.

Thank you,

Patricia Sausedo, Director
Government Affairs South Bay
BIA | Bay Area

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1 Nicholas "Nicky" Vu
From: Housing
Sent: Monday, August 22, 2022 11:45 AM
To: Nicholas "Nicky" Vu; Eloiza Murillo-Garcia
Subject: FW: Housing Element - Measure Y and Hillsdale Station Area

From: Yosef Tahbazof
Sent: Friday, August 19, 2022 3:32 PM
To: Housing <[email protected]>
Subject: Housing Element ‐ Measure Y and Hillsdale Station Area

Good afternoon – wondering how measure Y restricts the city’s ability to increase height and density along El Camino within the Hillsdale Station Area.

Does any increase over existing zoning require voter approval even if it’s necessary to comply with RHNA?

--
Regards,

Yosef Tahbazof, Esq.

Tahbazof Law Firm, LLP

This message and its contents are confidential. If you received this message in error, do not use or rely upon it. Instead, please inform the sender and then delete it. Thank you.

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1 Nicholas "Nicky" Vu
From: Housing
Sent: Thursday, September 22, 2022 10:57 AM
To: Nicholas "Nicky" Vu; Eloiza Murillo-Garcia
Subject: FW: San Mateo Housing Element Comments
Attachments: San Mateo HE Comments_TransForm.pdf

Sandra Belluomini
Administrative Tech| Housing
330 W. 20th Ave., San Mateo, CA 94403

From: Kendra
Ma
Sent: Thursday, September 22, 2022 10:55 AM
To: Housing <[email protected]>; City Council (San Mateo) <[email protected]> Cc: [email protected]
Subject: San Mateo Housing Element Comments

Hi San Mateo Planning Team and City Councilmembers,

My name is Kendra and I am the Policy Analyst at TransForm. We are a nonprofit policy advocacy organization focusing on better land use and transportation policy at the local, regional, and state level. Thank you for releasing a draft of the City's Housing Element for review and public comment. I am aware that we're sending this past the 30-day comment deadline, but if you get the chance, our team has put together some feedback that we would like to see addressed in the Housing Element.

We applaud the City for releasing their draft Housing Element for feedback so early! We'd love to see if the Element can include clearer goals and language around parking policies and TDM strategies. Please see the attachment in this email to see our comments and recommendations.

Feel free to reach out if you have any questions - we know this is a busy time of year and we thank you so much for your hard work around this!

Thanks,
Kendra

‐‐
Kendra Ma, Policy Analyst
(she/her/hers)

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2 TransForm

Sign up for our emails at www.TransFormCA.org. Follow us on Twitter, Instagram, Facebook, and Linkedin, too.

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September 22, 2022
Planning Manager and City Council
City of San Mateo
330 West 20th Avenue
San Mateo, CA 94403
Re: Draft Housing Element Needs Ambitious Parking Updates Dear San Mateo Planning Department and San Mateo City Council, TransForm is a regional non-profit focused on creating connected and healthy communities that can meet climate goals, reduce traffic, and include housing affordable to everyone. We applaud San Mateo’s work to date on the Draft Housing Element. However, to meet housing, transportation, and climate goals, San Mateo needs to expand on its successful programs and initiate some new ones.

In particular, there will need to be an effective mix of:
● Reducing parking provision and providing incentives and programs to drive less (Transportation Demand Management or TDM)
● Developing sufficient programs to meet affordable home targets of RHNA We were disappointed to see only passing reference to parking as a constraint to development, in San Mateo’s draft Housing Element. The city code currently requires at least 1.5 parking spaces per unit for multi-family developments, and at most 2.2 spaces for 3+ bedrooms. Parking provision is reduced within the Hillsdale Station Area and the Central Parking Improvement District, but not by any substantial margin. Given that each new parking space costs $30,000-$80,0001, and with inflation driving up construction costs by these estimates, two spaces may now cost up to $200,000. This raises the cost of housing development and makes it hard to meet production goals.

TransForm recommends that San Mateo consider the following policies in the Housing Element:

1. Funding a dedicated study of parking reforms, particularly how smart parking policies could positively impact housing, transportation and other goals. 1 https://www.shoupdogg.com/wp-content/uploads/sites/10/2016/05/Cutting-the-Cost-of-Parking-Requireme nts.pdf
| WWW.TRANSFORMCA.ORG
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2. Requiring unbundled parking for certain transit oriented developments.This is easier for building managers to implement now with new parking tech tools like Parkade.

3. Implementing TDMs such as requiring developers to buy annual bus passes for residents at a discounted bulk rate.

To show the tremendous transportation and climate benefits of these policies, as well as some of the financial savings for residents and reduced costs for development, we have used our GreenTRIP Connect tool to create scenarios for a potential future development site at480 N Bayshore Blvd. This site is identified in San Mateo’s draft Housing Element Site Inventory as a potential future opportunity site outside of any specific zoning district. The California Office of Planning and Research recommends GreenTRIP Connect as a tool to use while developing General Plans and is especially useful during the development of Housing Elements (the tool is free to use and supports better planning at the site and city-wide level).

By implementing the strategies above at 480 N Bayshore Blvd, GreenTRIP Connect predicts:

1. Implementing unbundling and providing transit passes at this site would decrease demand for parking by 26% and result in resident transportation savings of $792 per year.

2. With right-sized parking, incorporating the benefits of unbundled parking and free transit passes, the development would cost $6,350,500 less to build relative to current parking standards.

3. When combined with 100% affordable housing these strategies resulted in an incredible 58% reduction in driving and greenhouse gas emissions for the site, compared to the city average.

4. If an affordable development with smart parking strategies were built on this site each household would drive 6,654 less miles per year creating a greener and safer community.

By eliminating the high costs of parking, homes can be offered at more affordable prices, reducing the number of community members that face extreme housing cost burdens, getting priced out of their community, and/or becoming unsheltered. Residents, new and old alike, will greatly benefit from the reduction in vehicle traffic and associated air pollution (see the scenarios here).

In addition to parking and transportation strategies, we applaud some of the proposed strategies to support more affordable homes, since these would have such tremendous benefits as noted in the GreenTRIP scenario. Two of the most important are Policy 1.3 and 1.6 that streamline affordable development to help reach RHNA goals, by increasing density for BMR developments and streamlining affordable housing review, respectively. These programs are a cost-effective complement to strategies focused on housing production.

The GreenTRIP scenarios and the chart on the final page of our Scenario document also show the imperative of programs to accelerate development of affordable homes, like Policies 1.3 and

1.6. Not only do these households use transit more and drive much less than average, but | WWW.TRANSFORMCA.ORG
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success in this area can help provide homes for unsheltered individuals and families. A commitment to these programs will show that San Mateo is committed to planning for all levels of the 3,975 RHNA BMR units anticipated in this cycle.

Please let me know if you have any questions. TransForm hopes this information explains why San Mateo should make parking reform a priority in the Housing Element update.

Sincerely,
Kendra Ma
Housing Policy Analyst
| WWW.TRANSFORMCA.ORG
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1 Nicholas "Nicky" Vu
From: Housing
Sent: Friday, November 4, 2022 3:14 PM
To: Nicholas "Nicky" Vu; Eloiza Murillo-Garcia
Subject: FW: Online Form Submittal: Draft 2023-2031 Housing Element Comment Form

From: [email protected] <[email protected]>
Sent: Friday, November 4, 2022 10:09 AM
To: Housing <[email protected]>
Subject: Online Form Submittal: Draft 2023‐2031 Housing Element Comment Form

Draft 2023-2031 Housing Element Comment Form

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

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

First Name  Tom
Last Name  Lease
Email Address
Comment on 2023‐2031
Draft Housing Element
There needs to be much more affordable housing and work force housing.

Building a ton of luxury condos is not going to make them affordable.

Also adequate parking needs to be included with every
development.

Email not displaying correctly? View it in your browser.

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[1 of 1]

VIA EMAIL

October 24, 2022

Zachary Dahl
Deputy Director
City of San Mateo
Community Development Department
330 West 20th Avenue
San Mateo, CA 94403

RE: 2745 S. El Camino, San Mateo (APN 039-351-070) - Development Capacity

Dear Mr. Dahl:

As discussed, ownership is interested in redeveloping 2745 S. El Camino Real. This corner lot is ~36,000 sq.ft., located along the 28th street themed intersection, directly across from the newly improved Caltrain station and one block from the Hillsdale Shopping Center. Assuming an 85’ height limit, a midrise project could comfortably include 165 apartments with 72 x 1-bedrooms (679 average sq.ft.) and 93 x 2-bedrooms (1,071 average sq.ft.). We’d like the draft housing element’s sites inventory to reflect this amount. Please let me know if you have any questions or would like to discuss this further at your convenience. Thank you.

Sincerely,

Yosef Tahbazof, Esq.

Principal

CC:

Eloiza Murillo-Garcia
Christina Horrisberger
DocuSign Envelope ID: 3E81256F-F6B0-422A-9407-B4E88359478E

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1 Nicholas "Nicky" Vu
From: Housing
Sent: Tuesday, December 6, 2022 4:24 PM
To: Nicholas "Nicky" Vu; Eloiza Murillo-Garcia
Subject: FW: Housing Element

Sandra Belluomini
Administrative Tech| Housing
330 W. 20th Ave., San Mateo, CA 94403
650‐522‐7239| [email protected]

From: Blake Wellen
Sent: Tuesday, December 6, 2022 11:30 AM
To: Housing <[email protected]>
Subject: Housing Element

Hello, San Mateo Planning.

When do you expect to send HCD an updated draft of the Housing Element Update? When will the updated draft be available to view?

Kindly

Blake Wellen
Bella Vista Land Advisors
Real Estate Brokerage/Investment
DRE #02130931

www.bvla.net

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1 Nicholas "Nicky" Vu
From: Housing
Sent: Wednesday, December 14, 2022 12:39 PM
To: Nicholas "Nicky" Vu
Subject: FW: Housing Element Data Request

Sandra Belluomini
Administrative Tech| Housing
330 W. 20th Ave., San Mateo, CA 94403
650‐522‐7239| [email protected]

From: Makena Wong
Sent: Wednesday, December 14, 2022 9:56 AM
To: Zachary Dahl
Cc: Housing <[email protected]>
Subject: Housing Element Data Request

Hi Zach,

OneShoreline is hosting a PhD fellow from Stanford that is currently working on a countywide analysis of proposed opportunity sites in draft City/County Housing Elements and how they may be impacted by flooding/sea level rise.

Would you be able to share the data outlined below from the City’s Housing Element Update draft to help inform this analysis by Friday, January 6
th? These include data tables and accompanying GIS shapefiles for proposed projects, pipeline projects and housing opportunity sites selected for meeting RHNA requirements.

San Mateo  Appendix C Housing Resources: Figure 2 and Table A– Housing Sites Inventory

Sorry to add this request to your list amongst the many priorities you are balancing right now, let me know if there is a more appropriate contact that you could refer me to. I also cc’d the email address listed on the City’s Housing Element Update website in case anyone monitoring that email inbox is the more appropriate City contact to work with.

Thanks very much!

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2 Makena

Makena Wong
Project Manager | San Mateo County Flood and Sea Level Rise Resiliency District (OneShoreline) OneShoreline.org
Pronouns: she/her

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City of San Mateo
330 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 engage the City of San Mateo on its housing element. Earlier this year, we sent the city two letters outlining opportunities to approve the initial draft of its housing element, one focused primarily on needs and constraints, the other focused on affirmatively furthering fair housing, the sites inventory, and the goals, policies, and programs.

Now that the city has received its review letter from the department of Housing and Community Development, San Mateo has a new opportunity to address the housing needs of its entire community. However, we are concerned that arecent staff report and matrix of responses to HCD’s comments does not adequately reflect the city council’s strong commitment to meeting the housing needs of all. One line in particular raises concerns that San Mateo is considering legally dubious options. From the staff report:

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.

A local jurisdiction may attempt to adopt its own findings before receiving HCD certification, but doing so significantly increases the risk of lawsuits. Manhattan Beach attempted to adopt their housing element before receiving HCD certification; the city has now been sued twice by the nonprofit Californians for Homeownership (associated with the CA Realtors Association). If San Mateo were to attempt to adopt its current draft housing element without first implementing significant 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 Mateo must revise large portions of its housing element as follows:

1. Adjust realistic capacity for sites within the inventory based on site-specific information, and remove unrealistic sites: Currently, San Mateo’s site inventory assumes all parcels will be built out to 100% of zoned capacity. On some sites, such as Hillsdale 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’s current draft housing element assumes that 100% of the Hillsdale site will become new homes at 100% of zoned capacity, a clear violation of the law.1 In another example, the Bridgepoint Shopping Center recently renewed long term leases with several tenants, making development of the site highly unlikely. Unless the city can provide compelling evidence that these sites will be developed, such as property owner interest and the provision of favorable development standards, they must be removed from the inventory.2 As referenced earlier, Manhattan Beach has been sued twice for including sites that will not become housing in the next eight years within its inventory. Other sites have similar pre-existing uses that impede housing. Upon removal of unrealistic sites from the inventory and appropriate reduction of realistic capacity for other sites, San Mateo will no longer be able to demonstrate capacity to meet its Regional Housing Needs Allocations. As a result, the city will need to upzone beyond the limits created by Measure Y.

2. Fully analyze constraints to housing: The matrix of responses to HCD’s review letter provided by staff still makes no commitment to address Measure Y within the housing element. In its review letter, HCD writes “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.” Addressing the constraint “as part of the GPU [General Plan Update] adoption process,” as staff offer in their matrix of responses, does not suffice. The housing element is a chapter of the general plan; as such, constraints to housing, including Measure Y, should be addressed within the housing element. HCD lists a number of other significant underanalyzed and unaddressed constraints, including discretionary 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 and address them. In fact, by concentrating all of its opportunity sites outside of San Mateo’s highest opportunity areas, the housing element actively promotes segregation. In order to satisfy AFFH requirements, the city needs new policies to protect lower-income renters and promote housing in its highest-opportunity areas.

4. Implement new policies and programs to increase validity of site inventory: Based on complete analyses of sites, constraints, and AFFH, San Mateo will need to implement new 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 residential development, absent findings based on substantial evidence that the use is likely to be discontinued during the planning period.”
1 HCD Site Inventory Guidebook, p. 20: “The capacity calculation must be adjusted to reflect the realistic potential for residential development capacity on the sites in the inventory. Specifically, when the site has the potential to be developed with nonresidential uses, requires redevelopment, or has an overlay zone allowing the underlying zoning to be utilized for residential units, these capacity limits must be reflected in the housing element.”

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removed to the extent possible.3 Programs must promote AFFH goals.4 HLC recommends the following programs:
○ Implement an affordable housing overlay focused on land owned by religious institutions and schools in high-opportunity single-family neighborhoods. The overlay should allow development standards at least as generous as the city’s R6-D development standards to provide maximum flexibility for these public and semi-public institutions to create new homes. Furthermore, proposals for housing on sites owned by religious institutions or schools should be exempt from design review hearings and limited to two planning commission hearings. (AFFH) ○ Implement a rental registry to track rentals and provide data to the city regarding prices and evictions. Data from a rental registry will help the city identify landlords violating the law and devise additional renter protections as needed. (AFFH) ○ Reduce fees on affordable housing, especially impact fees and open space fees.

Waive fees entirely for low- and very low-income units, defer them until reception of occupancy permit for moderate-income units. (AFFH, constraints) ○ Allow ministerial approval for all opportunity sites, eliminating design review and planning commission review. Discretionary review processes add cost and uncertainty to the development process; these processes also put a heavy burden on planning staff time, which the city is eminently short of. (constraints) ○ Reduce parking requirements by (1) requiring only 1 parking space for 1-bedroom, 2-bedroom, and 3-or-more-bedroom units (2) eliminating guest parking requirements throughout the city (3) eliminating parking requirements for units serving those with physical or mental disabilities. (constraints) ○ Upzone opportunity sites above Measure Y limits to promote viability of opportunity sites. The exact quantity of upzoning required will depend in part on the results of a complete site inventory analysis. HLC believes that, in order to demonstrate 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; and all E zoning districts to allow:

1. 85 feet height and 8 stories

2. Eliminate density cap

3. Eliminate minimum lot size

4. Increase FAR to 5
ii. 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 of new affordable housing in areas of opportunity, as well as place-based strategies to encourage community revitalization, including preservation of existing affordable housing, and protecting existing residents from displacement.
3 Gov. Code, § 65583(c)(3): “Address and, where appropriate and legally possible, remove governmental and nongovernmental constraints to the maintenance, improvement, and development of housing, including housing for all income levels.”

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2. Eliminate density cap

3. Eliminate minimum lot size, rear setbacks, and side setbacks

4. Eliminate maximum lot coverage

5. Eliminate private open space requirement

6. Increase FAR to 8
San Mateo’s city council is responsible for providing staff direction to implement these policies and programs. These are not controversial proposals; according to the city’s own Community Input Survey, when asked about their zoning preferences, “63% of San Mateo residents indicated they would support concentrating new housing in higher-density buildings downtown and near transit up to 12 stories.5 HLC’s proposals reflect the widely held preferences of the San Mateo community.

Fundamentally, cities cannot analyze their way into new homes, nor can they analyze their way into compliance with state law. The housing element process challenges cities to provide a series of analyses and then commit to substantially change local policies in ways that incentivize new housing development. HLC looks forward to continue working with San Mateo’s leaders as they strive to meet the housing needs of the entire community.

Thank you for your consideration,
Jeremy Levine
Policy Manager, Housing Leadership Council of San Mateo County 5 Community Opinion Survey: Summary Report, p. 12

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Stephen A. Finn
Principal and Founder
RE Management, LLC
160 Bovet Rd., Suite 408
San Mateo, CA 94402
San Mateo City Council
330 West 20th Avenue
San Mateo, California 94403
August 13, 2019

Re: General Plan Analysis of Borel Square / Hayward Park Station Area

Dear Mayor Papan and Honorable Members of the City Council:

As the owner of the Borel Square Shopping Center, I have been following the General Plan Update process with great interest. Borel Square, located at Bovet Road and S. El Camino Real, is an ideal site for redevelopment. The eight-acre site was built out in the 1960’s and largely reflects the design and planning preferences of a bygone era. From the street, visitors must drive through a sea of parking to access retail, restaurants and services clustered in single-story strips located a significant distance from public streets and sidewalks. In connection with the General Plan Update, I have started to evaluate long-term options for revitalizing Borel Square, retained expert consultants to assist with analyzing potential redevelopment scenarios focused on housing and other uses, and I also plan to contact nearby property owners to explore potential collaboration opportunities.

I understand that you will be deciding which areas of the City should be studied as “change areas” at the August 19th City Council meeting, and that Borel Square is included in “Study Area

3.” After reviewing the draft map with our team and looking forward to the alternatives process to come, I would like to offer the following thoughts for your consideration.

First, I am excited that the City is taking a fresh look at its existing land use goals and policies. Times have changed significantly. Over the past thirty years, the City’s population has grown, leadership at all levels of government has changed, and new best practices have emerged for development and urban planning. In order to cultivate a diverse and thriving economy and responsibly manage for the impacts of growth, we must consider how these and other important trends have impacted the way current and future generations will live, learn, work, play and thrive in San Mateo. I look forward to a more robust conversation around these topics as the City moves forward to the alternatives process.

Second, I look forward to collaborating with your team and providing input on the future land use alternatives to be evaluated for Borel Square and the Hayward Park Station area. I believe there are positive opportunities available to strengthen the connection between Hayward Park and Borel Square, improve the streetscape along Bovet Road and 17 th Avenue, and encourage greater walkability, bikeability, and use of public transit. I applaud the City’s goal of encouraging greater

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Mayor Papan and
Honorable Members
of the San Mateo City
Council
August 13, 2019

use of alternative modes of transportation and also hope that you consider updating parking requirements to reflect the desired reduction in vehicle use.

Finally, I have some concerns about the size of Study Area 3, and respectfully request that you consider evaluating smaller study areas within Study Area 3, which I believe may lead to better planning outcomes. Study Area 3 is considerably larger than the other study areas and includes two Caltrain stations. As you know, the Hayward Park Station and Hillsdale Station are very different. While the area surrounding Hillsdale includes a regional shopping center, recently renovated retail, and new residential projects (such as Bay Meadows II), the area around Hayward Park largely consists of parking lots, office, retail, and industrial uses and has experienced challenges in redevelopment due to restrictive zoning requirements.

Because these different constraints and opportunities suggest the potential for different future policy and planning frameworks, and in order to make the upcoming conversations more efficient and streamlined, I would respectfully request that the City evaluate a smaller study area that is just inclusive of the Borel Square/Hayward Park area north of State Route 92. State Route 92 provides a natural border between the distinct communities surrounding Hayward Park and Hillsdale Station. Enclosed is a map illustrating the proposed study area prepared by Taecker Planning & Design, which hopefully illustrates some of the potential opportunities for this area of San Mateo for consideration as part of the upcoming alternatives process. In addition to creating a separate study area for the properties north of State Route 92, the enclosed map proposes that Study Area 3 be extended slightly north to include large underutilized parking lots between Bovet Road and Borel Avenue that may be ripe for development.

Thank you for making the General Plan Update a priority and for thoughtfully considering the input you are receiving from the community.

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-1-

April 15, 2022

Via Electronic Mail

Christina Horrisberger, Community Development Director
Zach Dahl, Deputy Community Development Director
City of San Mateo
330 West 20th Avenue
San Mateo, CA 94403

RE: Hillsdale Shopping Center—Preferred Land Use Scenario

Dear Ms. Horrisberger and Mr. Dahl,

We are writing on behalf of the Bohannon Development Company and our joint venture partner, Northwood Investments Corporation, the owners of the Hillsdale Shopping Center (the “Owners”) located at 60 31st Avenue in San Mateo, CA (the “Site”). Thank you for the opportunity to submit our preferred land use map for the City Council’s consideration on April 18, 2022.

While the City of San Mateo (the “City”) has been studying land use alternative scenarios for the Strive San Mateo General Plan Update process, we have been carefully considering the future of the Site, keeping in mind that the current changes in the retail market present special opportunities for the evolution of the Hillsdale Shopping Center and how it responds to the shifting needs of San Mateans and the Peninsula community at large. Both the General Plan Subcommittee and the Planning Commission recommended Mixed-Use High for the Site in recognition of this special opportunity for transit-oriented development in the heart of San Mateo.

While we have not established a set vision for the Site, we now intend to embark on a robust community engagement effort to help us plan for the future. We do know through our early listening that providing a mix of uses, including residential, retail and commercial spaces, would establish the appropriate land use framework with the necessary flexibility to create a special place that will meet market needs, exceed the community’s expectations, and protect the City’s fiscal health, all while respecting and blending with the edges adjacent to the existing neighborhoods.

Therefore, as you can see on the attached “Preferred Alternative” exhibit, we are proposing the Mixed-Use High designation for the parcels closest to the Hillsdale Caltrain Station and along El Camino Real, while proposing Mixed-Use Medium for the interior of the Site, with a Transitional Buffer zone to the adjacent neighborhood. We also would like to adjust thethe boundary of the Study Area to include parcel 042-121- 090 currently a portion of the Hillsdale Garden Apartments. The exclusion of this parcel, contiguous to the Hillsdale Mall parcel (South Block),creates a mid-block transition that we think hinders the flexibility necessary to plan for the site in the future. This site is

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currently occupied with aging housing stock that will be in need of investment in the coming years. Inclusion of this land in the study area will allow greater flexibility in how we answer the community’s call for adding housing, especially affordable housing, in reimagining Hillsdale. Inclusion of this parcel, provides an opportunity to think holistically about the future of Hillsdale and avoids having awkward mid-block transitions that can be an impediment to good design and planning.

We believe that the unique size and location of the Site warrant a fresh approach by showing more intensity along El Camino Real and the Transit Corridor and stepping down the intensity toward the existing neighborhoods. This combination of Mixed-Use High and Mixed-Use Medium designations will allow for the greatest master planning flexibility that, in turn, will not over burden the City’s existing infrastructure and will protect San Mateo’s neighborhoods.

Importantly, this proposed combination provides for the flexibility necessary to achieve a viable and feasible plan for redevelopment of the Site that is deliverable to the marketplace, while also preserving its role as a place for San Mateo residents to gather, shop, and enjoy. Not only will this balance of uses allow us to create an ecosystem that minimizes impacts, but it will create a realistic opportunity to deliver both market-rate and affordable housing that will significantly contribute to the City’s housing needs.

We look forward to our ongoing collaboration with the City as it moves forward with the General Plan Update process.

Thank you for your consideration.

Sincerely,

David Bohannon

Attachment 1: Preferred Land Use Map

cc: Drew Corbett, City Manager
Rick Bonilla, Mayor
Diane Papan, Vice Mayor
Eric Rodriguez, Council Member
Joe Goethals, Council Member
Amourence Lee, Council Member
Margaret Williams, Planning Commission Chair
John Ebneter, Planning Commissioner
Adam Nugent, Planning Commissioner
Seema Patel, Planning Commissioner

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[1 of 1]

VIA EMAIL

2745 El Camino, LLC
5042 Wilshire Blvd #39799
Los Angeles, CA 90036

October 24, 2022

Zachary Dahl
Deputy Director
City of San Mateo
Community Development Department
330 West 20th Avenue
San Mateo, CA 94403

RE: 2745 S. El Camino, San Mateo (APN 039-351-070) - Development Capacity

Dear Mr. Dahl:

As discussed, ownership is interested in redeveloping 2745 S. El Camino Real. This corner lot is ~36,000 sq.ft., located along the 28th street themed intersection, directly across from the newly improved Caltrain station and one block from the Hillsdale Shopping Center. Assuming an 85’ height limit, a midrise project could comfortably include 165 apartments with 72 x 1-bedrooms (679 average sq.ft.) and 93 x 2-bedrooms (1,071 average sq.ft.). We’d like the draft housing element’s sites inventory to reflect this amount. Please let me know if you have any questions or would like to discuss this further at your convenience. Thank you.

Sincerely,

Yosef Tahbazof, Esq.

Principal

CC:

Eloiza Murillo-Garcia
Christina Horrisberger
DocuSign Envelope ID: 3E81256F-F6B0-422A-9407-B4E88359478E

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Nicholas Hamilton <[email protected]>
FW: Meeting Followup and Commentary on RWC Housing Element Nicholas Hamilton <[email protected]> Fri, Dec 23, 2022 at 3:23 PM To: Nicholas Hamilton <[email protected]>
From: Jeremy Levine
Sent: Tuesday, December 20, 2022 9:31 PM
To: Manira Sandhir ; Eloiza Murillo-Garcia ; Zachary Dahl ; Diana Elrod - D.R. Elrod and Associates/Solutions for Affordable Housing
Cc: Evelyn Stivers
Subject: Meeting Followup and Commentary on RWC Housing Element

Good evening Manira, Eloiza, Diana, and Zach--Manira and Eloiza, it was a pleasure to talk with you last week. Thank you for taking the time to help me better understand staff's perspective. We're all working to get San Mateo the best housing element possible, and I appreciate the opportunity to share HLC's perspective on what that looks like.

As we discussed at the end of our conversation, I want to help you understand why HLC endorsed Redwood City's housing element. By sharing info about RWC's housing element, I hope your team will get a clearer picture of what HLC hopes to see in San Mateo's housing element.

For starters, RWC is upzoning its downtown by an additional 20 du/ac. The area to be upzoned is quite a tiny portion of town, much smaller than HLC's original recommendations, but it is an area in which RWC--a city which has an approximately 75% greater per capita rate of housing development than San Mateo--has demonstrated significant capacity for new homes in the past. Despite its great recent track record, RWC is rezoning even further.

RWC also rezoned single-family neighborhoods along a number of dimensions to allow smaller units on smaller lots. And they cut parking requirements in half throughout the city. (Not just in the 1/2 mile around transit required by state law, but EVERYWHERE.)

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It also really helps that RWC is donating city-owned land to support affordable homes. We are looking for subsidy of some form, land, money, or ideally both!

And the good policies continue. Redwood City is making big commitments to follow through on implementing its anti-displacement plan; streamline permit processing for 100% affordable housing developments; entirely eliminate a cap on new units in the downtown; and revise the city's affordable housing ordinance to remove city discretion over AH projects.

Fundamentally, RWC's housing element is nowhere near perfect from a pro-housing standpoint, but it commits to a number of significant policy changes that will have a beneficial impact when implemented. Even though Redwood City has an approximately 75% greater per capita rate of housing production than San Mateo, RWC is upzoning substantially in its downtown and pursuing a number of other ambitious production-oriented policies. In comparison, San Mateo's housing element commits to relatively few substantial policy changes beyond the base requirements of state law, yet it assumes that the rate of housing production will more than double.

As we discussed, HLC does not see theoretical upzoning in the general plan in the future equivalent to upzoning in the housing element today, as the housing element is a legally binding contract with the state and the general plan is, well, not. Considering its past track record of development and the constraints to housing present in the city, San Mateo may need to make commitments within the housing element to upzone opportunity sites in order to justify its site inventory. HLC has argued that the city in fact must rezone, but we are willing to wait and see what HCD requires.

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However, I continue to believe that San Mateo staff should be prepared to undergo a potentially long period of housing element noncompliance if HCD finds that the city's opportunity sites cannot be justified under current zoning, which would require new rezonings and a time-consuming housing element EIR. HLC would have preferred that the city study the potential environmental impacts of upzoning earlier in this process so that the council would have had the option to rezone now if necessary, but the city did not take that prudent course of action at an earlier time, and so we are faced with the present high-risk circumstances. If possible, HLC wants to help the city satisfy HCD, but we are reluctant to support a housing plan that includes so few incentives for development on the proposed opportunity sites. We look forward to seeing the city's new draft at the end of the month, hopefully with more policies that we can support wholeheartedly.

All of this aside, I recognize that staff are working hard and trying your best, and some housing activists (including myself) have not always recognized your work appropriately. After our conversation, I have been urging other activists to work toward a more constructive, supportive relationship with San Mateo staff. Regardless of differences of opinion, thank you for the opportunity to work together on creating a great housing plan that meets the needs of all San Mateo residents.

Regards,
Jeremy
--
Jeremy Levine (he • him)
Policy Manager
Housing Leadership Council of San Mateo County
2905 El Camino Real
San Mateo, CA 94403
www.hlcsmc.org
650.242.1764

Facebook • Twitter • LinkedIn • Instagram • Become A Member! * PRIVILEGE AND CONFIDENTIALITY NOTICE: This message, together with any attachments, is intended only for the use of the individual or entity to which it is addressed. It may contain information that is confidential and prohibited from disclosure. If you are not the intended recipient, you are hereby notified that any dissemination or copying of this message or any attachment is strictly prohibited. If you have received this message in error, please notify the original sender immediately by telephone or by return e-mail and delete this message along with any attachments from your computer. Thank you.

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1 Nicholas "Nicky" Vu
From: Higley, CJ (25) x4942
Sent: Friday, December 16, 2022 4:56 PM
To: Housing
Cc: Mayhew, Tom (22) x4948; Ali Sapirman;
Subject: Housing Element
Attachments: 2022-12-16 HAC Comments on San Mateo Draft Housing Element.docx; Appendix to HAC San Mateo Housing Element Comments (2022-12-16).pdf
Good afternoon – Attached are comments to San Mateo’s draft General Plan, submitted on behalf of the Housing Action Coalition.  Please let us know if you have any questions regarding our comments.  Thanks, ‐CJ Higley

CJ Higley
Partner

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THOMAS B. MAYHEW

CHARLES J. HIGLEY

December 16, 2022
Via E-Mail
Planning Manager
City of San Mateo
Planning Division
330 W. 20th Avenue
San Mateo, California 94403

E-Mail: [email protected], and

Re: Draft Housing Element for City of San Mateo 2023-2031 Comments of Housing Action Coalition

Dear Planning Manager:

On behalf of the Housing Action Coalition,1 we write to comment on the draft 2023-2031 Housing Element for the City of San Mateo. The draft Housing Element does not meet the City’s obligation to plan and provide for affordable housing. Absent substantial revisions, it may be found in violation of state law.

Below, we identify two significant issues to be addressed as San Mateo continues to work on formulating an acceptable Housing Element. First, San Mateo has included a number of sites that do not have a realistic likelihood of becoming housing during the next eight years, as required to meet the need for new housing. The inventory includes a major shopping center and a regional mall and claims that these are housing sites that will redevelop in the next eight years, despite busy stores, new long-term leases, and even multimillion dollar improvements that conclusively demonstrate that the current retail uses will continue. Second, San Mateo’s methodology for identifying how much of the regional need will be met by the sites on the inventory appears both unprincipled and inconsistently applied. In order to properly evaluate whether the site inventory will meet the needs of San Mateo’s anticipated population growth, San Mateo needs to formulate a proper methodology and then apply it consistently, and explain

1 The Housing Action Coalition is a nonprofit that advocates for building more homes at all levels of affordability to alleviate the Bay Area and California’s housing shortage, displacement, and affordability crisis.

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Housing Element
December 16, 2022

how it evaluates site-specific information, other potential uses of the property, and market evidence on what is likely to actually be built.

A. The City Includes Sites That Are Not “Suitable And Available” Because They Do Not Have A “Realistic And Demonstrated Potential” For Redevelopment During The Planning Period To Meet The Need For Housing.

One of the most concrete aspects of any housing element is the inventory of land “suitable and available” for residential development to meet the city’s regional housing need by income level. Government Code § 65583(a)(3); HCD Housing Element Site Inventory Guidebook at p. 1 (https://www.hcd.ca.gov/community-development/housing- element/docs/sites_inventory_memo_final06102020.pdf). The list is a specific means of evaluating whether the City has adequately planned for development of housing for all income levels.

Where nonvacant sites are listed on the sites inventory, there must be a “realistic and demonstrated potential for redevelopment” during the next eight years. Government Code § 65583(a)(3). To address past abuses – including where cities list unrealistic sites in order to avoid required rezoning – the California Legislature created a high standard for listing sites that are currently being used for something other than housing. Where nonvacant sites are used to address over 50% of the need for affordable housing for those with lower incomes, the City must show the realistic and demonstrated potential for redevelopment by making formal findings that the existing use does not impede residential development “based on substantial evidence that the use is likely to be discontinued” during the planning period. Government Code § 65583.2(g)(2) (final sentence). The City must analyze the evidence: existing leases, market demand for the existing uses, and anything else that would indicate whether existing uses will continue.

Government Code § 65583.2(g)(1).

As explained below, the current draft prepared by San Mateo identifies a number of non- vacant sites that are not realistic, suitable and available for redevelopment. The City relies heavily on the speculative and unlikely assumption that existing uses will cease during the next eight years in favor of affordable housing.

1. The Bridgepointe Shopping Center
(APN 035-466-010, -070, -080, -090, -100, -110)

The City’s sites inventory lists several parcels that together make up the Bridgepointe Shopping Center, a popular regional mall described by owner CBRE as “one of the premier power centers in the Bay Area.” Together, the parcels comprising Bridgepointe account for 1,188 total housing units in the site inventory. Of these, 241 units would be for Very Low income residents, and 180 would be Low income residents.

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Housing Element
December 16, 2022

The bulk of the units the City identifies for the Bridgepointe property would be contained on parcel 035-466-100, which the City describes in Appendix C, Table A as a “large parking lot, larger than .5 acre, potential for structured parking.” As an initial matter, HCD’s guidance for conducting the sites analyses provides that “[a] parcel smaller than one half acre or over 10 acres is considered inadequate to accommodate housing affordable to lower income households, unless the housing element demonstrates development of housing affordable to lower income households on these sites is realistic or feasible.” At 12 acres, this parcel is presumed to be inadequate without more specific information demonstrating feasibility. Aside from a vague mention on page H-34 of “a variety of discussions” with the owner of the shopping center, we have not found any such information in the City’s draft Housing Element or in the public discourse that demonstrates the feasibility of re-developing the site for housing. Nor does the City show that there is a history of successful developments of this size by affordable housing developers. For this reason, parcel 035-466-100 should be excluded from the sites inventory.

A more general (and more significant) problem with the City’s identification of the Bridgepointe parcels, however, is that there is no reason to believe that any of them will be available for development within the planning period contemplated by the draft Housing Element. Bridgepointe is a bustling power center with numerous national retailers. The City has presented no information that would indicate the imminent demise of the shopping center. To the contrary, based on information available from CompStak (HAC Appendix Tab 1), a website that “gathers and quality checks lease and sales comps from the professionals making deals,” it appears that numerous leases run through and beyond the end of this decade.

Hobby Lobby, a national retailer of arts and crafts supplies, for instance, apparently has a lease at Bridgepointe that doesn’t expire until 2029. HAC Appendix Tab 2.

Similarly, national cosmetics retailer Ulta Beauty appears to hold a lease that was entered into in 2021, and doesn’t expire until 2032. HAC Appendix Tab 3. Both the recent commencement date of the lease, as well as its long-term nature suggest that neither Ulta Beauty nor Bridgepointe is going anywhere anytime soon.

The list goes on. Total Wine & More has a lease that runs until 2027. HAC Appendix Tab 4. California Fish Grill just entered into a lease that will run through 2031. HAC Appendix Tab 5. Armadillo Willy’s has a lease that will expire in 2030. HAC Appendix Tab 6. Absent some evidence that the information available on CompStak is inaccurate, there is simply nothing at all to suggest Bridgepointe will be available for redevelopment during the upcoming eight years.

One possible explanation for the City’s inclusion of the Bridgepointe parcels, despite clear evidence the existing retail uses on the site are likely to continue for the foreseeable future, is that the City’s analysis seems to rely heavily on the availability of the parking lots associated with the shopping center. Presumably the logic here is that, because they are surface parking lots that aren’t occupied by other existing structures, they could theoretically accommodate construction of housing, while the requisite parking to serve the retail uses could be

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accommodated in one or more newly constructed parking garages. While this is theoretically true and makes sense as a matter of spatial arrangement, nothing in the City’s draft demonstrates that redevelopment of this nature is likely or would be legally feasible under the retailers’ leases.

We are not aware of the details regarding tenants’ rights to occupy or control the parking areas associated with the Bridgepointe Shopping Center. We note, however, that tenants in similar “power centers” typically possess non-exclusive rights to parking in the parking lots associated with the shopping center of which they are a part. Indeed, access to and availability of immediately adjacent parking is often viewed as crucial to a retail outlet’s success. While we have no affection for this land use pattern, the City has not demonstrated that the legal rights of tenants over the Bridgepointe parking lots would permit their redevelopment and reconfiguration.

2. Hillsdale Mall
(APN 042-121-040, -060, -080; 039-490-050, -170; 039-353-010, -020, -030, - 040)

The site of the Hillsdale Shopping Center, including surrounding parking lots and buildings (listed as Consolidated Site X on the draft Housing Element), is projected to provide 912 lower income units towards the RHNA. The assumption is that 100% of the acreage will redevelop at 100% of the maximum density for the site: 50 dwelling units per acre.

Unfortunately, there is not substantial evidence that the existing use on all of these parcels will discontinue during the next eight years.

As the comment by Housing Leadership Council of San Mateo County has previously noted, the Hillsdale Mall recently rebuilt a significant portion of the retail mall at Hillsdale. The single largest parcel at the site (APN 039-490-170, comprising 39.91 acres) was significantly redeveloped for retail and entertainment uses. Known as the “Hillsdale North Block,” it was a massive project involving the demolition, redesigning, and reconstructing of existing buildings, and constructing two new ones, on 12.5 acres of the site.2 The construction loan for the project was $240 million.3

Opened in November 2019, Hillsdale North Block has new stores, restaurants, a new multiscreen movie theater, and even a new upscale bowling alley. The remodeled structure ties into existing retail structures on the same parcel, including a two-story parking garage used to provide parking for the new retail and entertainment spaces, and a food court built over 31st Avenue, extending over to the Nordstrom’s building on the other side of 31st (in the older portion of the mall, which includes Nordstrom’s and Macy’s as anchor tenants). The food

2 Details on this project are available on the City Planning Department’s website at:
https://www.cityofsanmateo.org/DocumentCenter/View/47652/Hillsdale_Shopping_Center_Nort h_Block_Initial-Study--Mitigated-Negative-Declaration?bidId 3 HAC Appendix Tab 7. This January 2022 article also quotes the new co-owner of Hillsdale Mall as stating: “We are confident that Hillsdale Shopping Center will continue its meaningful presence in the city for years to come.” See also HAC Appendix Tab 8.

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court/pedestrian bridge, remodeled as part of the Hillsdale North Block improvements, shows that the retail uses to the south of 31st Street also continue to be part of the owner’s long-range plans.

The owner of Hillsdale Mall has publicly indicated an interest in some amount of housing, alongside its existing retail and entertainment uses. The problem for purposes of Housing Element analysis is that any residential plans have not yet been defined, and would at best comprise only a portion of the site. San Mateo has no evidence of what proportion of the site will involve continuation of existing uses, but cannot reasonably conclude that all existing uses will cease during the next eight years. The existing use of APN 039-490-170 precludes counting it towards 808 units of affordable housing; the recent and substantial improvements preclude any reasonable finding that the existing use will be discontinued.

Meanwhile, the main parcel separates the other parcels from one another, rendering unclear which, if any, might realistically be developed for residential housing in the next eight years. Thriving retail, restaurant, and banking uses (Trader Joe’s, Old Navy, a Wells Fargo bank branch, several restaurants, and associated parking) are located on the parcels south of Hillsdale Boulevard, an area known as “Hillsdale South,” with leases signed, and expensive tenant improvements done, as recently as 2021.4

A proper analysis under Government Code section 65583.2(g)(1) would preclude the City from making the required finding that this site is suitable, available, and realistic for affordable housing under 65583.2(g)(2), because existing uses are not likely to discontinue during the next eight years. A site of this size is also presumed to be insufficient to meet the needs for affordable housing, absent evidence of successful affordable housing developments of this size or special reason to believe that one would be successful here. Government Code § 65583.2(c)(2)(B). San Mateo shows neither.

4 These businesses are on APNs 039-490-050, and 042-121-040, -060, and -080, an area labeled as “Hillsdale South.” They are on the south side of West Hillsdale Boulevard from the main mall site on APN 039-490-170. Building permits indicate that $1.7 million in renovations was done in the 2009-2010 time frame when Trader Joe’s and other businesses were moving in; more recently, $150,000 of work was done on the interior in 2021, when Sleep Number opened a store there. BD-2021-279007; BD-2009-233895; BD-2009-34436; SG-2021-279679. Publicly available information shows that Sleep Number has a lease running into 2028. HAC Appendix Tab 10. Other building permits show substantial renovations and construction work done for the current tenants. When DSW (a shoe store) moved in, over $600,000 of improvements were done. BD-2011-240083, BD-2011-240152. When AT&T moved in next door to DSW, at 31 West Hillsdale Boulevard, over $1.8 million of construction was done; a Macaroni & Grill restaurant on the site was demolished and the AT&T building was constructed at the same location. BD-2016-260718, BD-2016-260255, BD-2017-263360. The AT&T construction was completed relatively recently: permits were signed-off and closed in 2018. It is not “likely” that these existing uses will discontinue in the next eight years.

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3. The Atrium: 1900 South Norfolk Street
(APN 035-391-090)

The executive office building located at 1900 South Norfolk Street is currently used by a large number of office tenants. The draft Housing Element does not perform any analysis of the current use, including whether existing leases would create obstacles to residential development of the site during the next eight years. Publicly available information indicates that a number of leases continue to be signed or renewed for this three story office building, with at least one lease publicly reported to extend until 2030. HAC Appendix Tab 9. The City should perform the required analysis under Government Code section 65583.2(g)(1), and evaluate whether it has substantial evidence to make the finding that existing uses are “likely to discontinue” during the next eight years, as required by section 65583.2(g)(2). If not, it should not be claimed to meet the need for 99 lower income affordable housing units, even if the owner has expressed a long- term interest in redevelopment.

4. Borel Shopping Center (71-77 Bovet; 1750 El Camino Real) (Consolidated Site AH: APN 039-011-450, -460, -470, -480, -500, -510)

This site is a busy shopping center anchored by a CVS Pharmacy, a 24 Hour Fitness,5 a branch of Patelco Credit Union, a UPS store, and a separate restaurant building for Jack’s Restaurant and Bar. There is publicly available information showing that the lease for Jack’s extends well into the planning period. HAC Appendix Tab 11 (indicating Jack’s lease extends from 2013-2029). The City should do the required section 65583.2(g)(1) analysis of the existing leases, and current market demand for the retail uses at the location. The City currently lacks substantial evidence that the site’s existing use is “likely to be discontinued” during the next eight years. It should not count towards 85 units of housing affordable to lower income households.

5. The Elks and The Shriners – 229 W. 20th Street and 150 W. 20th Street (APN 037-052-350 and APN 039-030-220)

The Benevolent and Protective Order of Elks, Lodge 1112 (“San Mateo Elks Lodge”), has been located at 229 W. 20th Street since 1954. The San Mateo Elks Lodge has a membership of over 1,100 as of earlier this year. The Elks use their lodge to operate a popular swimming center for kids and families, hold crab feeds and other events in the meeting hall, and engage in fun activities and philanthropic works.

The only suggestion that the San Mateo Elks are not likely to continue their existing use of the Elks Lodge at 229 W. 20th Street is the statement on the site inventory that “Preliminary

5 In 2008, the 24 Hour Fitness substantially modified the building it occupies 2008 when it moved into a space formerly occupied by Albertson’s. It added locker rooms, a swimming pool, basketball courts, showers, and other tenant improvements at a cost exceeding $2.2 million. BD- 2007-230493; BD-2007-230029; BD-2008-230692.

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conversations with the owner to convert to residential have occurred.” That kind of statement might sometimes go unnoticed and unquestioned by the City Council, HCD, or a court. But here, no one should take it as an adequate answer to the question of whether the San Mateo Elks will stop using their lodge in the next eight years. The reason is that the 2015 Housing Element, when listing the same site, said the same thing, word-for-word: “Existing private member club.

Preliminary conversations with the owner to convert to residential have occurred.”6 Nothing has happened in the last eight years to suggest that “preliminary conversations” are substantial evidence on which to predict a likely discontinuation of the existing use, even if the more recent note is based on more recent preliminary conversations. This site should not be counted towards accommodating the need for 77 units of housing affordable to lower income households.

Government Code § 65583.2(g)(2).

A second private club is located just down the street at 150 W. 20th Street: the Shriners.

The Shriners are likewise a longtime institution in San Mateo, and are likewise committed to philanthropy and social activities. The Shriners’ building is used in part for a day care center.

The site inventory provides insufficient detail to evaluate whether they plan to move out in the next eight years, saying only “Owners have considered mixed use with residential.” Without more, this is insufficient to justify concluding that the Shriners actually plan to leave or redevelop in the short or mid-term, or to treat their property as accommodating the need for 32 units of lower income housing.

The same analysis applies to other sites. See, e.g., 1500 Fashion Island Blvd. (APN 035- 550-040) (“Developer interest in redevelopment.”); Consolidated Site B (APN 032-312-250, - 270, -150, -100, -070) (“General interest in redevelopment”); 480 North Bayshore Blvd. (APN 033-081-280) (nonvacant use as motel; re-used from 2015 Housing Element: “General interest to redevelop, motel conversion.”). Vague expressions of interest do not constitute substantial evidence that the existing use will likely cease during the next eight years. Section 65583.2(g)(1) and (g)(2) require more analysis, more evidence, and more likelihood.

6 In order to rely on conversations purporting to express intent, the public needs to know much more. Who had the conversation cited by the City, and with whom did they have it? Has the Lodge taken any affirmative steps toward redevelopment beyond this conversation? Without more, the vague reference to “preliminary conversations” between unidentified speakers on an unidentified date does not constitute “substantial evidence.”

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6. Mollie Stone’s – Olympic Shopping Center
(Consolidated Site AD:

APN 042-242-050, -060, -070, -160, -180;
042-243-020, 042-244-040, -050;
042-245-040, -050, -060, -070, -080, -090, -100, -110, -120, -130; 042-263-010, 042-264-010)

This site, consisting of twenty parcels, is claimed to accommodate 161 units of housing affordable to those with lower incomes. The only basis for including it appears to be the claim that there is “ownership interest in specific plan redevelopment,” which does not indicate that all of the parcels would be redeveloped as housing at the maximum density, or indicate who said what to whom, and when.7

Meanwhile, and as discussed further in section B below, the draft Housing Element does not adequately analyze or demonstrate the realistic capacity of the site. Under section 65583.2(g)(1), for a nonvacant site like this, the city must “specify the additional development potential for each site within the planning period.” The required analysis is currently missing. A realistic assessment of the current uses and market conditions would preclude listing the entire site at maximum density. Mollie Stone’s is the only full service grocery store in the surrounding area. For households in the southwestern portion of town (for example, everyone near Laurel Elementary School and south to the Belmont border), closing Mollie Stone’s would more than double their travel times to the nearest grocery, and extend them well beyond the one-mile used to define a “food desert” – a condition no one expects to develop in this well-resourced city.8 Currently San Mateo’s land use pattern follows the predictable pattern: few, if any, households are more than one mile from a grocery. There is no reason to believe that the market need for grocery stores will make the need for Mollie Stone’s, or another grocery store, superfluous in this part of town. Particularly as San Mateo’s population grows, the need for grocery stores will increase, not diminish.

7 Here too, the concern about specificity is not idle. There are five separate owners.

Carstens Realty owns most of the parcels, but CLC Investments, Sadigh Sassan, Shamco E LLC, and San Mateo Investment Co. each own one. The City does not discuss or address whether the five are willing or interested in a joint project, though it lists each of them as having expressed interest in a specific plan. Without evidence of what makes consolidation likely, the smaller sites are deemed insufficient to accommodate the need for lower income housing. See Government Code § 65583.2(c)(2)(A).
8 If Mollie Stone’s closed, and no grocery store was rebuilt in its place, it would create the unlikely situation where an affluent, urban community became a “food desert.” The United States Department of Agriculture has defined a “food desert” as an area where at least 500 people, or 33 percent of the tract population, reside more than one mile from a full service supermarket. https://www.ers.usda.gov/webdocs/publications/45014/30940_err140.pdf.

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This means that any redevelopment or specific plan of the Olympic Shopping Center will almost certainly include a substantial retail component, at least on the ground floor. Mixed use may be a responsible way to increase density, but it precludes listing the site at maximum density, particularly given the constraints of Measure Y. The City must conduct further analysis, including an analysis of existing leases, common ownership, and market conditions, before claiming that this site will meet the needs for construction of 161 units of housing affordable to lower income households. And, given the substantial demand for the existing use, the City may not be able to make the required finding under 65583.2(g)(2).

7. Site AN (4100 and 4142 El Camino Real)
(APN 042-242-170 and -080)

On the draft Housing Element site inventory, consolidated Site AN consists of a City- owned vacant site and a neighboring parcel. In a recent staff report for the November 7, 2022 meeting, the chart responding to HCD comments indicated that the City had two city-owned sites: the “Talbot’s” site (APN 034-179-050 and -060), and APN 042-242-170, which it referred to as the “Ravioli” site. The chart indicated that staff recommended adding to the narrative about the Talbot’s site, but recommended removing the Ravioli site from discussion.

The draft Housing Element had shown the two sites APN 042-242-170 and APN -042- 242-080 as having a potential for consolidation, but if the City does not plan to sell APN 042- 242-170, and instead plans to take it off of the site inventory, it should also remove APN 042- 242-080 as unsuitably small for affordable housing.

However, the staff report is confusing on this point. It refers to APN 042-242-170 as the “Ravioli” site, and lists a street address of 505 South B Street. This is not the location of APN 042-242-170. APN 042-242-170 is located at 4140 El Camino Real. If it is indeed City-owned, we encourage the City to make plans to develop it, preferably by issuing a Request for Proposals to transfer it to a non-profit housing developer who could build a 100% affordable project on the site. If the site can be consolidated with the neighboring parcels – which have one story commercial or professional uses, and a relatively large percentage of surface parking – the opportunity would be even more meaningful in terms of providing for the need for housing affordable to those with lower incomes.

B. The Analysis Supporting The Government Code Section 65583.2(c)(1) and (c)(2) Calculation Is Insufficient.

The draft Housing Element states that the site inventory “generally” calculates the realistic capacity of each site based on the maximum density, unless the site is smaller than 0.5 acres or has “characteristics similar to the outlier projects,” in which case a density of 18.2 units/acre is used. Draft Housing Element at H-30 to H-31. The HCD comment letter noted that the assumed densities are not sufficiently supported, and we understand that staff is working on a re-draft to take this comment into account. We offer the following comments about the existing draft to aid in this process.

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Under section 65583.2(c)(1) and (c)(2), a City that lacks a required minimum residential density for a site, like San Mateo, must “demonstrate how the number of units determined for that site will be accommodated.” Under (c)(2), “the number of units calculated pursuant to paragraph (1) shall be adjusted, as necessary, based on the land use controls . . ., the realistic development capacity for the site, typical densities of existing or approved residential developments at a similar affordability level in that jurisdiction, and on [availability of utilities].” Section 65583.2(g)(1) layers on additional requirements to analyze nonvacant sites: the city is required to “provide an explanation of the methodology used to determine the development potential,” and to consider a number of statutory factors.

HCD provided further guidance about the “capacity analysis” in its site inventory guidebook, at page 19-22. It explained that where a city uses sites that are zoned for nonresidential uses, the city must evaluate the capacity analysis by taking into account that some or all of the site may be developed – as city law allows – for such nonresidential uses, such as commercial or office uses. The City is required to take into account any city laws that constrain development, including setbacks, to calculate the “buildable” area, rather than the total size of the site. The City is also required to take into account typical densities, by looking at other projects that have been built or approved.

Unfortunately, the City’s initial draft does not adequately or accurately analyze the required information, and does not present a reasonable methodology based on the data. To the extent it does identify a methodology, it does not apply it consistently. As currently presented, the claimed capacities on the site inventory are unreasonable and arbitrary.

First, the City’s calculation does not take into account the statute or HCD guidance for adjusting site capacity where nonresidential uses are possible. Most of the sites on the inventory, and by far most of the acres, are not zoned exclusively for residential uses. Some are zoned commercial or office with a residential overlay; others are zoned commercial or office with a requirement that any residential use seek a special use permit; the vast majority permit nonresidential uses. Thus, even if the existing use is likely to cease in the next eight years, the current zoning would allow someone else to begin a new nonresidential use.

San Mateo itself has experience with new developments proposed for sites that are not zoned exclusively residential, which then develop for entirely nonresidential uses. In table 5, listing twenty development approvals during the 2017-2021 time frame, the City itself identifies that five of the twenty sites, and 26.7% of the acreage, were developed for nonresidential uses.

Meanwhile, of those sites that did include some residential development, the development was not always 100% residential. Eight of the fifteen projects in table 15 were less than 100% residential. Combined with the five entirely nonresidential projects, 13 of 20 projects listed were not 100% residential. Under the HCD guidance and statutory mandate to consider typical experience with development, the City should apply a significant adjustment downward from maximum density to account for the very real probability that some of the sites may develop for

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nonresidential uses. The City’s application of maximum density to non-residentially zoned sites improperly ignores its experience of recent years.

Second, the City uses incomplete or misleading data to claim development at maximum density. The City’s primary argument for claiming 100% of maximum density for 100% of the acreage is in table 4 of the draft Housing Element. Table 4 distorts the City’s typical experience.

Table 4 carves the data into two categories, referred to as “in-fill” and “outlier.” The categories appear arbitrary,9, suggesting a principled distinction that the City does not rationally apply. Whether intentional or not, the distinction made between “in-fill” and “outlier” excludes from analysis three large, recent developments where a residential project did not develop at maximum density from consideration of the typical experience in San Mateo. Indeed, we were unable to identify a single site where the City applied the “outlier” density of 18.2 units per acre.

Instead of being used to analyze sites, the “outlier” category only serves to exclude from the three sites comprising 20% of all units produced since 2017 – and two of the largest three projects by acreage – from the average density built. Cherry-picking the data is not a proper methodology.

Meanwhile, the table also appears to omit recent information. While table 4 includes high density approvals like the unbuilt project at 666 Concar, it deliberately excludes from the average other lower density approvals like the projects at 21 Lodato, 2089 Pacific, or the mixed use projects at 405 E. 4th and 406 E. 3d, which would show that not every residential or mixed use project, even ones that would fairly be called “in-fill,” develops at or above maximum density as claimed. Also missing entirely, though it will presumably be added to the next draft, is the City’s recent approval of the Draeger’s project at 222 E. 4th/400 So. B Street, where the City approved 17,658 square feet of grocery, 104,554 square feet of office space, and just under 9,000 square feet of residential on a 1.14 acre site, for a residential density in this mixed use site of less than 9 units per acre in the downtown area. Similarly, we note that the recent MU2/MU3 approval will not be built at maximum residential density, given the open space and office uses.

Even projects fairly categorized as “in-fill” do not always develop at maximum (35 or 50) units per acre, contrary to the site inventory calculation. The City should adjust the calculation downward based on the full data set.

Third, the method is either highly subjective, or arbitrarily applied. To reiterate, we were unable to identify any site that the City applied the “outlier” density calculation to, with the exception of the three outlier sites themselves. Instead, even sites that were materially

9 There is little reason, for example, to distinguish 1919 O’Farrell (more than a mile from transit, hemmed in against a freeway in a residential neighborhood) from 220 North Bayshore (more than a mile from transit, hemmed in against a freeway in a residential neighborhood), other than that one developed at higher density than the other, and so is preferred as support for the city’s argument.

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indistinguishable from the “outliers” were nevertheless listed as accommodating the RHNA need at 100% of the maximum zoning capacity. For example:

• The “outlier” project at 1, 2, and 3 Waters Park Road is located less than 100 feet away – just on the other side of Borel Creek, as it empties into Seal Slough – from the Atrium Office Building at 1900 S. Norfolk (discussed above in section A.3). 1900 S. Norfolk is in the same flood zone and just as far from transit as Waters Park Road.10 Why was the 1, 2, and 3 Waters Park Road project an “outlier” that developed at a density of 17 units/acre, but 1900 S. Norfolk is listed as accommodating 50 units/acre? The answer isn’t in the zoning code, either: 1900 S. Norfolk is currently zoned as an office park (E1-0.5), and will need to run the gauntlet of seeking approval for a special use permit, just as the Waters Park Road project did. See San Mateo Zoning Code, § 27.44.030(g). 1900 South Norfolk is not fairly lumped in with “in-fill” sites like the Bay Meadows project, where block after block is filled with four and five story apartment buildings and high density on vacant land zoned using a specific plan. Until San Mateo proves through experience that developers will build high density projects on sites like 1900 S. Norfolk, San Mateo cannot assume that they will incur the expense to build 50 units per acre.
• The sites on the continuation of Norfolk on the opposite side of Highway 92 – still along Seal Slough, and still far from transit – are subject to the same conditions as the lower density “outlier” Waters Park Road project. Without a more convincing analysis, the City should thus apply the 18.2 unit/acre average to the sites at Consolidated Site AC (1826 & 1850 South Norfolk; “Parkside Plaza”).

Yet even while listing a maximum density of 30 du/ac, the City projects 332 units to be built at Parkside Plaza: a full 50 units per acre on the 6.65 acre site. • Are there sites like the “outlier” at 220 North Bayshore, developed in a residential neighborhood, on the eastern side of the 101 freeway? We would suggest that 480 North Bayshore, a quarter-mile away, is subject to the same market

10 These aren’t the only examples, just the clearest ones. Similarly, 1500 Fashion Island (APN 035-550-040) and the Bridgepointe Shopping Center are also down on the flood plain near Seal Slough, and far from transit stations, but not calculated based on the “outlier” density. We focus on the “flood zone” and “far from transit” rationales, because the third “outlier” distinction – whether the project is built for owner-occupied or rental housing – is inherently unknown about all of the sites in the inventory that have not yet applied for development, and so cannot serve as a rational factor to predict future density. Meanwhile, if the city has in mind other factors that explain the difference between “in-fill” and “outlier,” it hasn’t explained or “demonstrated” site capacities as the statute requires. See Government Code § 65583.2(g)(1) (“and shall provide an explanation of the methodology used to determine the development potential . . .”); § 65583.2(c)(1) (“shall demonstrate how the number of units pursuant to this subdivision will be accommodated.”).

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conditions. Yet the City assumed 480 North Bayshore would develop at a density of 50 units/acre: 47 units. If the City wants to apply its “outlier” principle in an intellectually consistent manner, it should list 480 North Bayshore for just 16 units.

Meanwhile, other calculation rules are also either inconsistently or arbitrarily applied:
• Consolidated Site A (two small medical offices, zoned for office but in a neighborhood of lower rent, older two-story apartment structures) appears to be treated as having a 25 unit/acre RHNA credit: 50 units per acre for high density, then cutting it in half because each of the sites separately was less than 0.5 acres.

The two medical offices might better be considered more like the outliers on Campus and Bayshore: far from transit, far from the places where new, high density apartment buildings are actually being built. But regardless, cutting the density in half because the pre-consolidated parcels weren’t 0.5 acres doesn’t seem to be a consistently applied rule, either. See, e.g., Consolidated Site AD (containing parcels smaller than 0.5 acres, but assuming development at 50 units/acre).

Fifth, the analysis doesn’t discuss how the city’s development rules reduce the acreage available for residential development. HCD’s guidance shows that where the city’s rules – for example, for setbacks or required first floor retail – constrain the site, the numbers should be adjusted downward. As others have commented, Measure Y in particular may represent a significant constraint. But other provisions of the zoning code could impact the ability to build to maximum density, or use the entire acreage as “net buildable” space. See, e.g., San Mateo Zoning Code § 27.29.118 (prohibiting residential uses on first floor in mixed use projects in downtown), 27.30.027 (prohibiting ground floor residential uses in the first 30 feet facing El Camino Real or 25th Avenue), 27.39.100 (required retail frontage in downtown),

27.42,010 (“Street Wall” regulations requiring upper floor setbacks in the downtown).

Sixth, the calculation fails to engage in site-specific adjustments, including regarding the current use or other constraints, as required by 65583.2(c)(2) and (g)(1). The Mollie Stone’s and Hillsdale North Block examples, discussed above, both illustrate this problem. The likelihood that the existing use will continue precludes listing these sites for lower income RHNA credit under section 65583.2(g)(2), but under (c)(2) and (g)(1), the City would still need to separately evaluate whether the existing uses provide a constraint on the ability to develop the entire site in order to correctly calculate the accommodation of moderate and above-moderate income households. The likelihood that the current owner of the Mollie Stone’s site will want to consider the grocery store use, based on market conditions and location, as part of their interest in a “specific plan,” means that the City should consider whether a 100% residential development is a fair calculation of site capacity. The City is required to address whether it foresees a significant retail presence there: a development more like the Draeger’s approval, where an existing grocery store was incorporated into the site plans and the site was developed at less than 20% of the maximum residential density. Similarly, given that the $200+ million

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construction of Hillsdale North Block precludes use of the 12.5 acres there, and the pedestrian bridge shows an intention to continue the use of the Nordstrom building at a minimum, the City needs to analyze which portions of the Hillsdale site might realistically be developed as residential housing during the next eight years, then reduce the calculation to take these site constraints into account.11

State law requires that the City develop and justify a cogent, realistic methodology to support its anticipated production calculations, and requires that it apply that methodology consistently and thoughtfully to the site inventory to yield realistic results. The current analysis and approach is insufficient, and the problems with it won’t be remedied merely by providing additional discussion. The “in-fill”/“outlier” methodology does not make sense: it appears subjective, overly-rudimentary, and arbitrary, and even if better explained may not legally “demonstrate how the number of units determined for [each] site . . . will be accommodated.” Unfortunately, the analysis so far appears to lack principles that can rationalize the densities used. Along with HCD, we look forward to improvements in the next draft.

C. Additional Comments On Zoning Status.

As noted above, a number of sites included in the City’s inventory are zoned commercial or office without a residential overlay. We request that San Mateo rezone these sites to add a residential overlay, so that developers are assured that residential uses will be permitted, rather than hope the desired inclusion of residential uses will be permitted on a site-by-site basis as part of project-specific approvals. Uncertainty regarding the ultimate success of a rezoning effort discourages residential development in the City. The entire point of the housing inventory is to

11 The Fishmarket site at 1863 South Norfolk is another example of the City not taking the analysis to the required next level. After identifying a methodology to estimate yields (Government Code § 65583.2(c)(1), the City is then supposed to consider site conditions and make adjustments. Id. (c)(2). In the case of 1863 South Norfolk (the “Fish Market”; APN 035- 383-200), just across the street from Parkside Plaza and squeezed between South Norfolk and Seal Slough, the City would need to start with its “outlier” calculation. Indeed, in a development application last year, the site owner initially proposed 74 townhomes, along with public space concessions to try to seek a special use permit for the property. The request was for 21 units/acre on a 3.5 acre parcel, quite close to the 18.2 estimate for outliers.

More recently, the owner has come back with a new plan; this time for 321 units (over 91 units/acre) in sixty foot tall buildings. How much is fair to estimate? More analysis is required, including consideration of Measure Y, and whether neighbors and the City will want some open space along the shoreline. (There is also the potential site constraint of BCDC jurisdiction, which might affect the ability to obtain an approval so close to the shoreline).

Regardless, the City’s current estimate of 30 units per acre lacks reasoning or principle under either the “in-fill” or “outlier” rationales. The 45 units per acre applied to 1500 Fashion Island (273 units/6.08 acres) likewise seems disconnected from the city’s explanation of the math. Even if these numbers were chosen deliberately based on site-specific conditions, an explanation is required to meet the statutory requirement.

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determine if there are sufficient sites that are either (1) vacant and zoned residential, (2) vacant and zoned for nonresidential use “that allows residential development,” (3) residentially zoned sites capable of being developed at a higher density, or (4) “sites zoned for nonresidential use that can be redeveloped for residential use, and for which the housing element contains a program to rezone the site, as necessary, to permit residential use.” Government Code § 65583.2(a)(1)-(4). The sites zoned for commercial or office use, without a residential overlay, do not fall within 65583.2(a)(3), because they are not zoned residential. They must therefore be included in a program to rezone to affirmatively permit residential use. Having the City retain discretion to refuse or condition residential development on these properties does not make them available as required by state housing law.12

The City should also consider the impact of Government Code section 65583.2(h).

Section 65583.2(h) provides that at least fifty percent of the need for very low and low income housing must be accommodated on sites designated for residential use where non-residential uses are not permitted. This would not appear to apply to San Mateo’s site inventory, because at least fifty percent of the need is proposed to be met using mixed use sites that allow commercial uses. (For example, the Bridgepointe and Hillsdale shopping centers, zoned for commercial uses, see, e.g., City of San Mateo Zoning Code chapter 27.34). Meanwhile, the alternative of accommodating 100% of the very low and low income need on sites designated for mixed uses, “if those sites allow 100 percent residential use,” would appear not to apply to certain of the City’s zoning designations. See, e.g., City of San Mateo Zoning Code § 27.38.110. The City should evaluate how to address the impact of this statutory provision as part of the final drafting of the Housing Element.

* * *

Based on the analysis above, San Mateo’s draft Housing Element does not comply with state law, because it proposes to meet more than 50% of the need for affordable housing with sites that are not vacant, and does so without substantial evidence that they are likely to be redeveloped. The City’s current analysis, which fails to analyze or account for leases, whether parcels proposed to be consolidated are under common ownership, recent remodeling/construction indicating that existing uses will continue, and other obstacles to development in the next eight years, is insufficient to meet its responsibility under state housing law. In particular, the City lacks substantial evidence showing that the Bridgepointe and Hillsdale shopping center sites have existing uses that are “likely to discontinue” during the next eight years, but as the other examples we cite above illustrate, the required analysis under 65583.2(g)(1) and (g)(2) must be done for each site separately in order to have a valid Housing Element. The estimates of how many units will be accommodated in each category also need considerable work before the reasoning will stand up to HCD or court analysis under 65583.2(c)(1) and (2), and (g)(1).

12 We note, for example, that the Waters Park Road project, zoned E-1, sought a rezoning because it was not zoned residential, as part of its attempt to seek permission to redevelop the site. Sites on the inventory should not have to go through this step.

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Housing Element
December 16, 2022

Given the substantial need for suitable, available, and realistic housing sites zoned to meet San Mateo’s share of the regional need, we suggest that additional sites will need to be identified and potentially rezoned to ensure compliance with state housing law. A more substantial inventory will avoid the possibility that the Housing Element will be invalidated in the event that HCD or a court agrees with the arguments above.

Respectfully submitted,

Thomas B. Mayhew

Charles J. Higley
36615\15195239.2

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1 Nicholas "Nicky" Vu
From: Housing
Sent: Tuesday, January 3, 2023 10:18 AM
To: Nicholas "Nicky" Vu; Eloiza Murillo-Garcia
Subject: FW: Housing Element Comment Letter
Attachments: San Mateo Housing Element_Comment Letter_UC Berkeley_12.22.22.pdf Follow Up Flag: Follow up
Flag Status: Flagged

Sandra Belluomini
Administrative Tech| Housing
330 W. 20th Ave., San Mateo, CA 94403

From: Andrew Wofford
Sent: Thursday, December 22, 2022 10:28 AM
To: Housing <[email protected]>
Subject: Housing Element Comment Letter

Hello,

My name is Andrew Wofford‐‐I am a graduate student in City Planning at UC Berkeley. I am writing to submit a comment letter regarding San Mateo's draft housing element. The letter was written by myself and three additional graduate students in City Planning and Public Policy‐‐Amba Gupta, Marisa Espinoza and Samuel Greenberg.

Please let me know if there are any additional persons to whom we should send the letter for consideration.

Thank you and happy holidays,
Andrew

‐‐
Andrew Wofford (he/him)
Master of City Planning ‐ 2024
College of Environmental Design ‐ UC Berkeley

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City of San Mateo330 W 20th Ave.San Mateo, CA 94403
To the honorable San Mateo City Council,
We greatly appreciate this opportunity to offer feedback to the City of San Mateo on its drafthousing element. We are graduate students in Public Policy and City Planning at the University ofCalifornia, Berkeley, where we are studying housing policy.

We applaud the City of San Mateo for planning for 154% of its Regional Housing NeedsAssessment (RHNA), and the diligent work conducted to craft its housing element and provideprotections for at-risk renters. However, in order to comply with state housing law, San Mateomust address the significant barrier that Measure Y poses to meeting its RHNA goals and fulfillingits obligation to Affirmatively Further Fair Housing (AFFH).

The housing element must identify specific ways to mitigate Measure Y density restrictions inorder to achieve the level of housing production required by the RHNA. Likewise, the city mustplan to take substantive action to achieve the goals required by the AFFH mandate. Specifically,we believe that San Mateo’s housing element must further define how it will incorporate affordablehousing into areas of significantly concentrated affluence, assess its site inventory for whether itimproves or exacerbates AFFH goals, reduce the high percentage of planned low income housingunits located on non-vacant sites, and generally ensure that its plan to fulfill AFFH requirements isrealistic and complies with state law. By strengthening AFFH planning and moving beyond theconstraints of Measure Y, the City of San Mateo can meet its RHNA goals and help ensure thatSan Mateo will be a vibrant, welcoming, and affordable city for current and future residents.

Why San Mateo Can and Must Ignore Measure Y
Since 1991, Measure Y has imposed a height restriction of 50 feet (four to five stories) and adensity restriction of 50 dwelling units per acre on all new buildings within the City of San Mateo.The restriction applies to every parcel of land in the city. On November 4th, 2020, San Mateansvoted to reapprove Measure Y by a margin of 43 votes out of a total of 46,033 votes cast.

Policy advocates at the Greenbelt Alliance have argued that Measure Y is an act of“exclusionary zoning.” By severely limiting the heightand density of multifamily buildings, the 1 ordinance renders most multifamily housing in the city financially infeasible. More importantly,these restrictions likely increase home prices in the few multifamily buildings that are viable; asa result, fewer low-income families can afford to live in San Mateo. 2 2
Muhammad Alameldin, David Garcia, “The Cost to Build New Housing Keeps Rising,” Terner Center for HousingInnovation, August 4, 2022,https://ternercenter.berkeley.edu/research-and-policy/cost-to-build-housing-legislation-2022/ 1 Teri Shore, “Loss: San Mateo Measure Y,” Greenbelt Alliance, November 4, 2020,https://www.greenbelt.org/blog/vote-no-on-measure-y-to-provide-essential-homes-in-san-mateo/#:~:text=Measure%20Y%20is%20an%20example,to%20the%20three%20 Caltrain%20 stations

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Commendably, the Council acknowledges the long history of San Mateo’s exclusionary zoningpractices in its draft housing element. Although not intended to discriminate, Measure Y is anextension of the legalized housing segregation which the Council is working to undo and repair.Multifamily apartment buildings remain one of the few affordable housing options for low-incomepeople of color and immigrants in San Mateo and the wider Bay Area. By making it all but 3 impossible to create new, multifamily housing units at an affordable price, Measure Y threatensSan Mateo’s ability to create an equitable and inclusive city going forward.

More immediately, based on its existing site inventory, the City of San Mateo cannot fulfill itsRHNA goals if it adheres to Measure Y. If the Council does not demonstrate that the city canrealistically meet these goals, San Mateo will be out of compliance with state law.

A number of precedents confirm that the City of San Mateo must ignore an existing localordinance if that ordinance prohibits a jurisdiction’s ability to comply with state law (seeUrbanHabitat v. Pleasanton). Last November, HCD providedclear guidance to the City of Alameda that 4 its voter-enactedMeasure A, which similarly limiteddensity across all parcels, was “in conflict withstatelaw and should be voided.” The City of Alamedahas since submitted a draft housing 5 element–deemed compliant by HCD–thatignores MeasureA constraints and plans forhigher-density housing than the ordinancewould haveallowed. 6 We are particularly concerned that the City of San Mateo cannot comply with state AFFH laws ifthe city adheres to Measure Y. In its review of Alameda’s Measure A, HCD found that themeasure violated Government Code sections 8899.50 and 65583 because the densityrestrictions “deny fair housing choices and are fundamentally contrary to affirmatively furtheringfair housing.” This decisive finding indicates that HCD will correctly identify Measure Y’s densityrestrictions as impediments to fair housing choice that violate state housing law.Therefore, westrongly recommend that the Council move to ignore Measure Y and plan for higher-density,multi-family housing in the final housing element.

We recognize that it is difficult for Councilmembers to ignore ameasure approved byconstituents. However, we remind the Council thataccording to the Community Input Survey itcommissioned earlier this year, 63% of SanMateanssupport new, higher-density housing in thecity’s downtown of up to 12 stories; while68% supportnew housing of up to 8 stories. 7 7
True North Research, “Community Opinion Survey,” City of San Mateo, February 21, 2022, p. 12,https://www.cityofsanmateo.org/DocumentCenter/View/87282/San-Mateo-Community-Opinion-Survey-2022-Report 6 Ken Der, City’s Housing Element Deemed Compliant,” Alameda Post, September 7, 2022,https://alamedapost.com/news/citys-housing-element-deemed-compliant/ 5 Paul McDougall, “RE: City of Alameda Measure A Provisions and Housing Element Compliance,” Department ofHousing and Community Development, November 29, 2021, p. 4,https://www.hcd.ca.gov/community-development/housing-element/docs/alaalamedacity-ta-112921.pdf 4 “Urban Habitat v. City of Pleasanton,” Public Advocates, November 30, 2022,https://www.publicadvocates.org/our-work/housing-justice/urban-habitat-v-city-pleasanton/ 3 Chair Cecilia Rouse, Jared Bernstein, Helen Knudsen, Jeffery Zhang, “Exclusionary Zoning: Its Effect on RacialDiscrimination on the Housing Market,” The White House, June 17, 2021https://www.whitehouse.gov/cea/written-materials/2021/06/17/exclusionary-zoning-its-effect-on-racial-discrimination-in-the-housing-market/

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San Mateo residents understand that the city needs higher-density housing in order to growsustainably. To do so, San Mateo must move beyond Measure Y.

Site Analysis: Hillsdale Shopping Center
If the city upholds the exclusionary restrictions of Measure Y, some of its current housing sites inthe draft element will simply not be feasible for development within the next eight years. TheHillsdale Shopping Center is an important example.

As the largest site in San Mateo’s inventory, Hillsdale is estimated to accommodate 1,996 units,comprising approximately 28% of the city’s total RHNA target. The housing element justifies thisestimate by simply stating that the owner is interested in mixed-use redevelopment thatmaximizes residential units. It does not demonstrate an in-depth unit calculation as per severalcapacity factors suggested by HCD’s Site Inventory Guidebook. As a result, the city has putforward an unrealistic estimate of the site’s capacity.

The draft housing element assumes that 100% of the available land at the Hillsdale site willbecome new homes at 100% of the zoned capacity. Recently,however, the site’s owner David 8 Bohannon invested $257 million to renovate 12.5 acres of the shopping center. This renovation,along with other factors detailed in the table below, significantly impacts realistic capacitycalculations:
8 Jerimy Levine, Housing Leadership Council of San Mateo, “San Mateo Housing Element Letter”, pg. 2https://drive.google.com/file/d/1dclzoVUm5i_mjGauJof60bKplZxBc6dU/view

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Most notably, the city must allow greater density than Measure Y currently permits in order forDavid Bohannon to even consider redeveloping the site for residential use. Thus far, he has statedthat there is no timeline for redeveloping the site because the city has not indicated that it intendsto lift Measure Y. 9 Fortunately, if the Council does plan for density beyond the constraints of Measure Y, the HillsdaleShopping Center site has significant potential for affordable housing development as part of atransit-oriented district. Without such restrictions, the developer can distribute densities across thesite as intended and realistically develop the units estimated in the element site inventory.

There are other similar sites in the inventory that are highly unlikely to be developed, such as theBridgepointe Shopping Center, which recently renewed long term leases with several commercialtenants. These sites have been misidentified as opportunitysites for the inventory. A more 10 realistic capacity calculation which accounts for Measure Y’s constraints will considerably reducetheir estimated potential units. Thus, the city must identify additional opportunity sites not currentlylisted in its inventory or suspend Measure Y to allow for higher-density housing on these existingsites.

Affirmatively Furthering Fair Housing
San Mateo’s housing element additionally misses critical opportunities to better comply withHCD’s AFFH requirements. The AFFH assessment, which according to HCD, must “include anassessment of fair housing in the jurisdiction” has significant shortcomings. While the housing 11 element does map racially and ethnically concentrated areas of poverty, it does not mapaffluentracially segregated areas. This is a notable omission as the most residentially segregatedpopulation in San Mateo is non-hispanic white residents. In order to meet state requirements and 12 decrease residential segregation, the AFFH assessment must first effectively document patternsof residential segregation.

Beyond the assessment, the AFFH section fails to appropriately “identify and prioritizesignificant contributing factors” which “create, perpetuate, or increase the severity of one ormore fair housing issues,”as required by HCD. Currently,many of the noted contributing 13 factors simply state the characteristics of poverty and identity-driven disparities rather thancity-controlled factors that cause or contribute to fair housing issues. For example, the element 13 Olmstead, Zachary
12 Adam Nuget,Commissioner Input Draft 2023-2031 HousingElement. April 6, 2022,https://drive.google.com/file/d/19UCFi_6p3JvL5cw2GkcHgbkhcWNwk1Yl/view 11 Zachary Olmstead,AB 686 Summary of Requirementsin Housing Element Law Government Code Section 8899.50,65583(c)(5), 65583(c)(10), 65583.2(a). CaliforniaDepartment of Housing and Community Development, 23 Apr. 2020,https://www.hcd.ca.gov/community-development/housing-element/housing-element-memos/docs/ab686_summaryhousingelementfinal_04222020.pdf 10 Jerimy Levine, Housing Leadership Council of SanMateo, “San Mateo Housing Element Letter”, pg. 2https://drive.google.com/file/d/1dclzoVUm5i_mjGauJof60bKplZxBc6dU/view 9 Curtis Driscoll, “Hillsdale Mall seeks New Zoning”, The Daily Journal, April 11, 2022https://www.smdailyjournal.com/news/local/hillsdale-mall-seeks-new-zoning/article_6ebb7f56-b971-11ec-b53a-0f92f5a9aca1.html

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states that “there are concentrations of the population living witha disability west of Highway 101 in the North Centralneighborhood,” a neighborhood that scores poorly onenvironmental and economic opportunity indexes. This is simplya statement of the characteristics of disparities betweenresidents with and without disabilities, and belongs in the fairhousing assessment. To effectively address these disparities andnot merely describe them, the housing element must first identifywhat planning and policy decisions led to these conditions.

San Mateo’s plan to respond to this assessment and addressthese contributing factors is limited in two fundamental ways.First, no areas designated for affordable housing are locatedwithin San Mateo’s highest-opportunity neighborhoods. Bycontrast, significant affordable housing is planned for the city’slowest-income neighborhoods. This imbalance will likely increaseresidential segregation. Additionally, according to HCD’sassessment,San Mateo’s draft housing element “reliesuponnon-vacantsites to accommodate more than 50 percentof theRHNA for lower-income households.” This means thatSan 14 Mateo is relying on sites unlikely to be developed in the nearterm for much of itsplanned affordable housing development.

A Call to Action
San Mateo should take meaningful action by 2024 to overcome existing policy barriers to housingaccess. The city has an opportunity to work in coalition with neighboring jurisdictions to bolstersignificant regional goals to affirmatively further fair housing and rapidly increase housingproduction across the south Bay Area.

This should take the form of a two-pronged approach. First, San Mateo must deepen its AFFHefforts through strong policies that incorporate affordable housing into high-opportunityneighborhoods. It will be necessary for the city to do the following: 1) allow for more density insingle-family zoned, high-opportunity neighborhoods; 2) increase the share of affordable housingplanned for vacant sites and high-opportunity neighborhoods; 3) establish an overlay to prioritizeaffordable housing in high-opportunity areas; and 4) reduce overall fees on affordable housingdevelopment.

Second, the city must proactively address impediments caused by Measure Y through anambitious legal and legislative strategy. By the close of 2023, the city should produce a detailed 14 McDougall, Paul.RE: City of San Mateo’s 6th Cycle(2023-2031) Draft Housing Element. California DepartmentofHousing and Community Development, September 28, 2022,https://www.cityofsanmateo.org/DocumentCenter/View/89423/September-28-2022-HCD-Response-Letter.

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study on the impacts of Measure Y and whether repeal of this ordinance is necessary for the cityto actually permit the planned units in its housing element within the next eight years. If deemednecessary, the city should pursue a veto referendum to repeal Measure Y. Most importantly, thisstudy should also ensure that a potential reversal meets AFFH and inclusionary housingobjectives that benefit historically excluded communities and populations targeted by housingsegregation and discrimination.

Such a strategy would require more immediate action as well: in the near-term, the city shouldsuspend implementation of Measure Y and clarify city powers for the purposes of submitting acompliant housing element. The city should pursue expert legal advice and craft a robust policyagenda that can withstand potential legal challenges.

An Opportunity for San Mateo
The statewide housing element process provides the City Council of San Mateo with atremendous opportunity to lead the south Bay Area in creating a more accessible andsustainable region. In aiming to exceed its RHNA goals, the Council has shown that it can bothset an example for the wider region and impact residents beyond its boundaries. As the city’selement is currently drafted, however, these lofty goals will not materialize.

The Council must take clear action to ensure that San Mateo can achieve these urgently neededhousing goals and fulfill its legal obligations to the state. We look forward to seeing how theCouncilmembers respond to this opportunity.

Thank you for your consideration,
Andrew Wofford, Masters Candidate in City Planning, UC BerkeleyAmba Gupta, Masters Candidate in City Planning, UC BerkeleyMarisa Espinoza, Masters Candidate in Public Affairs, UC BerkeleySamuel Greenberg, Masters Candidate in Public Affairs, UC Berkeley

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C ITY OF SAN MATEO 20 31 HOUSING ELEMENT
Appendix H-F
PLANNING COMMISSION AND CITY COUNCIL MINUTES – APRIL 26, 2020 TO NOVEMBER 7 , 2022

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Planning Commission Regular Meeting Minutes – 4/26/22 1 6 6
6 9

COMMISSION MEMBERS
Margaret Williams, Chair
John Ebneter, Vice Chair
Adam Nugent
Seema Patel
Vacant
City of San Mateo
Regular Meeting Minutes
Planning Commission
Tuesday, April 26, 2022
Remote 7:00 PM
Regular Meeting
City Hall
330 W. 20th Avenue
San Mateo CA 94403
www.cityofsanmateo.org

CALL TO ORDER
This meeting is being held under the provisions of State of California Bill AB361; in which Brown Act regulations are relaxed to allow members to remote in due to the Coronavirus Covid-19 health emergency.

PLEDGE OF ALLEGIANCE

ROLL CALL
Remote: Vice-Chair Margaret Williams, Commissioners John Ebneter, Adam Nugent, and Seema Patel

Absent: None

CONSENT CALENDAR

1. Planning Commission Meeting Minutes – Approval
Approve the minutes of the Planning Commission Regular meeting of March 22, 2022.

Moved: Nugent, Seconded: Patel
Ayes: Williams, Ebneter, Nugent, Patel
Noes: None

Absent: None
PUBLIC COMMENT: None.

PUBLIC HEARING

2. Draft 2023-2031 Housing Element
Housing Consultant Diana Elrod, Planning Manager Manira Sandhir and Deputy Director Zach Dahl did a presentation on the Draft Housing Element 2023-2031, including providing information on the Sites Inventory, Affirmatively Furthering Fair Housing (AFFH), other Housing Element Sections, and Goals, Policies, and Programs.

Planning Commissioners requested to provide discussion and feedback to help refine the Draft Housing Element.

Commissioner Questions:

The Commission asked questions of staff relating to the sites inventory methodology; definition of “preservation” of housing units, and whether executive office zoning allowed residential uses.

Public Comments:

Members of the public, Raayan Mohtashemi, Ken Abreu and Martin Wiggins addressed the Commission, raising concerns relating to sites inventory methodology; exploring more aggressive policies for funding and lowering cost of development; workforce needs, under the Carpenters Union, to build the housing; and Measure Y constraints.

Jordan Grimes expressed disappointment that the Housing Element Draft doesn’t promote housing inventory based on the sites inventory and realistic housing goals.

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Planning Commission Regular Meeting Minutes – 4/26/22 2 6 6
6 9
Commissioner Comments:

Discussion ensued regarding the methodology used for the sites inventory, including the need to bolster the analysis to support the inclusion of each site; concerns about including Target site and recently established restaurant sites, inclusion of smaller sites and sites within 500 feet of freeways, a site under the County’s groundwater protection program; and concerns about anecdotal conversations regarding property owner intent for some of the proposed sites.

Commissioner Williams also provided comments relating to conserving and preserving existing housing stock.

Additional Commissioner comments focused on the AFFH narratives asking for significantly more history and background to analyze racially segregated concentrated areas of affluence, considering housing sites within the highest opportunity areas, addressing overcrowding and the history of disinvestment in certain areas, and prioritize addressing the history of segregation by analyzing city-controlled regulatory factors that has caused the situation.

Commissioners also provided comments on outdated, exclusionary CC&Rs and protecting/conserving existing housing stock in good repair.

At 11 pm there was a discussion among the Commissioners if they wanted to proceed with this item or continue to a date certain. The majority of the Commission favored a continuance.

The commission continued this item to a Special Planning Commission remote meeting on May 3, 2022 at 7 pm.

Moved: Nugent, Seconded: Ebneter
Ayes: Williams, Ebneter, Nugent, Patel
Noes: None

Absent: None

REPORTS AND ANNOUNCEMENTS
Planning Manager, Manira Sandhir provided updates on items for future Planning Commission meetings and provided information on Planning Commission handbook and upcoming trainings. She also provided a staff update related to the meeting being Assistant City Attorney Gabrielle Whelan’s last meeting, as she had accepted a role with another jurisdiction. Commissioner Patel confirmed she would be absent for the May 10, 2022, Planning Commission meeting.

Chair Williams confirmed she would be absent for the May 24, 2022, Planning Commission Meeting. There were no other reports from Chair, Commissioners or City Attorney.

ADJOURNMENT
The meeting adjourned at 11:13 pm.

APPROVED BY:
___________________________________
Margaret Williams, Chair
SUBMITTED BY:
___________________________________
Mary Way, Administrative Assistant

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Planning Commission Special Meeting Minutes – 5/3/22 1

COMMISSION MEMBERS
Margaret Williams, Chair
John Ebneter, Vice Chair
Adam Nugent
Seema Patel
vacant
City of San Mateo
Special Meeting Minutes
Planning Commission
Tuesday, May 3, 2022
Remote 7:00 PM
Special Meeting
City Hall
330 W. 20th Avenue
San Mateo CA 94403
www.cityofsanmateo.org

CALL TO ORDER
This meeting is being held under the provisions of State of California Bill AB361; in which Brown Act regulations are relaxed to allow members to remote in due to the Coronavirus Covid-19 health emergency.

An announcement was made that attendees would not be able to watch a live feed of this meeting via Youtube due to technical issues but were able to see the meeting live via zoom and participate via zoom. It was confirmed through the City Attorney that this meeting could proceed as it met the Brown Act requirements.

PLEDGE OF ALLEGIANCE

ROLL CALL
Remote: Chair Margaret Williams, Vice Chair John Ebneter, Adam Nugent, and Seema Patel

Absent: None

PUBLIC HEARING

1. Draft 2023-2031 Housing Element – CONTINUED FROM PLANNING COMMISSION MEETING OF 4.26.2022 Planning Manager, Manira Sandhir presented an overview of the past meeting, objectives for this meeting, and next steps. Feedback was requested on components of the Draft Housing Element 2023-2031 including Other Housing Elements Sections, and the Goals, Policies, and Programs including the action plan for Affirmatively Furthering Fair Housing Policies and Programs (AFFH).

Commissioner Questions:

Commissioners had not questions of staff.

Public Comments:

Members of the public, Kalisha Webster, Senior Housing Advocate and Carol Eldridge with One San Mateo addressed the Commission, regarding supporting policies for accessible housing to address reasonable accommodation for physical and/or mental disabilities; and concerns regarding Measure Y imposed constraints, sites inventory methodology and exclusion of R1 (single-family) zoned neighborhoods.

Commissioners commented on the following items:

The Commission provided several comments relating to strengthening the Constraints Analysis and the Quantified Objectives. The Commission also provided extensive feedback on the Goals, Policies and Programs, including to strengthen the terminology and any non-committal language with firm targets and commitments such as for family housing, missing middle housing, looking at funding options such as vacancy taxes etc., expanding tenant protection, creating new goal to eliminate disparity and overcrowding, longer deed restrictions, special needs, housing,

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Planning Commission Special Meeting Minutes – 5/3/22 2
achieving health and housing parity, address R1-zoned neighborhoods and provide parity of amenities, Bridgepoint condominiums preservation, u- zoning the entire city, and creating objective architectural goals.

ADJOURNMENT
The meeting adjourned at 9:55 pm.

APPROVED BY:
___________________________________
Margaret Williams, Chair
SUBMITTED BY:
___________________________________
Mary Way, Administrative Assistant

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7 0
0 4

COUNCIL MEMBERS
Rick Bonilla, Mayor
Diane Papan, Deputy Mayor
Amourence Lee
Joe Goethals
Eric Rodriguez

CITY OF SAN MATEO
Special Meeting Minutes
City Council
City Hall
330 W. 20th Avenue
San Mateo CA 94403
www.cityofsanmateo.org
May 23, 2022
In Person and Remote 5:30 PM
Special Meeting

CALL TO ORDER
Roll Call: Mayor Bonilla, Deputy Mayor Papan, Council Members: Lee, Goethals and Rodriguez

PUBLIC HEARING

1. Draft 2023-2031 Housing Element Public Hearing
Zachary Dahl, Deputy Director, provided a presentation to Council which included an explanation of the methodology for estimating development potential for the sites inventory, which is expected to evolve and change. He provided an overview of the quantified objectives, and the public outreach and engagement process, and further explained how public participation helped influence the development of the Draft Housing Element.

He noted Diana Elrod, Housing Consultant, was participating remotely and would be available to answer questions as needed.

Manira Sandhir, Planning Manager, explained additional required components and goals, policies, and actions; she summarized public comments received to date, shared the Planning Commission perspective and reviewed the timeline for the process.

Council asked questions of staff including additional information on the sites inventory methodology, inquired about the consultant’s experience and thanked staff for their efforts on preparing the Draft Housing Element.

Public Comments – Tom Taber supported building more housing and fewer office buildings; Michael from Local 217 Foster City stated encouraged labor standards and well-paying jobs are needed; Ken Abreu from local chapter of the Sierra Club restated elements from submitted letter; Karen Herrel stated concern that there seems to be a desire for the Housing Element to fail and why there is still a push for R1 districts; Lisa Diaz Nash supported the proposed Housing Element; Jennifer Martinez read remarks from Carol Steinfeld noted the history of racial segregation through housing; Noelle Langmack concern that there is no rezoning required to achieve housing numbers; Michael Weinhauer stated trickle down housing does not work; Sean stated concern for green space and parks in the planning; Karyl Eldridge commented on historical racial issues; Jordan Grimes noted deficiencies with lack of rezoning in the element; Justin Alley, One San Mateo, noted the City is not following the law; and Jeremy Levine, Housing Leadership Council, noted two letters provided to the City with their recommendations.

Councilmembers complimented staff on the presentation and follow-up responses to questions, and provided individual comments, which included concerns with Commissioner use of their title when providing individual comments, review of the demographic trends narrative to ensure that historical segregation and displacement were appropriately reflected, the need for more affordable home ownership opportunities, the importance of planning for the housing needs of our ‘silver tsunami’ population and homeless population, the importance of keeping the Housing Element adoption on schedule to maintain funding opportunities and that staff should explore the feasibility of the City achieving a Pro Housing designation from the State.

Staff revisited various comments that were heard to confirm Council consensus on the topics raised, including evaluating minimum residential requirements in mixed-use zoning districts, prioritizing senior housing, evaluating DocuSign Envelope ID: F46F9E8B-450F-44E4-BCC7-0BE6A5CBFB04

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7 0
0 4
parking standards for sites near transit, and exploring ways to support non-profits and faith-based organizations that want to produce affordable housing.

ADJOURNMENT – The meeting adjourned at 8:31 p.m.

APPROVED BY: SUBMITTED BY:

Rick Bonilla, Mayor Joan P. Diskin, Deputy City Clerk DocuSign Envelope ID: F46F9E8B-450F-44E4-BCC7-0BE6A5CBFB04

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City Council Special Meeting Minutes – 11/07/2022 Page 1

COUNCIL MEMBERS
Rick Bonilla, Mayor
Diane Papan, Deputy Mayor
Amourence Lee
Joe Goethals
Eric Rodriguez

CITY OF SAN MATEO
Special Meeting Minutes
City Council
City Hall
330 W. 20th Avenue
San Mateo CA 94403
www.cityofsanmateo.org

November 7, 2022
Council Chambers 5:30 PM
Special Meeting

CALL TO ORDER -
Roll Call

Present: Mayor Bonilla, Council Members: Lee, Goethals and Rodriguez

Deputy Mayor Papan arrived at 5:35 p.m.

CLOSED SESSION
Following the opportunity for public comment, there were no speakers, the City Council convened into Closed Session at 5:32 p.m. to consider:

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

The City Council reconvened at 5:43 p.m.

STUDY SESSION
Following the opportunity for public comment, there were no speakers, the City Council convened into Closed Session to consider:

2. Draft 2023-2031 Housing Element Study Session
Eloiza Murillo-Garcia, Housing Manager, provided a presentation on the history of the Housing Element effort.

Zachary Dahl, Deputy Director of Community Development, provided an overview of the 91 comments received, outlined the activity that needs to take place for the eight-year housing element cycle, and explained the next steps in the process. He requested direction on 13 comments called out regarding responses to the California Department of Housing and Community Development’s comment letter on the City’s Draft Housing Element.

Council asked questions of staff. Staff and Consultant Diana Elrod responded to questions. Prasanna Rasiah, City Attorney, responded to question regarding exposure to lawsuit.

Public Comment – Ken Abreu expressed the need to deal with the housing crisis on a regional basis. Jeremy Levine stated this Council is not moving in a direction to make substantial changes. Karyl Eldridge, One San Mateo, commented on impact of non-dense housing on affordability. Mitch Speigle spoke of implementation issues. Jordan Grimes stated there are a myriad of issues with the staff report.

Council asked additional questions of staff.

The City Council convened to the Regular Meeting at 7:05 p.m. and reconvened to the Study Session at 10:41 p.m.

Further discussion ensued and staff felt confident in moving forward with Council recommendations.

DocuSign Envelope ID: 69D29DD1-A484-43BA-AB88-B9B16616E0BF

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City Council Special Meeting Minutes – 11/07/2022 Page 2

ADJOURNMENT – After a moment of silence, the meeting adjourned in honor of Lory Lorimar Lawson, Margaret Donnellan, and Linda McCoy at 11:34 p.m.

APPROVED BY: SUBMITTED BY:

Rick Bonilla, Mayor Patrice Olds, City Clerk DocuSign Envelope ID: 69D29DD1-A484-43BA-AB88-B9B16616E0BF

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STABLE

RESIDENTIAL
STABLE

RESIDENTIAL
OFFICE

BUILDINGS
OFFICE
OFFICE

SAFEWAY

CALTRAIN
FOCAL
POINT
GATE
BOREL
SQUARE
FOCAL
POINT
1/4 MILE
FROM

CALTRAIN
1/2
MILE

HAYWARD
PARK

CALTRAIN

STATION

HAYWARD PARK /

BOREL SQUARE

POTENTIAL

STUDY AREA

STABLE USES
(not likely to change)
.
. Moderate-/High-Intensity

LOW-INTENSITY USES
(redevelopment opportunity)
.
. Retail & Office
.
. Industrial & Service Comm’l
27TH/BOVET CONNECTION
.
. Activity & Improvements

FOCAL POINT
.
. Activity & Identity
0’ 200’
August 12, 2019
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C I T Y O F S A N M A T E O
20 4 0 G E N E R A L P L A N

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

Appendix H-F

AT TIME OF PUBLICATION THE MINUTES OF THE PLANNING COMMISSION AND CITY COUNCIL MEETINGS HELD AFTER NOVEMBER 7, 2022 WERE NOT AVAILABLE. WHEN AVAILABLE THEY WILL BE POSTED TO THE CITY’S WEBSITE AT:

HTTPS://WWW.CITYOFSANMATEO.ORG/4478/HOUSING-ELEMENT-2023-2031

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C I T Y O F S A N M A T E O 2 0 31 H O U S I N G E L E M E N T Appendix H-F

ADDITIONAL COMMUNITY OUTREACH COLLATERAL AND ACTIVITIES

THIS SECTION WAS ADDED TO THIS APPENDIX FOLLOWING THE DRAFT HOUSING ELEMENT SUBMITTED TO HCD IN JULY 2022.

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CITY OF SAN MATEO
The City of San Mateo must plan for thousands of new homes to prepare for future growth and your input is needed.

Join an upcoming workshop or take a quick survey to tell us what types of housing policies and programs you think would benefit the community.

Housing Policies
Virtual Workshop
Tuesday, Nov. 2, 2021 from 6-8 p.m.

More info at: www.cityofsanmateo.org/HousingElement2023 Take a quick survey!
Visit our web page or use your phone
camera to scan the QR code
¿Cómo se ve afectado por la falta de
viviendas asequibles en la Ciudad de San
Mateo? ¿Qué tipos de vivienda cree usted
que necesitamos más? ¡Estamos creando
un plan de vivienda a largo plazo y
queremos oir de usted!

Responda a una encuesta rápida o únase a
un taller en línea el
Martes, 2 de Noviembre de 2021.

Más información en:
“Why are our housing
prices so high, and what
can we do about it?”
“What types of
housing do we
need more of?”
“Where should new
housing be built?”

Contact the Housing Division:

[email protected]
(650) 522-7229

Learn about current affordable housing
and first-time home buyer programs at:
www.cityofsanmateo.org/Housing
www.cityofsanmateo.org/HousingElement2023
¡Tome una encuesta rápida!
Visite nuestra página web o use la cámara de su
teléfono para escanear el código QR

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City of San Mateo
Housing Plan

What can we do about the high cost of housing in San Mateo? How can we create housing that is more affordable while ensuring San Mateo is a great place to live? The City of San Mateo is working on its 8-year housing plan, also known as the Housing Element 2023-2031, that provides a roadmap to address housing needs of our community members.

Your input will help us prepare our Housing Element update, which will become part of the City’s General Plan. Please take a few minutes to share your thoughts. This information will remain confidential. THANK YOU!

WHAT IS YOUR RELATIONSHIP TO THE CITY OF SAN
MATEO? Select all that apply
___I live here
___I work here
___I own a business here
___I own property here
___I am a visitor or patronize San Mateo businesses
___I am a leader/representative of an organization

IF YOU LIVE IN SAN MATEO, WHAT IS YOUR ZIP CODE?
____________

WHAT IS YOUR RACE OR ETHNICITY?
___White
___Asian
___Latino/Hispanic
___Black/African American
___Pacific Islander
___Mixed or Other

WHAT IS YOUR AGE GROUP?
___0-20 years
___20-35 years
___35-50 years
___50-65 years
___65+ years

GIVEN THAT THERE IS LIMITED LAND AVAILABLE, WHAT DO

YOU THINK ARE BEST STRATEGIES TO MANAGE
PRODUCTION OF NEW HOUSING? Please select up to three
___Redeveloping existing properties that have potential for more housing.
___Create accessory units on existing single-family properties. ___Convert existing single-family houses into duplexes. ___Increase the allowable density in areas that are close to transit.
___Allow taller developments.
___Other (please describe)_____________________________ ___________________________________________________

HOW DOES THE CURRENT HOUSING SITUATION IN SAN
MATEO AFFECT YOU OR PEOPLE YOU KNOW?
____________________________________________________
____________________________________________________
____________________________________________________
____________________________________________________
____________________________________________________

HOW CAN WE MAKE HOUSING MORE AFFORDABLE?
Please select up to three

___Financial assistance programs for people who cannot afford housing.
___Public funding to construct affordable housing.
___Encourage the private sector to construct more affordable housing.
___Encourage conversion of single-family units to duplexes. ___Help homeowners add rentable units (ADUs).
___Build affordable housing near transit and jobs.
___Help homeless people find housing.
___Other (please describe)___________________________
_________________________________________________

ARE THERE ANY OTHER THOUGHTS ABOUT HOUSING
YOU WOULD LIKE TO SHARE? _______________________
___________________________________________________
___________________________________________________
___________________________________________________
____________________________________________________

MORE INFORMATION ABOUT HOUSING IN SAN MATEO:
www.cityofsanmateo.org/HousingElement2023

WOULD YOU LIKE TO JOIN OUR MAILING LIST TO KEEP
CURRENT ON EVENTS?
Email address:_______________________________________

Version November 17, 2021

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City of San Mateo
Plan de Vivienda

¿Qué podemos hacer con el alto costo de la vivienda en San Mateo? ¿Cómo podemos crear viviendas que sean más asequibles y al mismo tiempo garantizar que San Mateo sea un gran lugar para vivir? La Ciudad de San Mateo está trabajando en su plan de vivienda de 8 años, también conocido como Elemento de Vivienda 2023-2031, que proporciona un camino para abordar las necesidades de vivienda de los miembros de nuestra comunidad.

Su opinión nos ayudará a preparar nuestra actualización del Elemento de Vivienda, que se convertirá en parte del Plan General de la Ciudad. Le pedimos de favor que tome unos minutos para compartir lo que piensa. Esta información se mantendrá confidencial. ¡GRACIAS!

¿CUAL ES SU RELACION CON LA CIUDAD DE SAN MATEO?
Seleccione todas las que apliquen
___ Aquí vivo
___ Aquí trabajo
___ Soy propietario de un negocio aquí
___ Soy propietario de una casa aquí
___ Soy visitante o patrocino negocios de San Mateo
___ Soy un líder/representante de una organización

SI USTED VIVE EN SAN MATEO, ¿CUÁL ES SU CÓDIGO
POSTAL? ____________

¿CUÁL ES SU RAZA O ETNICIDAD?
___Blanco
___Asiático
___Latino/Hispano
___Negro/Afroamericano
___Nativo de Hawái o de otras islas del Pacífico
___2 o más razas u Otro

¿CUÁL ES SU GRUPO DE EDAD?
___0-20 Años
___20-35 Años
___35-50 Años
___50-65 Años
___65+ Años

DADO QUE HAY POCOS TERRENOS DISPONIBLES, ¿CUÁLES
ESTRATEGIAS PRODUCIRÍAN MÁS VIVIENDAS NUEVAS?
Seleccione hasta tres
___Reconstruir propiedades existentes con más viviendas. ___ Crear casitas adicionales en terrenos de casas individuales. ___ Convertir casas individuales en dúplex.
___ Aumentar la cantidad de viviendas permitidas en áreas cercanas a transporte público.
___ Permitir edificios más altos
___Otro (Describa)_____________________________________ ____________________________________________________

¿CÓMO LE AFECTA A USTED O A LAS PERSONAS QUE
CONOCE LA SITUACIÓN ACTUAL DE LA VIVIENDA EN SAN
MATEO?
_____________________________________________________
_____________________________________________________
_____________________________________________________
_____________________________________________________
_____________________________________________________

¿COMO PODEMOS HACER QUE LAS VIVIENDAS SEAN MAS
ECONÓMICAS? Seleccione hasta tres

___Asistencia financiera para personas que no pueden pagar vivienda.
___Financiamiento público para construir viviendas económicas. ___Fomentar que el sector privado construya viviendas
económicas.
___Fomentar la conversión de casas individuales a dúplex. ___Ayudar a los dueños de casas individuales a agregar casitas para alquilar en sus terrenos.
___Construir viviendas económicas cerca de transporte público y centros de trabajo.
___Ayudar a las personas sin hogar a encontrar vivienda. ___Otro (Describa) ___________________________________
____________________________________________________

¿TIENE ALGUNA OTRA IDEA SOBRE LA VIVIENDA QUE LE
GUSTARÍA COMPARTIR? ______________________________
_____________________________________________________
_____________________________________________________
_____________________________________________________

MAS INFORMACIÓN:
www.cityofsanmateo.org/HousingElement2023

¿LE GUSTARÍA UNIRSE A NUESTRA LISTA DE CORREO
PARA MANTENERSE AL DÍA SOBRE LOS EVENTOS?
Dirección de correo electrónico:___________________________

Version November 17, 2021

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Share Your Thoughts on Draft Housing Element

The City has released the Draft Housing Element, its plan for how the City of San Mateo can accommodate at least 7,000 new homes over the next 8 years. It establishes goals, policies and programs to help address the City’s current and future housing needs. The 30-day public review period is open from April 6 through May 6, 2022. The Draft Housing Element is available for public review at City Hall and online at
www.cityofsanmateo.org/HousingElement2023

Send written comments with subject line “Housing Element”  By email to: [email protected]
 By mail to: Planning Manager, City of San Mateo, Planning Division, 330 West 20th Avenue, San Mateo, CA 94403
 Online: on our Draft Housing Element website

Attend an upcoming public hearing:
 Planning Commission – Tuesday, April 26 at 7 p.m.
 City Council – Monday, May 16 at 7 p.m.

The plan is guided by over a year of technical analysis and community engagement efforts and articulates five goals to shape policy and programs moving forward:
 Production: Facilitate the production of new housing, especially affordable housing.  Preservation: Preserve existing housing that is affordable to lower- and middle-income residents.
 Protection: Protect current residents to prevent displacement.  Promotion: Promote community engagement and public outreach.  Fair Housing: Ensure fair housing laws proactively protect residents.

For more information on the Draft Housing Element and to make a comment, please visit our Draft Housing Element at
www.cityofsanmateo.org/HousingElement2023

San Mateo is also updating its General Plan, which will guide how the City will change over the next 20 years. Upcoming milestones include a City Council meeting to review the input received so far and provide direction on the preferred land use and circulation scenario. The meeting can be accessed online and is scheduled for 7:00 pm, April 18, 2022. More information at: strivesanmateo.org

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Comparta sus pensamientos sobre el plan preliminar de elemento de vivienda

La Ciudad ha publicado el Plan Preliminar del proyecto Elemento de Vivienda, el plan sobre cómo la Ciudad de San Mateo puede acomodar al menos 7,000 casas nuevas en los próximos 8 años. Establece metas, políticas y programas para ayudar a abordar las necesidades de vivienda actuales y futuras de la Ciudad. El período de revisión pública de 30 días está abierto del 6 de Abril al 6 de Mayo de 2022. El Proyecto de Elemento de Vivienda está disponible para revisión pública en el Ayuntamiento y en línea en
www.cityofsanmateo.org/HousingElement2023

Enviar comentarios escritos con la línea de asunto "Elemento de vivienda"  Por correo electrónico a: [email protected]
 Por correo a: Gerente de Planificación, Ciudad de San Mateo, División de Planificación, 330 West 20th Avenue, San Mateo, CA 94403
 En línea: en nuestro sitio web Draft Housing Element

Asista a una próxima audiencia pública:
 Comisión de Planificación – Martes, 26 de Abril a las 7 p.m.  El Consejo Municipal – Lunes, 16 de Mayo a las 7 p.m.

El plan está guiado por más de un año de análisis técnico y esfuerzos de participación comunitaria y articula cinco objetivos para dar forma a las políticas y programas en el futuro:
 Producción: Facilitar la producción de vivienda nueva, especialmente vivienda asequible.
 Preservación: Preservar la vivienda existente que sea asequible para los residentes de ingresos bajos y medios.
 Protección: Proteger a los residentes actuales para evitar el desplazamiento.  Promoción: Promover la participación de la comunidad y la divulgación pública.  Vivienda justa: Garantizar que las leyes de vivienda justa protejan proactivamente a los residentes.

Para obtener más información sobre el Proyecto de Elemento de Vivienda y cómo hacer un comentario, visite nuestro Borrador de Elemento de Vivienda en www.cityofsanmateo.org/HousingElement2023

San Mateo también está actualizando su Plan General, que guiará cómo cambiará la Ciudad en los próximos 20 años. Los próximos hitos incluyen una reunión del Concejo Municipal para revisar los aportes recibidos hasta ahora y proporcionar orientación sobre el escenario preferido de uso y circulación de la tierra. La Reunión es accesible en línea y está programada para las 7:00 pm del 18 de Abril de 2022.

Más información en: www.strivesanmateo.org

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Draft Housing Element: more information and make a comment at:

Proyecto Elemento de Vivienda: más información y hacer un comentario en:
www.cityofsanmateo.org/HousingElement2023

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Draft Housing Element: more information and make a comment at:

Proyecto Elemento de Vivienda: más información y hacer un comentario en:
www.cityofsanmateo.org/HousingElement2023

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APPENDIX G

PUBLIC REVIEW PERIOD

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CITY OF SAN MATEO 20 31 HOUSING ELEMENT
Appendix H-F
APPENDIX G | PUBLIC REVIEW PERIOD
Public Review Period
- 1st Public Review Period Commen ts Received – April 6, 2022 to May 6, 2022 - 2nd Public Review Period Comments Received – December 30, 2022 to January 9, 2023 - Comments Received Post 2nd Public Review Period - January 10, 2023 to present

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From:

To:

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

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

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

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

John Monfredini
Sent from my iPad
John Monfredini
​

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

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

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

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

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

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

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

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

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

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

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

Draft Housing Element Feedback Form

Please share your comments regarding the Draft Housing Element.

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

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

Email not displaying correctly? View it in your browser.

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 SharePoint  Search this library   LL
 New   Upload   Edit in grid view  Share  Copy link  Sync  Down  Name  Modified
Original (move here after redaction) April 7
Redacted April 7
4-6-22 Monfredini.msg April 6
4-6-22 Zane.msg April 7
Docum s on Draft HE
From: Housing <[email protected]> on behalf of Housing Sent on: Wednesday, April 6, 2022 10:45:22 PM
To: -
Subject: FW: Housing Element

From:

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

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

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

Maureen Zane
76 year old resident of San Mateo
 Share  Copy link  Download     4 / 4
  

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Subject: San Mateo’s Draft Sixth Cycle Housing Element
From:

To:
cc:

April 20, 2022
To whom it may concern:

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

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

Previously Identified Issues Still Outstanding
The following issues identified in our previous letter have not been addressed. ● On page H-6 of the draft, the ADU numbers are still overestimated. Pages H-33 through H-34 justify this by stating that “The State now allows jurisdictions to count projected development of accessory dwelling units (ADUs) based on prior years’ production averages”. However, the state specifically recommends counting trends since 2018, when ADU laws were liberalized. 4 The city does not provide sufficient explanation to justify exceeding the safe harbor estimates. 480 are estimated; past production justifies an estimate of 344.
● On the same page, the nominal capacity of about 10.9k remains unrealistic. As shown in our February letter, previous production trends indicate a realistic capacity of only 908 units, far short of the realistic capacity needed to achieve the City’s RHNA floor of 7,015 units.
4 Housing Element Site Inventory Guidebook,
https://www.hcd.ca.gov/community-development/housing-element/housing-element-memos/docs/sites_in ventory_memo_final06102020.pdf , page 31.
3 https://www.hcd.ca.gov/community-development/building-blocks/index.shtml 2 https://www.cityofsanmateo.org/DocumentCenter/View/87035/Additional-Correspondence-as-of-2-11-22 , pages 1-10.
1 https://www.cityofsanmateo.org/DocumentCenter/View/87532/San-Mateo-2023-2031-Housing-Element-- -DRAFT

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● On page H-28, the city continues to incorrectly average residential project densities by project , failing to account for differences in project acreage. The expected density should be 43 du/ac, not 60 du/ac.
● On pages H-28 through H-31, the city uses the same incorrect averaging method for mixed-use developments, on a variety of levels. The expected density of mixed-use projects should be 29 du/ac, not 48 du/ac. (Excluding projects already on the Adequate Sites List, expected density is an alarmingly low 1.7 du/ac!) ● On pages H-40 through H-41, the city makes no mention of surveying property owners to determine whether or not they plan to redevelop their properties.

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

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

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

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

Support the production of more missing middle housing. (Policies H1.4, H1.11 and H1.13 )
Policy H1.4 (page H-59) concerns ADU development, policy H1.11 (page H-60) is to adopt an SB 9 ordinance (which would merely adhere to state law), and policy H1.13’s targets (same page) read:
6 https://www.cityofsanmateo.org/4004/Monte-Diablo-North-Kingston-SPAR 5 https://www.cityofsanmateo.org/DocumentCenter/View/87528/APPENDIX-C---Housing-Resources

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Evaluate sites that have potential for Missing Middle development. Research and evaluate policies and code amendments to allow for Missing Middle housing under SB 10 and schedule for City Council consideration.

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

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

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

Air Quality Issues
The California Air Resources Board has published an Air Quality and Land Use Handbook 11 that considers the risks of poor air quality on sensitive receptors such as homes, daycares, etc, and 11 https://ww3.arb.ca.gov/ch/handbook.pdf
10 https://missingmiddlehousing.com/types/townhouse#idealized 9 https://missingmiddlehousing.com/types/duplex-stacked#idealized 8 https://sanmateo.ca.us.open.law/us/ca/cities/san-mateo/code/27.20 (All zoning laws evaluated as of April 10, 2022.)
7 https://missingmiddlehousing.com/types/duplex-side-by-side#idealized

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recommends against locating these uses within five hundred feet of a roadway that averages in excess of 100,000 vehicles/day. This standard was cited by the City at least once, as background 12 for a General Plan update in 2009. As far back as 2001, the City identified 13 Highway 92 (east of Delaware) and Highway 101, as routes exceeding this threshold. Current Caltrans data 14 shows that Highway 92 east of El Camino exceeds 100,000 vehicles per day.

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

Address APN Total Units Affordable Units
1900 S. Norfolk St 035-391-090 245 99
2000 Winward Dr 035-610-030 160 24
1820 Gateway Drive 035-443-030 177 72
1800 Gateway Drive 035-430-060
1850 NORFOLK ST 035-381-020 332 134
1826 NORFOLK ST 035-381-030
19 KINGSTON ST 033-191-040 59 24
25 KINGSTON ST 033-191-060
3 KINGSTON ST 033-191-070
1017 3RD AVE 033-134-100 32 13
1015 3RD AVE 033-134-110
245 HUMBOLDT ST 033-134-240
1900 FASHION ISLAND 035-466-060 461 186
2260 BRIDGEPOINTE PKWY 035-466-070 97 39
2270 BRIDGEPOINTE PKWY 035-466-080 42 17
15 https://dot.ca.gov/programs/traffic-operations/census/traffic-volumes/2017/route-101 14 https://dot.ca.gov/programs/traffic-operations/census/traffic-volumes/2017/route-92-98 13 https://www.cityofsanmateo.org/DocumentCenter/View/5126/7-Mobility-and-Access 12 https://www.cityofsanmateo.org/DocumentCenter/View/5229/Appendix-C-Air-Quality-Analysis

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3012 BRIDGEPOINTE PKWY 035-466-090 82 33
[NO ADDRESS] 035-466-110 89 36
1863 NORFOLK ST 035-383-200 105 53
1670 AMPHLETT BLVD 035-241-240 173 71
1700 AMPHLETT BLVD 035-241-250 122 49
1720 AMPHLETT BLVD 035-241-260 138 56
145 Kingston 033-171-040 35 0
139 Kingston 033-171-050
131 Kingston 033-171-060
1218 Monte Diablo 033-171-180
480 N Bayshore Blvd 033-081-280 47 19
Evidence On Specific Sites
Hillsdale Mall
Hillsdale Mall (41 Hillsdale Boulevard) is identified in the Site Inventory as a 39.91 acre parcel with potential for a total 1,995 units, 808 of which are affordable (40.5%). HCD’s Housing Element Sites Inventory Guidebook states that sites larger than 10 acres cannot be considered feasible for affordable housing without one of the following factors 16 :
a) an analysis demonstrating that sites of equivalent size were successfully developed during the prior planning period with an equivalent number of lower income housing units as projected for the site, or
b) evidence that the site is adequate to accommodate lower income housing such as developer interest, proposed specific-plan development, potential for subdivision, the jurisdiction’s role or track record in facilitating lot splits, or other information that can demonstrate feasibility of the site for development. The housing element should include programs promoting, incentivizing, and supporting lot splits and/or large lot development, or
c) a development affordable to lower income households has been proposed and approved for development on the site.

San Mateo’s Housing Element states on page H-31 that “The City has a demonstrated track record of large site development, typically completed in phases, that includes affordable 16 Housing Element Site Inventory Guidebook, page 17.

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

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

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

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

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

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

Therefore, this 11-acre portion should be excluded from the site inventory. When the overall site is thus reduced by 27%, the affordable unit count would proportionally drop - from a realistic 67 units delivered in the next cycle down to 49.
1900 S. Norfolk St
The City’s inventory describes this as a 1983 Class-B office building, and assigns it 245 units over 8.18 acres at 30 units per acre (including 99 affordable units). However, a cursory review 19 Site Inventory Guidebook, page 25.
18 https://pe-insights.com/news/2022/01/05/northwood-investors-paid-257m-to-purchase-an-interest-in-ma ll-asset/
17 Compiled City data through 2020, RHNA annual reporting

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of the assessor’s map reveals that the site is a “U” shape, wrapping around a PG&E substation with another corner carved off. This unconventional shape will reduce its effective density.

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

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

Please address the issues raised our original letter in order to identify enough sites and commit to an appropriate program of rezoning and constraint removal in a manner that is consistent with 21 https://www.cafishgrill.com/pages/san-mateo
20 https://www.smdailyjournal.com/news/local/lazy-dog-restaurant-opening-in-san-mateo/article_7a53bf46- 9b7a-11ec-9577-33f27fd5aefd.html

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your duty to affirmatively further fair housing and such that the actual capacity of the Sites Inventory over the next eight years meets or exceeds your RHNA.

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

Campaign for Fair Housing Elements

Peninsula for Everyone

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1 From: Housing
Sent: Friday, April 22, 2022 9:02 AM
To:

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

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

Draft 2023-2031 Housing Element Comment Form

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

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

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

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

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

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

Draft 2023-2031 Housing Element Comment Form

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

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

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

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

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

Diverse population. The downtown is a rare walkable gem.

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

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

There’s simply not much available within budget on Redfin. I’m deeply worried that the city is becoming too exclusive and rich so I started followin
g the city planning meetings. The new

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2 general plan is very encouraging and I hope we all work together to keep the momentum.

My thoughts on the housing elements:

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

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

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

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

Regards,
Kai

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sierraclub.org/loma-prieta ~

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

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

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

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

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

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

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

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

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

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

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

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

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

3 Jobs/Housing Fit: Jobs/housing fit means that the majority of homes within the city are affordable to the majority of employees who work in the city, and conversely, the jobs in the city pay enough to cover the cost of housing in the city. Without an adequate jobs/housing fit, businesses find it difficult to hire and retain lower-income employees.
4 Page H-43

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a. H 1.6 - Streamline Housing Application Review
b. H 1.8 - Adopt Objective Design Standards
c. H 1.9 - Create Minimum Densities for Mixed-Use Residential Projects d. H 1.10 - Establish By-Right Housing Designation for Prior Housing Sites e. H 1.12 - Encourage Residential Uses within Housing Overlay

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

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

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

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

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

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

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

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

Respectfully submitted,

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

Cc: James Eggers
Executive Director
Loma Prieta Chapter Sierra Club

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

8 Ocean Protection Council- Sea Level Rise Guidance: The rate at which sea levels will rise can help inform the planning and implementation timelines of state and local adaptation efforts. Understanding the speed at which sea level is rising can provide context for planning decisions and establish thresholds for action… https://opc.ca.gov/webmaster/ftp/pdf/agenda_items/20180314/Item3_Exhibit-A_OPC_SLR_Guidance-rd3.pdf

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1 From: Housing
Sent: Wednesday, April 27, 2022 9:17 AM
To:

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

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

Draft 2023-2031 Housing Element Comment Form

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

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

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

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

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

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

Draft 2023-2031 Housing Element Comment Form

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

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

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

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

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

Administrative Tech| Hous
ing
330 W. 20th Ave., San Mateo, CA 94403
650‐522‐7239|

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

Draft 2023-2031 Housing Element Comment Form

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

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

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

I want to show my support for a Housing Element that respects the single family home neighborhoods in the the City of San Mateo. As a long time resident and voter, the collected voice

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

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1 From:

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

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

Mary

Begin forwarded message:

From:

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

Subject: FW: Planning Commission Regular Meeting

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

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

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

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

Sad to see what the city council of San Mateo has turned into what it has done to divide our city into sections based on race and wealth. The racial undertones of comments by the city council, contributors and consultants are enough to anger many residents who have lived in and contributed much more to

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2 this city than all of you. Stop ruining San Mateo, you had no part in creating or developing this city to what it is today.

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

Chris Conway
San Mateo, Ca.

1145 of 1732

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

Subject: FW: Housing Element Comment

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

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

Thank you,

Thomas Morgan

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

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

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

Draft 2023-2031 Housing Element Comment Form

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

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

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

None of us knows what the future will bring.

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

California population is decreasing.

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

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

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

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1147 of 1732

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

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

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

Draft 2023-2031 Housing Element Comment Form

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

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

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

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

Building on Campus Drive sounds like a nightmare to me, because public transportation is currently miserable in that area, and the 92/West Hillsdale interchan
ge can be horrific

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2 traffic-wise. If building must be done there, then the public transportation issue ALSO has to be addressed.

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1149 of 1732

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

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

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

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

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

Thank you,

We have moved! Please note the new office address!
This e-mail message is intended only for the named recipient(s) above and is covered by the Electronic Communications Privacy Act 18 U.S.C. Section 2510-2521. This e-mail is confidential and may contain information that is privileged or exempt from disclosure under applicable law. If you have received this message in error please immediately notify the sender by return e-mail and delete this e-mail message from your computer.

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May 6, 2022
Planning Manager and City Council
City of San Mateo, Planning Division
330 West 20th Avenue
San Mateo, CA 94403
[email protected]
Re: Comments on the Draft Housing Element
Thank you for sharing this early draft of the Housing Element with the public. On behalf of San Mateo’s more than 800 residents with intellectual and developmental disabilities, Housing Choices is grateful for the opportunity to comment before it is sent to HCD. We also appreciate the work that the City of San Mateo has done to engage with Housing Choices throughout the community engagement process and consider the programs and policies that we have recommended as best practices for inclusion of people of all abilities in the city’s future housing plans. However, we have concerns that the assessment of the housing needs of the San Mateo population with developmental disabilities in the draft Housing Element is very superficial and does not provide enough analysis to support meaningful inclusion of people with developmental disabilities in the city’s housing plans. We also ask that the city immediately update the obsolete and derogatory language used to describe developmental disabilities as including mild to severe “mental retardation” on page H-A-55 of Appendix A-Needs Analysis and instead use the standard term “intellectual disability”.

About Housing Choices
Housing Choices is a housing organization funded by the Golden Gate Regional Center to support people with developmental disabilities to be fully integrated in San Mateo’s affordable housing supply. We provide housing navigation services for both individuals and families. We also partner with affordable housing developers to make inclusive housing commitments for people with disabilities in their housing projects. At these projects we provide onsite housing retention services. A San Mateo example of this highly successful model is the new Kiku Crossing where 8 of the 225 units will include a preference for people with developmental disabilities who will benefit from Housing Choices’ coordinated supportive services funded by the Golden Gate Regional Center. The Golden Gate Regional Center has contracted with 1 1151 of 1732

Housing Choices to provide the San Mateo planning staff and Housing Element consultants with an assessment of the housing needs of people with developmental disabilities, as required by SB 812. In addition, 21 Elements has facilitated Housing Choices’ involvement of people with developmental disabilities in the planning process through its Equity Advisory Group.

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

As discussed below, San Mateo’s draft does not incorporate any of the Housing Choices’ data and analysis, does not meaningfully discuss the potential housing problems, unmet needs or best practices for inclusion of people with developmental disabilities in integrated and least restrictive housing settings in the community. We believe that the inclusion of these missing elements would demonstrate that the city has a clear understanding of the accessibility needs of people with developmental disabilities and how they differ from other disability types.

Furthermore it would help the city to create more meaningful programs and policies to meet the housing needs of residents with developmental disabilities as required by Housing Element law.

Underestimation of the San Mateo Population with Developmental Disabilities The draft analysis undercounts the population of San Mateo residents with developmental disabilities by using outdated demographic data reported by the Department of Developmental Services (DDS) as of 2020 rather than the more current data from DDS as of September 2021 provided in Housing Choices comments. On page H-A-56 of Appendix A- Needs Analysis, Table 12 states that there are 500 individuals age 18+ and 277 individuals under age 18 with developmental disabilities living in San Mateo based on Department of Developmental Services 2020 data of consumer counts by zip code for a total of 777 San Mateo residents with developmental disabilities. However, based on data reported by DDS by zip code as of September 2021 for zip codes 94401, 94402 and 94403 (provided to us by the City of San Mateo planning staff) there were 531 individuals age 18+and 304 individuals under age 18 with developmental disabilities living in San Mateo for a total of 835 San Mateo residents with 2 1152 of 1732

developmental disabilities. This represents an increase of 58 total residents or 7% of the population.

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

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

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

Other data which Housing Choices’ comments reported on which are vital to an understanding of the barriers to housing access for this special needs population that were omitted from the Housing Element analysis are:

1. Continuing increases in the diagnosis of autism affecting growth of the population of San Mateo residents with developmental disabilities (21% increase from 2013-2021) beyond that of the general population (6% increase from 2010-2020)

2. Decreases in age groups 42-61 despite increases in all other age groups including 62+ which Housing Choices attributes to greater risk of displacement from the home 3 1153 of 1732

community among this age group upon the death or infirmity of the parent who was providing housing
Lack of Meaningful Analysis of Strategies to Increase Housing Access for People with Developmental Disabilities
The Housing Element acknowledges the significance of the transition from the family home for an adult with a developmental disability including the increased risk of displacement or homelessness when a parent caregiver passes away or becomes unable to house and care for the adult. There are also basic descriptions of the alternative housing options available to people with developmental disabilities including:
● Living independently in conventional housing
● Group living (including different levels of care and support) However, there is no further analysis of the housing needs of people with developmental disabilities beyond a single sentence on page H-A-55 which states “Some people with developmental disabilities are unable to work, rely on Supplemental Security Income and live with family members. By not including information, provided by Housing Choices, on best practices for inclusion of people with developmental disabilities in conventional affordable housing, the city is unable to create meaningful strategies to increase housing accessibility for this population needed to decrease the risk of displacement or homelessness when their family home is no longer an option. These best practices to increase accessibility include:
● Integration in typical affordable housing in order to affirmatively further fair housing for a group that has historically experienced no alternatives to segregated living and to counter the loss of supply of licensed care facilities
● Coordination of housing with onsite supportive services funded by the Golden Gate Regional Center should be encouraged. These fully funded coordinated services are often as essential to a person with a developmental disability as a physically modified unit is to a person with a mobility, vision, or hearing impairment and provide a supported pathway for people with developmental disabilities to apply for and retain an affordable apartment
● A mix of unit sizes set-aside at inclusive housing properties would address the needs of those who require live-in aides, want to live with roommates or partners, or have children.
● Location near public transit would accommodate the transit-dependency of most adults with developmental disabilities.
● Deeply affordable housing is needed, targeting incomes not more than 30% of Area Median Income and taking advantage of Housing Authority Project Based Vouchers or HUD 811 Project Rental Assistance when available to create housing opportunities for those who cannot meet minimum income requirements for units priced at 30% of Area Median Income.
4 1154 of 1732

‘Without this complete analysis of the housing needs of people with developmental disabilities any programs or policies aimed at increasing “accessible units” will be discriminatory in nature as they apply only to people with physical disabilities needing physically modified units and not to people of other abilities who may require services to increase housing access. This is most evident on page H-A-54 of Appendix A where accessible units are defined as designed to “offers greater mobility and opportunity for independence” but makes no mention of the supportive services needed by people with other types of disabilities including developmental and mental health disorders. This model of housing combined with supportive services has been shown to be incredibly effective in helping individuals with developmental disabilities find and retain housing, and is equally as important to a person with a developmental disability as the physical design of a building is to a person with a physical disability. This also puts the city at risk of not meeting HCD’s AFFH guidance to promote fair housing choice and access to opportunity to support integration for a historically segregated population. Per HCD guidance, “For persons with disabilities, fair housing choice and access to opportunity include access to accessible housing and housing in the most integrated setting appropriate to an individual’s needs as required under federal civil rights law, including equitably provided disability-related services that an individual needs to live in such housing.” HCD defines fair housing choice as:
● Actual choice, which means the existence of realistic housing options ● Protected choice, which means housing that can be accessed without discrimination; and
● Enabled choice, which means realistic access to sufficient information regarding options so that any choice is informed.

Need to Clarify How Programs and Policies Will Increase Housing Access For People with Developmental Disabilities
We want to thank planning staff and the consultant who developed this draft for acknowledging the need for affordable housing to increase housing access for people with disabilities. This is especially important for those whose sole source of income is from disability benefits such as Supplemental Security Income, which in 2022 has a maximum monthly payment of $1,040, well below minimum income requirements for even the Extremely Low Income housing (30% of AMI) available in San Mateo. The lack of housing priced to be affordable to people of Extremely Low Income does not only affect people with disabilities. According to the draft Housing Element,

12.7% of all San Mateo households fall under the Extremely Low Income limits which represents the second largest lower income group in the city, exceeded only by Low Income households. And Figure 13 on page H-A-25 of Appendix A- Needs Analysis shows that Extremely Low Income renters are the second largest proportion of San Mateo Renters exceeded only by Above Moderate Income.

According to the HCD’s APR dashboard between 2015-2020 San Mateo met less than 15% of its Very Low Income RHNA target (of which half are supposed to ELI). In order to address this shortfall, the 2023-2031 draft housing element identified Policy 5.2.3: “Prioritize city funding proposals for city funded affordable housing that are committed to serving hard to serve residents (e.g., extremely low income, special needs, on site services)”. We strongly encourage 5 1155 of 1732

the city to go further in its commitment to meeting the need for more units of Extremely Low Income housing by including proposals for city-owned land and land dedicated to affordable housing under the inclusionary program to this Policy.

Secondly, people with developmental disabilities not only need deeply affordable housing, they also need housing that is coordinated with onsite supportive services funded by the Golden Gate Regional Center. In order to specifically address the housing needs of people with developmental disabilities, San Mateo must clarify their definition of accessible/visitable units as referenced in Policies 5.1.1 and most importantly 5.2.2 Incentivize developers through direct subsidies, fee waivers, and/or density bonuses, to increase accessibility requirements beyond the federal requirement of 5% for subsidized developments. Currently, federal accessibility requirements only address the housing needs of people with physical disabilities. Housing Choices is extremely supportive of Policy 5.2.2 but asks that the city include incentivizing inclusion of units set aside for people with developmental disabilities who will benefit from coordinated on-site supportive services funded by the Golden Gate Regional Center to help them stay stably housed so that we do not continue to see decreases in the number of adults able to transition into their own apartment.

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

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

Reporting of data from the assessment also does not clearly show demographics of who was surveyed to show the number of residents from special needs groups that are most likely to face 6 1156 of 1732

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

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

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

Sincerely,
Kalisha Webster
Senior Housing Advocate
Email
Cell
7 1157 of 1732

DEVELOPMENTAL DISABILITIES SUBMISSION FOR

CITY OF SAN MATEO HOUSING ELEMENT
Introduction to Developmental Disabilities
People with developmental disabilities have a disability that emerged before age 18, is expected to be lifelong, and is of sufficient severity to require a coordinated program of services and support in order to live successfully in the community. Developmental disabilities include intellectual disability, autism, Down syndrome, epilepsy, cerebral palsy, and other disabling conditions similar in their functional impact to an intellectual disability. Under California’s Developmental Disabilities Services Act and the U.S.

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

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

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

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

Of the City’s total population with developmental disabilities, 531 (64%) are adults and 304 (36%) are 1 1158 of 1732

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

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

Increase of Autism Diagnosis Reflected in Increase in Adults in their 20s and 30s. Growth in the City of San Mateo’s population with developmental disabilities since the 2015 Housing Element correlates with a significant annual increase in the diagnosis of autism that began in the mid-1980s and did not level out until after 2015. The cumulative impact of this trend is already seen in the growth in the San Mateo County population age 18 to 41 with developmental disabilities and will continue into the future. This trend has significant implications for housing needs among City of San Mateo adults with developmental disabilities during the period of the 2023 to 2031 Housing Element. 2 1159 of 1732

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

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

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

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

Displacement. The California Department of Developmental Services has documented a 12% decline in the age group 42 to 51 and a 10% decline in the age group 52 to 61 in San Mateo County between September 2015 and June 2021. (Table __). In light of gains in life expectancy, this loss can reasonably be attributed to homelessness or displacement from the county because of the lack of residential living options (either licensed facilities or affordable housing) when an elderly parent caregiver passes away or becomes unable to house and care for the adult. Displacement takes a particular toll on adults with 3 1160 of 1732

developmental disabilities who depend on familiarity with transit routes and shopping and services, as well as support from community-based services and informal networks built up over years in living in the City of San Mateo.

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

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

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

Best Practices for Inclusion of People with Developmental Disabilities in Typical Affordable Housing
As demonstrated by a growing number of inclusive affordable housing developments in neighboring jurisdictions, the City of San Mateo can meet the housing needs of people with developmental disabilities by adopting policies and programs to promote their inclusion with coordinated services in typical affordable housing. The following considerations should guide the City of San Mateo in this pursuit:
● Integration in typical affordable housing is a priority in order to affirmatively further fair housing for a group that has historically experienced no alternatives to segregated living and also to counter the displacement of adults with developmental disabilities out of San Mateo County. ● Coordination of housing with onsite supportive services funded by the Golden Gate Regional Center should be encouraged. These fully funded coordinated services provide a supported pathway for people with developmental disabilities to apply for and retain an affordable apartment and are often as essential to a person with a developmental disability as a physically modified unit is to a person with a mobility, vision, or hearing impairment. ● A mix of unit sizes at inclusive housing properties would address the needs of those who require live-in aides, want to live with roommates or partners, or have children. ● Location near public transit would accommodate the transit-dependency of most adults with developmental disabilities.
● Deeply affordable housing is needed, targeting incomes not more than 30% of Area Median Income and taking advantage of Housing Authority Project Based Vouchers or HUD 811 Project 4 1161 of 1732

Rental Assistance when available to create housing opportunities for those who cannot meet minimum income requirements for units priced at 30% of Area Median Income.

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

Sample Language: The City of San Mateo shall monitor progress towards a quantitative goal of 150 new Extremely Low Income housing units that are subject to a preference for people with developmental disabilities needing the coordinated services provided by Golden Gate Regional Center to live inclusively in affordable housing.
● Target City-Owned Land, Land Dedicated to Affordable Housing under the Inclusionary Ordinance and City Housing Funds to Meet City-Specific Priorities. City-owned land, land dedicated to affordable housing in lieu of providing affordable units under the inclusionary ordinance, and city housing funds are often essential to the development of affordable housing that is financially feasible in high-cost City of San Mateo. In creating guidelines for the scoring of any competitive requests for proposals for these scarce resources, the City should grant additional points to affordable housing projects that address the housing needs of City of San Mateo residents who are most difficult to house under existing state and federal housing finance programs--for example, by prioritizing proposals with a higher number of extremely low income units or that make a percentage of units subject to a preference for identified categories of special needs people who would benefit from coordinated onsite services, including but not limited to people with developmental disabilities who benefit from services of the Golden Gate Regional Center.
5 1162 of 1732

Sample Language: In publishing requests for competitive proposals for any city-owned land, land dedicated to affordable housing under the city’s inclusionary ordinance or city housing funds, the City of San Mateo shall grant additional points to proposals that address the city’s most difficult to achieve housing priorities, by, for example, providing a greater number of extremely low-income units or committing to make a percentage of the units subject to a preference for people with special needs who will benefit from coordinated onsite services, such as people with developmental disabilities who receive services from the Golden Gate Regional Center. ● Offer Developers a Range of Affordability Options Under the Inclusionary Ordinance. Most adults with developmental disabilities have incomes too low to satisfy minimum income requirements for the Low Income units currently offered under the city’s inclusionary ordinance and are effectively excluded from this housing option. California law (AB 1505, the “Palmer Fix”) explicitly allows cities to adopt inclusionary housing ordinances that address a range of income levels from moderate-income to extremely low-income. The City should take advantage of this authority to make its ordinance more responsive to local needs by offering developers of market rate housing a menu of options for including affordable units, for example, by setting a higher percentage of units priced at moderate income and a lower percentage of units set at extremely low income. Such a menu would address a broader range of City of San Mateo housing needs, while giving developers more options for meeting the inclusionary requirement.

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

Sample Language: The City shall encourage the inclusion of people with developmental and other disabilities in affordable housing by recognizing their transit dependence and establishing lower parking ratios for units targeted to people with developmental and other disabilities than would otherwise be required for affordable housing.
● Local Density Bonus Concessions. The state density bonus law currently provides additional density for housing projects that include at least 10% of the units for disabled veterans, transition-age foster youth, and homeless persons at the very low income level. Above and beyond the density bonus guidelines mandated by state law, the City should add the same incentives when at least 10% of the units are subject to preference for people with 6 1163 of 1732

developmental disabilities who will benefit from coordinated onsite services provided by the Golden Gate Regional Center.

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

Affirmative Marketing of Physically Accessible Units: Developers are allowed to affirmatively market accessible units to disability-serving organizations in San Mateo County (i.e. Golden Gate Regional Center, Housing Choices Coalition for Person with Developmental Disabilities, Center for Independence of Individuals with Disabilities and others) but rarely take this step.

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

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

Sample Language: Subject to funding availability, the City shall devise a program of financing for Accessory Dwelling Units subject to rent restrictions for at least 15 years at Extremely Low-Income rent levels to people with developmental disabilities who would benefit from coordinated housing support and other services provided by the Golden Gate Regional Center. ● Affirmatively Further Fair Housing. Not only is disability the highest-ranked source of Fair Housing complaints, a growing body of San Mateo County data indicates that Black, Indigenous and other People of Color (BIPOC) with disabilities experience higher rates of housing discrimination and severe rent burden than either BIPOC without disabilities or whites with disabilities. Currently the City of San Mateo offers its residents exceptional employment, educational and social opportunities but the severe shortfall of Extremely Low Income units means that BIPOC--particularly those with disabilities--are too often excluded from enjoying 7 1164 of 1732

those community assets. Multiple barriers including high land and construction costs and limited funding make it difficult for developers to produce Extremely Low Income units that will overcome such disparities. Policies that lead to increased production of Extremely Low Income units, as well as city staff dedicated to implementing and overseeing those policies, will Affirmatively Further Fair Housing in the City of San Mateo and decrease displacement and homelessnessness for the most at-risk City of San Mateo residents.

Sample Language: The City of San Mateo's plans to Affirmatively Further Fair Housing for Black, Indigenous and other People of Color, particularly those with disabilities, shall include policies designed to increase the production of Extremely Low Income units, as well as adequate staff capacity to implement and monitor the impact of these policies. 8 1165 of 1732

1 DEVELOPMENTAL DISABILITIES SUBMISSION FOR

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

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

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

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

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

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

Increase of Autism Diagnosis Reflected in Increase in Adults in their 20s and 30s. Growth in the City of San Mateo’s population with developmental disabilities since the 2015 Housing Element correlates with a significant annual increase in the diagnosis of autism that began in the mid-1980s and did not level out until after 2015. The cumulative impact of this trend is already seen in the growth in the San Mateo County population age 18 to 41 with developmental disabilities and will continue into the future. This

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

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

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

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

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

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

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

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

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

Best Practices for Inclusion of People with Developmental Disabilities in Typical Affordable Housing
As demonstrated by a growing number of inclusive affordable housing developments in neighboring jurisdictions, the City of San Mateo can meet the housing needs of people with developmental disabilities by adopting policies and programs to promote their inclusion with coordinated services in typical affordable housing. The following considerations should guide the City of San Mateo in this pursuit:
● Integration in typical affordable housing is a priority in order to affirmatively further fair housing for a group that has historically experienced no alternatives to segregated living and also to counter the displacement of adults with developmental disabilities out of San Mateo County.
● Coordination of housing with onsite supportive services funded by the Golden Gate Regional Center should be encouraged. These fully funded coordinated services provide a supported pathway for people with developmental disabilities to apply for and retain an affordable

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

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

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

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

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

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

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

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

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

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

Sample Language: The City shall encourage the inclusion of people with developmental and other disabilities in affordable housing by recognizing their transit dependence and establishing lower parking ratios for units targeted to people with developmental and other disabilities than would otherwise be required for affordable housing.

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

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

Affirmative Marketing of Physically Accessible Units: Developers are allowed to affirmatively market accessible units to disability-serving organizations in San Mateo County (i.e. Golden Gate Regional Center, Housing Choices Coalition for Person with Developmental Disabilities, Center for Independence of Individuals with Disabilities and others) but rarely take this step.

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

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

Sample Language: As a condition of the disposition of any city-owned land, land dedicated to affordable housing under the city’s inclusionary ordinance, the award of city financing, any density bonus concessions, or land use exceptions or waivers for any affordable housing project, the City shall require that the housing developer implement an affirmative marketing plan for physically accessible units which, among other measures, provides disability-serving organizations adequate prior notice of the availability of the accessible units and a process for supporting people with qualifying disabilities to apply.

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

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

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

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9 1174 of 1732

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

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

Subject: San Mateo Housing Element

May 4, 2022

Dear Mayor Bonilla and San Mateo City Council Members,

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

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

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

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

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

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

While much work has been done to create the current Housing Element, it falls short of state guidelines as well as the hopes and aspirations we should have for San Mateo. There is no reason why the burden of the housing crisis we face in our communities should continue to fall on low-income people and people of color,

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2 while the windfall benefits of increased home values accrue to a largely-white, wealthier part of our community.

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

Respectfully,

Jennifer Martinez
Resident, San Mateo

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1 From: Housing
Sent: Monday, May 9, 2022 8:30 AM
To:

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

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

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

Mike Heagerty

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All people deserve respect, justice and opportunity

April 29, 2022

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

RE: Draft Housing Element

To whom it may concern,

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

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

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

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

Sincerely,

Social Action Ministry
of St. Matthew Catholic Church

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All people deserve respect, justice and opportunity

Selected SAM members residing in San Mateo:

María del Carmen Muñoz

Anne A. Fariss

Michael Heagerty

John H. Love II

Vilma Sanchez

Susan Wilbur

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

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

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

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

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

Cc: Planning <planning@cityofsanmateo .org>; [email protected];

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

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

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

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

HOUSING NEEDS AND THE RISK OF DISPLACEMENT

Misleading metric. Preventing the displacement of existing residents is central to the fulfillment of AFFH, as is made clear by the AFFH guidance memo issued by HCD in April of 2021. As it currently stands, the needs analysis in the draft housing element contains metrics that seriously downplay the risk of displacement in San Mateo. One such metric appears as follows: “According to research from the University of California, Berkeley, 0.0% of households in San Mateo live in neighborhoods that are susceptible to or experiencing displacement ...” Regardless of the source, offering this as a meaningful metric of the displacement threat in San Mateo is extremely misleading. Elsewhere in the needs analysis, the northeast section of San Mateo, particularly the area south of Poplar Avenue, is said to be characterized by high poverty, concentrations of cost burdened households, and overcrowding. The existence of high levels of cost burden and overcrowding are clear predictors of

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2 displacement. Furthermore, the needs analysis reveals that the North Central and downtown neighborhoods are “At Risk of Becoming Exclusive” or “Becoming Exclusive.” Looming exclusion necessarily translates into a threat of displacement. Thus, we maintain that this 0.0% statistic taken from UC Berkeley only serves to cloud the gravity of the displacement threat and underplay the need for aggressive action to prevent it. The credibility of the analysis would be strengthened if this statistic were removed.

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

MISSING CONSTRAINTS

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

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

SITES INVENTORY AND R-1 ZONING

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

POLICIES, PROGRAMS AND AFFH

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

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

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

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

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

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

 Create new resources for emergency rental assistance.

 Investigate adoption of a Community Opportunity to Purchase Act.

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

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

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

Sincerely,

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4 Karyl Eldridge
Vice Chair of One San Mateo

*Wire Fraud is Real*.  Before wiring any money, call the intended recipient at a number you know is valid to confirm the instructions. Additionally, please note that the sender does not have authority to bind a party to a real estate contract via written or verbal communication.

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San Mateo Housing Element-Sandy’s notes
At Risk Units/Preservation
Humboldt House
Why is expiration of Humboldt House (2041!) included in this Housing Element? See Table 9 policy H2.2 (page H-62) and Table 12 H5.3.3 (page H-72). Perhaps this got carried over from prior HE which required agreement extension for that planning period (accomplished in 2021).

Table 13 page H-75 remove Humboldt House 9 units under Preservation Belmont Building
Section 3.3 page H-22 – the units were converted from commercial office to residential. Funds not used for acquisition, just construction. Although property is owned by private entity and loss of affordability is possible, owner has long participated in Section 8 voucher program, so it may or may not be a “high” risk situation.

Since this property expires in 2032, suggest adding a separate implementation date to work with owner.

Perhaps 2030-2031 instead of 2025-2026? See Table 9 policy H2.2 (page H-62) and Table 12 H5.3.3 (page H-72).

Appendix D Attachment 1
Quantified Objective- “Advertise Bridgepointe units going to sale” Seems unlikely to assume that Bridgepointe owner would sell off affordable units since this is one large rental project . Suggest something more general like negotiate with owner to “explore” selling units to non profit and/ or provide rental assistance to displaced tenants
Similar language for Belmont- could also add explore extension of participation in Section 8 program for that building. Update timeline.

Remove Humboldt House.

Funding Sources/Programs-
Section 3.3.3 (page H-24)
State: Can add PLHA
Local funds listed: San Mateo Aff Hsg Fund/Housing Innovation funds ( these are county programs, so add County to title). --I believe Innovation Fund was a one-time program and not available at this time- check with County staff
May want to add City funding sources as well.

Section 3.3.6 ( page H-38)
Include sources listed on page H-24
Other State programs that could be mentioned, since City has used them: Infill Infrastructure Grant (IIG), Local Housing Trust Fund (LHTF)

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Table 8 Policy 1.2 (page H-58) Target Column
Do you want to specify the “Talbots” parking lot project? ( Could include some milestones and number of units in the target and timeline columns.)
Table 10 Policy 3.1 (page H-64)- Target Column
Add qualifiers to list of programs (“as funds are available”, “for programs that have been funded in the past such as “ etc) City does not traditionally fund Vendome, and may or may not continue to fund HIP Housing. Montara is likely only for a couple of years. Rapid ReHousing may or may not continue to get funding if other priorities are identified for future PLHA. This is an 8 year plan and these things can change on an annual basis.

Appendix C Housing Resources Pages HC-6-7:

Section 2.2.2 -could add other State programs as mentioned above Section 2.3 Suggest adding County AFH Funds--City has relied on them extensively over the past several years.

Section 2.3.1 Former RDA funds include loan repayments from prior loans- this is the source of the $2.85M for Kiku with 250K balance as described. Seems odd to mention this small fund balance, since it is projected to grow over the HE time period ( I did revenue projections on the spreadsheet that summarizes Quantified Objectives.) especially since the other larger sources of funding are not quantified.

The $706K plus 20% annual contribution ( collectively called “boomerang funds- total over $5M ) are still available to spend. Maybe just keep this simple and leave dollar amounts out entirely. Or, go all in ,and list projected resources for all local City housing funds for the entire HE period.

Section 2.3.2 BMR program is not the name of the “fund”. It is referred to as “City Housing Fund”, which includes fractional BMR fees, as well as other misc housing revenues ( fees collected for subordination processing, loan payoffs from old First time buyer program, etc). Also City Housing Fund is mentioned specifically in Section 3.11 (page HC10) and 3.11.2 ( p HC 11), so it would be good to be consistent.

Section 2.3.3 The Commercial Linkage fees mentioned are adjusted each year using construction cost index. These are out of date already! Seems too detailed to include specific fee.

Section 2.4.4. HEART Down payment program income requirements are out of date- they change from time to time as median income changes. Also don’t think it is called Opening Doors anymore- check website for info.

Appendix C Housing Programs pages HC 9-12
Section 3.5 Acquisition of Land
3rd sentence is incorrect. The two parcels comprise one surface parking lot- does not include the toy store building. Internally, we’ve always called it “Talbots parking lot”, since it is adjacent to Talbots (closed toy store and owned by private party).

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The last sentence refers to the other surface parking lot, which is next door to “Raviloli House”- it is not the site of the restaurant. ( again staff nick name). The City has owned this surface lot for years and years, so might be misleading to say City acquired it. The “Ravioli” and “Talbots” parking lots are not adjacent to each other, but are about a block away from each other. Also correct Appendix E 4.6 pageHE10.

Section 3.11.1 Life Moves
The “annual CDBG funding” for First Step is relatively recent (2020) and not guaranteed since these funds are competitive. It would be awkward to infer this is a done deal for the future given its short history of funding. Could say “ City has provided operational funds in the past and may continue based on available funds”
Also Vendome is not a shelter. Perhaps say they have two properties in San Mateo, the First Step shelter and permanent supportive housing at the Vendome.

Section 3.12.3 HIP Self Sufficiency
City has not funded Self Sufficiency Program for over 15 years- I would eliminate funding comment. (This is different that Home Sharing program)

3.13 HOT Team
The final sentence is out of date- eliminate.

3.14 Homeless Prevention. Second sentence is confusing.

Section 3.14.2 Legal Aid.

Again this funding is not guaranteed since they need to compete for funding. That said, the odds of this program to be funded continuously is more likely than other programs. Maybe say City “traditionally” funds this on annual basis.

Special Needs/Homeless
FYI: Shelter Overview
City has one emergency/transitional shelter -First Step for Families (Life Moves)—City provided extensive capital funding to develop property, but typically has not provided ongoing operating subsidy.

However, starting in 2020 Community Resource Commission awarded CDBG grants for operations (competitive process).

Vendome (Life Moves) Permanent supportive housing for formerly homeless. City provided 100% of acquisition/rehab costs for this property, but has not provided any annual operating subsidies, but does support their efforts to obtain HUD funds (PUSH) for operations through Continuum of Care process.

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Special Needs
Humboldt House (Mateo Lodge)- Permanent supportive housing for individuals with mental illness. ( not a shelter) City provided extensive funds for acq/rehab of apartment building formerly owned by private individual with County contracts to house mentally ill. City has never provided annual operating funds.

Delaware Pacific (Mid Pen)- City provided land/ subsidy to construct permanent affordable housing with 10 units set aside for households with mental health issues at risk of homelessness as referred by the County. City has never provided operating subsidies.

Montara ( BRDIGE) -City provided land and subsidy to construct permanent affordable housing with 12 units set aside for formerly homeless veterans and 4 other formerly homeless ( nonvets). Will provide operating funds for resident services for 4 years with PLHA funds.

Kiku ( Mid Pen) - City provided land and subsidy to construct permanent affordable housing with 8 units set aside for IDD, and 16 for formerly homeless

Appendix B Constraints

2.9.5 Emergency Shelters page H B 29 final paragraph- City has one shelter, First Step. Humboldt House and Vendome are not shelters.

2.9.7 Emergency Shelter Strategies page HB 30
Re-use of residential buildings. Humboldt House is not an example of this since it is not a shelter and not really re-use since it was always, and still is, an apartment building. ( It served as housing for the mentally ill by a private owner for many years prior to Mateo Lodge acquisition and rehab ) Perhaps this example can be moved above to “Special Needs”. Humboldt House serves the mentally ill, so conceivably could be considered Housing for persons with Disabilities. (2.9.1 ). Also, it serves more than 9 individuals since residents share units- Sandy B can provide the number of individuals who live there.

The info about the services it provides the residents is correct.

Partnership with Faith Based Organizations -FYI there is a program in existence that does this- Home and Hope, based in Burlingame. Many years ago , it received CDBG Community Funding for the congregations who provided sites in San Mateo.

Appendix D AFFH
Section 5.4 R/eCAP Page HD-23 final paragraph—“Edge” Recap language was supposed to be removed by consultant- it’s not required, and for SM is misleading for the CT by Belmont border-could pose AFFH problems for parcels on Sites List along southern stretch of ECR ( Mollie Stones, etc.). I thought they made the correction on the revised draft they sent us. Remove final paragraph entirely.

Check top of page HD -24- Seems like a dangling statement--not sure if it is describing R/ECAP or Edge R/ECAP.

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Appendix E Review of Prior Element
Section 2.4 page HE 3 ADU’s Maybe compare the success of 40-60 units now to the prior average of 2- 5/year to stress the success of revisions?
Section 2.7 Preserve Affordable page HE 5. The expiring agreements were negotiated with motivated non profit organizations, and frankly not much of an issue to achieve the affordability extensions. It is an overstatement that it involved “many meetings and prolonged” collaborative efforts. I would delete those describers and just say “ Through collaborative efforts between staff…….” Table A H2.3 page5/12 Item 3 Kiku- Construction commenced in Jan2022—correct estimated dates

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1 Manira Sandhir
From: Adam Nugent
Sent: Wednesday, April 27, 2022 9:56 PM
To: Manira Sandhir; Zachary Dahl
Cc: Eloiza Murillo-Garcia; [email protected]
Subject: San Mateo Planning Commission Input - Draft Housing Element - Apr 26 Attachments: Planning Commission Input - Draft Housing Element - Adam Nugent - April 26.pdf Hi Manira and Zach,

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

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

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

Best,
Adam

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

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Commissioner Adam Nugent, April 26, 2022 Planning Commission Meeting Commissioner Input
Draft 2023-2031 Housing Element
Draft for Public Review: Housing Element of the General Plan 2023-2031, April 6, 2022

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Outline
Draft 2023-2031 Housing Element Input
• Introduction and Thank You
• Part 1: Site Inventory Comments
• Methodology-focused
• Part 2: Affirmatively Furthering Fair
Housing Comments
• General Comments
• Fair Housing Assessment
• Contributing Factors
Note: Topics to be discussed at
Continuance Meeting, May 3:
• Part 3: Other Housing Element
Sections
• Part 4: Goals, Policies, and
Programs
• Including Affirmatively
Furthering Fair Housing
Policies and Programs

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Introduction and Thank You

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Thank you, Housing Element Team!
The work you are doing is extremely important and impactful • All of my comments and questions come from a place of deep respect and appreciation for the hard work you are doing!
• I am proud to have a city with staff of such caliber, who genuinely desire to create a better, more just housing landscape for our future • This is HARD WORK; and you are undertaking it in uncharted territory that is fraught with puzzles and potential pitfalls
Introduction

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Thank you, Housing Element Team!
Fair warning:
• My comments are extensive
• To implement the Housing Element in a way that truly advances fair housing goals and meets the needs of our younger generations it will take:
• Tough decisions and a lot of work
• This Housing Element is an opportunity to make real progress:
• Repair racial and economic disparities
• Combat cost of living increases that are disproportionately harming younger adults
Introduction

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The Push for Change Has Never Been Greater
Demographics will drive our housing needs and our political will • The younger half of our population has a different outlook and set of values than many who are in the older generations
• The political winds are blowing in the right direction for positive change • The Millennial and Gen-Z generations are the largest generations in history and will have continually increasing political voice and power
• It is the younger generations that are feeling the most pain in this crisis, and they are the most motivated to bring about change
• 14% of 4-year university students experienced homelessness last year; 42% experienced housing insecurity (Governing, 4/26/2022)
• We cannot botch this for the next generation
Introduction

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Quantified Objectives Discussion
Draft City of San Mateo 2031 Housing Element, Chapter 8 • “According to HCD, the sum of the quantified objectives for the programs should ideally be equal to or surpass the community's identified housing needs.” (Page H-75)
• Nevertheless, in the Draft Housing Element, the City has chosen not to produce a plan that meets our Regional Housing Needs Assessment (RHNA) allocation
• The City has (erroneously*) calculated its own, quantified objectives that are below its regionally identified housing needs
• The Draft Housing Element does not currently include meaningful, quantifiable actions that would significantly increase housing production to an appropriate level, but this can and should be changed • The only way we can justify not planning to meet our identified housing needs is if it is impossible for us to create programs, policies, develop funding, or make land use changes that can commensurably increase housing production in line with our allocation, i.e. if there were no precedents in which municipalities reformed policies and subsequently increased housing production
* The quantified objectives themselves are incorrect due to omissions in the Housing Element’s capacity calculation methodology, discussed next
Introduction

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Kevin Erdmann
“Unaffordable housing has one and only one
cause: purposeful communal enforcement
of it. This is legislated poverty.”
“We have a housing problem. And in researching that problem, you many have found that income inequality affects housing affordability. You many have found that the home building industry is inefficient. Dubious mortgage lending. Speculators. Slum lords, etc. etc. “All those things can be real things! They all can even be important things! We should deal with them AFTER the poisoning [purposeful communal enforcement of scarcity] stops!”Introduction

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Part 1: Sites Inventory

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Fundamentally, there is not a set of
programs or proposals in the Draft Housing
Element that justify an assertion that there
will be a 300% increase in housing
production over the next eight years.

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My comments focus entirely on methodological
issues and I will heavily reference state statutes
and documented state guidance

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How much buffer do we have and how does it affect
housing costs and fair housing?
Historically, most US cities planned for far more
housing than was needed for the existing
population. But as cities started to integrate in the
post-war era of the 1950s and 60s, a backlash
ended this practice, and a wave of mass
downzonings followed.

The result: Housing is increasingly unaffordable for
most households. This was deliberate, and often
predicted, as downzonings greatly reduced the
“zoning buffer” between current housing stock and
the maximum allowable housing capacity. “Before
1960, the buffer in both New York and Los Angeles
was at least 300% … New York’s fell to roughly
50% after the 1961 zoning update, and it was just
12% in Los Angeles in 2010.” (Shane Phillips,
Housing Initiative Project Manager, UCLA Lewis
Center for Regional Policy Studies)
Why does zoning capacity matter?

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• “Nonvacant Sites Analysis: For nonvacant sites,
demonstrate the potential and likelihood of
additional development within the planning
period based on extent to which existing uses
may constitute an impediment to additional
residential development, past experience with
converting existing uses to higher density
residential development, current market
demand for the existing use, any existing leases
or other contracts that would perpetuate the
existing use or prevent redevelopment of the site
for additional residential development,
development trends, market conditions, and
regulatory or other incentives or standards to
encourage additional residential development on
these sites”
This information needs to be objectively quantified
Methodological Shortcomings: Nonvacant Sites Analysis
Sites Inventory
A Necessary Threshold listed in the “HDC Housing Element Completeness Checklist 1/1/2021”:

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• “If nonvacant sites
accommodate 50 percent or
more of the lower-income RHNA
[which is the case in San Mateo],
demonstrate the existing use
is not an impediment to
additional development and
will likely discontinue in the
planning period, including
adopted findings based on
substantial evidence.”
Sites Inventory
Methodological Shortcomings: Nonvacant Sites Analysis
A Necessary Threshold listed in the “HDC Housing Element Completeness Checklist 1/1/2021”:

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Realistic Development Capacity
My Underlying Questions
• How does the city plan to increase home building by over 300%? • And is this development increase realistic under the described methodology? • What is different in cycle 6 from cycle 5?
• The city’s site’s capacities have only decreased from cycle 5 as the city has grown and land uses intensified (new developments have replaced existing underutilized parcels)
• So, is there a proposed program or group of new programs that can be shown to increase home building by over 300%, based on substantial evidence from other municipalities or from economic studies? Sites Inventory

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Sites Inventory Analysis is Incomplete
Current incompleteness prohibits City from assessing actual capacity to meet its RHNA allocation
• From the Draft Housing Element: “The purpose of the Sites Inventory is to evaluate whether there are sufficient sites with appropriate zoning to meet the RHNA goal. It is based on the City’s current land use designations and zoning requirements. The analysis does not include the economic feasibility of specific sites, nor does it take into consideration the owner’s intended use of the land now or in the future.” (Page H-25 Draft City of San Mateo 2031 Housing Element)
• My Q: What substantial evidence, then, does the city provide that uses will be discontinued for nonvacant sites?
• My Q: How does the city incorporate redevelopment trends in its site capacity calculations?
Sites Inventory

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Site Inventory Methodology - State Law
(Compare to Draft City of San Mateo 2031 Housing Element, Page H-26) • Government Code section 65583.2(c)(2) The housing element must describe the methodology used to determine the number of units calculated based on the following factors:

1. Land use controls and site improvements requirements,

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

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

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

The realistic development capacity for sites has not been factored in an appropriate or meaningful way Sites Inventory

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Page H-26
Draft City of San Mateo 2031 Housing Element
• “The number of units that might be able to be developed at various affordability levels was then estimated, e.g.,
available land zoned at higher densities can be counted toward the very low- and low-income level needs, and land zoned at lower densities are counted toward the moderate and above moderate-income housing need. The analysis
was then completed using the actual average residential densities for developments built on land with various
zoning designations over the past five years.” (Page H-26 Draft City of San Mateo 2031 Housing Element)
• This a surprisingly short description of a crucial part of our otherwise extensive Draft Housing Element
• “was then estimated” is doing a lot of work in this passage • The City needs to show its math and data so the public can adjudicate its capacity calculations
Site Inventory Methodology
Sites Inventory

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Page H-26
Draft City of San Mateo 2031 Housing Element
• “The number of units that might be able to be developed at various affordability levels was then estimated, e.g., available land zoned at higher densities can be counted toward the very low- and low-income level needs, and
land zoned at lower densities are counted toward the
moderate and above moderate-income housing need.

The analysis was then completed using the actual
average residential densities for developments built
on land with various zoning designations over the past
five years.” (Page H-26 Draft City of San Mateo 2031
Housing Element)
• Q: What is the denominator used in calculating the
average?
• Q: Does this denominator only use recently
developed sites or does it look at all similarly zoned
parcels?
Site Inventory Methodology
Sites Inventory

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Site Inventory Methodology
Realistic Development Capacity for nonresidential, nonvacant, or overlay zoned sites • Practically all sites are non-vacant, and so we must look at production trends…
Sites Inventory

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City must consider past experience
converting existing uses for Nonvacant Sites
• HCD’s “Site Inventory Guidebook,” page 24:
• “If the inventory identifies nonvacant sites to address a portion of the RHNA, the housing element must describe
the realistic development potential of each site within the planning period. Specifically, the analysis must
consider the extent that the nonvacant site’s existing use impedes additional residential development, the
jurisdiction's past experience converting existing uses to higher density residential development, market
trends and conditions, and regulatory or other incentives or standards that encourage additional housing
development on the nonvacant sites.”
“Development potential”
X period of time (“planning period”)
= rate of parcel conversion to new housing
Realistic Development Capacity
Sites Inventory

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Nonvacant Site Analysis Methodology
From HCD’s “Site Inventory Guidebook,” May 2020, page 25 Sites Inventory

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Part C: Example
Calculation
From HCD’s “Site Inventory
Guidebook,” May 2020, page 22
I cannot find this factor in our
site inventory methodology
Sites Inventory

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Site Inventory Approach
Page H-26-27
Draft City of San Mateo 2031 Housing Element
The closest thing I can find to a calculation
of the rate at which similar parcels were
redeveloped is this non-empirical
“Development Potential Ranking”.

The writers of this draft used a subjective,
ranked series of numbers, 1-5, in its
calculations to encode what amounts to an
unsubstantiated guesstimate of the
“realistic development capacity” of sites
This is like using “thumbs up” emojis
where we should be using available,
numerical, development trend data
Sites Inventory

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Realistic Development Capacity
for nonvacant sites
• Using qualitative characteristics to “rank” the “likelihood” of redevelopment for various sites is not an acceptable methodology in any HCD guidance documentation (Draft Housing Element, page H-26 to H-27) • The likelihood of redevelopment should be based on quantitative, measurable trends [rates] (HCD “Site Inventory Guidebook,” page 21) • The only valid exceptions should be for places without reasonably similar development history to calculate trends from, and that should generally not apply to the Bay Area
Sites Inventory

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Realistic Development Capacity
• Using qualitative characteristics to “rank” the “likelihood” of redevelopment for various sites is not an acceptable methodology in any HCD guidance documentation (Draft Housing Element, page H-26 to H-27) • When ratings are subjective, it is impossible for the public to ascertain the quality of the City’s analysis.
• It amounts to staff saying, “there is enough capacity because, to us, it feels like there is enough capacity. Trust us.”
• It then becomes uncannily convenient that staff “determined” we have enough zoned capacity to meet our RHNA allocation.
for nonvacant sites
Sites Inventory

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Realistic Development Capacity
• Using qualitative characteristics to “rank” the “likelihood” of redevelopment for various sites is not an acceptable methodology in any HCD guidance documentation (Draft Housing Element, page H-26 to H-27) • When we use objective, quantitative data and we find that the probability of development is lower than what we need to meet our goals, we have the ability to draft policies that will enable changes that will help us meet our goals in predictable ways
• In contrast, when you base development capacity on subjective, non- empirical ratings, the Public has no way to understand how to change policies in ways that will meet our development needs
for nonvacant sites
Sites Inventory

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Non-Vacant Site Analysis Methodology - State Law
Government Code section 65583.2, subdivision (g)(2) states:
• “An existing use shall be presumed to impede additional residential development, absent findings based on substantial evidence that the use is likely to be discontinued during the planning period.”
• Q: How can a qualitative ranking of sites be considered substantial evidence? Sites Inventory

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Realistic Development Capacity - Nonvacant Sites
• In sum, past production trends must be used, including whether or not a site will be developed at all. Staff or consultant “intuition” is not acceptable • Unless there is substantial evidence that a site will be redeveloped according to a listed density, be it a letter from the property owner or a pre- application submission, the city should be using an objective, calculated probability of redevelopment based on all similar properties locally or regionally over the course of the past RHNA cycle.
• For the City of San Mateo, that probability is 8.5% according to a UCLA study published in 2021
Sites Inventory
Current incompleteness prohibits City from assessing actual capacity to meet its RHNA allocation

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• In sum, past production trends must be used, including whether or not a site will be developed at all. Staff or consultant “intuition” is not acceptable • Each parcel capacity calculation should be multiplied by the probability of development for parcels in San Mateo, something akin to 0.085 (or

1.0 if the parcel has substantial evidence of redevelopment) • If there is additional, refined and warranted, development trend data, such as the probability of development for parcels with a specific zoning- designation that are of a functionally equivalent size, that probability may be factored into the calculation if reviewed and approved by the PC or council
Current incompleteness prohibits City from assessing actual capacity to meet its RHNA allocation
Sites Inventory
Realistic Development Capacity - Nonvacant Sites

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The City shall serve the Public in its evaluation of suitable sites • From HCD Site Inventory Guidebook, page 27:
• “If a housing element relies on nonvacant sites to
accommodate 50 percent or more of its RHNA for
lower income households, the nonvacant site’s existing
use is presumed to impede additional residential
development, unless the housing element describes
findings based on substantial evidence that the use
will likely be discontinued during the planning period.

The housing element must include the following:
• As part of the resolution adopting the housing
elements, findings stating the uses on nonvacant
sites identified in the inventory to accommodate the
RHNA for lower income is likely to be discontinued
during the planning period and the factors used to
make that determination. This can be included in
the body or in the recital section of the resolution.”
Non-vacant Site Analysis Next Steps
Sites Inventory

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Non-vacant Site Analysis Next Steps
The City shall serve the Public in its evaluation of suitable sites • When substantial evidence is provided for site redevelopment, it should be available to the public, early in the process, in an easy, user-friendly way that is connected to the site geographically,
• The substantial evidence’s warrant for use should be adjudicated by the the Public through the Planning Commission and verified by HCD • Absent substantial evidence:
• The likelihood of redevelopment of any given site should default to the likelihood of development for all sites across the city (or all sites of a particular zoning category and equivalent size, if the data are available) Sites Inventory

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Realistic Development Capacity
Include a Monitoring Program with next-step actions
• Monitoring Programs with next-step actions should be incorporated if the expected housing development is not produced
• “In addition, the housing element should include monitoring programs with next-step actions to ensure sites are achieving the anticipated development patterns. The programs should identify modifications to incentives, sites, programs, or rezoning the jurisdiction will take should these strategies not yield the expected housing potential.” (HCD “Site Inventory Guidebook,” page 21)
Sites Inventory

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Part 2: Affirmatively Furthering
Fair Housing
Using California HCD Guidance for Public Entities and Housing Elements to advocate for our neighbors in San Mateo
Commissioner Adam Nugent, April 26, 2022 Planning Commission Meeting

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AFFH General Comments
Where are we going with this?
• We should have a very clear end-state where this city has solved the identified patterns of segregation, geographic disparities, and affirmatively furthered fair housing
• It does not have to be achieved by the end of this single cycle, but its expected year of achievement should be stated and agreed upon, under the direct consultation of identified, excluded demographics and protected classes, like an emissions goal
• This end-state should be discernible and anticipated by the goals and actions AFFH: General Comments

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Michael Kraus, a social psychologist and an associate professor at Yale University “Many Americans have a hard time recognizing the magnitude and persistence of racial inequality because, psychologically, we resist these truths. Psychologists refer to this kind of broad bias in perception as “motivated cognition” — that is, most Americans want to live in a society that is more racially equal, and so they engage in mental actions that ignore, discount or downplay contradictory evidence to maintain coherence between belief and reality.” AFFH: General Comments

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Likewise, when progress toward equality is
seen as inevitable, incentives for political
action are low.

AFFH: General Comments

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We need to end residential segregation
and reinvest in our Northern
Neighborhoods
Without displacement
AFFH: General Comments

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State Guidance
Affirmatively Furthering Fair Housing
• New California laws require active steps
by our city government to dismantle
housing segregation
• Actions must be taken in the Housing
Element/General Plan creation in 2021
and 2022
• HCD outlines best practices and
policies for cities to use

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Quick AFFH
Overview for Readers
of These Notes

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What is AFFH?
Affirmatively Furthering Fair Housing
Affirmatively furthering fair housing means
taking meaningful actions, in addition to
combating discrimination, that overcome
patterns of segregation and foster
inclusive communities free from barriers
that restrict access to opportunity based
on protected characteristics.

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

AFFH: General Comments

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• Address significant disparities in housing
needs and in access to opportunity
• Replace segregated living patterns with
truly integrated and balanced living
patterns
• Transform racially and ethnically
concentrated areas of poverty into areas
of opportunity
• Foster and maintain compliance with
civil rights and fair housing laws
Meaningful Action
AFFH requirements
AFFH: General Comments

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Fair Housing Actions
What we need San Mateo to do
• Create housing mobility strategies
• Provide new housing choices and
affordability in areas of opportunity
• Design place-based strategies to
encourage community conservation
and revitalization
• Protect existing residents from
displacement
AFFH: General Comments

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AFFH: General Comments

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6.3 San Mateo’s Fair Housing
Assessment

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Fair Housing Assessment
Shortcomings In the Assessment of Segregation and Integration Patterns and Trends:
• No analysis of racially segregated, concentrated areas of affluence • Missing assessment of the most segregated racial population: non- Hispanic whites (APPENDIX D, Attachment 4 – UC Merced Segregation Report)
• No opportunity sites are located within the city’s highest-opportunity areas "Figure II-7: White Majority Census Tracts," Root Policy Research Map and Data Packet, Page 11
AFFH: Fair Housing Assessment

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Racially Concentrated Areas of Affluence Completely Left Out of the Analysis and Sites Inventory Assessment’s Miss:
70-80% WHITE
70-80% WHITE
70-80% WHITE
90% NON-WHITE
"Figure II-6: % Non-
White Population by
Census Block Groups,"
2018, Root Policy
Research Map and
Data Packet, Page 10
AFFH: Fair Housing Assessment

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Fair Housing Assessment
Shortcomings In the Assessment of Segregation and Integration Patterns and Trends:
• Why is income-segregation substantially higher in San Mateo compared to the rest of the Bay Area?
• This assessment should highlight factors that can be fixed • Why has San Mateo’s income segregation at the neighborhood level not improved over time and why is it worse than the Bay Area average? AFFH: Fair Housing Assessment

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Fair Housing Assessment
• Missing meaningful assessment of segregation in San Mateo relative to the Bay Area region
• Extremely low population of black people. Why?
• Need assessment of causes for the growing exclusion of this demographic from San Mateo in order to solve for this issue Shortcomings In the Assessment of Segregation and Integration Patterns and Trends:

AFFH: Fair Housing Assessment

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Exclusion and displacement —> low population relative to Bay Area • Only 2% of the city’s population is now black
• In 1990 the North Central census tract was
18% black, the highest in the city
• In 2017 it was only 4% black
• Discuss possible causes:
• Disinvestment-driven displacement in
North Central due to rising rental costs
and lack of improvement of rental housing
conditions
• Government policy preventing home
purchasing
• Historical exclusion elsewhere in the city
Assessment’s Miss: Black population
AFFH: Fair Housing Assessment

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Housing Habitability Issues
Assessment’s Miss: Geographic Differences
• Strong and distinguishing
characteristic of North Central
• Highly concentrated in North
Central and downtown
• North Shoreview is not
characterized by this issue
See also: ”Figure III-11: Healthy Places
Index by Census Tract, 2021," Root Policy
Research Map and Data Packet, Page 40
AFFH: Fair Housing Assessment

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Overcrowding issues in North Central
• Strong and distinguishing characteristic of
southern North Central
• Highly concentrated in one neighborhood
• North Shoreview (13%) is much less
characterized by this issue
• San Mateo overcrowding overall average:
7%, which is heavily skewed by North
Central
• San Mateo Park: < 1%
• North Central north of Poplar Ave: 1%
• North Central south of Poplar Ave: 27%
Assessment’s Miss: Geographic Differences
"Figure IV-19: Overcrowded Households by Census Tract,
2019," Root Policy Research Map and Data Packet, Page 60 AFFH: Contributing Factors

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Fair Housing Assessment
• North Central residents, including many who are alive today, have experienced the trauma of exclusion and steering from other neighborhoods of San Mateo
• Paired with a strong history of disinvestment and government practices to prevent POC from home ownership, the neighborhood and its people will need thoughtful repair in both the public and private realms Resident trauma and exclusion
AFFH: Fair Housing Assessment

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6.3.2 Contributing factors and
Fair Housing Action Plan.

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Excerpt from HCD’s AFFH Presentation

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Excerpt from HCD’s AFFH Presentation

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Analysis of Contributing Factors is inadequate
• It currently focuses more on the characteristics of the victims of our discriminatory structures and thus functions more as a continuation of the fair housing assessment than what it’s meant to be
• For instance, listing the fact that Hispanic residents are more likely to work low-wage jobs or that Hispanic residents are primarily concentrated in the northeastern area of the city where residents face higher poverty and cost burden as well as poor opportunity outcomes is something that belongs in the fair housing assessment, not in the contributing factors space AFFH: Contributing Factors

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Analysis of Contributing Factors is inadequate
What is a fair housing contributing factor?
• Fair housing contributing factor = a factor that creates, contributes to, perpetuates, or increases the severity of one or more fair housing issues • City-controlled regulatory factors, policies, or ways of doing business that cause or contribute to fair housing issues should be fully identified and take primacy in this analysis, but they are inadequately discussed AFFH: Contributing Factors

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Examples of Contributing Factors to Fair Housing Issues by Area • Segregation and Integration
• Community opposition
• Lack of community
revitalization strategies
• Lack of private investments
in specific neighborhoods
• Land use and zoning laws
From HCD’s “Affirmatively Furthering Fair Housing: Guidance to All Public Entities and for Housing Elements” Pages 68-70
AFFH: Contributing Factors

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Examples of Contributing Factors to Fair Housing Issues by Area • Racially and Ethnically
Concentrated Areas of Poverty
• Deteriorated and abandoned
properties
• Displacement of residents
due to economic pressures
• Land use and zoning laws
• Occupancy codes and
restrictions
From HCD’s “Affirmatively Furthering Fair Housing: Guidance to All Public Entities and for Housing Elements” Pages 68-70
AFFH: Contributing Factors

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Examples of Contributing Factors to Fair Housing Issues by Area From HCD’s “Affirmatively Furthering Fair Housing: Guidance to All Public Entities and for Housing Elements” Pages 68-70
• Disparities in Access to Opportunity
• The availability, type, frequency, and
reliability of public transportation
• Land use and zoning laws
• Lack of public investments in
specific neighborhoods, including
services or amenities
• Location of proficient schools and
school assignment policies
• Location and type of affordable
housing
AFFH: Contributing Factors

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Examples of Contributing Factors to Fair Housing Issues by Area From HCD’s “Affirmatively Furthering Fair Housing: Guidance to All Public Entities and for Housing Elements” Pages 68-70
• Disproportionate Housing Needs,
Including Displacement Risks
• The availability of affordable
units in a range of sizes
• Lack of renter protections
• Land use and zoning laws
AFFH: Contributing Factors

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Analysis of Contributing Factors
Analysis of Contributing Factors is inadequate.
• Contributing Factors analysis must answer key “why” questions:
• What unique factors, characteristics, and history in North Central and, separately, North Shoreview are leading to the concentration of higher poverty, low economic and environmental opportunity, high-cost burden, overcrowding, and flood hazards compared to the rest of the City of San Mateo?
• What existing government constraints or policies have perpetuated these concentrated characteristics?
• What factors, policies, and history in other parts of the city contribute to the absence of these characteristics, especially west of El Camino? AFFH: Contributing Factors

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Shortcomings
• The Housing Element needs to assess the geographic and regulatory causes leading to the concentration of poverty, low economic and environmental opportunity, high-cost burden, and overcrowding in North Central and, to a lesser extent, North Shoreview
• The Housing Element also needs to assess the geographic and regulatory causes leading to the concentration of affluence and, disproportionately, white people in western neighborhoods
• This necessary assessment of causes is needed in order to develop place- based programs and actions that will meaningfully repair these issues The Analysis of Contributing Factors
AFFH: Contributing Factors

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Must be able to guide Significant, Meaningful, and Sufficient policies to Overcome Patterns of Segregation
• Existing patterns of segregation in San Mateo are significant and persistent • Census tract divergence within the city ranges from 82% white to 6% white (San Mateo Park vs North Central, respectively)
• Class segregation largely follows these lines
• Actions and policies must be sufficient to overcome this pattern in a reasonable period of time
• Why is the white population significant? Check out Appendix D and read Segregation by Design by Prof. Jessica Trounstine
The Analysis of Contributing Factors
AFFH: Contributing Factors

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Must be able to guide Significant, Meaningful, and Sufficient policies to Overcome Patterns of Segregation
• The Housing Element also fails to discuss strategic approaches to inform and strongly connect “Contributing Factors” to “Goals and Actions” • This contributes to the the creation of goals and actions that are not yet sufficient to produce meaningful action
The Analysis of Contributing Factors
AFFH: Contributing Factors

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Must be able to guide Significant, Meaningful, and Sufficient policies to Overcome Patterns of Segregation
• Again, existing patterns of segregation in San Mateo are significant and persistent • Analysis of Contributing Factors should be able to connect to Actions and Policies that are structured in a way that, economically, creates value for the city and for residents, without destroying the value of existing places
• This should not be about diminishing the quality of existing high-resource neighborhoods in order to achieve parity
• This process is about:
• Lifting up disinvested portions of our city, and
• Pairing that uplift with expanded access and residential integration across the city through thoughtful government-guided programs
The Analysis of Contributing Factors
AFFH: Contributing Factors

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Tell the Story: North Shoreview: Environmental Hazard and Isolation • Why is North Shoreview an edge
Racially/Ethnically Concentrated
Area of Poverty?
• What characteristics
distinguish North Shoreview
from other similar
neighborhoods, and how
might they lead to higher
concentrations of marginalized
or vulnerable groups?
Identify and Prioritize Contributing Factors
"Figure IV-31: Special Flood Hazard Areas, 2000,"
Root Policy Research Map and Data Packet, Page 69 AFFH: Contributing Factors

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Identify and Prioritize Contributing Factors:

Tell the Story

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Tell the Story: North Shoreview: Environmental Hazard and Isolation • Why is North Shoreview an edge
Racially/Ethnically Concentrated
Area of Poverty?
• Key differences between North
Shoreview and South
Shoreview:
• Levy protection and flood
hazard chance.
• Limited access to circulation
and transportation
Identify and Prioritize Contributing Factors
"Figure IV-31: Special Flood Hazard Areas, 2000," Root Policy Research Map and Data Packet, Page 69

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Tell the Story: North Central: Poor Housing Conditions + Overcrowding • Why is North Central (south of
Poplar) an edge Racially/
Ethnically Concentrated Area of
Poverty?
• What characteristics distinguish
North Central south of Poplar
Ave from other parts of the city,
and
• How might they lead to higher
concentrations of marginalized
groups?
Identify and Prioritize Contributing Factors
Overcrowding
Unhealthy Housing
Conditions
AFFH: Contributing Factors

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Tell the Story: North Central: Disinvestment + Environmental Hazard Identify and Prioritize Contributing Factors
• Why is North Central (south of Poplar) an
edge Racially/Ethnically Concentrated Area of
Poverty?
• Key differences between North Central
(south of Poplar) and other areas:
• Decades of disinvestment:
• Both private housing stock and
public infrastructure
• Overcrowding and poverty as both
symptoms and causes of private
disinvestment
• Levy protection and flood hazard
chance (in portions of that area)
"Figure IV-31: Special Flood Hazard Areas, 2000,"
Root Policy Research Map and Data Packet, Page 69 AFFH: Contributing Factors

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Tell the Story: North Central: Historical Ghettoization + Failed, Segregated Schools Identify and Prioritize Contributing Factors
• Why is North Central (south of Poplar) an
edge Racially/Ethnically Concentrated Area
of Poverty?
• Key differences between North Central
and other areas:
• History of a highly segregated
neighborhood and its
underperforming school
• Neighborhood’s Turnbull Learning
Academy closed about 15 years ago
• The building repurposed for the
College Park Mandarin Immersion
magnet school
AFFH: Contributing Factors

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AFFH Links
and Resources
• California HCD Affirmatively Furthering
Fair Housing (AFFH) Guidance https://
www.hcd.ca.gov/community-
development/affh/docs/
affh_document_final_4-27-2021.pdf
• AFFH Data Viewer https://affh-data-
resources-cahcd.hub.arcgis.com
• California Healthy Places Index https://
map.healthyplacesindex.org

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The Planning Commission discussion will resume on
May 3rd at 7pm where we will discuss Goals, Policies,
and Actions, including those related to AFFH

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1 Manira Sandhir
From: Adam Nugent
Sent: Thursday, May 5, 2022 5:45 PM
To: Manira Sandhir; Zachary Dahl
Cc: Eloiza Murillo-Garcia; [email protected]
Subject: San Mateo Planning Commissioner Input - Draft Housing Element - May 3 Attachments: Planning Commission Input - Draft Housing Element - Adam Nugent - May 3.pdf Hi Manira and Zach,

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

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

Best,
Adam

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

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Commissioner Adam Nugent, May 3, 2022 Planning Commission Meeting Draft Housing Element
Comments
Draft for Public Review: Housing Element of the General Plan 2023-2031, April 6, 2022

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Outline
Draft 2023-2031 Housing Element Input
• Introduction and Thank You (Same as 4/26)
• Part 3: Other Housing Element Sections
• Part 4: Goals, Policies, and Programs
• Selected Excerpts of Rejection Letters
for Other Cities
• Goals, Policies, and Actions Discussion
• AFFH-Specific Policy-by-Policy Review
• Non-AFFH-Specific Policy-by-Policy
Review
Note: Topics that were discussed at the
April 26 Planning Commission Meeting:
• Part 1: Site Inventory Comments
• Methodology-focused
• Part 2: Affirmatively Furthering Fair
Housing Comments
• General Comments
• Fair Housing Assessment
• Contributing Factors

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Public Comments
Notes and Highlights
• Market special-needs units to the most appropriate special needs population.

Unit-specific needs should be marketed so that the unique, appropriate population is matched with the special features of the unit • Measure Y as an obstacle to affordable housing development

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Thank you, Housing Element Team!
The work you are doing is extremely important and impactful • All of my comments and questions come from a place of deep respect and appreciation for the hard work you are doing!
• I am proud to have a city with staff of such caliber, who genuinely desire to create a better, more just housing landscape for our future • This is HARD WORK; and you are undertaking it in uncharted territory that is fraught with puzzles and potential pitfalls
Introduction

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Thank you, Housing Element Team!
Fair warning:
• My comments are extensive
• To implement the Housing Element in a way that truly advances Fair Housing Goals and meets the needs of our younger generations it will take:
• Tough decisions and a lot of work
• This Housing Element is an opportunity to make real progress:
• Repair racial and economic disparities
• Combat cost of living increases that are disproportionately hitting younger adults
Introduction

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The Push for Change Has Never Been Greater
Demographics will drive our housing needs and our political will • The younger half of our population has a different outlook and set of values than many who are in the older generations
• The political winds are blowing in the right direction for positive change • The Millennial is the largest generation in history and Gen-Z is close behind; they will have continually increasing political voice and power
• It is the younger generations that are feeling the most pain in this crisis, and they are the most motivated to bring about change
• 14% of 4-year university students experienced homelessness last year; 42% experienced housing insecurity (Governing, 4/26/2022)
• We cannot botch this for the next generation
Introduction

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Kevin Erdmann
“Unaffordable housing has one and only one
cause: purposeful communal enforcement
of it. This is legislated poverty.”
“We have a housing problem. And in researching that problem, you many have found that income inequality affects housing affordability. You many have found that the home building industry is inefficient. Dubious mortgage lending. Speculators. Slum lords, etc. etc. “All those things can be real things! They all can even be important things! We should deal with them AFTER the poisoning [purposeful communal enforcement of scarcity] stops!”Introduction

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Part 3: Other Housing Element
Sections

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Constraints Analysis
Draft Analysis Not Very Useful
• Constraints analysis should provide metrics on how existing land use and related policies affect the City’s ability to build housing • What are the counterfactuals?
• How much more housing could be built under different zoning scenarios? • What are the true limiting factors over the long term? • Why are construction costs so high and what can the city do to counteract these trends?
Part 3: Other Housing Element Sections

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Constraints Analysis
Zoning and Land Use Constraints
• Height and Density Constraints on BMR Units: Measure Y • Height and Density constraints contained in measure Y are limiting the city’s ability to increase the percentage of BMR units for the city’s inclusionary ordinance • Recent city-commissioned study found increasing the inclusionary percentage to 20% would render projects infeasible
• This adds up and translates to needing significantly more redevelopable land to achieve any given quantity of subsidized units than necessary • Increases costs substantially by increasing costs imposed by land acquisition and entitlement processes
Part 3: Other Housing Element Sections

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Constraints Analysis
Zoning and Land Use Constraints
• Height and Density Constraints: Measure Y
• Density limits also significantly reduce the number of units that can be built by 2-3x, even under the existing 5-story height limit
• Doubles or triples the land costs per unit for all ranges of affordability • Doubles or triples the procedural, consultant, and time costs of additional design and entitlement processes
Part 3: Other Housing Element Sections

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Constraints Analysis
Community Opposition
• Community opposition is a clear problem
• Most people want more housing and to solve our housing crisis • It only takes a few, vocal or influential residents to block housing • Counterfactuals are hard to quantify, but the effects of a vocal, negative minority are likely enormous
• When good, potential projects never even get proposed • When bad policies and zoning go unchanged
• Need policies to overcome community opposition - especially as it relates to AFFH Part 3: Other Housing Element Sections

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Constraints Analysis
Fee Disparities
• Fees take up an unusually large proportion of the total costs of development in the City of San Mateo compared to the rest of San Mateo County • Fees impact small multi-family projects especially hard • They are 3.5 times higher per unit than single family homes Part 3: Other Housing Element Sections

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Part 4: San Mateo’s Goals,
Policies, and Actions

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Dr. Martin Luther King Jr. “Letter from Birmingham Jail” 1963 “We must come to see that human progress
never rolls in on wheels of inevitability. It
comes through the tireless efforts and
persistent work of men willing to be
coworkers with God, and without this hard
work time itself becomes an ally of the
forces of social stagnation.”
Part 4: San Mateo’s Goals, Policies, and Actions

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Excerpts from HCD’s AFFH Presentation

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Excerpts from HCD’s AFFH Presentation

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Selected Excerpts of Rejection
Letters for Other Cities’ 6th-Cycle
Housing Elements

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LA’s exemplary Housing Element Rejected
• Praised for metrics used to
demonstrate and determine
adequate sites for the Housing
Element
• Pursuing large rezoning program
Los Angeles

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Reason: AFFH
• Programs did not include metrics
• “In addition, while the element
included some actions to replace
segregated patterns, these
actions lacked specific
geographic focus (communities
with fair housing issues), firm
commitments and significant
targets for AFFH outcomes.”
LA Rejection Letter

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Programs
How should programs be structured?
• “Programs must demonstrate that they will have a beneficial impact within the planning period. Beneficial impact means specific commitment to deliverables, measurable metrics or objectives, definitive deadlines, dates, or benchmarks for implementation. Deliverables should occur early in the planning period to ensure actual housing outcomes.” (From HCD’s Davis, CA rejection letter)
• “Programs should include specific actions and commitments the City will take to implement the program. For example, a Program should be specific on the regulatory incentives, zoning standards, and programs it will offer to assist in the development of housing.” (From HCD’s Davis, CA rejection letter)

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AFFH-specific
Goals and Actions must be significant and meaningful
• “Goals and actions must specifically respond to the analysis and the identified and prioritized contributing factors to fair housing issues and must be significant and meaningful enough to overcome identified patterns and trends… Actions must have specific commitment, metrics, and milestones as appropriate and must address housing mobility enhancement, new housing choices, and affordability in high opportunity areas, place-based strategies for community preservation and revitalization, and displacement protection.” (From HCD’s Redondo Beach rejection letter)

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AFFH-specific
Programs must have metrics and milestones
• “Based on the outcomes of a complete AFFH analysis, the element must add or modify programs to include specific metrics and milestones to target meaningful AFFH outcomes, including providing mobility opportunity, place- based strategies [for community preservation and revitalization], new housing opportunities, and preservation and conservation efforts to address displacement.” (From HCD’s Davis, CA rejection letter)

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AFFH-specific
Programs must have objective measures to determine success of outcomes • [We need to] “replace non-committal language such as “if feasible”, “assess the feasibility of”, or “assess” with language that commits to follow-up actions. The program must include specific timeframes for action and provide quantifiable description of actions to objectively measure for successful outcomes.” (From HCD’s Redondo Beach rejection letter)
• Many policies with AFFH impacts proposed by San Mateo’s Draft Housing Element are characterized by this issue
• All proposed policies that have words like “investigate,” “explore,” or “evaluate” should be amended to provide specific timeframes for action and provide quantifiable descriptions of actions to objectively measure for successful outcomes

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Goals, Policies, and Actions
Discussion

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Goals, Policies, and Actions
Actions must be:
• Significant
• Meaningful
• Sufficient to Overcome Patterns of Segregation
• Affirmatively Further Fair Housing
Part 4: San Mateo’s Goals, Policies, and Actions

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Goals, Policies, and Actions
Necessary Components
• Metrics and milestones for evaluating:
• Progress on programs/actions
• Fair housing results
• Remember:
• Must have a clear timeline with specific dates and milestones paired with quantifiable outcomes • Meaningful impact during the planning period
• Go beyond a continuation of past actions
Part 4: San Mateo’s Goals, Policies, and Actions

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• Address significant disparities in housing
needs and in access to opportunity
• Replace segregated living patterns with
truly integrated and balanced living
patterns
• Transform racially and ethnically
concentrated areas of poverty into areas
of opportunity
• Foster and maintain compliance with
civil rights and fair housing laws
Meaningful Action
AFFH requirements
Part 4: San Mateo’s Goals, Policies, and Actions

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How to combat exclusion and segregation
• We will need to tie our policies to
key quantitative metrics focused
on integration and segregation
data
• We will also need well-defined
anti-displacement program
requirements
• Without these two things we will
further collectivize the right to
exclude
Goals, Policies, and Actions
UC Berkeley Othering and Belonging Institute

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Goals, Policies, and Actions
Address significant disparities in housing needs and in access to opportunity • Hispanic residents, single female parent households, renters, and the people of North Central, and to a lesser extent North Shoreview, have Disproportionate Housing Needs:

1. Cost Burden & Severe Cost Burden

2. Overcrowding

3. Substandard Housing

4. Displacement risk
• Investment-driven
• Disinvestment-driven
Part 4: San Mateo’s Goals, Policies, and Actions

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Goals, Policies, and Actions
Address significant disparities in housing needs and in access to opportunity • Cost Burden and Severe Cost Burden
• Site inventory, together with goals, policies, and actions, must be sufficiently developed to actually produce at a minimum, the allocated 7000+ units of housing in San Mateo • Previous production trends indicate less than 1,000 units can be reasonably expected to be developed over the course of the 6th housing cycle, as currently planned in this Draft Housing Element
• Failure to adequately plan for the minimum allocated number of units will lead to further increasing cost burden and severe cost burden. It will also drive young families out of the Bay Area
• The City’s methodology must be revised to produce a high likelihood of meeting our regional allocation in order to address this AFFH disparity Part 4: San Mateo’s Goals, Policies, and Actions

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Goals, Policies, and Actions
Address significant disparities in housing needs and in access to opportunity • Overcrowding
• Overcrowding is similarly affected by the reasonable achievement of the regional housing needs allocation goals
• Overcrowding is also highly location-specific and must be addressed in a combined effort to prevent displacement as part of a program to transform racially and ethnically concentrated areas of poverty into areas of opportunity
• North Central contains an area that is nearly 4X the San Mateo average • 27% vs 7% overcrowded households
• Thousands of people in North Central live in overcrowded conditions • Overcrowding is a measurable factor.
• Policies and Actions should be tailored to eliminate disparities in overcrowding and overcrowding in general within set timelines, say 1 and 2 decades, respectively Part 4: San Mateo’s Goals, Policies, and Actions

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Goals, Policies, and Actions
Address significant disparities in housing needs and in access to opportunity • Substandard Housing
• Substandard Housing is closely linked geographically to overcrowding in North Central
• Material conditions must be improved, as with overcrowding, in a way that prevents displacement
• Best done as part of a larger program to transform racially and ethnically concentrated areas of poverty into areas of opportunity • Policies and Actions should be tailored to realistically eliminate substandard and unhealthy housing conditions within a set timeline, say 1-2 decades Part 4: San Mateo’s Goals, Policies, and Actions

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Address significant disparities in housing needs and in
access to opportunity
• Displacement Risk 1
• Programs must be developed to specifically address
displacement risk caused both by cost burden and by
potential neighborhood reinvestment
• Robust Right of Return for renters, paired
with…
• Alternative option for Unrestricted Negotiable
Tenant Buyouts
• Some tenants may not want to return
• All residents should be materially better
off following any neighborhood
investment
• All zoning changes and production policies
must be formulated to make the increased
costs imposed by associated displacement
protections feasible
Goals, Policies, and Actions
Part 4: San Mateo’s Goals, Policies, and Actions

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Address significant disparities in housing needs and in
access to opportunity
• Displacement Risk 2
• Programs must be developed to specifically
address displacement risk caused both by cost
burden and by potential neighborhood
reinvestment
• Relocation Payments for substantial
remodel, demolition…
• and owner move-in
• All residents should be materially
better off following any
neighborhood investment
• All zoning changes and production policies
must be formulated to make the increased
costs imposed by associated displacement
protections feasible
Goals, Policies, and Actions
Part 4: San Mateo’s Goals, Policies, and Actions

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Address significant disparities in housing needs and in
access to opportunity
• Displacement Risk 3
• Programs must be developed to specifically address
displacement risk caused both by cost burden and by
potential neighborhood reinvestment
• Create Community Opportunity to Purchase/
Tenant Opportunity to Purchase program,
paired with…
• Partnerships with Philanthropic Organizations
to bring funds to our most disinvested places
• All residents should be materially better
off following any neighborhood
investment
• All zoning changes and production policies
must be formulated to make the increased
costs imposed by associated displacement
protections feasible
Goals, Policies, and Actions
Part 4: San Mateo’s Goals, Policies, and Actions

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Address significant disparities in housing needs and in
access to opportunity
• Displacement Risk 4
• Programs must be developed
to specifically address
displacement risk caused both
by cost burden and by potential
neighborhood reinvestment
• Extend AB1482
protections to tenants
whose tenure is less than
1 year
Goals, Policies, and Actions
Part 4: San Mateo’s Goals, Policies, and Actions

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Goals, Policies, and Actions
Additional Policy Suggestions
• Fee Parity
• San Mateo charges higher fees than the majority of its peers, and the city’s fees impose significant costs on developers–especially for small multi-family housing • The city’s massive fees for small multi-family projects impose obvious burdens on developers and should be amended to support lower-cost home building • Achieve parity with Single Family home development
Part 4: San Mateo’s Goals, Policies, and Actions

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Goals, Policies, and Actions
Additional Policy Suggestions
• Affordable Housing Overlay
• Provide affordable housing developers an advantage in the market for developable properties
• Geographically locate the overlay(s) to compensate for existing housing disparities in access to opportunity
Part 4: San Mateo’s Goals, Policies, and Actions

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AFFH-Specific Policy-by-Policy
Review
Part 4: San Mateo’s Goals, Policies, and Actions

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Part 4: San Mateo’s Goals, Policies, and Actions

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Adjust City’s BMR Program
• Positive program but:
• Lacks firm commitments
• Lacks significant targets for
AFFH outcomes
Policy 5.1.1
Part 4: San Mateo’s Goals, Policies, and Actions

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Participate in a Regional Downpayment program
• Program with potential life-
changing outcomes but:
• Limited scope will not
significantly address large-scale
Systemic issues
Policy 5.1.2
Part 4: San Mateo’s Goals, Policies, and Actions

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Support the Design of Regional Forgivable Loan Program for 15-year ELI ADU Construction • Potential to contribute to overcoming
patterns of segregation
• Positive program with potential life-
changing outcomes but:
• Limited scope will not significantly
address large-scale systematic issues
• Deliverables should occur early in the
planning period to ensure actual
housing outcomes
• Lacks specific actions and metric-ready
commitments
Policy 5.1.3
Part 4: San Mateo’s Goals, Policies, and Actions

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Support the Design of Regional Forgivable Loan Program for 15-year ELI ADU Construction • Policy revision recommendations:
• Expand to SB 9 projects
• Incorporate option for longer
deed restriction (55 years) for
one low income unit within a
SB 9 program
Policy 5.1.3 continued
Part 4: San Mateo’s Goals, Policies, and Actions

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Affirmatively Market BMR units to households with disproportionate housing needs • Positive program with metrics
• People with special needs have
unique and special needs. Each
potential recipient may be quite
different from the next and the
program will need to be
tailorable
• Limited scope will not
significantly address large-scale
systemic issues
Policy 5.2.1
Part 4: San Mateo’s Goals, Policies, and Actions

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Incentivize development of new accessible units
• Positive program with potential
life-changing outcomes but:
• Limited scope
• Deliverables should occur earlier
in the planning period to ensure
actual housing outcomes
• Lacks specific actions and
metric-ready commitments
Policy 5.2.2
Part 4: San Mateo’s Goals, Policies, and Actions

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Prioritize city affordable housing funds for hard-to-serve residents • Positive program but:
• Limited $ = limited impact
• Lacks specific actions and
quantifiable commitments
Policy 5.2.3
Part 4: San Mateo’s Goals, Policies, and Actions

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Conduct an area plan for North Shoreview and North Central • Potentially substantial program, but:
• Currently lacking firm commitments
and significant targets for AFFH
outcomes
• Policy 5.3.1 should be specific on
the regulatory incentives, zoning
standards, and programs it will offer
Policy 5.3.1
• Deliverables should occur earlier and
demonstrate that the program will
have a beneficial impact within the
planning period
• Provide measurable milestones and
a target dates to achieve goals
Part 4: San Mateo’s Goals, Policies, and Actions

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Conduct an area plan for North Shoreview and North Central • Actions must specifically respond
to the analysis and the identified
and prioritized contributing factors
to fair housing issues and must be
significant and meaningful
enough to overcome identified
patterns and trends
Policy 5.3.1 continued
• Specific planning goals must also include:
• Displacement prevention +
• Elimination of disproportionate
concentrations poverty, low income
households, and overcrowding
Part 4: San Mateo’s Goals, Policies, and Actions

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Plan for the opposite of Urban
Renewal
Urban Renewal conflated overcrowding with urban density
• Must not repeat the horrors of these Mid-Century
Planning Efforts
• Urban Renewal sought to:
• Disperse and displace the resident population,
without providing adequate accommodations
elsewhere
• “Clear” slums, and replace them with things
like:
• Freeways, stadiums, convention centers,
• Inadequately-sized public housing
projects

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Conduct an area plan for North Shoreview and North Central • Planning goals should be structured with metrics and target dates, for example:
• Eliminate overcrowding by 2040
• Achieve parity with City in economic integration by 2050 Policy 5.3.1 continued
Part 4: San Mateo’s Goals, Policies, and Actions

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Conduct an area plan for North Shoreview and North Central Policy 5.3.1 continued
• Additional example planning goals:
• Achieve health and housing habitability parity with City by 2040 • Eliminate disproportionate concentrations of low-income residents while maintaining an outmigration rate below 20xx rate and increasing subsidized, deed-restricted affordable housing at 150% the rate of outmigration
Part 4: San Mateo’s Goals, Policies, and Actions

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Conduct an area plan for North Shoreview and North Central • Plan to feasibly accommodate Community Benefits
Agreements that balance redevelopment proposals with
tangible, local benefits to residents in the area, e.g.:
• Creating affordable housing
• Funding renter assistance programs for nearby residents • Other investments that meet community-identified
needs, such as infrastructure and community amenities
Policy 5.3.1 continued
Part 4: San Mateo’s Goals, Policies, and Actions

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Conduct an area plan for North Shoreview and North Central • R-1 portions of these neighborhoods should be provided total parity of treatment with the rest of San Mateo’s R-1
neighborhoods
• Why? The lower home values and lower wealth of non-white, owner-occupant homeowners means we need to carefully
manage and enhance the amenity-related value of ownership housing in places predominantly occupied by minorities
• Balance this task with displacement protections
Policy 5.3.1 continued
Part 4: San Mateo’s Goals, Policies, and Actions

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Conduct an area plan for North Shoreview and North Central • Provide specific timeframes for action and a quantifiable description of actions to objectively measure for successful outcomes
• Metrics to evaluate the plan must be in place and they must ultimately:
• Replace segregated living patterns with truly integrated and balanced living patterns • Transform racially and ethnically concentrated areas of poverty into areas of opportunity
Policy 5.3.1 Conclusions
Part 4: San Mateo’s Goals, Policies, and Actions

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Continue to fund minor home repairs
• Nice program but:
• Limited $ = limited impact
• Existing program
Policy 5.3.2
Part 4: San Mateo’s Goals, Policies, and Actions

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Monitor affordable housing projects at risk of conversion • Important to preserve
affordability, but:
• “Monitor” and “develop a plan”
are inadequate policies
Policy 5.3.3
Part 4: San Mateo’s Goals, Policies, and Actions

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Tenant Protections to extend AB1482 related to relocation, documentation, and right to return policy
• Vital, can be strengthened
• Relocation payments for
demolition should be uncapped
and negotiable
Policy 5.4.1
Part 4: San Mateo’s Goals, Policies, and Actions

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Non-AFFH-Specific Policy-by-
Policy Review
Part 4: San Mateo’s Goals, Policies, and Actions

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Policy Comment Potpourri
Selected Policies
• Policy H 1.2 - Utilize Public Funding for Low/
Moderate Income Housing
• Comment: Well defined, ongoing program
• Policy H 1.3 - Increase Below Market Rate Unit
Production through Density Bonus/Community
Benefits Programs *
• Policy H 1.5 - Encourage Family Housing *
* = Replace non-committal
language such as “explore”
or “assess” with language
that commits to follow-up
actions. The program must
include specific timeframes
for action and provide
quantifiable description of
actions to objectively
measure for successful
outcomes.

Part 4: San Mateo’s Goals, Policies, and Actions

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

Part 4: San Mateo’s Goals, Policies, and Actions

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

Part 4: San Mateo’s Goals, Policies, and Actions

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Policy Comment Potpourri
Selected Policies
• Policy H 2.5 - Promote Housing Resilience
• Comment: Existing, ongoing, important
• Policy H 2.6 - Require Replacement Units
• Comment: Make this a permanent local
ordinance
Part 4: San Mateo’s Goals, Policies, and Actions

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• Change “Evaluate” to “Pursue” Additional Local Funding Sources:
• Vacancy Tax - Parcel taxes in the form of a vacant property tax have been used by cities (VPT, Oakland) to fund affordable housing and homeless services; as well as to entice owners of undeveloped sites to either sell or build homes on their parcels. • Increase Commercial Linkage Fees - To help mitigate the increase in demand for housing, cities have the ability to charge a fee on new commercial developments.

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

Policy Comment Potpourri
Policy H 3.3 “Evaluate Housing Revenue Sources”
Part 4: San Mateo’s Goals, Policies, and Actions

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

Part 4: San Mateo’s Goals, Policies, and Actions

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Links and Resources
• California HCD Affirmatively Furthering
Fair Housing (AFFH) Guidance https://
www.hcd.ca.gov/community-
development/affh/docs/
affh_document_final_4-27-2021.pdf
• AFFH Data Viewer https://affh-data-
resources-cahcd.hub.arcgis.com
• California Healthy Places Index https://
map.healthyplacesindex.org

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1 Nicholas "Nicky" Vu
From: Housing
Sent: Tuesday, January 3, 2023 10:17 AM
To: Nicholas "Nicky" Vu; Eloiza Murillo-Garcia
Subject: FW: Online Form Submittal: Draft 2023-2031 Housing Element Comment Form Follow Up Flag: Follow up
Flag Status: Flagged

Sandra Belluomini
Administrative Tech| Housing
330 W. 20th Ave., San Mateo, CA 94403

From: [email protected] <[email protected]>
Sent: Friday, December 30, 2022 10:40 AM
To: Housing <[email protected]>
Subject: Online Form Submittal: Draft 2023‐2031 Housing Element Comment Form

Draft 2023-2031 Housing Element Comment Form

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

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

First Name  William
Last Name  Graham
Email Address
Comment on 2023‐2031
Draft Housing Element
Thank you to city staff and others for their work on the 2023-31 housing plan. As with all plans, there are many things residents

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2 will agree on and many they won’t. The plan, though, is well thought out and addresses many challenges the city faces in meeting housing need at all levels.

I may have missed it in my review, but it appears the plan doesn’t speak to public education and alignment with the elementary and high school districts to ensure they have the resources to support additional capacity.

It’s very likely these discussions are happening in other settings. However, knowing that this has been an area of concern for many in the past, I encourage staff to address this upfront to ensure it doesn’t become a barrier. The districts are capable and can meet the need with appropriate planning and integration with the city.

Thank you again for the thought and well considered plan.

Email not displaying correctly? View it in your browser.

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1 Nicholas "Nicky" Vu
From: Housing
Sent: Tuesday, January 3, 2023 10:17 AM
To: Nicholas "Nicky" Vu; Eloiza Murillo-Garcia
Subject: FW: Housing Element
Follow Up Flag: Follow up
Flag Status: Flagged

Sandra Belluomini
Administrative Tech| Housing
330 W. 20th Ave., San Mateo, CA 94403

From: Susan Shankle
Sent: Friday, December 30, 2022 11:02 AM
To: Housing <[email protected]>
Subject: Housing Element

Great report. I have one comment, which relates to Section 4.3, Climate Change and Energy Conservation:

Let’s follow the lead of the CA Central Valley agricultural canal system which, after decades of suggestion and input, finally capped the canals with solar panels, which both significantly reduces evaporation plus offers an additional power source. Smart!

I’ve been asking for more City solar panel installation in San Mateo for years, especially during the planning and construction of the new 92/82 interchange. Lots of space there for panels. It’s getting easier, cheaper and more necessary all the time.

Every new building should have solar panels on its roof.

Thank you,
Susan Shankle
30‐year San Mateo resident
Lifetime Bay Area resident
Citizen, Taxpayer and Voter

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1 Nicholas "Nicky" Vu
From: Housing
Sent: Tuesday, January 3, 2023 10:17 AM
To: Nicholas "Nicky" Vu; Eloiza Murillo-Garcia
Subject: FW: Online Form Submittal: Draft 2023-2031 Housing Element Comment Form Follow Up Flag: Follow up
Flag Status: Flagged

Sandra Belluomini
Administrative Tech| Housing
330 W. 20th Ave., San Mateo, CA 94403

From: [email protected] <[email protected]>
Sent: Saturday, December 31, 2022 11:19 AM
To: Housing <[email protected]>
Subject: Online Form Submittal: Draft 2023‐2031 Housing Element Comment Form

Draft 2023-2031 Housing Element Comment Form

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

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

First Name  Kailun
Last Name  Wu
Email Address
Comment on 2023‐2031
Draft Housing Element
Hi city staff, planning commissioners and council members,

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2 Happy New Year! I'm commenting as a homeowner in Hillsdale and am only representing my small family of three. My wife and I both live and work in San Mateo.

I want to first thank you for your hard work. This is a pivotal moment for current and future San Mateans. For decades our city has been built around driving and parking for literally everything in life, which unfortunately causes climate change, congestions, slow housing production and high cost of living. I believe that a more human-centric, not car-centric San Mateo is popular and achievable so this housing element is our chance to make real progress.

My comments on the housing elements:

1. Teamwork

I urge the newly elected city council to collaborate in good faith, debate and make compromises no matter which sides you're on. After the disastrous and widely publicized mayor
appointment in 2022, this is your moment to show teamwork, transparency and integrity. Use our shared core values when you disagree. Show us that you are fixing our housing crisis by completing a compliant housing element.

2. Zoning

Simplify zoning and improve objective standards. Legalize diverse and medium density buildings. Legalize small scale local shops, daycare, and other services in single family communities (Sunnybrae, North Central, the Village, Hillsdale) to reduce car trips. Allow more homes in downtown to increase home supply while minimizing car traffic because walking can get a lot more done in downtown. Develop empty lots in Bay Meadow and Event Center.

3. Circulation

Building thousands of new homes cannot be done without
traffic improvements. I know this is outside of the housing element but it is a chicken-egg problem. A city-wide,
continuous bike highway needs to be built to encourage more people to run errands, go to school and offices without driving.

Palm Ave, Delaware St are streets that could be a north-south bike highway. SF, Mountain View and many more examples
are there for us to copy. Allocate more money on e-bike rebate, bike paths and traffic calming features.

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3 Building homes unfortunately has become so contentious and expensive throughout California. My house is across the street from the Hillsdale Mall which is ripe for more housing/services.

I hope to see new homes, shops and neighbors replacing the lifeless and underutilized parking garage. I want more homes built not for profit but for my friends, coworkers and children to be able to stay without being severely burdened by mortgage or rent.

Inclusivity is one of the values of the City. $1.5M home prices are not inclusive. I really appreciate what you have done given the constraints and history of San Mateo. I believe you can do the right thing for us and the silent majority.

Thanks again!
Kailun

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1 Nicholas "Nicky" Vu
From: Housing
Sent: Tuesday, January 3, 2023 4:28 PM
To: Nicholas "Nicky" Vu; Eloiza Murillo-Garcia
Subject: FW: Housing Element

Sandra Belluomini
Administrative Technician Housing Dept
330 W 20
th Avenue, San Mateo, Ca 94403

Sandra Belluomini
City of San Mateo

From: Bill Williams
Sent: Tuesday, January 3, 2023 12:53 PM
To: Housing <[email protected]>
Subject: Housing Element

1. The Sewage Treatment Plant should be completed before additional construction is started.

2. Since the City of San Mateo has paid fines for untreated storm runoff into the Bay, the storm water overflow system should also be completed before additional construction is started.

3. Open Space calculations for developments should not include rooftops and balconies.

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1 Nicholas "Nicky" Vu
From:

Sent: Thursday, January 5, 2023 9:32 PM
To: Housing
Subject: housing
I am not really sure who really reads our comments and also assume you committee just trashes what you do not like to read I get it but here goes

my name is rick karr and was born in San Mateo Mills Hospital 72 yrs ago and bought my house at 39 1/2 years ago

Basically I understand you committee gets marching orders from the Board of Supervisors or the Govenor ,,,I am hoping you do not volunteer the number of increased housing to be 7000

Again I will state the infrastructure of San Mateo cannot accomodate a great deal of more building ..The traffic is bad The sewage system is overloaded and I can go on and on You have heard all the reasons why big population growth here in the confines of San Mateo is really almost impossible

No one is going to rip up train lines or destroy freeways to provide more housing space There is not a lot of open space left and I do not expect large landowners like the BOHANNON family to just provide a lot of land to the city so that being said I provide the folllowing solutions

HIP Housing and similar should submit a list of numbers of people who are placed each month and use those number to show that the city of SM has complied or is trying to comply,,,I have no idea The city can also publicize to home owners or similar the advantages to renting out a room for extra income,,,I realize many people may be afraid to take a stranger in the home and those apprehensions are realistic ,,,However volunteers fo assist and publicize HIP and similar organzations would be great as some decent types can rent a room or similar and the homeowners will have some extra money each month,,,I suggest that the HIP contact the nursing department at CSM as these students and others are ideal for elderly types who are still living at home,,,,I personally rented out my front bedroom to someone who was pals with a SM pal of mine and he works in Burlingame and has been here for five years now ,,,i also now have another SM person living in my back room ( tv sports room ) who has been here for three months now and maybe another four as he split up with his GF,,,What I am trying to say is that the city and volunteers can assist others like HIP to find people and then those numbers can be tallied ,,

we do not have the space or ability to build say 5000 houses in the city of San Mateo. Yes there are places like FRESNO or MODESTO that have a lot of land but San Mateo does not

I highly suggest you counter this absurd high figure of say 7000 and have it reduced and also delayed The recapture of people provided housing like I mentioned above should be seriously mentioned to these GOV HACKS who dictate these absurd numbers...Those people who do build duplexes or fourplexes are helpful of course ...

I do not consider this issue to be a Republican or DEMOCRATIC party issue ,,,,it is a common sense issue for us the tax payers of San Mateo and residents and unfortunately I have no trust in the ability or courage of these elected or appointed people to stand up for us

please respond to my comments
You need to solicit others for great ideas and not wait for the elected types to dictate to us ..

We have a 55 foot height limit that was voted in and cannot be changed by one hack using a pen,,,that is what is done in RUSSIA or North Korea or CHINA (PRC) or CUBA

Rick Karr

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1 Nicholas "Nicky" Vu
From: Housing
Sent: Friday, January 6, 2023 3:26 PM
To: Nicholas "Nicky" Vu
Subject: FW: Housing Element

Sandra Belluomini
Administrative Technician Housing Dept
330 W 20th Avenue, San Mateo, Ca 94403
650‐522‐7239
[email protected]

Sandra Belluomini
City of San Mateo
p‐650‐522‐7239
f‐ 650‐522‐7221

‐‐‐‐‐Original Message‐‐‐‐‐
From: David Eligator
Sent: Friday, January 6, 2023 1:37 PM
To: Housing <[email protected]>
Subject: Housing Element

Dear Mayor Lee, Councilmembers and Commissioners:

I own and live at  . in North Central (at Delaware), a beautiful 1913 Victorian that I have been renovating myself from decades of neglect.  I invite you to stop by and see it.

I took a day off and read the most recent draft Housing Element.  I commend those who drafted it.  My comments are specific to North Central, where you’ll find me picking up litter or walking with my dog Susie.

North Central screams with unmet potential.  Its location next to downtown is fantastic.  It suffers from past redlining, a too‐high percentage of renters, and concentrated poverty.  By allowing investment, development and growth, North Central could blossom and become one of the truly great walkable neighborhoods in the San Francisco Bay Area.

The housing element acknowledges the damage done by North Central’s former redlined status.  The City can and should remedy by allowing significant new development in North Central to replace our obsolete housing stock and create vibrant neighborhood commercial areas.  Even with the 55ft height limit there is potential to build interesting,

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2 stylish, ornate and even iconic buildings with visual architectural appeal, which provide both public and private benefit and serve far more than mundane utilitarian function.  Architectural beauty is key.  Let’s build while at the same time keeping North Central free of huge, streetlife‐deadening projects and bland five‐over‐one boxes (which the 55‐foot limit unfortunately encourages).  Let’s harness the market to encourage investment in North Central and allow people to build! We want more neighborhood commercial areas, taquerias, cafes, art galleries, music venues, corner stores and commercial gathering places.  Please empower mom‐and ‐pop builders and emphasize small scale developments, many small footprint projects, which create a charming, diverse, varied and interesting urban fabric.  And more gardens and trees throughout North Central, please!

The housing element rightly focuses attention on AFFH and social issues affecting low‐income and other vulnerable residents.  For North Central, the way to address this is to invite wealth and economic growth in.  While the housing market remains strong, the City can use market forces to reshape North Central in a bold and transformative way so as to make it a more dynamic and truly diverse place and not an island of disenfranchisement and poverty.  Look to other cities’ models of desirable neighborhoods that truly work. Jane Jacobs’ Death and Life of Great American Cities discusses what physical spaces actually work for and feel good to human beings.  North Central needs well‐constructed, well‐ designed, architecturally‐pleasing housing of all types, not mere utilitarian, uninspired buildings withiut aspiration, style, design, craftsmanship, ornament, or redeeming aesthetic qualities.  (Who would want to live in a shoebox?)

Especially for North Central, the
housing element provides an exciting opportunity for bold action. Why not use principles of New Urbanism to make North Central a truly diverse, leafy, walkable and desirable neighborhood with flats, townhouses, and a high percentage of owner‐occupants  (which create strong communities, prevent blight and permit people and and families to build equity and long‐term economic strength)?  North Central will greatly benefit from having more stakeholders with long‐ term economic self‐interest.

To make an omelet one must break some eggs.  Let’s not think small when it comes to North Central! North Central has all the ingredients of becoming a stunning, spectacular, highly desirable neighborhood that transcends its redlined past, for the benefit of all.   Let’s not be timid or cling to mediocre visions from the past.

David Eligator

North Central

Sent from my iPhone

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1 Nicholas "Nicky" Vu
From: Housing
Sent: Friday, January 6, 2023 3:26 PM
To: Nicholas "Nicky" Vu
Subject: FW: Housing Element

Sandra Belluomini
Administrative Technician Housing Dept
330 W 20
th Avenue, San Mateo, Ca 94403
650‐522‐7239
[email protected]

Sandra Belluomini
City of San Mateo
p-650-522-7239
f- 650-522-7221

From: Skye Nygaard
Sent: Friday, January 6, 2023 1:59 PM
To: Housing <[email protected]>
Subject: Housing Element

Hello,

After reading through the new draft housing element, I am overall quite happy with the changes and how they address the needs of the community.

However, I have some points of concern.

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2 On page H‐31, there is reference to "physical constraints" limiting the development of smaller lots. Rather, it is zoning regulations, such as setbacks, that are the constraining factor. I would hardly call a law "physical". I would prefer the wording to reflect that it is a result of current policy rather than some universal rule that you can't develop as much on smaller sites.

I appreciate the inclusion of SROs in the latest update. However, it is not a big change. Simply being more specific about where SROs can be built does not get them built. SROs tend to have unit sizes in the range of 100‐200 sq ft. 1 acre = 43560 sq ft. At just 1 story, you could fit upwards of 200 SRO units. When we have a limit of 50 units per acre, no SROs are going to be built. It is a subpar use of limited unit counts. I would like some mention of this constraint to be included in the housing element, to reflect the reason SROs are not being built.

I appreciated the mention of putting adjustments to measure Y on the ballot, on page H‐41. However, I would like it mentioned where measure Y conflicts with state law. Density bonus and state law supersede measure Y already in several conditions, and there was no mention of this in the housing element (at least that I found).

The phrase "a variety of housing" was mentioned on page H‐23 and several other locations. On H‐23, it was then listed the breakdown of single‐family vs 2‐4 unit multifamily, vs > 4‐unit multifamily. This leads to the implication that the variety of housing merely comes down to single‐family vs multi‐family, as well as the price point. However, I think there are other very large variety factors. These include the number of lots, rather than units, and the location of those lots.

While single‐family homes are spread throughout the city, multi‐family dwellings are concentrated in just a few locations. As a renter, there are many places in the city where I cannot find a rental available. Therefore, the diversity of locations for multi‐family is severely limited, due to the much smaller number of lots available with this zoning. I would like this location diversity to be explicitly mentioned, as it is something I have personally dealt with.

Best,
Skye Nygaard, a San Mateo Resident

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1 Nicholas "Nicky" Vu
From: Mayhew, Tom (22) x4948
Sent: Saturday, January 7, 2023 4:39 PM
To: Housing
Cc: Planning Commission; City Council (San Mateo); Higley, CJ (25) x4942 Subject: Housing Element - Comments of Housing Action Coalition Attachments: 2023-01-07 Housing Action Coalition - Second Round Comments on San Mateo Draft Housing Element(15225917.pdf; Housing Element
Please see two attachments:

1. The January 7, 2023 letter on behalf of Housing Action Coalition, commenting on the draft December 2022 Housing Element.

2. An earlier email and attachments sent on behalf of Housing Action Coalition on December 16, 2022.  This email and its attachments are being re‐sent because it was not included in Appendix F (Public Participation) and we wanted to make sure that you have it.

Please include our comments in the packet for the Planning Commission meeting for January 10, 2023 and City Council meeting (date TBD) concerning the adoption of the Housing Element.

Thank you,
Tom Mayhew
CJ Higley

Thomas B. Mayhew
Partner

San Francisco, CA 94104
www.fbm.com

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THOMAS B. MAYHEW

CHARLES J. HIGLEY

January 7, 2023
Via E-Mail
Housing Manager
City of San Mateo
Planning Division
330 W. 20th Avenue
San Mateo, California 94403
E-Mail: [email protected]
Re: Draft Housing Element for City of San Mateo 2023-2031 Comments of Housing Action Coalition
Dear Housing Manager, Planning Commission, and City Council:

On behalf of the Housing Action Coalition,1 we write to further comment on the draft 2023-2031 Housing Element for the City of San Mateo, including changes in the December 2022 draft. The draft Housing Element still does not meet the City’s obligation to plan and provide for affordable housing. Absent substantial revisions, it may be found in violation of state law.

Below, we identify two significant issues to be addressed as San Mateo continues to work on formulating an acceptable Housing Element. First, San Mateo has included a number of sites that do not have a realistic likelihood of becoming housing during the next eight years, as required to meet the need for new housing. The inventory includes a major shopping center and a regional mall and claims that these are housing sites that will redevelop in the next eight years, despite busy stores, new long-term leases, and even multimillion dollar improvements that conclusively demonstrate that the current retail uses will continue. Second, San Mateo’s methodology for identifying how much of the regional need will be met by the sites on the inventory appears both unprincipled and inconsistently applied. In order to properly evaluate whether the site inventory will meet the needs of San Mateo’s anticipated population growth, San Mateo needs to formulate a proper methodology and then apply it consistently, and explain how it evaluates site-specific information, other potential uses of the property, and market evidence on what is likely to actually be built.
1 The Housing Action Coalition is a nonprofit that advocates for building more homes at all levels of affordability to alleviate the Bay Area and California’s housing shortage, displacement, and affordability crisis.

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Housing Element
January 7, 2023